ML051090364

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Supplement to Proposed Amendment to Ynps Possession Only License
ML051090364
Person / Time
Site: Yankee Rowe
Issue date: 04/07/2005
From: Jesse Rollins
Yankee Atomic Electric Co
To:
Document Control Desk, NRC/FSME
References
BYR 2005-028
Download: ML051090364 (16)
v • d • e


Text

V YANKEE ATOMIC ELECTRIC COMPANY Telephone (413) 424-5261 49 Yankee Road, Rowe, Massachusetts 01367 YANKE April 7, 2005 BYR 2005-028 P.C. No. 269, Suppl. I United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1.YNPS License No. DPR-3 (Docket No. 50-29)

2. YAEC Letter to USNRC, "Submittal of YNPS's License Termination Plan and Proposed Revision to Possession Only License," dated November 24, 2003, BYR 2003-080, P.C. No. 269
3. YAEC Letter to USNRC, "Submittal of Revision I to the YNPS's License Termination Plan (LTP)," dated November 19, 2004, BYR 2004-133

Subject:

Supplement to Proposed Amendment to YNPS Possession Only License In response to the NRC's request, Yankee Atomic Electric Company (YAEC) herewith supplements its application to amend the Yankee Nuclear Power Station (YNPS) Possession Only License No. DPR-3 (References I and 2) by adding the following proposed license condition*

(cf. Reference 2, Attachment 1, "Description of Change", new License Condition C.l 1):

(e) Prior to license termination, if the concentrations of site-generated radionuclides other than tritium are reported in the groundwater in excess of the individual concentrations listed below, or if a sum of the fractions formed by dividing the reported concentrations by these values is greater than 2.0, the licensee shall evaluate the need for site-specific groundwater DCGLs for these radionuclides. New groundwater DCGLs will require that a license amendment request be submitted to the NRC for approval.

Individual Individual Radionuclide Concentration Radionuclide Concentration Limit, pCi/L Limit, pCiIL Ag-108m 50 Fe-55 25 Am-241 0.5 Nb-94 50 C-14 200 Ni-63 15 Cm-243/244 0.50 Pu-238 0.50 Co-60 25 Pu-239/240 0.50 Cs-134 14 Pu-241 15 Cs-137 15 Sb-125 50 Eu-152 50 Sr-90 3 Eu-154 50 Tc-99 15 Eu-155 50 Also, as discussed with the NRC Staff, YAEC is providing its current program procedure governing the groundwater monitoring program at YNPS. This procedure, AP-8601 'Ground and Well Monitoring Program for the Yankee Nuclear Power Station Site,'(see Attachment 2) j MSS D(

  • The basis for the license condition is provided in Attachment 1.

U.S. Nuclear Regulatory Commission BYR 2005-028, Page 2/2 describes the implementation of the YNPS monitoring program including radioactivity analyses performed on specific wells and how the data are evaluated to affect program changes, as necessary.

Should you have any questions regarding the contents of this submittal, please contact Mr. Greg Babineau, YNPS Radiation Protection Manager, at (413) 424-2202.

Sincerely, YANKEE ATOMIC ELECTRIC COMPANY Jack D. Rollins Regulatory Affairs Manager : Basis for License Condition Procedure AP-8601, "Ground and Well Monitoring Program for the Yankee Nuclear Power Station Site."

cc: J.L. Hickman, NRC Project Manager, NMSS S. Collins, NRC, Region I Administrator J. Kottan, Inspector, NRC Region I M. Whalen, MA DPH R. Walker, MA DPH D. Howland, MA DEP M. Rosenstein, EPA, Region I W. Perlman, Executive Committee Chair, FRCOG T.W. Hutcheson, Chair, Franklin Regional Planning Board L. Dunlavy, Executive Director, FRCOG P. Sloan, Director of Planning & Development, FRCOG D. Katz, CAN J. Block, Esq.

ATTACHMENT I Basis for License Condition 1.0

Introduction:

In recognition of the potential for analytical variances and the occurrence of false positive results in the analysis of groundwater samples at the Yankee site, a method is needed to establish groundwater concentration limits, below which analytical results are considered insignificant.

These limits are derived by considering detectability for each radionuclide in groundwater, its MCL fraction, and its potential annual dose consequence.

2.0 MCL Comparison:

For all but three LTP radionuclides, values for the EPA's Maximum Contaminant Level, MCL, are available. For these radionuclides, the established individual concentration limit was derived by considering the practical detectability for each radionuclide in groundwater, its MCL fraction, and its potential annual dose consequence. Table 1 below provides a comparison of the individual concentration limit to the MCL value.

