ML13303B822

Yankee Atomic Electric Company - Biennial Update to the Yankee Nuclear Power Station License Termination Plan

ML13303B822
Person / Time
Site:	Yankee Rowe
Issue date:	10/23/2013
From:	Norton W Yankee Atomic Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
BYR 2013-032
Download: ML13303B822 (127)

Text

YANKEE ATOMIC ELECTRIC COMPANY Telephone (413)49 Yankee Road, Rowe, Massachusetts 01367AN KEEOctober 23, 2013BYR 2013-03210 CFR 50.71(e)(4) and 10 CFR 50.4ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555 -0001Yankee Atomic Electric CompanyYankee Nuclear Power Station Independent Spent Fuel Storage Installation NRC License No. DPR-3 (NRC Docket Nos.50-029 and 72-31)

Subject:

Biennial Update to the Yankee Nuclear Power Station License Termination PlanPursuant to the requirements of 10 CFR 50.71 (e)(4) and 10 CFR 50.4, Yankee Atomic ElectricCompany provides Revision 4 to the Yankee Nuclear Power Station (YNPS) LicenseTermination Plan (LTP) (Enclosure 1). This revision addresses the changes made to the YNPSLTP, since the submittal of the last biennial update on October 3, 2011 (Reference a).Attachment I provides a summary and rationale for the changes.

Attachment 2 providesinstructions for removal and insertion of affected pages for Revision 4 of the YNPS LTP.This letter contains no commitments.

If you have any questions regarding this submittal, please do not hesitate to contact Bob Mitchell at(413) 424-5261 ext. 303.1 state under penalty of perjury that the foregoing is true and correct.

Executed on October 23,2013.Respectfully, Wayne NortonYAEC President and Chief Executive Officer Yankee Atomic Electric CompanyBYR 2013-032/October 23, 2013/Page 2Attachments and Enclosures Attachment 1 -Summary of Proposed Changes to the Yankee Nuclear Power Station LicenseTermination PlanAttachment 2 -Instructions for Removal and Insertion

, Yankee Nuclear Power Station LicenseTermination Plan, Revision 4Enclosure 1 -Revision 4 to the Yankee Nuclear Power Station License Termination PlanReferences

a. Letter from W. Norton (YAEC) to Document Control Desk (NRC), Biennial Update of theLicense Termination Plan, dated October 3, 2011 (BYR 2011-023)

(Accession No.MLI 1286A225).

cc: W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region 1J. Goshen, NRC Project ManagerJ. Giarrusso,

Planning, Preparedness

& Nuclear Section Chief, MEMAJ. Cope-Flanagan, Assistant General Counsel, MDPUJ. Reyes, State of Massachusetts Office of the Attorney General ATTACHMENT 1 TO BYR 2013-032SUMMARY OF CHANGES TO THE YANKEE NUCLEAR POWER STATIONLICENSE TERMINATION PLAN ATTACHMENT 1 TO BYR 2013-032SUMMARY OF CHANGES TO THE YANKEE NUCLEAR POWER STATIONLICENSE TERMINATION PLANDocument Section # Proposed Change Reason for ChangeLTP 1.2.1, 1.3, 1.4.3, Updated to reflect that the On November 21, 2005 and August 10, 2007,1.4.7, 1.7, 2, decommissioning of the YNPS is the NRC approved the release of land from the2.1.2, 2.1.4, complete, with the exception of the 10 CFR 50 License to only those areas2.2.1, 2.2.2, ISFS1 and the applicable land areas, associated with the ISFSI.2.2.3, 2.2.4.1,2.2.4.2, 2.3.1, Letter from J. Hickman (USNRC) to W. Norton2.4, 2.4.1, 2.4.2, (YAEC), "Yankee Nuclear Power Station -2.5, 2.5.1, 2.5.5, Release of Non-Impacted Site Area from Part 502.6, 2.7.1, 2.7.2, License,"

dated November 21, 2005 (Accession 2.8, Tables 2-1, Number ML052420608).

2-2, 2-3, 2-4, 2-5, Appendices Letter from K. McConnell (USNRC) to W.2A, 2B and 2C, Norton (YAEC), "Yankee Nuclear Power3.2, 3.2.2, Station -Release of Land from Part 50 License,"

3.2.2.1, 3.2.2.2, dated August 10, 2007 (Accession Number3.2.3, Tables 3-1, ML071830515).

3-2, 8.1.2,8.1.3.1, 8.1.3.3(All), 8.2.1.2,8.2.6.2, 8.2.9, 8.3LTP 1.2.1, 2.1.2 In the LTP, the discussions regarding the The discussions regarding the variousproperty

boundary, site boundary (i.e., boundaries and areas are consistent with theboundary of area controlled in applicable regulations and the YNPS Emergency accordance with the 10 CFR 50 License),

Plan and the NRC Safety Evaluation Reportcontrolled area, and exclusion area were issued on August 10, 2007.updated.Letter from K. McConnell (USNRC) to W.Norton (YAEC), "Yankee Nuclear PowerStation -Release of Land from Part 50 License,"

dated August 10, 2007 (Accession NumberML071830515).

