ML050870401

Final Status Survey, Final Report Phase II, Haddam Neck Plant, Book 1 of 16

ML050870401
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/18/2005
From:	Keyes C, Wager J Connecticut Yankee Atomic Power Co
To:	NRC/FSME
References
CY-05-040
Download: ML050870401 (60)

Text

-I I e I-I l s ---:;-, i --S !~ : --,s ~Final Status Survey Final Report Phase 1l Connecticut Yankee Atomic Power Company Haddam Neck Plant V.STO~t Haddam, Connecticut 4 February 2005 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Report -Phase II February 2005 Prepared By: k- FSS Engineer Date: i Reviewed By: k FnginotB Date: I Approved By: Date:.._ b _

Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase 1. February 2005 TABLE OF CONTENTS 1.0 Introduction

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4 1.1 Executive Summary .....................................

4 1.2 Phased Submittal Approach .....................................

7 2.0 Final Status Survey Program Overview ...............................

10 2.1 Survey Planning .12 2.2 Survey Design .16 2.3 Survey Implementation

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19 2.4 Survey Data Assessment

.20 2.5 Quality Assurance and Quality Control Measures .21 3.0 Site Information

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23 3.1 Site Description

.23 3.2 Survey Area/Unit Description

.24 3.3 Summary of Historical Radiological Data .26 3.4 Conditions at the Time of Final Status Survey .30 3.5 Identification of Potential Contaminants

.31 3.6 Radiological Release Criteria .33 4.0 Final Status Survey Protocol .......................

33 4.1 Data Quality Objectives

.33 4.2 Survey Unit Designation and Classification

.40 4.3 Background Determination

.41 4.4 Final Status Survey Plans .41 4.5 Survey Design .42 4.6 Instrumentation

.43 4.7 Survey Methodology

.47 4.8 Quality Control Surveys .49 5.0 Survey Findings .............

49 5.1 Survey Data Conversion

.50 5.2 Survey Data Verification and Validation

.51 5.3 Evaluation of Number of Sample/Measurement Locations in Survey Units 52 5.4 Comparison of Findings with Derived Concentration Guideline Levels 53 5.5 USNRC/Independent Verification Team Findings .54 6.0 Summary .......... 54 7.0 References

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55 8.0 Appendices

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59 Connecticut Yankee Atomic Power Company Haddam Neck P~lant Final Status Survey Final Report -Phase H February 2005 LIST OF TABLES 1-1 Phase II Survey Unit Classification and Description List 5 2-1 Derived Concentration Guideline Levels for Land Area FSS 14 2-2 FSS Area Classifications 16 2-3 Easy-To-Detect and Hard-To-Detect Radionuclides 17 3-1 Basic Statistical Quantities of 9531-0001 Characterization Samples 30 3-2 Statistical Quantities of Post-Remediation Samples from 9535-0001 31 4-1 Number of Surface Samples for FSS 43 4-2 SPA-3 Technical Details 44 4-3 Action Levels and Associated Background Counts per Minute 46 4-4 Scan Coverage 48 4-5 Summary of Total Area Scanned 48 5-1 Summary of Statistical Analysis 52 5-2 IVT Confirmatory Survey 55 LIST OF FIGURES 1-1 Phase II Survey Unit Locations 6 1-2 FSS Final Report Phased Submittal Areas 9 2-1 FSS Organizational Chart 11 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005

1.0 INTRODUCTION

1.1 Executive Summary The purpose of this Phase II Final Status Survey (FSS) Final Report is to provide a summary of the survey results and the overall conclusions, which demonstrate that the Connecticut Yankee Atomic Power Company's (CYAPCO) Haddam Neck Plant (HNP) site, or portions of the site, meets the CYAPCO established 10 mrem/yr Administrative Level Derived Concentration Guideline Levels (DCGL) for soils. The Final Status Survey results provided herein address the dose component due to soil as provided in the License Termination Plan (LTP) compliance Equation 5-1. The second component of Equation 5-1, dose contribution due to groundwater radiological contamination, for this phase of the submittal, is addressed in Health Physics Technical Support Document (TSD) CY-HP-0193, "Assessment of Existing Groundwater Dose for Phase II Release Areas of the Final Status Survey Report" (Reference 7.1). The dose contribution from the third component of Equation 5-1,"future groundwater," is zero since there are no structures containing residual radioactivity for the survey areas submitted in this Phase II report.This report also documents that the FSS activities were performed consistent with the guidance provided in the Haddam Neck Plant License Termination Plan (Reference 7.2), NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual " (MARSSIM) (Reference 7.3), CYAPCO program document ISC-GQP-00001-003, "Final Status Survey Quality Assurance Plan" (Reference 7.4), CYAPCO Procedure RPM 5.1-00, "Final Status Survey Program" (Reference 7.5), as well as various station implementing procedures.

This FSS Final Report has been written consistent with the guidance provided in NUREG-1757, Vol. 2, "Consolidated NMSS Decommissioning Guidance-Characterization, Survey, and Determination of Radiological Criteria"' (Reference 7.6), MARSSIM, and the requirements specified in Procedure RPM 5.1-22, "Preparation of Final Status Survey Reports " (Reference 7.7).To facilitate the data management process, as well as overall project management, FSS Final Reports will usually incorporate multiple Survey Unit Release Records. Survey Unit Release Records are complete and unambiguous records of the as-left radiological status of specific survey units. Sufficient data and information are provided in each Survey Unit Release Record to enable an independent re-creation and evaluation at some future time of both the survey activities and the derived results.This Phase II FSS Final Report specifically addresses fourteen (14) land area survey units and one (1) subsurface soil survey unit within the east 4 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 mountainous and lowland survey areas of the HNP site that total approximately 313 surface acres in size. This report contains a compilation of all fifteen (15) Survey Unit Release Records that are within the Phase II scope. Table 1-1 provides a listing of all survey units addressed in this report including the classification and general description for each. Figure 1-1 depicts the locations of the survey units in relation to the HNP site as well as survey unit boundaries.

All final status survey activities essential to data quality have been implemented and performed under approved procedures.

Trained individuals, using properly calibrated instruments and laboratory equipment that are sensitive to the suspected contaminants, performed the Final Status Survey of the Phase II survey units. The survey data for all Phase II survey units demonstrate that the dose from residual radioactivity is less than the maximum annual dose criterion for license termination for unrestricted use specified in Title 10CFR20.1402 and support release of these areas from the IOCFR50 license. The additional requirement of 10CFR20.1402 that residual radioactivity be reduced to levels that is As Low As Reasonably Achievable (ALARA) has been satisfied.

Table 1-1 Phase II Survey Unit Classification and Description List Survey Survey Class General Description of the Survey Unit Area Unit (see Section 3.2 for a more detailed description) 9523 0000 3 Southeast Wetland Area; land area (151,364 mi 2)9524 0000 3 South Site Grounds; land area (61,975 M 2)9525 0000 3 Southeast Site Road; land area (28,000 in 2)9526 0000 3 Northeast Mountain Side; land area (444,700 in 2)9526 0001 2 Northeast Mountain Side; land area (6,504 in 2)9526 0002 2 Northeast Mountain Side; land area (6,068 in 2)9528 0000 3 Southeast Mountain Side; land area (508,000 in 2)9528 0003 2 Southeast Mountain Side; land area (10,000 in 2)9528 0004 2 Southeast Mountain Side; land area (3,100 in 2)9535 0001 1 Southeast LandfillArea; land area (1,860 in 2)9535 0002 2 Southeast Landfill Area; land area (3,320 mi 2)9536 0000 2 Constnrction Piles Near Rifle Range; land area (1,536 in 2)9537 0000 2 PernittedLandfillArea; land area (850 mi 2)9538 0000 2 Material Storage Area; land area (1,500 mi 2)9806 0000 A Southeast Landfill-9535; subsurface soils (5,180 in 2)5 m m m m m M M -m m m m m M M M M Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Figure 1-1, Phase II Survey Unit Locations 6 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 1.2 Phased Submittal Approach To minimize the incorporation of redundant historical assessment and other FSS program information, and to facilitate potential phased releases from the current license, FSS Final Reports will be prepared and submitted in a phased approach.

CYAPCO estimates that a total of four (4) FSS Final Reports will be submitted during the decommissioning project (see Figure 1-2 for locations of phased submittal areas).Phase I Final Status Survey Final Report On April 29, 2004, CYAPCO submitted a request to release a portion of the HNP site (Reference 7.8) from the IOCFR50 License (DPR-61).Specifically, the request addressed the removal/release of the East Site Grounds (Survey Area 9532), a non-impacted area, from the Part 50 License. In accordance with Section 1.4.2 of the HNP LTP and United States Nuclear Regulatory Commission (USNRC) Safety Evaluation dated November 25, 2002 (Reference 7.9), CYAPCO determined the proposed action would have no adverse impact on the ability of the site in aggregate to meet 1 OCFR20, Subpart E, criteria for unrestricted release. The request did not contain a FSS Final Report for Survey Area 9532 because this area is characterized as non-impacted.

The site release and removal of Survey Area 9532 from the site was approved by the USNRC on September 01, 2004 (Reference 7.10).Phase III and Phase IV Final Status Survey Final Reports As discussed above, CYAPCO anticipates at least two additional FSS Final Report submittals.

In the following text, there is a list of the remaining survey areas, grouped by phase, with the approximated submittal date. Details on the number, description, and location of survey units within each survey area can be found in Chapter 2 of the LTP.The schedule and identity of survey areas included in each of the remaining submittals were developed based on a review of the demolition and final status survey schedule, as well as in consideration of USNRC review requirements.

The demolition schedule, including the cleanup of demolition debris to permit access for FSS, is dynamic and subject to continued refinement in logic, durations, and completion dates. It is CYAPCO's intent to maintain the basic submittal milestone schedule provided below. However, because of potential changes in the decommissioning schedule, it is possible that additional, interim submittals will be filed with the USNRC with the goal of providing Survey Unit Release Records as soon as possible to support the agency's review, as well as CYAPCO's goals regarding the release of site lands.7 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase 11 February 2005 Phase III FSS Final Report Submittal scheduled for December 2005* 2000 Primary Auxiliary Building -Soils/Foundations

• 4000 Turbine Building -Soils/Foundations

• 5000 Service Building -Soils/Foundations

• 5502 Circulating Water System Discharge Structures

• 6000 Waste Disposal Building -Soils/Foundations

• 7002 Screen house Building/Intake Structure* 9106 Discharge Canal* 9202 Switchgear Building "B"* 9518 Southwest Site Grounds (Non-Protected Area)* 9520 Southwest Site Storage Area* 9521 Southeast Pond* 9522 Southeast Site Grounds (Non-Protected Area)* 9527 East Mountain Side* 9528 Southeast Mountainside (Survey Unit 0002)* 9530 Central Peninsula Area* 9531 South End of Peninsula* 9804 Subsurface Soils Associated with 9522* 9805 Subsurface Soils Associated with Peninsula Phase IV FSS Final Report Submittal Scheduled for December 2006* 1000 Fuel Building -Soils/Foundations

• 1308 Fuel Building Spent Fuel Pit* 3000 Reactor Containment

• 9102 YD 115KV Switchyard Area* 9302 Northwest Protected Area Grounds* 9304 Southwest Protected Area Grounds* 9306 South Central Protected Area Grounds* 9308 Southeast Protected Area Grounds* 9310 East Protected Area Grounds* 9312 Northeast Protected Area Grounds* 9313 Central Site Grounds* 9402 Emergency Operations Facility -Soils/Foundations

• 9502 Northeast Site Grounds (Non-Protected Area)* 9504 Bypass Road / Secondary Parking Lot* 9506 North Site Grounds (Non-Protected Area)* 9508 Pond* 9510 Access Road* 9512 Northwest Site Grounds (Non-Protected Area)* 9514 Primary Parking Lot* 9801 Subsurface Soils in Radiologically Controlled Area* 9802 Subsurface Soils Associated with 9308* 9803 Subsurface Soils Located North of Industrial Area 8 m m m m m m m m m -m m -m m -m m =Connecticut Yankee Atomic Power Company H.Final Status Survey Final Report -Phase II Figure 1-2, FSS Final Report Phased Submittal Areas addam Neck Plant February 2005 9 CO Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase H February 2005 2.0 FINAL STATUS SURVEY PROGRAM OVERVIEW The FSS Program consists of the methods used in planning, designing, conducting, and evaluating FSS at the HNP site to demonstrate that the premises are suitable for release in accordance with the criteria for decommissioning in Title 10CFR20, Subpart E. Final Status Surveys serve as key elements to demonstrate that:* Dose from residual radioactivity is less than the maximum annual dose criterion for license termination for unrestricted use as specified in Title 1OCFR20.1402 provided that the residual radioactivity that is distinguishable from background radiation results in a Total Effective Dose Equivalent (TEDE) to an average member of a critical group that does not exceed 25 millirem per year;* All residual radioactivity at the site is reduced to levels that are ALARA in accordance with Title 1OCFR20.1402;

• Although the annual dose criteria in the LTP is 25 mrem/yr and ALARA, Final Status Surveys for the areas addressed in this Final Report were designed to an administrative annual dose criterion of 10 mrem/yr for the land area surveys performed.

