ML050110118
| ML050110118 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/03/2005 |
| From: | Kacich R Yankee Atomic Electric Co |
| To: | Document Control Desk, NRC/FSME |
| References | |
| BYR 2005-001 | |
| Download: ML050110118 (14) | |
Text
YANKEE ATOMIC ELECTRIC COMPANY Telephone (413) 424-5261 PGj> 49 Yankee Road, Rowe, Massachusetts 01367 January 3, 2005 BYR 2005-001 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001
Reference:
(a) License No. DPR-3 (Docket No. 50-29)
Subject:
Letter of Intent Concerning the Release of Yankee Nuclear Power Station Site Property from the Part 50 License This letter provides written notification to the Nuclear Regulatory Commission (NRC) of Yankee Atomic Electric Company's (YAEC's) intent to release a portion of the Yankee Nuclear Power Station (YNPS) site from its 10 CFR Part 50 License (DPR-3).
Specifically, YAEC intends to release approximately 2170 acres of the non- impacted area from its Part 50 License.
Figure 1 depicts the site property boundary. The land area proposed for release consists of the land within the site boundary less the non-impacted land area (see Figure 2) and is referred to hereafter as the "Release Area." For operation of the ISFSI, YAEC will retain control of a rectangular areal encompassing the 300-meter owner controlled area around the ISFSI.
In accordance with Section 1.5 of the YNPS License Termination Plan (LTP), YAEC has reviewed and assessed the subject "Release Area" to ensure that this proposed action will have no adverse impact on the ability of the site in the aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release. It is noted that the Attachment does not contain the Final Status Survey (FSS) report for the area because this area is characterized as non-impacted and does not require an FSS.
Additionally, during the week of November 14, 2004, NRC inspectors and NRC's contractor, ORISE, performed independent radiological surveys of the "Release Area" and the borders of the adjacent Class 3 areas. No radiological material above background was found in the non-impacted area. The results of soil area surface scans and soil samples will be documented in an ORISE report issued to the NRC. A summary of this inspection activity will be documented in a future NRC integrated inspection report.
lThe retained YAEC controlled property (-87.5 acres) will include the ISFSI site (8,443 ft2), fenced property around the ISFSI, and land area associated with the 300-meter owner controlled area (OCA).
The area is bounded by USGen property (Sherman Reservoir, Dam & Extension, and Power House) to the north and east and the wooded boundary associated with the 300-meter OCA to the west and south.
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USNRC Document Control Desk BYR 2005-001, Page 2 We request that the NRC review and concur with the acceptability of the release of the subject land from the YNPS Part 50 license by April 30, 2005. Although the LTP is still under review by the NRC Staff, we expect it to be approved by the requested date. The Attachment contains a summary of the assessment performed.
If you should have any questions regarding this submittal, please contact Mr. G. P. van Noordennen, Regulatory Affairs Manager at (860) 267-3938.
Sincerely, YANKEE ATOMIC ELECTRIC COMPANY Richard M. Kacich President
Attachment:
YNPS Release Report for the Non-Impacted Land cc: S. Collins, NRC Region 1 Administrator R. R. Bellamy, Chief, Decommissioning and Laboratory Branch, NRC Region 1 J. Hickman, NRC Project Manager D. Howland, Regional Engineer, MA DEP R. Walker, Director, MA DPH M. Rosenstein, US Environmental Protection Agency, Region 1 W. Perlman, Executive Committee Chair, FRCOG T. W. Hutcheson, Chair, Franklin Regional Planning Board L. Dunlavy, Executive Director, FRCOG P. Sloan, Director of Planning & Development, FRCOG D. Katz, CAN
BYR 2005-001 Docket No. 50-29 Attachment Yankee Nuclear Power Station Release Report for the Non-Impacted Land January 2005
Release Report for the Non-Impacted Land Backeround:
The Yankee Nuclear Power Station (YNPS) is located at 49 Yankee Road, Rowe, in Franklin County, Massachusetts. Yankee Atomic Electric Company (YAEC) is the license holder for YNPS. The plant site contains approximately 2200 acres, of which approximately 10 acres were developed for plant use.
The site is at the bottom of a deep valley-along the Deerfield River (elevation 1022') at the southeast corner of Sherman Reservoir (also referred to as Sherman Pond). The area surrounding the site is mostly wooded with very steep slopes on both sides of the Deerfield River. The hills on either side of the site rise about 1000 feet above the river and extend from 12 miles north to 8 miles southeast of the site. Sherman Reservoir served as the source of cooling water for the plant.
