Text

Response to NRC RAIs on FSS Final Report Nos. 1 and 2
	ML050970076
Person / Time
Site:	Maine Yankee
Issue date:	02/16/2005
From:	Meisner M; Maine Yankee Atomic Power Co
To:	; Document Control Desk, NRC/FSME
References
	MN-05-006, RA-05-008
	Download: ML050970076 (131)
	v • d • e

Maine Yankee 321 OLD FERRY RD.

WISCASSET, ME 04578.4922 February 16, 2005 MN-05-006 RA-05-008 Proposed Change No. 218, Supplement 14 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555

References:

Subject:

(1)

License No. DPR-36 (Docket No. 50-309)

(2)

Maine Yankee Letter to USNRC, MN-04-020, dated March 15, 2004, License Amendment Request: Release of Non-ISFSI Site Land, Proposed Change No. 218 (3)

USNRC Letter to Maine Yankee, dated January 7, 2005, Receipt of Maine Yankee's Response to Request for Information on Final Status Survey Report Supplements I and 3 (4)

USNRC Letter to Maine Yankee, dated January 19, 2005, Request for Additional Information (RAI) Regarding Final Status Survey (FSS)

Supplement No. 2.

Rcsponsc to NRC RAI's on FSS Final Report Nos. I and 2 On March 15, 2004, Maine Yankee submitted a request for amendment (Reference No. 2) to the facility operating license (Reference No. 1) pursuant to 10 CFR 50.90 and in accordance with the NRC Approved License Termination Plan (LTP) for Maine Yankee, to indicate NRC's approval of the release of the Non-ISFSI site land from the jurisdiction of the license. In support of that request, Maine Yankee supplied the information required in LTP section 1.4.2 and 5.9.3. The land area associated with the license amendment request included the entire non-ISFSI portion of the site land. The dismantlement and survey information for the survey units is being submitted to the NRC in FSS Final Reports.

In Reference Nos. 3 and 4, USNRC requested additional information on technical information submitted in FSS Final Report Nos. I and 2. This additional information is provided in an attachment to this letter.

If you have any questions, please contact me.

Sincerely, 71L" M.51M.

Michael J. Meisner I

Vice President & Chief Nuclear Officer

/J fyOS5 oI

UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Page 2 of 2

Attachment:

Maine Yankee Response to NRC Request for Additional Information (RAI)

Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 cc:

Dr. R. R. Bellamy, NRC Region I Mr. D. R. Lewis, Esq., Shaw Pittman Mr. C. Pray, State of Maine, Nuclear Safety Advisor Mr. P. J. Dostie, State of Maine, Division of Health Engineering Mr. D. Gillen, NRC Acting Director, Division of Waste Management Mr. M. Rosenstein, USEPA Region I Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. J. Buckley, NRC NMSS Project Manager, Decommissioning Mr. M. Roberts, NRC Region I Mr. R. Shadis, Friends of the Coast

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Surncy (FSS) Final Report Nos. I and 2 Introduction Maine Yankee's response to the remaining NRC RAI questions from FSS Report Nos. 1 and 2 contain elements common to more than one question. Rather than repeat the common elements in response to each question, those elements are discussed below and referenced, where appropriate, in specific question responses.

Gamma Scan 30K cpm Criterion During a September 9, 2004 meeting with the NRC, Maine Yankee agreed to include a statement in relevant release records as follows: "All basement surfaces were remediated to the 30,000 cpm gross gamma activity criterion value to detect and remove contamination at depth...".

Subsequently, the NRC reviewers have been onsite to review available records associated with these remediation surveys. Maine Yankee clearly indicated at the September 9, 2004 meeting that, since these surveys were performed as remediation surveys, not final status surveys, the records of these surveys were not required to be kept and might be difficult to retrieve.

Notwithstanding, Maine Yankee was able to produce these remediation survey records for most of the scan surfaces and has now been able to produce the records for more than 99% of the scan surfaces. Maine Yankee believes that the intent of the statement quoted above has been extended by the NRC beyond the context of the meeting agreement. Maine Yankee provides the following clarification. The 30,000 cpm (30K cpm) criterion:

1. Up to this point, has not been part of the License Termination Plan.

2. Applies only to concrete surfaces that receive a final status survey. Therefore, the criterion has no bearing on concrete surfaces that no longer exist, bedrock surfaces or metallic surfaces.

3. Is not exclusive nor necessary provided other technical means are applied (e.g., technical judgment that an elevated gamma reading is clearly due to adjacent radiation sources, analysis of sampling results, etc.). The 30K gamma criterion was meant to be informed by, and no more unique than, the various approaches allowed in the LTP/MARSIMM for final status survey measurements (e.g., sampling in the place of beta scans).

4. Is qualitative and was not part of, but goes beyond the NRC approved LTP dose model.

Minor variations call for technical judgment, not necessarily more remediation.

5. Is applied during remediation surveys. Use of the criterion does not imply a more rigorous treatment of remediation survey records than that required by the LTP.

6. Is used as a remediation guideline and is not meant to be applied in a manner more restrictive than the application of a DCGL (eg. evaluation may be applied to accept areas exceeding the DCGL without further remediation)

Page 1

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 The LTP has been clarified, under I OCFR50.59, to reflect the above (See Appendix M for the change to the LTP).

Bedrock As noted above, the 30K gamma criterion has no applicability to bedrock. Neither does the LTP provide a DCGL for bedrock.

Maine Yankee evaluated the fate and transport of Cs-137 and Co-60 contamination through bedrock at Maine Yankee 'with known groundwater chemistry parameters. This evaluation concluded that negligible Co-60 would be transported because the Co-60 would irreversibly co-precipitate with iron on rock fracture surfaces. The evaluation also concluded that Cs-137 would have a finite but low mobility within the bedrock. Finally, the evaluation constructed a worst-case scenario and predicted relatively low concentrations of Cs-l 37 in a postulated residential well. Maine Yankee submitted this evaluation as part of the LTP by reference to the NRC on August 28, 2002 MN-02-037 "Maine Yankee Addendum Report Regarding Site Hydrogeology" (Reference No. 1). NRC approved the LTP on February 28, 2003 (Reference No. 3).

Nonetheless, for reasons of its owvn, Maine Yankee has chosen on occasion to take bedrock samples and analyze them independent of LTP requirements. Some of those analyses are discussed below in response to individual RAI questions, but only as a matter of interest. The compliance of bedrock surfaces with the LTP has already been demonstrated by Reference 1.

NRC RAI on FSS Report No. I - RAI No. 2. Gamma Survey Results LTP Section 5.5.1 (a) and (d) requires surveys and/or sampling of structures, and the cracks and itvall/floor interfaces. Gamma surveys and/or sampling of concrete cracks and wall/floor interfaces are critical measurements for ensuring that these are not pathis'ays for the movement of residual radioactivity under foundations and in structures buried onsite lwhich may become a fiture source term contributing to the groundivater dose. The gamma survey results provide the pre-requisite information justifying the License Termination Plan (LTP) Final Status Survey Report (ESSR) requirement to provide surface measurements to demonstrate compliance with the dose criteria.

At the September 9, 2004, meeting, NRC and Maine Yankee agreed that the gamma surveys provided critical information for determining the contamination at depth in cracks and wtall!

floor interfaces, andfor ensuring that there is no signifi cant residual radioactivity under remaining foundations that Would be a source term for groundwvater contamination. Maine Yankee agreed, that since gamma surveys wvere performed during the reemediation phase, and l vere performed prior to turnover of the areas for final surveys, FSSRs wtyould include a statement indicating that the below grade and undergroundfoundations, and structures wvere surveyedfor gamma radiation and wvere found to be less than 30K cpm (J.5XBackgroznd).

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Maine Yankee Responsc to NRC Request for Additional Information (RAI) Regarding Final Status Surney (FSS) Final Report Nos. 1 and 2 On page 8 of 16 of the second re-submittal of Supplement I Final Status Surveys - Release Records, "Release of Non-ISFSI Site Land - Addendum to FSS Report No. 1, " dated October 14, 2004, it states that, "All basement surfaces were remediated to the 30, 000 cpin gross gamma activity criterion value to detect and remove contamination at depth... " ArRC staff attempted to verify Maine Yankee 's statement during an October 24 -28, 2004, site visit by reviewing gamma survey information supporting the FSSRsfor survey units included in Supplements 1 1and 2.

Maine Yankee did not provide the gamma surveys as requested, citing the difficulty in retrieving the records. Instead, Mfaine Yankee provided the surveys referenced in NRC's letter to Maine Yankee dated ATovember 4, 2004. These Supplement I gamma survey records document that only one of the nine Survey Units examined met the 30K cpm criteria. The remaining eight Supplement I survey units had numnerous areas exceeding the 30K cpm gross gamma criterion, or no survey information was provided.

Maine Yankee 's response to NRC RAI's on Supplement 1 states that half of areas with survey results exceeding the 30K cpm gamma criteria no longer exist, and 25% of the areas Here re-surveyed afterfiurther remediation andfound to be below the limit. However, this means that approximately 25% of the areas exceed the 30K cpm gamma criteria. Maine Yankee 's response states that most of these areas "reflect minor (and non-significant) deviations from the 30K CPM criteria. " It is not clearfrom Maine Yankee 's response which ofthe areas are significant. In addition, the response does not include a discussion about why many areas above 30K cpm were left, and what the potential dose impactfrom these areas is. The staff does not agree that Maine Yankee 's apparentfailure to meet the 30K cpm gamma criteria is trivial.

In addition, Maine Yankee 's response provides a technical justification based on surface beta mneasuremnents performed with gasflowv proportional detectors which are sensitive primarily to beta radiation and ineffective for gamma radiation. The technical justification addresses the detection of contamination at depth based on surface measurements, which is inconsistent with the rationale for performing gamma surveys to determine contamination in cracks and crevices.

In Maine Yankee's analysis, gamma measurements are compared to surface measurements and are treated as "trivial" based on the size of the elevated contaminated area. The analysisfails to address that the principal reasonfor performing the gamma surveys is to determine the depth of the contamination. It is industry practice to decontaminate all surface areas exceeding the 1.5X background radiation criteria. Any areas exceeding J.5Xbackground are decontaminated and re-surveyed until the area meets the release criterion. By performing the additional decontamination, cracks and crevices can be eliminated as a pathway for uander building contamination and a potential sourcefor groundwater contamination.

As previously discussed with Maine Yankee, it is the NRC staff's position that each of the gamma survey areas exceeding the 1. 5X background criteria, despite its size, has the potential for providing a pathwayfor undetected residual radioactivity under thefoundations and structures. The contaminated soil cotild impact the State imposed groundwlater dose limit of 4 mremn/year. The potentialfor under-building contamination cannot be technically justified or modeled until the extent of the residual activity is determined by actual measurement.

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Maine Yankce Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 In summary gamma surveys documenting that survey units do not exceed 1.5X background radiation levels (30K cpm) are one of the bases for Maine Yankee 's FSS surface release criteria.

The staff understands that gamma survey results are not required to be reported in the FSSRs.

Howsever; the staff intends to verify, through the review of gamma survey results, Maine Yankee 's statement that, "All basement surfaces wvere remediated to the 30, 000 cpm gross gamnna activity criterion value to detect and remove contamination at depth...

WVithout this verification, or an acceptable justification as to why Maine Yankee does not need to meet the 30K cpm gamma criteria, the staff wtill not approve Supplement I of Maine Yankee 's FSSR.

Maine Yankee Response:

For accuracy, Maine Yankee notes that it never characterized any measurement results as "trivial".

In response to NRC RAIs on FSS Report Nos. 1 and 2 (Reference Nos. 10, 11, 14 and 15), MY has performed a detailed review of the gamma remediation survey records as well as the process used to perform the surveys. In summary, a massive campaign was mounted to remediate concrete basement surfaces to the qualitative gamma guideline notwithstanding the fact that the guideline is not required by any approved licensing document or regulation. While there is no requirement to document any remediation survey, regardless of type, substantial documentation of gamma remediation surveys was completed. This documentation clearly demonstrates that gamma surveys were used extensively and that the administrative goal to apply the guideline was fully met. To provide insight into the discussion of the gamma survey results, the survey and remediation process is briefly described below.

In the Spray Building, concrete surfaces were scanned for beta with a 43-68 detector to check for areas above 3000 cpm. Any areas >3000 cpm were painted blue and remediated. Following the 43-68 surveys and remediation, the area was gamma scanned looking for areas >30,000 cpm by SPA-3. Such areas would be painted blue. In the PAB Building, only gamma surveys were used to direct remediation activities. The process of collecting and using the remediation survey data was as follows:

1.

Each evening the RP techs would survey areas that had been remediated that day and prepare a map showing the survey results.

2.

Each morning the Remediation Team (management and supervisory level personnel) would meet to review the current survey results and decide which areas were satisfactory and which required further remediation. New areas were painted blue and the process was repeated.

3.

For the vast majority of the grids, the results of final post-remediation scans were documented on a survey form. However, when a grid or area was nearing completion (especially for small areas), the remediation worker might have the tech in the field check an area and if the area was less than 30,000 cpm, the tech might pass the area without documenting the final result. This was more likely during the early phases of the Spray Page 4

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 Building remediation. As the remediation progressed through the Spray and PAB Buildings, the documentation of the remediation gamma surveys became more rigorous to provide more detailed information for remediation planning.

Records of gamma scans exist for all areas of the Spray Building (excluding the penetrations in SU-9, which are a special case discussed below). The records indicate that there are only eight small areas where the last documented remediation surveys exceeded the gamma guideline due to contamination in the given grid. (In other words, only 8 instances occurred where a technician passed an area without documenting the final result - see item 3, above.) The eight grids containing these small areas represent < 0.6% of the 1483 grids in the Spray Building. In other words, the guideline is shown to be met in 99.4% of the Spray Building grids.

The eight areas with final remediation records indicating measurements above 30,000 cpm were more than likely remediated but the final measurement was not documented. However, if the areas were still present, the potential impact would be negligible. One way to put the eight areas into perspective is to recognize that in total they represent less than 0.08% of the Spray Building surface area. Another way to demonstrate that the potential impact is negligible is to perform a bounding dose assessment from the contamination above the 30,000 cpm guideline. The bounding assessment shows that the dose from the eight areas combined would total less than I E-03 mrem/yr (See Appendix H). Assuming a cost as low as $ 100 to remediate each of these eight small spots, the cost/person-rem would have exceeded $800,000/person-rem.

Provided below is a discussion of the gamma survey results for all of the grids listed in the table for RAI No. 2 of NRC's RAI's on FSS Final Report No. 1 (Reference No. 10). These grids have been organized into categories and dispositioned accordingly.

Category A - Acceptable Gamma Surveys are Documented The survey unit grids included in this category have been gamma scanned and documentation is attached to this RAI response in referenced appendices.

Survey Unit No. 1 Scan Grid C043: The remediation survey gamma scan conducted on January 28, 2004 produced a grid scan result of 65k cpm. The elevated reading was due the to the presence of a pipe in the E3B cubicle which was later removed during the remediation of FR-01 11-03 Yard West Excavation Survey Unit No. 3. Following this pipe removal and some additional soil remediation, remediation/verification surveys were conducted on the spray building wall around the pipe penetration. These surveys dated July 29, 2004 and August 10, 2004 (See Appendix A) demonstrated that the wall area, which was FR-1700-01 scan grid C043, was remediated to the 30 k cpm guideline. Appendix A includes schematics and pictures showing the as-left surfaces of SU No. I and the RicWil pipe removed.