This report contains the results of the FSS that addresses the dose due to soil in the LTP Equation 5-1. As there are no structures containing residual radioactivity in the survey areas addressed in this report, this dose component for the compliance calculation is zero. Any impact from exiting groundwater is addressed in the associated Release Record and Reference 7.1.To implement the FSS Program as provided in Reference 7.5 and MARSSIM, CYAPCO established a Final Status Survey organization, within the Site Closure Group, with sufficient management and technical resources to fulfill project objectives and goals. The FSS organization was responsible for the safe completion of all activities related to FSS necessary to obtain the radiological release for unrestricted use of the HNP site. Approved site procedures directed this process to ensure consistent implementation and adherence to applicable requirements.

Figure 2-1 provides an organizational chart of the FSS organization and its relationship within the Site Closure Group.10

(_ ., ( , ( ' , ( _ -U [ -I , I ( -I -f ( i Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Figure 2-1 FSS Organizational ChartlNuclearl Safety l+ L Site Release/Technical Support Lead [Site Release/Technical Support Engineer LTP Programs Independent Oversight Group Final Status Survey Project Lead I , ,.RCRA/CAP ' : Groil ProjectLead I Proj indwater ect Lead Final Status Survey FSS Engineer Senior Lead FSS Engineer(s)

Implementation Coordinator Coordinator Pre-Demolition Surveys (URS/CVS)FSS Engineer Lead Implementation Coordinator Design Specialist l FSS Technicians Site Radiological Characterization FSS Engineer Lead FSS Engineer I I Core Bore Contractor 11 Connecticut Yankee Atomic Power Company Hadldam Neck Plant Final Status Survey Final Report -Phase H February 2005 2.1 Survey Planning Following termination of commercial operations, the initial development and planning phase started in 1997 with the characterization and Historical Site Assessment (HSA) process that continued until submittal of the LTP in 2000. The assessment consisted of a review of site historical records regarding plant incidents, radiological survey documents, operations and maintenance records, plant modification documents, and both routine and special reports submitted by CYAPCO to various regulatory agencies.Along with the assessment, interviews with site personnel, both past and present, reviews of historical site photos and extensive area inspections were performed to meet the following objectives:

• To develop the information to support FSS design including the development of Data Quality Objectives (DQO) and survey instrument performance standards;

• To develop the initial radiological information to support decommissioning planning including building decontamination, demolition, and waste disposal;* To identify any unique radiological or health and safety issues associated with decommissioning.

.To identify the potential and known sources of radioactive contamination in systems, on structures, in surface or subsurface soils, and in ground water;* To divide the HNP site into manageable areas or units for survey and classification purposes; and* To determine the initial classification of each survey area or unit as non-impacted or impacted Class 1, 2, or 3 as defined in MARSSIM or Class A, B, or C for subsurface soils (below 15 cm) as described in the LTP.Data Quality Objectives are qualitative and quantitative statements derived from the DQO process that clarify technical and quality objectives, define the appropriate type of data, and specify tolerable levels of potential decision errors used as the basis for establishing the quality and quantity of data needed to support decisions.

This process, described in MARSSIM and Procedure RPM 5.1-11, "Preparation of Final Status Survey Plans, " (Reference 7.11), is a series of graded, planning steps found to be effective in establishing criteria for data quality and developing survey plans. DQOs developed and implemented during the initial phase of planning directed all data collection efforts.Used extensively during HNP FSS, the DQO approach consists of the following seven steps: 12 Connecticut Yankee Atomic Powver Company Haddam Neck Plant Final Status Surve' Final Report -Phase II February 2005* State the Problem- provides a clear description of the problem, identification of planning team members (especially the decision-makers), a conceptual model of the hazard to be investigated and the estimated resources;

• Identify the Decision-consists of developing a decision statement based on a principal study question, which is typically "Does residual radioactive contamination present in the survey unit exceed the release criteria?" The alternative actions may include no action, investigation, resurvey, remediation and reclassification;

• Identify the Inputs to the Decision-depends on the type of media under consideration (e.g., soil, water, concrete) and whether existing data are sufficient or new data are needed to make the decision;* Define the Boundaries of the Survey- Spatial boundaries include the entire area of interest including soil depth, area dimensions, contained water bodies and natural boundaries, as needed.Temporal boundaries include those activities impacted by time-related events including weather conditions, seasons, operation of equipment under different environmental conditions, resource loading and work schedule;* Develop a Decision Rule- The statement that defines a logical process for choosing among alternative actions;.Specify Tolerable Limits on Decision Errors- incorporates hypothesis testing and probabilistic sampling distributions to control decision errors during data analysis, and* Optimize the Design for Obtaining Data- leads to the development of an adequate survey design.As stated, a primary objective of the DQO process was to demonstrate that the level of residual radioactivity in the survey area or unit, including any areas of elevated activity, met the CYAPCO established Administrative Level DCGLSOi of 10 mrem/yr. The administrative criteria represent a 60% reduction of the 25 mrem/yr Base Case DCGLSOl designed for HNP during the development of the LTP. These administrative limits, used in the ALARA survey design process, provided the minimum sensitivities required for the available survey instruments, Minimum Detectable Concentration (MDC), and techniques, and in some cases, the spacing of fixed measurements or samples within a survey unit.Table 2-1 provides a listing for the soil DCGLs used for FSS.13 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survej Final Report -Phase H February 2005 Table 2-1 Derived Concentration Guideline Levels for Land Area FSS Base Case Soil Administrative Level Required MDC Radionuclide DCGL (pCilg) DCGL (pCi/g) (pCilg)H-3 412.00 165.00 16.50 C-14 5.66 2.26 0.23 Mn-54 17.40 6.96 0.70 Fe-55 27400.00 11000.00 1100.00 Co-60 3.81 1.52 0.15 Ag-108m 7.14 2.86 0.29 Ni-63 723.00 289.00 28.90 Sr-90 1.55 0.62 0.06 Nb-94 7.12 2.85 0.29 Tc-99 12.60 5.04 0.50 Cs-134 4.67 1.87 0.19 Cs-137 7.91 3.16 0.32 Eu-152 10.10 4.04 0.40 Eu-154 9.29 3.72 0.37 Eu-155 392.00 157.00 15.70 Pu-238 29.60 11.80 1.18 Pu-239/240 26.70 10.70 1.07 Pu-241 870.00 348.00 34.80 Am-241 25.80 10.30 1.03 Cm-243/244 29.00 11.60 1.16 The development of information to support decommissioning planning and execution was accomplished through a review of all known site radiological and environmental records. Much of this information was consolidated in the "Historical Site Assessment Supplement" (HSA)(Reference 7.12), "Characterization Report" (Reference 7.13) and in files containing copies of records maintained pursuant to Title 1 OCFR 50.75(g)(1). These documents are discussed further in applicable sections of this report.An initial objective of site characterization and assessment was to correlate the impact of a radiological event to physical locations on the plant site and to provide a means to correlate subsequent survey data. To satisfy these objectives, the FSS organization divided the site into large, manageable areas and assigned a unique four digit System Survey Code (e.g. Survey Area 9528) to each area. The area designations form the basis for survey units presented in Table 1-1 of this report. Physically, survey area boundaries were determined using commercially available mapping software with coordinates consistent with the Connecticut State Plane System.14 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Upon completion of survey area assignment, the FSS organization began the task of initial classification and establishing the initial set of survey units. Classification, as described in MARSSIM, is the process by which an area or survey unit is described according to its radiological characteristics and potential for residual radioactivity.

Not all areas of the site had the same potential for residual radioactivity.

Residual radioactivity could be evenly distributed over a large area, appear as small areas of elevated activity or a combination of both. In some cases, there may be no residual radioactivity in a survey unit. Therefore, the adequacy and effectiveness of the FSS process depends upon properly classified survey units to ensure that areas with the highest potential for contamination receive a higher degree of survey effort.The surface area limits provided in MARSSIM were used to establish the initial set of survey units for the HNP LTP. A survey area may consist of one or more survey units. A survey unit is a physical area consisting of structures or land areas of a specified size and shape that would be subjected to a FSS. Survey units were limited in size based on classification, exposure pathway modeling assumptions, and site-specific conditions.

Utilization of this method of classification and size limitation ensures that each area was assigned an adequate number of data points.For identification, survey units were assigned the area four-digit code and a sub-code to designate the unit within the survey area (e.g. Survey Unit 9528-0002).

Table 2-2 provides an outline for classification and area limits.Prior to FSS, several units or areas have undergone reclassification.

Survey unit verification and a change to increase the class (more restrictive) can be performed at anytime. Typically, reclassification occurs when the evaluation of new sample results or emergent data indicates that measures that are more conservative are needed. Final classification was performed in conjunction with the preparation of the Final Status Survey Work Package, thus indicating all issues of classification are resolved.15 Connecticut Yankee Atomic Power Company Hadldam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Table 2-2 FSS Area Classifications Survey Unit Surface Contamination Classification Area Limit Potential Class 1: Structures (floor area) Up to 100 m 2 Land areas Up to 2,000 m 2 Highest Class A: Subsurface Class 2: Structures 100 22 to 1,000 m2 (floor area)Land areas 2,000 m 2 to 10,000 m 2 Moderate Class B: Subsurface Class 3: Structures (floor area) no limit Land areas no limit Lowest Class C: Subsurface 2.2 Survey Design Final status surveys for the HNP surface soils and structures are designed following HNP procedures, Chapter 5 of the LTP and MARSSIM guidance using combinations of fixed measurements, traditional scanning surveys, and other advanced survey methods, as appropriate, to evaluate survey units relative to the applicable release criteria.During characterization and in preparation for FSS, the HNP Radiochemistry Lab, using gamma spectroscopy, analyzed soil samples collected from random and biased locations in selected survey units for Easy-to-Detect (ETD) radionuclides (Table 2-3). Gamma spectroscopy indicated that Cs-137 and/or Co-60 would be the primary radionuclides of concern for survey design and FSS for a majority of the areas submitted in this report. Applied statistically, these data were used to determine the expected variability, number of samples required, and to establish the Operational DCGLSII.For the purposes of survey planning, the Operational DCGL for multiple radionuclides is based upon "unity" or sum of the fractions.

For a single radionuclide, the Operational DCGL is the Administrative Level DCGL for the nuclide of concern.Although the LTP only required a minimum of 5%, approximately 10% of the soil samples were sent to an off site laboratory for analysis of Hard-to-Detect (HTD) radionuclides listed in Table 2-3. Hard-to-Detect 16 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Statuls Survey Final Report -Phase H1 Februar 2005 radionuclides, mainly Sr-90, were detected in most of the samples. Levels of HTDs were usually less than 5% of the DCGL and were not considered as nuclides of concern in survey design. Exceptions to this are discussed in applicable sections of this Final Report and associated release records.Consistent with Equation 5-7 of the LTP, the 5% rule for single radionuclides or 10% rule for multiple radionuclides is conservative relative to the process presented in Title lOCFR20 in which radionuclides that contribute less than 10% to dose, provided the aggregate does not exceed 30%, are not required to be included in the dose assessment.

Table 2-3 Easy-to-Detect and Hard-to-Detect Radionuclides Radionuclide Analyses H-3 HTD C-14 HTD Mn-54 ETD Fe-55 HTD Co-60 ETD Ag-108m ETD Ni-63 HTD Sr-90 HTD Nb-94 ETD Tc-99 HTD Cs-134 ETD Cs-137 ETD Eu-152 ETD Eu-154 ETD Eu-155 ETD Pu-238 HTD Pu-239/240 HTD Pu-241 HTD Am-241 ETD/HTD Cm-243/244 HTD Survey design objectives included a verification of the survey instrument's ability to detect the radiation(s) of interest relative to the DCGL. As standard practice to ensure that this objective was consistently met, radiation detection instruments used in FSS were calibrated every six months with a National Institute of Standards and Technology (NIST)traceable Cs-137 source in accordance with CYAPCO HNP procedures.

Instruments were response checked before and after the instrument was used. Minimum Detectable Count Rates (MDCR) were established prior to FSS and verified.

Control and accountability of survey instruments were maintained and documented to assure the quality and prevent the loss of data.17 Connecticut Yankee Atomic Powver Company Hadldam Neck Plant Final Status Survey Final Report -Phase II February 2005 Based upon classification, areas were selected and scanned with gamma radiation detection instruments.

Information obtained during the survey was automatically logged by the instrument for review and analysis.Samples were collected at areas with elevated scan readings identified during the scanning.

Each sample point was also scanned and the information logged.Soil sample locations were determined randomly for Class 3 or by triangular systematic grid for Class 1 and 2 using commercially available software.

Sample location coordinates are programmed into a Global Positioning System (GPS), then physically located, marked or "flagged".

Samples were collected horizontally to a dept of 15 cm (6") below the top soil surface. Leaves, rocks, and roots were excluded as much as possible from the sample prior to bagging and closure. When applicable, subsurface samples were collected, using a backhoe or "push-probe" technology, to a depth of 3 meters or refusal. Composite samples were collected from this profile and prepared for shipment as mentioned previously.

Routinely, approximately ten percent (10%) of the samples collected were designated for quality control analysis such as "split samples" or duplicates.

