RA-05-012, Maine Yankee'S License Termination Plan
| ML050940373 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/28/2005 |
| From: | Meisner M Maine Yankee Atomic Power Co |
| To: | Document Control Desk, NRC/FSME |
| References | |
| MN-05-010, RA-05-012 | |
| Download: ML050940373 (15) | |
Text
Maine Yankee 321 OLD FERRY RD.
- WISCASSET, ME 04578-4922 February 28, 2005 MN-05-010 RA-05-012 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555
References:
(1) License No. DPR-36 (Docket No. 50-309)
(2) MYAPC Letter to USNRC, MN-00-004, dated January 13, 2000, Maine Yankee License Termination Plan (3) MYAPC Letter to USNRC, MN-01-023, dated June 1, 2001, Revision 1, Maine Yankee's License Termination-Plan (4) MYAPC Letter to USNRC, MN-01-032, dated August 13, 2001, Revision 2, Maine Yankee's License Termination Plan (5) MYAPC Letter to USNRC, MN-02-048, dated October 15, 2002, Revision 3, Maine Yankee's License Termination Plan (6) NRC Letter to MYAPC dated February 28, 2003, Issuance of Amendment No. 168 to Facility Operating License No. DPR Maine Yankee Atomic Power Station (TAC No. M8000)
Subject:
Revision 4, Maine Yankee's License Termination Plan In accordance with 10 CFR 50.71 (e), Maine Yankee (MY) hereby submits an update to the License Termination Plan (LTP). The updated LTP (Revision 4) continues to demonstrate that the remainder of decommissioning activities: (1) will be performed in accordance with Title 10 Code of Federal Regulations, (2) will not be inimical to the common defense and security or to the health and safety of the public, and (3) will not have a significant effect on the quality of the environment.
This 10 CFR 50.71 (e) update' contains changes necessary to reflect current information2 and analyses, including NRC approved addenda to LTP Revision 3, approved license amendments, and changes made in accordance with 10 CFR 50.59. The LTP revision history and the update approach to Revision 4 are discussed further below. Attachment 1 provides a summary listing of the key LTP Revision 4 changes. Attachment 2 provides a List of Effective Sections and Attachments (Only those Sections and Attachments requiring update are reflected as "Revision 4". The Sections and Attachments requiring no update remain labeled as "Revision 3"). provides the complete, updated LTP via CD-ROM. Changes are identified by right margin revision bars.
Also in accordance with LTP Section 1.1 and 1.4.
2 Note that Section 3 of the LTP has not been updated to reflect the current status of dismantlement activities.
Dismantlement status is being provided via the Final Status Survey (FSS) Reports that are submitted to the NRC for review.
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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Page 2 Maine Yankee LTP Revision History Reference 2 transmitted the initial Maine Yankee LTP for NRC review and approval. Reference 3 transmitted LTP Revision 1 and reflected changes in the approach for decommissioning and revised criteria for completion of decommissioning activities. LTP Revision I also incorporated MY responses to comments and questions from the State of Maine, Friends of the Coast, and the NRC. Reference 4 transmitted LTP Revision 2 which incorporated additional changes resulting from on-going stakeholder interface, as well as internal MY LTP review and refinement.
Reference 5 transmitted LTP Revision 3 which incorporated additional changes addressing NRC Requests for Additional Information (RAI), and other decommissioning updates. Reference 6 provided the NRC SER on LTP Revision 3, and incorporated the NRC approved LTP Revision 3 and associated LTP addenda correspondence' into the MY license.
LTP Revision 4 Update Approach The LTP is part of the FSAR per 10 CFR 50.82 and therefore the 10 CFR 50.71(e) update rule applies. However, the LTP has certain attributes that make it somewhat different from the FSAR and therefore the update rule is applied in a slightly different manner. First, the LTP is inherently a plan and as such is subject to change. The LTP approval process established the special criteria under which the LTP is changed, identifying which changes require prior NRC notification and/or approval. The second element of the decommissioning licensing process that differs from the FSAR is that the fulfillment of the plan is described in additional submittals to the NRC staff in the form of FSS reports (see footnote 2). These reports describe the final implementation of demolition activities and the approach and results of the final status survey, survey unit by survey unit. As such, updates to the plan, following 10 CFR 50.71(e), include those changes to the plan that: (1) have been submitted to the NRC for review and approval or (2) evaluated and implemented under 10 CFR 50.59 and the special criteria related to changes in the LTP.