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Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Survey Unit No. 3 Scan Grid C131: The remediation survey gamma scan conducted on August 14, 2003 produced a scan results of 57 k cpm. As noted previously in Maine Yankee's response to NRC RAI's on FSS Report No. 1 (Reference No. 12), this wall grid was located just underneath the floor at the 12 foot elevation which was removed. Following the backfill of the spray building basement (Survey Unit Nos. 2 through 9), the 12 foot elevation floor was removed and fill material removed as necessary to expose the upper surface of these walls for survey under Survey Unit No. 1. SU 3 Scan Grid C 131 corresponds to SU 1 Scan Grids C124 and C125 as indicated in the attached drawings (See Appendix G). The remediation survey gamma scans conducted in Survey Unit No. 1 on January 28, 2004 on these grids produced scan results less than 30 k cpm.

Survey Unit No. 4 Scan Grid 182: The remediation survey gamma scan conducted on August 4, 2003 produced a scan result of 40 k cpm at a hole in grid C182. The hole penetrated the wall between SU 4 and 5 and was associated with instrument line. The hole was successfully surveyed under SU 5 wall scan grid C124. (See Appendix C)

Survey Unit No. 5 Scan Grid C045: The remediation survey gamma scan conducted on August 25, 2003 indicated an elevated area about 200 cm2 in size at about 32 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result to be equal to 30 k cpm.

Scan Grid C054: The remediation survey gamma scans conducted on September 11 and 22, 2003 produced grid scan results of 35 k cpm, 35.3 k cpm and 32.6 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result to be 22.8 k cpm.

Scan Grid C069: The remediation survey gamma scan conducted on August 25, 2003 produced a grid scan result of 35 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result to be 29.9 k cpm.

Scan Grid C070: The remediation survey gamma scans conducted on August 25, 2003 and September 11, 2003 produced grid scan results of 32 k cpm and 33.1 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result to be 23.5 k cpm.

Scan Grid C085: The remediation survey gamma scan conducted on August 27, 2003 produced a grid scan result of 70 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result to be 24 k cpm.

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Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Scan Grid C100: The remediation survey gamma scans conducted on August 26 and 27, 2003 produced grid scan results of 65 k cpm and 38 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result to be at 41 kcpm, which was remediated and resurveyed to 28.3 k cpm.

Scan Grid C133: The remediation survey gamma scan conducted on September 11, 2003 produced a grid scan result of 30.8 k cpm. A later gamma scan dated September 24, 2003 showed the grid scan result of 19.9 k cpm.

All of the Survey Unit No. 5 scan grids identified above are dispositioned by the attached September 24, 2003 remediation survey (See Appendix D).

Scan Grid C026, C027, C089, C096 (C097)', C155, C156 and C157: The remediation survey gamma scans conducted on August 26, 2003 (and on September 1 1, 2003 for Scan Grid C026 and on September 24, 2003 for Scan Grid C089) produced scan results of 83 k cpm (60 k cpm on 9/11/03), 100 k cpm, 43 k cpm (54.9 k cpm on 9/24/03), 46 k cpm, 32 k cpm, 36 k cpm and 90 k cpm, respectively. As noted previously in Maine Yankee's response to NRC RAI's on FSS Report No. 1 (Reference No. 12), these wvall grids were located just underneath the floor at the 12 foot elevation which was removed. Following the backfill of the spray building basement (Survey Unit Nos. 2 through 9), the 12 foot elevation floor was removed and fill material removed as necessary to expose the upper surface of these wvalls for survey under Survey Unit No. 1. SU 5 Scan Grids C026, C027, C089, C096, C155, C156 and C157 correspond to SU I Scan Grids C046 through C048, C061 through C063, C084 through C087 and Cl 16 through Cl 19 as indicated in the attached drawings (See Appendix G). The remediation survey gamma scans conducted in Survey Unit No. I on January 28, 2004 on these grids produced results less than 30 k cpm Survey Unit No. 6 Scan Grid C134 and C 135: The remediation survey gamma scans conducted on July 31, 2003 produced a scan result of 56 k cpm for each of the two scan grids. As noted previously in Maine Yankee's response to NRC RAI's on FSS Report No. I (Reference No. 12), these wall grids were located just underneath the floor at the 12 foot elevation which was removed. Following the backfill of the spray building basement (Survey Unit Nos. 2 through 9), the 12 foot elevation floor was removed and fill material removed as necessary to expose the upper surface of these walls for survey under Survey Unit No. 1.

SU 6 Scan Grids C134 and C135 correspond to SU 1 Scan Grids C082 and C083 as indicated in the attached drawings (See Appendix G). The remediation survey gamma scans conducted in Survey Unit No. 1 on January 28, 2004 on these grids produced scan results less than 30 k cpm.

As noted previously in Maine Yankee's response to NRC RAI's on FSS Report No. I (Reference No. 12): The NRC RAI dated November 4, 2004 (Reference No. 10) incorrectly stated Grid C097 at 46kcpm. The August 26, 2003 survey shows Grid C097 at 22 kcpm and Grid C096 at 46 kcpm (See Appendix G).

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Maine Yankee Responsc to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Survev Unit No 8 The NRC RAI on FSS Report No. 1 (Reference No. 10) stated: "Missing survey data for parts of the lower cubicle." Remediation survey gamma scans of the lower cubicle were conducted on May 12, 2003, June 2, 2003 and June 3, 2003. The survey dated 5/12/03 indicated two small areas exceeding 30,000 cpm. The final remediation survey record (dated 6/3/02) describes the remediation of two small spots in locations that differed from those described in the 5/12/03 record. The review of the 6/3/02 SU-8 record leads to the conclusion that the two areas addressed were the only elevated areas remaining at the time and serves as sufficient documentation that the two areas identified in the earlier 5/12/03 survey record were remediated. This conclusion is supported by the ORISE confirmatory survey report for SU-8 dated 11/20/2003 which states that "gamma scans did not identify any indications of volumetric or subsurface contamination (i.e., gamma radiation levels were consistently within background ranges) except for upper walls in SU-6 and 8." Thus the attached (Appendix E) remediation surveys dated May 12, 2003, June 2, 2003 and June 3, 2003 demonstrate that the lower cubicle was remediated to the 30 k cpm guideline.

Scan Grids C039, C040, C043 and C044: The remediation survey gamma scans conducted on July 21 and 22, 2003 produced scan results of 28.2 k cpm, 29.6 k cpm, 22.1 k cpm and 22.1 k cpm, respectively, however the data form indicated that the surfaces

,were wet or puddled. In Maine Yankee's response to NRC RAI's on FSS Report No. I (Reference No. 12), Maine Yankee provided an evaluation of the SPA-3 to various depths of water and concluded that the scan results corrected for a thin layer of water indicated acceptable remediation.

Scan Grid C124, C173, C234, C236 and C237: The remediation survey gamma scans conducted on July 21 and 22, 2003 produced scan results of 47.8 k cpm, 134 k cpm, 61.9 k cpm, 50.9 k cpm and 68.4 k cpm, respectively. As noted previously in Maine Yankee's response to NRC RAI's on FSS Report No. 1 (Reference No. 12), these wall grids were located just underneath the floor at the 12 foot elevation which was removed. Following the backfill of the spray building basement (Survey Unit Nos. 2 through 9), the 12 foot elevation floor was removed and fill material removed as necessary to expose the upper surface of these walls for survey under Survey UnitNo. 1. SU 8 Scan Grids C124, C173, C234, C236 and C237 correspond to SU I Scan Grids C043 through C045, C052 through C054 and C073 through C076 as indicated in the attached drawings (Appendix G). The remediation survey gamma scans conducted in Survey Unit No. I on January 28, 2004 on these grids produced scan results less than 30 k cpm with the exception of Scan Grid C043 which is dispositioned above.

Survev Unit No. 9 The NRC RAI on FSS Report No. 1 (Reference No. 10) stated: "No surveys provided."

Survey Unit No. 9 consists of two shake spaces wall interfaces between the Containment Page 8

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 and Spray Building walls, and the penetrations. Remediation survey gamma scans conducted on February 27, 2003 and September 3 and 15, 2003 demonstrated that the two shake space wall interfaces were remediated to the 30 k cpm guideline. Note that the February 27, 2003 survey shows that gamma scan of the Containment wall right up to the interfacing exterior Spray Building wall in the E3B cubicle was less than 30 k cpm (16 to 24 k cpm). These remediation surveys are attached (Appendix F). A discussion of Survey Unit No. 9 penetrations is provided below.

Cateeorv B - Contaminated Concrete Source Removed Survey Unit No. 2 Scan Grid 032: The pump mount curb in E-3A was judged by the gamma scan surveyor to be the source of the high reading. The entire curb was removed.

Scan Grid C197: The remediation survey gamma scan conducted on July 17, 2003 produced a scan result of 39.1 k cpm. The elevated reading was judged by the gamma scan surveyor to be due to the presence of RicWil pipes in the E3A cubical. These pipes were later removed during the remedition of FR-01 11-03 Yard West Excavation Survey Unit No. 3. Attached (Appendix B) is a picture showing the RicWil pipes removed.

Survey Unit No. 5 Scan Grid C171 was completely removed. See Appendix G Survev Unit No. 6 Scan Grid C233 was completely removed. See Appendix G Catecory C - Evaluation Performed As described above, the following eight areas were evaluated. The evaluation is described in Appendix H:

FA-1700-03-CIOI 7/25/03 31,000 cpm 929 cm2 FA-1700-04-C094 8/14/03 36,700 cpm 100 cm2 FA-1700-05-C053 9/24/03 35,000 cpm 25 cm2 FA-1700-05-C082 9/22/03 60,600 cpm 64 cm2 FA-1700-05-C039 9/24/03 46,500 cpm 50 cm2 FA-1700-05-C115 9/24/03 31,000 cpm 200 cm2 FA-1700-06-C132 7/31/03 32,000 cpm 6,700 cm2 FA-1700-08-C092 7/21-22/03 35,400 cpm 2,500 cm2 Page 9

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Survey Unit No. 4 Scan Grid C139 vas the area surrounding the Spray Pipes. The License Termination Plan allowed a DCGL in the Spray Pipe up to 800,000 dpm/l OOcm2.

The gamma scan measurement identified in this grid was a result of the as-left contamination on the spray pipe. The dose from this residual activity was completely evaluated under FC-0300 in accordance with the License Termination Plan.

FR-1700 Survey Unit 9 consisted of 14 - 3"ID concrete penetrations, 6 - 4" ID steel lined penetrations, 1 - 6" ID steel lined penetration, 1 - 8' ID concrete penetration, I - 10" ID steel lined penetration and the previously grout-filled spray pipe penetrations for CS-M-91 and 92. The steel lined penetrations consisted of either steel pipe installed during construction such that any surface contamination present would have been limited to the interior steel surface of the penetration. Since this steel surface activity was not capable of penetrating the concrete as verified by the surrounding wall surveys, no gamma scans were performed in steel line penetrations. The concrete openings were core bored out to remove any surface contamination resulting in a clean interior surface prior to final survey. Thus the beta scan survey appropriately surveyed for surface activity. The maximum scan measurement for SU-9 was 122,000 dpm/I00 cm2 (which was less than 4% of the EMC fraction) and the average value was 27,700 dpm/lOOcm2 showing the relative cleanliness of the penetrations against the embedded pipe DCGL of 100,000 dpm/100cm2.

As seen above, with the exception of the eight grids previously discussed, there is either 1) sufficient documentation to demonstrate that the gamma radiation originating from the listed grids was less than the 30,000 cpm guideline, or 2) sufficient documentation to support a conclusion that elevated readings were from adjacent sources or were removed.

NRC RAI on FSS Report No. 2 - RAI No. 2. PAB Gamma Survey Results RAI 2-2 RAI No. 2 requested documentation demonstrating compliance i'ith the 30,000 cpm ganuna criterionfor Survey Units 1, 2, 6, 8, 10, 12, and 14. In addition, the staffrequested that Maine Yankee clarify the placement of shielding and relationship to the measurements reported.

Based on our revieu, of the information provided by Maine Yankee in the response to the RAI, the staiffinds that the RAI response for Survey Units 1, 6, 10 and 12 is incomplete and unresponsive to the information request. The staff's response is detailed below (Only open items listed):

PAB - SU I 11/19/2003 Area C43 7: The response states, "The elevated readings noted in the remnediation surveyfor PAB SU-1 grid number C43 7 were due to an elevated area on the bottom of the penetration which wtas only accessible from SU-ll at the time. The initial survey wvas performed on 11/19/03 and it was noted on the survey log that this penetration wvould be remediated as part of SU-11. The penetration itas remediated and surveyed with a reading of24,900 cpm as part of Grid C-016 on 12/18/03. "

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Maine Yankce Response to NRC Request for Additional Information (RAI) Regarding Final Status Sunrey (FSS) Final Report Nos. I and 2 Please clarify which survey unit contains Area C43 7, and provide the gamma survey that clearly identified that the penetration gamma measurement for Grid C43 7 meets the 30, 000 cpm criteria.

Maine Yankee Response:

PAB - SU I grid C437 consists of a penetration in SU-1 wall no. 4. This penetration grid is shown on Map FA0600-O1J submitted to the NRC in FSS Report No. 2 (Reference No. 8). The remediation survey gamma scan for this penetration was performed as part of FR-0600 SU 11 wall grid C016 in SU-II wall no. 2. This %vall grid is shown on Map FA-0600-1 la also submitted to the NRC in FSS Report No. 2 (Reference No. 8).

On November, 19, 2003, a gamma survey of penetration C437 resulted in a scan result of 35.1 k cpm. This elevated reading was due to an elevated area on the bottom of the penetration which was only accessible from Survey Unit 1 1. Following remediation of Survey Unit I 1, a gamma scan of SU-1 I wall no. 2, including wall grid no. C016 was performed (see attached Final Rad Remediation Survey dated December 17 and 18) (Appendix I) resulting in scan measurements of 20.8 k cpm and 24.9 k cpm, respectively. These scan results satisfy the 30 k cpm guideline.

NRC RAI on FSS Report No. 2 - RAI No. 2. PAB Gamma Survey Results (continued)

PAB - SU 1 11/13/2003 Areas C039, C086, C087. Maine Yankee 's reply says that the elevated readings in Grids C039, C086, C087 were due to the location of the grids with respect to the Fuel Building tunnel area, which at the time was posted as a high radiation area (HRA). Further, attempts to shield the area affecting the high readings in Grids C039, C086 and C087 were unsuccessful in reducing background levels beolow 30, 000 cpm with the SPA-3 but did allow Maine Yankee to perform beta measurements with the 43-68 probe.

The staff does not have questions regarding the beta measurements pemfornted in Grids C039, C086, C087. The staff is interested in verifying Maine Yankee 's statement on page 8 of "Release of Non-ISFSI Site Land - FSS Final Report No. 2, " that "All basement surfaces were remediated to the 30, 000 cpm gross gamma activity criterion value to detect and remove contamination at depth... " Please clarify ifgamnma survey were performed in these grids after the Fuel Building tunnel wealls wmere removed Ifgamnma surveys revere performed, please provide gamma surveys that clearly identify that gamma measurements for Grids C039, C086, C087 meet the 30K cpm criteria.

