RA-05-016, Response to NRC RAI on FSS Final Report No. 5

Response to NRC RAI on FSS Final Report No. 5

ML051090433
Person / Time
Site:	Maine Yankee
Issue date:	04/07/2005
From:	Meisner M Maine Yankee Atomic Power Co
To:	Document Control Desk, NRC/FSME
References
MN-05-015, RA-05-016
Download: ML051090433 (33)

Text

Maine Yankee 321 OLD FERRY RD.

• WISCASSET. ME 04578-4922 April 7, 2005 MN-05-015 RA-05-016 Proposed Change No. 218, Supplement 17 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555

References:

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

(2) Maine Yankee Letter to USNRC, MN-04-020, dated March 15, 2004, License Amendment Request: Release of Non-ISFSI Site Land, Proposed Change No. 218 (3) Maine Yankee Letter to USNRC, MN-04-59, dated December 7, 2004, Release of Non-ISFSI Site Land - FSS Final Report No. 5 (4) USNRC Letter to Maine Yankee, dated March 18, 2005 Request for Additional Information (RAI) Regarding Final Status Survey (FSS)

Supplement No. 5.

Subject:

Response to NRC RAI on FSS Final Rcport No. 5 On March 15, 2004, Maine Yankee submitted a request for amendment (Reference No. 2) to the facility operating license (Reference No. 1) pursuant to 10 CFR 50.90 and in accordance with the NRC Approved License Termination Plan (LTP) for Maine Yankee, to indicate NRC's approval of the release of the Non-ISFSI site land from the jurisdiction of the license. In support of that request, Maine Yankee supplied the information required in LTP section 1.4.2 and 5.9.3. The land area associated with the license amendment request included the entire non-ISFSI portion of the site land. The dismantlement and survey information for the survey units is being submitted to the NRC in FSS Final Reports.

In Reference No. 3, Maine Yankee submitted FSS Final Report No. 5. In Reference No. 4, USNRC requested additional information on technical information submitted in FSS Final Report No 5. This additional information is provided in an attachment to this letter.

If you have any questions, please contact me.

& Chief Nuclear Officer 1 M55bI

UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Page 2 of 2

Attachment:

Maine Yankee Response to NRC Request for Additional Information (RAI)

Regarding Final Status Survey (FSS) Final Report No. 5 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. D. Gillen, NRC Acting 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

Maine Yankee Rcsponsc to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report No. 5 NRC RAI on FSS Report No. 5 - RAI No. 1 -

FSS - Release RecordFA-0100 Survey Unit 2 is a Class 1 area. LTP Section 5.4.1 requiresthe performance of 100% Scan Surveyfor Class I areas in accordancewith MARSSIM. In addition, LTP Section 5.5.1 (a & d) requiresampling or surveys to determine contaminationat depth.

During the May 24-2 7 site inspection, the staffobserved large deep holes in the floors principallynear the pedestals, ihere the flow-able concrete placedduring originalplant construction left voids. In addition, the staff noted that in some areas the metal liner was missing and the floor was bare concrete. The holes in the floor are not mentioned in the release recordnor is survey informationprovided that specifically correspondsto these configuration anomolies. Pleaseprovide survey data to demonstrate these areasuvere scanned to comply with the 100% scan requirement.

In addition, the staff observed significant quantities of water on the containmentfloor which requireda significant effort by Maine Yankee to dry priorto performing FSS s offloor surfaces.

Given the influx of water onto the containmentfloor and observing the water under the steel liner, the potentialformigrationof contaminationexisted. Pleaseprovide (gamma) surveys of the areas(either in conjunction with the FSS orfrom the Remediation Phase) that demonstrate that no significant contaminationat depth was present under the metal liner.

Maine Yankee Response: Holes were made in the steel liner as a consequence of the removal of all concrete from the Containment floors down to the liner. The holes were not a pre-existing condition. In order to ensure that the underlying concrete did not become contaminated to significant levels, the exposed area beneath the liner was checked. The larger holes were surveyed by SPA-3 and 43-68 for signs of elevated activity. Concrete samples were taken and analyzed using the same criteria as previous sub-surface samples. Results of 74 floor and sub-liner SPA-3 measurements were all less than 30,000 c/m. The concrete samples were all less than the 37 pCi/g criteria for 1 cm depth of concrete (the maximum value was 19.2 pCi/g).