All of the land located within the licensed site property boundary (see Figure 1)is owned by either YAEC or USGen New England, Inc. (referred hereafter as "USGen"). All of the property within the exclusion area is under the control of YAEC. Of the 2200 acres, YAEC owns approximately 1870 acres. The remaining land is owned by USGen. The USGen property is associated with the Deerfield River Project and is generally located along the riverbank and Sherman Reservoir. The portions of the YAEC industrial area located on USGen property are the circulating water discharge seal pit, the Screenwell Pump House, and the meteorological tower located on a peninsula at the northeast comer of the site. USGen also owns that portion of the northeast yard area that fronts Sherman Reservoir and the property outside of the industrial area fence located between Yankee Road and the Deerfield River. A portion of the USGen property is considered impacted by licensed activities and is included in license termination activities. The boundaries of survey areas have been drawn along the property lines for convenience. The current nearest resident is located approximately 0.8 miles from the plant site.
YNPS achieved initial criticality in 1960 and began commercial operations in 1961. The nuclear steam supply system was a four-loop pressurized water reactor designed by Westinghouse Electric Corporation. The original thermal power design limit of 485 MWt was upgraded to 600 MWt in 1963. The turbine generator, also designed by Westinghouse, was rated to produce 185 MWe.
On February 26, 1992, a decision by the Yankee Atomic Electric Company (YAEC)
Board of Directors was made to permanently cease power operations at YNPS. This decision was based upon the following two factors:
- 1. Economic analyses indicated that shutdown of the plant before expiration of the NRC operating license in July 2000 could produce a substantial savings to the electricity producers.
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- 2. Significant regulatory uncertainty existed concerning the timing and cost of completion of the NRC's review of the integrity of the YNPS Reactor Pressure Vessel.
On August 5, 1992, the NRC amended the YNPS Facility Operating License to a possession only status.
The YNPS Decommissioning Plan was submitted March 29, 1994, and received final approval in October 28, 1996. In May 1997, Yankee submitted to the NRC for approval a License Termination Plan (LTP) for YNPS, pursuant to 10CFR50.82(a)(9). The initial YNPS LTP employed a survey methodology based upon the "Manual for Conducting Radiological Surveys in Support of License Termination," also referred to as the Draft NUREG/CR-5849 methodology. Subsequently the NRC, jointly with the DOD, DOE, and EPA, approved an alternate survey methodology documented in MARSSIM ("Multi-Agency Radiation Survey and Site Investigation Manual" or NUREG-1575). In May 1999, Yankee advised the NRC that it intended to shift from the survey methodology in NUREG/CR-5849 to the MARSSIM methodology, and withdrew its previously submitted LTP application. The current LTP, submitted in November 20032, is written to reflect the MARSSIM methodology, as well as appropriate regulatory guidance made available since the previous LTP submittal.
In 2000, Yankee created a Post-Shutdown Decommissioning Activities Report (PSDAR) within the Final Safety Analysis Report (FSAR). NRC Draft Regulatory Guide DG-1071 recommends that licensees with approved Decommissioning Plans "extract pertinent detail from the decommissioning plan and submit a PSDAR update in the format and content specified by [DG-107 1]."
Purpose:
The purpose of this report is to inform the NRC of YAEC's intent to remove a portion of the land from the Part 50 License. Specifically, YAEC intends to remove/release the non-impacted land area (approximately 2170 acres) from its Part 50 License. In accordance with Section 1.5 of the YNPS LTP, YAEC has reviewed and assessed the "Release Area" to ensure that the proposed action will have no adverse impact on the ability of the site in aggregate to meet 10 CFR Part 20, Subpart E, criteria for unrestricted release. This Report contains a summary of the assessment performed. It is noted that this Report does not contain the Final Status Survey (FSS) report because the "Release Area" is characterized as non-impacted.
2YAEC Letter to USNRC, "Submittal of YNPS's License Termination Plan and Proposed Revision to Possession Only License," dated November 24, 2003, BYR 2003-080.
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Site Historv (Related to "Release Area")
The Yankee Nuclear Power Station Historical Site Assessment Report 3 has classified this "Release Area" as non-impacted (see Figure 2). As documented in this report and supported by technical evaluations, the "Release Area" classification as non-impacted is based upon historical photographs, results of REMP surveys, particulate gaseous effluent deposition modeling and statistical analysis of Cs-137 soil concentrations relative to a set of background reference areas.