Page 11

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 Maine Yankee Response:

PAB - SU I grid nos. C039, C086 and C087 consist of the most westerly wall grids on SU-1 wall nos 4 and 7. These wall grids are shown on Map FA-0600-OIA submitted to the NRC in FSS Report No. 2 (Reference No. 8). These xvall grids were located adjacent to the Fuel Building Tunnel area, which at the time was posted as a high radiation area. On November 13, 2003, the wall grids were gamma scanned resulting in scan results for wall grid nos. C039, C086 and C087 of 32 k cpm, 41 k cpm and 45 k cpm. It was the surveyor's judgement that the reason the scan results were higher than the 30 k cpm gamma scan guideline was due to the shine from the fuel building not from the wall grids themselves. Measures were taken (eg. shielding of the fuel building wall) to obtain gamma scans of these wall grids, but these measures were not successful.

It was not possible to demonstrate that these wall grids met the 30 k cpm guideline without first removing the fuel building tunnel walls. The Fuel Building tunnel wvalls are now being demolished and properly removed. In addition, Maine Yankee will also removed the PAB wall areas associated with wall grid nos. C026, C039, C086 and C087 (Appendix J)

NRC RAI on FSS Report No. 2 - RAI No. 2. PAB Gamma Survey Results (continued)

PAB - SU 6 02/13/04 Areas C334, C350, C351, C356, C357: The Maine Yankee response only partially addresses the issues in the RAL. Only measuremnents for Grids C334 and C351 are correlated to specific samples taken in the survey unit. The remaining grids; C350, C356 and C35 7 are not correlated to specific sample data provided. Please provide documentation correlating these grids with specific samples.

In addition, in FA - 0600-06, Table 1, the DCGL is 18,000 dpmn/l OOcm2. Please provide the basis for the 37 pCi/g "volumetric equivalent to the DCGL."

Maine Yankee Response On February 13 and 17, 2004, a remediation survey gamma scan of the PAB pipe tunnel test pit was performed (Appendix K). This survey identified wall grid nos. C334, C350, C351, C356 and C357 with scan results of 3 1.1 k cpm (1 ft2), 48.2 k cpm (0.5 ft2), 30.2 k cpm (1 ft2), 35.8 k cpm (2 ft2) and 34.1 k cpm (I ft2), respectively.

Clearly noted on the data form beside each of these grids is the comment "ledge" (i.e., bedrock), rather than "concrete". Each of these measurements is indicative of bedrock not concrete. Thus the 30 k cpm gamma scan guideline does not apply. Also indicated on the remediation survey data form are the following notes:

"Grids 350, 356 & 357 previously sampled and shown to be <DCGL by isotopic analysis. Grids 334 & 351 sampled in conjunction with this survey and shown to be < DCGL by isotopic analysis." The table previously provided to the NRC in response to the RAI's on FSS Report No.

2 (Reference No. 13) has been annotated, as shown below, to indicate which samples apply to which wall grids.

2 The volumetric sample for Scan Grid C350 was taken slightly on the concrete side of the ledge-rock line (See Appendix K).

So, the surface of the sample was concrete, but the sample was mostly bedrock.

Page 12

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Sample ID Date Grid Cs-137 Co-60 Total Activity

-_-_-_(pCi/g)

(pCi/g)

PAB Test Pit -

1/28/04 Wall Grid 20.9 4.7 25.6 North Ledge - I C356 PAB Test Pit -

1/28/04 Wall Grids 6.1 4.1 10.2 North Ledge - 2 PAB Test Pit -

1/28/04 Wall Grid 12.9 4.8 17.7 North Ledge - 3 C357 PAB Test Pit East 1/19/04 Wall Grid 29.4 0.8 30.2 Wall Ledge "A" C350 PAB Test Pit -

1/26/04 Floor Grids 6.2 2.8 9

North Bottom PAB Test Pit A 1/26/04 Wall Grids 13.5 1.2 14.7 North Face Bottom PAB Test Pit B 1/26/04 Wall Grids 19 1.5 20.5 North Face Bottom PAB Test Pit 2/18/04 C334 1.7

<0.23 1.93 Ledge Rock PAB Test Pit 2/18/04 C351 8.1 0.32 8.42 I

I I

I As described in the Introduction, since the concrete was completely removed down to bedrock in these areas, neither the 30 kcpm remediation guideline nor a DCGL apply. However, Maine Yankee used a DCGL based volumetric guideline to compare to the bedrock sample results. LTP Section 5.5.1 identifies the option of detecting the presence of radioactivity below the surface by performing gamma spectroscopy of volumetric samples to meet the equivalent of the surface contamination DCGL. Converting the surface contamination DCGL to a volumetric equivalent requires depth of activity to be specified. This depth is determined based upon the depth of contaminated material which will remain in the survey unit. This method can be used to determine the required depth of concrete to be removed. When used to determine remediation depth, the final surface conditions (depth of contaminated layer) is what is used to calculate the volumetric equivalent of the surface contamination DCGL. All of the activity in the contaminated layer is then assumed to exist at the surface and converted to dpm/100 cm2. The final surface condition is assumed to be a contaminated layer depth of 1 mm. This is consistent with LTP Section 6.6.1.b, pg. 6-11, which based this depth on analysis of contaminated Maine Yankee concrete. A conservative volumetric DCGL may be calculated based on a contaminated layer depth of 1 cm and then used for initial evaluation.

Page 13

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Thus the conservative 1 cm volumetric DCGL is calculated as follows:

DCGLvolumctric =

18.000 dr2m

- 36.9 pCi/g 100 cm2

I cm

2.2 g/cm3

2.22 dpm/pCi The actual 1 mm volumetric DCGL is 369 pCi/g.

NRC RAI on FSS Report No. 2 - RAI No. 2. PAB Gamma Survey Results (continued)

PAB - SU 10 01/16/04 Areas C029, C064, C213: Maine Yankee 's response indicates that the January 16, 2004, surveysfor Areas C029, C064, and C213 did not meet the 30K cpm criteria due to the proximity ofthe/ Fuel Building tunnel area and the inability to effectively shield the areas from the HRA. During discussions wi'ith Maine Yankee on Jantaiy 19, 2005, Mlaine Yankee stated that there are no gamma survey records document that Areas C029 and C064 meet the 30K cpm criteria. Maine Yankee also stated that Area C213 weas located on an upper wall that was removed with Fuel Building tunnel demolition. Please provide historical survey data to demonstrate that contamination is not present at depth.

Maine Yankee Response:

PAB - SU 10 grid nos. C029 and C064 consist of the most westerly floor grids in SU-10. These floor grids were located adjacent to the Fuel Building tunnel area, which at the time was posted as a high radiation area. PAB - SU 10 grid no. C213 is an upper wall grid located in the middle of the PAB in the former letdown heat exchanger pre-filter cubicle. These grids are shown on Map FA-0600-1 OA submitted to the NRC in FSS Report No. 2 (Reference No. 8). On January 16, 2004, the grids were gamma scanned resulting in scan results for grid nos. C029, C064 and C213 of 57 k cpm, 56.9 k cpm and 30.4 k cpm.

For the floor grid nos C029 and C064, it was the surveyor's judgement that the reason the scan results were higher than the 30 k cpm gamma scan guideline was due to the shine from the fuel building not from the floor grids themselves. Measures were taken (eg. shielding of the fuel building wall) to obtain gamma scans of these floor grids, but these measures were not successful. It was not possible to demonstrate that these floor grids met the 30 k cpm guideline without first removing the fuel building tunnel walls. The Fuel Building tunnel walls are now being demolished and properly removed. In addition, Maine Yankee will also removed the PAB floor areas associated with floor grid nos. C029 and C064 (Appendix J).

For wall grid no. C213, an earlier survey dated November 19, 2003, determined that the only portion of this grid that was above the 30 k cpm gamma scan guideline was the area above the boundary line, ie 17' elevation, 3 ft below grade. Any concrete above this elevation, will be removed in accordance with LTP Section 3 dismantlement plan. As indicated in the attached (Appendix J) Final Rad Remediation Survey Form dated November 19, 2003, the "area below SU 10 boundary line < 30 k."

Page 14

Maine Yankce Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. 1 and 2 NRC RAI on FSS Report No. 2 - RAI No. 2. PAB Gamma Survey Results (continued)

PAB - SU 12: The staff requested documentation that demonstrates compliance with the 30K cpin gamma criteriafor Survey Unit 12. Maine Yankee 's response is unacceptable because the data shows three samples Grids C046, C046/47, and C021/C022 that exceed the 37pCi/g volumetric DCGL for Cs-i 37. It is also noted that Grid C042 may exceed the DCGL when the unity rule is applied.

As requestedfor PAB - SU 6, please provide the basis for converting the sulface DCGL to a DCGL volumetric equivalent activity. Please clarify which samples are from bedrock sum faces and which samples are from concrete foundations. Since the samples referenced are taken on bedrock or concrete foundations, provide the basis for considering these samples to be near-surface activity In addition, please describe howe these sample activities, including those exceeding the volumetric equivalent DCGL, are accountedfor in determining the annual dose, since the grids are not listed in Table 3-1, TEA0600-12 Investigation Table.

Maine Yankee Response:

All of the samples shown in the table provided in Maine Yankee's RAI response (Reference No.

13) were bedrock samples, not concrete samples. As noted in the Introduction, neither the 30K gamma criterion nor a DCGL apply to bedrock. The appropriate bedrock analyses (Reference No. 1) was incorporated by reference into the draft LTP and is included in the original LTP approval. So, no compliance with the gamma criterion or a DCGL is necessary.

Nonetheless, for its own purposes, Maine Yankee chose to take bedrock core samples and analyze them. For purposes of information only, Maine Yankee provides the following discussion In November 2003, a decision was made to core sample certain trench areas in the PAB showing elevated gamma measurement, to guide gross concrete remediation. PAB Core 01 was a core sample which was taken in the concrete floor of west side PAB letdown heat exchanger area trench, in PAB SU-12 floor grid no. C046. This floor grid is shown on Map FA-0600-12c submitted to the NRC in FSS Report No. 2 (Reference No. 8). Core 01 was sliced into eleven -

three inch slices and analyzed by gamma spectroscopy. The results of these core samples showed a trend of Cs-137 activity from 76.8 pCi/g at the top to maximum of 818.1 pCi/g and 495.2 pCi/g at about 15 to 21 inches. The Cs-137 activity then decreased to about 4 pCi/g from 21 inches to 30 inches. The Cs-137 activity in the bedrock sample (30 to 33 inches) was 204 pCi/g. The Co-60 activity was all less than MDA.

Page 15

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 The results of this core caused Maine Yankee to take Cores 02 through 04 in the immediate vicinity of Core 01. The results of Cores 02, 03 and 04 showed Cs-137 activity of 1.6 pCi/g, less than MDA and 3.3 pCi/g, respectively and Co:60 activity of 0.063 pCi/g, less than MDA and 0.04 pCi/g. Guided by the boundary of these core samples, gross concrete remediation was then performed in this trench area, removing the concrete down to bedrock. On January 29, 2004, a remediation survey gamma scan of this portion of the PAB trench was performed. The data form indicated that floor grids nos C046 through C048 were bedrock and therefore not subject to the 30k cpm gamma guideline. The gamma scan result for grid no. C046 was 34.1 k cpm. This was dispositioned on the data form by the isotopic evaluation previously performed in November 2003.

As described above, the volumetric DCGL for 1 mm depth of contamination is 369 pCi/g. This depth of contamination, which was shown to be applicable for concrete at Maine Yankee, is particularly appropriate for more competent, less porous bedrock. Since Maine Yankee has remediated the concrete down to the DCGL and has used the 30 k cpm guideline to guide remediation, down to bedrock when necessary, it is concluded that the evaluation of bedrock contamination (Reference No. 1) sufficiently bounds the effect of this activity level in the bedrock.

Similarly, PAB Cores 05 and 06 are core samples in concrete floor of west side PAB letdown heat exchanger area trench on the north and south side of FA-0600 SU 12 floor grid no C041, respectively. This floor grid is shown on Map FA-0600-12c submitted to the NRC in FSS Report No. 2 (Reference No. 8). PAB Cores 05 and 06 were taken and analyzed in November and December 2003. The bedrock portion of Core 05 was sliced and measured by gamma spectroscopy at 5 inches and 7 inches into the bedrock as 89 pCi/g and 34 pCi/g Cs-137, respectively and 15 pCi/g and 14 pCi/g Co-60. The bedrock portion of Core 06 was measured by gamma spectroscopy as 3.9 pCi/g Cs-137 and 2.1 pCi/g Co-60. Guided by the boundary of these core samples, gross concrete remediation was then performed in this trench area, removing the concrete down to bedrock. On January 29, 2004, a remediation survey gamma scan of this portion of the PAB trench was performed. The data form indicated that floor grid nos C041 through C042 were bedrock and therefore not subject to the 30 k cpm gamma guideline. The gamma scan result for grid nos. C041 and C042 was 36.7 k cpm and 28.5 k cpm, respectively.

Grid no C041 was dispositioned on the data form by the isotopic evaluation previously performed in November and December 2003. As described above the remediation of contaminated concrete had reached bedrock and was concluded to be within the surface contamination DCGL (even though no DCGL applies to bedrock) and bounded by the previous bedrock evaluation (Reference No. 1)

Finally, PAB Core 07 is a core sample in the concrete floor of the east side PAB letdown heat exchanger area trench between FA-0600 SU floor grid no C021 and C022. These floor grids are shown on Map FA-0600-12a. PAB Core 07 was taken and analyzed in November and December 2003. The bedrock portion of Core 07 was sliced and measured by gamma spectroscopy with the sixth sample into the bedrock at 12.3 pCi/g Cs-137 and 6.5 pCi/g Co-60. Guided by the Page 16

Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 The final remediation surveys included gamma surveys using an Nal detector. The gamma surveys would have detected any significant residual contamination beneath any interferences such as scaffold legs or junction boxes. The interferences were typically small in area (e.g.;

scaffold legs are approximately 100 cm2 which is about 1% of the surface area of a typical 1 m2 scan grid). The following gamma surveys were performed in the survey units where similar instances were specifically by the CR.

SU-1 Grid 075 was surveyed with no indication of any elevated readings around the fire system pipe penetration. The fire system was expected to be clean based on operating history and site characterization data. The fire system wvas final surveyed as FD-0700 as a Class 3 survey. The survey results were consistent with those expectations (the maximum direct measurement point gross reading was 989 dpm/100 cm2 and there were no elevated areas found).

SU-4 During the Final Remediation Survey (1/7/04) grids C012, C048, C061, and C076 were gamma surveyed with the maximum reading being 21,100 cpm.

SU-5 During the Final Remediation Survey (1/26/04) grid C103 were gamma surveyed with the maximum reading being 21,000 cpm.

SU-6 During the Final Remediation Survey (2/11-12/04) grids C127, C138, C140, C142, C161, C170, C172, C174, C176, C178, C180, C226, C248, C255, C259, C277, C279, C295, C298, and C303 were gamma surveyed with the maximum reading being 23,800 cpm. Grids C342, C343, C348, C349, C35 1, and C350 were grids within the test pit. These grids were gamma surveyed on 2/18/04 and those greater than 30,000 cpm were evaluated volumetrically.

SU12 During the Final Remediation Survey (1/29/04) grids C003 and C012 were gamma surveyed with the maximum reading being 21,300 cpm.

A copy of the Final Remediation Surveys identified above are included in Appendix L.