These survey results demonstrate that no significant contamination at depth is present under the metal liner.

Attached (Appendix A) are the gamma scan results of the Containment Building liner holes.

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Maine Yankee Rcsponsc to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report No. 5 NRC RAI on FSS Report No. 5 - RAI No. 2 -

In FA-01 00 SU-4, Table 2, Sample Location I5 has a negative value of-580 cpm equating to -

1395 dpm/J 00 cm2 . This measurement appears to be excessively negative and does not appearto be a valid sample measurement within the data set presented. Pleasejustify the quality of the sample measurementand validity ofthe measurement within the dataset.

Maine Yankee Response:

While the measurement at Sample Location 15 appears to be excessively negative, it is within 2 sigma (501 cpm) of the mean value of 398 cpm. All 21 measurements were taken with the same 43-68 detector and E-600 instrument. The detector and E-600 used in the survey were properly calibrated and source checked prior to performing the survey. Both were satisfactorily checked following the survey. There were no problem reports issued for the instrument at the time of the direct measurement survey.

Survey location MO15 was located on the south wall of the access tunnel to the ICI Sump area.

The direct measurement location was near the opening of the tunnel into the ICI Sump. Since the location was near the opening, it was exposed to higher neutron fluence rates than portions of the vertical shaft further away from the opening such as MO I1 and M012 but less than those located in the ICI Sump wall such as M018 through M021. The complex geometry of the ICI Sump resulted in variations in the ambient radiation levels.

The mean and standard deviation of the 21 FSS direct measurements was 957 dpm/l OOcm 2 and 1,205 dpm/100cm2 , respectively. If sample measurement, M015, were removed from the data set, the mean and standard deviation would be: 1075 dpmlOOcm2 and 1106 dpm/lOOcm 2 respectively, resulting in an actual relative shift of 15.3, which when adjusted to 3.0 would result in a required number of samples of 14. Therefore, the survey unit would have passed with sufficient statistical power even if sample measurement, MO15, were removed from the data set.

NRC RAI on FSS Report No. 5 - RAI No. 3 On October 14, 2004, Maine Yankee submitted an addendum to FSS Supplement 1. In this addendum, Table 2A, information is provided on howv and where variousfeatures not included in the scope of FSS Supplement I will be dispositioned. Table 2A indicatesthat a nwmber of penetrationsfrom the Spray Building uvill be surveyed iwith the survey unitsfrom Supplement 5.

Specifically based on our review of Supplement 5, the staff wvas not able to verify the following:

• Survey of 10 inch penetrationfrom FA-l 700 SU3 in FA-0100 SU5.

• Survey of l0 inchpenetrationfromFA-l 700 SU4 in FA-0100 SU5.

• Survey of 2 inch penetrationfromFA-I 700 SU5 in FA-0100 SU5

• Surveys of the 5 penetrationsthru the south wall (from FA 1700 SU2) and the 5 penetrations thru south wall (from FA-I 700 SU8). Table 2A indicates that these penetrations will be surveyed aspart of alleyway east-west excavations (FR-0J 10 SU3).

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Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report No. 5 Based on information in Supplement 5, alleysway east-west excavations are included in FR-OJlO, not FR-Oil I(identifiedas soil remediationsurvey unit areas). Further,these I Openetrationsdo not appearto be included in the east-wsest excavations FR-OIl] SU3.

Pleaseprovide survey datafor the above referencedpenetrations.

Maine Yankee Response:

Provided below are the specific references to the FSS survey documentation where each of these penetrations is covered.

• Survey of 10 inch penetrationfrom FA-I 700 SU3 in FA-O100 SU5 - This penetration was designated M008 on Map FA 0100-U5-SCANS in survey package FA-0100-05.

• Survey of I 0 inch penetrationfrom FA-1 700 SU4 in FA-OJ1O0 SU5. - This penetration was designated C007 on Map FA 0100-U5-SCANS in survey package FA-0100-05. The penetration was core bored and removed during the remediation process. The resulting hole was a 24" concrete penetration hence the "C" designation.