LTP 1.2.1, 2.1.2, Updated to reflect the current activities Changes were made to reflect the current2.1.4, 2.2.2, of the YNPS ISFSI. practices at the ISFSI. These changes are2.2.3, 2.2.4.1, consistent with approved procedures or other2.2.4.2, 2.3.1, license basis documents.

2.5.1, 3.4, 3.5LTP 3.1 Eliminated the list of specific low-level The general statement regarding the need forwaste disposal sites. access to low-level waste sites is sufficient atthis time. The decommissioning of the ISFSI isnot expected to occur for numerous years, thus,the names, owners, and locations of the sites thatwill be available at that time is not known.1 of 3 ATTACHMENT 1 TO BYR 2013-032SUMMARY OF CHANGES TO THE YANKEE NUCLEAR POWER STATIONLICENSE TERMINATION PLANDocument Section # Proposed Change Reason for ChangeLTP 3.3, Figure 3-1, Updated to reflect the new cost estimates The decommissioning cost estimate was7.1, 7.2, 7.3, 7.4, regarding decommissioning and storage submitted to the NRC in December 2012 as partTable 7-1, Table of spent nuclear fuel and Greater than of the Decommissioning Funding Plan. In7-2, 8.1.3.4 Class C (GTCC) waste approved by addition, the Federal Energy Regulatory FERC in July 2013. The cost estimate Commission approved the newassumes that the storage period will be decommissioning cost estimate and a new costextended from 2022 to 2031 with license estimate for the management of spent nucleartermination in 2033. In addition, the fuel and GTCC Waste in July 2013.decommissioning cost estimate assumesthat all of the concrete and steel from the Letter from C. Pizzella (YAEC) to theVCCs and ISFSI storage will be shipped Document Control Desk (USNRC),

Independent offsite as low-level radioactive waste. Spent Fuel Storage Installation Decommissioning Funding Plan, datedDecember 17, 2012 (BYR 2012-043)

(Accession Number ML12363A106).

LTP 3.4.2, 8.1.3.5 Updated to reflect the environmental The changes update the environmental impactimpacts associated with the change in associated with decommissioning the ISFSI andschedule for storage of spent nuclear the longer time period that the spent nuclear fuelfuel and GTCC waste and change in and GTCC waste will be stored onsite. Themethodology regarding disposal of the environmental impact remains bounded by thematerials comprising the Vertical previous assessment.

Concrete Casks and the ISFSI StoragePad as low-level radioactive waste.LTP Table of Editorial or administrative changes were These changes are non-substantive changes thatContents, 2.9, made. do not modify the intent of the document.

Appendix 6.FRevision number on Pages 6F-4 through6F-8 was corrected to Revision 1.LTP 3.4.1 Updated to address the impacts of The 1SFSI structures,

systems, and components decommissioning the ISFSI on are not expected to be significantly occupational health and safety. contaminated at the time of decommissioning.

During decommissioning of the ISFSI, thematerial comprising the Vertical Concrete Casksand the ISFSI storage pad will be shipped off-site as low-level radioactive waste. This activitywill be managed, so that doses to workers andthe public are minimized and federal regulations regarding doses and dose rates are met.2 of 3 ATTACHMENT 1 TO BYR 2013-032SUMMARY OF CHANGES TO THE YANKEE NUCLEAR POWER STATIONLICENSE TERMINATION PLANDocument Section # Proposed Change Reason for ChangeLTP 1, 2, 2.5.5, Table Updated to reflect that some historical In August 2007, the NRC issued a Safety2-3, Appendix information regarding the Evaluation Report that reduced the land areas2A, 3, Table 3-3, decommissioning of the YNPS has been that remained within the control of the 10 CFR4, 5, 6, 7, and 8 maintained in the LTP. 50 License to only those areas associated withthe ISFSI. The LTP is only applicable to thoseland areas. However, some of the historical information regarding the YNPSdecommissioning may provide value during thedecommissioning of the YNPS ISFSI; thus, theinformation was retained.

Letter from K. McConnell (USNRC) to W.Norton (YAEC), "Yankee Nuclear PowerStation -Release of Land from Part 50 License,"

dated August 10, 2007 (Accession NumberML071830515).

