ML20197D426
| ML20197D426 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/18/1997 |
| From: | Desiree Davis YANKEE ATOMIC ELECTRIC CO. |
| To: | Fairtile M NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20197D431 | List: |
| References | |
| BYR-97-064, BYR-97-64, NUDOCS 9712290054 | |
| Download: ML20197D426 (13) | |
Text
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YANKEE ATOMIC ELECTRIC COMPANY
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580 Mwn Street, Bolton..assachusotts C1740-1398 December 18.1997 BYR 97-064 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention:
Mr. Morton B. Fairtile, Senior Project Manager Non Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management 0
OfTice of Nuclear Reactor Regulation
References:
(a)
License No. DPR-3 (Docket No. 50 29)
(b)
Lettes, M. B. Fairtile, U. S. Nuclear Regulatory Commission (NRC) to J. A.
Kay, Yankee Atomic illectric Company (YAEC), Request for Additional Information - License Termination Plan, dated September 9,1997 (c)
Letter, A. C. Katak (YAEC), to M. B. Fairtile (NRC), License Termination Plan for Yankee Nuclear Power Station, dated May 15,1997 (d)
Letter, J. M. Grant (YAEC) to M. B. Fairtile (NRC), Sale of Yankee Nuclear 1
Service Division Assets, dated December 5,1997 (c)
Letter, D. K. Davis (YAliC) to M. B. Fairtile (NRC), Proposed License Amendment to Approve Yankee Nuclear Power Station License Termination Plan, dated December 18,1997
Subject:
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION AND REVISIONS TO YANKEE NUCLEAR POWER STATION LICENSE TERMINATION PLAN
Dear Mr. Fairtile:
On September 9,1997, the Nuclear Regulatory Commission requested additional information (Reference (b)) to complete their review of the Yankee Nuclear Power Station (YNPS) License Tennination Plan (Reference (c)). Attachment I to this letter presents the Yankee Atomic Electric Cctmpany (YAEC) responses to each request for additional information.
Also enclosed with this letter are nine (9) copies of revisions to the License Termination Plan.
Revisions to the License Tennination Plan een be classified in one of the following categories:
Changes that are strictly administrative in naiura (e.g., correction of typographical errors).
Revisions made in response to NRC comments contained in Reference (b).
9712290054 971218 PDR ADDCK 05000029-_
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Revisions made in response to NRC comments provided during telephone discussions on November 5,1997 and November 24,1997.
Specific references to the YAEC Nuclear Services Division changed to Duke Engineering and Services (DE&S) to reflect the current decommissioning organization (Reference (d)). to this letter provides a summary listing of the changes to the License Termination Plan. Attachment 3 provides a list of administrative instructions for updating the License Termination Plan.
The responses to the request for additional it formation and the revisions to the License Termination Plan presented in this letter have been reviewed by the Plant Operations Review Committee and the Nuclear Safety Audit and Review Cornmittee. The changes to the License Termination Plan are relatively minor and are not expected to adversely imp.ct NRC review and
- approval of the License Termination Plan by February 15,1998. Ifyou have any questions or require further informa.Un, please contact Ms. Jane Grant of my staff.
Sincerely, YANKEE ATOMIC ELECTRIC COMPANY O
bmk<
Don K. Davis President and Chief Executive Officer Enclosure Requested Distribution with
Enclosure:
Public Document Room - original and 3 copies M. Fairtile, Senior Project Manager, NRR 3 copies R. Bellamy, Citief, Decommissioning and Lab Pranch, Region 1 - I copy J. Ilickey, Chief, Low Level Wasy and Decommissioning Projects Branch, NMSS ATTN: L. Pittiglio - I copy s
4 COMMONWEALTH OF MASSACHUSETTS)
)ss i
WORCESTER COUNTY
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l Then personally appeared before me, Don K. Davis, who, being duly sworn, did state that j
he is the President and Chief Executive Officer of Yankee Atomic Electric Ccmpany, that he is i
duly authorized to execute and file the foregoing document in the name and on behalf of Yankee j
Atomic Electric Company and that the statements therein are true to the best of his knowledge l
and belief.