• Slurvey of2 inch penetrationfrom FA-I 700 SU5 in FA-010 SU5 - This penetration was designated C005 on Map FA 0100-U5-SCANS in survey package FA-0100-05. The penetration was core bored and removed during the remediation process. The resulting hole was an 8" concrete penetration hence the "C" designation.

• Surveys of the 5 penetrationsthru the south wall (from FA 1700 SU2) - Except for two 14" PCC penetrations, all pipe sleeves were removed from the wall. The opening, surrounding concrete, and PCC penetrations were surveyed in Survey Package FRO I11-

03. This survey package also contains Map FROI 1IU3-04 which shows the remaining PCC penetrations as POOl and P002. Additional information of the removed penetrations was provided in Reference No 22.

• and the 5penetrations thri south wvall (from FA-J 700 SU8). - Except for two 14" SCC penetrations, all pipe sleeves were removed from the wall. The opening, surrounding concrete, and SCC penetrations surveyed in survey package FROI 11-03. This survey package also contains Map FROI1 I U3-04 which shows the remaining SCC penetrations as P003 and P004. Additional information on the removed penetrations was provided in Reference No. 22.

• Table 2A indicates that these penetrations vill be surveyed as part of alleyway east-west excavations (FR-OJIO SU3). Based on information in Supplement 5, alleyway east-west excavations are included in FR-Oil0, not FR-Oil (identified as soil remediation sunrey unit areas). Further,these I Openetrationsdo not appearto be included in the east-west excavations FR-Oil] SU3. - As indicated above, these penetrations were surveyed as part of the Yard West Excavation Survey Unit 3 (FR-Oi II SU 3).

In Appendix B, Maine Yankee is providing an update to Table 2A of Reference No. 12. In this update, each penetration which was covered by FA-0I 00 and FRO 111 survey unit release records are specifically identified. Note that the 10" penetration (SU-7 through north (containment) wall) does not exist and has been corrected.

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Maine Yankce Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report No. 5 NRC RAI on FSS Report No. 5 - RAI No. 4 The FSS designfor these four survey units is basedon the assumption that the soil nuclide fractionsfor Cs-137 and Co-60 are 0.890 and 0.009, respectively, asprovidedin Section 2.5.3, "Nluclide Profile," Table 2-11, of the LTP. Consistent with the profile, Table 2-2 of FSS-RR for FR-0110 Survey Units 1-4, lists the scan MDC as 5.9 pCi/gfor Cs-137 (per LTP Table 5.6).

Informationpresented in the FSS-RRs suggests that significantlymore Co-60 may be present in the soil than was anticipated It is not clearfrom the FSS-RR that the FSS design adequately consideredthe potentialfor Co-60 and other contaminants in the soil. Therefore, it is not clear that appropriatemeasurements were performedto demonstrate compliance with requirements.

Basis:

Section B of the FSS-RR for FR-01 0 Survey Units 1-4 states that the soil silrVey unit was suspended in late 2002 and resumedduring the spring of2003. At this time, "it wtas determined that radioactivityhad migrated into the remainingsoilfrom the open, abandonedpipes in the excavation." The nuclide profilefor contaminants in the abandonedpipe is not addressedin the FSS-RRs. However, FSS-RR Table 2, "Direct Measurements" data (see summary table belowt) indicates that the ratioof Co-60 to Cs-137 is approximately 1 for Survey Units 1-4. This ratio indicates that the Co-60fractionalactivityfor Survey Units 1-4 is higher that the 0.009 listed in LTP Table 2-11.

FR-0110 Co-60 Table 2 Cs-137 Table 2 Ratio Survey Unit Mean pCi/g Mean pCi/g Cobalt:Cesium 1 0.251 0.259 0.97 2 0.149 0.119 1.25 3 0.267 0.282 0.95 4 0.18 0.38 0.47 Average 0.21 0.26 0.81 LTP Table 2.8, "Nuclide Fractionsfor ContaminatedConcrete Surfaces SpecialAreas, " which includes PAB pipe tunnel, identifiesfractionsfor Co-60 and Cs-13 7 as 0.368 and 0.289, respectivelylwhich results in a ratioof approximately 1. The FSS-RR data appearsto be more consistent with the nuclidefractionsin LTP Table 2.8.