LTP 2.7.3, 2.7.5, The status of the Groundwater This information was updated to reflect theTable 2-7, Monitoring Program is updated to reflect discussion in the NRC's Safety Evaluation Figures 2-9a, 2- the discussion in the NRC's Safety Report dated August 10, 2007.9b, 2-9c, 2-9d, 2- Evaluation Report dated August 10,1Oa, 2-1Ob, 2- 2007. Letter from K. McConnell (USNRC) to W.10c, 2-10d, 2- Norton (YAEC), "Yankee Nuclear Powerl0e, 2-11, 2-12, Station -Release of Land from Part 50 License,"

2-13, 2-14, 2-15, dated August 10, 2007 (Accession Number2-16 ML071830515).

LTP 8.2.9, 8.3 Updated to include references to an Letter from M. D. Lombard (NRC) to R.exemption to 10 CFR 50.47 and 10 CFR Mitchell (YAEC), Response to Exemption 50, Appendix E granted by the NRC I Request for Portions of Title 10 of the Code ofMay 2013, and re-issued in August Federal Regulations Part 50 Appendix E, and2013. Section 50.47 of Title 10 of the Code of FederalRegulations for the Yankee Rowe Plant (TACNo. L24662),

dated May 7, 2013 (Accession Number ML13121A560).

Letter from J. M. Goshen (NRC) to R. Mitchell(YAEC), Revised Response to Exemption Request for Portions of Title 10 of the Code ofFederal Regulations Part 50 Appendix E, andSection 50.47 of Title 10 of the Code of FederalRegulations for the Yankee Rowe Plant (TACNo. L24662),

dated August 15, 2013 (Accession Number ML13228A241).

3 of 3 ATTACHMENT 2 TO BYR 2013-032INSTRUCTIONS FOR REMOVAL AND INSERTION YANKEE NUCLEAR POWER STATION LICENSE TERMINATION PLANREVISION 4

ATTACHMENT 2 TO BYR 2013-032INSTRUCTIONS FOR REMOVAL AND INSERTION YANKEE NUCLEAR POWER STATION LICENSE TERMINATION PLANREVISION 4DELETE INSERTPages i through xiv Pages i through xiiiPages 1 -1 through 1-16 Pages 1 -1 through 1-16Pages 2-1 through 2-36 Pages 2-1 through 2-31Pages 2A-1 through 2A-6 Pages 2A-1 through 2A-6Pages 2B-1 through 2B-26 Pages 2B-1 through 2B-3Pages 2C-1 through 2C-22 Pages 2C-1 and 2C-2Figures 2-9a through 2-9dFigures 2-10a through 2-1OeFigures 2-11 through 2-16Pages 3-1 through 3-26 Pages 3-1 through 3-12Page 4-1 Page 4-1Page 5-1 Page 5-1Page 6-1 Page 6-1Pages 6F-4 through 6F-8 Pages 6F-4 through 6F-8Pages 7-1 through 7-10 Pages 7-1 and 7-2Pages 8-1 through 8-25 Pages 8-1 through 8-25 ENCLOSURE 1 TO BYR 2013-032REVISION 4 TO THE YANKEE NUCLEAR POWER STATIONLICENSE TERMINATION PLAN YNPS License Termination PlanRevision 4Table of ContentsGENERAL INFORMATION 1-11.1 EXECUTIVE SUMMARY 1-11.2 DESCRIPTION OF THE YNPS SITE AND SURROUNDING AREAS 1-21.2.1 YTNPS Site 1-21.2.2 Surrounding Areas 1-21.3 HISTORICAL INFORMATION 1-31.4 PLAN SUMMARY 1-41.4.1 General Information 1-41.4.2 HSA and Site Characterization 1-51.4.3 Identification of Remaining Site Dismantlement Activities 1-51.4.4 Site Remediation Plans 1-61.4.5 Final Status Survey Plans 1-71.4.6 Compliance with the Radiological Criteria for License Termination 1-71.4.7 Update of the Site-Specific Decommissioning Costs 1-71.4.8 Supplement to the Environmental Report 1-71.5 PARTIAL SITE RELEASE PROCESS 1-81.6 CHANGE CRITERIA FOR THE LICENSE TERMINATION PLAN 1-

91.7 REFERENCES

1-102 SITE CLASSIFICATION 2-12.1 HISTORICAL SITE ASSESSMENT AND SURVEY AREA DELINEATION 2-12.1.1 Approach and Rationale 2-12.1.2 Historical Boundaries of the Site 2-42.1.3 Documents Reviewed 2-52.1.4 Property Inspections 2-62.1.5 Personnel Interviews 2-72.2 HISTORY AND CURRENT STATUS 2-72.2.1 Licensing History 2-72.2.2 Regulatory Involvement 2-82.2.3 Description of Operations Impacting Site Radiological Status 2-102.2.4 History of Unplanned Events 2-112.2.4.1 Unplanned Gaseous Releases