NRC RAI on FSS Report No. 2 - RAI No. 5 Maine Yankee continues to raise the issue regarding confirmatory surveys versus in-process inspection surveys. Maine Yankee contends that the staffs use of confirmatory surveys at Maine Yankee is a change in staffposition, from that provided in Inspection Procedure 83801, and that a backfit analysis should be performed. The staff disagrees with Maine Yankee, and believes that NRC staff actions are consistent with Inspection Procedure 83801.

Page 18

Mainc Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report Nos. I and 2 Based on the type and number of issues identified during the FSSpackage revieivw the staff maintains that wve have the regulatory basis to perform confirmatory surveys. Inspection Procedure 83801 states that the goal is to conduct sufficient confirmatory surveys and sampling so that the inspector can conclude the licensee 's survey program is bing implemented in a manner that prov ides confidence in the reszdts. Surveys should be conducted simultaneously with the licensee during the licensee 'sfinal statns surveys (as opposed to waiting until after the FSSR has been subnmitted to the NRCfor review and approval). "Sites where wtork-in-process surveys and sampling have not identified significant weaknesses in the final survey program may not require after the fact surveying and sampling. Howzever, after the fact confirmatory surveys may be requiredfor sites where significant unresolved weaknesses were previously identified.

Inspection of a licensee 'sfinal survey may include independent confirmatomy measurements by the inspector or NRC contractor. "

In addition, ARC conduct of confirmatory measurements is consistent with Section 5.10.7 of the LTP. It states that Maine Yankee anticipates that both the NRC and the State ma,}y choose to conduct confirmatory measurements.

The staff is confused by Maine Yankee's ongoing resistance to NRC's pelformance of confirmatory surveys. It continues to be the staffs intent to perform confirmatory measurements.

The measurements may be conducted concurrent with Maine Yankee 's FSS or they may be conducted after Maine Yankee has completed the FSS but before the FSS Report has been subbmittedfor reviei' and approval. To date, the staff is not aware of any instance which ANRC confirmatory measurements have caused a significant dely to Maine Yankee 's schedule.

Maine Yankee Response:

Maine Yankee believes that the staff's view on in-process vs. confirmatory surveys is now consistent with ours.

In the RAI question, the staff equates confirmatory measurements with confirmatory surveys. In fact, confirmatory measurements are conducted in both in-process and confirmatory surveys in accordance with IP 83801.3 However, Maine Yankee agrees that "These measurements may be conducted concurrent with Maine Yankee's FSS or they may be conducted after Maine Yankee has completed the FSS but before the FSS report has been submitted... " and still be in-process surveys within the meaning of IP 83801. In fact, with this re-definition by the staff, all surveys the staff has conducted during Maine Yankee's decommissioning have also been "confirmatory" surveys.4 This should clear up some of the misunderstandings and miscommunications of the past.

3 This confusion of the terms confirmatory measurement and survey also lead to thc NRC's misinterpretation of Maine Yankee's intent in LTP Section 5.10.7.

4 Given this position, it is not clear why the staff contended in RAI #2 that Maine Yankee did not allow a confirmatory survey in May, 2004 contrary to the LTP.

Page 19

Appendix A FA-1700 Spray Building Survey Unit No. 1 Final Remediation Survey Gamma Scan For Scan Grid C043 Performed as a Verification Survey for FR-01 11 Yard West Excavation Survey Unit No. 3 Surveys dated July 29, 2004 and August 10, 2004 and Schematics and pictures showing the as-left surfaces of SU No. 1 and the RicWil pipe removed

Maine Yankee MAINE YANKE=EGENERPALSURVE(Y RECoRD ORM I Map#: MSC-OO1 Date:

ime:

Reactor Pwr % lTAfile Nu I.er I RWPs Used:

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Surveyor Name: (Printed)

Surveyor Name: (Signature)

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-- NI[A-t-GSHIE'DING" KOTHER (Specify):

INSTRUMENTS USED CONTAMINATION RESULTS KEY.

MODEL SERIAL #

I CAL DUE I MDA SAMLE RESULTS SAMPE RESULTS SAME S

RESULTS SAMPLE R

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Contact exposure rates denoted by:

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C126 C125 Cl24 C123 C12?

C121 C120 C033 C082 C081 C080 C079 C078 C077 C127 C128 C129 C 130 C158 CIS7 CI56 C155 C154 C153 C15?

C151 C150 C149 C148 C147 C146 C145 Cl4-C1a Cl42 C141 C140 C139 C138 C137 C136 C135_ C134 C133 C132 C131 C119 Cite Clt7 C116 i

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i CO8 Ccoot C087 CIIS C114 C113 C112 Clii CIIO C109 C1O0 C107 C106 C1O5 j Cl4 C103 C102 CII C100 C0999 CO9 Cf97 C096 C095 C094 C093 C092 C091 C090 C0e9 COBS C076 C075 C074

073

-FA 1700 Spray Building Survey Unit 1 Concrete Surface Area = 1 24.26 m 2 II

= Flowable Fill El

= Concrete pedestals 1-FA-1700-01. Revision I Page 1-1 of23

Spray Building Spay Building' Depicting "AS Left" surfaces surveyed Survey Unit 1

& Flowable Fill Verification

Picture showing the removal of RieNVil pipe on the East Side of the Spray Building Corresponds to FR-1700 Survey Unit No. 1 Scan Grid C043

Appendix B FA-1700 Spray Building Survey Unit No. 2 Final Remediation Survey Gamma Scan For Scan Grid C197 RicWil piping removed as part of FR-01 I1 Survey Unit No. 3 - Picture showing Ricfil removed

Picture showing the removal of RicVil pipe on the Vest Side of the Spray Building Corresponds to F;R-1700 Survey Unit No. 2 Scan Grid C197

_'~

Appendix C FA-1700 Spray Building Survey Unit No. 4 Final Remediation Survey Gamma Scan For Scan Grid C1 82 Corresponds to Survey Unit No. 5 Scan Grid C124 Survey dated August 25, 2003

CO 5

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Appendix D FA-1700 Spray Building Survey Unit No. 5 Final Remediation Survey Gamma Scan For Scan Grids C045, C054, C069, C070, C085, CI00, C133 Survey dated September 24, 2003

FINAIUoRAREMEDIATION SURVEY Related FSS Package #:

FAI700 Survey Uni 5 1 Data Form #:

NIA Survey Area:

Spray Building Cubicle P-61S (FA1700 Survey Unit 5)

RWPIWAN:

Page 1 of I 03-00001151851300 Survey Date:

q-?J-0 3 Instrument SIN Cal Due Detector SIN Cal Due E-600 l//%

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Comments

Appendix E FA-1700 Spray Building Survey Unit No. 8 Final Remediation Survey Gamma Scan For Entire Lower Cubicle Survey dated May 12, 2003, June 2, 2003 and June 3, 2003

ai i nkce MAINE KEI; (.,NAE'AL SUR'VE Y, RJ.XY(ORI) D( F P$Apo: FAzt7>0J.'

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aine Yankee R-rrstlc~m_

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MAINE Y/LNKIE GENE8RAL SURVEY RECORD FORMf M#C-: fAI70r-OS DCt:

Time: fOA0 P oactor P-r %I Teci File Number: lWPs Used DOSC f t ze U.fi d fi P' evic-

/

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. t)ose rates dewoted I1.

r Large area SI e!r:'d.at.'d by Air so"nmple b

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Appcndix F FA-1700 Spray Building Survey Unit No. 9 Final Remediation Survey Gamma Scan For Shake Space Wall Interfaces Survey dated February 27, 2003

lAaine Yankee MAINE YANICEE GENER SURVEY RECORD FORM AE LEICIRY I

E 17

/_

,op#: SPR001 Dale:

Timel Recto P-fr %

Tech Filo Numbor:

RWPs Used:

Dose Rocovod Rey;s;on#: 00 N

N/A 19.20.,44 mR

,rveyor Name: (Prn od)

Suroyor Name: (Signoture) tocat;on/Job Doscription.

Spray Building 12'-6" and 14'-O" EL.

t.quircdR.P. Ro's

/ Dato 2 Roquv;od tARA uporn;sor Rco- / Doao REASON FOR SURVEY I

I 1 ROUTINE I

U JOOBCOVERAGE I

,3 StIIELDING Q.

G OTHERCSpocilyI: t 2 L Ž/Cr?

£-

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_______E_____D CONTAMINATION RESULTS KEY MODEL SMlt f CAI DUE SAMrJE fr RESULtS SAMPtE' RESULtS SAMPLE RESULTS SAMPLE RESUS Conlact oaposure rates denoted by:

s¢-oo

'-'55 dA

_Smear locations donolod by:

()

S=>

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BA Boundaoris or barriors donoted by:

-a-*r-

_ I Dose rolos denoted by:

Large area smoarsc donoled by:

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Air sample local;on donolad by:

5-J I l___

Sample Cont;nuaoton Shoot Used. U YES cm

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<1q-Spray Building i- -ad 14'-6" EL A-

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Maine Yankee DecommissonIng Project Survey Map I Map ID# TA1 700-1 0 id Stam F

I &iVey Am N.-no: Spray Buildina Shake Space East Side

\\C:

TWALL East Side 17 ieva "4/i.

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Appendix G FA-1700 Spray Building Survey Unit 1 Final Remediation Survey Gamma Scan Survey dated January 28, 2004 For the corresponding survey unit scan grids Category A - Acceptable Gamma Surveys are Documented Sun Survea Unit Scan Grid(s4 Corresponds to Sc 3

C131 C12 5

C026 - C027 C02 C089 - C096

C04, 6

8 C155 - C157 C134-C135 C124 & C173 C06 C111 C08:

C04:

C05:

vey Unit No. 1 an Grid(s)

'4-C125

'9-C030 66-C048 I - C063

.6-C119 22-C083 3 - C045 2 - C054 C234, C236 - C237 C073 - C076 Category B - Contaminated Concrete Source Removed Survev Unit Scan Grid(s) 5 C171 6

C233 Also see FA-1 700 Spray Building SU# 5 Final Remediation Survey dated August 26, 2003

Deco~mrnlsslYaonkeTeam l

Maine Yankee Decommissioning Project Survey Map Map ID#

FA 1700-01 b SuaveyType:

[ Vefltcftion El Turnover X

Final Status Survey ISuiveyArea Name: Spray Building Unit 1 Final Remnant N

C6 O2c3 - C024 C025 C

C 026 1 C27 I c028 I C029 c030 i C031 I C032 l C033 c034 I c035 l C036 I C037 i co38 C039 C040 C041 I C42 c025 I

9 Is C160 I

SU5-CI56 SU5-C1 55 FA 1 700 Siray Building Survey Unit 1 Concrete Surface Area = 124.26 m 2 D

= Flowable Fill 0

= Concrete pedestals

= Scan grid locations from Units 2 through 8

FINAL RAD REMEDIA11ON SURVEY hilatid FSS Packae #:

FAII00 sage 1 of 2 Survey Unit#:

I Data Form #:

NA RWPJWAN:

urqre-,r

/c, lepsizoo SurveyArea: Spray luldlng Final Remnant SurveyDate: t l-E Instrument SIN Cal Due Detector SIN Cal Due E400 I1 OO:

12 L

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o 5

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Review: //';

//..a i>'

-i Surveys l

Surveys Sca A

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(Jpm)

Cm2 Comments (CXXX)

(Cpm)

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<3k 024 43pk 072

__k 025

<3Ok 073

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<"I 074

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055 I's 103 056 1t 104

<<,o 057 C

105 (3ck 058 ca1k 106

<O 059

<03ok 107

< <V 060 C3tk 108 c 5e 061 c3 k 109

<-0 K

062 e -sot 110 063

< -3O I 111 (OK 064

'50 112

<'5Ov 065 L

2tt 113 4:5O0.

066 114 C-,t 067

<3ek 115 C '

068 C3__0k_

116 069 117 070

<!30 k 118 Comments: *

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Related fSS PatkigttS FRI700 FINAL AkAb RtEMEtDIAON SURVEY Suivey Unit S:

I Data Form N:

NIA Page 2 of 2 Sunweyt Sueveyt Grid i Scan

[iYN (Cx) Result At"a (CXXX)

(__

Cm2 Coinmenbt 120 121 122 IL3c0k 123

<30k 124 o

_5 _

k 125

<OkL 126

<5OIC 127

<50K 125 C'350 129 4,3o0._

130

<Soie 131

<50 132 3

133 C3ok 134 b

135

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<30K 137 ct50k 138

<30K 139 63bk 140

<30K 141

'3__O 142

<j'_O 143 (35O 144

c.

145

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146

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<7j O

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C 150 ec-O k.

151 152 c' o-k 153 C'.50K 154 155 156 C50k.

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Co65 C066 C067 C068 C069 C070 C071 C072 C073 C074 C075

,Co86 C085 COB4 C083 C082 Co01 Coo C079 C078 C077 C076 092 C093 C094 CO9S C096 C097 C098 C099 I..........

1 _ f.

107 C106 COS C104 C103 108 C109 C115 C1114C112 e~

6120.bl22 12-136Cj38C14OC 144C

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83 C155 C157 0159 ISI 184 C183 C182C181.C180 185.C186.c187C188 C18s 195 C194 C193 C192 C191 17-C198 C199 C200 C201,C202 C203 C204 i5 C214 C213 211 C210 C20s C208 C.

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Surface Area 221.60 m 2 11 11 C

0 0

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C123124 b12Z...020 C.118 0116.C114.

C139 C137 C135 4

t7127 17 017 11 C119 C117 CMI 1:1I3 FAl 700 Spray Building Unit 3 (P-61A)

Surface Area 189.35 m2 C142 C143,0144,0145C046 0C14 C1iSi 0150 C149 0148-i C152.C153 C154C155

.159. 0158.0157...C15656 00 C16O0..161..C162.C163.C164..

C171.C170.C0169'C168..C167.C 172C0173.0174.C175.Cl176..r

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Surface Area 199.90 m2 I

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Spray Building Unit 5 (P-61S)

Surface Area 196.12 m 2 II vl

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Surface Area 199.9 m 2 Cn C,

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Appendix H Evaluation of Spray Building Gamma Measurements Last Documented to be > 30 kcpm As a result of the extensive review of final remediation survey records, Maine Yankee identified eight areas where the final remediation records indicate gamma scan measurements above 30,000 cpm. These areas were more than likely remediated but the final measurements was not documented. These areas were evaluated to assess the dose impact if the final documented measurement were to represent the final condition.

The geometry for each measurement was modeled using Microshield for a constant source of Cs-137 and Co-60 activity (proportional to their nuclide fraction) assuming the volume of contaminated concrete equal to the area of the activity times a depth of 15 cm (the expected depth of view of the Nal detector). The exposure rate calculated from Microshield was then converted to counts per minute using the Cs-137 conversion factor from NUREG-1507 (900 cpm per uR/hr), which was appropriate considering Cs-I 37 is ten times for prevalent in concrete than Co-60. This count rate was used to develop a "source mutliplier" by dividing the grid gamma result (with 20k cpm background subtracted) by the Microshield calculated count rate. The source multiplier was then multiplied by the constant source and the volume of contaminated concrete to estimate the amount of activity above background contained in the elevated area.

