ML072200349

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Letter of Intent Concerning the Phased Release of Land from the Part 50 License
ML072200349
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 07/31/2007
From: Norton W
Connecticut Yankee Atomic Power Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CY 07-079
Download: ML072200349 (24)
v • d • e


Text

CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD

  • EAST HAMPTON, CT 06424-3099 Docket No. 50-213 CY 07-079 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-001 Haddam Neck Plant Letter of Intent Concerning the Phased Release of Land from the Part 50 License The purpose of this letter is to provide written notification to the Nuclear Regulatory Commission (NRC) of Connecticut Yankee Atomic Power Company's (CYAPCO's) intent to release a portion of the Haddam Neck Plant (HNP) site from the 10 CFR 50 License, DPR-61. Specifically, CYAPCO intends to release an area consisting of sixty-four (64) open land survey units, one (1) structure that has been free released under CYAPCO's Operational Radiation Program and six (6) subsurface soil survey areas.

This area encompasses approximately 40 % of the original site area of 525 acres. The remainder of the area of the site was released from license by NRC letter dated September 1, 2004 (Phase I, Non-impacted Area) and NRC letter dated February 28, 2006 (Phase II). Approximately 4.6 acres of the area released with Phase II and associated with the Independent Spent Fuel Storage Installation (ISFSI) will be retained in the Part 50 license until the ISFSI is decommissioned under the License Termination Plan 1 after movement of the spent nuclear fuel from the site. Figure 1 in the attachment to this letter show that area to be retained in the license. This area includes portions of survey units 9523-0000, 9528-0000 and 9528-0004.

The requirements of 10 CFR 50.83, "Release of part of a power reactor facility or site for unrestricted use," are not applicable in cases where there is an approved License Termination Plan (LTP). In the Statements of Consideration for Section 50.83, the Commission stated that "[p]artial releases following LTP approval would be governed by the LTP or changes thereto" provided that the "LTP contained a sufficient change process or describes staged releases of the property prior to license termination." In a letter dated November 25, 2002, the NRC approved the CYAPCO LTP via a License Amendment (License Amendment No. 197). The Safety Evaluation Report that

'J. D. Donahue (USNRC) to K. Heider (CYAPCO), "Haddam Neck Plant - Issuance of Amendment RE: Approval of License Termination Plan", dated November 25, 2002.

U.S. Nuclear Regulatory Commission CY-07-079/Page 2 supports the License Amendment indicates that the NRC accepted the process for releasing the land area(s) from the Part 50 License. Section 1.4.2 of the HNP LTP specifies the scope of the review and the process for removing land areas from the license. The non-impacted areas of the site (approximately 80 acres under Phase 1) and approximately 240 acres under Phase II were previously released from the Part 50 license, under separate partial site release requests.

As stated previously, CYAPCO intends to release the site areas outside of the ISFSI and associated land area from its Part 50 License. Table 1 provides a listing of all survey areas/units included in this proposed release of land from the Part 50 License.

For completeness Table 1 also includes a listing of the Phase II survey units previously released as discussed above. In accordance with Section 1.5 of the CYAPCO LTP and NRC Safety Evaluation dated November 25, 2002, CYAPCO has reviewed and assessed the subject survey areas (see Table 1 for a listing of specific survey areas to be released) to ensure that this proposed action will have no adverse impact on the ability of the site in aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release.

Attachment I contains a summary of the assessment performed. It is noted that does not contain the Final Status Survey (FSS) reports for the subject survey areas as these reports were previously submitted to the NRC (Table 1 contains a list of submittal dates).

CYAPCO plans to begin undertaking activities associated with the release of the subject survey areas from the HNP Part 50 License on or before September 30, 2007.

Therefore, we request that the NRC approve the acceptability of the release of the subject survey areas from the CYAPCO Part 50 License by September 17, 2007.

If you should have any questions regarding this submittal, please contact Mr. G. P. van Noordennen at (860) 573-5523.

Sincerely, 4Way A. Norton bate President Attachments cc: S. J. Collins, NRC Region 1 Administrator T. B. Smith, NRC Project Manager L. A. Kauffman, NRC Region 1 E. L. Wilds, Jr., Director, Radiation Division, CT DEP

U.S. Nuclear Regulatory Commission CY-07-079/Page 3 Table 1 Survey Area/Unit Classification and Description for Areas Proposed for Release Survey Description MARSSIM Media Survey Present Future Total Survey Total GW Unit Class Unit Soil Ground- GW Dose Unit Dose Design water Dose Target Actual Target &

Dose (GW) Target (mrem Average Actual (mrem/yr) Dose (mrem /yr) Soil Dose Soil Dose Target /yr) (mrem/yr) (mrem/yr)