This area consists of approximately 2170 acres of uninhabited, wooded and undeveloped land. The majority of the land surrounding the industrial area of the site is classified as non-impacted according to MARSSIM criteria. The non-impacted land surrounds the industrial area and all other routinely utilized areas. The non-impacted area is bounded on the east and south by Monroe State Forest, on the southeast by USGen property, on the west by Readsboro Road (with the exception of an 89-acre plot on Kingsley Hill Road),
and on the north by the Massachusetts/Vermont state line. The non-impacted area was not involved in plant operations and consists mostly of rugged terrain which is forested and undisturbed. Power lines traverse the area in a northeast by east direction (see Figure 2).
The general site is shown on USGS map Rowe, Massachusetts-Vermont.
Access to the interior of the land is limited to abandoned or seldom used logging paths and trails, and the power transmission clearing. Walk-downs and visual inspection of the "Release Area" indicate that the land was not used to store YNPS materials. There are no identified soil disturbances that would indicate dumping or burial of materials.
Historical data indicate that plant operations had no impact on the "Release Area" based on the following:
- Samples collected as part of the Radiological Environmental Monitoring Program (REMP) throughout the plant's operational and post-operational history show no evidence of any radiological impact due to plant operations;
. Aerial photographs from 1966, 1970, 1974, 1980, 1981, 1982, 1989, and 1990 show no evidence of soil disturbance;
- A conservative evaluation of the potential impact of particulate effluents to soils outside of the industrial area using a Gaussian dispersion/deposition model substantiates the conclusion that this source of plant-derived radioactive material would be expected to contribute (at a maximum) a very small fraction of the DCGL.
Beyond the impacted area boundary, concentrations of this plant-derived radioactive material are shown to be undetectable and indistinguishable from background; 3
YAEC Letter to USNRC, "Submittal of Revision I of the Historical Site Assessment for YNPS," dated September 30, 2004, BYR 2004-113.
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- A statistical comparison of soil sample analytical data from the non-impacted area and an environmentally equivalent reference area (unaffected by plant releases) was performed.
Radiological environmental monitoring and sampling is performed in the "Release Area" in accordance with the REMP and Off-site Dose Calculation Manual (ODCM).
Radiological analyses have been performed with gamma exposure measuring devices, on samples for radionuclide airborne particulates and for reactor produced iodine, and on broad leaf vegetation.
The YNPS Annual Radiological Environmental Operating Reports show no long-lived radionuclides other than Sr-90 and Cs-137 above the Minimum Detection Level (MDL).
Sr-90 and Cs-137 are measured at levels consistent with those found throughout the western Massachusetts area and are attributed to past atmospheric nuclear weapons testing. The results are included in the YNPS Annual Radiological Environmental Operating Report and the past results support the classification of the "Release Area" as a non-impacted area.
2.0 Impact of Release of the Area 2.1 Statement of Dismantling Activities No dismantlement activities are required in the "Release Area" for YAEC to release this area (as the only structures in the survey area are associated with the Massachusetts Electric/USGen transmission line supports which will continue to operate). Since the subject area is non-impacted, there is no need for a Final Status Survey.
2.2 Potential for Cross-Contamination from Subsequent Activities The "Release Area" is bounded on the east and south by Monroe State Forest, on the southeast by USGen property, on the west by Readsboro Road (with the exception of an 89-acre plot on Kingsley Hill Road), and on the north by the Massachusetts/Vermont state line. Figure 2 also shows the MARSSIM Class 3 survey areas which also bound the "Release Area." Final Status Surveys have been performed of these Class 3 areas (see Figure 3) that will not be impacted by plant demolition activities and the results of the surveys show no evidence of detectable plant-related radioactivity. The results of confirmatory surveys conducted by ORISE will be available shortly.
The YNPS LTP Section 5.4.5.2 describes isolation and control measures that are used to protect areas where FSS is being performed or has been completed. These isolation and control measures are implemented through approved procedures and will remain in force until there is no undue risk of recontamination from decommissioning activities. In the event that isolation and control measures established for these survey areas are compromised, evaluations will be performed and documented to confirm that no radioactive material was introduced into the area that would affect the results of the FSS.