m~-- y Kathr'yn GatesNotary Public l
My Commission Expires January 1,2004 i
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cc:
Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department ofPublic Health -
-305 South Street Boston, MA 02130
- Commissioner Richard P. Sedano
. Vermont Department of Public Senrice 120 State Street,3rd Floor Montpelier, VT 05602
- Mr. David Rodham, Director
- ATTN:Mr.JamesMuckerheide
' Massachusetts Civil Defense Agency 400 Worcester Road P. O. Box 14%
Framingham, MA 0170103173
ATTACHMENT 1 Yankee Atomie Electric Company Respmises to NRC Request for AdditionalInformation on YNPS License Termination Plan Ouestion 1 - SectionL3.2. 3.3. and 414 The licensee is proposing to release buildings, demolish the buildings, release the building rubble, then remediate soils previously under the Hoors that may be contaminated. In this case, there may be contaminated soils that adhere to and are removed whh the demolished Hoor rubble. The licensee needs to discuss how it will verify that demolition rubble is clean if contaminated soils are identified under buildings.
Response
The Yankee Nuclear Power Station (YNPS) License Termination Plan states that Yankee may elect to delay remediation of radiologically contaminated subfloor soils until structures above the soils are surveyed and demolished. In this case, final status surveys would first be conducted on the interior surfaces and above-grade exterior surfaces of a structure to verify that residual levels of contamination were below the site release criteria. The above grade part of the structure would then be demolished. The basement floor slabs or other suitable barriers would be maintained in place during demolition to prevent contaminated subfloor soil from coming in contact with previously surveyed building material. This building material would be removed and stored in a clean area until release of the site (or portion thereof). Floor slabs or other contamination barriers would be removed later as part of soil remediation. Depending on the level of contamination, floor material would be (1) disposed of as low level radioactive waste, (2) surveyed in accordance with Final Status Survey protocola arid stored in a clean area until release of the site (or portion thereof), or (3) released from the site with no detectible contamination in accordance with the guidance presented in NRC IE Circular 81-07.
Question 2 - Secijon_4.2 In Section 4.2.2, the licensee has indicated that the asphalt surfaces will be treated the same way as soli. Asphalt surfaces should be treated under surface criteria.
Response
The YNPS License Termination Plan Section 4.2.2 states that asphalt surfaces will be remediated using the same methods as used for soil (i.e., excavation of contaminated materials to meet site release criteria). This section does not discuss final status survey requirements for asphalt surfaces. Final status survey requirements for asphalt surfaces in open land areas are presented in Section 4.3.3 of Appendix A. These requirements are similar to those for surfaces in structures and include scan surveys, total surface contamination measurements, and asphalt and surface soil samples, i
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O=-dam 3 - Sections 2.4.6. and Apnendir A. Section 3.2
' Section 2.4.6 states that sediment samples will be taken. Also, Section 4.4.5 states that in the pond sediment areas,30 samples per unit will be taken. However, Appendix A.
Section 3.2 states that sediment samples will not be included in areas affected by monitored and licensed emuent discharges. Section 3.2 should be revised to reflect that sediment samples will be taken.
Response
-Yankee Nuclear Power Station (YNPS) is licensed to release liquid effluent through a monitored discharge point on Sherman Pond. This release path is controlled in accordance with the Radioactive Effluents Controls Program and assessed in accordance with the 4
Radiological Environmental Monitoring Program. Additionally, sediment near the discharge point has been wmpled as part of site characterization activities. As reported in Yankee's semi-annual effluent reports and in Section 2.4.6 of the License Termination Plan, samples of the sediment near the discharge point indicate the presence of a very small amount of YNPS-related radioactivity (predominantly cobalt-60). Although this contamination was deposited as a result of licensed plant discharges amt the resulting radiological dose is a small fraction of regulatory limits, the License Termination Plan has been revised to incorporate sampling of the sediment near the discharge point in the south end of Sherman Pond.
Question 4 - Appendir A. Section 3.1 The licensee committed, in the Decommissioning Environmental Repr-t, December 1993, to use NRC IE Circular 81-07," Control of Radioactive Contaminated Material" for all materials leaving the Radiation Control Area to ensure that radioactive materials are not inadvertently released from the facility. This commitment is to limit release of materials from the site to no detectable activity. The licensee needs to discuss how this commitment is consistent or inconsistent with the release criteria proposed in this section.