As shown in Table 1,the limit selected is a small fraction of the MCL for those radionuclides where an MCL is available.

Table 1. Comparison of Individual Radionuclide Groundwater Limits to the EPA MICLs Individual Concentration Radionuclide Concentration MCL, Limit Limit, pCi/L PCiL (Fraction of Ag-108m 50 NC' NC' Am-241 0.5 15 0.03 C-14 200 2,000 0.10 Cm-243/244 0.50 15 0.03 Co-60 25 100 0.25 Cs-1 34 14 20,000 0.00 Cs-137 15 200 0.08 Eu-152 50 60 0.83 Eu-154 50 200 0.25 Eu-I 55 50 600 0.08 Fe-55 25 2,000 0.01 Nb-94 50 NC' NC' Ni-63 15 50 0.30 Pu-238 0.50 15 0.03 Pu-239/240 0.50 15 0.03 Pu-241 15 NC' NC' Sb-125 50 300 0.17 Sr-90 3 8 0.38 Tc-99 15 900 0.02

' MCL not calculated (NC) for this radionuclide.

Page 1 of 3

3.0 Dose Significance Evaluation:

For the three radionuclides where an MCL value is not available, a practical groundwater MDC value was selected and compared to the Connecticut Yankee (CY) groundwater DCGLs normalized to an annual dose of I mrem. Table 2 provides this comparison for all radionuclides including those with no corresponding MCL.

As shown in Table 2, the calculated annual dose using the CY DCGL for I mrem and the selected concentration limit for the three radionuclides with no corresponding MCL is bounded by the dose values for all other radionuclides. One radionuclide listed has no corresponding dose value, Sb-125. This radionuclide was not included in the CY suite of radionuclides, however its MCL fraction from Table I is quite low.

Table 2. Comparison of Individual Radionuclide Groundwatcr Limits to the CY DCGLs to Determine an Annual Dose CY DCGL for Individual Corresponding Radionuclide I mrem/yr, Concentration Annual Dose, pCi/L Limit, pCi/L mrem Ag-108Im I 1.70E+02 50 0.29 Am-241 5.28E-01 0.50 0.95 C-14 3.60E+02 200 0.55 Cm-243/24 14 7.76E-01 0.50 0.64 Co-60 4.56E+01 25 0.55 Cs-134 1.37E+01 14 1.02 Cs-137 1.72E+0I 15 0.87 Eu-152 2.93E+02 50 0.17 Eu-1 54 2.02E+02 50 0.25 Eu-155 1.30E+03 50 0.04 Fe-55 2.62E+03 25 0.01 Nb-94' 2.70E+02 50 0.19 Ni-63 1.26E+03 15 0.01 Pu-238 6.04E-01 0.50 0.83 Pu-239/24 0 5.44E-01 0.50 0.92 Pu-241' 1.84E+01 15 0.82 Sb-1252 NC 50 NC Sr-90 1.00E+01 3 0.30 Tc-99 1.06E+03 15 0.01

'MCL not available for this radionuclide.

2 CY DCGL not listed for this radionuclide.

4.0 Proposed Implementation Method:

The analysis of groundwater samples will include a criterion that the minimum detectable concentration be equal to or less than the individual concentration limit provided in Table I or Table 2. If the reported activity concentration for any detected radionuclide listed on Table I exceeds the individual activity concentration limit or if the sum of the fractions formed by dividing the reported concentrations by these limits exceeds 2.0, then an LTP amendment will be Page 2 of 3

made to establish site specific dose-based groundwater concentration limits for the applicable radionuclides. For most of the radionuclides listed in Tablel, this cumulative limit represents a combined concentration that is a small fraction of MCLs.

This process will ensure that the concentration and dose significance of any radionuclide other than H-3 is low when considering the individual or collective presence of radionuclides, while allowing for the normal occurrence of low-level false positive analytical results.

5.0

Conclusions:

The proposed method establishes low concentration thresholds for radionuclide groundwater concentrations in support of the Yankee decommissioning site while allowing for and recognizing the potential for statistically false positive sample results.