'_2-122.2.4.2 Unplanned Liquid Releases 2-122.3 FINDINGS 2-122.3.1 Overview 2-122.3.2 Radionuclides of Concern at 1VPS 2-142.4 IMPACTED AREA ASSESSMENTS 2-142.4.1 Buildings, Structures and Open Land Area Inside the RCA 2-142.4.2 Buildings, Structures and Open LandArea Outside the RCA 2-152.5 NON-IMPACTED AREA JUSTIFICATION 2-152.5.1 Non-Impacted Area Justification 2-152.5.2 Decommissioning Activities 2-162.5.3 Basis ofArea Classification 2-162.5.4 Occurrence of A nthropogenic Radionuclides in the Environmental Background

__ 2-162.5.5 Evaluation of the Impact of Elevated Releases of Particulate Radioactive Material 2-172.5.6 Statistical Evaluations 2-172.5.6.1 Description of Reference Areas 2-172.5.6.2 Approach and Methodology for Evaluation of the Non-Impacted Area 2-182.5.7 Summary 2-182.6 INVESTIGATION OF SUBSURFACE CONTAMINATION 2-192.7 INVESTIGATION OF GROUNDWATER CONTAMINATION 2-192.7.1 History 2-19i YNPS License Termination Plan Revision 42.7.2 Evaluation of Historical Data 2-202.7.3 Groundwater Monitoring Program 2-212.8 CONTINUING CHARACTERIZATION ACTIVITIES (As OF OCTOBER 2013) 2-212.8.1 Introduction 2-222.8.2 Characterization Survey Plans Prepared Under a Quality Assurance Project Plan _ 2-222.8.3 Characterization Survey Plans 2-2

32.9 REFERENCES

2-23APPENDIX 2A SUMMARIES OF THE SIGNIFICANT EVENTS LEADING TO LONG-TERM CONTAMINATION OF THE YNPS SITE 2A-IAPPENDIX 2B IMPACTED AREA ASSESSMENTS-BUILDINGS, STRUCTURES, AND OPENLAND AREAS INSIDE OF THE RCA OF TilE YNPS 2B-1APPENDIX 2C IMPACTED AREA ASSESSMENTS-BUILDINGS, STRUCTURES, AND OPENLAND AREAS OUTSIDEOF THE RCA OF THE YNPS 2C-I3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES 3-

13.1 INTRODUCTION

AND GENERAL CONSIDERATIONS 3-13.2 DECOMMISSIONING APPROACH (As OF OCTOBER 2013) 3-23.2.1 Phase I Activities 3-33.2.2 Phase 2 Activities 3-33.2.2.1 Systems and Components 3-53.2.2.1.1 Electrical System 3-53.2.2.1.2 Heating System 3-53.2.2.2 Structures

_ 3-53.2.3 Phase 3 Activities 3-63.3 DECOMMISSIONING SCHEDULE (AS OF OCTOBER 2013) 3-63.4 RADIOLOGICAL IMPACTS OF DECOMMISSIONING (AS OF OCTOBER 2013) 3-63.4.1 Occupational Exposure 3-73.4.2 Radioactive Waste Projections 3-

73.5 REFERENCES

3-84 SITE REMEDIATION PLANS 4-

14.1 INTRODUCTION

4-i4.2 REMEDIATION ACTIONS 4-14.2.1 Soils 4-24.2.2 Structures 4-24.2.3 Surface Water and Ground Water 4-34.3 ALARA EVALUATIONS 4-34.3.1 Generic ALARA Screening Levels 4-44.3.2 Survey Unit-Specific ALARA Evaluations 4-

44.4 REFERENCES

4-5APPENDIX 4A ALARA EVALUATIONS 4A-15 FINAL STATUS SURVEY (FSS) PLAN 5-

15.1 INTRODUCTION

5-15.2 SCOPE 5-25.3 SUMMARY OF FSS PROCESS 5-25.4 FSS PLANNING 5-45.4.1 Data Quality Objectives 5-45.4.2 Classification of Survey Areas and Units 5-85.4.3 Reference Coordinate Systems 5-95.4.4 Reference Areas and Materials 5-105.4.5 Area Preparation:

Isolation and Control 5-115.4.5.1 Area Preparation 5-11ii YNPS License Termination Plan Revision 45.4.5.2 Area Surveillance Following Final Status Surveys 5-135.4.6 Selections of DCGLs 5-145.4.6.1 Gross Activity DCGLs 5-155.4.6.2 Surrogate Ratio DCGLs 5-155.4.6.3 Elevated Measurement Comparison (EMC) DCGLs 5-175.5 FINAL STATUS SURVEY DESIGN 5-185.5.1 Selecting the Number of Fixed Measurements and Locations 5-205.5.1.1 Establishing Acceptable Decision Error Rates 5-205.5.1.2 Determining the Relative Shift 5-215.5.1.3 Selecting the Required Number of Measurements for the WRS Test 5-225.5.1.4 Selecting the Required Number of Measurements for the Sign Test 5-225.5.1.5 Assessing the Need for Additional Measurements in Class 1 Survey Units__ 5-235.5.1.6 Determining Measurement Locations 5-285.5.2 Judgmental Assessments 5-295.5.3 Data Investigations 5-295.5.3.1 Investigation Levels 5-295.5.3.2 Investigations 5-315.5.3.3 Remediation 5-315.5.3.4 Re-classification 5-315.5.3.5 Re-survey

_5-325.6 FSS IMPLEMENTATION AND DATA COLLECTION 5-335.6.1 Survey Methods 5-335.6.1.1 Scanning 5-335.6.1.2 Fixed Measurements 5-345.6.1.3 Advanced Technologies 5-345.6.1.4 Bulk Spectroscopy Monitor 5-355.6.1.5 Other Advanced Survey Technologies 5-355.6.1.6 Samples 5-365.6.2 Survey Instrumentation 5-365.6.2.1 Instrument Selection 5-365.6.2.2 Calibration and Maintenance 5-375.6.2.3 Response Checks 5-385.6.2.4 MDC Calculations 5-385.6.2.4.1 MDCs for Fixed Measurements 5-395.6.2.4.2MDCs for Beta-Gamma Scan Surveys for Structure Surfaces 5-405.6.2.4.3 MDCs for Alpha Scan Surveys for Structure Surfaces 5-415.6.2.4.4MDCs for Gamma Scans of Land Areas 5-415.6.2.5 Scan MDCs for Hot Particles 5-435.6.2.6 Typical Instrumentation and MDCs 5-435.6.3 Survey Considerations 5-455.6.3.1 Survey Considerations for Buildings and Structures 5-455.6.3.1.1 Activity Beneath Surfaces 5-465.6.3.1.2 Exterior Surfaces of Building Foundations 5-465.6.3.1.3 Buried Piping, Storm Drains, Sewer Systems, Plumbing and Floor Drains_ 5-475.6.3.1.4 Concrete Debris 5-475.6.3.2 Survey Considerations for Outdoor Areas 5-475.6.3.2.1 Residual Radioactivity in Surface Soils 5-475.6.3.2.2 Residual Radioactivity in Subsurface Soils 5-475.6.3.2.3 Paved Areas 5-495.6.3.2.4 Groundwater 5-495.6.3.2.5 Sediments 5-495.7 FINAL STATUS SURVEY DATA ASSESSMENT 5-505. 7.1 1W"ilcoxon Rank Sum Test 5-525. 7.2 Sign Test 5-535.7.3 Elevated Measurement Comparison 5-54Illo.

YNPS License Termination PlanRevision 45.7.4 Unit)' Rule 5-545.7.5 Data Assessment Conclusions 5-555.8 FINAL STATUS SURVEY REPORTS 5-565.9 FINAL STATUS SURVEY QUALITY ASSURANCE AND QUALITY CONTROL MEASURES

__ 5-575.9.1 Introduction 5-575.9.2 Organization 5-585.9.3 Program Controls 5-585.9.4 Design Controls 5-585.9.5 Procurement Document Control 5-585.9.6 Instructions, Procedures, and Drawings 5-595.9.7 Document Control 5-595.9.8 Control of Purchased

Material, Items and Services 5-595.9.9 Control of Special Processes 5-595.9.10 Inspections 5-595.9.11 Control of Measuring and Test Equipment 5-605.9.12 Handling,