I (mrem/yr) I I Phase II Submittal - March 8, 2005 (15 Survey Unit Release Records) Areas previously releasedfrom the NRC License 9523-0000 Southeast Wetland Area 3 Soil 10 0 0 10 0.37 0.37 9524-0000 South Site Grounds 3 Soil 10 0 0 10 0.06 0.06 9525-0000 Southeast Site Road 3 Soil 10 0 0 10 0.00 0.00 9526-0000 Northeast Mountain Side 3 Soil 10 0 0 10 0.22 0.22 9526-0001 Northeast Mountain Side 2 Soil 10 0 0 10 0.31 0.31 9526-0002 NortheastMountain Side 2 Soil 10 0 0 10 0.24 0.24 9528-0000 Southeast Mountain Side 3 Soil 10 2 0 12 0.19 2.19 9528-0003 Southeast Mountain Side 2 Soil 10 2 0 12 0.03 2.03 9528-0004 Southeast Mountain Side 2 Soil 10 0 0 10 0.05 0.05 9535-0001 Southeast Landfill Area 1 Soil 10 0 0 10 0.22 0.22 9535-0002 Southeast Landfill Area 2 Soil 10 0 0 10 0.06 0.06 9536-0000 ConstructionPiles Near 2 Soil 10 0 0 10 0.01 0.01 Rifle Range 9537-0000 PermittedLandfill Area 2 Soil 10 0 0 10 0.01 0.01 9538-0000 MaterialStorageArea 2 Soil 10 0 0 10 0.06 0.06 9806-0000 Southeast Landfill A Soil 10 0 0 10 0.03 0.03 Phase III Submittal - May 4, 2006, revised September 9, 2006 (7 Survey Unit Release Records) 9521-0000 Southeast Pond 3 Soil 10 2 0 12 2.70 4.70 9527-0001 East Mountain Side 2 Soil 8 2 0 10 1.28 3.28

U.S. Nuclear Regulatory Commission CY-07-079/Page 4 Table 1 Survey Area/Unit Classification and Description for Areas Proposed for Release Survey Description MARSSIM Media Survey Present Future Total Survey Total GW Unit Class Unit Soil Ground- GW Dose Unit Dose Design water Dose Target Actual Target &

Dose (GW) Target (mrem/ Average Actual Soil (mrem/yr) Dose (mrem/ yr) Soil Dose Dose Target yr) (mrem/yr) (mrem/yr)

(mrem/yr) 9527-0002 East Mountain Side 2 Soil 8 2 0 10 2.48 4.48 9527-0003 East Mountain Side 2 Soil 8 2 0 10 2.16 4.16 9527-0004 East Mountain Side 2 Soil 8 2 0 10 1.92 3.92 9528-0002 Southeast Mountainside 2 Soil 10 2 0 12 1.60 3.60 9531-0000 South end of Peninsula 3 Soil 10 0 0 10 1.50 3.50 Phase IV Submittal - November 30, 2006 (16 Survey Unit Release Records) 9106-0001 DischargeCanal 1 Sediment 17 2 0 19 4.10 6.10 9106-0002 DischargeCanal 2 Sediment 17 2 0 19 1.92 3.92 9106-0003 DischargeCanal 2 Sediment 17 2 0 19 4.30 6.30 9106-0004 DischargeCanal 2 Sediment 17 2 0 19 5.10 7.10 9106-0005 DischargeCanal 2 Sediment 19 0 0 19 2.20 2.20 9106-0006 DischargeCanal 2 Sediment 19 0 0 19 2.80 2.80 9106-0007 DischargeCanal 2 Sediment 19 0 0 19 1.90 1.90 9106-0008 DischargeCanal 2 Sediment 19 0 0 19 1.90 1.90 9106-0009 DischargeCanal 2 Sediment 19 0 0 19 2.70 2.70 9106-0010 DischargeCanal 2 Sediment 19 0 0 19 1.30 1.30 9106-0011 DischargeCanal 2 Sediment 19 0 0 19 1.00 1.00 9106-0012 Permanent Wetlands 2 Sediment 19 0 0 19 0.13 0.13 Area

U.S. Nuclear Regulatory Commission CY-07-079/Page 5 Table 1 Survey Area/Unit Classification and Description for Areas Proposed for Release Survey Description MARSSIM Media Survey Present Future Total Survey Unit Total GW Unit Class Unit Ground- GW Dose Actual Dose Soil water Dose Target Average Target &

Design (GW) Target (mrem Soil Dose Actual Dose Dose (mrem /yr) (mrem/yr) Soil Dose (mrem Target /yr) (mrem/

/yr) (mrem/ yr) yr) 9106-0013 Permanentwetlands Area 2 Sediment 19 0 0 19 0.11 0.11 9106-0014 Discharge Canal I Sediment 17 2 0 19 3.50 5.50 9106-0015 DischargeCanal I Sediment 19 0 0 19 3.10 3.10 9508-0000 Pond 3 Sediment 19 0 0 19 0.41 0.41 Phase V Submittal - December 7, 2006, Revised July 12, 2007 (12 Survey Unit Release Records) 9520-0001 Southwest Site StorageArea 2 Soil 17 2 0 19 0.15 2.15 9520-0002 Southwest Site StorageArea 2 Soil 17 2 0 19 0.32 2.32 9520-0003 Southwest Site StorageArea 2 Soil 17 2 0 19 0.44 2.44 9520-0004 Southwest Site StorageArea 1 Soil 17 2 0 19 0.15 2.15 9520-0005 Southwest Site StorageArea 1 Soil 17 2 0 19 0.56 2.56 9520-0006 Southwest Site Storage Area 1 Soil 17 2 0 19 0.38 2.38 9530-0001 CentralPeninsula 2 Soil 17 2 0 19 0.35 2.35 9530-0002 CentralPeninsula 2 Soil 17 2 0 19 0.27 2.27 9530-0003 CentralPeninsula 2 Soil 17 2 0 19 0.78 2.78 9530-0004 CentralPeninsula 3 Soil 17 2 0 19 0.47 2.47 9805-0000 SubsurfaceArea Associated C Soil 17 2 0 19 0.08 2.08 with the Peninsula 9807-0000 Subsurface Area Associated B Soil 17 2 0 19 0.47 2.47 with the Southwest Site Storage Area