Response
Section 3.1 of Appendix A of the License Termination Plan presents the site release criteria for YNPS. These criteria will be met in order to release the YNPS site (or portions thereof) from the Part 50 license. Prior to release of the site (or portions thereof) from the Part SG license, Yankee will continue to meet the requirements of NRC IE Circular 81-07 for release of materials from the site. This commitment, contained in the approved Decommissioning Plan and Decommissioning Environmental Report, is therefore unchanged by the License Termination Plan.
e Question 5 - Apggadir A. Section 4.1.2 This section should be revised to include surveys and samples as an unaffected area as recommended in NUREG/CR 5849.
Resatinas The YNPS site is approximately 2,200 acres in size and is comprised of steeply sloped terrain, dense woods, and miscellaneous open areas in addition to the plant facilities. The majority of this area was not developed or otherwise disturbed by plant operations and is classified as Non.
Impacted. Final status surveys and samples in the Non-Impacted Area of the site are not justified because there is no reasonable potential for contamination.
As described in Appendix A, Section 4.1.2, the initN classification of the site is based on site characterization data and a review of the history of radioactive materials involvement. Soil samples were collected in the part of the Non-Impr:ted Area closest to the plant as part of site characterization. These samples contained no plant related radioactivity and were consistent with Radiological Environmental Monitoring Program (REMP) data from throughout opentions and decommissioning. In addition to the soil sampling data, the classification of the Non-Impacted Area is supported by aerial photos, interviews with longtime employees, and historical plant documents. These sources were used to determine which areas oOhe site were disturbed by past activities. No area with reasonable potential for contamination is classified as Non-Impacted.
To provide further assurance that the extent of plant contamination is conservatively bounded by the coverage of final status surveys, Unaffected Areas at least 20 m wide act as buffer zones between Affected Open Land Areas and the Non Impacted Area. If warranted by information from future final status surveys or additional site characterization, any part of the Non Impacted Area is subject to reclassification and surveys according to final status survey procedures.
Finally, the concept of a Non-Impacted Area is consistent with Draft NUREG-1505, "A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning Surveys." Draft NUREG-1505 recommends the use of non-impacted areas with no level of survey coverage to make the best use of decommissioning resources. This approach is also consistent with past decommissioning projects at Shoreham and Fort St. Vrain.
Question 6 - Appendir A. Section 4.3.1 Section 4.3.2 should be revised to include gridding er a method for referencing measurements back to a specific location.
Rcanonic The method for designating survey locations within survey units is outlined by procedure DP-8802 (Procedure Reference 3 of Appendix A). Gridding will be utilized mainly in Suspect
Affected Structural survey units and Affected Open Land survey units. Other types of sun ey units will generally not be gridded. For non-gridded survey units, the survey locations will generally be designated prior to the survey and will be selected at biased locations where the potential for contamination is greatest, at locations evenly distributed throughout the survey unit, or at a combination of these locations. Survey locations will be indicated on surfaces and open land areas by the use of self-adhesive labels, permanent marker, stakes, notations on sun'ey maps, or equivalent methods. Plant system survey locations will be located at sample point openings or on the interior surfaces oflarge components and will be designated with tags, self-adhesive labels, permanent markings, notations on survey maps, or equivalent methods.
Appendix A, Section 4.3 has been revised to state that measurement locations distributed throughout a survey unit will be documented in accordance with written final status sun'ey procedures.
Que111on 7 - Appendix A. Section 4.4.3 This section states that for activated structures and components only exposure rate measurements will be taken. In addition to the exposure rate measurements, direct measurements and smears should also be taken in accordance with Regulatory Guide 1.86.
Rcaponse Activated structures and components will be in areas classified as Suspect Affected survey units.
In accordance with Appendix A, Section 4.3.1, final status surveys of activated concrete and components will include:
A scan survey of 100% of the accessible area, e
Total surface contamination (fixed point) measurements, e
Removable contamination measurements (smears) at locations where the result or minimum detectable concentration of the total surface contamination measurement is greater than the removable contamination limit, and Exposure rate measurements.
e As described in Appendix A, Section 4.4.3, no exposure rate measurements will be taken on structures and components where the only source of radioactivity is surface contamination.