Page 3 of 3

ATTACHMENT 2 YNPS PROCEDURE NO. AP-8601 GROUND AND NVELL MONITORING PROGRAM FOR THE YANKEE NUCLEAR POWER STATION SITE

Proc. No. AP-8601 Rev. No. 8 Issue Date 02/2005 Review Date 06/2008 GROUND AND WELL WATER MONITORING PROGRAM FOR TIHE YANKEE NUCLEAR POWER STATION SITE SCOPE This procedure outlines the overall program for the collection of radiological ground and well water samples to support decommissioning activities at the Yankee Nuclear Power Station (YNPS) site.

The procedures, which support this document, implement the sampling, analysis, quality and record keeping procedures for the program are listed in the Reference Section.

ENCLOSURES AP-8601 - Pgs. 1-8 Attachment A - Pgs. 1-2 Attachment B - Pg. 1 Attachment C - Pg. 1 APF-8601.1 -Pg. 1 REFERENCES

1. DP-9745, "Ground Water Level Measurement and Sample Collection in Observation Wells"
2. AP-960 1, "Yankee Nuclear Power Station Site Characterization and Site Release Quality Assurance Program Plan (QAPP) for sample Data Quality"
3. DP-8602, "Ground Water Monitoring Well Drilling and Completion"
4. DP-8603, "Radiochemical Data Quality Assessment"
5. 10CFR20 Subpart E, "Radiological Criteria for Licensing Termination" DISCUSSION IOCFR20 Subpart E requires that the total annual dose from site activities in the future be less than 25 mrem/yr from the sum of all potential uptake pathways. Analysis of the site groundwater through the use of monitoring and observation wells will help characterize the final condition of that medium. It is important that a standard set of protocols be established so that the Data Quality Objectives (DQO) will be met for all sampling and analysis activities.

The License Termination Project (LTP) Team has discussed extensively the suite of radionuclides that are important to the monitoring process at the plant site. They have decided upon the radionuclides identified in Attachments A and B, based on the probability of their (measurable) presence and potential dose consequence.

AP-8601 Rev. 8 PRECAUTIONS Changes to this procedure and its referenced implementation procedures must be made in accordance with the LTP and documented on Att. C. Any changes which alter the sample collection, sample analysis or data analysis, must be evaluated prior to changing these procedures to establish a connection to historical data (see Enclosure APF- 8601.1).

EQUIPMENT AND MATERIALS N/A PROCEDURE A. Roles and Responsibilities

1. Program Oversight.
a. The YNPS Site Closure Implementation Manager or designee will have overall responsibility for program oversight, including:
  • Approval of budget expenditures
  • Designation of appropriate personnel qualified to review data and propose program changes.
  • Approval of Sampling events.
  • Approval of vendor selection for sampling and analytical services.
  • Final approval of program changes
2. Sample Collection Scheduling.
a. The YNPS Site Closure Implementation Manager or designee shall be responsible for coordinating the sampling events.
b. The Site Closure Implementation Manager or designee will schedule all sampling events with the contractor selected for this task.
c. A list of the wells to be sampled shall be first approved by the Site Closure Implementation Manager or designee and then communicated, in writing, to the vendor. This shall be part of the sampling package documentation.

AP-8601 Rev. 8

3. Program Changes Changes to programs or procedures shall be initiated by the YNPS Site Closure Implementation Manager or designee, and approved by the Site Closure Implementation Manager or designee and documented on Att. C. Changes may result from the following conditions as well as others:
  • Significant changes in radioactivity levels of the wells
  • Appearance of new radionuclides in the monitoring program.
  • Significant physical changes to the site geology or site contour.

It is also significant to note that deselection of wells or radionuclides should be part of the monitoring process. If sufficient historical data indicates that certain wells or radionuclides indicate less than quantifiable radioactivity, they may be deselected using APF-8601 .1.

4. Sample Collection Activities The Site Closure Implementation Manager or designee shall designate YNPS site personnel to have direct oversight of:
a. The sampling events and any necessary escort functions for contract personnel.
b. Proper packaging, preservation, labeling, and shipment of the samples to the contract laboratory.
c. Return of all chain of custody forms and verification that all samples were received intact.