U.S. Nuclear Regulatory Commission CY-07-079/Page 6 Table 1 Survey Area/Unit Classification and Description for Areas Proposed for Release Survey Description MARSSIM Media Survey Present Future Total Survey Total GW Unit Class Unit Ground- GW Dose Unit Dose Soil water Dose Target Actual Target &

Design (GW) Target (mrem Average Actual Dose Dose (mrem /yr) Soil Soil Dose (mrem/ Target /yr) Dose (mrem/yr) yr) (mrem/yr) (mrem/

yr)

Phase VI Submittal - February 20, 2007 Revised July 12, 2007(17 Survey Unit Release Records) 9304-0001 Southwest ProtectedArea 2 Soil 15 2 2 19 0.06 4.06 Grounds 9304-0002 Southwest ProtectedArea I Soil 15 2 2 19 0.08 4.08 Grounds 9504-0000 Bypass Road and Secondary 3 Soil 17 2 0 19 0.37 2.37 ParkingLot 9506-0000 North Site Grounds 3 Soil 19 0 0 19 0.25 0.25 9512-0000 Northwest Site Grounds 3 Soil 17 2 0 19 0.63 2.63 9522-0001 Southeast Site Grounds 2 Soil 17 2 0 19 3.13 5.13 9522-0002 Southeast Site Grounds 1 Soil 17 2 0 19 2.94 4.94 9522-0003 Southeast Site Grounds 1 Soil 17 2 0 19 1.18 3.18 9522-0004 Southeast Site Grounds I Soil 17 2 0 19 0.73 2.73 9522-0005 Southeast Site Grounds I Soil 15 2 2 19 0.18 4.18 9522-0006 Southeast Site Grounds 1 Soil 15 2 2 19 0.80 4.80 9522-0007 Southeast Site Grounds 1 Soil 15 2 2 19 0.79 4.79 9527-0005 East Mountain Side 2 Soil 17 2 0 19 3.16 5.16 9527-0006 East Mountain Side 1 Soil 17 2 0 19 6.91 8.91 9539-0001 ISFSI Haul Road (Northern 2 Soil 17 2 0 19 0.28 2.28 section)

U.S. Nuclear Regulatory Commission CY-07-079/Page 7 Table 1 Survey Area/Unit Classification and Description for Areas Proposed for Release Survey Description MARSSIM Media Survey Present Future Total Survey Total GW Unit Class Unit Ground- GW Dose Unit Dose Soil water (GW) Dose Target Actual Target &

Design Dose Target Target (mrem Average Actual Dose (mrem/yr) (mrem /yr) Soil Dose Soil Dose (mrem/ /yr) (mrem/yr) (mrem/yr) yr) 9539-0002 1SFSIHaul Road (Southern 2 Soil 17 2 0 19 0.16 2.16 section) 9804-0000 Subsurface Area Associated C Soil 15 2 2 19 0.10 4.10 with the Southeast Grounds I Phase VII Submittal - May, 2007 Revised July 12, 2007(18 Survey Unit Release Records) 9302-0000 Northwest ProtectedArea 3 Soil 15 2 2 19 0.20 4.20 Grounds 9306-0000 Southwest ProtectedArea 2 Soil 15 2 2 19 0.17 4.17 Grounds 9312-0001 Containment Radiologically 1 Soil 15 2 2 19 0.10 4.10 ControlledArea (RCA) 9312-0002 Spent Fuel Building (RCA) 1 Soil 15 2 2 19 0.06 4.06 9312-0003 Southwest 115kVSwitchyard 1 Soil 15 2 2 19 0.07 4.07 (RCA) 9312-0004 North of the PAB and Tank 1 Soil 15 2 2 19 0.96 4.96 Farm (RCA) 9312-0005 TankFarm (RCA) 1 Soil 15 2 2 19 4.11 8.11 9312-0006 PrimaryAuxiliary Building 1 Soil 15 2 2 19 0.21 4.21 (PAB) - (RCA) 9312-0007 RRFBuilding/ll5kV 1 Soil 15 2 2 19 0.17 4.17 Switchyard (RCA)

U.S. Nuclear Regulatory Commission CY-07-079/Page 8 Table 1 Survey Area/Unit Classification and Description for Areas Proposed for Release Survey Description MARSSIM Media Survey Present Future Total Survey Total GW Unit Class Unit Ground- GW Dose Unit Dose Soil water (GW) Dose Target Actual Target &

Design Dose Target Target (mrem Average Actual Dose (mrem/yr) (mrem /yr) Soil Dose Soil Dose (mrem/ /yr) (mrem/yr) (mrem/

yr) yr) 9312-0008 115 kV West Side, GW 1 Soil 15 2 2 19 0.54 4.54 Treatment Facility (RCA) 9312-0009 East Trench North (RCA) 1 Soil 15 2 2 19 3.42 7.42 9312-0010 East Trench South/lAWST 1 Soil 15 2 2 19 1.20 5.20 A&B (RCA) 9313-0000 CentralSite Grounds 2 Soil 15 2 2 19 0.14 4.14 9514-0000 West PrimaryParking Lot 3 Soil 17 2 0 19 0.25 2.25 9514-0001 East PrimaryParking Lot 2 Soil 17 2 0 19 1.43 3.43 9801-0000 SubsurfaceArea Associated A Soil 15 2 2 19 0.52 4.52 with the RCA 9802-0000 Subsurface Area Associated B Soil 15 2 2 19 0.09 4.09 with the West IndustrialSite Grounds 9803-0000 Subsurface Area Associated C Soil 17 2 0 19 0.14 2.14 with the North Grounds

