ML070430141
| ML070430141 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/13/2007 |
| From: | Tanya Smith NRC/FSME/DWMEP/DURLD |
| To: | Norton W Connecticut Yankee Atomic Power Co |
| Smith, T. B. (301) 415-6721 | |
| References | |
| Download: ML070430141 (5) | |
Text
1 ML061980469, ML070320448, ML070320450, and ML042170277.
February 13, 2007 Mr. Wayne Norton, President Connecticut Yankee Atomic Power Company 362 Injun Hollow Road East Hampton, CT 06424-3099
SUBJECT:
ACCEPTABILITY OF PHASE III FINAL STATUS SURVEY REPORTS FOR THE HADDAM NECK PLANT FOR CONNECTICUT YANKEE ATOMIC POWER COMPANY
Dear Mr. Norton:
This letter is responsive to your staffs request for a report from U.S. Nuclear Regulatory Commission (NRC) staff on the acceptability of Final Status Survey (FSS) reports for the Phase III areas of the Haddam Neck 10 CFR Part 50 license (DPR-061)).
The Phase III areas are comprised of seven survey units (9521-0000, 9527-0001, 9527-0002, 9527-0003, 9727-0004, 9528-0002, and 9531-0000) as defined in the Haddam Neck License Termination Plan [(LTP), Revision 4, issued November 2006]. (NRC staff notes that survey unit 9527-0002 appears to have been inadvertently omitted from Table 2-10 of the LTP, page 2-61.)
You have requested a letter to document the results of NRCs evaluation of the Phase III survey units in accordance with NRC requirements and Section 1.4.2 of the LTP, but prior to formal request for phased release of these areas from the site. Final release of these areas is awaiting the completion of groundwater monitoring, and a formal request by Connecticut Yankee Atomic Power Company (henceforth CY) which is anticipated later this calendar year.
Discussions Phase III FSS reports were originally submitted to NRC in May 2006. Based on discussions documented in the enclosed Phase III Evaluation Summary, CY revised several Phase III FSS reports. Revision 1 to CYs Phase III FSS reports were submitted to NRC on September 21, 2006. Revision 1 included changes to the main report, and the individual reports for survey units 9527-0001, 9527-0002, 9527-0003 and 9527-0004.
NRC Findings:
NRC inspectors and survey contractors from the Oak Ridge Institute for Science and Education (ORISE) performed an independent survey on all seven survey units in Phase III, which included 39 surface soil samples, surface scans of over 50% of class 2 areas and surface scans of over 10% of class 3 areas. Samples were tested by gamma spectroscopy for Co-60, Cs-137, and other gamma-emitting radionuclides associated with the Haddam Neck Plant.
NRC Inspection Reports and ORISE Confirmatory Survey Reports1 corroborated that the
W. Norton 2
radiological conditions of the open land area survey units met the approved site-specific Derived Concentration Guideline Levels (DCGLs) for soils, and that CYs laboratory data were consistent and in agreement with the ORISEs analytical results.
NRC staff has completed the review of the Phase III FSS reports and concluded that: (1) the FSSs were conducted in accordance with the LTP, and (2) the FSS reports, as revised, contain the information identified in NUREG 1757, Consolidated Office of Nuclear Material Safety and Safeguards (NMSS) Decommissioning Guidance, Volume II, Section 4.5. CY must still demonstrate that the dose from all sources (i.e. ground water and soil) meets the LTP requirements before the Phase III survey units can be evaluated to the radiological criteria for unrestricted release or released from the site.
In accordance with 10 CFR Part 2.390 of NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in NRC Public Document Room, or from the Publically Available Records component of NRCs Agency-wide Document Access Management System (ADAMS). ADAMS is accessible from NRC Web site:
http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this evaluation, please contact me by phone at (301) 415-6721, or by e-mail at tbs1@nrc.gov.
Sincerely,
/RA/
Theodore Smith, Project Manager Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-213 License No.: DPR-61
Enclosure:
Phase III Evaluation Summary cc: Haddam Neck distribution list Incoming: ML070120538, ML070120541, ML070120543, ML070120545, ML070120546, ML070120547, ML061360082, ML061360121, ML061360339, ML061360374, ML061360384, ML061360394, ML061360399, and ML061360405
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the radiological conditions of the open land area survey units met the approved site-specific Derived Concentration Guideline Levels (DCGLs) for soils, and that CYs laboratory data were consistent and in agreement with the ORISEs analytical results.
NRC staff has completed the review of the Phase III FSS reports and concluded that: (1) the FSSs were conducted in accordance with the LTP, and (2) the FSS reports, as revised, contain the information identified in NUREG 1757, Consolidated Office of Nuclear Material Safety and Safeguards (NMSS)
Decommissioning Guidance, Volume II, Section 4.5. CY must still demonstrate that the dose from all sources (i.e. ground water and soil) meets the LTP requirements before the Phase III survey units can be evaluated to the radiological criteria for unrestricted release or released from the site.