Contamination at or near the surfaces of such structures and components will be the only significant contributor to exposure rates. Calculations have been performed to demonstrate that for such surfaces at YNPS, the exposure rate at one meter from a surface will be below 5 pR/hr above background if the surface contamination levels are below the limits in Regulatory Guide 2
1.86 (i.e.,5000 dpm/100 cm ). Therefore, only total surface contamination measurements will be needed to demonstrate that the release criteria have been met for both surface contamination and exposure rates.
l L
To demonstrate that surface contamination levels are the limiting condition, exposure rates from several surface source contamination scenarios were calculated using the MICROSillELD 1
computer code, These scenarios assumed that the floors and walls below 2 meters of typical 2
rooms were uniformly contaminated at the 5000 dpm/100 cm limit. The calculated exposure rate in each scenario, at on9 meter from the floor surface, was as follows:
Scenario A: The exposure rates in a typical equipment room of 10 x 10 meter floor area were calculated to be no greater than 4.3 pR/hr, assuming that the contaminated surface source was comprised entirely of Co-60. This assumption is conservative because Co 60 has the highest average gamma energy per disintegration of any of the radionuclides expected to be present at YNPS during the Final Status Survey. In fact, Co 60 comprises only about 9 to 14% of the total activity in the mix of radionuclides found in actual surface contamir_ation at YNPS. Exposure rates for this scenario were calculated for the center of the room and in the comer at one meter from the floor and adjacent walls.
Scenario B: The exposure rates at the center and comer of a trige area such as the YNPS Turbine Deck (46 x 22 meters) were calculated to be no greater than 4.8 pR/hr, conservatively assuming that the contaminated surface source consisted entirely of Co-4 60.
Scenario C: The exposure rate at the center of a room with the same dimensicus as Scenario B, but with a radionuclide mix representative of actual surface contamination at YNPS, was 0.5 pR/hr.
The effect of adding several localized hot spots to the uniform contamination of the above scenarios was also evaluated and found not to be significant. The Final Status Survey Plan allows individual localized areas of surface contamination up to three times the guideline value, provided the area weighted average does not exceed the guideline value. Adding several 15,000 dpm/100 cm hot spots to the above scenarios, and assuming a radionuclide mix representative of 2
actual surface contamination at YNPS, the additi,,nal exposure was calculated to be less than 0.02 pR/hr.
In conclusion, demonstrating that the surface contamination release criteria are met is sufficient to satisfy the exposure rate release criterion of 5 pR/hr where the only source of radioactivity is surface contamination.
Question 8 - Appendir A. Section 4.4.4 Section 4.3.2 should include a description of the frequency of groundwater samples collected from the observation wells, and a description of what potential contaminants the water is being analyzed for.
Response
A total of 20 wells on site are available for groundwater sampling. As described in Appendix A, 1
Section 4.3.3, a single groundwater sample will be collected as part of the final status survey in any survey unit where an operable groundwater observation well is located. Groundwater samples will be analyzed for tritium and gamma-emitting radionuclides. Although Sr 90 is not expected to be present, the water will also be analyzed for this radionuclide in order to demonstrate compliance with the EPA National Primary Drinking Water Standards for Radioactivity (40 CFR Part 141). Appendix A, Sections 4.3.3 and 4.4.4 have been revised to clarify these requirements.
The single final status surycy sample from each well will be supported by site characterization data. All groundwater observation wells are currently sampled on a regular basis as a part of site characteristion activities. The only plant related radionuclides found in groundwater samples to date have been tritium and Co-60. The concentrations of these radionuclides have remained relatively consistent and are well below the standards of 40 CFR Part 141.
Qucation 9 - Annendix A. Section 4.5.4 and 5.1.3 Section 4.5.4 and Section 5.1.3 should be revised to identify the dominant beta-gamma emitters.
Respons The dominant plant-related beta-gamma emitting radionuclides in contaminated soil are Co-60, Cs-137 and,in some areas, Ag 108m. Co-60 and Cs-137 are the dominant beta gamma emitters in surface contamination and Co-60 and Eu-IS2 are the primary beta-gamma emitting radionuclides in activated concrete. Appendix A, Sections 4.5.4 and 5.1.3 have been revised to inco porate this information.