Offsite laboratories were chosen to perform ETD and HTD analysis of samples collected during FSS. Laboratory DQO and analysis results were reported as actual calculated results. Sample report summaries included unique sample identification, analytical method, radioisotope, result, and uncertainty of two standard deviations (2a), laboratory data qualifiers, units, and required MDC. Results reported as <MDC (less than Minimum Detectable Concentration) were not accepted for FSS.A consideration of survey design was the use of "surrogates." In lieu of analyzing every sample for HTDs, the development and application of"Surrogate Ratio DCGLs" is an accepted industry practice to assay HTD radionuclides.

Surrogate Ratios allow for expedient decision making in characterization, remediation planning, or FSS design.Briefly described, a surrogate is a mathematical ratio where an ETD radionuclide concentration is related to a HTD radionuclide concentration, such as Cs-137/Sr-90.

From the analytical data, a ratio is developed and applied in the survey scheme for samples taken in the area. The result is referred to as the surrogate DCGL. Details and applications of this method are provided in Section 5.4.7.3 of the LTP.Some portion of the Cs-137 and Sr-90 found in the soil samples is certainly attributed to "background" or fallout; however, the DQO process assessed the application of media specific radiation background and ambient area radiation background to specific survey areas and units.Based upon the DQO process, the FSS planning determined that 18 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase H February 2005 background subtraction would not be applied during the survey of the land areas included in this submittal.

2.3 Survey Implementation Final Status Survey implementation started in November 2001.Implementation was the physical process of Final Status Survey Plan (FSSP) execution for a given survey unit. Each FSSP was assigned to a FSS Engineer for implementation and completion in accordance with CYAPCO FSS program procedures and FSSQAP. Some of the tasks included in the implementation are:* Verification and Validation of personnel training as required by Procedure RPM 5.4-0 "Site Closure Training Program" (Reference 7.14);* Monitoring instrument calibration as detailed in Procedure RPM 5.1-4, "Control and Accountability of Portable Survey Instnuments for Scoping, Characterization and Final Status Surveys " (Reference 7.15);* Implementation of applicable operating, health and safety procedures and personnel safety as detailed in Procedure 000-GEN-0000-00061-00, "Work Plan and Inspection Record" (WPIR) (Reference 7.16);* Determination of the amount of sampling required to meet survey DQOs as described in Procedure R5.1-12,"Determination of the Number of Surface and Subsurface Samples for FSS of Opemn Land Areas" (Reference 7.16);* Determination of where measurements or samples are to be made or collected along with maps of the survey area showing the measurement/sample locations, in accordance with Procedure RPM 5.1-11;* Maintaining Quality Assurance/Quality Control requirements (e.g., replicate measurements or samples) in accordance with Procedure RPM 5.1-24, "Split Sample Assessment for Final Status Survey" (Reference 7.18) and the FSSQAP;* Sample submission to approved laboratories as provided in Procedure RPM 5.1-5, "Chain of Custody for Final Status Survey Samples" (Reference 7.19);* Application of the DCGLs to sample results in accordance with the Data Quality Assessment (DQA) process as detailed in Procedure RPM 5.1-23, "Data Quality Assessment" (Reference 7.20) as well as, 19 Connecticut Yankee Atomic Power Company Haddlam Neck Plant Final Status Survey Final Report -Phase II February 2005* Determination of investigation methodology;

• Corrective actions, if applicable.

The FSS implementation and completion process resulted in the generation of raw data consisting of measurements taken with handheld radiation detection equipment, field logs, and radionuclide specific analysis.

Data were stored electronically on the CYAPCO network server.2.4 Survey Data Assessment Prior to proceeding with data evaluation and assessment, the assigned FSS Engineer resolves and documents discrepancies between the data quality or the data collection process and the applicable requirements.

The DQA process is an evaluation method used during the assessment phase of FSS to ensure the validity of FSS results and demonstrate achievement of the survey plan objectives.

The first step in the data assessment process converts all of the survey results to DCGL units. The individual measurements and sample concentrations are compared to the DCGL for evidence of small areas of elevated activity or results that are statistical outliers relative to the rest of the measurements.

When practical, graphical analyses of survey data that depicts the spatial correlation of the measurements were used.To demonstrate that survey data fulfills the radiological release criteria, FSS planning incorporated hypothesis testing and probabilistic sampling distributions to control decision errors during data analysis.

Hypothesis testing is a process based on the scientific method that compares a baseline condition to an alternate condition.

The baseline condition is technically known as the null hypothesis.

Hypothesis testing rests on the premise that the null hypothesis is true and that sufficient evidence must be provided for rejection.

In designing the survey plan, the underlying assumption, or null hypothesis was that residual activity in the survey unit exceeded the release criteria.

Rejection of the null hypothesis would demonstrate that residual activity was at or below the release criteria objective of the FSS.Hypothesis testing is demonstrated through the application of the Sign Test on the sample data collected in the survey unit. The Sign Test is considered a one-sample statistical test that compares sample data directly to the release criteria.

Combined with an effective sampling scheme, passing the Sign Test constitutes satisfying the release criteria.

Selection of the Sign Test is prudent and conservative in the assumption that the radionuclides being considered are not present in background or are at levels at a small fraction of the applicable release criteria.

Reference areas and reference samples are not needed, thus simplifying the FSS.Furthermore, any background contribution (e.g., Cs-137 from atmospheric weapons testing) in the sample increases the likelihood of failing the 20 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 survey unit, which is conservative.

If the release criteria were exceeded or if results indicated the need for additional data points, appropriate further actions were implemented usually through the issue of an addendum to the FSSP.2.5 Quality Assurance and Quality Control Measures Quality assurance and control measures were employed throughout the FSS process to ensure that all decisions are based on data of acceptable quality. Quality assurance and control measures were applied to ensure:* The plan is correctly implemented as prescribed;

• DQOs are properly defined and derived;* All data and samples are collected by individuals with the proper training following approved procedures;

• All instruments are properly calibrated;

• All collected data are validated, recorded, and stored in accordance with approved procedures;

• All required documents are properly maintained; and,* If necessary, corrective actions are prescribed, implemented and tracked.Independent laboratories used for analysis of the samples collected during FSS maintain Quality Assurance Plans designed for their facility.CYAPCO reviews these plans, as required by the "Quality Assurance Program for Haddam Nuclear Plan " (CYQAP) (Reference 7.21), and the FSSQAP, prior to selection of a laboratory for FSS sample analysis to ensure standards are acceptable.

During 2004, three Quality Surveillance Reports (QSRs) were produced on activities related to FSS. In general, these reports were performed to evaluate the adequacy of the implementation of regulatory and LTP/FSS requirements.

QSR-04-072-CY (Reference 7.22) performed during March 29 to April 8, 2004, was an independent review of the FSS program. The LTP, FSS Plan, and procedures, interviews, inspection of FSS equipment, and FSS data and documentation were reviewed and compared.

The assessment considered procedures, organization, and performance in assessing LTP implementation.

Experience and lessons learned from other FSS programs were considered by the Assessment Team. The use of the assessment to evaluate the program was considered a very positive initiative and useful tool for improving performance in the Site Closure group. The surveillance verified that the controls instituted to plan, design, conduct, 21

...... --.-Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase H February 2005 and evaluate LTP/FSS requirements at HNP demonstrate compliance with USNRC radiological criteria for unrestricted use.QSR-04-073-CY (Reference 7.23) performed during June 7 to June 16, 2004, evaluated the guidance for preparing, performing, documenting, and approving the FSS Plan for Survey Unit 9537-0000, Permitted Landfill.The surveillance verified that the controls instituted to plan, design, conduct, and evaluate FSS at HNP demonstrate compliance with USNRC radiological criteria for unrestricted use. The FSS Plan was consistent with MARSSIM guidelines.

QSR-04-078-CY (Reference 7.24) performed during April and June of 2004, evaluated the guidance for performing field activities during the FSS for Survey Units 9535-0001/0002 and 9806-0000.

The surveillance verified that the controls instituted to plan, design, and conduct the FSS at the HNP site demonstrate compliance with the USNRC radiological criteria for unrestricted use. The general and specific FSS Plan was consistent with MARSSIM guidelines.

In June of 2004, the "Final Status Survey Program Assessment Report" (Reference 7.24) was issued. The objective of this comprehensive, independent assessment was to evaluate the effectiveness of the FSS program in implementing LTP requirements including a "limited" review of the LTP. Training, instrumentation, documentation, and data management were also assessed during this time. The report concluded that the CYAPCO FSS program contained the necessary elements to meet LTP requirements to perform FSS of land areas. However, there were three findings in the areas of document and software controls, and training.

Condition Report 04-0810 (Reference 7.26) and 04-0811 (Reference 7.27) were issued to document and implement corrective actions. The training program was revised and controlling procedures issued.An internal audit was performed in November 2004 by CYAPCO. The objective of the CY Nuclear Safety Audit Report, CY-04-A09-01, "Final Site Survey (FSS)/License Termination Plan (LTP)" (Reference 7.28), was to assess the compliance with commitments and regulatory requirements and to verify that FSS/LTP implementation was maintained consistent with associated requirements and that implementation was meeting expectations.

Only one deficiency was identified during the audit.Condition Report CR 04-1298, "Failure to process timely License Basis Document Change Request (LBDCR) for the License Termination Plan (LTP) changes, " (Reference 7.29) was issued to document and implement corrective actions based on the audit finding.By the end of 2004, all findings from the QSRs, audits, and assessments were corrected and systematic controls implemented.

22 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 3.0 SITE INFORMATION 3.1 Site Description Haddam Neck Plant, owned by Connecticut Yankee Atomic Power Company, is located on the east bank of the Connecticut River, approximately 21 miles south-southeast of Hartford.The site consists of approximately 525 acres, with a minimum distance overland from the reactor containment to the site boundary of 1,740 ft and the distance to the nearest residence is over 2,000 ft.The plant incorporated a 4-loop closed-cycle pressurized water type Nuclear Steam Supply system (NSS system); a turbine generator and electrical systems; engineered safety features; radioactive waste systems;fuel handling systems; instrumentation and control systems; the necessary auxiliaries; and structures to house plant systems and other onsite facilities.

HNP was designed to produce 1,825 MW of thermal power and 590 MW of gross electrical power.Westinghouse Electric Corporation was responsible for design and fabrication of all NSS and auxiliary systems and equipment, as well as design and supply of all secondary plant mechanical and electrical equipment, which it normally manufactures.

Stone and Webster Engineering Corporation was responsible for site development, design of buildings and secondary systems, and all plant construction.

Each of these contractors was responsible to CYAPCO for tasks performed in their respective areas of design and construction.

Pre-operational plant checkout, core loading, plant start-up, and operation were the responsibility of CYAPCO.On December 4, 1996, HNP permanently shut down after approximately 28 years of operation.

On December 5, 1996, CYAPCO notified the USNRC of the permanent cessation of operations at the HNP and the permanent removal of all fuel assemblies from the Reactor Pressure Vessel and their placement in the Spent Fuel Pool. Following the cessation of operations, CYAPCO began the decommissioning of the HNP. The Post Shutdown Decommissioning Activities Report (PSDAR) was submitted, in accordance with Title IOCFR50.82 (a) (4), on August 22, 1997, and was accepted by the USNRC. On January 26, 1998, CYAPCO transmitted an Updated Final Safety Analysis Report to reflect the plant's permanent shutdown status, and on June 30, 1998, the USNRC amended the HNP Facility Operating License to reflect plant conditions.

On October 19, 1999, the Operating License was amended to reflect the decommissioning status of the plant and long-term storage of the spent fuel in the spent fuel pool. Additional licensing basis documents were also revised and submitted to reflect long-term fuel storage in the spent fuel 23 Connecticut Yankee Atomic Power Company Hadldam Neck Plant Final Status Suney Final Report -Phase HI February 2005 pool (Defueled Emergency Plan, Security Plan, QA program, and Operator Training Program).In 1997, in accordance with NUREG/CR-5849 (Reference 7.30) initial site characterization was implemented.

In 1999, following the guidelines of MARSSIM, initial characterization was completed.

The information developed during the initial HNP characterization program represented-a radiological assessment based on the knowledge and information available at the end of 1999.3.2 Survey Area/Unit Description The following information is a description of each survey unit at the time of FSS from November 2001 until August 2004. During this period, fifteen (15) final status surveys covering approximately 313 surface acres were completed on the outlaying lands surrounding the Haddam Neck Plant. Mostly wooded, located to the north and east of the plant, the areas consist of hilly, rocky uplands that drain to wetland areas.Survey Unit 9523-0000 Survey Unit 9523-0000, (Southeast Wetlands Area) is designated Class 3, and consists of approximately 151,363.19 m 2 (37.4 acres) of uninhabited, undeveloped land located about 0.75 miles from the center of the Haddam Neck Plant Containment Building.Survey Unit 9524-0000 Survey Unit 9524-0000 (South Site Grounds area) is designated Class 3, and is located approximately 0.85 miles from the Haddam Neck Plant Industrial Area. The survey unit is located south of the southeast mountainside and has a land area of 61,974.8 m 2 (15.3 acres).Survey Unit 9525-0000 Survey Unit 9525-0000 (Southeast Site Road) is a Class 3 section of asphalt-paved road with a steep grade located east of Haddam Neck Plant site industrial area. The road area selected for the survey unit is approximately 1,400 meters in length, 2.5 meters wide (0.86 acres), and runs in a north-south direction.