This activity was then analyzed using the LTP Basement Fill dose model for contaminated concrete to determine the dose impact. The eight areas along with their respective dose impacts are identified below:

Gamma Result Area Dose Scan Grid (cpm)

(cm2)

(mrem/yr)

FA-1700-03-CIOI 31,000 929 1.00 E-05 FA-1700-04-C094 36,700 100 3.43 E-05 FA-1700-05-C053 35,000 25 2.44 E-05 FA-1700-05-C082 60,600 64 1.60 E-04 FA-1700-05-C039 46,500 50 8.66 E-05 FA-1700-05-CI 15 31,000 200 6.30 E-06 FA-1700-06-C132 32,000 6,700 7.42 E-05 FA-1700-08-C092 35,400 2,500 9.70 E-05 Total: 4.93 E-04 Cs-137 & Co-60 5.52 E-04 all radionuclides This is a small dose impact compared to the total dose allowed in the NRC Radiological Criteria for License Termination and the State of Maine's Enhanced Criterial of 10 mrem/yr all pathways including 4 mrem/yr from drinking water sources of groundwater. This dose impact is also small compared to the general, simplified retrospective dose from the spray building survey units (0.01 mrem/yr on average). The dose impact from the areas is sufficiently small as to be negligible and therefore will not need to be added into the EMC Unity Rule for these survey units.

Attached is the spreadsheet used to determine the source inventory.

Area cpm > 30k (cm2)

Vol (cm3) uR/hr Equivalent source cpm multiplier Grid FA-1700-03-CO1l FA-1700-04-C094 FA-1700-05-C053 FA-1700-05-C082 FA-1700-05-C039 FA-1700-05-C115 FA-1700-06-C132 FA-1700-08-C092 1,000 6,700 5,000 30,600 16,500 1,000 2,000 5,400 929 100 25 64 50 200 6,700 2,500 13,935 1,500 375 960 750 3000 100,500 37,500 3.80E-02 8.OOE-03 2.10E-03 5.OOE-03 3.90E-03 1.30E-02 7.40E-02 5.70E-02 3.42E+01 7.20E+00 1.89E+00 4.50E+00 3.51 E+00 1.17E+01 6.66E+01 5.13E+01 2.92E+01 9.31 E+02 2.65E+03 6.80E+03 4.70E+03 8.55E+01 3.OOE+01 1.05E+02 Cs-137 Inventory (ci) 1.10E+05 3.77E+05 2.68E+05 1.76E+06 9.53E+05 6.93E+04 8.16E+05 1.07E+06 Co-60 Inventory (pCi) 1.16E+04 3.96E+04 2.82E+04 1.85E+05 1.OOE+05 7.28E+03 8.56E+04 1.12E+05 Dose (mrem/y) 1.OOE-05 3.43E-05 2.44E-05 1.60E-04 8.66E-05 6.30E-06 7.42E-05 9.70E-05 4.93E-04 Co + Cs 5.52E-04 all radionuclides Check of potential total dose from 10,000 cpm above background in 800 m2 in spray building 1 m2/15cm jM2/jCM 10,000 10,000 150,000 7.90E-02 7.11E+01 10,000 10,000 10,000 1.43E-02 1.29E+01 1.41E+02 5.70E+06 7.77E+02 2.10E+06 0.46 mrem/y assuming 800 m2 in spray building potential for 5.99E+05 volumetric contamination 0.17 mrem/y assuming 800 m' in spray building potential for 2.21 E+04 volumetric contamination Assumptions contamination uniformly distributed over 15 cm depth (worst case) spray building fill volume = 2400 m3 spray building surface area = 1600 m2 900 cpm/uRlhr conversion factor total dose equals (Co + Cs)*1.12 to account for all radionuclides in mixture microshield runs used baseline concentrations of 0.01 Bq/cm3 Cs and.00105 Bq/cm3 Co (the assumed baseline concentrations do not affect result since accounted for in source multiplier)

Appendix I FA-0600 Primary Auxiliary Building Survey Unit No. 1 Final Remediation Survey Gamma Scan For Scan Grid C437 Corresponds to FA-0600 Survey Unit No. 11 Scan Grid 016 Survey dated December 17 and 18, 2003

FINAL RAD REMEDIATION SURVEY Survey Unit#

11 DataFormr:

N/A Related FSS Package :

FA0600 Page 1 of Survey Area:

PAB Survey Unit 11 Floors and and walls of Primary Water Pump Cubicle RWP/WAN:

Survey Date: ia-17-03 Instrument SIN Cal Due Detector SIN Cal Due E400 I

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Appendix J FA-0600 Primary Auxiliary Building Survey Unit No. I Wall Scan Grids C026, C039, C086 and C087 and Survey Unit No. 10 Floor Scan Grids C029 and C064 Picture of Final Condition showing Wall & Floor Scan Grids Being Removed and Survey Unit No. 10 Wall Scan Grid C213 Final Rad Remediation Survey dated November 19, 2003 showing area below SU-10 Boundary (below 17 ft elevation) less than 30 k cpm

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Appendix K FA-0600 Primary Auxiliary Building Survey Unit No. 6 Scan Grids C334, 350, 351, 356, and 357 Final Remediation Survey dated February 13 & 17, 2004 and Survey Form MAP ID # TA-0600-6j dated February 18, 2004

REMEDIATION SURVEY DATA Survey Unit #:

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Map ID #: TA 06C Decommissioning Team IMainc Yankee Decozinnissioning Project Survey Formn Revised: 2-18-04 Survey Type:

0 Characterization 13 Turnover 0 Final Status Survey Survey Area Name: Primary Auxiliary Building

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Appendix L Maine Yankee Condition Report No.04-126 and Final Remediation Survey Gamma Scans for FR-0600 Primary Auxiliary Building Survey Units Survey Unit Scan Grid(s)

Survey Date(s) 12 Trench April 2, 3, 4, 7 and 23, 2003 1

C075 November 13, 2003 4

C012, C048, C061, C076 January 7,2004 5

C103 January 26, 2004 6

20 out of 27 Grids*

February 11 - 12,2004 12 C003, C012 January 29, 2004

C127, C138, C140, C142, C161, C170, C172, C176, C178, C180, C226, C248, C255, C259, C2778, C279, C295, C297, C298 AND C303

Proc. No. ISFSI 0-16-1 Rev. No. 2 Page 7 of 17 ATTACHMENT A ISFSI CONDITION REPORT PART A: ISSUE IDENTIFICATION CR NUMSR:

o Cf_ / a>TCR INITIATION DATE/TME: 09t1 4ID4 061 5 DISCOVERER: R. Tozzie 7 ISSUE TITLE: Locations not scanned during FSS of PA8 SUS and SU12 ISSUE DESCRIPTtON: Final review of PAB survey pactkage FA0600 identified scan grids that were not surveyed. Locations Intified are a section of trench in the P-8 cube (SU 12) and the floortwall juncture around the Letdown Heal Exchanger cubide (SU5).

Aftachmnrj YES O7 NO ft IMMEDIATE ACTIONS TAKEN. Notified FSS MOP and FSS Suporinlendent. Began evaluation.

Arfecwnwnt YES D No IO HAND CARRYIFAXIE-MAIL THIS FORM TO THE ISFSI SHIFT LEAD Contact the ISFSI Shift Lead by telephonr (882-1309) to ensure the CR was rnceveed.

understooid. and to resolve any quesions from the ISFSI Shift Lead.

PART B: ISFSI SHIFT LEAD REVIEW ISFSI SHIFT LEAD: A{2r&

DATEMlME:

5=

7r COMMENTSICORRECTIVE ACTIONS TAKEN:

OPERABLE YES O) NO 12 N/A 0 AttaxCmjf YES £7 NO REPORTABLE YES O0 NO 9 AttaIp" YES O7 NO 9, Shmt~ead

/-Da PART C: ISFSI MANAGERIDESIGNEE 9/419 REPORTABILITY1OPERABLITY VALIRYION SAT "'L*SM o if tr*Acry. ach clau of *c11n Iuikn.

SIGNIFICANCE: l0 SCAO XCAO 0 Other EVALUATION LEVEL:

0 O A PX 0 C Assigned Issue Owner:

PAc/e v-Sign:

Date Delivered:

9115104 Ations taken are sufficient to resolve Issue and close CR7 YES 17 No A

t ISFSI ManagerDesignee DT3e AudWSurveitlanCe CR? YES £ NO O It YES, Verify ted adequaq d te corffCSve wciom and cmrm tt the cwtIve xons v aconVlshnd a-sdd ISF1S1 QAIDesignee Dale

Proc. No. ISFSI 0-16-1 Rev. No. 2 Page 8 of 17 ATTACHMENT B CORRECTIVE ACTION REPORT FORM CORRECTIVE ACTION BDue Date: m/6/oq I CR 04-126 Evaluation AO Be CO ASSIGNED CORRECTIVE ACTION(S)

AND ACTION COMPLETED COMPLETION DOCUMENTATION TO SUPPORT CLOSURE (Signature)

DATE SP2 - Pre-work FSSE review of survey mapping design SP5, SP8 - Use tracking system to follow-up open items and survey discrepencies l

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t l - Y WC2 - Change survey design process to identify interface points between survey units 4

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° WK2, SP5-Require post-design field inspection

& design confirmation I$/

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104 WK2 - Conduct Training I briefing session with FSSS, FSSE to review self-checking, expectations, and attention to detail with specific reference to this CR.

a

___Of__

Document evaluation of adequacy of surveys, impact on release decisions, and extent of

/

condition.

(

li° Notify FSSMOP & FSSSup, Begin evaluation 8 J N 2k;,

l 11,3; APPROVAL FOR CLOSURE Responsible Department Manager/Designee:

r 4 96 J by a A ate:

{ 2,s /D/

ISFSI Manager/Designee:

g o

Date:

President (SCAQ only):

Date:

Proc. No. ISFSI 0-16-1 Rev. No. 2 Page 9 of 17 ATTACHMENT C BARRIER SCREEN BARRIER SCREENING ISSUE / CR # 04-126 ISSUE

SUMMARY

Portions of a survey unit were omitted from the Final Status Survey design CORRECTIVE ACTIONS PROBLEMS BARRIER (Strengthen/Added Barriers)

(Cause of Failed or Missing Barriers)

CODE (Include: Task Owner & Target Date)

See attached page 5 of 7 SP2 See attached Page 5 of 7 R Leddy, 12/01/04 See attached page 5 of 7 SP5 See attached Page 5 of 7 R Leddy, 12/01/04 See attached page 6 of 7 SP8 See attached Page 6 of 7 R Leddy, 12/01/04 See attached page 6 of 7 WC2 See attached Page 6 of 7 R Leddy, 12/01/04 See attached page 7 of 7 WK2 See attached Page 7 of 7 R Leddy, 12101/04 4-I (Use additional pages as necessary)

Print Name:

e:_ _ __a_

Sianature:

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4 Page I

of I

CR 04-126 Attachment Page I o' 7 Small portions of juncture and trench were not surveyed in the PAB.

SU5:

The floor / wall juncture (about 40 feet) on the outside of the Heat Exchanger Cubicle in Survey Unit 5 was not included in the survey design. This represents about 1% of the PAB juncture length.

SU12:

A 5 foot section of trench in Survey Unit 12 located in the P-8 cubicle was not included in the survey design. This represents about 1 % of the PAB trench area.

Assessment:

The survey data (form 6 s) for the entirety of the PAB were reviewed to identify additional areas related to interferences that may not have been surveyed. This extent review identified the following, organized by survey unit:

SUl:

A penetration in grid C075 was not surveyed. This penetration is part of the fire service system, which, based on inteviews, is a separate survey unit. However, there is no indication in the PAB SUl records that this penetration is covered in another survey unit.

SU4:

Eighteen grids (C012, C048, and C061 through C076) contained interferences that did not receive FSS quality surveys but were surveyed.

Based on the data and interviews, the interferences in grids C012 and C061 through C076 were removed, the grids surveyed, and then the Interferences were replaced. Subsequently, the survey instrument quality assurance was questioned due to a lack of a post use source check. Since the data then became questionable, the grids were re-surveyed, but without removal of the interferences. These interferences consisted of wires and in C070, a junction box.

The interference in grid C048, a security camera, was not removed for the survey and the grid was not repeated in the follow-up.

SU5:

Grid C103 had interference from scaffold, covering about 10% of the grid. This grid was resurveyed on the same day with a notation that 10% of the grid was surveyed.

However, it is unclear that this represents coverage of the interference or a normal SHP360 follow-up for surface condition of other portions of the grid. Interviews are also inconclusive on this.

CR 04-126 Attachment Page 2 of 7 SU6:

Twenty-seven grids (C127, C138, C140, C142, C161, C170, C172, C174, C176, C178, C180, C226, C248, C255, C259, C277, C279, C295, C297, C298, C303, C342, C343, C348, C349, C351, and C350) had interferences in the grids that were re-surveyed following removal of the interferences. However, the survey was not an 'FSS quality' survey and the survey as recorded does not contain any measurement data, only a notation that the areas were surveyed. In addition, the survey meter used failed the post-use source check low (about 20% below the minimum of the allowable range).

Interviews indicate that there were no alarm conditions detected in the survey.

SU12:

Two grids (C003, C012) had interferences that were not resurveyed.

Spray Building:

The survey design maps for the entirety of the Spray Building were reviewed to identify possible design omissions in the survey coverage that may have resulted in areas not receiving a survey. This extent review identified the following:

Based on interview(s) surveys of doorway frame faces, large penetration (holes in the floor) faces, doorway frame bottom junctures, and ends of 'floating' walls and floors were conducted with a wall or floor grid that encompassed the surface. However there are no notations on the form 6s that this was done and no instructions to do this on the design forms. In the PAB, these surfaces (in particular, doorway faces and wall-ends) were explicitly identified as grid locations. The documentation is incomplete on the surveys of these spray building surfaces.

Based on the drawings and follow-up interviews, the upper side of the 14' elevation In the E-3B cubicle contained a toe-curb (based on interviews, the toe-curb in the E-3A space was removed, but it is still on the survey unit drawings). The resulting juncture space between the curb and floor was not identified on the surveys and does not have a juncture survey.

Upper corners of doorway frames are not identified as junctures on the drawings and do not have a juncture survey.

Survey unit 1 does not identify junctures between the top of the foundation blocks and the south wall. Juncture surveys may not have been required due to the 'rounded' as left condition but it is not clear from the existing documentation.

Vertical joints In the upper floor 'tray' area shown on the drawings are not identified as junctures. Interviews indicate that those walls were removed and those junctures are not -

present. However, a spot check of the design forms (2,3,4,5) and drawings for survey units 2 and 3 all indicate that these 2'/2 foot high walls were present. Documentation should indicate that these are not present if they were removed prior to the FSS.

Based on the extent review of the PAB and the Spray Building, and assuming that these are typical, it is likely that FSS surveys will contain a small extent of omissions, caused

CR 04-126 Attachxnent Page 3 of 7 by either survey design errors or from incomplete follow-up of interferences. The evaluation addresses this degree of extent generically for FSS surveys.

Evaluation:

PAB SU 5 missing juncture survey:

The 43-68 detector was tested for gamma response to Cs-1 37 gammas through the side wall of the detector assembly. The efficiency is dependent on the placement of the source. With the source in the center of the side wall, the detector is 0.08% efficient while a slightly lower efficiency of 0.06% (as expected due to the geometry) is obtained if the source is nearer the front or back of the detector side wall.