In accordance with 10 CFR Part 2.390 of NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in NRC Public Document Room, or from the Publically Available Records component of NRCs Agency-wide Document Access Management System (ADAMS). ADAMS is accessible from NRC Web site: http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this evaluation, please contact me by phone at (301) 415-6721, or by e-mail at tbs1@nrc.gov.
Sincerely,
/RA/
Theodore Smith, Project Manager Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-213 License No.: DPR-61
Enclosure:
Phase III Evaluation Summary cc: Haddam Neck distribution list Incoming: ML070120538, ML070120541, ML070120543, ML070120545, ML070120546, ML070120547, ML061360082, ML061360121, ML061360339, ML061360374, ML061360384, ML061360394, ML061360399, and ML061360405 DISTRIBUTION:
DCD r/f RidsAcrsAcnwMailCenter RidsRgn1MailCenter KMcConnell CCraig TSmith RidsFsmeOd ML070430141 OFFICE DWMEP/DD DWMEP/DD DWMEP/DD DWMEP/LA DWMEP/DD DWMEP/DD NAME TSmith*
TYoungblood*
DSchmidt*
TMixon*
CCraig KMcConnell DATE 2/1/2007 2 /1/2007 2/8/2007 2/8/2007 02/13/2007
/ /2007 OFFICIAL RECORD COPY
Enclosure Phase III Evaluation Summary for the Haddam Neck Plant DCGLs and Dose Allocation:
The licensee submitted Final Status Survey Reports (FSSRs) - Phase III, dated May 4, 2006, to NRC for review. The Phase III report included the following Survey Areas: 9521-Southwest Pond; 9527-East Mountain Side; 9528-Southwest Mountain Side; and 9531-South End of Peninsula. The Region I inspector and NRC headquarters staff reviewed the report and compared survey and soil sample results with the Oak Ridge Institute for Science and Education (ORISE) results.
The NRC noted that the licensees method for determining elevated areas and the description of operational Derived Concentration Guideline Levels (DCGLs) was not clear.
By letter of February 27, 2006 (ML060530075), NRC staff approved release of Phase II survey units from the site. Within that letter, NRC staff commented as follows:
NRC staff noted what appeared to be inconsistent usage of the terms Derived Concentration Guideline Level (DCGL), DCGLw, Administrative DCGL, Operational DCGL, and Surrogate or Surrogate-adjusted DCGL. CYs supplement clarified the usage and committed to consistent usage in future submittals.
On June 29, 2006, the NRC discussed these issues with the licensee. The licensee revised and resubmitted the Phase III FSSRs, Revision 1, dated September 21, 2006. NRC staff then commenced a detailed review of the Phase III FSSRs, and made the following observations:
- 1. The 9527-0004 survey unit has been given a class 2 designation. FSSR Table 7 indicates that none of the 15 soil samples exceeded 61% of the DCGLw. Scan surveys indicated that 14 localized areas exceeded the investigation level, and consequently, additional soil samples were taken. One of these soil samples was 1.028 times the operational DCGL.
NRC and CY staff discussed the sample locations. CY indicated that the area was rocky with shallow soil or moss. Because of the different soil profiles, CY collected the moss and collected a larger surface area of soil than normal. The 9527-0004 FSSR discussion indicates that the soil sample most likely included 0.819 picoCuries per gram (pCi/g) of Cesium-137 (Cs-137) from past atmospheric weapons testing. The FSSR further states that if that Cs-137 contribution were excluded, the sample would not have exceeded the DCGL. The NRC staff notes that subtraction of background is a change to the approach for this survey unit (CY initially was not subtracting background), and changing the approach should generally not be done after performance of the FSS. In addition, the NRC staff has not reviewed and approved CYs determination of average background. However, the NRC staff agrees that the background of Cs-137 concentration is likely greater than than the 0.15 pCi/g, and that the subject sample minus background does not exceed the Cs-137 operational DCGL.
NRC staff also notes that the operational DCGLs for survey unit 9527-0004 are based on an allowance of 17 millirem per year (mrem/y) for soil contamination, while CYs dose allocation under their license termination plan could be up to 23 mrem/y, given that CY has established a 2 mrem/y limit to their groundwater dose contribution.
Thus, NRC accepts CYs explanation and agrees that this survey unit need not be re-classified as a Class 1 survey unit.
- 2. A hot particle was identified in survey unit 9527-0002 in sample 9527-0002-018F.
Post sample collection scanning confirmed that no elevated activity remained. Gamma spectroscopy analysis performed on the remaining soil on March 9, 2006 by the on-site laboratory did not exceed 30% of the Operational DCGL.
NRC staff reviewed the circumstances surrounding this finding with the licensee. The licensee indicated that they believe the particle was associated with some wind damage to the tank farm isolation tent which was located in an adjacent survey unit. The licensee conducted additional sampling and scanning in the survey unit, and did not identify additional hot particles. NRC inspectors and ORISE contractors reviewed the area surrounding the sample area, and agreed with the extent of the additional surveying and sampling.
Since this sample point is near the edge of survey unit 9527-0002, NRC staff requested CY to perform biased scanning in any adjacent survey units when those units are surveyed for FSS.
CY committed to this as part of their data quality objectives final status survey design process.