As noted in the FSS-RRs Table 1, "Survey Unit Design Parameters," the survey design is based on a DCGLfor Cs-13 7. A scan MDC of 5.9 pCi/gfor Cs-13 7, from LTP Table 5-6, is listed in FSS-RR Table 2-2 as being ttilizedfor FR-01O0 Survey Units 1-4. The 5.9 pCi/g scan MDC exceeds the DCGL_,~(for Co-60 shown in Table 2-2 as 3.3, 5.2, 5.8, 3.3 pCi/gfor Survey Units 1-4, respectively A scan MDCfor Co-60 is not provided.

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Maine Yankee Response to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report No. 5 In addition, the use of the scan MDC basedsolely on Cs-]37 is non-conservative. According to NUREG 1507, Table 6.4, the scan MDCfor Co-60 should be approximatelyti'ice the scan MDC for Cs-137, given that the efficiency of the SPA-3 detector is less than halffor the higher energy Co-60 ganmma energies. In NUREG-1507, a 2 in. X2 in. Mal` detector 's responsefor Co-60 is 430 cmp per microR/hr versus 900 cpm microR/hrfor Cs-137.

Pleasejustify the designfor these survey units and the adequacy of the measurementsperformed Maine Yankee Response:

The FSS sampling design for the FROl 10 survey units was based upon Cs-137, which is the predominant nuclide in the contaminated soil at Maine Yankee. As stated in LTP Section 5.8.1, "the Cs-137 to Co-60 ratio will vary in the final survey soil samples, and this will be accounted for using a "unity rule" approach as described in NUREG 1505 Chapter 11."

The survey design was based on a range of Cs-137 design DCGLEMC (a priori)values from 6.5 pCi/g to 16.3 pCi/g depending on the layout of the direct points and a scan MDC value of 5.9 pCi/g for Cs-137 as described in section 5.5.2 of the LTP. If the FSS sampling design was based upon the Co-60 DCGL (0.86 pCi/g), the range of Co-60 design DCGLEMC (apriori) values would be from 3.3 pCi/g to 5.8 pCi/g, for the sample area (the area between the sample points). The survey results are adequate to demonstrate that the survey units meet the release criterion based upon the following:

1. A total of 196 individual soil samples were taken in the four survey units including the investigation samples. Out of these 196 samples, only 6 showed as-left activity greater than the Co-60 DCGL with a maximum activity of 1.07 pCi/g. None of these results were greater than 50% of the lowest Co-60 design DCGLEMC (apriorl)of 3.3 pCi/g.

2. A significant portion of the survey unit's area was investigated. Of the 109 scan grids located in the survey units, 59 or 54%, were investigated. Only five of the grids had as-left activity above the DCGL.

3. As indicated in the LTP, the design basis hot spot is 2 m2 . Table 6-12 of the LTP shows that the Co-60 area factor for a contaminated soil area of 2 m2 is 7.2. This results in a DCGLEMC of 6.2 pCi/g for Co-60 which is greater than the scan MDC of 5.9 pCi/g (for Cs-137) given in the LTP. NUREG-1757, Vol.2, Appendix A.7.6 identifies circumstances where design elevated area (apriori) may be set at less than the area between the sample points based upon an estimate of the area likely to have elevated concentrations, similar to the design basis hot spot described in Maine Yankee LTP Section 5.5.2.d.

4. The four soil survey units in FROl 10 covered a total of 513 m2 . If this total area were divided by the total number of soil samples, the resulted sample frequency would be an average of one sample being taken per 2.6 m2 (an area slightly larger than the design hot Page 5

Maine Yankee Response to NRC Request for Additional Information (RAT) Regarding Final Status Survey (FSS) Final Report No. 5 spot). A 2.6 m2 area has a corresponding Co-60 area factor of 6.4 which gives a DCGLEmC of 5.5 pCi/g for Co-60.

5. As shown in the characterization data described in the LTP, the most likely nuclide to be present in elevated areas is Cs-1 37, which was scan detectable to levels less than the design DCGLEMC (a priori).