CY-07-079 Attachment 1 Haddam Neck Plant Phased Release of Land from the Part 50 License July 2007

Attachment to CY-07-079 Page 1 CYAPCO Release Request for Non-ISFSI Areas

Background

In a letter dated July 7, 2000, as revised in August of 2002 (Revision 1) and October of 2002 (Revision 1A), CYAPCO requested an amendment to the Operating License for the HNP. The proposed change would add a License Condition which would approve the License Termination Plan (LTP) for the HNP and provide the criteria by which CYAPCO could change the LTP without prior NRC approval. In addition, CYAPCO indicated in Section 1.4.2 of the LTP that it may want to remove areas from the license once decommissioning and remediation tasks are complete and the licensee can demonstrate that the area and any associated buildings will have no adverse impact on the site in the aggregate to meet the 10 CFR Part 20, Subpart E, criteria for unrestricted release.

Sections 1.5 and 1.4.2 of the LTP respectively specify the scope of the review and the process for removing the land area(s) from the license. In a letter dated November 25, 2002, the NRC issued Amendment No. 197 to the HNP Facility Operating License (No. DPR-61). The amendment adds a license condition which approves the LTP for the HNP. The Safety Evaluation that supports the license amendment indicates that the NRC accepted the proposed process for releasing the land area(s) from the Part 50 license.

Purpose The purpose of this report is to provide written notification to the NRC of CYAPCO's intent to release a portion of the HNP site from the 10 CFR 50 License (DPR-61). Specifically, CYAPCO intends to release an area consisting of sixty-four (64) open land survey units, one (1) structure that has been free released under CYAPCO's Operational Radiation Program and six (6) subsurface soil survey areas. This area encompasses approximately 40 % of the original site area of 525 acres. The remainder of the area of the site was released from the license by NRC letter dated September 1, 2004 (Phase I, Non-impacted Area) and NRC letter dated February 28, 2006 (Phase II). Approximately 4.6 acres of the area released with Phase II are associated with the Independent Spent Fuel Storage Installation (ISFSI) and will be retained in the Part 50 license until the ISFSI is decommissioned after movement of the spent nuclear fuel from site. Figure 1 in the attachment to this letter shows that area to be retained in the license. This area includes portions of survey units 9523-0000, 9528-0000 and 9528-0004.

In accordance with Section 1.5 of the HNP LTP and NRC Safety Evaluation dated November 25, 2002, CYAPCO has reviewed and assessed the subject survey areas to ensure that this proposed action will have no adverse impact on the ability

Attachment to CY-07-079 Page 2 of the site in aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release.

1.0 Site Information (Related to Survey Areas Covered under This Request) 1.1 Physical description of the survey areas to be released The Haddam Neck Plant (HNP) is located at 362 Injun Hollow Road, Haddam, in Middlesex County, Connecticut. Connecticut Yankee Atomic Power Company (CYAPCO) is the license holder for HNP. The plant site originally contained 525 acres, approximately 25 acres of which were developed for plant use. The area surrounding the plant area is mostly wooded with steep slopes rising from plant elevation on side of the Connecticut River. The non-impacted areas of the site (approximately 80 acres under Phase 1) and approximately 240 acres under Phase II were previously released from the Part 50 license, under separate partial site release requests. NRC approval was granted on September 1, 2004 and February 28, 2006 respectively.

Presently, CYAPCO intends to release an area consisting of sixty-four (64) open land survey units, one (1) structure that has been free released under CYAPCO's Operational Radiation Program and six (6) subsurface soil survey areas. This area encompasses approximately 40 % of the original site area of 525 acres, leaving only the land area associated with the Independent Spent Fuel Storage Installation (ISFSI) within the Part 50 License.

Approximately 4.6 acres of the area released with Phase II associated with the Independent Spent Fuel Storage Installation (ISFSI) will be retained in the Part 50 license until the ISFSI is decommissioned after movement of the spent nuclear fuel from site. Figure 1 in the attachment to this letter show that area to be retained in the license. This area includes portions of survey units 9523-0000, 9528-0000 and 9528-0004.

In 1997 a Historical Site Assessment and initial site classification commenced, following the guidelines of MARSSIM, and was completed in 1999. Site characterization identified areas of surface soil contamination, contamination of structures, and areas of subsurface contamination. A summary of characterization activities and the Historical Site Assessment are provided in Section 2 of the LTP.

DCGLs, representing a dose of 25 mrem/yr (Base Case DCGLs) or less to the average member of the critical group, were calculated for soil, "existing" groundwater and building surfaces and included in the LTP. Section 6 of the LTP discusses the scenarios used for the DCGL calculations and the associated dose pathways assumed. A calculation method used to calculate "future" groundwater dose called the Basement Fill Model was also approved for use by the NRC as a part of the LTP in a letter dated August 19, 2005.

Attachment to CY-07-079 Page 3 As the only remaining above ground structure (the former Emergency Operations Facility) in the area to be released from the NRC license has been free released under the more restrictive criteria of the CYAPCO Operational Radiation Protection Program, the Building Surface DCGLs are not applicable. All survey units are treated as open land areas containing soil or sediments and potentially having additional dose contributions from existing and future groundwater. In order to account for any additional dose contributions from existing and/or future groundwater, a reduction to the Base Case DCGLs provided in Chapter 6 of the HNP LTP must be performed to ensure compliance with the release criteria of twenty five (25) mrem/yr TEDE.

Chapter 5 of the HNP LTP shows the compliance formula, Equation 5-1, for determining the total dose from the three pathways. The reduced DCGLs are called Operational DCGLs, whose relationship to the Base Case DCGLs is shown by Equation 5-3 of the HNP LTP.