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ATTACIIMENT 2 Summary Listing of Changes to YNPS License Termination Plan Section Description of Change LTP Title Page Revision number and date changed.
Table of Contents List of Page Revisions added.
2.4.3 Typographical error corrected.
2.6 Typographical error corrected.
3.2 Typographical error ccrrected.
App'ndix A, Revision number and date changed.
FSSP Title Page Appendix A, Page numbers changed to reflect revised sections of the Final Status Table of Contents Survey Plan.
Appendix A, Added statement that release criteria comply with 10 CFR 20.1401(b).
Exec. Summary Also deleted wording referring to the Final Status Survey Plan as
" administrative guidance"in order to clarify its status as a supplement to the FSAR.
Appendix A, Fig.
Added survey at _ in Sherman Pond to include sediment impacted by 2.3 licensed discharges. Also corrected classincation of one shoreline area to reflect current status based on site characterization data.
Appendix A 3.1 Added statement that release criteria comply with 10 CFR 20.1401(b).
Appendix A,3.2 Revised to include sediment impacted by licensed discharges in final status surveys.
Appendix A,3.3.1 Revised to identify dominant beta gamma emitters.
Appendix A,3.3.2 Revised to identify dominant beta-gamma emitters.
Appendix A,3.4.2 Revised to state that guideline values for so:i, sediment, and bulk materials will be conservatively detennined from RESRAD, D&D Screen, or NUREG-1500.
Appendix A,3.5
" Yankee personnel" changed to " Duke Engineering & Services personnel" to reflect sale of YNSD to Duke Engineering & Services (DE&S).
Appendix A,3.6
" Yankee Atomic Environmental Laboratory" changed to " Duke Engineering & Services Environmental Laboratory" to reflect sale of YNSD to DE&S.
l Susunary Listing of Changes to YNPS License Termination Plan (Continued)
Section Description of Change Appendix A,3.6.7
" Yankee Atomic's Quality Services Group" changed to " Duke Engineering & Services Quality Assurance Services" to reflect sale of YNSD to DE&S.
Appendix A,3.8
" Yankee Atomic Environmental Laboratory" changed to " Duke Engineering & Services Enviromnental Laboratory" to reflect sale of YNSD to DE&S.
Appendix A,3.9 Typographical error corrected.
Appendix A,4.1.7 Typographical error corrected.
Appendix A,4.2 Added survey area in Sherman Pond to include sediment impacted by licensed discharges.
Appendix A,4.3 Reference added to final status survey procedures for documenting measurement locations.
Appendix A,4.3.3 Clarification made regarding frequency of water sampling (r, ingle sample at time of final status survey).
Appendix A,4.4.4 Clarification made regarding frequency of water sampling. Also revised to state what contaminants soil and water samples will be analyzed for, Appendix A,4.5.4 Reference made to Section 3.3 for identification of dominant beta-gamma emitters.
Appendix A,4.6.3
" Yankee Atomic Environmental Laboratory" chs.nged to " Duke Engineering & Services Erwironmental Labora:ory" to reflect sale of YNSD to DE&S.
Appendix A,5.1.3 Reference made to Section 3.3 for identification of dominant beta-gamma emitters.
Appendix A, Wording errors corrected to clarify reclassification and remediation action Table 5.1 level criteria for soil and bulk materials.
Appendix A,6.3 Revised to state that final TEDE evaluation using RESRAD or D&D Screen shall be performed in accordance with applicable NRC guidance.
Also, reference to 10 CFR 20.1401(d)is added.
Appendix A,7.1 Added references to D&D Screen and NUREG-5512.
e ATTACHMENT 3 Administrative Instructions for Updating the YNPS License Termination Plan Section Instructions Cover Page Insert revised Cover Page.
Discard current Cover Page.
Table of Contents Insert revised pages y through sii.
Discard current page v.
Section 2 Insert revised pages 2-3,2-4, and 2-9.
Discard current pages 2-3,2-4, and 2-9.
Section 3 Insert revised pages 3-1 and 3-2.
Discard current pages 31 and 3-2.
Appendix A Insert revised pages A-1 through A-vil.
Insed revised pages A-1 through A-55.
Discard current pcges A-i through A-vii.
Discard current pages A-1 through A-56, 1
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