Survey Unit 9526-0000 Survey Unit 9526-0000, (Northeast Mountainside Area) , is designated Class 3, and consists of approximately 444,700 m 2 (110 acres) of uninhabited and undeveloped land located about a tenth of a mile (0.09 miles) from the center of the Containment Building.24 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Surrey Final Report -Phase 11 February 2005 Survey Unit 9526-0001 Survey Unit 9526-0001 (Northeast Mountainside Area) is designated Class 2, and consists of approximately 6,503.5 m 2 (1.6 acres) of uninhabited, undeveloped land located about a tenth of a mile (0.09 miles) from the center of the Containment Building.Survey Unit 9526-0002 Survey Unit 9526-0002 (Northeast Mountainside Area) is designated Class 2, and consists of approximately 6,068 m 2 (1.5 acres) of uninhabited, undeveloped land located about a tenth of a mile (0.09 miles) from the center of the Haddam Neck Plant Containment Building.Survey Unit 9528-0000 Survey Unit 9528-0000 (Southeast Mountainside Area) is a Class 3 area and consists of approximately 508,000 m 2 (125.5 acres) of uninhabited, undeveloped land located about a quarter of a mile (0.23 miles) from the centerline of the containment building.Survey Unit 9528-0003 Survey Unit 9528-0003 (Southeast Mountainside)

Haul Road Section 2 is a Class 2 area that comprises an open land area of approximately 0,000m 2 (2.5 acres) located between the Discharge Canal on the south and approximately 15 meters into the interior of area 9528-0000 on the north.Survey Unit 9528-0004 Survey Unit 9528-0004 (Southeast Mountainside)

Haul Road Section 3, is Class 3 open land area of approximately 3,100 m 2 (0.8 acre) located outside of the Industrial Area. It includes the access road to the Southeast Landfill Area and 15 meters north of the road.Survey Unit 9535-0001 Survey Unit 9535-0001 (Southeast Landfill) is a Class 1 area located approximately 0.85 miles from the Industrial Area and has a land area of 1,860 m 2 (0.45 acres).Survey Unit 9535-0002 Survey Unit 9535-0002 (Southeast Landfill) is a Class 2 area located approximately 0.85 miles from the Industrial Area. Survey Unit 9535-0002 is located north of the pistol range and has a land area of 3,320 m 2 (0.82 acres).25 Connecticut Yankee Atomic Power Company.HaddamNeckPlant Final Status Survey Final Report -Phase ! February 2005 Survey Unit 9536-0000 Survey Unit 9536-0000 (Construction Piles near the Rifle Range) is a Class 3 open land area of 1,536 m 2 (0.38 acres). The survey unit is at the south end of an excavated sandpit approximately 0.85 miles from the Industrial Area, west of the former pistol range and adjacent to the Permitted Landfill.Survey Unit 9537-0000 Survey Unit 9537-0000 (Permitted Landfill) is a Class 2 open land area of 850 m 2 (0.21 acres). The Permitted Landfill is at the south end of an excavated sandpit approximately 0.85 miles from the Industrial Area and west of the former pistol range.Survey Unit 9538-0000 Survey Unit 9538-0000 (Material Storage Area) is designated Class 2 and consists of approximately 1,500 m 2 (0.36 acres) of uninhabited, undeveloped, open land located about 0.85 miles from the center of the Haddam Neck Plant Containment Building.Survey Unit 9806-0000 Survey Unit 9806-0000 (Southeast Landfill Area) is a Class A area located approximately 0.85 miles from the Industrial Area and has a land area of 5,180 m 2 (1.27 acres). Survey Unit 9806 is the subsurface FSS evaluation of Survey Unit 9535.3.3 Summary of Historical Radiological Data The site historical radiological data for HNP includes the results of Historical Site Assessment, conducted during the late 1990s and in 2001, scoping surveys completed in 1998, initial characterization surveys completed in 1999, characterization surveys conducted prior to FSS and a remedial action survey.3.3.1 Scoping Surveys The purpose of the scoping surveys was to establish early in the decommissioning process, the necessary areas requiring remediation and to what extent. Details of the scoping surveys are provided in "Results of Scoping Survey for CYAPCO 's Haddam Neck Plant, " 1998 (Reference 7.31). The scoping survey identified 140 events that could potentially contaminate the facility outside of the Radiologically Controlled Area. From this list, only two events were considered to have the potential to contaminate survey units discussed in this FSS Final Report. The first event(s) was the 26 Connecticut Yankee Atomic Power Company Haddeam Neck Plant Final Status Surrve Final Report -Phase H February 2005 unplanned radioactive releases from the plant stack in December 1979. The second event involved plant related waste materials that were disposed of at the Southeast Landfill Area. As described in the release record, only Survey Unit 9535-0001 was documented as containing plant related radioactive materials resulting from this event.3.3.2 Characterization Surveys The characterization of radiological and hazardous materials conditions of all areas of the HNP site, an initial task in the plant decommissioning and license termination process, centered around four main objectives:

• Determine the nature and extent of contamination;

• Provide the basis for initial classification of areas;* Provide a basis for remediation planning, including recommendations for additional surveys or samples, and* Provide input into the FSS design.Following plant shutdown at the end of 1996, it was determined that there was a need for additional surveys to better define the scope of radioactivity or "characterization" in several on-site areas.To fill this gap, surveys were conducted in plant areas along with the sampling and analysis of environmental media that included ground water, paved surfaces outside the radiologically controlled area and soils suspected of containing radioactive materials.

The coalescence of this data, as well as all available site data, occurred during the development of the HSA. The HSA consisted of a review of plant operational records since initial license approval, a review of events that have potential impact on decommissioning activities compiled in accordance with Title lOCFR50.75 (g) (1), and interviews with present and former employees regarding events and activities that may impact license termination.

The results of the HSA identified radiological conditions or events that impacted the HNP. These events fall into several categories:

• Normal plant operation that affected systems, components, and building surfaces that are designed to contain radioactive material.

Examples of these are the reactor coolant system, residual heat removal pumps, and building areas such as sumps and pipe vaults.27 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut

~ ~ YakeAoi oe opn admNc ln Final Status Survey Final Report -Phase 11 February 2005* The discharge and runoff of radiological effluents to the canal;* Operational events that occurred in which radioactive materials were released from ventilation, and waste processing systems. Examples are elevated readings on the primary auxiliary building roof and owner controlled hillside locations east of the plant, and* Leakage of water containing radioactive material that was documented historically.

Incidents of this nature included leaking lines under the PAB drumming room floor, overflowing of a manhole just east of the Service Building and leakage from radioactive liquid storage tanks.The summary information developed during the HSA process was evaluated concurrently with the information provided in the "NRC Historical Review Team Report -Radiological Control and Area Contamination Issues at Haddam Neck" (Reference 7.32), dated March 26, 1998, to assure completeness of the historical data.Another significant document, the "Characterization Report"-(Reference 7.13), provided an assessment of the radiological and hazardous material conditions for each of the site buildings and subsections of the site grounds at a specific point in time. A listing of the areas was provided in the table of contents, along with the area identification number(s) and the area's initial classification in accordance with the criteria established in MARSSIM. Site maps were provided to locate the areas and the respective survey area number(s).

A report for each area contained a description (boundaries) of the area, known radiological and hazardous material information, impacted systems within an area and recommendations for further samples or surveys. Buildings assumed to remain in support of spent fuel storage activities, were not included (i.e. not be part of the LTP process).As suggested in the "Characterization Report" and discussed in the applicable release records, recent characterization surveys to aid in the FSSP design were performed as needed for each survey unit.3.3.3 Remedial Action Surveys All survey areas submitted in this Final Report were evaluated in accordance with Health Physics TSD BCY-HP-0078, "ALARA Evaluation of Soil Remediation in Support of Final Status Survey," (Reference 7.33). This evaluation determined that remediation beyond that required to satisfy the release criteria to 28 Connecticut Yankee Atomic Power Company Hadldam Neck Plant Final Status Surety Final Report -Phase H February 2005 be unnecessary and that the remaining residual radioactivity in soil was ALARA.During the phase of decommissioning and surveying covered by this report, remedial action, and Remedial Action Surveys (RAS)were only conducted in Survey Unit 9535-0001, the Southeast Landfill.Survey Unit 9535-0001 is a Class I area located approximately 0.85 miles from the Haddam Neck Plant Industrial Area. In July of 2003, a characterization of Survey Unit 9535-0001 was performed that focused on those areas previously identified in 1997 and 1999 as containing residual radioactivity related to plant operations.

The survey included radiation surveys with a sensitive gamma radiation detector and the collection and analysis of soil samples. During the survey, approximately 100% of the land area was scanned with a gamma detector and twenty soil samples were collected and analyzed by gamma spectroscopy.

Most samples were collected from discrete locations indicating elevated activity (i.e. instrument response was greater than twice ambient background).

The analytical data from the twenty (20) samples were subjected to review and statistical analysis.

Cs-137 was identified in all of the samples collected.

Thirteen (13) of the twenty (20) samples contained identifiable amounts of Co-60. Compared to Administrative Level DCGLs routinely used for FSS, nine of the twenty samples would exceed the 10 mrem/yr DCGLSOI, administrative limit. An overview of the statistical analysis for samples prior to remediation is provided in Table 3-1.Table 3-1 Basic Statistical Quantities of 9535-0001 Characterization Samples.Cesium-137 Cobalt-60 Parameters (pCi/g) (pCi/g)Minimum Value: 0.0814 0.00211 Maximum Value: 15.9 1.90 Mean: 3.29 0.273 Median: 2.79 0.115 Standard 3.78 0.518 Deviation:

3 A remedial action plan was developed and implemented from July 30 to October 21, 2003. Three samples collected during the remedial action were analyzed off-site for the full suite of ETD and HTD radionuclides.

The highest concentrations reported in the 29 Connecticut Yankee Atomic Power Company Hadd~am Neck Plant Final Status Survey Fijial Report -Phase II February 2005 analysis were Co-60 at 2.21 pCi/g and Cs-137 at 52.9 pCi/g. The HTD analyses identified SR-90, Ni-63, and C-14 as well. An independent analysis of the three samples by Oak Ridge Institute for Science and Education also confirmed these results.During the remediation, approximated 4,000 ii3 of soil was removed for transport and disposition.

All concrete and other industrial materials removed from the area were surveyed and found not to exceed the radiological release criteria for unrestricted use under the radiation protection program's "unconditional release" criteria.

Based on the results of the radiation survey and the sample results, the remedial action was completed on October 21, 2003.Post remediation sampling and analysis identified Cs-137 in the soil samples at levels consistent with those concentrations determined from off-site locations.

Table 3-2 provides a statistical analysis of the post remediation samples collected in Survey Unit 9535-0001.

Table 3-2 Statistical Quantities of Post Remediation Samples from 9535-0001.

Cesium-137 Cobalt-60 Parameters (pCi/g) (pCilg)Minimum value: 0.0835 0.00149 Maximum Value: 0.408 0.0156 Mean: 0.211 0.00715 Median: 0.182 0.00487 Standard 0.121 0.00615 Deviation:

3.4 Conditions at the Time of Final Status Survey The land areas discussed in this report are mostly wooded or open land areas with little to no disturbance occurring since the construction of HNP.A transmission right-of-way, partially maintained, runs through the property.

In addition, several areas contain service roads or fire roads that were used to access the site during FSS. Most of these roads are no longer in use and are closed for security reasons and/or are in disrepair.

Some survey areas have undergone archaeological investigations that resulted in small test pits and trenches.Recent activities have occurred mostly in two general areas. The first area(s) is associated with the construction of the Independent Spent Fuel Storage Installation (ISFSI). The reconstruction of the roads leading to the ISFSI, along with the building of the ISFSI has occurred since 2002.30

---Connecticut Yankee Atomic Powver Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 The other area includes the Rifle Range, Permitted Landfill, and Radioactive Materials Storage Area (Survey Units 9524, 9535, 9536, 9537, and 9538). This open area located to the east of the HNP industrial site, undenvent remediation and removal of radioactive materials (Survey Unit 9535-0001), hazardous materials (lead), typical debris and refuse resulting from normal plant operations.

Minor amounts of concrete debris that was below release criteria were left as backfill.

These areas were backfilled with clean soil, restored, graded and seeded for erosion control.Release records associated with these areas provide further details.Prior to FSS, areas ready for survey were isolated and controlled under Procedure RPM 5.1-16, "Turnover and Control of Open Land Areas for Final Status Survey, " (Reference 7.34). This includes posting of the area as well as notifications to site personnel.

Permission to enter and work in these areas must be obtained from FSS staff. Obvious posting of the boundaries in the heavily wooded areas controls public access; however, the impact of public access is considered minimal to nonexistent.

In Survey Area 9528, the area around the IFSI is a controlled security area.3.5 Identification of Potential Contaminants In general, the identification of potential contaminants was accomplished through the review of plant operating records, radiological surveys, and laboratory analysis for ETD gamma emitting radionuclides.