The compliance equation of the HNP LTP, Equation 5-1, equates the total dose to three (3) components, soil dose, existing groundwater dose and future groundwater dose. To calculate DCGLs, dose models were developed to relate levels of residual radioactivity to potential dose. In the HNP LTP, Equation 5-1 expresses the total dose (HTotal) from all three (3) media, which is shown below:

HTotal can be expressed as:

HToal, =HSo,, + HEi,,igGYw + HFutureGW (HNP LTP Equation 5-1)

The total dose, HTotal, under the LTP criteria is twenty five (25) mrem/yr TEDE from all three (3) components. The allowable total dose under the Connecticut Department of Environmental Protection (CTDEP) radiological remediation standard for the HNP is nineteen (19) mrem/yr TEDE. Although the CTDEP standard dose not apply until the property is transferred to a new owner, the value for HTotai of nineteen (19) mrem/yr has been used as a target for all survey units. Table 1 shows a breakdown of the:

" Dose to which the Open Land Area FSS was designed

" Dose Target for Existing Groundwater

  • Dose Target for Future Groundwater as calculated by the Basement Fill Model As can be seen from Table 1, the sum of these three dose components is never greater then 19 mrem/yr. The survey units shown in Table 1 as being affected by existing and or future groundwater are consistent with Table 5-3 of the LTP. It should be noted that for the purpose of removing areas from

Attachment to CY-07-079 Page 4 the NRC license, an allotment of 6 mrem/yr could be added to the existing groundwater dose target of 2 mrem/yr, making for a maximum allowable dose of 8 mrem/yr.

As can be seen in the previously submitted Final Status Survey Reports for Phases III through VII, all of the survey units for those phases passed Final Status Surveys designed to the listed dose values for soil. Table 1 also shows the actual average soil/sediment dose equivalent based on the survey unit data analyses. In all cases the actual average dose due to soil or sediment is well below the design dose. The maximum unit (9527-0006) is approximately 41 % of the design soil dose.

Contained in a letter submitted to the NRC on May 30, 2007 is a Technical Support Document that shows the results of the two LTP required calculations performed for the Containment Building Basement and for the Discharge Tunnels. The doses calculated for those two structures are 1.58 and 0.25 mrem/yr, respectively which are within the 2 mrem/yr allotment for future groundwater. As these two structures are in separate survey units, each calculation result is compared individually to the allotment.

A groundwater monitoring program has also been developed and implemented at the HNP to investigate the hydrogeology at the site and monitor radiological and non-radiological contamination in groundwater at the site. A Groundwater Compliance Plan was developed and submitted to the NRC on January 10, 2006 and resubmitted in response to NRC comments on September 22, 2006. The purpose of the Groundwater Compliance Plan was to describe the groundwater monitoring program and to define the method by which Connecticut Yankee Atomic Company would demonstrate that plant-related radioactivity in groundwater at HNP meets the phased release requirements defined in its License Termination Plan (LTP) and License Amendment No. 197 to License No. DPR-61.

As discussed in a letter submitted to NRC on July 19, 2007, the existing groundwater dose from the highest onsite monitoring well is 1.98 mrem/yr as of the date of the final sampling event conducted in June of 2007. This result is below the target value listed in Table 1 of 2 mrem/yr and well below the maximum allowable dose of 8 mrem/yr for existing groundwater dose. The July 19, 2007 letter also includes additional information concerning compliance with the other groundwater related requirements of the LTP.

Attachment to CY-07-079 Page 5 2.0 Impact of Release of the Area 2.1 Statement of Dismantling Activities With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel has been removed, all decommissioning and dismantlement activities have been completed at this site. Thus, no dismantlement activities are required in these survey areas for CYAPCO to release them. The FSS Reports for each of these survey areas has been submitted to the NRC as indicated in Table 1 of this letter. The results of the future groundwater dose calculation were sent to the NRC on May 15, 2007.

The Groundwater Compliance Report is included in the letter to the NRC dated July 19, 2007, as indicated above 2.2 Potential for Cross-Contamination from Subsequent Activities Prior to FSS, areas ready for survey were isolated and controlled under RPM 5.1-16, "Area Preparation for Final Status Survey Activities" and in accordance with LTP Section 5.4.6. This included posting of the area as well as notifications to site personnel. Permission to enter and work in these areas was required to be obtained from the Final Status Survey personnel.

During decommissioning, controls were placed on the release of material from radiological controlled areas and the industrial area which decreased the probability that areas would be impacted from decommissioning activities.

These control measures included contamination containment, dust control measures, storm water runoff measures, building demolition controls, and additional evaluations and surveys of material leaving the industrial area.

LTP Section 5.7.3.3 describes periodic surveillance/re-survey to confirm that no radioactive material had been introduced into the areas that would invalidate the results of the final status surveys.

These isolation and control measures (both pre- and post-FSS) have been implemented in these survey areas through approved procedures at the time of turnover to the Final Status Survey Group and remained in effect throughout site final survey activities and until the risk of recontamination from decommissioning activities was alleviated.

These requirements for decommissioning activities, as well as the additional protections afforded from FSS isolation and control measures, provide strong assurance that the potential for cross-contamination of the subject survey areas is minimal. It is noted that all open land areas of the site were remediated and surveyed using the survey design doses listed in Table 1.

In addition, the site has carried out an erosion control program to reduce the potential for soil erosion into adjacent land areas and surface water bodies.

