ML052500219

Yankee Station - NRC Safety Evaluation Related to License Amendment No. 158

ML052500219
Person / Time
Site:	Yankee Rowe
Issue date:	08/30/2005
From:	Jesse Rollins Yankee Atomic Electric Co
To:	Document Control Desk, NRC/FSME
References
BYR 2005-078, TAC L52095
Download: ML052500219 (4)

Text

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YANKEE ATOMIC ELECTRIC COMPANY Telephone (413)424-5261 49 Yankee Road, Rowe, Massachusetts 01367

• KEE August 30, 2005 BYR 2005-078 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

References:

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

2. Yankee Nuclear Power Station - Issuance of Amendment No. 158, Re: License Termination Plan (TAC No. L52095), dated July 28, 2005

Subject:

NRC Safety Evaluation Related to License Amendment No. 158 As agreed during its August 24, 2005 telephone conference with the NRC staff, Yankee Atomic Electric Company (YAEC) herewith submits the attached review comments (Attachment) on the NRC's Safety Evaluation related to Amendment No. 158 (Reference 2) to the Yankee Nuclear Power Station (YNPS)

Possession Only License (Reference 1).

Also, YAEC has identified the following typographical errors in the YNPS License Termination Plan (LTP), Revision 1 that it intends to correct using the LTP change process outlined in Section 1.6 of the LTP:

• On Page 6-4, in the last line of Section 6.2.4, "Version 6-0" should read "Version 6.0".

• On Page 6A-9, in Section 6, the equation for the evapotranspiration coefficient is missing.

• On Page 6-14, in Table 6-1, and in the Appendices to Section 6, the DCGLs do not identify the second nuclide in the radionuclide pairs (i.e., Cm-244 in the Cm-243/244 pair, and Pu-240 in the Pu-239/249 pair).

Should you have any questions or comments regarding the subject matter of this submittal, please contact the undersigned at 413-424-2300.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY kD. ollins Licensing and Regulatory Affairs Manager

Attachment:

U nss

United States Nuclear Regulatory Commission Page 2 of 2 cc: J. Hickman, NRC, Project Manager, NMSS S. Collins, NRC, Region I Administrator J. Kottan, NRC, Region I Inspector D. Everhart, NRC, Region 1 Inspector M. Whalen, MA DPH R. Walker, MA DPH D. Howland, MA DEP M. Rosenstein, EPA, Region I W. Perlman, Executive Committee Chair, FRCOG T. Hutcheson, Chair, Franklin Regional Planning Board L. Dunlavy, Executive Director, FRCOG P. Sloan, Director of Planning & Development, FRCOG D. Katz, CAN J.-Block; Esq.

Page 1 of 2 ATTACHIENT YAEC Review Comments on the NRC's Safety Evaluation (SE) Related to License Amendment No. 158 to the Yankee Nuclear Power Station (YNPS) License No. DPR-3

1. Comment: The tables of radionuclides on Pages 2, 24, and 31 of the SE include "U-241." "U-241" was not identified as a radionuclide of concern in the LTP. This is likely just a typographical error.

Proposed Response/Action: Change U-241 to Pu-241, or remove where Pu-241 is already listed.

2. -Comment:-Pages 11 through 14 of the SE include commitments for continued groundwater-sampling and hydrogeologic investigation at the site such as:

• Further characterization of the glaciolacustrine unit and additional monitoring of sand layers (i.e. additional monitoring well installation)

• Continued mapping of ground water flow

• Replacement of 'critical' monitoring wells, continued quarterly ground water sampling during decommissioning and further ground water monitoring before license termination The extent and duration of characterization and monitoring-as stated in the SE is unclear.

Proposed Response/Action: Since 2003, YAEC has published an annual hydrogeological report that discusses the data obtained during that year and includes recommendations for future investigation and monitoring activities, based upon the data obtained. The next report is scheduled to be issued in the spring of 2006. YAEC proposes to engage the NRC in a discussion (either via teleconference or public meeting) of the data findings and the proposed future investigation and monitoring activities prior to issuance of future reports.

3. Comment: Page 20 of the SE, Section 2.4, Final Status Survey, notes that technical support documents produced in support of the use of advanced technologies, such as in situ gamma spec, will be provided for the NRC's review and approval[emphasis added]. Yankee's License Termination Plan does not require NRC approval of the technical support document prior to use of the advanced instrumentation. _ _

Proposed Response/Action: Remove the word "approval" from the statement. YAEC understands this "approval" as being consensus-like and not a "regulatory approval" of the technical support document. Further, YAEC understands that it is to its benefit to allow sufficient lead time for the NRC's review before use of advanced technology, so that the NRC can review the documents and identify any potential concerns before the survey has been completed. In not providing sufficient lead time, YAEC may put the subject final status survey at risk of rework, if the NRC has questions or concerns about the technical support documents.

4. Comment: SE Section 2.5.3, "Source Term," includes a commitment that "Tests for homogeneity wvill be done as part of the FSSs."

Proposed Response/Action: Add ", such as the MARSSIM referenced Sign and WRS tests,"

after the word "homogeneity." YAEC understands this commitment to be the tests (such as Sign

Page 2 of 2 Test and WRS Test) normally conducted as a part of the Final Status Survey being conducted under MARSSIM.

5. Comment: SE Section 2.7, "Cost Estimate," includes the sentence "However, the majority of remaining decommissioning and decontamination activities will be performed under a fixed price contract, and are not subject to escalation." [Note: YAEC has changed some of its contract structuring since the issuance of Revision 1 to the LTP.]

Proposed Response/Action: Suggest deleting the SE sentence quoted in the Comment above since it does not represent the current contract arrangement.

6. Comment: The SE indicates that GW samples were analyzed for all the LTP nuclides AND Mn-54, which is not an LTP nuclide.

Proposed Response/Action: Although this is currently a correct statement, the need for------- -----

analyzing groundwater samples for Mn-54 is being re-evaluated. Mn-54 was included in groundwater sampling early in the development of the LTP. Although it was subsequently determined that Mn-54 was not a radionuclide of concern for the YNPS site, it was not removed from the groundwater sampling program. YAEC intends to remove Mn-54 from the site groundwater sampling procedure in an upcoming revision to that procedure

7. Comment: SE Section 2.4 includes a statement that standing structure FSS results will be evaluated against concrete debris DCGLs.

Proposed Response/Action: As delineated in the LTP, FSS of subsurface partial structures will use DCGLs for subsurface partial structures as given in Column 4 of Table 6-1, and FSS for standing buildings (such as the Admin. Building) will use the building surface DCGLs, as given in Column 3 of Table 6-1.

8. Comment: SE Section 2.5 includes a statement that the licensee has developed a DCGL for ground water.

Proposed Response/Action: Yankee understands the reference to a "DCGL for ground water" to be the limit set in LTP Section 6.5 for tritium in the groundwater, which is equal to the EPA MCL of 20,000 pCi/l. Yankee also recognizes that there is a license commitment to calculate groundwater DCGLs if certain criteria are exceeded.