During characterization, soil samples collected from areas that would undergo FSS were sent to an off site laboratory for HTD analysis.

In addition, data obtained from waste streams analyzed for Title 10CFR61 radionuclides were reviewed and considered.

The 10CFR61 and HTD analysis usually includes chemical separation or other advanced methods of detection not available at HNP.During FSS and characterization, elevated readings led to the identification of plant related radionuclides in Survey Units 9528-0004 and 9535-0001.

Levels of Co-60 in Survey Unit 9528-0004 were identified and confirmed at a maximum concentration of 0.359 pCi/g, 23%of the Administrative Level DCGLSOii.

In 9535-0001, analysis indicated that multiple radionuclides were present, Cs-137, Co-60, Sr-90, Ni-63 and C-14. As discussed previously, a remedial action plan for 9535-0001 was developed and implemented in 2003. In addition, some of the samples collected along the Discharge Canal have indicated low levels of Co-60.As shown by the FSS Release Records, the plant related radionuclide identified in most of the samples was Cs-137 and in a few areas, Co-60.For a majority of the samples, the concentrations of Cs-137 were below or at those concentrations determined from off-site locations as documented by Health Physics TSD BCY-HP-0063, "Background Cs-137 Concentration in Soil," and (Reference 7.35). With one exception (Survey 31 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Unit 9535-0001), the reported values of Cs-137 were not enough to warrant radiological soil remediation.

Cesium-137 deposition resulting from nuclear weapons testing is thought to be the source of most of the Cs-137 encountered in samples collected in the outlands surrounding HNP. Geological deposition, regional concentrations and transport mechanisms are well documented and the subject of numerous publications and studies. However, as a conservative measure, Cs-137 resulting from fallout or "background" was not subtracted from analytical results for FSS at HNP.Another nuclide resulting from nuclear weapons testing and originally deposited with Cs-137 fallout is Sr-90. With the exception of Survey Unit 9535-0001, concentrations found in samples collected in the outland areas of HNP compares favorably with research conducted in other regional areas concerning fallout resultant from nuclear testing in the past as referenced in EPRI Technical Report 1003030, "Determnining

Background

Radiation Levels in Support of Decomnnissioning Nuclear Powver Plants" (Reference 7.36).Analysis for HTD radionuclides identified Pu-239/240, Pu-241, and Am-241 in some samples. Given the very low concentrations and sensitivities of the analysis, the likely source of the plutonium/americium is from past atmospheric nuclear weapons testing fallout, Chernobyl, and bum-up and vaporization of the United States SNAP 17A satellite in the atmosphere.

At times, analytical errors such as "false positives" contributed to the HTD indicators.

These indicators were assessed and are discussed in the applicable release records.During the FSS implementation, areas of interest were "scanned" with portable, hand-held radiation detection meters. Prior to scanning, background levels were determined and investigation levels set in accordance with Health Physics TSD BCY-HP-008 1, "Scan MDC of Land Areas using a 2-inch by 2-inch Sodium Iodide Detector," (Reference 7.37). Areas were then scanned for elevated readings.

When an elevated area was found, the area was marked and a sample collected at that location for gamma spectroscopy analysis and further evaluation.

Occasionally, during the scanning surveys, rock outcroppings would exhibit elevated activity above the investigation levels established by the sample plan. As suspected, pegmatite containing primordial radionuclides was the cause of the elevated instrument readings.

Details on this occurrence are discussed further in Health Physics TSD BCY-HP-0150,"Investigation of Rock Outcropping Exhibiting Elevated Activity," (Reference 7.38) and mentioned in associated release records.32 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase 11 February 2005 3.6 Radiological Release Criteria All FSSs for the land area surveys submitted in the Phase II report were conservatively designed to the 10 mrem/yr Administrative Level DCGLsoil and all results compared to this value. However, since the release criteria was based on the 25 mrem/yr DCGL, failure of the survey unit to meet the 10 mrem/yr DCGL did not "disqualify" the unit from release provided that the 25 mrem/yr criteria was not exceeded.

For the two survey units affected by groundwater in this phase submittal, 9528-0000 and 0003, the dose attributed to groundwater is less than 0.2 mrem/yr. This is detailed in Reference 7.1.4.0 FINAL STATUS SURVEY PROTOCOL 4.1 Data Quality Objectives The DQO process as outlined in Section 2.0 of this report was applied for each FSSP and contains basic elements common to all FSSPs at HNP. An outline of those elements presented in the HNP FSSPs is as follows:* STATE THE PROBLEM The problem: To demonstrate that the level of residual radioactivity in a survey unit including any areas of elevated activity does not exceed the release criteria of 25 mrem/yr Total Effective Dose Equivalent (TEDE) as specified in the LTP; is below an administrative level of 10 mrem/yr TEDE; and that the potential dose from residual radioactivity is ALARA.Stakelholders:

The primary stakeholders interested in the answer to these problems are CYAPCO, the CT Department of Environmental Protection (CTDEP), and the USNRC.The Planning Team: The planning team consisted of the Site Closure personnel with input from CYAPCO Health Physics management.

The primary decision maker was the assigned FSS Engineer.

The engineer obtained input from CYAPCO Project Support on issues relating to schedule and costs.Schedule:

The approximate time to complete a FSSP and collect field data. Security constraints and activities related to the ISFSI might temporarily limit access to area, if applicable.

Resources:

The primary resources needed to determine the answer to the problem are American National Standards Institute (ANSI)qualified Health Physics Technicians to perform fieldwork and qualified FSS Engineers to prepare the plan, generate maps, coordinate field activities, and evaluate data. An off site laboratory will analyze the samples and provide radionuclide specific results.Ancillary support may be required from the HNP Radiochemistry 33 Connecticut Yankee Atomic Power Company Haddam Neck Plant Finial Status Sunrey Final Report -Phase II February 2005 Count Room for soil sample gamma spectroscopy analysis, Security for access through site gates and the Warehouse to assist in shipment of samples offsite.* IDENTIFY THE DECISION Several decisions need to be defined to address the stated problem: Principal Study Question (1): Does the mean concentration of residual radioactivity in the survey unit exceed the release criteria or the stated administrative level?Alternate Actions (1): Alternative actions include failure of the survey unit, remediation, reclassification, and no action.The Decision (1): Determine whether the mean concentration of residual radioactivity in the survey unit exceeds the release criteria or the administrative level stated in the problem.Principal Study Question (2): Do any areas of elevated activity in the survey unit exceed the release criteria or the stated administrative level?Alternate Actions (2): Alternative actions include confirmation and investigation, performing the, spot remediation, reclassification of part or the entire survey unit and no action.The Decision (2): Determine if any areas of elevated activity in the survey unit exceed the release criteria or the administrative level stated in the problem.Principal Studdy Question (3): Is the potential dose from residual radioactivity in the survey unit ALARA?Alternate Actions (3): Alternative actions include remediation, resurvey, and no action.The Decision (3): Determine if the potential dose from residual radioactivity in the survey unit is ALARA.* IDENTIFY THE INPUTS TO THE DECISION Information Needed: The survey unit requiring evaluation of residual activity in accordance with Section 5.7.3.2.3 of the LTP. New measurements of sample media are needed to determine the concentration and variability for those radionuclides potentially present at the site at the time of final status survey and if required, the extent of any areas of elevated activity or results that are statistical outliers relative to the rest of the measurements.

34 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut

~ ~ YakeAoi oe opn admNc ln Final Status Survey' Final Report -Phase II February 2005 Source of the Inforniation:

A review of historical information, 1OCFR50.75 (g) (1) files, and radiological surveys providing an indication of the potential for contamination.

Sampling and Analysis Methods to Meet the Data Requirements:

The media consisted of soils, asphalt, or concrete as required to complete the FSS. Soil samples were collected down to a depth of 15 cm (6 inches) and analyzed by an off site laboratory.

Other media considered during FSS planning included underlying soil, that is, soil below the asphalt, concrete, and groundwater.

As detailed in Reference 7.1, only two survey units in this phase submittal are affected by dose attributed to groundwater contamination.

Survey Units 9528-0000 and 9528-0003 were assessed and the resultant dose was less than 0.2 mrem/yr for both units. The LTP does not associate the remaining survey units in Phase II submittal with groundwater contamination (LTP Table 5-4 for groundwater).

With the exception of Survey Unit 9806, subsurface soil samples were not collected or analyzed to support the objectives of the FSSP. Radiation scans were performed to identify areas of elevated activity.Table 2-12 of the LTP lists twenty radionuclides potentially present at the site. Derived Concentration Guideline Levels were calculated for each of the radionuclides listed based on a 25 mrem/yr dose limit. To calculate DCGLs, dose models were developed to relate levels of residual radioactivity into potential dose. The DCGLs presented in Chapter 6 of the LTP were developed for exposures from three potential media, which is residual radioactivity in soil, existing groundwater radioactivity, and additional future groundwater radioactivity from the potential burial of concrete debris from site buildings containing residual radioactivity.

In the LTP, Equation 5-1 expresses the total dose (H) from all three media: HTotal can be expressed as: HTotal = Hsoil + H&Lsting GY + HFUiUreGW (Equation 5-1)The elimination of the existing and future groundwater dose components from Equation 5-1 for the purpose of performing the FSS for soil simplifies the use of the subsequent equation, LTP Equation 5-2, for the determination of dose from residual radioactivity in soil.35 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Suntey Final Report -Phase II February 2005 Dosefrom the residual radioactivity from radionuclide "i" is: H' =25* DCGL' (Equation 5-2)For soil, Base Case DCGLSOi was determined for the radionuclides listed in Table 2-12 of the LTP using the resident farmer scenario.The assumption is that residual radioactivity is present in the soil, which is used for residential and light farming activities.

Characterization was performed under a sample plan with data quality commensurate with objectives of the survey. Characterization may have included radiation scanning for areas of elevated activity within one-meter radius of the sample measurement location and sample collection and transfer to the on-site laboratory using proper chain-of-custody controls for analysis by gamma-spectroscopy.

Qualified personnel using approved procedures implemented the characterization plan. Equipment was properly calibrated in accordance with procedure.

The data was evaluated to determine if any of the twenty listed radionuclides are present in quantities greater than 5% of the applicable Base Case DCGL in the survey unit at the time of FSS. In addition, the evaluation determines if the aggregate concentration of the twenty radionuclides will exceed 10%. The use of the 5% and 10%rule is consistent with the development of surrogate ratio DCGLs as described in the LTP.Available data is used to determine the radiological concentration variability in the survey unit and number of radionuclides present. If a single radionuclide is assumed present, then determining the operational DCGL is simplified.

In addition, the Base Case DCGLs for all radionuclides used in FSS design are reduced by 60% to achieve the administrative level of 10 mrem/yr TEDE.Meeting the administrative level automatically satisfies the release criteria by design, pending any groundwater dose.As verification, a minimum of 5% of the samples required for compliance are analyzed for all radionuclides listed in Table 2-1 of this report. All radionuclides listed in Table 2-1 verified present in FSS samples are included in the assessment of data and incorporated into the decision process as necessary.

Based on survey unit class, a decision to apply the Elevated Measurement Comparison (EMC) was evaluated.

During Phase II FSS, surveys indicated that EMC was not required.

For example, 36

--Connecticut Yankee Atomic Power Company Hadldam Neck Plant Final Status Survey Final Report -Phase II February 2005 EMC was included in the FSSP design of Survey Unit 9535-0001; however, application of the EMC was not used since isolated areas of elevated activity were not found.A decision to use Surrogate DCGLs was evaluated based on radionuclide analysis.

During Phase II FSS, surrogates were only applied in Survey Unit 9535-0001.

Soil samples analyzed on site were dried and analyzed by gamma spectroscopy.

Samples analyzed off site at an approved laboratory were dried in accordance with approved vendor procedures and analyzed by gamma spectroscopy.

Samples sent off site for HTD radionuclides (e.g., Sr-90, Pu-239/240) were analyzed using alpha spectroscopy or other radiochemistry methods (e.g., liquid scintillation).

The LTP specifies a required scanning coverage fraction of 0% to 100% based on FSS classification.

The fraction of scanning coverage is determined during the DQO process with the total amount, and location(s) based on the likelihood of finding elevated activity during FSS.All activities fall under the FSSQAP. This plan requires, among other things, the use of trained technicians, calibrated instruments, and procedures.

In addition to these requirements, a minimum of 5% of the required number of samples will be selected for QC evaluation.

This evaluation may be either splits or duplicates.

Basis for Determining the Action Level: An Action Level, as described by LTP Equation 5-30, is based on the concentrations of residual radioactivity compared to the reduced DCGLs by complying with the unity rule, or sum of the fractions.

Sampling and Analysis Methods to Meet the Data Requirements:

The LTP requires that MDCs for fixed measurements (samples are considered fixed measurements) be as far below the DCGL as possible.

A value of 10% is the desired level of sensitivity with up to 50% of the DCGL being acceptable.