Attachment to CY-07-079 Page 6 The HNP spent fuel at the ISFSI is stored in the NAC-MPC System. The NAC-MPC System is a sealed and leak-tight spent fuel storage system. In addition, CYAPCO completed in-process inspections and tests during fabrication and sealing of the canisters. Consequently, there is no release of radioactive material during normal conditions of storage. The structural analysis of the canister for off-normal and accident conditions of storage, which is presented in Chapter 10 of the NAC-MPC-FSAR, shows that the canister is not breached in any of the evaluated events. Consequently, there is no release of radioactive material during off-normal and accident conditions of storage that could impact the areas proposed for release.

2.3 Impact of Releasing the Specific Area on Part 50 License Basis The license basis for the HNP includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities. Throughout decommissioning, these programs have been modified as necessary and terminated when the applicable concern is no longer relevant. These program changes are implemented using the change processes specified for each type of program. The phased release approach is described in Section 1.5 of the HNP LTP. The methodology for releasing land requires a review and assessment of the impact on license programs for the site lands remaining within the domain of the Part 50 License. The NRC accepted this approach included in the HNP LTP via License Amendment 197. The impact of releasing the subject survey areas from the Part 50 License on each of the licensing programs included in Section 1.4.2 of the LTP is described below.

With this submittal, CYAPCO is not requesting NRC approval of any potential changes described herein.

2.3.1 Technical Specifications The HNP Defueled Technical Specifications are not impacted by the release of the subject survey areas, as a size and description of the site are not included in the Technical Specifications. The survey and release are consistent with the License Termination Plan and associated License Condition.

The NAC-MPC Technical Specifications, associated with allowable surface contamination on the cask after loading, were based upon limiting the dose at 100 m due to a total mechanistic release of the surface contamination. The partial site release will not affect the basis for this Technical Specification, as the assumed 100 m dose point is within the 300 m owner controlled boundary that will continue to be maintained after partial site release has been implemented.

Attachment to CY-07-079 Page 7 2.3.2 Final Safety Analysis Report (FSAR) and Environmental Report The Decommissioning Final Safety Analysis Report will require minor changes to Section 2.1 and Figure 2-1, "Site Boundary" to describe the reduced site area resulting from the removal of the subject survey area from the Part 50 License.

During preparation of the License Termination Plan, the impacts on information provided in the Decommissioning Environmental Report and to NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" were evaluated. The information contained within the LTP was determined to be consistent or bounded by the information in the Decommissioning Environmental Report and to NUREG-0586. The process of partial site release was included in the LTP, and this partial site release is being proposed consistent with the process in the LTP. Thus, the Decommissioning Environmental Report and conclusions in Section 8 of the LTP concerning NUREG-0586 are not impacted by partial site release.

2.3.3 ISFSI Emergency Plan As the former nuclear plant has been dismantled and decommissioned, the Emergency Plan for the site has been reduced to address the ISFSI only. The ISFSI Emergency Plan describes the location of the ISFSI, the Radiologically Controlled and Protected Areas, and the 300 m Owner Controlled Area. None of these locations/areas will be affected by the proposed partial site release.

Although portions of the owner controlled area are included in the area proposed for partial site release, CYAPCO will continue to maintain control of this area.

2.3.4 Security Plan This plan will not be affected by the release of the proposed release area.

2.3.5 Off-site Dose Calculation Manual (ODCM)

Gaseous, liquid, and solid radwaste systems associated with the operation of HNP have been removed and disposed of. Site decommissioning activities have been concluded for the site (except those required in the future for the ISFSI), and discharges of radioactive material (gaseous or liquid) are no longer made. In addition, the ISFSI casks are considered to be leak tight under normal and various postulated accident conditions, and thus are not a source of effluent.

Attachment to CY-07-079 Page 8 Accordingly, the ODCM has been revised to address the ISFSI only.

Thus, it no longer includes X/Qs, and recently the NPDES permit for the site was terminated. Monitoring in accordance with the ODCM continues and will not be impacted by the proposed partial site release.

Thus, the ODCM will not be affected by release of the proposed areas.

2.3.6 Environmental Monitoring Program Gaseous, liquid, and solid radwaste systems associated with the operation of HNP have been removed and disposed of. Site decommissioning activities have been concluded for the site (except those required in the future for the ISFSI), and discharges of radioactive material (gaseous or liquid) are no longer made.

In addition, the ISFSI casks are considered to be leak tight under normal and various postulated accident conditions, and thus are not a source of effluent. Accordingly, the Environmental Monitoring Program has been revised to address monitoring associated with the ISFSI only.

The Environmental Monitoring Program will not be affected by the release of the proposed areas.

2.3.7 Ground Water Monitoring Program The Groundwater Monitoring Program is intended to integrate all aspects of groundwater characterization, monitoring and remediation required to support unrestricted release of the HNP site. Now that the final sample round required by the LTP and the NRC has been taken, the Groundwater Monitoring Program will no longer be needed for the purposes of the NRC Part 50 license and is being modified to fulfill the needs of property transfer as governed by the CTDEP Remediation Standards Regulations.

2.3.8 Fire Protection Program This ISFSI program will not be affected by the release of the subject survey areas.

2.3.9 Training Program The training program for the ISFSI SSCs that are important to safety will not be affected by the release of the subject survey areas.

2.3.10 Post Shutdown Decommissioning Activities Report (PSDAR)

Attachment to CY-07-079 Page 9 The PSDAR has been updated as decommissioning has progressed.

The release of the subject will not impact the current revision of the PSDAR.