Given the isolation and control measures established for these FSS areas adjacent to 4
"Release Area," it is highly unlikely that radioactive materials could be introduced into the "Release Area" via these borders.
The YNPS Historical Site Assessment and site characterization efforts indicate that the "Release Area" has not been impacted by the release of radioactive material during plant operations. Since the commencement of decommissioning, more restrictive controls have been placed on the release of material from radiological controlled areas and the industrial area which further decreases the probability that the "Release Area" will be impacted from decommissioning activities. These controls include contamination containment, dust control measures, storm water runoff control measures, building demolition controls, and additional evaluations and surveys of material leaving the industrial area. These stringent radiation protection program requirements for decommissioning activities, as well as the additional protections afforded from FSS isolation and control measures, provide strong assurance that the potential for cross-contamination of the "Release Area" is de minimis.
2.3 Impact of Releasing the Specific Area on Part 50 License Basis The license basis for the YNPS includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities. Throughout decommissioning, these programs are modified as necessary and terminated when the applicable concern is no longer relevant. These program changes are implemented using the change processes specified for each type of program. The phased release approach is described in Section 1.5 of the YNPS LTP. The methodology for releasing land requires a review and assessment of the impact on license programs for the site lands remaining within the domain of the Part 50 License. The impact of releasing the "Release Area" from the Part 50 License on each of the licensing programs included in Section 1.5 of the LTP is described below. With this submittal, YAEC is requesting NRC review and concurrence of the changes described herein.
2.3.1 Technical Specifications The YNPS Technical Specifications are not impacted by the release of the "Release Area," a non-impacted area.
2.3.2 Final Safety Analysis Report (FSAR) and Environmental Report The Updated Final Safety Analysis Report (June 2003) will require minor changes to Section 300, Figure 300-1, "Site Boundary and Exclusion Area" to show the reduced site area resulting from the removal of the "Release Area" from the Part 50 License and to identify the new site boundary on Figure 300-1. The YNPS Environmental Report is not impacted by the release of the "Release Area."
2.3.3 Defueled Emergency Plan This Plan will not be affected by the release of the "Release Area."
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2.3.4 ISFSI Security Plan This plan will not be affected by the release of the "Release Area."
2.3.5 Off-site Dose Calculation Manual (ODCM)
The ODCM will be revised, as necessary, consistent with the alteration of the site boundary on which the offsite dose calculation X/Qs are based.
2.3.6 Environmental Monitoring Program The Environmental Monitoring Program will not be affected by release of the "Release Area."
2.3.7 Ground Water Monitoring Program The Ground Water Monitoring Program will not be affected by release of the "Release Area." There are no ground water monitoring wells in or near the "Release Area." All of the existing monitoring wells are down gradient of the "Release Area" with the nearest well being along the Wheeler Brook Divertment, approximately 250 feet from the boundary of the "Release Area." As discussed in Section 1.0 above, there is no information to suggest that "Release Area" has been impacted by plant operation. Being that the area is up gradient and a considerable distance from areas of known groundwater contamination, there is no need to place groundwater wells in the "Release Area."
Therefore, there is no need to perform a capture zone analysis and there is no need to add a ground water contribution in the "Release Area."
3.8 Fire Protection Program This program will not be affected by the release of the "Release Area."
2.3.9 Training Program The training program for the ISFSI Operations/Security personnel will not be affected by the release of the "Release Area."
2.3.10 Post Shutdown Decommissioning Activities Report (PSDAR)
The release of the "Release Area" will not impact the YNPS PSDAR (as of June 2003) which is contained in the FSAR.
2.3.11 License Termination Plan (LTP)
A minor revision to the YNPS LTP will be made to describe the reduced site area resulting from the release of the "Release Area."
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2.4 Additional Areas to be Addressed to Support the Release of the Area The exclusion area (owner controlled area or OCA) for the YNPS is equivalent to the area within a 300 meter radius around the ISFSI, as shown on Figure 2. YAEC will continue to maintain authority over all activities conducted within 300 meters of the ISFSI until such time as the spent fuel is removed from the site.
YAEC will maintain the following records through license termination: 1) a map of the site identifying the facility and site as defined in the original license; 2) a record of the "Release Area" released under this action; and 3) documentation of the radiological conditions of the lands released under this action.
2.5 Site-Release Criteria The site release criteria for the YNPS site correspond to the 10 CFR 20.1402 criteria for unrestricted use. The residual radioactivity, including that from ground water sources, that is distinguishable from background, must not cause the total effective dose equivalent (TEDE) to an average member of the critical group to exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels that are ALARA.