Revision 4 also includes another category of changes, namely those submitted to the NRC (after Revision 3 was submitted) during the final stages of the review process. These are referred to as Revision 3 Addenda (see footnote 3). The NRC, in approving the LTP, recognized the approved LTP as Revision 3, including the addenda. Thus, Revision 4 simply incorporates the Revision 3 Addenda changes.
3 Three addenda letters were submitted to the NRC: (1) MN-02-058, LTP Revision 3 Addenda dated November 21, 2002 - Clarifications and Minor Corrections to Maine Yankee License Termination Plan Revision 3; (2)
MN-02-061, dated November 26, 2002, Maine Yankee License Termination Plan, Rev. 3 Addenda and Additional Information Related to the Eberline Model E600 Instrument; (3) MN-02-063, dated December 12, 2002, Update on Forebay Dike Coring Results and Associated Changes to LTP Attachment 2H (LTP Revision 3 Addenda).
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Page 3 Finally, it should be understood that Revision 4 does not reflect the current status of plan implementation. That is the role of the FSS Reports.
The following is a description of the change rationale and content, on a section-by-section basis:
Chapter 1 - Changes were primarily to reflect LTP correspondence and revision history.
Chapter 2 - Characterization information was revised, under 10 CFR 50.59, if later remediation, sampling and surveys revealed significant and material changes to site characterization.
.Chapter 3 - Information was updated, under 10 CFR 50.59, only if significant and material changes were made to the decommissioning approach for a survey area.
Chapter 4 - No update review was considered warranted for ALARA related analyses. The only change to this section is related to License Amendment 170.
Chapters 5 and 6 - Changes were primarily due to LTP Revision 3 Addenda, changes related to License Amendment 170, and changes implemented under 10 CFR 50.59.
Chapters 7 and 9 - No changes were considered appropriate for Chapters 7 and 9.
Chapter 8 - The only change to this section is related to the Forebay Remediation Plan as approved by Maine Department of Environmental Protection.
If you have any questions, please contact us.
resident and Chief Nuclear Officer Attachments
- 1. Listing of Key Changes - LTP Revision 4
- 2. List of Effective Sections and Attachments - LTP Revision 4
- 3. License Termination Plan, Revision 4 (CD-ROM) cc: Dr. R. R. Bellamy, NRC Region I Mr. D. R. Lewis, Esq., Shaw Pittman Mr. C. Pray, State of Maine, Nuclear Safety Advisor Mr. P. J. Dostie, State of Maine, Division of Health Engineering Mr. L. Camper, Director, Division of Waste Management Mr. M. Rosenstein, USEPA Region I Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. J. Buckley, NRC NMSS Project Manager, Decommissioning Mr. M. Roberts, NRC Region I Mr. R. Shadis, Friends of the Coast
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Page 4 STATE OF MAINE Then personally appeared before me, Michael J. Meisner, who being duly sworn did state that he is the Vice President and Chief Nuclear Officer of Maine Yankee Atomic Power Company, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Maine Yankee Atomic Power Company, and that the statements therein are true to the best of his knowledge and belief.