6. The SPA-3 is capable of detecting Co-60 activity at levels consistent with the lowest Co-60 DCGLEmC (a priori)and would have easily detected Co-60 activity at the DCGLEMC for the design basis hot spot (2m2 ).

The SPA-3 scan MDC identified in NUREG 1507, Table 6.4 for Co-60 is less than half that for Cs-137. Thus, NUREG 1507 reinforces our conclusion that it is conservative to use the scan MDC established for Cs-137 for comparison to Co-60 values. The scan MDC of the SPA-3 detector was established in EC-009-01 as described in the LTP based on a Cs-137 response factor of 472 c/m per pCi/g in soil. The scan MDC is a function of the detector response factor and the background count rate which gives an alarm rate corresponding to Type 1 and Type 2 errors of 0.05. The LTP (Table 5-4a) lists an MDC for the SPA-3 of 3.2 pCi/g (later administratively raised to 5.9 pCi/g) for a 2 m2 design basis hot spot.

Maine Yankee determined the detector response factor for Co-60 in the same manner as the response to Cs-1 37 was determined, by measuring the counts per minute from a known pCi/g source of contaminated soil. Co-60 gives a detector response of 478 c/m per pCi/g in soil. As stated above, the MDC is a function of the response factor and the background count rate. Because the response factors are similar for either nuclide, the SPA-3 MDC for Co-60 is very similar and slightly lower than that for Cs-137.

7. Notwithstanding Maine Yankee's stated intent in LTP section 5.5.1.b, to treat excavated areas as surface soil for FSS purposes, the as-left location of this survey area is actually below the surface and not normally subject to scanning, as per NUREG-1757, Vol. 2, Appendix G.2.1.

Section B of the FR-01 10 Survey Unit Release Records described the recontamination of the survey units following the initial remediation performed in late 2002. The radioactivity that had presumably migrated into the remaining soil from open, abandoned pipes in the excavation was no different than the contamination source that originally contaminated the PAB alleyway, ie. the pipes which interfaced with the Refueling Water Storage Tanks. This contamination source relationship is established in LTP section 2.5.3.c (footnote 6). Furthermore, the nuclide fraction described in LTP Table 2.8 applies to specific special areas including the containment outer annulus trench and the Primary Auxiliary Building tunnel. The conditions which produced these special areas are described in the special report entitled: "Transuranic and other Hard to Detect Radionuclides in Maine Yankee Sample Media," transmitted to the NRC in Reference No.1.

These conditions were not present in these contamination sources.

Page 6

Maine Yankee Rcsponse to NRC Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Final Report No. 5 References

1. Maine Yankee Letter to USNRC dated January 16, 2002, MN-02-002, Transuranic and other Hard to Detect Radionuclides in Maine Yankee Sample Media

2. Maine Yankee Letter to USNRC, MN-02-037, dated August 28, 2002, Maine Yankee Addendum Report Regarding Site Hydrogeology

3. Maine Yankee Letter to USNRC, MN-02-048, dated October 15, 2002, Revision 3, Maine Yankee's License Termination Plan

4. USNRC Letter to Maine Yankee dated February 28, 2003, "Issuance of Amendment No.

168 to Facility Operating License No. DPR Maine Yankee Atomic Power Station -

Approval of the MY License Termination Plan

5. Maine Yankee letter to the USNRC, MN-03-049, dated September 11, 2003, Proposed Change: Revised Activated Concrete DCGL and More Realistic Activated Concrete Dose Modeling - License Condition 2.B.(l0), License Termination; Proposed Change No. 216.