The Site Closure Implementation Manager or designee shall also coordinate with the Site Environmental Supervisor:

a. All non-radiological analyses required by sampling procedures
b. Verify purge time requirements or immediate analysis required prior to the samples being shipped to the analytical contract laboratory.
c. Disposal of all wastewater and chemicals associated with the sampling events.
5. Data Validation and Verification
a. The Site Closure Implementation Manager or designee shall designate a qualified individual to perform these functions. A qualified person is defined as one who has at least 5 years experience in radiochemistry or

AP-8601 Rev. 8 radiation protection, and has a bachelors degree in a related scientific field, or equivalent experience dealing with radiochemistry calculations.

b. Procedure DP-8603 shall be used for documentation of the verification and validation activities of all parameters related to radiological sample analysis.
c. The verification and validation activities shall be independent of those activities performed by the contract laboratory for sample analysis.
6. Report Generation
a. The Site Closure Implementation Manager or designee shall have the responsibility for generation of any report that will be subject to regulatory review.
b. Final approval of the report will be the responsibility of the Site Closure Implementation Manager or designee.

B. Schedule for Sampling and Analysis I. The routine sampling and analysis frequency will be as specified in Attachment A for each of the wells.

2. Chemical separation of radionuclides in radiochemical samples should be initiated as soon as practicable after sampling, but should begin within three weeks of the sampling event.
3. If evaluation of data trends identifies unexpected changes (as described in B.4) selected monitoring wells may be resampled. Resampling and analysis shall occur as soon as practical after discovery of the need to resample.
4. It is anticipated that radioactivity levels in the monitoring wells will decrease over time. However, the following data changes may indicate an unexpected change in groundwater conditions.
  • A sample location normally showing < MDC activity shows activity level significantly greater than the MDC. Significantly is identified as >3 MDC for the time of analysis.
  • A sample location showing a steady downward trend shows a sudden increase or decrease in the projected value by greater than 20%. Projected values may be determined by best-fit extrapolation of the existing curve shape.

Such changes may require program changes to the sampling and analysis frequency for the affected well and any down gradient wells. This evaluation is recorded on APF-8601.1, and approved by the Site Closure Implementation Manager or designee.

AP-8601 Rev. 8

5. Samples which are lost, or "analytical blunders" to sole samples, should be replaced with a new sample, taken as close in time to the subject sample, if possible.
6. The initial data set for the purposes of this program shall be the first one following program approval. However, the results of the initial data set should be compared to the site historical data prior to making any changes to the sampling or analysis schedules.

C. Data Quality Objectives

1. When required, samples shall be analyzed by the contract laboratory for the radionuclides noted in Attachment B, such that the laboratory MDC is less than or equal to that noted in Attachment B.
2. Values for duplicate results >10 times the MDC shall be within
  • 20% for gamma and 90Sr, and
  • 30% for gross alpha, TRUs and beta only emitters (except 90Sr).
3. Values for duplicate results between I and 10 times the MDC shall be within
  • 25% for gamma and 90Sr, and
  • 60% for gross alpha, TRUs and beta only emitters (except 90Sr).
4. Sample counts less than the critical levels (critical level = 1.645x[lstandard deviation of the counting error]) are considered non-detectable, and there are no requirements on agreement of duplicate samples.
5. One laboratory QC, one well sample duplicate and one matrix spike shall be run with each batch of samples for tritium, Co, 90 Sr, one TRU and 241 Pu. The maximum batch size is 20 samples, not including these quality assurance samples.
6. One equipment rinsate sample ("equipment blank"), one blind duplicate sample and one matrix spike sample shall be collected in the field and analyzed with each investigatory sample batch for tritium, 60 Co, 90Sr, one TRU and "'Cs. The maximum batch size is 20 samples. This is only required when the same sample tubing is re-used for different wells.
7. Laboratory spike samples should have a radionuclide concentration added, which is 8-15 times the anticipated laboratory MDC for that analyte (except "Fe and 14C which shall be spiked to 5-1 0 times the MDC in Attachment B).
8. Recoveries for matrix spikes shall be in agreement as per C.2.

AP-8601 Rev. 8

9. Five percent (5%) of the data calculations (exclusive of QC data) shall be independently verified by a qualified individual. The data to be independently verified shall be selected at random and any calculations/information retained with the data package.

D. Analytical Laboratory Requirements

1. Quality Assurance Program (QAP)

The contract analytical laboratory shall have a QAP that meets the requirements of USNRC Regulatory Guide 4.15-1979, and ANSI/ASQC E4-1994, for all aspects of the work that they perform for the YNPS Groundwater Monitoring Program.

2. Procedures Analytical procedures shall be written using the guidance of an accepted standards organization such as ASTM, ANSI, ISO, etc., or a recognized reference such as MARSSIM or MARLAP (when first issued).