Notary Public VDONN L. PELLEIER
. I
Attachment I Listing of Key Changes - LTP Revision 4 LTP Section LTP Section Title Source of LTP Change4 1.2 and 1.7 "Operating and Decommissioning History" MY and NRC correspondence submitting and approving LTP and "References" Revision 3 and associated Addenda 1.6 & Preface Maine Yankee LTP Information Contact Updated contact information 2.5.3.b Activated Concrete / Rebar Decrease soil DCGL inside RA to 2.39 pCi/g and use building specific surface area to volume ratio for containment (resulting from License Amendment 170) 2.5.3.d Nuclide Profile - Groundwater and Surface LTP Revision 3 Addenda dated November 21, 2002 -
Water Clarifications and Minor Corrections to Maine Yankee License Termination Plan Revision 3 (HSA, background, groundwater, and miscellaneous) (MN-02-058) 2.7 References (2.7.24 & 2.7.25) LTP Revision 3 Addenda dated November 21, 2002 -
Clarifications and Minor Corrections to Maine Yankee License Termination Plan Revision 3 (HSA, background, groundwater, and miscellaneous) (MN-02-058) 2.7 References (2.7.26) LTP Revision 3 Addenda dated December 12, 2002, Update of Forebay Dike Coring Results and Associated Changes to LTP Attachment 2H (LTP Revision 3 Addenda) (MN 063) A.3 Non-Impacted Area Assessment - Historical LTP Revision 3 Addenda dated November 21, 2002 -
Site Assessment Clarifications and Minor Corrections to Maine Yankee License Termination Plan Revision 3 (HSA, background, groundwater, and miscellaneous) (MN-02-058) 4 All changes were made either (1) as a result of prior NRC approval (noted as "License Amendment" or "LTP Revision 3 Addenda") or (2) under the provision of 10 CFR 50.59 (all other changes.)
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Attachment 1 LTP Section LTP Section Title Source of LTP Change' B Radiological Characterization Water Sample LTP Revision 3 Addenda dated November 21, 2002 -
Table 2B-8 Results for Affected and Unaffected Clarifications and Minor Corrections to Maine Yankee Environs, Including Environs Background License Termination Plan Revision 3 (HSA, background, Study groundwater, and miscellaneous) (MN-02-058) F - Analysis of Concrete Sample Variance Maine Yankee Letter MN-03-023, May, 6, 2003,"Maine Page 5,6 Yankee Comments on NRC's Safety Evaluation on the Maine Yankee License Termination Plan." Comment 11 -
Clarification of the second evaluation of the individual core data set. H Forebay and Diffuser Characterization LTP Revision 3 Addenda dated December 12, 2002, Update Discussion of Forebay Dike Coring Results and Associated Changes to LTP Attachment 2H (LTP Revision 3 Addenda) (MN 063) 3.1.3 Introduction - Decontamination & Free release process of PMP 6.0.22 summarized in LTP Dismantlement Process Summary Section 3.1.3 in accordance with ASLB Settlement Agreement No. A.3 closure discussions 3.1.3 Introduction - Decontamination & FSS Survey Area Turnover and Control (PMP 6.7.5) -
Dismantlement Process Summary Clarifies requirements for confinnatory measurements on the surface of soil fill material after super structure demolition 3.2.1 Major Decommissioning Activities Update on completed activities 4.2.1 Remediation Actions / Structures Decrease soil DCGL inside RA to 2.39 pCi/g and use building specific surface area to volume ratio for containment (resulting from License Amendment 170 - Realistic Release Rates for Activated Concrete) 4.2.1 Structures Remediation Surveys - Structural Concrete Gamma Scans C Remediation Surveys - Gamma Scans description 4.4.3.b Remediation Methods and Cost / Structure Decrease soil DCGL inside RA to 2.39 pCi/g and use Activated Concrete building specific surface area to volume ratio for containment (resulting from License Amendment 170 - Realistic Release Rates for Activated Concrete)
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Attachment 1 LTP Section LTP Section Title Source of LTP Change4 5.1.2.a Introduction - Overview - Survey Preparation FSS Survey Area Turnover and Control (PMP 6.7.5) -