Using the average of the front and center efficiencies (0.07%), the 43-68 detector would be capable of alarming at about 4.3E6 dpm with an area of about 80cm2. It is unlikely that such an elevated area would be discretely isolated to the limited area of the probe wall or that such an unusually elevated beta flux would not be during the adjacent flat d cl"c surface scans since there is a small 'standoff' from the surface during scan X

measurements, that provides some 'view' of the adjacent juncture area. This 'view' of the floor/wall interface area would certainly result in substantially better detection efficiency than for the gamma through-wall efficiency used here.

The LTP explicitly allows for adjustment of the area factor and thus the effective DCGLemc based on the actual area of concrete surface identified to have elevated activity. For normal basement concrete activity, the effective DCGLemc for a 80 cm2 area (twice the approximate area of the side of the probe) would be 1.1 E8 dpm/1 OOcm 2 (50m 2*18000dpm/1 OOcm2I80cm2). This results in a DCGLemc fraction of about 0.04 (4.3E6dpm/1.1 E8dpm/1 OOcm 2) at the detection (alarm setpoint) limit for a 43-68 probe through the side wall. The existing DCGLemc unity fraction for the survey unit is 0.06.

Even with the highly conservative assumption above, the survey unit remains well below the DCGLemc unity requirements.

A final remediation survey (1/21/04 through 1/29/04) of the juncture area reported about 22,000 cpm or less using a SSPA3. This was normal for post-remediation / pre-FSS survey results and is at most about 3500 cpm above the lowest values recorded in the survey unit. This puts an upper limit on the potential activity present that is well below the activities discussed above.

The SSPA-3 detector was tested for response to a Cs-1 37 source to determine the detection of a discrete elevated area in the juncture during the SSPA-3 scan of the adjacent grid. The SSPA-3 showed an efficiency of about 0.12% at 1 foot from a 'button' source. Therefore the SSPA scans of the adjacent grids would have detected activity on the order of 2.9E6 dpm, about half the conservatively estimated detection limit of the 43-68, in the juncture during the final remediation grid surveys.

It is concluded that while this small area was not explicitly surveyed consistent with the normal FSS design, there is no consequence to the conclusion that the survey unit meets the release criteria.

CR 04-1 26 Attachment Page 4 of 7 PAB SU 12 missing trench survey:

Interview(s) indicated that the trench area in the P-8 cubicle had been extensively remediated, and that the entire floor area, including the remediated trench (which reportedly was no longer a trench, but was a depression in the floor) was surveyed with 43-68 and 43-37 detectors. A remediation survey conducted on 4/7/03 showed less than 1500 cpm in the trench inside the cubicle measured with a 43-68 detector.This is well below the typical FSS 43-68 alarm setpoint and represents a value less than the DCGL A final remediation survey of the P-8 area on 4/22/03 reported a maximum of about 5000 cpm from the 43-37. These results are normal for post-remediation / pre-FSS survey results and is equivalent to about 27000 dpm. This puts an upper limit on the potential activity present, and is equivalent to about a 0.0006 DCGLemc fraction.

While this small area was not explicitly surveyed consistent with the normal FSS design, it is likely that substantial portions of it received FSS quality surveys during the FSS survey of the floor (SU 7) due to the post-remediation as-left condition of the surface. It is concluded that there is no consequence to the conclusion that the survey unit meets the release criteria.

MARSSIM:

MARSSIM Appendix N discusses the condition where less than 100% of the survey unit measurements are completed. This appendix distinguishes between this 'completeness' and 'representativeness'.

Representativeness is affected by survey bias and inaccurate measurement and may be resolved by additional measurements.

Completeness is the ratio of the survey that was actually done to that intended to be done. Completeness does not measure representativeness. A survey may be fully representative with less than 100% completeness, while a 100% complete survey may not be representative due to various potential errors or discrepancies in the survey design or measurements. Generally, completeness is an issue more applicable to the direct measurements. The direct measurement design is based on selecting a number of samples sufficient to provide adequate 'power' to demonstrate compliance, and the value of 'N' accounts for the possibility of 20% incompleteness in the direct survey.

The FSS surveys reviewed demonstrated a strong 'power' providing high confidence that the survey unit satisfied release criteria. Thereby, the representativeness of the surveys is high. A completeness of slightly less than 100% in the scans does not affect the conclusion that the unit meets the release criterion. This is an essential purpose of the direct measurement with supplemental scan survey design process in MARSSIM: to ensure representativeness through survey design with allowance for variations in contaminant concentration and survey extent.

Generally, these or other MARSSIM based FSS surveys that: 1) meet design criteria for

'N' directs (and many FSS surveys exceed the minimum N defined by the statistics), 2) have sufficient power, but 3) have slightly less than100% completeness in the scan, either from omissions or interferences, will be fully acceptable for use in demonstrating compliance.

CR 04-126 Attachment Page 5 of 7 Barrier Screen SP2 - Pre-Work Document Review Problem - Pre work independent review is conducted on the forms that define the survey design. However, the pre-work, independent review of the survey design mapping to assess the completeness of the survey design is less formal and may be less detailed and complete in actual implementation.

CA - pre work FSSE review of survey mapping / design Step 6.8.3 of PMP 6.7.4 requires "The FSSE reviews the survey design, and instructions..." This step includes document review and approval of the finished package design, with signatures on various forms. The step does not explicitly require a thorough independent verification of the layout. The process currently could be conducted by reading through the package and verifying that the design is typical, that all of the forms are complete, etc. A thorough inspection and confirmation that the design contains no omissions in the physical layout of the survey grids is not explicitly required. This procedure step could be changed to include, or management direction could be given through explicit definitions of expectations, to specify the extent required in the 'review' in step 6.8.3.

SP5 - Post Work Review Problem - Extensive post-work review is conducted of the survey results. Thiis process detects missing or incomplete survey data and provides feedback to the survey process to complete surveys and repeat surveys when needed. However, there is a large amount of data, and numerous follow-up issues are identified in any given survey unit. This barrier could have identified the grids that needed additional measurements and/or documentation (identified in the extent review). The challenge rate on this barrier Is high, with numerous issues and problems with the survey data, survey unit condition, removable interferences, etc. in most survey units.

CA - use open item tracking to reduce opportunities to overlook follow-up Management can specify that open item / issue tracking be used in survey package development, conduct, review, and closeout. The electronic data systems currently in use include network folders allocated to each survey unit accessible to anyone working on the package. A common tracking file can be set up to allow persons identifying items to log them on a survey unit specific basis.

This could be any item that has the potential to be pending for a period of time, that has the potential to be forgotten or overlooked. This could take any simple form desired. A Word document that is used as a 'shopping list' may suffice.

CR 04-126 Attachment Pag~e 6 of 7 SP8 - Work Environment Problem - The conduct of an FSS ideally will be in an empty space, free of interferences, in-use equipment, and other work in progress. The presence of interferences, ongoing adjacent work, etc. challenges the conduct of the FSS and reduces the effectiveness of this barrier. The presence of scaffold and still-in-use equipment provided a challenge to this barrier.

CA - same as SP5 The open item tracking system would easily include interferences ('scaffold pole 100cm2 grid C023') and other items ('penetration to be done in SU3') that affect completeness of the survey. Action sufficient to accommodate SP5 should suffice for this as well.

WC2 - Sufficient Information Problem - The interface points between survey units are not completely connected.

When an item exists in two different survey units, there is no information provided between the two units. For example, if a penetration goes between two rooms that are separate survey units (e.g. 1 and 2), if the penetration is surveyed in sul, then the su2 unit should indicate that the penetration is covered in sul and sul should indicate which unit it interfaces with. The lack of written documentation 'connection' at interfaces provides an opportunity to miss such interface points.

CA - change survey design process to identify interfaces Survey unit designs do not generally explicitly define where interface points are.

When a survey unit ends at the wall of the next cubicle, the unit does not explain that the wall is not included because it is in a different survey unit. Definition of this in the survey design may improve the opportunity to Identify interface problems. For example, if a survey includes a wall with a penetration but not the penetration, there is an opportunity to overlook the penetration in the other survey unit, if there is no documented connection. Management expectation should be communicated that survey design should be explicit about interface points. 'Wall and wall/floor juncture included in survey unit 6'. Such items can also be included in the action item tracking of the other survey unit until that unit is designed.

CR 04-126 Attachment Page 7 of 7 WK2 - Self Check Problem - The omissions in survey design specifically identified in the CR could be identified with a thorough self-check of the work. Personal observation of the survey unit is used to design the unit survey and to verify the design. Post-design checking of the design maps should identify omissions.

CA - implement requirement to perform 'ground truthing' post design phase and prior to the review identified in SP2 This action is similar to the corrective action discussed for SP2 and could be included in that action. The survey design process can be conducted In parallel with remediation and / or demolition. Therefore, there may not be opportunity to fully observe the final configuration of a survey unit during the design phase.

Management expectations should be communicated to the FSSS, FSSE that a final walk-down to review the survey unit condition, and verify the mapping and grid layout should be conducted as close as possible to the start of FSS survey.

CA - training / briefing session with FSSS, FSSE to review self checking, management expectations, attention to detail, etc. specifically discussing this CR.

Management should conduct a training / briefing session with all FSSS, FSSE, SFSS, etc. to review the events surrounding this CR. The event itself, the failure modes, the missed barriers, corrective actions, and revised management expectations intended to strengthen barriers should be communicated. Input from attendees should be used to adjust the corrective action implementation if needed.

Prepared By: W. J. Cooper 9I I

i'/

Reviewed By:

(

2 1

30 oy4

RAD REMEDIATION & FSS BRIEFING ATTENDANCE FORM Briefing Topic:- CR04-126-Evaluation. Barrier Screen and Exprectations NAME INITIAL DATE Anderson, Dccl Cooper, Bill

/ -

/

1Dockins, Larr 12 l

L~cddy,° Bob)X1;1 lo, Litton, Vicki L

Va' 12-ol Madison, Gordon Z/ /

0 V

Olsen, And)'

cc.

a Packer, Jim 14/

Pillsbury, Gcorge.

N.R.

Randall., Dalc Tozzic, Robert N.R. = Not required to attend

RAD REMEDIATION & FSS MEMORANDUM ro: Distribution DATE: Decemher 1, 2004 FROM: Bob Leddy. Supcirinten1cnt. 1Y;S (SFSS)

FIL;E: REL-04-003 SUBJECI': FSS lExpectations Rcsulting From CR 04-126 Barrier Screen Refercuce

1.

Maine Yankcc Condition Rcport (CR) No.04-126, "Locations not scanned during FSS of PAB 51U5 and SUl12", initiated Scptemhcr 14,22004.

Issue Dcscipioln Final review Ofr PAB survey packagc FAO600 identified scan grids that werc not surneyed.

Locations identificd vcrc a section of trcnch in the P-8 cubicle (SU12) and the floor/wall juncture aroundl the Lctdown HX cubiclc (SUS).

In both cases (SUi5 & SU 12) thc areas in question were not included in the survcy design.

Thc extent of condition rcviewv of all PAB Form 6s identified additional locations where surveys wvcre either missc(l or not performed to ISS quality.

Discussion The cvalilation identified 5 failed harriers. Thlc failed barriers. problem statements, and expectations to strengthen thesc hairiers are provided belowv.

Failed Barrier 1: SP2 - Prc-WorkDocument Rcvie\\N' Problem - Pre work independent review is conducted on the forms that define the sunrey design. Howevecr, tile pre-work, indcpeiident review of the survey design mapping to assess tle completCenss ofthc surVCe d(csigl is lCss foma~l and may be les detailcd and complete in actual implementation.

Step 6.8.3 of PMP 6.7.4 requircs "'I'lic FSSE reviews the survey design, and instnictions..."

This step includes document revicev and approval of the finished packagc (lesign, with signatures on various forms. The step does not explicitly require a thorough independent verification of the layout.

Expectation WJIen perfor7minggStep 6.8.3 of 6.7.4, the FSSE is expected to read through thepackage and ver/if' iIha the (design is typical, that till of the forms are compalete, etc. In aldition, the ESSE vill perform aw(zlk dow n of the suiViey utit to confirn that the design contains no omissions in the physical layoutt of the sunrey gridls.

FailC(I BalTier 2: SI1P5 Post Work Review Problemi Extensive post-work review is conducted of thc survey results. This proccss detects missing or inconiplete survey data and provides fccdback to thc survey process to completc surveys and repeat surveys when neceded. However, these rcvicws gencrally result in a largc amount of dala. and numcrous followv-up issues arc identified in any given survey unit. Thliis rcvicw should have identified the grids that necded additional measurements and/or documentation (identified in the extent review). The challenge rate on this barrier is high, with numerous issues and problems with the survey data, survey unit condition, removable interrerences. etc. in most survey units.

ExpLectation f'or ctach stirve

packaOgC,

/hC assxigncd F.S.!' iw-ill create an open itemi / issue tracking docuwent oln the netwiork, itha is accessible to anyone working onl the package.

This document i'rill bIc used to capture ilenis that have either th/e potential to existfor extend/ed pcriodls *f tn' o(r have tlhe potciltial to befor rqouten or overlooke(l. This document can be creatcd in cit/ier I'ord ('punch list) or Excel. IIcn each: of the items have been addressed, they can eithe-r ye (cleted firomiihc Jmor orstrucktlhough. Themnanagement releiew priorto ESS release of t/c unit should addries the fiict that the document has been revielvedfor closure. 7Th list may allso incld(fe actiois assigne(l (luring lhe mnanageimienrt re iew to track the itens to closiure. See Atnachient I for an example of such a list. ihi/li uaws used for FB2400-O1.

Failed BarTier 3: SPs - Work Environmcnt Problcrn The conduct of an FSS wvould ideally 'be in an empty space, free of interferences, in-usc equipment. and other work in progress. The presence of interferences. ongoing ad jacent work. ctc. challenges the conduct ol the FSS and reduces the cffcctivcness of this barrier. Thc presence of scaffold and still-in-use equipment provides a challenge to this barrier. Without a method of capturing these 'challenges", they can be Iorgotten.

l.'.pectaltioui (Jsc the open itemt / isste tracking dcuminent discussed above to capture intciferences (and othler portions (of the surve) that coull not be pci formed.

Failed Barrier 4: WC2 - Sufficient Information Problem - The interface points between survey units are not always completely connected.

Whcn an itcm exists in two different surAvey units, there is no information provided between the two units. For example, i fa penetration goes between two rooms that are separate survey units (e.g. I and 2), if the penetration is surveyed in SUI, then the SU2 unit should indicate that the penetration is surveyed in SU I and SU I should indicate which unit it interfaces with.

The lack of written documentation connecting the interfaces provides an opportunity to miss such interface points.

Sur vv u init (lesigils do not gencrally explicitly dclinc wvhere interface points exist. When a survcv unit ends at the vall of the next cubicic. tile unit does not explain dial tile wvall is not included because it is in a different survey unit. I)elinition ol this in the survey delsign may improve tile opportunity to i(lentify interface problems. For exampie, ifa survey includes a wvall with a penetration but not the penetration, there is an opportunity to overlook the penetration in the otiler survey unit. i ftIerc is no documented connection. Depepnding on the magnitude ofthe effort required to survey the interface, it may be appropriate to include it in both survev Units to decrease the likelihood that it will be missed.