Non-impacted areas are defined in NUREG-1575 (MARSSIM) as areas that "have no reasonable potential for residual contamination, no radiological impact from site operations and are typically identified during the Historical Site Assessment." To date, YAEC has found no evidence of using, storing, or burying radioactive material in the subject area (the "Release Area"). None of the event records in the Historical Site Assessment indicate the uncontrolled release of radioactive material to the "Release Area." Therefore, it can be concluded that the release of the subject area (a non-impacted area) will have no adverse impact on the ability of the YNPS site in the aggregate to meet the Part 20, Subpart E, for unrestricted release. As discussed in the prior section on the Groundwater Monitoring Program, there are no groundwater monitoring wells within or near the "Release Area." The results of the Groundwater Monitoring Program to date indicate that there is no reasonable potential for contamination conveyed by groundwater to impact the "Release Area."
2.6 Final Status Survey The YNPS LTP Section 5.2 states the Final Status Survey Plan encompasses the radiological assessment of all affected structures, systems and land areas for the purpose of quantifying the concentrations of any residual activity that exists following all decontamination activities. A Final Status Survey was not performed in the "Release Area" since the area is classified as non-impacted, or unaffected. The YNPS LTP Section 2.5 provides the justification for this classification.
MARSSIM Section 3.6 suggests evaluating historical analytical data along with utilizing process knowledge to support the hypothesis that no radioactive materials have been 7
released to a specific portion of a facility. If process knowledge suggests that no residual contamination should be present and the historical analytical data also suggests that no residual contamination is present, this would support a non-impacted classification. As described in Section 1.0 of this report, a walk-down and visual inspection of the "Release Area" was performed. Results of past environmental sampling and monitoring performed in accordance with the REMP and ODCM both suggest that no residual contamination in excess of natural background and fallout levels is present in the "Release Area" and therefore, the non-impacted classification is justified.
MARSSIM Section 2.5.2 states, "Non-impacted areas represent areas where all of the information necessary to demonstrate compliance is available from existing sources. For these areas, no statistical tests are considered necessary." Additionally, Table 2.2 of MARSSIM, "Recommended Conditions for Demonstrating Compliance Based on Survey Unit Classification for a Final Status Survey", requires no elevated measurement comparison, no sampling and/or direct measurements and no scanning to be performed in non-impacted areas.
2.7 Conclusion The release of the "Release Area" is part of YAEC's overall effort to terminate license DPR-3 and to achieve unrestricted release of the entire site in accordance with the criteria in Subpart E of 10 CFR 20. This action is also consistent with the approach described in Section 1.5 of the YNPS LTP.
In addition, 10 CFR 50.82(a)(l 1) establishes the criteria to be used by the NRC for terminating the license of a power reactor facility. These criteria include (1) dismantlement has been performed in accordance with the approved license termination plan and, (2) the final radiation survey and associated documentation demonstrate that the facility and site have met the criteria for decommissioning in 10 CFR 20, Subpart E.
Although no dismantling activities or a FSS are required for the "Release Area," the release of the "Release Area" supports the process of license termination by demonstrating that this portion of the site land can be released from YNPS license. This report, along with future reports, provides documentation that demolition activities have been performed in accordance with the LTP and the final status survey confirms the residual radioactivity in each survey unit meets the criteria established in the LTP. Thus, this action of the release of the subject land supports the overall license termination process in accordance with NRC regulations.
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Figure 1:
Yankee Nuclear Power Station Site Property Boundary (- 2200 Acres)
Legend CD Boundary of Limensed Area EO00ngYAEC PropertyBoundary(1,S70Aeal)
US Gen Property Reservokr6 River Eesemnent
- State BoundaryLine Non-ProjoetRored.
0 425 050 1,700 2050 Feet Map Numberrro.0O351 December 22, 2004
(, . IL c-o1r"
Figure 2:
wo Yankee Nuclear Power Station Release Area (-2170 Acres)
Legend I En.en.ne
--- Exisng YAECPropertyBoundary
= Reease Area
=I] Reseto &River
_ Ro.d.
ParidngLot NRC Class Areas
_ ofts 1
_ rlas 2 L C4e. 3 0 100 200 400 600 Feet MopNumber roweO37&
December 22, 2004
- CLF Co)2-