Turnover surveys made optional and equipment staging in survey areas revised to address loose contamination on external surfaces (PMP 6.7.5) 5.2.3 Initial Classification of Basements, Land, Maine Yankee letter to NRC dated May 13, 2004, Table Embedded Piping and Buried Piping Reassessment of Area Classification of Containment 5-1E Table 5-1E Survey Area Classification - Foundation Drains from Class 1 to Class 2 and Revision of Embedded and Buried Pipe FSS Requirements 5.3.1.a Table 5-2 Establishing Survey Units - Survey Unit - Decrease soil DCGL inside RA to 2.39 pCi/g and use Survey Unit Size - Table 5-2 building specific surface area to volume ratio for containment (resulting from Amendment 170) 5.4.3 & 5.12.35 Background Reference Areas Added reference to Background White Paper per NRC staff recommendation 5.5.1 and "Survey Measurement Methods" and Maine Yankee Letter to NRC, MN-03-051, dated September 5.12.37 and "References" 3, 2003, "Technical Basis Document for NRC Review -
5.12.38 Forebay FSS Survey Measurement Methods (In-Situ Gamma Spectroscopy) - 30 Day Notice per LTP Requirement" and Maine Yankee Letter to NRC, MN-03-067, dated October 21, 2003, "Maine Yankee Response to NRC and State of Maine Comments on the Teclmical Basis Document for NRC Review - Forebay FSS Survey Measurement Methods (In-Situ Gamma Spectroscopy)"
5.5. 1.a Survey Methods and Instrumentation - Use of SPA-3 Gamma Detector for Concrete FSS Scans to Survey Measurement Methods - Structures Reduce the amount of smoothing needed during Concrete Remediation (PMP 6.7.1) 5.5.1.a Survey Methods and Instrumentation Decrease soil DCGL inside RA to 2.39 pCi/g and use Survey Measurement Methods - Structures - building specific surface area to volume ratio for containment Concrete with Activated Radionuclides (resulting from License Amendment 170 - Realistic Release Rates for Activated Concrete)
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Attachment I LTP Section LTP Section Title - Source of LTP Change 4 5.5.1 .d Survey Methods and Instrumentation - Add method for surveying & reusing class I & 2 stored Survey Measurement Methods - Specific excavated soil Areas and Conditions 5.5.2.d Instrumentation - Minimum Detectable LTP Revision 3 Addenda dated November 26, 2002, Maine Concentration - Open Land Area and Yankee License Termination Plan, Rev. 3 Addenda and Structure Scan MDC Using Alarm Set Point Additional Information Related to the Eberline Model E600 Instrument (MN-02-061) 5.5.2.d Instrumentation - Minimum Detectable Revised Report on Eberline Model E-600 Field Testing (MN-Concentration - Open Land Area and 03-009) - Maine Yankee Response to SOM Comment No..
Structure Scan MDC Using Alarm Set Point - B.5 Maximum scan grid size of 10 in2 .
5.12.36 Reference MN-03-009 Revised Report on Eberline Model E-600 Field Testing (MN-03-009) - Maine Yankee Response to SOM Comment No.
B.5 5.5.2.d Instrumentation - Minimum Detectable Use of SPA-3 Gamma Detector for Concrete FSS Scans to Concentration - Open Land Area and Reduce the amount of smoothing needed during Concrete Structure Scan MDC Using Alarm Set Point Remediation (PMP 6.7.1)
Table 5-5 and "Survey Instrument Efficiencies" and Updated with current FSS instrument efficiencies Table 5-6 "Measurement Detection Sensitivities" 5.5.2.e Table Instrumentation - Detection Sensitivities LTP Revision 3 Addenda dated November 26, 2002, Maine 5-6 Yankee License Termination Plan, Rev. 3 Addenda and Additional Information Related to the Eberline Model E600 Instrument (MN-02-061) 5.5.2.e Table Instrumentation - Detection Sensitivity - Use of SPA-3 Gamma Detector for Concrete FSS Scans to 5-6 Table 5-6 Reduce the amount of smoothing needed during Concrete Remediation (PMP 6.7.1) 5.5.2.e Table Instrumentation - Detection Sensitivity - Decrease soil DCGL inside RA to 2.39 pCi/g and use 5-6 Table 5-6 building specific surface area to volume ratio for containment (resulting from License Amendment 170 - Realistic Release Rates for Activated Concrete)