6. USNRC Letter to Maine Yankee dated February 18, 2004, Issuance of Amendment No.

170 to Facility Operating License No. DPR Maine Yankee Atomic Power Station -

Approval of the Revised Activated Concrete DCGL and More Realistic Activated Concrete Dose Modeling

7. Maine Yankee Letter to USNRC, MN-04-020, dated March 15, 2004, License Amendment Request: Release of Non-ISFSI Site Land, Proposed Change No. 218

8. Maine Yankee Letter to USNRC, MN-04-044, dated August 12, 2004, Release of Non-ISFSI Site Land - Resubmittal of FSS Final Report No. 1, Proposed Change No. 218, Supplement 2

9. Maine Yankee Letter to USNRC, MN-04-047, dated September 2, 2004, License Amendment Request - Release of Non-ISFSI Site Land, Proposed Change No. 218, Supplement 3

10. USNRC Letter to Maine Yankee dated October 14, 2004, Meeting Report for the September 9, 2004, Meeting with Maine Yankee Atomic Power Company (Maine Yankee)

11. Maine Yankee Letter to USNRC, MN-04-049, dated September 15, 2004, Release of Non-ISFSI Site Land - FSS Final Report No. 2, Proposed Change No. 218, Supplement 4.

12. Maine Yankee Letter to USNRC, MN-04-053, dated October 14, 2004, Release of Non-ISFSI Site Land - Addendum to FSS Final Report No. 1, Proposed Change No. 218, Supplement 6

13. USNRC Letter to Maine Yankee dated November 4, 2004, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement Nos. 1 and 3

14. USNRC Letter to Maine Yankee dated November 30, 2004, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement No. 2.

15. Maine Yankee Letter to USNRC, MN-04-058, dated December 7, 2004, Response to NRC RAI's on FSS Report Nos. 1 and 3, Proposed Change No. 218, Supplement 8

16. Maine Yankee Letter to USNRC, MN-04-059, dated December 7, 2004, Release of Non-ISFSI Site Land - FSS Final Report No. 5, Proposed Change No. 218, Supplement 9 Page 7

Maine Yankcc Response to NRC Request for Additional Information (RAT) Regarding Final Status Survey (FSS) Final Report No. 5

17. Maine Yankee Letter to USNRC, MN-04-060, dated December 22, 2004, Release of Non-ISFSI Site Land - FSS Final Report No. 6, Proposed Change No. 218, Supplement 10

18. Maine Yankee Letter to USNRC, MN-04-061, dated December 23, 2004, Response to NRC RAI's on FSS Report No. 2, Proposed Change No. 218, Supplement 11

19. USNRC Letter to Maine Yankee dated January 7, 2005, Receipt of Maine Yankee's Response to Request for Information on Final Status Survey Report Supplements 1 and 3

20. USNRC Letter to Maine Yankee dated January 19, 2005, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement No. 2

21. Maine Yankee Letter to USNRC, MN-05-001, dated January 20, 2005, Release of Non-ISFSI Site Land - FSS Final Report No. 7, Proposed Change No. 218, Supplement 12

22. Maine Yankee Letter to USNRC, MN-05-006, dated February 16, 2005, Response to NRC RAI's on FSS Final Report Nos. I and 2, Proposed Change No. 218, Supplement 14

23. Maine Yankee Letter to USNRC, MN-05-007, dated February 17, 2005, Release of Non-ISFSI Site Land - FSS Final Report No. 8, Proposed Change No. 218, Supplement 15

24. Maine Yankee Letter to USNRC, MN-05-008, dated February 23, 2005, Release of Non-ISFSI Land - FSS Final Report No. 8 - Attachment 1, Figure 1 and 2 and Attachment II Header Page, Proposed Change No. 218, Supplement 16

25. USNRC Letter to Maine Yankee dated March 13, 2005, Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement No. 5 Page 8

Appendix A Final Remediation Survey Gamma Scan For Containment Holes in Liner Following Complete Removal on Concrete Above the Liner Three Surveys dated April 28, 2004 One Survey dated June 17, 2004 (11 pages)

One Survey dated June 21, 2004 (2 pages)

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Maine Yankee MAN Y AKEGENERAL I~ALLOCW~1972 SUBRVEY RECORD FORM ... ...

Map#. MSC-001 DTt . Time: Roodor Pwr % lech File Numbr l RWrs Used: Dose eci-ved:

Payisil:OO IO.( l 0 tq4ZCo.qb- I CYl-D(c70 l ) mR Surveyor Name: (Printed] Su Noam: gnaturo) Location/Job

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Appendix 13 Update of Table 2A - Survey Unit Exceptions - Disposition Cross Reference From Maine Yankee Letter to USNRC dated October 14, 2004

Table 2A - Survey Unit Exceptions - Disposition Cross Reference Survey Exception Survey Unit Disposition Unit Cross Reference FA-1700-SU1 None FA-1700-SU2 Portion of the ceiling that was NA This surface was removed with the in common with the floor of the demolition of the Spray building.