The MDC for soil samples is 40% of the Base Case DCGLs listed in Table 2-1 to account for the Administrative Level DCGL of 10 mremlyr TEDE. Experience has shown that gamma spectroscopy is capable of achieving these results in soil. For some HTD analyses, the radionuclides may not fulfill MDC requirements due to analytic method (e.g., C-14 in soil). In these cases, comparison to the higher value (i.e., 50% of the DCGL)or alternate methods may be used to evaluate the effective concentration relative to the release criteria.37 Connecticut Yankee Atomic Power Company Haddlam Neck Plant Final Status Survey Final Report -Phase II February 2005 Laboratory analysis results would include actual calculated results.Results reported as <MDC were not accepted for FSS. Results included reporting error, observed MDC and data qualifiers as appropriate.

• DEFINE THE BOUNDARIES OF THE SURVEY.Boundaries of the survey: The actual physical boundaries as stated for each survey unit.Temporal boundaries:

Estimated times and dates for the survey.Scanning and sampling in a survey unit is normally performed only during daylight and dry weather.Constraints:

The most common constraints are the weather, the brush and undergrowth, and potential chance of local flooding from seasonal rainfall or tidal flows.* DEVELOP A DECISION RULE The following decisions rules were developed to define a logical process for choosing among alternative actions for the principal study questions associated with each survey unit.Decision Rule (1): If all reported concentrations for residual radioactivity are less than the Administrative Level DCGL and the unity rule has been satisfied for each sample then the survey unit meets both the LTP specified and administrative release criteria.

No further action is required.Decision Rule (2): If the mean of the sum of the ratios of the residual radioactivity from the required number of samples exceeds the operational DCGL, then the survey unit fails the release criteria.Resurvey the area after considering remediation and reclassification.

Decision Rutle (3): If the mean of the sum of the ratios of the residual radioactivity from the required number of samples is less than the operational DCGL, but an individual sample result exceeds the operational DCGL, then conduct the Sign Test in accordance with Procedure RPM 5.1-21, "Perform the Sign Test," (Reference 7.39), and the EMC in accordance with the LTP Section 5.5.1.5. If the EMC and the Sign Test have been satisfied then the survey unit meets both the LTP specified and administrative release criteria.

No further action is required.

If the EMC or the Sign Test has not been satisfied, then remediate the area(s) of elevated activity, resurvey the affected location, and evaluate the results relative to the decision rule.Decision Rule (4): If the potential dose from residual radioactivity in the survey unit is ALARA then no further action is necessary.

If the 38-Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Sunrey Final Report -Phase H February 2005 potential dose from residual radioactivity in the survey unit is not ALARA, then remediate and resurvey.* SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

Residual radioactivity in the survey unit exceeds the release criteria.Type I Error: This is the ax error. This is the error associated with incorrectly concluding that the null hypothesis was rejected.

The LTP has set the a error at 0.05 (5%) unless prior approval is granted from the USNRC to use a less restrictive value. Therefore, a value of 0.05 (5%) was used for survey planning and data assessment for FSS.Type II Error: This is the P error. This is the error associated with incorrectly concluding that the null hypothesis was accepted.

A value of 0.05 (5%) was used for survey planning and data assessment for these survey units.The Lower Bound of the Gray Region (LBGR): The LBGR is set or adjusted during the optimization phase of the DQO process.Relative Shift (A/a): The relative shift will be maintained within the range of 1.0 and 3.0 by adjusting the LBGR in accordance with Procedure RPM 5.1-11.* OPTIMIZE DESIGN Type of statistical test: The Sign Test was selected as the statistical test for FSS.The Sign Test is conservative as it increases the probability of incorrectly accepting the null hypothesis (i.e., the conclusion will be that the survey unit does not meet the release criteria) and will not require the selection or use of a background reference area.Number of samples determined in accordance with Procedure RPM S. 1-12, "Determination of the Numnber of Surface Samples for FSS of Open Land Areas ". (Reference 7.17) The number of samples for systematic Sample Measurement Locations (SMLs) was determined in accordance with Procedure RPM 5.1-12. The LBGR is set to obtain a relative shift in the range of 1 and 3. The locations of the samples were determined using software Visual Sample Plan (VSP)in accordance with Procedure RPM 5.1-14, "Identif ing and Marking Surface Sample Locations for FSS in Open Land Areas" (Reference 7.40), and the appropriate grid spacing for the assigned class (i.e.random or systematic).

Nunber of judgmental samples and locations:

The selection of judgmental or biased samples was at the discretion of the FSS 39 Connecticut Yankee Atomic Power Company Haddeam Neck Plant Final Status Survey Final Report -Phase H February 2005 Engineer.

Locations chosen for sampling were usually areas of interest (small piles, trenches, etc).Number of scan areas and location:

Scan survey areas locations were based on the conditions found during the area inspection or historic evaluation.

Number of samples for Quality Control: The minimum number of quality control samples is 5% of the sample set. The locations for split samples are selected randomly using the Microsoft Excel"RANDBETWEEN" function.Investigation Levels: Investigation levels are established in the LTP for the various classifications.

Investigation levels may prompt additional survey and analysis to identify areas of elevated activity.The investigation level for a soil sample measurement includes individual radionuclide results greater than the Administrative Level DCGL or if the combined radionuclide results exceed the unity rule.For scan measurements, the investigation level is the MDC^N with values determined as a function of ambient background level using guidance in Health Physics TSD BCY-HP-0081, "Scan MDCs for Land Areas using a Two-Inch by Two-Inch Sodium Iodide Detector, (Reference 7.37).Power Curve: The Power Curve, developed using characterization data described in the FSSP and COMPASS software, showed adequate power for the survey design.4.2 Survey Unit Designation and Classification Procedure RPM 5.1-10, "Survey Unit Classification," (Reference 7.41)defines the decision process for classifying an area in accordance with the LTP and MARSSIM. During the FSS of areas submitted for Phase II Final Report, three survey areas, Survey Area 9526, 9528, and 9535, were subdivided and reclassified.

In the Class 3 Survey Area 9526, a soil sample identified Cs-137 above those concentrations found at offsite locations within the vicinity of the HNP. Based on these sample results, a small section of Survey Area 9526 was subdivided and a new Class 2 Survey Unit 9526-0001 was created.The 9526-0001 survey unit included the location where the elevated Cs-137 radioactivity was identified and confirmed.

The land area for 9526-0001 exceeded the LTP size requirements for a FSS Class 2 area and the unit was split into two Class 2 survey units designated as 9526-0001 and 9526-0002.

Several areas were identified in Survey Unit 9528-0000 along the southern border of 9528 that possibly contained plant related radioactive materials.

40 Connecticut Yankee Atomic Powver Company Haddam Neck Plant Final Status Survey Final Report -Phase H February 2005 Initially the area was subdivided into one survey unit, 9528-0001.

This area, located along the Discharge Canal, was approximately 5.75 acres and designated Class 2. During the FSS of survey unit 9528-0001 it was determined that plant-related activity was present in a soil sample located in an area along the Canal Road. Based on area limitations from the LTP, the decision was made to subdivide area 9528-0001, and create three new survey units. Each of the areas resulting from this subdivision, Survey Units 9528-0002, 0003 and 0004, were designated Class 2.For Survey Area 9535, the reclassification and subsequent remedial actions are discussed further in Section 3.0 of this Final Report and describe in detail in the Final Status Survey Release Record for Survey Unit 9535-0001, 9535-0002 and Survey Unit 9806.4.3 Background Determination As previously stated, "background" for soil samples was not calculated nor included in the DCGL comparisons to sample data. However, two documents are referenced, Health Physics TSD BCY-HP-0063,"Background Cs-137 Concentration in Soil," (Reference 7.35), and EPRI Technical Report 1003030, "Determining Background Radiation Levels in Support of Decommissioning Nuclear Power Plants," (Reference 7.42).These documents, respectively, provided justification and support in determining the origins of non-HNP derived Cs-137 and Sr-90 encountered during the sampling campaign.

None of the radionuclide concentrations believed to be non-HNP derived were subtracted from the DCGL comparisons.

During FSS, area scanning, ambient backgrounds were determined and the technician established the "elevated" reading "action level" or investigation limit for that scan area. Instrument backgrounds are discussed in the applicable procedure and in Health Physics TSD BCY-HP-0081. Instrument readings and a discussion about the scan areas are enclosed with each release record in the appendices.

4.4 Final Status Survey Plans The level of effort associated with planning a survey is based on the complexity of the survey and nature of the hazards. To assist the Site Closure FSS Engineers when preparing survey plans to support FSS, guidance is provided in Procedure RPM 5.1-11, "Preparation of Final Status Survey Plans" (Reference 7.7).41 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey' Final Report -Phase H February 2005 4.5 Survey Design 4.5.1 Determination of Number of Data Points The number of samples for SMLs were determined in accordance with Procedure RPM 5.1-12., "Determination of the Number of Surface Samples for FSS of Open Land Areas, " (Reference 7.17).A summary of survey design data points is provided in Table 4-1.Table 4-1 -Number of Surface Samples for FSS Survey Unit Survey Design Biased Investigation Samples Samples' Samples 9523-0000 15 17 26 9524-0000 15 6 1 9525-0000 15 2 9526-0000 15 2 3 9526-0001 17 5 6 9526-0002 17 7 5 9528-0000 14(2) -1 9528-0003 15 4 12 9528-0004 15 5 9535-0001 15 4 -9535-0002 15 3 7 9536-0000 15 -6 9537-0000 15 -7 9538-0000 15 13 9806-0000 31 3 1 1. The collection ofjudgmental samples may be at the discretion of the FSS Engineer.2. Survey Design was for 15 samples. However, one sample was subsequently located in another survey unit.4.5.2 Sample Locations Locations of the samples were determined using software Visual Sample Plan (VSP) in accordance with Procedure RPM 5.1-14.VSP software imports a topographical map of the selected survey area and designates the VSP SMLs with coordinates and bearings based on the Connecticut State Plane System.Pacific Northwest National Laboratory (PNNL) created VSP for the United States Department of Energy. This software is verified and validated by Health Physics TSD BCY-HP-0079, "Use and Verification of Visual Sample Plan, " (Reference 7.43). The TSD contains documentation including a user's manual for VSP Version 1.0 and verification documentation.

For those locations where access was impractical or unsafe, alternate random sample locations were generated and documented.

42 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Sample locations were identified using GPS coordinates in accordance with Procedure RPM 5.1-19, "Global Positioning System (GPS) Calibration, Setup, Operation and Soil Sample Location Identification Instructions," (Reference 7.44), and are consistent with the Connecticut State Plane System. Once located, sample points are physically marked as required by Procedure RPM 5.1-14 and graphically plotted using AutoCAD-LtD software.4.6 Instrumentation The DQO process evaluates the ability of the instrument to measure radioactivity at levels below the applicable DCGL. Referenced by the survey plan, this evaluation is documented in Health Physics TSD BCY-HP-0081. Detector sensitivities are also discussed in Section 5.7 of the LTP.4.6.1 Detector Efficiencies The Eberline E-600 survey instrument coupled with the SPA-3 High Sensitivity Gamma Detector was selected as the primary radiation detection instrumentation for FSS land surveys at HNP.Efficiencies for the SPA-3 Sodium Iodide probe are demonstrated during calibration as the ability to respond as expected when exposed to a gamma radiation field from a NIST traceable Cs-137 source in a Shepard Calibrator Model 28.5. For calibration, the detector is exposed to a 0.4 mR/hr gamma radiation field for a period of 60 seconds. Instrument readings taken during the exposure time are used to calculate a cpm/itR (count per minute/micro-REM) reading, which is compared to a range of accepted values. If the cpm/4R reading is within an acceptable range, the detector may be placed in service. If values are not within the range of acceptable response, the instrument is considered "Out of Service" and sent for evaluation and repair.This method is described in Procedure RPM 4.2-14, "Calibration of the Eberline SPA-3 Smart Probe, " (Reference 7.45).4.6.2 Detector Sensitivities Instrument DQOs include a verification of the ability of the survey instrument to detect the radiation(s) of interest relative to the DCGLSO. DQOs established that the E-600 with the SPA-3 scintillation probe, operated in the data-logging, rate-meter mode, set to audio response, met the detection criteria needed to perform FSS surveys. Table 4-2 provides specifications for the SPA-3 detector.43 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Table 4-2 -SPA-3 Technical Details Specifications Application High sensitivity gamma measurements Detector Type 2" diameter by 2" thick Nal (TI) (5.1 x 5.1cm)Operating 1,000 v nominal Voltage Dead Time 14 ,s nominal Background

-1.2 Mcpm/mR/h Sensitivity (Cs-137)Energy Range -60 keV to 2 MeV Operating

-220 to +1 400 F (-30° to +600 C)Temp Housing Aluminum body Connector CJ-1 Size 2.63" diameter x 11.13" long (6.7 x 28.3 cm)Weight 3.4 lbs. (1.5 kg)Detector sensitivity, or the ability to detect radionuclides of interest at levels acceptable for FSS, is derived as a function of the application of the DQO process, from vendor specifications, instrument calibration, survey technique and a determination of background and MDCR. Unless noted otherwise in the release records, before performing FSS of land areas, a scanning action level was established at each sample location and judgmental scan area based upon the background levels at the location.

The background level was determined by holding the detector at arms length and at waist height near the scan location and the reading logged. An "Action Level" is then established which is equal to the MDCR plus the background counts per minute (cpm) rate.. Any areas identified with readings above the Action Level required investigation and sampling.