Ypecr at ionl WIhenc' cesigningf inal status surnl s, eavplicith, identiy the infterfaces wit/h a(jacent survey, ulnits. A a examalllie statentc! Imniight he, "If'all enul wall/JloorjuncluLre incluetl in survey unit 6". Such iteniisC c'n alo hc inc lte(l in thle oietion iteli tracking oft/c othte 0

.ve~sti ' unit until that iil is (kesigine(L.

Failed Barrier 5: WK2 - Self-Check Problem - Trhe omissions in survey design specifically identified in the CR vere not identified prior to the start of survey activities. Personal observation of the survey unit is used to design the unit sUTrvey and to verify the design.

EXpcctation The rFSSE :assigned to the survey uait wlill petform an independent review of t/e surve.y lesign ndul izne s and strive to itleanteif ontissions in thic surne) (lesign andi also ensure that surey unilt inlerfaces, as (lescrilbee I ahove! are cffectively captured.

Cc:

.1. Connell

.1. P'acker G. Pillsbury CR04-126 File Attachment Distribution:

D. Randall V. Litton 1,. Dockins D. Anderson R. To7zicV W. Cooper A. Olsen G. Madison

REL 04-003 Attachment I FB2400-01 open items Address comments from form 6s Stair interferences C025 400cm2 C026 1/3 grid C029 200cm2 C030 1000cm2 C034 - Y2 grid electrical panel C035-100 cm2 unistrut C052 100 cm2 damp C109 400cm2 rough, damp, not surveyed C078 100 cm2 damp Expected resolution - survey unit OK as is, class 2 scan area is 10-100%, use damp eff in RR for damp grids. All grids results actually <damp setpoint even if originally scanned with dry flats setpoint Demo will include removal of piping, stairs, upper portion of walls, dividing wall.

Some follow-up demo survey will be required.

Follow-up from closeout meeting:

1) chhik-instntees4 efr5

,stos-tG.

done 11/1/04wjc

2) identify pipe in sump, put on sump map

CR 04-126 Portions of PAB Survey Units (SU5

& SU 12) were omitted from the Final Status Survey Design 0 4 -I6 FL

Survey Unit Design Omissions

SU5 - floor / wall juncture outside the HX cubicle not included.

SU12 - 5' section of trench in the P-8 cubicle not included

Extent of Condition

SUl - penetration in grid C075 was not surveyed.

SU4 - 18 grids contained interferences that did not receive FSS quality surveys.

SU5 - Small area potentially unsurveyed

SU6 - 27 grids contained interferences that did not receive FSS quality surveys.

Extent of Condition (cont'd)

SU 12 - 2 grids had interferences that were not resurveyed.

Spray Building - Some design discrepancies

Consequences

No consequence to the conclusion that the survey units meet the release criteria.

Barrier Screen

SP-2

SP-5

SP-8

WC-2

WK-2 Pre-work Document Review Post-work Review Work Environment Sufficient Information Self Check

SP-2 Pre-Work Doc. Review Problem - Procedure PMP 6.7.4 requires a review of survey design and instructions but does not require a thorough inspection of the survey unit.

Expectation - Include a physical walk down of the survey unit in the review.

SP-5 Post-Work Review

Problem - Issues and problems occur during the conduct of surveys.

Expectation-issue tracking issues FSSE creates an open item /

document to capture these

SP8 - Workl Environment

Problem - Presence of interferences challenges the survey.

Expectation - use open items / issue tracking document to capture interferences.

WC2 - Sufficient Informlation

Problem - When an item (doorway) exists in two different survey units, information is not always captured as to which unit the item belongs.

Expectation - Identify the interface points in the survey design even if in another survey unit. Consider inclusion in tracking docurnent.

WNK2 - Self Check

Expectation - Self check, self check, self check. Second walk down and intermittent walk downs of unit before / during survey.

FSSE independent review and walk down during surveys.

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REMEDIATION SURVEY DATA Survey Unit #:

4 Data Form #:

N/A Related FSS Package #:

FA0600 Page 2 of I Surveys I

it 4

i f

Scans (Peak Hold)

Elevated Related Survey Grid Inst.

Result Area Location Pair (cpm) cm2 COMMENTS FA0600-04 iD3 b

1 JU K FA0600404 Cf5..

1.9q KiK FA0600404 e054j jq 3 I

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Elevated Related Survey Grid Inst.

Result Area Location Pair (cpm) cm2 COMMENTS FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 FA0600-04 a

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Related FSS Package #:

FA0600 REMEDIATION SURVEY DATA Survey Unit #:

5 Data Form #:

NIA Page 1 of 1 Survey Area:

Survey Unit 5 Primary Letdown Open Area (FA0600-SU-5)

RWPIWAN:

04-00001/51851300 Survey Date: /&

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Survey Team

.9, L oj

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Elevated Relited Survey Grid Inst.

Result Area Location Pair (cpm) cm2 COMMENTS FA0600-05 C101 1-4 188 K PI /A I

FA0600-05 C102 A

,cqk =

I=

FA0600-05 C103 A

20-5k_

FA0600-05 C105 A

22a____

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1 CAfanlnfn fis4 Scans (Peak Hold)

Elevated Related Survey Grid Inst.

Result Area Location Pair (cpm) cm2 COMMENTS FA0600-05 FA0600-05 FA0600-05 FA0600-05 FA0600-05 FA060005 FA0600-05 FA0600-05 FA0600-0S FA0600-OS FA0600-05 FA0600-05 FA0600-05 FA0600-5O

REMEDIATION SURVEY DATA Survey Unit #:

6 Data Form #:

NIA Related FSS Package #:

FA0600 Page t of :2_

Survey Area:

Survey Unit 6 PAB (FA0600-SU6)

RWPIWAN: o '-OcowO Y3Y/S

'° Survey Date:

b2-b Instrument SIN Cal Due Detector SIN Cal Due Pair E-.600 I

f; 2 i//ts Y

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)..' 5fl2>/c A

E-600 SSPA-3 B

E-600 SSPA-3 C

E-600 SSPA-3 j

D E-600 SSPA-3 E

E-600 SSPA-3 F

,,h-Syey Team Reyjes.

, /

v A~.v 217/09 Surveys Scans (Peak Hold)

Elevated Related Survey Grid Inst.

Result Area Location Pair (cpm) cm2 COMMENTS FA0600-06 C

A 1r3,.

jY4 at FAO600-06 C023 A

FA0600-06 Co3 A

1L LIS-FAOGOO-06 CO31 A

1 FA0600-06 COG 3I A

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,Elevated Related Survey Grid Inst.

Result ArEa Location Pair (cpm) cm2 COMMENTS FA0600-06 CI A

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REMEDIATION SURVEY DATA Survey Unit #:

6 Data Form #:

NIA Related FSS Package #:

FA0600 Page I of 2

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Survey Unit 6 PAB (FAO600.SU6)

RWPJWAN: o.

n C/

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Result Area Location Pair (cpm) cm2 COMMENTS FAOOO-6OB 9 16 4 1,O.b&e

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Elevated Related Survey Grid Inst.

Result Area Location Pair (epm) cm2 COMMENTS FA 0600.0 O B 0 J 2

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Related FSS Package #:

FA0600 REMEDIATION SURVEY DATA Survey Unit #:

6 Data Form #:

NIA Page d of 2 Survey Area:

Survey Unit 6 PAB (FA0600-SU6)

RWPIWAN:

/./ /'.

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2//z / a y Survey Team S7'it 6 GA k Instrument SIN Cal Due Detector SIN Cal Due Pair E.600 l 33

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Re vw:

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Elevated Related Survey Grid Inst Result Area Location Pair PM)

Cm2 COMMENTS FAO600O0B 3o.3 I4

/7 c

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FA0600406

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Ele~vated Related Survey Grid InsL Result Area LocatIon Par cpm) cm2 COMMENTS FA06 00-06 FAOOO-B06 FAOBOO406 FA0600-06 FA0600-06 FA0600-06 FAO600-06 FA0600-06 FAO600.06 FA0600-06 FA0600-06 FAO600.06 FAO600-06 FAO600-06 FAO600460

REMEDIATION SUR Survey Unit #:

12 Data Fc Related FSS Package #:

FA0600 VEY DATA rm #:

NIA Page I of 34'*

RWPNVAN:

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=

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Survey Area:

Survey Unit 12 PAB Trenches (FA0600-SU12)

Survey Date:

Instrument SIN Cal Due Detector SIN Cal Due Pair E.600 3 e. A SSPA-3 A

A E-600 SSPA-3 B

E-600 SSPA-3 C

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Elevated Related Survey Grid Inst.

Result Area Location Pair k

cm2 COMMENTS FA0600-12 157 31 1 ? 23 j'4.

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FA0600-12 pL

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FA0600-12

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y4 Surveys Scans (Peak Hold)

Elevated Related Survey Grid Inst.

Result' Area Location Pair It(cpm) cm2 COMMENTS FA0600-12 Lt I t 2 /Y.

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l FA0B00-12 t~'3 5

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REMEDIATION SURVEY DATA Survey Unit #:

12 Data Form #:

N/A Related FSS Package #:

FA0600 Page & of -3 Survoy Area:

Survey Unit 12 PAB Trenches (FA0600-SU12)

Survey Date:

Instrument SIN Cal Due Detector SIN Cal Due Pair E-600

'v.&

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SSPA-3 725 3, u.

l E.600 SSPA.3

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Elevated Related Survey Grid Inst.

Result Area Location 6

3,_Palr (cpm) cm2 COMMENTS FAOtOO-12 "A

Z gI, 3 FA0600A12 3

A

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i

= =-_

FA0600 12 Scans (Peak Hold)

Elevated Related Survey Grid Inst.

Result Area Location Pair (cpm) cm2 COMMENTS FA0600-12 FAO600-12 FA0600-12 FA0600-12 FA0600.12 FA0600.12 FA0600.12 FA0600.12 FA0600-12 FA0600-12 FAO600.12 FAO600.12 FA0600.12 FA0600.12 FA0600.12 IFA0600-12 I /

Appendix MI LTP Change Concrete Remediation Gamma Scans Dated February 15, 2005

Proc. No. ISFSI 0-06-4 Rev. No. 1 Page 9 of 1 1 ATTACHMENT B 50.59 SCREEN I.

ActivitylDocument Number:

L Revision Number:

Title:

Li cetr,

'1 T ett 2 P/1 BriefDcripti n of Activ(what is beig cha9edand hY).