12'6" elevation.

The 23" ID penetration through FA-O100-SU5 The interior of this penetration will the North wall (containment be surveyed as part of containment wall) located at elevation 10' FSS (FAOIOO Survey Unit 5). This 3". penetration was designated M009 on Map FA 0100-U5-SCANS in Survey Package FA-0100-05 The 5 penetrations through the FR-O I I I -SU3 These will be surveyed as part of the South wall. allcyw ay East-Yard West excavation (FROI II Survey Unit 3).

Except for two 14" PCC penetrations, all pipe sleeves were removed from the wall. The opening, surrounding concrete, and PCC penetrations surveyed in Survey Package FRO111-03. This survey package also contains Map FRO111U3-04 which shows the remaining PCC penetrations as POOl and P002. Additional information of the removed penetrations was provided in Reference 22.

The 14" ID penetration at NA Penetration was removed with elevation 17' 11". building demolition.

The two 4" ID penetrations FA-1700-SU9 Penetrations were surveyed as part of through the floor of the 14' 6" FAI700 Survey Unit 9.

elevation.

FA-1700-SU3 Portion of the ceiling that is in NA This surface was removed with the common with the floor of the demolition of the spray building 12'6" elevation.

The 10" ID penetration through The interior of this penetration will the North wall (containment be surveyed as part of containment wall) located at elevation 10' FSS (FAO 100 Survey Unit 5). This 3". penetration was designated M008 on Map FA 0100-U5-SCANS in survey package FA-0100-05.

The 3" ID hole located on the FA-1700-SU9 Surveyed as part of FAI700-09.

floor of elevation -4'.

Survey Exception Survey Unit Disposition Unit Cross Reference The 8" ID penetration which FA-1700-SU9 Surveyed in Survey Unit 9 of ran through the concrete slab FA1700 that formed the floor of the 14' elevation and a portion of the ceiling for lower elevations of the cubicle.

Holes through the cubicle West FA-1700-SU2 These were surveyed as part of wall (the wall in common with Survey Unit 2 of FA1700 cubicle E-3A).

FA-1700-SU4 That portion of the ceiling that NA This surface was removed with the was in common with the floor demolition of the Spray Building of the 12'6" elevation.

The 1O" ID and 29" ID FA-0100-SU5 The interiors of these penetrations penetrations through the North will be surveyed as part of

-wall (containment wall) located containment FSS (FAO 100, Survey at elevations 12' and 10' 3" Unit 5).

respectively. 10" ID - This penetration was designated C007 on Map FA 0100-U5-SCANS in survey package FA-0100-05. The penetration was core bored and removed during the remediation process. The resulting hole was a 24" concrete penetration hence the "C" designation.

29" ID - This penetration was designated M006 on Map FA 0100-U5-SCANS in survey package FA-0100-05.

15.5" ID penetration (CS-M- FA-1700-SU9 Surveyed as part of FAI700 Survey

91) located at -14' 9". Unit 9 The two 3" ID holes located on FA-1700-SU9 Surveyed as part of FA1700 Survey the floor of elevation -4'. Unit 9 The four 3" ID penetrations FA-1700-SU9 Surveyed as part of FA1700 Survey running through the South wall Unit 9

• ofelevation 14'6" to elevation 12' 6". . . _

Holes through the cubicle West FA-1700-SU3 Surveyed as part of Survey Unit 3 of wall (the wall in common with FAI700.

P-61A).

Survey Exception Survey Unit Disposition Unit Cross Reference FA-1700-SU5 That portion of the ceiling that NA This surface was removed with the was in common with the floor demolition of the Spray building of the 12'6" elevation.

The 2" ID penetration through FA-0100-SU5 The interior of this penetration will the North wall (containment be surveyed as part of containment wall) located at elevation 12'. FSS (FAO 100, Survey Unit 5).