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Attachment 1 LTP Section LTP Section Title Source of LTP Change4 5.6.1 Table Investigation Levels and Elevated Areas Test LTP Revision 3 Addenda dated November 26, 2002, Maine 5-7 - Investigation Levels Yankee License Termination Plan, Rev. 3 Addenda and Additional Information Related to the Eberline Model E600 Instrument (MN-02-061) 5.6.2 Investigation Levels and Elevated Areas Test LTP Revision 3 Addenda dated November 26, 2002, Maine
- Investigation Process Yankee License Termination Plan, Rev. 3 Addenda and Additional Information Related to the Eberline Model E600 Instrument (MN-02-061) 5.6.2 Investigation levels and Elevated Areas Test - Spray Building Survey Unit I Release Record - Clarify Investigation Process requirements for investigations 5.6.3 Investigation Levels and Elevated Areas Test LTP Revision 3 Addenda dated November 26, 2002, Maine
- Elevated Measurement Comparison (EMC) Yankee License Termination Plan, Rev. 3 Addenda and Additional Information Related to the Eberline Model E600 Instrument (MN-02-061) 5.6.3 Investigation Levels and Elevated Areas Test Evaluation of LTP Change: Elevated Measurement
- Elevated Measurement Comparison (EMC) Comparison (EMC) Unity Rule (PMP 6.7.4) 5.9.2 Reporting Format - Survey Unit Release FSS Data Processing and Reporting (PMP 6.7.8) - Minor Record reorganization of information included in release record and FSS report 5.9.3 Reporting Format - Final Status Survey FSS Data Processing and Reporting (PMP 6.7.8) - Minor Report reorganization of information included in release record and FSS report 5.10.1 .b FSS Quality Assurance Program (QAP) - FSS Survey Area Turnover and Control (PMP 6.7.5) -
Project Management and Organization - Turnover surveys made optional and equipment staging in Superintendent of Radiation Remediation survey areas revised to address loose contamination on external surfaces (PMP 6.7.5) 5.1 1.1.d Access Control Measures - Turnover FSS Survey Area Turnover and Control (PMP 6.7.5) -
Turnover surveys made optional and equipment staging in survey areas revised to address loose contamination on external surfaces (PMP 6.7.5)
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Attachment I LTP Section LTP Section Title Source of LTP Change4 5.12 References (5.12.34) Use of SPA-3 Gamma Detector for Concrete FSS Scans to Reduce the amount of smoothing needed during Concrete Remediation (PMP 6.7.1) A Embedded and Buried Piping Remaining on Maine Yankee letter to NRC dated January 26, 2005, Area Site Classification Change: Storm Drains (D3500) - Section 7 A Embedded and Buried Piping Remaining on Maine Yankee letter to NRC dated May 13, 2004, Site Reassessment of Area Classification of Containment Foundation Drains from Class 1 to Class 2 6.6.1.b Material Specific Dose Assessment Methods Decrease soil DCGL inside RA to 2.39 pCi/g and use and Unitized Dose Factors - Contaminated building specific surface area to volume ratio for containment Basement Surfaces - Mathematical Model (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) 6.6.1 .d Material Specific Dose Assessment Methods Decrease soil DCGL inside RA to 2.39 pCi/g and use and Unitized Dose Factors - Contaminated building specific surface area to volume ratio for containment Basement Surfaces - Model Input Parameters (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) 6.6.2 Activated Basement Concrete / Rebar Decrease soil DCGL inside RA to 2.39 pCi/g and use Table 6-5 building specific surface area to volume ratio for containment (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) 6.6.9 Forebay and Diffuser Elimination of unnecessary conservatism in the Forebay Table 6-1OB _ ledge and dike soil DCGLs 6.7 Material Specific DCGLs and Total Dose Decrease soil DCGL inside RA to 2.39 pCi/g and use Table 6-11 Calculation - Table 6-11 Contaminated building specific surface area to volume ratio for containment Material DCGL (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete)
Table 6-11 Table 6-1 1 Contaminated Material DCGL Deep Soil Co-60 DCGL Change - to restore the original intent of the License Termination Plan to simplify dose modeling by restricting the Deep Soil DCGL to be the same as the Surface Soil DCGL.