Storage, and Shipping 5-605.9.13 Control of Nonconformances 5-605.9.14 Corrective Action Program 5-605.9.15 Records 5-605.9.16 Audits 5-615.10 REFERENCES 5-616 COMPLIANCE W/ THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION6-1 6.1 SITE RELEASE CRITERIA 6-16.1.1 Radiological Criteria for Unrestricted Use 6-16.1.2 Conditions Satisfying the Site Release Criteria 6-16.2 DOSE MODELING APPROACH 6-26.2.1 Overview 6-26.2.2 Resident Farmer Scenario 6-36.2.2.1 Scenario Definition 6-36.2.2.2 Critical Group 6-36.2.2.3 Exposure Pathways 6-36.2.3 Building Occupancy Scenario 6-46.2.3.1 Scenario Definition 6-46.2.3.2 Critical Group 6-46.2.3.3 Exposure Pathways 6-56.2.4 Code Selection 6-56 2.5 Input Parameter Selection Process 6-56.2.5.1 Classification (Type) 6-66.2.5.2 Prioritization 6-66.2.5.3 Treatment 6-66.2.5.4 Sensitivity Analysis 6-66.2.5.5 Parameter Value Assessment for DCGL Determination 6-76.2.6 Code Output and Calculation of DCGL 6-86.3 CALCULATION OF DCGLS FOR SOIL 6-86.3.1 Dose Model 6-86.3.2 Conceptual Model 6-96.3.3 Parameter Value Assignment 6-96.3.4 DCGL Determination 6-96.4 CALCULATION OF DCGL FOR STRUCTURES 6-96.4.1 Structure Surface DCGL 6-96.4.1.1 Dose Model 6-96.4.1.2 Conceptual Model 6-96.4.1.3 Parameter Value Assignment 6-10iv YNPS License Termination PlanRevision 46.4.1.4 DCGL Determination 6-106.4.2 Structure Volumetric DCGL 6-106.4.3 Calculation of DCGLs for Subsurface Partial Structures 6-116.4.3.1 Dose Model 6-116.4.3.2 Conceptual Model 6-116.4.3.3 Parameter Value Assignment 6-126.4.3.4 DCGL Determination 6-126.4.4 Calculation of DCGLs for Concrete Debris 6-126.4.4.1 Dose Model 6-126.4.4.2 Conceptual Model 6-126.4.4.2.1 General Model 6-126.4.4.2.2 Tritium Model 6-136.4.4.3 Parameter Value Assignment 6-136.4.4.4 DCGL Determination 6-146.5 RESIDUAL RADIOACTIVITY IN GROUNDWATER 6-146.6 COMBINING DOSE CONTRIBUTIONS FROM DIFFERENT MEDIA 6-146.7 APPLICATION OF DECAY 6-166.8 CALCULATION OF AREA FACTORS 6-166.8.1 Calculation ofArea Factors for Soils 6-166.8.2 Calculation ofArea Factors for Building Sumfaces 6-1

76.9 REFERENCES

6-18APPENDIX 6A BASIS DOCUMENT FOR SITE-SPECIFIC PARAMETER VALUEASSIGNMENT, SOIL 6A-1APPENDIX 6B INPUT PARAMETER VALUES FOR SENSITIVITY

ANALYSIS, SOIL __ 6B-1APPENDIX 6C RESULTS OF SENSITIVITY

ANALYSIS, SOIL 6C-1APPENDIX 6D INPUT PARAMETER VALUES FOR SOIL DCGL DETERMINATION 6D-1APPENDIX 6E SOIL DCGL RESULTS 6E-IAPPENDIX 6F BASIS DOCUMENT FOR SITE-SPECIFIC PARAMETER VALUEASSIGNMENT, BUILDING OCCUPANCY 6F-1APPENDIX 6G INPUT PARAMETER VALUES FOR SENSITIVITY

ANALYSIS, BUILDINGOCCUPANCY 6G-1APPENDIX 6H RESULTS OF SENSITIVITY

ANALYSIS, BUILDING OCCUPANCY

__ 6H-1APPENDIX 61 INPUT PARAMETER VALUES FOR BUILDING OCCUPANCY DCGLDETERMINATION 61-1APPENDIX 6J BUILDING SURFACE AREA DCGL RESULTS 6J-1APPENDIX 6K DCGLS FOR SUBSURFACE PARTIAL STRUCTURES 6K-IAPPENDIX 6L PARAMETERS USED TO QUANTIFY CONCEPTUAL MODEL 6L-1APPENDIX 6M INPUT PARAMETERS FOR SENSITIVITY ANALYSIS 6M-1APPENDIX 6N SENSITIVITY ANALYSIS SUMMARY 6N-1APPENDIX 60 DCGL FOR CONCRETE DEBRIS AND EQUILIBRIUM CONCENTRATIONS60-1 APPENDIX 6P INPUT PARAMETER VALUES FOR AREA FACTORS, SOIL 6P-1APPENDIX 6Q AREA FACTORS FOR SOIL 6Q-1APPENDIX 6R INPUT PARAMETER VALUES FOR AREA FACTORS, BUILDINGOCCUPANCY 6R-1APPENDIX 6S AREA FACTORS FOR BUILDING SURFACE AREA 6S-1V YNPS License Termination Plan Revision 47 UPDATES OF THE SITE-SPECIFIC DECOMMISSIONING COSTS 7-17.1 SUMMARY OF DECOMMISSIONING COST ESTIMATE 7-