This penetration was designated C005 on Map FA 0100-U5-SCANS in survey package FA-0100-05.

The penetration was core bored and removed during the remediation process. The resulting hole was an 8" concrete penetration hence the "C" designation.

The two 4" ID through slab FA-1700-SU9 Surveyed as part of FAI700 Survey penetrations located at elevation Unit 9 14'6".

The four 3" ID penetrations FA-1700-SU9 Surveyed as part of FA1700 Survey located at elevation -16'. Unit 9.

Holes through the cubicle West FA-1700-SU4 Surveyed as part of FA1700 Survey wall (the wall in common with Unit 4.

P-12A),

FA-1700-SU6 That portion of the ceiling that NA This surface was removed with the was in common with the floor demolition of the Spray building of the 12'6" elevation.

The 10" ID and 23" ID FA-0100-SU5 The interiors of these penetrations penetrations through the North will be surveyed as part of wall (containment wall) located containment FSS (FA0100, Survey

.at elevations 12' and 10' 3" Unit 5).

respectively. 10" ID - This penetration was designated C003 on Map FA 0100-U5-SCANS in survey package FA-0100-05. The penetration was core bored and removed during the remediation process. The resulting hole was a 24" concrete penetration hence the "'C" designation.

23" ID - This penetration was designated M004 on Map FA 0100-U5-SCANS in survey package FA-0100-05.

15.5" ID penetration (CS-M- FA-1700-SU9 Surveyed as part of FAI700 Survey

92) located at -14' 9". Unit 9

I Survey Exception Survey Unit Disposition Unit Cross Reference Holes through the West wall FA-1700-SU5 Surveyed as part of Survey Unit 5 of (the wall in common with P- FA1 700 61 S).

FA-1700-SU7 That portion of the ceiling that NA This surface was removed with the is in common with the floor of demolition of the Spray Building the 12'6" elevation.

The 2" ID and 10" ID FA-0100-SU5 The interiors of these penetrations penetrations through the North will be surveyed as part of the wall (containment wvall) located containment FSS (FAO100, Survey at elevations 10' 3" and 12' Unit 5).

respectively. 2" ID - This penetration was designated C002 on Map FA 0100-U5-SCANS in survey package FA-0100-05. The penetration was core bored and removed during the remediation process. The resulting hole was an 8" concrete penetration hence the "C" designation.

10" ID - This penetration does not exist. This error was carried forward from the release record to Table 2A of Reference 12.

The three 3" penetrations and Fa-1700-SU9 Surveyed in Survey Unit 9 of two 4" penetrations, that ran FA1700.

through the concrete slab that formed the floor of the 14' 6" elevation.

Holes through the cubicle West FA-1700-SU6 These were surveyed as part of wall (the wall in common with Survey Unit 6 of FA1700.

P-12B).

FA-1700-SUS That portion of the ceiling that NA This surface was removed with the was in common with the floor demolition of the Spray Building of the 12'6" elevation.

The 23" ID penetration through FA-0100-SU5 The interior of this penetration will the North wall (Containment be surveyed as part of the Building wall) located at Containment Building FSS (FAO100, elevation 10' 3". Survey Unit 5). This penetration was designated M001 on Map FA 0100-U5-SCANS in survey package FA-0100-05.

The electrical duct bank at NA Removed during the demolition of elevation 16'6". I _ the Spray Building.

Survey Exception Survey Unit Disposition Unit Cross Reference The 5 penetrations through the FR-O1 101- Will be surveyed as part of the South wall. SU3 Alleyway East-Yard West excavation (FR-OI 101, Survey Unit 3Area). Except for two 14" SCC penetrations, all pipe sleeves were removed from the wall. The opening, surrounding concrete, and SCC penetrations surveyed in survey package FRO111-03. This survey package also contains Map FROMIIU3-04 which shows the remaining SCC penetrations as P003 and P004. Additional information on the removed penetrations was provided in Reference 22.

The IO"and 6" ID penetrations FA-1700-SU9 Surveyed as part of FA-1700, Survey both located at elevation 14' 6". Unit 9 FA-1700-SU9 None (FA-1700-SU9 is a compilation of miscellaneous remaining structural remnants in the Spray Building.)