Examples of such standards are:

40 CFR Ch. I, Part 141.25 Analytical Methods for Radioactivity EML Procedures Environmental Measurements Laboratory Manual(formerly HASL-300) Procedures Manual, 2 8 th Edition, February 1997 EPA 520/5-84-006,1984 Eastern Environmental Radiation Facility Radiochemistry Procedures Manual EPA-600/4-80-032, 1980 Prescribed Procedures for Measurement of Radioactivity in Drinking Water, EPA R4-73-014, 1973 Procedures for Radiochemical Analysis of Nuclear Reactor Aqueous Solutions, EMSL-LV-0539-17, 1979 Radiochemical Analytical Procedures for Analysis of Environmental Samples, E. Training Requirements

1. Personnel performing sampling shall have been trained in accordance with the procedure in force at the time of training. The training shall include on-the-job-training style instruction as well as procedural review with a knowledgeable individual.

AP-8601 Rev. 8

2. Personnel shall have been deemed qualified for procedural use, following successful procedure use by an evaluator (usually previously qualified personnel or a designee of the Site Closure Implementation Manager).
3. Qualification may occur by the following processes:
a. Through the training process
b. Documented historical experience of at least three years using the procedures involved or equivalent.
c. Development of the procedure as the subject matter expert (SME).
d. Documented training from another organization using equivalent procedures.
4. All personnel involved in the monitoring program shall review approved procedure changes prior to their using the procedures.
5. All vendor personnel performing analysis or sampling with the monitoring program procedures shall be qualified in accordance with the vendors QAP.
6. All training shall be appropriately documented in retrievable records maintained by the vendor or onsite in accordance with approved procedures.

F. Documentation Package Requirements for Sampling and Analysis

1. Each sampling event will normally take samples for multiple wells.
2. Each sampling event will include the following forms, at a minimum:
  • Attachment A - One copy of the page in force at the date of sampling.
  • Form DPF-9745.4, "Ground Water Sampling Field Log" will be completed for each well. Attached to this form will be a data sheet from the laboratory, which includes the measurements made for each sample parameter and values for the blank, QC and any splits, spikes, or duplicates identified for that sampling event.
  • Original Chain of Custody Forms that have accompanied the samples to the analytical laboratory.
3. In the event that a sample is lost or not analyzed appropriately, or any of the conditions described in A.3 above have occurred, the data package will also include the appropriate number of copies of APF-8601.1 from this procedure.

AP-8601 Rev. 8

4. The Analytical Laboratory report shall include as a minimum:
  • The values of all radionuclides stated in pCi/L
  • The total propagated uncertainty (TPU) of the individual results in pCiIL
  • The MDC for each analyte
  • The value of the QC and its target value for the batches reported
  • The value of the Blank for each of the analyses
  • The values for spike samples shall be reported, with a recovery percentage
  • Any irregularities in sample processing
  • Reproductions of the data sheets, which show sample count times, sample mass, carrier or tracer mass, and yield, or any other data necessary to reproduce analytical calculations.

AP-8601 Rev. 8 Att. C Attachment C Justification for Procedure Change Note: Above and beyond the requirements ofAP-0001 the following guidance must be followed to ensure any change made to this procedure does not affect the DQO, Sample Integrity, Sample Validity, Reproducibility of Sampling, or Data obtained.

1. Procedure Number Procedural Step(s) Changed_

Date Required II. Identify the type of procedure change being made:

El Administrative change (no technical details of procedure have changed)

El Change of Analytical Method l Change of Procedural Steps E Change of Detection Limits E Other: Describe III. Description of Change IV. Does the Change Negatively Effect:

  • The DQOs YES NO
  • The Sample Integrity or Validity YES NO
  • The Reproducibility of Sampling or Data YES NO If any of the answers above is "YES", write a justification for the change, and have an independent technical review performed before processing the change through the existing change program.

If all answers above are "NO", process the change through the existing change program.

V. Approval Site Closure Implementation Manager or designee Date_

  • 4 Groundwater Resample and Reanalysis Report Date Analyst_

Sample Identification Analyte(s)_

The following incident(s) has occurred:

[] The identified sample has been lost.

D The identified sample did not have analysis performed.

The value of exceeded 20% of the projected value of the analyte from the historical trend.

j The value of has exceeded 3 times the MDC, and the previous sample had been < MDC.

Fii Other(Explain)

The following remedial action(s) are recommended:

Remedial Actions Approved:

YNPS Site Closure Implementation Manager or designee Date Actions Completed:

Analyst DDate/ Time APF-8601.1 Rev. 8 Pg. I

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