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Attachment 1 LTP Section LTP Section Title Source of LTP Change4 6.7.2 Activated Concrete/Rebar Decrease soil DCGL inside RA to 2.39 pCi/g and use building specific surface area to volume ratio for containment (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) 6.8.1 Area Factors: Basement Contamination Evaluation of LTP Change: Elevated Measurement Comparison (EMC) Unity Rule (PMP 6.7.4) 6.8.1 Area Factors: Basement Contamination Allows the use of either Equation 19 or 20 of LTP Section 6.8.1 for the Area Factor used in the Unity Rule for contaminated basement concrete (restricting the number of elevated areas in a survey unit).
6.8.2 Surface Soil and Deep Soil Area Factors LTP Revision 3 Addenda dated November 21, 2002 Table 6-12 Clarifications and Minor Corrections to Maine Yankee License Termination Plan Revision 3 (HSA, background, groundwater, and miscellaneous) (MN-02-058) 6.8.5 Activated Concrete/Rebar Area Factors . Decrease soil DCGL inside RA to 2.39 pCi/g and use building specific surface area to volume ratio for containment (resulting from License Amendment 170-Realistic Release Rates for Activated Concrete)
- Allows the use of either Equation 19 or 20 of LTP Section 6.8.1 for the Area Factor used in the Unity Rule for activated concrete (restricting the number of elevated areas in a survey unit).
6.10.7 References Decrease soil DCGL inside RA to 2.39 pCi/g and use 6.10.8 building specific surface area to volume ratio for containment (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) -6 Activated Concrete Inventory - Deleted Decrease soil DCGL inside RA to 2.39 pCi/g and use building specific surface area to volume ratio for containment (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete)
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Attachment I LTP Section LTP Section Title Source of LTP Change 4 -13 Attachment 6-13 DCGL/Total Dose Decrease soil DCGL inside RA to 2.39 pCi/g and use Spreadsheets building specific surface area to volume ratio for containment (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) -13 Attachment 6-13 DCGL/Total Dose Deep Soil Co-60 DCGL Change - to restore the original Spreadsheets intent of the License Termination Plan to simplify dose modeling by restricting the Deep Soil DCGL to be the same as the Surface Soil DCGL. -17 Unitized Dose Factors for Activated Rebar - Decrease soil DCGL inside RA to 2.39 pCi/g and use Deleted building specific surface area to volume ratio for containment (resulting from License Amendment 170- Realistic Release Rates for Activated Concrete) -20 Dose Model Input Parameters New attachment per ASLB Settlement Agreement No. A.8 8.2 Site Description after License Termination Maine Yankee letter to NRC dated February 24, 2003, Maine 8.9.40 Yankee Forebay Remediation Plan Approved by Maine Department of Environmental Protection (MDEP)(MN 008) - Forebay "end state" Page 8 of 8
Attachment 2 LTP Revision 4 - List of Effective Sections and Attachments Section / Attachment ReVision Number - Comments Preface 4 1 4 Attachment IA 3 2 4 Attachment 2A 4 Attachment 2B 4 Attachment 2C 3 Attachment 2D 3 Attachment 2E 3 Attachment 2F 4 Attachment 2G 3 Attachment 2H 4 Attachment 2I 3 3 4 Attachment 3A 3 4 4 Attachment 4A 3 Attachment 4B 3 Attachment 4C 4 New Attachment 5 4 Attachment SA 4 6 4 Attachment 6-1 3 Attachment 6-2 3 Attachment 6-3 3 Attachment 6-4 3 Attachment 6-5 3 Attachment 6-6 4 deleted Page 1 of 2
Attachment 2 Section / Attachment Revision Number Comments Attachment 6-7 3 Attachment 6-8 3 Attachment 6-9 3 Attachment 6-10 3 Attachment 6-11 3 Attachment 6-12 3 Attachment 6-13 4 Attachment 6-14 3 Attachment 6-15 3 Attachment 6-16 3 Attachment 6-17 4 deleted Attachment 6-18 3 Attachment 6-19 3 Attachment 6-20 4 new attachment 7 3 8 4 9 3 Page 2 of 2
Attachment 3 MAINE YANKEE LICENSE TERMINATION PLAN REVISION 4 (Enclosed CD-ROM)