2.3.11 License Termination Plan (LTP)

The requested release is consistent with the information in the LTP concerning final status survey and partial site release. A minor revision will be made to the LTP to revise the area of the site still under the Part 50 license.

2.3.12 Compliance with 10 CFR 100 The 300 m owner controlled area ensures that public dose will meet 10 CFR 100 criteria. The public will be allowed to walk or drive through portions of this controlled area but will not be allowed to temporarily reside (e.g., camp or hunt) in the area. Dose to members of the public will also meet 10 CFR Part 20 and 40 CFR 190 requirements.

2.4 Consideration of Interaction between the Proposed Partial Site Release and the Previously Released Site and between the Proposed Partial Site Release and Remaining License Site Appendix L to NUREG 1757, Volume 2, provides guidance for the licensee to identify and analyze the potential interaction between the potential site release and any on-site or offsite sources. That guidance has been integrated into this partial site release request.

The following sections describe effects of interaction between the proposed site release and previously released site and interaction between the proposed site release and the remaining license site.

2.4.1 Effects on the Proposed Site Release from Previous Land Release Prior to the subject proposed release, CYAPCO proposed and the NRC approved the release of the non-impacted site area (Phase I) and the Phase II Release Areas of the HNP site from its Part 50 License. The previously release areas were classified as non-impacted or as can be seen from Table 1, were surveyed to LTP dose criteria. Any migration of material from the previously released areas to the proposed release area (although very unlikely) would have radionuclide concentrations which on the average are well below the Operational DCGLs used in the areas of the proposed release.

The previously released areas were also shown in CYAPCO's letter to NRC of March 8, 2005 to have no groundwater impact that needs to be considered

Attachment to CY-07-079 Page 10 significant per the LTP. Therefore, the previous land release will not have an adverse effect on the areas of the proposed release.

2.4.2 Dose Effects on ISFSI Land (i.e., land that will remain under Jurisdiction of Part 50 License)

The HNP ISFSI is located within the site boundary of the existing HNP site.

The Controlled Area for an ISFSI as defined in 10 CFR 72.3 as the area immediately surrounding an ISFSI for which the Licensee exercises authority regulating its use and within which ISFSI operations are performed. The 300 meter radius ISFSI Controlled Area will encompass some of the land being requested by this submittal for release from jurisdiction of the license; however, this area will continue to be under the authority and control of CYAPCO until the spent fuel has been transferred offsite.

As stated previously, certain land around the ISFSI is not the subject of the proposed site release and will remain in CYAPCO Part 50 License (Figure 1).

A radiological evaluation was performed for the ISFSI in accordance with 10 CFR 72.212 (b)(2)(i)(C) to establish that the requirements of 10 CFR 72.104 have been met. These requirements specify that the annual dose equivalent from normal operation or any anticipated occurrences at the ISFSI to any real individual who is located beyond the controlled area would not exceed 25 mrem to the whole body, 75 mrem to the thyroid and 25 mrem to any other critical organ as a result of exposure to: (1) planned discharges of radioactive materials, (2) direct radiation from the ISFSI or (3) any other radiation from uranium fuel cycle operations within the region.

The HNP spent fuel is stored in the NAC-MPC System. The NAC-MPC System is a sealed and leak tight spent fuel storage system. In addition, CYAPCO completed in-process inspections and tests during fabrication and sealing of the canisters. Consequently, there is no release of radioactive material during normal conditions of storage. The structural analysis of the canister for off-normal and accident conditions of storage, which is presented in Chapter 10 of the NAC-MPC-FSAR, shows that the canister is not breached in any of the evaluated events. Consequently, there is no release of radioactive material during off-normal and accident conditions of storage.

Using conservative assumptions for the contact dose rates for top, sides and air inlet/outlet, NAC determined that the dose at the controlled area would be less than 25 mrem/yr. However, actual measurements at locations at the boundary of the 300 m controlled area have been determined to be indistinguishable from background. Doses associated with the uranium fuel cycle operations at HNP no longer exist, and the areas to be released meet the criteria for unrestricted release in 10 CFR 20.1402. Thus this satisfies, with considerable margin, the limit of 25 mrem/year stipulated in 10 CFR 72.104 and 40 CFR 190.

Attachment to CY-07-079 Page 11 2.4.3 Dose Effect on the Proposed Site Release from the remaining decommissioning activities at the remaining HNP Site Decommissioning activities have been completed at HNP. Only activities associated with maintenance and operation of the ISFSI are being conducted.

As previously discussed, the casks stored in the ISFSI are sealed and leak-tight such that there is no release of radioactive materials in normal, off-normal or accident conditions.

Also discussed previously, the dose to a member of the public outside the controlled area of the ISFSI will receive less than the 25 mrem/yr dose as stipulated in 10 CFR 72.104 2.5 Additional Areas to be addressed to Support the Release of the Subject Survey Units HNP will maintain the following records through license termination: 1) a map of the site identifying the facility and site as defined in the original license; 2) a record of the Phase III, IV, V, VI and VII Survey Units released under this action; and 3) documentation of the radiological conditions of the lands released under this action.

2.6 Site-Release Criteria The site release criteria for the HNP site correspond to the 10 CFR 20.1402, criteria for unrestricted use. The residual radioactivity, including that from groundwater sources, that is distinguishable from background, must not cause the total effective dose equivalent (TEDE) to an average member of the critical group to exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels that are ALARA.