Table 4-3, from Health Physics TSD BCY-HP-0081, provides calculated action levels and associated Scan MDCs for Cs-137 and Co-60.The methods described in NUREG-1507, "Minjinunm Detectable Concentrations with Typical Radiation Survey Instntments for Various Contaminants and Field Conditions," December 1997 (Reference 7.46), were incorporated in Health Physics TSD BCY-HP-0081 during the development of this document.4.6.3 Instrument Maintenance and Control Control and accountability of survey instruments were maintained to assure the quality and prevent the loss of data. Health Physics 44 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status SurvAe Final Report -Phase 11 February 2005 Technicians operating the E-600 were trained and qualified through a documented "OJT" program. Procedure RPM 5.2-1,"Setup and Operation of the E-600 Digital Survey Instrument for Scoping, Characterization and Final Status Surveys" (Reference 7.47), provided details on the instrument for field use.Table 4-3 -Action Levels and Associated Background Counts per Minute Background

.Action Scan MDC Scan MDC cpm Level pCi/g Cs-137 pCilg Co-60 2500 714 3214 3.13 0.82 3000 782 3782 3.43 0.90 3500 845 4345 3.70 0.97 4000 903 4903 3.96 1.04 4500 958 5458 4.20 1.10 5000 1010 6010 4.43 1.16 5500 1059 6559 4.64 1.22 6000 1106 7106 4.85 1.27 6500 1152 7652 5.05 1.32 7000 1195 8195 5.24 1.37 7500 1237 8737 5.42 1.42 8000 1278 9278 5.60 1.47 8500 1317 9817 5.77 1.51 9000 1355 10355 5.94 1.56 9500 1392 10892 6.10 1.60 10000 1428 11428 6.26 1.64 10500 1464 11964 6.41 1.68 11000 1498 12498 6.56 1.72 11500 1532 13032 6.71 1.76 12000 1565 13565 6.86 1.80 12500 1597 14097 7.00 1.83 13000 1629 14629 7.14 1.87 13500 1660 15160 7.27 1.91 14000 1690 15690 7.41 1.94 14500 1720 16220 7.54 1.98 15000 1749 16749 7.67 2.01 15500 1778 17278 7.79 2.04 16000 1807 17807 7.92 2.08 16500 1835 18335 8.04 2.11 17000 1862 18862 8.16 2.14 17500 1890 19390 8.28 2.17 18000 1916 19916 8.40 2.20 18500 1943 20443 8.51 2.23 19000 1969 20969 8.63 2.26 19500 1995 21495 8.74 2.29 45 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Background MDCR cpm Action Scan MDC Scan MDC cpm, P Level pCi/g Cs-137 pCilg Co-60 20000 2020 22020 8.85 2.32 20500 2045 22545 8.96 2.35 21000 2070 23070 9.07 2.38 21500 2094 23594 9.18 2.41 22000 2119 24119 9.28 2.43 22500 2143 24643 9.39 2.46 23000 2166 25166 9.49 2.49 23500 2190 25690 9.59 2.52 24000 2213 26213 9.70 2.54 24500 2236 26736 9.80 2.57 25000 2259 27259 9.90 2.59 25500 2281 27781 9.99 2.62 26000 2303 28303 10.09 2.65 26500 2325 28825 10.19 2.67 27000 2347 29347 10.28 2.70 27500 2369 29869 10.38 2.72 28000 2390 30390 10.47 2.75 28500 2411 30911 10.57 2.77 29000 2433 31433 10.66 2.79 29500 2453 31953 10.75 2.82 30000 2474 32474 10.84 2.84 30500 2495 32995 10.93 2.87 31000 2515 33515 11.02 2.89 31500 2535 34035 11.11 2.91 32000 2555 34555 11.20 2.94 32500 2575 35075 11.28 2.96 33000 2595 35595 11.37 2.98 33500 2614 36114 11.45 3.00 34000 2634 36634 11.54 3.03 34500 2653 37153 11.62 3.05 35000 2672 37672 11.71 3.07 35500 2691 38191 11.79 3.09 36000 2710 38710 11.87 3.11 36500 2729 39229 11.96 3.14 37000 2748 39748 12.04 3.16 37500 2766 40266 12.12 3.18 38000 2785 40785 12.20 3.20 38500 2803 41303 12.28 3.22 39000 2821 41821 12.36 3.24 39500 2839 42339 12.44 3.26 40000 2857 42857 12.52 3.28 46 Connecticut Yankee Atomic Power Company Hadldam Neck Plant Final Status Survey Final Report -Phase II February 2005 4.6.4 Instrument Calibration Calibration of the Eberline E-600 and SPA 3 was performed every six months with a NIST traceable Cs-137 source, Source #CY-33 (120 mCi -09/04/85) in a Shepard Calibrator Model 28.5. Survey instruments are "response checked" daily before issue and after the instruments are used with a 5 pCi Cs-137 "button source" serial number E212YA.4.7 Survey Methodology 4.7.1 Scan Surveys The LTP specifies the minimum amount of scanning required for each class as summarized in Table 4-4. The total fraction of scanning coverage is determined during the DQO process with the amount, and location(s) based on the likelihood of finding elevated activity during Final Status Survey.Table 44 -Scan Coverage Survey Unit Required Scanning Coverage Fraction Classification Class 1 100%Outdoor areas, floors, or lower walls of Class 2 buildings:

10% to 100%Upper walls or ceilings:

10% to 50%Class 3 Judgmental Upon selection, at the time of FSS, each scan area was located with GPS and marked. The area was divided into manageable 1-meter wide strips with a length approximately 8 to 10 meters long. The strips are then mapped and scanned 100%. Areas with elevated readings are marked, sampled and a 1-meter radius around each sample location is scanned and documented.

The probe is positioned as close to the ground as possible and is moved at a scan speed of about 0.5 meters per second. Table 4-5 provides a summary of the area scanned during FSS.47 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company iladdam Neck Plant Final Status Surv4e' Final Report -Phase H February 2005 Table 4-5 -Summary of Total Area Scanned Survey Survey Unit Area in Area Scanned Unit Classification Square are Meters % Scan 9523-0000 3 151,364 502.3 0.33 9524-0000 3 61,975 1,949.8 3.2 9525-0000 3 28,000 186.7 0.7 9526-0000 3 444,700 1,000 0.2 9526-0001 2 6,504 663 10.2 9526-0002 2 6,068 675.2 11.1 9528-0000 3 508,000 783 0.15 9528-0003 2 10,000 1,028 10.3 9528-0004 3 3,100 388 12.5 9535-0001 1 1,860 1,860 100 9535-0002 2 3,320 3,320 100 9536-0000 3 1,536 1,536 100 9537-0000 2 850 850 100 9538-0000 2 1,500 195 13 9806-0000 A 5,180 Subsurface Not____ ___ ___ _ _ ____ ___ ___ _ _ ____ ___ ___ _ _ ____ ___ ___ ___ ap p licab le '1. Excavated soils and materials were scanned prior to backfill.For random and biased sample locations, the scan area for samples was a circle of one (1) meter radius around the sample flag. The probe was positioned as close to the ground as possible and was moved at a scan speed of about 0.5 meters per second.During the scanning, the technician recorded data in a "Daily Survey Journal." This log documented field activities and other information pertaining to the final survey.4.7.2 Soil Sampling In accordance with the FSS plan and Procedure RPM 5.1-3,"Collection of Surface and Subsurface Soil, Shoreline Sediment, Asphalt and Liquid samples for Scoping, Clharacterization and Final Status Survey, " (Reference 7.53), the FSS technician collected surface soil or asphalt samples in random, systematic, and biased locations.

Each sample location was documented, along with soil conditions and observations, and a chain of custody developed to maintain sample integrity.

4.7.3 Total Surface Contamination Measurements"Total Surface Contamination Measurements" refers to the FSS of structural surfaces such as walls, floors, and ceilings.

During this phase of FSS and submittal, no areas containing structures subject to FSS were surveyed.48 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 Based on historic data and potential for use, approximately 20% of the cable vaults in Survey Area 9526 were surveyed.

The surveys did not identify any areas that contained detectable plant related radionuclides, thus meeting the unconditional release criteria for HNP.4.8 Quality Control Surveys Procedure RPM 5.1-24, "Split Sample Assessment for Final Status Survey," (Reference 7.49), establishes a method for evaluating Quality Control (QC) split samples collected in support of the FSS program.Quality Control split sample data is assessed on criteria taken from the USNRC Inspection Manual, Inspection Procedure 84750, "Radioactive Waste Treatment and Effluent and Environmental Monitoring," March 1994 (Reference 7.50).A minimum of five percent (5%) of the sample locations used in the FSS design were selected randomly using the Microsoft Excel"RANDBETWEEN" function and submitted as "splits." Most splits taken for FSS were field replicates, that is, samples obtained from one location, homogenized, divided into separate containers, and treated as separate samples. These samples were used to assess errors associated with sample heterogeneity, sample methodology, and analytical procedures.

It is desirable that when analyzed, there is agreement between the splits resulting in data acceptance.

If there is no agreement between the samples, the FSS Engineer evaluates the magnitude and impact on sample plan design, the implementation and evaluation of results as well as the need to perform confirmatory sampling.

When the FSS Engineer has determined that the discrepancy affects quality or is detrimental to the FSS program then the discrepancy warrants the issuance of a Condition Report.To maintain the quality of the FSS, isolation and control measures are implemented throughout FSS activities until there is no risk of recontamination from decommissioning or the survey area has been released from the license. Following FSS, until the area is released, a semi-annual surveillance is performed on FSS completed survey units.This includes an inspection of area postings, inspection of the area for signs of dumping or disturbance and some sampling from selected locations.

In the event that isolation and control measures were compromised, a follow-up survey may be performed after evaluation.

5.0 SURVEY FINDINGS Procedure RPM 5.1-23, "Data Quality Assessment," (Reference 7.51), provides guidance to Site Closure personnel to interpret survey results using the DQA process during the assessment phase of FSS activities.

Although intended for FSS 49 Connecticut Yankee Atomic Power Company Hadd~am Neck Plant Final Status Survey Final Report -Phase H February 2005 activities, the DQA process can be used for other radiological data collection activities (e.g., characterization and remedial action surveys).

The extent to which of the DQA process applies for these surveys will be commensurate with the objectives of the particular survey.The DQA process is the primary evaluation tool to determine that data are of the right type, quality and quantity to support the objectives of the sample plan (e.g., FSSP and the requirements of the HNP LTP). The five steps of the DQA process are:* Review the sample plan DQOs and the survey design,* Conduct a preliminary data review,* Select the statistical test,* Verify the assumptions of the statistical test, and* Draw conclusions from the data.Data validation descriptors described in MARSSIM Table 9.3 was used during the DQA process to verify and validate collected data as required by the FSSQAP.5.1 Survey Data Conversion During the data conversion, the FSS Engineer will evaluate raw data for problems or anomalies encountered during the FSSP activities (sample collection and analysis, handling and control, etc.) including the following:

• Recorded data,* Missing values,* Deviation from established procedure, and* Analysis flags.Once resolved, initial data conversion, which is part of preliminary data review was performed and consists of converting the data into units relative to the release criteria (i.e., pCi/g), and calculating basic statistical quantities (e.g., mean, median, standard deviation).

Table 5-1 provides a summary of the data analysis.50 Connecticut Yankee Atomic Powver Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase 11 February 2005 Table 5-1 -Summary of Statistical Analysis Radionuclide Statistical Summary (pCi/g)Cs-137 Co-60 Survey Unit Class Samples JDCGL-3.16 Ci/g) CGA-1.52 pCng)Ma en Standard NIStandard Max Mean Deviation Max Mean Deviation 9523-0000 3 15 3.83 1.15 1.10 0.0728 0.0118 0.0274 9524-0000 3 15 0.646 0.175 0.221 9525-0000 3 15 0.0486 0.00729 0.0201 X -9526-0000 3 15 1.31 0.703 0.290 --_9526-0001 2 17 1.87 0.923 0.515 0.0298 0.00205 0.0156 9526-0002 2 17 3.02 0.769 0.455 0.0778 O.0O049 0.0219 9528-0000 3 14 0.943 0.589 0.229 --9528-0003 2 15 0.562 0.101 0.158 0.0682 0.00301 0.0301 9528-0004 2 15 0.875 0.168 0.268 0.0318 -0.0015 0.0157 9535-0001 1 15 0.313 0.642 0.508 0.00852 0.0288 0.0319 9535-0002 2 15 0.66 0.169 0.143 0.014 0.00565 0.0103 9536-0000 2 15 0.152 0.0361 0.049 0.0288 0.00017 0.0150 9537-0000 2 15 0.0833 0.0293 0.0273 --9538-0000 2 15 0.337 0.170 0.0915 0.0457 0.00479 0.0171 9806-0000 A 31 0.37 0.0964 0.103 0.0261 0.00464 0.00963 Note: Some Co-60 statistics not applicable to survey design. ( -)5.2 Survey Data Verification and Validation Items supporting DQO sample design and completeness and consistency.