a reryel6,dfh 4, r0 L e lwe 62"<r

~~~

ew 1<

ot j/

0 Continued II.

Applicability Determination Other applicable processes identified during the applicability determination:

III.

50.59 Screening Questions (check correct response)

1. Does the proposed activity involve a change to an SSC that adversely affects a DSAR described design O Yes function?

2.

Does the proposed activity involve a change to a procedure that adversely affects how DSAR described G

O Yes SSC design functions are performed or controlled?

3.

Does the proposed activity involve revising or replacing a DSAR described evaluation methodology that G

O Yes is used in establishing the design bases or used in the safety analyses?

4.

Does the proposed activity involve a test or experiment not described in the DSAR. where an SSC is 11w Yes utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the DSAR?

IV.

If all questions are answered NO, then implement the activity per the applicable plant procedure for the type of activity without obtaining a License Amendment.

i/A If any of questions 1-4 above is answered YES, then a 50.59 Evaluation shall be performed. /Vtl 50.59 Evaluation No.

V.

List the documents (DSAR, Technical Specifications, and other documents) reviewed where relevant information was found, including section numbers:

o Continued VI.

If the conclusion of the screening questions is that a 50.59 Evaluation is not required, provide justification for that determination:

$5-e /+hc bJ O Continued VII. Screen Signoffs:

Screen Preparer: (printname)

A1AAc

l.

Ail (sign)

Date:

)/

0 ScreenReviewer:(print name)

// /(/>

(sign)

Date:

i

/

e ~---71Y

Proc. No.26-315 Rev. No. 2 Page 10 of 12 ATTACHMENT A (Page 1 of 2)

EVALUATION CHECKLIST FOR A PROPOSED CHANGE TO THE MYLTP Document No. LT P Rev. No. 3 Cognizant Individual: _______L_

Title:

Llreuse Ter`

,t P/G,,

Brief Description of Change to the Proposed MYLTP: A cli a ree I

d bon sUvrtr <-

-P ternelf t Lt Scre6eenet7 7,

-e lerk i I>c1 Ib Iict?: be I -s cek ?erl recb),

IQL_

e MYLTP Sections EVALUATION TO DETERMINE IF PRIOR NRC APPROVAL IS REQUIRED Would the proposed LTP change:

1. Require Commission approval pursuant to 10 CFR 50.59?

2. Violate the requirements of 10 CFR 50.82(a)(6)?

a. foreclose releases of the site for possible unrestricted use?

b. result in significant environmental impacts not previously considered?

c. result in there no longer being reasonable assurance that adequate funds will be available for decommissioning?

3.

Reduce the coverage requirements for scan measurements per Table 5-3?

4.

Increase the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs per Table 5-7?

5.

Increase the probability (a) of making a Type I decision error above 0.05?

6.

Increase a DCGL in Table 6-11 by more than a factor of two?

7.

Exceed Table 6-11 total annual dose of 10 mremlyr or drinking water dose of 4 mrem/yr?

State legislative action would be needed to make this change.

go Yes O

1 Yes-.

t<0-o Yes Ge0 0 Yes 9od Yes O Yes

'Prohibited IF any of the above questions are answered YES, THEN the change may not be implemented prior to obtaining NRC approval via license amendment submitted pursuant to 10CFR50.90.

IF all of the above questions are answered NO, THEN proceed to the next section and perform any required evaluations or notifications.

Proc. No.26-315 Rev. No. 2 Page 11 of 12 ATTACHMENT A (Page 2 of 2)

EVALUATION CHECKLIST FOR A PROPOSED CHANGE TO THE MYLTP EVALUATION TO DETERMINE ADDITIONAL NOTIFICATION OR REVIEW REQUIREMENTS Would the proposed LTP change:

1. Adversely affect a DQO process primary output?

2.

Involve changes to dismantlement activities that impact the final state of the site?

3.

Reduce a survey unit's classification?

4.

Increase activated concretelrebar DCGL or dose contribution greater than 1.0 mremlyr?

5.

Involve new instruments or technologies?

6.

Increase a Table 6-11 DCGL?

7.

Involve a change to radionuclide profiles?

YES NO If yes, perform the additional notification or review.

Review affected DQOs, if appropriate. See Maine Yankee DQO document.

Review impact on dose model,

)

characterization, FSS or environmental assessment.

Review IAW LTP 5.6.4 and

__perform 14-day NRC notice.

Perform additional ALARA evaluation IAW LTP 4.2.1.

Develop technical basis document IAW LTP 5.5.2.a and perform 30-day NRC notice.

Perform prior notice to state (State Nuclear Inspector(SNI)).

>(Perform 30-day notice to NRC

_ /tand state (SNI).

IF all of the above questions are answered NO, THEN no additional notification or review requirements apply. Attach completed 50.59 and submit to Licensing.

BRIEF DESCRIPTION OF ADDITIONAL NOTIFICATION OR REVIEW PERFORMED (Use additional sheets if necessary)

[V0 aJdJ,'ba la ndb/cj-,C S-7 -I.

LTP Change Initiator:

Date:

5 Date: 2

/Jg5 k) 5 Cognizant Licensing E inee

Evaluation of LTP Change Concrete Remediation Gamma Scans Purpose The purpose of this LTP Change is to add a remediation survey element to the License Termination Plan and to describe the implementation of that survey.

LTP Change License Termination Plan Section 4.2.1 is being changed to include the following statement:

"Following the removal of equipment and components, structures will be surveyed as necessary and contaminated materials will be remediated or removed and disposed of as radioactive waste.

Gamma scans are employed on remaining structural concrete surfaces to identify contamination at depth. These gamma scans are employed in accordance with Appendix 4C and approved procedures." Attachment 4C is also being added to describe the implementation of these gamma scans.

These LTP pages are attached.

Background

During the NRC review of Maine Yankee Final FSS Reports on the Spray Building and the Primary Auxiliary Building it became clear that the conduct of Remediation Survey Gamma Scans on Building Basement Concrete surfaces needed to be clarified. Maine Yankee implemented these gamma scans as a good practice following discussions with the State of Maine. The License Termination Plan did not require the gamma scans or provide guidance on how to implements them for concrete surfaces.

Evaluation The criteria by which this LTP change should be evaluated are found in Maine Yankee License Condition 2.B.(10) and LTP Sections 1.4.1, 2.5.3.f, 3.2,4.2.1, 5.5.2.a, and 5.6.4. These criteria are summarized as follows:

"The licensee may make changes to the LTP without prior approval provided the proposed changes do not:

a.

Require Commission approval pursuant to I OCFR50.59;

b.

Violate the requirements of 10 CFR 50.82(a)(6);

C.

Reduce the coverage requirements for scan measurements;

d.

Increase the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs; or

e.

Increase the probability of making a Type I decision error."

Page 1

Evaluation of LTP Change Concrete Remediation Gamma Scans "As appropriate, Maine Yankee will evaluate changes to the LTP using the Data Quality Objective (DQO) process outlined in NUREG-1575, "Multi Agency Radiological Survey and Site Investigation Manual" and/or the considerations described in section 3.2."

"In addition to the above license condition LTP change criteria, Maine Yankee will notify the State of Maine promptly prior to making a change to the LTP that would result in an increase, of any amount, in a Derived Concentration Guideline Level (DCGL) and will request NRC approval if a change to the LTP would result in an increase in a DCGL, as specified in Table 6-1 1, by more than a factor of two. Note that any DCGL increase is only allowable provided the resulting "Total Annual Dose" remains less than or equal to lO mrem/y and the "Drinking Water" (dose) remains less than or equal to 4 mrem/y (as presented Table 6-11). In other words, the individual contaminated material DCGLs listed in Table 6-11 must always collectively result in a total annual dose of 10 mrem/y or less and a drinking water dose of 4 mrem/y or less."

"In the event that Maine Yankee elects to reduce a survey unit's classification as listed in Section 5, i.e., from Class I to Class 2 or 3, or from Class 2 to 3, prior notification will be provided to the NRC. Criteria for reclassification is discussed in Section 5.6.4. Maine Yankee will provide the NRC as much early notice of this decision as practical but not less than two weeks."

"If radionuclide profiles are revised, the revised profiles will be provided to the NRC and the State of Maine at least 30 days prior to their use."

"However, additional ALARA evaluations for activated concrete will be performed if the remediation goal is increased and the dose contribution to the critical group for activated concrete exceeds 1.0 mrem per year."

"In situ gamma spectroscopy or other methods not specifically described may also be used for final status surveys. If so, Maine Yankee will give the NRC 30 days notice to provide an opportunity to review the associated basis document as described in LTP Section 5.3.1."

An evaluation of this change against these criteria is described below:

1. -

The proposed change does not require Commission approval pursuant to I OCFR50.59.

The change can be screened out since:

a.

The proposed change does not involve a change to a structure, system or component (SSC) that adversely affects a DSAR described design function.

The proposed change does not involve a change to an SSC.

Page 2

Evaluation of LTP Change Concrete Remediation Gamma Scans

b.

The proposed change does not involve a change to a procedure that adversely affects how DSAR described SSC design functions are performed or controlled.

The proposed change does not involve a change to an SSC.

c.

The proposed change does not involve revising or replacing a DSAR described evaluation methodology that is used in establishing the design bases or used in the safety analyses.

This change adds a survey element to the License Termination Plan that is not currently included in the LTP. The proposed change is not part of the LTP dose model, although the dose model may be used to evaluate small areas of activity above the 30 kcpm guideline.

Thus the LTP change does not affect the dose model described in the License Termination Plan and does not involve a revision to the dose model or the parameters used in the dose model.

d.

The proposed change does not involve a test or experiment not described in the DSAR, where an SSC is utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analysis or descriptions in the DSAR.

The proposed change does not involve a change to an SSC.

2.

The proposed change does not violate the requirements of 10 CFR 50.82(a)(6) since:

a.

The proposed change does not foreclose release of the site for possible unrestricted use.

The proposed change continues to meet the license termination dose criteria for unrestricted use and the State of Maine enhanced criteria.

b.

The proposed change does not result in significant environmental impacts not previously reviewed.

The proposed change does not affect the assumptions in the review of environmental impacts described in the License Termination Plan.

c.

The proposed change does not result in there no longer being reasonable assurance that adequate funds will be available for decommissioning.

The proposed change does not affect the expenditure of decommissioning funds.

Page 3

Evaluation of LTP Change Concrete Remediation Gamma Scans

3.

The proposed change does not reduce the coverage requirements for scan measurements License Termination Plan section 5.4.1 and Table 5-3 describe the scan coverage requirements for FSS surveys based upon the classification of a survey unit. These coverage requirements are not affected by this change.

4.

The proposed change does not increase the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs.

License Termination Plan section 5.6 and Table 5-7 describe the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs. This change does not affect the requirement to set the investigation level at the levels indicated in Table 5-7.

5.

The proposed change does not increase the probability of making a Type I decision error.

The proposed change does not affect the FSS measurement method or the FSS instrumentation employed as described in the LTP.

6.

Maine Yankee's evaluation of this change included a review of affected Data Quality Objectives (DQO's)

The proposed change simply adds a remediation survey element to the remediation section of the License Termination Plan and does not affect any DQO's.

7.

Maine Yankee's evaluation of this change included a review of the considerations described in LTP Section 3.2. This section states: "Any changes to dismantlement activities described in this section which are made pursuant to 10 CFR 50.59 must also consider the impact of those changes on the final state of the site and any impacts on dose assessment, survey design or environmental assessment."

The proposed change does not involve a change to dismantlement activities.

8.

The proposed change does increase a DCGL but does not result in an increase in a DCGL by more than by a factor of two.

The proposed change does not affect any DCGL's described in the LTP.

9.

The proposed change does not reduce a survey unit's classification as listed in Section 5, i.e., from Class I to Class 2 or 3, or from Class 2 to 3.

The proposed change does not reduce a survey unit's classification as listed in LTP Section 5.

Page 4

Evaluation of LTP Change Concrete Remediation Gamma Scans

10.

The proposed change does not involve a revision to radionuclide profiles.

The proposed change does not affect a radionuclide profile as described in the LTP.

11.

The proposed change does not involve an increase in the activated concrete remediation goal or dose contribution.

The proposed change does not involve activated concrete

12.

The proposed change does not propose the use of In situ gamma spectroscopy or other methods not previously described.

The proposed change does not involve the use of In situ gamma spectroscopy or other methods of conducting Final Status Survey not previously described. The survey method included in this change only addresses remediation surveys.

Conclusion The change to the License Termination Plan to add an element to the remediation section to include a description of the conduct of remediation survey gamma scans does not require prior NRC approval pursuant to the change processes described in the Maine Yankee Operating License or the License Termination Plan.

References

1.

Maine Yankee Letter to USNRC, MN-02-037, dated August 28, 2002, Maine Yankee Addendum Report Regarding Site Hydrogeology

2.

Maine Yankee Letter to USNRC, MN-02-048, dated October 15, 2002, Revision 3, Maine Yankee's License Termination Plan

3.

USNRC Letter to Maine Yankee dated February 28, 2003, "Issuance of Amendment No.

168 to Facility Operating License No. DPR Maine Yankee Atomic Power Station -

Approval of the MY License Termination Plan

4.

Maine Yankee Letter to USNRC, MN-04-020, dated March 15, 2004, License Amendment Request: Release of Non-ISFSI Site Land, Proposed Change No. 218

5.

Maine Yankee Letter to USNRC, MN-04-044, dated August 12, 2004, Release of Non-ISFSI Site Land - Resubmittal of FSS Final Report No. 1, Proposed.Change No. 218, Supplement 2

6.

Maine Yankee Letter to USNRC, MN-04-047, dated September 2, 2004, License Amendment Request - Release of Non-ISFSI Site Land, Proposed Change No. 218, Supplement 3 Page 5

Evaluation of LTP Change Concrete Reniediation Gamma Scans

7.

USNRC Letter to Maine Yankee dated October 14, 2004, Meeting Report for the September 9, 2004, Meeting with Maine Yankee Atomic Power Company (Maine Yankee)

8.

Maine Yankee Letter to USNRC, MN-04-049, dated September 15, 2004, Release of Non-ISFSI Site Land - FSS Final Report No. 2, Proposed Change No. 218, Supplement 4.

9.

Maine Yankee Letter to USNRC, MN-04-053, dated October 14, 2004, Release of Non-ISFSI Site Land - Addendum to FSS Final Report No. 1, Proposed Change No. 218, Supplement 6

10.

USNRC Letter to Maine Yankee dated November 4, 2004, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement Nos. I and 3

11.

USNRC Letter to Maine Yankee dated November 30,2004, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement No. 2.

12.

Maine Yankee Letter to USNRC, MN-04-058, dated December 7,2004, Response to NRC RAI's on FSS Report Nos. I and 3, Proposed Change No. 218, Supplement 8

13.

Maine Yankee Letter to USNRC, MN-04-061, dated December 23, 2004, Response to NRC RAI's on FSS Report No. 2, Proposed Change No. 218, Supplement 11

14.

USNRC Letter to Maine Yankee dated January 7, 2005, Receipt of Maine Yankee's Response to Request for Information on Final Status Survey Report Supplements I and 3

15.

USNRC Letter to Maine Yankee dated January 19, 2005, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement No. 2 Page 6

%I~YAPC License Termination Plan Page 4-i Revision 3 - Addenda February 15, 2005 TABLE OF CONTENTS 4.0 SITE REMEDIATION PLAN............................................

4-1 4.1 Remediation Actions and ALARA Evaluations......

................... 4-1 4.2 Remediation Actions.............................................

4-1 4.2.1 Structures................................................

4-1 4.2.2 Soil....................................................

4-5 4.3 Remediation Activities Impact on the Radiation Protection Program....

.... 4-6 4.4 ALARA Evaluation..............................................

4-7 4.4.1 Dose Models.

4-8 4.4.2 Methods for ALARA Evaluation........

...................... 4-9 4.4.3 Remediation Methods and Cost...........

..................... 4-9 4.4.4 Remediation Cost Basis...........

......................... 4-10 4.5 Unit Cost Estimates.

4-14 4.6 Benefit of Averted Dose..............

4-14 4.7 ALARA Calculation Results............

.......................... 4-16 4.8 References....................................................

4-16 ATTACHMENT 4A Calculation of ALARA Residual Radioactivity Levels ATTACHMENT 4B Unit Cost Values ATTACHMENT 4C Remediation Surveys - Gamma Scans

~lYAPC License Termination Plan Page 4-1 Revision 3 - Addenda February 15, 2005 4.0 SITE REMEDIATION PLAN 4.1 Remediation Actions and ALARA Evaluations This section of the LTP describes various remediation actions which may be used during the decommissioning of MY. In addition, the methods used to reduce residual contamination to levels that comply with the NRC's annual dose limit of 25 mrem plus ALARA, as well as the enhanced State of Maine clean-up standard of 10 mrem/year or less for all pathways and 4 mrem/year or less for groundwater drinking sources, are described. Finally, the Radiation Protection Program requirements for the remediation are described.

4.2 Remediation Actions Remediation actions are performed throughout the decommissioning process. The remediation action taken is dependent on the material contaminated. The principal materials that may be subjected to remediation are structure basements 3-feet below grade and soils. Attachment 4B of this section describes the equipment, personnel, and waste costs used to generate a unit cost basis for the remediation actions discussed below.

4.2.1 Structures Following the removal of equipment and components, structures will be surveyed as necessary and contaminated materials will be remediated or removed and disposed of as radioactive waste. Gamma scans may be employed on remaining structural concrete surfaces to identify contamination at depth. These gamma scans are described in Appendix 4C and approved procedures. Contaminated structure surfaces at elevations less than 3-feet below grade will be remediated to a level that will meet the established radiological criteria provided in Section 6.0.

The remediated building basements (elevations at and below - 3 foot below grade) will be backfilled.

Remediation techniques that may be used for the structure surfaces include washing, wiping, pressure washing, vacuuming, scabbling, chipping, and sponge or abrasive blasting. Washing, wiping, abrasive blasting, vacuuming and pressure washing techniques may be used for both metal and concrete surfaces. Scabbling and chipping are mechanical surface removal methods that are intended for concrete surfaces. Activated concrete removal may include using machines with hydraulic-assisted, remote-operated, articulating tools. These machines have the ability to exchange scabbling, shear, chisel and other tool heads.

A YAPC License Termination Plan Revision 3 - Addenda February 15, 2005 C Page I of 3 ATTACHMENT 4C I

I I

Remediation Surveys - Structural Concrete Gamma Scans

Mh%'APC License Termination Plan C Revision 3 - Addenda Page 2 of 3 February 15, 2005 Remediation Surveys - Structural Concrete Gamma Scans i

During the remediation phase of decommissioning Class I building basements in the Restricted I

area, gamma scans of structural concrete surfaces may be employed to identify contamination at depth. These scans only apply to concrete surfaces, not to bedrock surfaces. A guideline of l

30,000 cpm is used to identify concrete surfaces for remediation. Since these surveys are I

performed as remediation surveys, not final status surveys, the records of these surveys are not required to be maintained, but may be used, as available, to assist remediation decisions or provide evaluations of radiological conditions.

I The use of gamma scans in implementing this 30,000 cpm guideline is subject to the following l

limitations and conditions. The 30,000 cpm guideline:

1.

Applies only to concrete surfaces that receive a final status survey. Therefore, the I

guideline has no bearing on concrete surfaces that no longer exist, bedrock surfaces or metallic surfaces.

2.

Is not exclusive nor necessary provided other technical means are applied (e.g., technical judgment that an elevated gamma reading is clearly due to adjacent radiation sources, analysis of sampling results, etc.). The 30K gamma criterion is meant to be informed by, and no more unique than, the various approaches allowed in the LTP/MARSIMM for final status survey measurements (e.g., sampling in the place of beta scans).

l

3.

Is qualitative and is not part of, but goes beyond the LTP dose model. Minor variations call for technical judgment, not necessarily more remediation.

4.

Is applied during remediation surveys. Use of the criterion does not imply a more rigorous treatment of remediation survey records than that required for remediation surveys.

5.

Is used as a remediation guideline and is not meant to be applied in a manner more I

restrictive than the application of a DCGL (eg. evaluation may be applied to accept areas exceeding the DCGL without further remediation) l

v t e Letter Sequence Request
TAC:M8000, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance... Administration Questions Answers Results Approval, Approval, Approval Other: ML091130320
MONTHYEAR2005-05-16 [Table View]

RA-05-008, Response to NRC RAIs on FSS Final Report Nos. 1 and 2

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