17.2 REFERENCES

7-28 SUPPLEMENT TO THE ENVIRONMENTAL REPORT 8-

18.1 INTRODUCTION

8-18.1.1 Overview 8-18.1.2 Proposed Site Conditions at the Time of License Termination 8-48.1.3 Remaining Dismantlement and Decommissioning Activities 8-48.1.3.1 General Description of Decommissioning Activities 8-48.1.3.2 Other Decommissioning Considerations 8-58.1.3.3 General Decommissioning Activities Related to Removal of Radiological Components and Structures 8-58.1.3.3.1 Decontamination Methods 8-58.1.3.3.2 Dismantlement Methods 8-68.1.3.3.3 Special Programs 8-68.1.3.3.4 Removal of LLW and Compaction or Incineration 8-68.1.3.3.5 Soil Remediation 8-68.1.3.3.6 Processing and Disposal Site Locations 8-68.1.3.3.7 Removal of Mixed Wastes 8-78.1.3.3.8 Storage/Removal of Spent Fuel and GTCC Waste and Decommissioning ofthe ISFSI 8-78.1.3.3.9 LTP, Final Status Survey, and Site Release Criteria 8-78.1.3.3.10 Site Restoration 8-78.1.3.4 Schedule of Decommissioning Activities 8-88.1.3.5 Conclusions Regarding Environmental Impact Included in PSDAR 8-88.2 ANALYSIS OF SITE-SPECIFIC ISSUES 8-108.2.1 Onsite-Offsite Land Uses 8-108.2.1.1 Onsite Land Uses 8-108.2.1.2 Offsite Land Uses 8-118.2.2 Water Use 8-118.2.3 Water Quality 8-118.2.4 Air Ouality 8-128.2.5 Aquatic Ecology 8-148.2.5.1 Activities Within the Operational Area 8-148.2.5.2 Activities Outside of the Operational Area 8-148.2.6 Terrestrial Ecology 8-148.2.6.1 Activities Within the Operational Area 8-148.2.6.2 Activities Outside of the Operational Area 8-158.2.7 Threatened and Endangered Species 8-158.2.8 Radiological 8-168.2.8.1 Activities Resulting in Occupational Doses to Workers 8-168.2.8.2 Activities Resulting in Doses to the Public 8-168.2.9 Radiological Accidents 8-168.2.10 Occupational Issues 8-178.2.11 Socioeconomic Impacts 8-188.2.12 Environmental Justice 8-188.2.13 Cultural and Historic Resource Impacts 8-198.2.13.1 Activities Within the Operational Area 8-198.2.13.2 Activities Outside of the Operational Area 8-198.2.14 Aesthetics 8-198.2.15 Noise 8-208.2.16 Transportation 8-208.2.17 Irretrievable Resources 8-2

18.3 REFERENCES

8-21vi YNPS License Termination PlanRevision 4Table of TablesTABLE 1-1 CURRENT NEAREST RESIDENT, GARDEN, AND MILK ANIMAL LOCATIONS WITHIN 5 MILES OF YNPS 1-12TABLE 1-2 PERMANENT POPULATION ESTIMATES FOR MUNICIPALITIES WITHIN10 MILES OF THE YANKEE NUCLEAR POWER STATION 1-13TABLE 2-1 FLOOR AND TOTAL AREA OF BUILDINGS AND FEATURES 2-26TABLE 2-2 AREA OF OPEN LAND SURVEY AREAS 2-27TABLE 2-3 AOR/PIR LIST OF UNPLANNED LIQUID RELEASES 2-28TABLE 2-4 CURRENT RADIOLOGICAL CONDITIONS OF BUILDINGS IN THE INDUSTRIAL AREA BY SURVEY AREA 2-29TABLE 2-5 SUMMARY OF RADIOLOGICAL CONDITIONS OF OPEN LAND AREA 2-30TABLE 2-6 RADIONUCLIDES OF CONCERN AT YNPS 2-31TABLE 3-1 REMAINING CONTAMINATED PLANT SYSTEMS (AS OF OCTOBER 2013) _ 3-9TABLE 3-2 STATUS OF PLANT SSCS AS OF OCTOBER 2013 3-10TABLE 3-3 HISTORICAL RADIATION EXPOSURE PROJECTIONS ASSOCIATED WITHTHE FORMER YNPS 3-12TABLE 4A-1 PARAMETER VALUES FOR USE IN ALARA ANALYSES 4A-3TABLE 5-1 SUGGESTED YNPS SURVEY UNIT SURFACE AREA LIMITS 5-9TABLE 5-2 INVESTIGATION LEVELS 5-30TABLE 5-3 TRADITIONAL SCANNING COVERAGE REQUIREMENTS 5-34TABLE 5-4 AVAILABLE INSTRUMENTS AND NOMINAL DETECTION SENSITIVITIES 5-44TABLE 5-5 INITIAL EVALUATION OF SURVEY RESULTS (BACKGROUND REFERENCE AREA USED) _ 5-51TABLE 5-6 INITIAL EVALUATION OF SURVEY RESULTS (BACKGROUND REFERENCE AREA NOT USED) _ 5-52TABLE 6-1 SUMMARY OF DCGLS FOR DIFFERENT MEDIA TYPES 6-15TABLE 8-1 SUMMARY OF ENVIRONMENTAL IMPACTS FROM DECOMMISSIONING_