This includes: data are reviewed for* Classification history and related documents,* Site description,* Survey design and measurement locations,* Analytic method and detection limit and that the required analytical method(s) are adequate for the radionuclides of concern,* Sampling variability has been provided for the radionuclides of interest,* QC measurements have been specified,* Survey and sampling result accuracy has been specified,* MDC limits,* Field conditions for media and environment, and* Field records.51 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Sunvy Final Report -Phase 11 February 2005 Documentation, as listed, is reviewed to verify completeness and that it is legible:* Field and analytical results,* Chain-of-custody,* Daily Survey Journals,* Instrument issue, return and source check records,* Instrument downloads, and* Measurement results relative to measurement location.After completion of these previously mentioned tasks, a Preliminary Data Review record was initiated.

This record serves to verify that all data are in standard units in relation to the DCGLs and requires the calculation of the statistical parameters needed to complete data evaluation.

Included, at a minimum, are the following parameters:

• The number of observations (i.e., samples or measurements),* The range of observations (i.e., minimum and maximum values),* Mean,* Median, and* Standard deviation.

Considerations as an optional aid to evaluate the data set are the coefficient of variation, measurements of relative standing, such as percentile, and other statistical applications as necessary (frequency distribution, skew etc.). Finalization of the data review consists of graphically displaying the data in distributions and percentiles plots.5.3 Evaluation of Number of Sample/Measurement Locations in Survey Units An effective tool utilized to evaluate the number of samples collected in the sampling scheme is the Retrospective Power Curve generated by COMPASS. The Retrospective Power Curve shows how well the survey design achieved the DQOs. For reporting purposes, all release records include a Retrospective Power Curve analysis indicating that the sampling design had adequate power to pass FSS release criteria (i.e. adequate number of samples was collected).

The Sign Test was the selected statistical test for all release records submitted in this report. This test, performed in accordance with Procedure 52 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase H February 2005 RPM 5.1-21, along with the Retrospective Power Curve demonstrates survey design adequacy.

If the data passes the Sign Test and Retrospective Power Curve, the null hypothesis is rejected and the survey unit can be released with no further actions required.

For reporting purposes, all Survey Unit Release Records passed the Sign Test indicating that the sampling design was adequate (i.e. adequate number of samples was collected).

The need to apply the EMC was evaluated and determined to be non-applicable for survey areas submitted in this report.5.4 Comparison of Findings with Derived Concentration Guideline Levels Upon completion of the Sign Test, the results were compared to the decision rule provided in the FSSP. Based on the comparison, the instructions in the FSSP are implemented and may include no action, re-survey or investigate.

Investigations are accomplished through the issue of an addendum to the FSSP. When the investigational criteria (e.g. sample results exceeds Administrative Level DCGLIoil) is exceeded a "resample" is taken to verify lab results. If verified, several actions may occur at the discretion of the FSS Engineer.

The most conservative response is a sample plan designed to bound the elevated area with multiple samples. Information collected from this type of plan provides additional information for statistical analysis and may stimulate further considerations to remediate and resurvey.

It should be noted that one or more samples exceeding the Administrative Level DCGL may not constitute failure of the survey unit and a viable option is to do nothing more in this area.Areas discovered with concentrations of radionuclides exceeding the 10 mrem/yr Administrative Level DCGL may require remedial action and would therefore need another FSSP upon completion of remediation.

Another consideration is that, although verified, the sample reflects a mechanism for concentrating the radionuclide of concern, and additional sampling would only produce the same results. The engineer, through consensus, would take no further action and provide justification as needed. This situation was encountered during FSS in the wetlands and rocky slopes where a natural mechanism for concentrating Cs-137 exists.Researching this event shows that this type of occurrence is common and well documented in other regions of the United States.The "no-action" response is the most desirable condition.

In general, a no action response usually means that the sample plan was successful and the survey unit passes the release criteria.

The assigned FSS Engineer will compile the data, re-verify the results, and produce the Survey Unit Release Record as the product of the FSS.53 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase 11 February 2005 5.5 USNRC/lndependent Verification Team Findings The Environmental Survey and Site Assessment Program (ESSAP) of the Oak Ridge Institute for Science and Education (ORISE) performed confirmatory survey activities on selected open land survey units at the HNP site during the period of September 29 through October 1, 2003 and March 16 through 17, 2004. Survey units included in the scope of the Independent Verification Team (IVT) survey are provided in Table 5-2.Survey units 9525-0000, a paved site road, and 9528-0004, which is mostly a rocky ledge and road right of way, were not included. (Sample collection points for 9525 are below roadway pavement.)

Survey Units 9524-0000, 9535-0001, 9535-0002 and 9806 were not surveyed as CYAPCO was in the process of performing the FSS of these survey areas at the time of the IVT survey.Table 5-2 -IVT Confirmatory Survey I Survey Units I 9523-0000 9531-0000 9526-0000 9532-0000 9526-0001 9536-0000 9526-0002 9537-0000 9528-0000 953+8-0000 9528-0003 The USNRC "Integrated Inspection Report 05000213/2004001," dated September 20, 2004, (Reference 7.52) and the ORISE Revised Final Report, "Confirmatory Survey of Open Land Area Survey Units at the Connecticut Yankee Haddam Neck Plant, Haddani, Connecticut" (Reference 7.58), found that the results of the survey activities confirmed that the radiological conditions of open land area survey units that were part of these confirmatory survey activities met the approved site-specific DCGLs for Co-60 and Cs-137 and the survey areas were appropriately classified.

The results of the laboratory analysis on the three samples collected in Survey Unit 9535-0001 indicated that the CYAPCO contractor laboratory data were consistent and in agreement with ESSAP's analytical results.6.0

SUMMARY

The site release criteria for the Haddam Neck site meet the Title 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 54 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels that are ALARA.As demonstrated in the Survey Unit Release Records, the fifteen (15) areas submitted in this phase met the conservatively designed Administrative Level DCGL of 10 mrem/yr criteria, thereby achieving ALARA.

7.0 REFERENCES

7.1 Health Physics Technical Support Document CY-HP-0193, "Assessment of Existing Groundwater Dosefor Phase II Release Areas of the Final Status Suvey Report. " 7.2 Haddam Neck Plant License Termination Plan (LTP)7.3 NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)7.4 ISC-QGP-00001-003, Final Status Survey Quality Assurance Plan (FSSQAP)7.5 RPM 5.1 -00, Final Status Survey Program 7.6 NUREG-1757, Volume 2, Consolidated NMSS Decommissioning Guidance-Characterization, Survey, and Determination of Radiological Criteria 7.7 RPM 5.1-22, Preparation of Final Status Survey Reports 7.8 W. Norton (CYAPCO) to USNRC, "Letter of Intent Concerning the Release of the East Site Grounds from the Part 50 License," dated April 29, 2004 (CY-04-069

/ Docket No. 50-213)7.9 J. D. Donahue (USNRC) to K. Heider (CYAPCO), "Haddam Neck Plant -Issuance of Amendment RE: Approval of License Termination Plan," dated November 25, 2002 7.10 T. Smith (USNRC) to W. Norton (CYAPCO), "Haddam Neck Plant -Release of East Site Grounds from Part 50 License," dated September 01, 2004 7.11 RPM 5.1-11, "Preparation of Final Status Survey Plans" 7.12 "Historical Site Assessment Supplement" (HSA) June 30, 2000 7.13 "Characterization Report"- January 2000 55 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 7.14 RPM 5.4-0 "Site Closure Training Program" 7.15 RPM 5.1-4, "Control and Accountability of Portable Survey Instruments for Scoping, Characterization and Final Status Surveys" 7.16 CYAPCO Procedure 000-GEN-0000-00061-000, "Work Plan and Inspection Record" (WPIR)7.17 Procedure R5.1-12, "Determination of the Number of Surface and Subsurface Samples for FSS of Open Land Areas." 7.18 RPM 5.1-24, "Split Sample Assessment for Final Status Survey" 7.19 RPM 5.1-5, "Chain of Custody for Final Status Survey Samples" 7.20 RPM 5.1-23, "Data Quality Assessment" 7.21 "Quality Assurance Prograi for Haddam Nuclear Plant, " (CYQAP)7.22 Quality Surveillance Report QSR-04-072-CY, March 9 -April 8, 2004 7.23 Quality Surveillance Report QSR-04-073-CY, June 7 -June 16, 2004 7.24 Quality Surveillance Report QSR-04-078-CY, April -June 2004 7.25 CYAPCO, "Final Status Survey Program Assessment Report" June, 2004 7.26 Condition Report 04-0810 7.27 Condition Report 04-0811 7.28 CYAPCO Nuclear Safety Audit Report, CY-04-A09-01, "Final Site Survey (FSS)/License Termination Plan (LTP), " November, 2004 7.29 Condition Report 04-1298, "Failure to Process timely License Basis Document Change Request (LBDCR) for the License Termination Plan (LTP) changes" 7.30 US NRC NUREG CR-5 849 "Manualfor Conducting Radiological Surveys in Support of License Termination

" 7.31 "Results of Scoping Survey for CYAPCO 's Haddam Neck Plant," CYAPCO 1998 7.32 "NRC Historical Review Team Report -Radiological Control and Area Contamination Issues at Haddam Neck" USNRC, dated March 26, 1998 56 Connecticut Yankee Atomic Power Company Haddlam Neck Plant Final Status Survey Final Report -Phase ! February 2005 7.33 Health Physics Department Technical Support Document BCY-HP-0078,"ALARA Evaluation of Soil Remediation in Support of Final Status Survey 7.34 RPM 5.1-16, "Turnover and Control of Open Land Areas for Final Status Survey." 7.35 Health Physics Technical Support Document BCY-HP-0063,"Background Cs-137 Concentration in Soil." 7.36 EPRI Technical Report 1003030, "Determining Background Radiation Levels in Support of Decommissioning Nuclear Power Plants." 7.37 Health Physics Technical Support Document BCY-HP-0081, "Scan MDC of Land Areas using a 2-inch by 2-inch Sodium Iodide Detector." 7.38 Health Physics Technical Support Document BCY-HP-0 150,"Investigation of Rock Outcropping Exhibiting Elevated Activity," 7.39 RPM 5.1-21, "Perform the Sign Test" 7.40 RPM 5.1-14, "Identifying and Marking Surface Sample Locations for FSS in Open Land Areas" 7.41 RPM 5.1-10, "Survey Unit Classification" 7.42 EPRI Technical Report 1003030, "Determining Background Radiation Levels in Support of Decommissioning Nuclear Power Plants" 7.43 Health Physics Technical Support Document BCY-HP-0079, "Use and Verification of Visual Sample Plan" 7.44 RPM 5.1-19, "Global Positioning System (GPS) Calibration, Setup, Operation and Soil Sample Location Identification Instructions" 7.45 RPM 4.2-14, "Calibration of the Eberline SPA-3 Smart Probe" 7.46 NUREG-1507, "Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions" December 1997 7.47 RPM 5.2-1, "Setup and Operation of the E-600 Digital Survey Instrument for Scoping, Characterization and Final Status Surveys" 7.48 RPM 5.1-3, "Collection of Surface and Subsurface Soil, Shoreline Sediment, Asphalt and Liquid samples for Scoping, Characterization and Final Status Survey" 57 Connecticut Yankee Atomic Power Company Haddam Neck Plant Connecticut Yankee Atomic Power Company iladdam Neck Plant Final Status Survey Final Report -Phase II February 2005 7.49 RPM 5.1-24, "Split Sample Assessment for Final Status Survey" 7.50 USNRC Inspection Manual, Inspection Procedure 84750, "Radioactive Waste Treatment and Effluent and Environmental Monitoring," March 1994 7.51 RPM 5.1-23, "Data Quality Assessment" 7.52 USNRC "Integrated Inspection Report 05000213/2004001," dated September 20, 2004 7.53 ORISE Revised Final Report -" Confirmatory Survey of Open Land Area Survey Units at the Connecticut Yankee Haddam Neck Plant, Haddam, Connecticut," (Docket No. 50-0213, RFTA No. 03-0008 58 Connecticut Yankee Atomic Power Company Haddam Neck Plant Final Status Survey Final Report -Phase II February 2005 8.0 APPENDICES Al Survey Unit Release Record 9523-0000, Southwest Wetland Area A2 Survey Unit Release Record 9524-0000, South Site Grounds A3 Survey Unit Release Record 9525-0000, Southeast Site Road A4 Survey Unit Release Record 9526-0000, Northeast Mountain Side A5 Survey Unit Release Record 9526-0001, Northeast Mountain Side A6 Survey Unit Release Record 9526-0002, Northeast Mountain Side A7 Survey Unit Release Record 9528-0000, Southeast Mountain Side A8 Survey Unit Release Record 9528-0003, Southeast Mountain Side A9 Survey Unit Release Record 9528-0004, Southeast Mountain Side A10 Survey Unit Release Record 9535-0001, Southeast Landfill Area Al l Survey Unit Release Record 9535-0002, Southeast Landfill Area A12 Survey Unit Release Record 9536-0000, Construction Pile Near Rifle Range A13 Survey Unit Release Record 9537-0000, Pernitted Landfill Area A14 Survey Unit Release Record 9538-0000, Material Storage Area A15 Survey Unit Release Record 9806-0000, Southeast Landfill-9535 59