ML20211C059

Forwards Addl Justification for Proprietary Request Re 990809 Submittal Info on Maine Yankee License Termination Plan

ML20211C059
Person / Time
Site:	Maine Yankee
Issue date:	08/19/1999
From:	Zinke G Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GAZ-99-28, MN-99-27, NUDOCS 9908250150
Download: ML20211C059 (2)

Text

y .

MaineYankee 321 OLD FERRY RD.

• WISCASSET. ME 04578-4922

, . August 19,1999 MN-99-27 GAZ-99-28 i

UNITED STATES NIJCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) MYAPC Letter to USNRC "Information on Maine Yankee's License Tennination Plan (MYLTP), dated August 9,1999 (MN-99-26)

Subject:

Additional Justification for Proprietary Request Gentlemen:

In Reference (b), Maine Yankee submitted a ground water dose assessment description and dose model code input / output files as proprietary documents pursuant to 10 CFR 2.790. These documents contain information of considerable commercial interest to Radiological Services Incorporated.

Attached is additionaljustification for the proprietary request.

If you have any questions, please contact me at 207-882-5824.

Very truly yours,

)

/

4 / /

v .f. << f t George A. Zinke, Director Nuclear Safety & Regulatory Affairs Department  !

Attachment

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c: Mr. H. J. Miller, NRC Regional Administrator, Region I Mr. C. J. Paperiello, NRC Director, Office of Nuclear Material Safety and Safeguards  ;

Mr. M. K. Webb, NRR Project Manager Mr. J. T. Greeves, Director, Division of Waste Management I,

Mr. M. C. Roberts, NRC Region I Mr. C.L. Pittiglio, NMSS Project Manager, Decommissioning i Mr. M.T. Masnik, Section Chief, Project Directorate IV & Decommissioning \

Mr. P. J. Dostie, State of Maine, Division of Health Engineering g\

Mr. U. Vanags, State of Maine, Nuclear Safety Advisior ..O Mr. D. Rothstein, USEPA Region 1, Office of Regional Counsel i 9908250150 990019 PDR ADOCK 05000309 u PDR

s Attachment Justification for Proprietary Reauest for Submittals Related to the Dose Assessment Methods for Concrete 10 CFR 20 Subpart E requires decommissioning facilities requesting release for unrestricted use to demonstrate that the dose from any residual contamination remaining on the site is less than 25 mrem /yr. The NRC staffissued guidance documents for implementing the 25 mrem /yr criteria in Draft Regulatory Guide DG-4006, " Demonstrating Compliance with the Radiological Criteria for License Temiination" and NUREG-1549, "Using Decision Methods for Dose Assessment to Comply with Radiological Criteria for License Termination."

The two guidance documents, DG-4006 and NUREG-1549, address the dose assessment for l contamination in soil and buildings to remain standing. However, certain decommissioning nuclear power reactor facilities have evaluated demolition of onsite buildings as a decommissioning I approach.

The NRC DandD, Version 1, screening model and the RESRAD pathway analysis / dose assessment code are recommended in the NRC guidance. These codes were evaluated to determine if they were l applicable for modeling the dose from concrete rubble. There are three major reasons why these codes are not applicable to concrete. First, a major factor affecting the leach rate from concrete is diffusion. Neither code has a diffusion component. Second, the geometry of the residua' contamination in the concrete is a 1 cm layer on the surface, with the concrete rubble uniformly mixed in a subsurface volume. This geometry is different from the assumption of a uniform mixture in the two codes. The third reason is that the models are specifically designed for soil contamination, not concrete, and a number of the parameters are not applicable to concrete. Since the DandD and RESRAD models are not appropriate for estimating leach rate from concrete, mMels specifically designed for this purpose were used.

RSI has developed a unique approach for performing dose assessments for concrete rubble based on a specialized use of a modeling code which has never been used for this purpose. In addition, RSI ,

I has performed extensive literature review to justify the input parameters that can be used for this specialized application. The methods developed to date for concrete rubble dose assessment have potentially widespread application in the power reactor decommissioning industry. These tools would not be available for demonstrating compliance with 10 CFR 20 Subpart E without RSI's development effort to provide a unique combination of several disparate sources ofinformation.

This method could have a significant economic benefit to RSI and the public release of such information may cause substantial harm to the competitive position of RSI related to providing dose assessment services to the nuclear industry.

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