As discussed above, the dose contribution from existing groundwater for the areas identified as impacted by existing groundwater is no more than a dose of 1.98 mrem/yr. The maximum allowable dose by LTP Equation 5-1 is 8 mrem/yr. Buried concrete foundations at levels calculated in accordance with the LTP would contribute no more then 1.58 mrem/yr. The allotted dose using LTP equation 5-1 is 2 mrem/yr. As shown in Table 1, the sum of the individual dose components is never more then 19 mrem/yr and when average soil concentrations are used instead of soil FSS design and target values, the highest value is 8.91 mrem/yr.

2.7 Final Status Survey The HNP LTP Section 5 states that the Final Status Survey Plan encompasses the radiological assessment of all affected structures, systems

Attachment to CY-07-079 Page 12 and land areas for the purpose of quantifying the concentrations of any residual activity that exists following all decontamination activities. Final status surveys were performed and reports submitted for the subject survey areas, as indicated in Table 1 of attached letter.

Table 1 of this letter provides a listing of all survey units associated with this proposed release and includes their classification and date of associated report submittal.

These reports document the results and conclusions of the final status surveys of survey uhits and were prepared in accordance with guidance and requirements contained in the following:

" Haddam Neck Plant License Termination Plan,

" NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), Section 8.6 and

" NUREG-1757, Volume 2, Consolidated NMSS Decommissioning Guidance

- Characterization, Survey, and Determination of Radiological Criteria, (Although not referenced in the CY LTP, guidance contained in many sections of this NUREG have been utilized).

These reports concluded that the surveys were conducted in a manner consistent with the LTP and that the survey units passed the survey. The reports indicated that the criteria for allowable dose due to soil allotted for each survey unit have been met. As shown in Table 1, when the soil FSS design dose is added to the target existing and future groundwater dose for each unit, the criteria for unrestricted release is met.

2.8 Conclusion The release of the subject survey units is part of CYAPCO's overall effort to achieve unrestricted release of the site in accordance with the criteria in Subpart E of 10 CFR 20. This action is also consistent with the approach described in Section 1.4.2 of the HNP LTP and is consistent with the approach endorsed by the NRC in their Safety Evaluation that supported approval of the HNP LTP.

In addition, 10 CFR 50.82(a)(1 1) establishes the criteria to be used by the NRC for terminating the license of a power reactor facility. These criteria include (1) dismantlement has been performed in accordance with the approved license termination plan, and (2) the final radiation survey and associated documentation demonstrate that the facility and site have met the criteria for decommissioning in 10 CFR 20, Subpart E. All decommissioning and dismantlement activities have been completed in the subject survey units, and the release of the subject survey units supports the process of license termination by demonstrating that this portion of the site can be released from

Attachment to CY-07-079 Page 13 the HNP license. The final status surveys have confirmed that the residual radioactivity in each of the subject survey units meets the criteria established in the LTP. Thus, the action of the release of the subject survey units supports the overall goal of unrestricted release of the site in accordance with NRC regulations.

3.0 References 3.1 License Termination Plan, Rev. 0, July 7, 2002.

3.2 License Termination Plan, Rev. 1, August 20, 2002.

3.3 License Termination Plan, Rev. 1A, October 10, 2002.

3.4 License Amendment 197 Re: License Termination Plan, November 25, 2002.

3.5 NRC Approval of Phase 1 Site Release of Unimpacted Area, September 1, 2004.

3.6 CYAPCO Request to Release Phase 2 from License, March 8, 2005.

3.7 Phase 2 Final Status Survey Report, May 8, 2005 3.8 License Amendment 2002, Approval to Use Basement Fill Model in License Termination Plan, August 19, 2005.

3.9 LTP Groundwater Monitoring Plan, Rev. 0, January 10, 2006.

3.10 NRC Approval of Phase 2 Site Release from License, February 28, 2006.

3.11 Phase 3 Final Status Survey Report, May 4, 2006.

3.12 LTP Groundwater Monitoring Plan, Rev. 1, September 22, 2006.

3.13 License Termination Plan, Rev. 4, November 16, 2006.

3.14 Phase 4 Final Status Survey Report, November 30, 2006.

3.15 Phase 5 Final Status Survey Report, December 7, 2006.

3.16 Phase 6 Final Status Survey Report, February 20, 2007.

3.17 License Termination Plan, Rev. 5, February 22, 2007.

3.18 LTP Groundwater Dose Calculations, May 15, 2007.

Attachment to CY-07-079 Page 14 3.19 Phase 7 Final Status Survey Report, May 17, 2007.

3.20 Technical Support Documents for the Containment Building Basement and Discharge Tunnels, May 30, 2007.

3.21 Groundwater Compliance Report, May 31, 2007.

3.22 License Termination Plan, Rev. 6, July 12, 2007.

3.23 Revised Final Status Survey Reports for Phases 5, 6 and 7, July 12, 2007.

3.24 Final LTP Groundwater Monitoring Report and Groundwater Compliance Report, July 19, 2007.

3.25 Final Safety Analysis Report (including Post-Shutdown Decommissioning Activities Report) 3.26 Defueled Technical Specifications 3.27 Independent Spent Fuel Storage Installation 10CFR .72.212 Evaluation.

3.28 NAC-MPC Final Safety Analysis Report.

3.29 Emergency Plan, Revision 14.

3.30 Independent Spent Fuel Storage Installation Offsite Dose Calculation Manual, Revision 20.

3.31 Supplement 1 to NUREG-0856, "Final Generic Environmental Impact Statement," November 2002.

3.32 NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), Revision 1, August 2000.

3.33 NUREG-1757, Consolidated NMSS Decommissioning Guidance-Characterization, Survey, and Determination of Radiological Criteria.

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