8-24TABLE 8- 2 POPULATION CHANGES IN THE VICINITY OF YNPS 8-25vii YNPS License Termination PlanRevision 4List of FiguresFIGURE 1-1 YNPS SITE BOUNDARYFIGURE 1-2 SITE DESIGN (AS OF JUNE 2003)FIGURE 1-3 CURRENT 10 CFR 50 LICENSED SITE BOUNDARYFIGURE 2-1A PRELIMINARY LAND SURFACE IMPACTED AREA BOUNDARES FIGURE 2-1B PRELIMINARY LAND SURFACE IMPACTED AREA BOUNDARIES (CON'T)FIGURE 2-2 PRELIMINARY STRUCTURE SURVEY AREA BOUNDARIES FIGURE 2-3 PRELIMINARY LAND SURFACE IMPACTED AREA CLASSIFICATION FIGURE 2-4 PRELIMINARY STRUCTURE CLASSIFICATION FIGURE 2-5 LOCATIONS OF SAMPLES TO DETERMINE BACKGROUND CS-137 IN SOILFIGURE 2-6 PRELIMARY SUBSURFACE INVESTIGATION AREASFIGURE 2-7 MONITORING WELL LOCATION MAPFIGURE 2-8 CONCENTRATION OF H-3 IN GROUNDWATER (NOVEMBER 2003)FIGURE 4-1 SURVEY UNIT ALARA EVALUATION PROCESSFIGURE 5-1 FINAL STATUS SURVEY ORGANIZATION FIGURE 6-1 PARAMETER SELECTION PROCESSviii YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 4List of Effective PagesPage Revision DateFRONT MATTERi through xii 4 October 2013I GENERAL INFORMATION 1-1 through 1-16 4 October 20132 SITE CLASSIFICATION 2-1 through 2-31 4 October 2013APPENDIX 2A2A-1 through 2A-6 4 October 2013APPENDIX 2B2B-1 through 2B-3 4 October 2013APPENDIX 2C2C-1 through 2C-2 4 October 20133 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES 3-1 through 3-12 4 October 20134 SITE REMEDIATION PLANS4-1 4 October 20134-2 through 4-8 3 October 2007APPENDIX 4A4A- I through 4A-6 1 November 2004ix YNPS License Termination PlanRevision 4Page Revision Date5 FINAL STATUS SURVEY (FSS) PLAN5-1 4 October 20135-2 through 5-62 3 October 20076 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSETERMINATION 6-1 4 October 20136-2 through 6-21 3 October 2007APPENDIX 6A6A- I through 6A-8 I November 20046A-9 2 November 20066A- 10 through 6A- 16 1 November 2004APPENDIX 6B through 6D6B-1 through 6B-24 I November 20046C-1 through 6C-46D-1 through 6D-24APPENDIX 6E6E-1 through 6E-2 2 November 2006APPENDIX 6F through 616F-1 through 6F-8 1 November 20046G-1 through 6G-86H-1 through 6H-261-1 through 61-16x YNPS License Termination PlanRevision 4APPENDIX 6J6J-1 through 6J-2 2 November 2006APPENDIX 6K through Appendix 6SPage Revision DateAll except 60-2 1 November 200460-2 2 November 20067 UPDATES OF THE SITE-SPECIFIC DECOMMISSIONING COSTS7-1 and 7-2 4 October 20138 SUPPLEMENT TO THE ENVIRONMENTAL REPORT8-1 through 8-25 4 October 2013Xi YNPS License Termination PlanRevision 4List of AcronymsALARA As Low As Reasonably Achievable AMDA Alternate Method of Disposal Authorization AOR Abnormal Operating ReportASWS Auxiliary Service Water SystemCFR Code of Federal Regulations cpm Counts per minuteCR Condition ReportDCGL Derived Concentration Guideline LevelDCGLw DCGL for average concentration over a wide area, used with statistical testsDCGLEMc DCLGS for small areas of elevated activityDEP [Massachusetts]

Department of Environmental Protection DOD Department of DefenseDOE Department of EnergyDOT Department of Transportation DPH [Massachusetts]

Department of Public Healthdpm Disintegrations per minuteDQO Data quality objective EMC Elevated Measurement Comparison EPA Environmental Protection AgencyFERC Federal Energy Regulatory Commission FGEIS Final Generic Environmental Impact Statement FSS Final Status SurveyFSAR Final Safety Analysis ReportGPS Global positioning systemGTCC Greater than Class C [Waste]HEPA High Efficiency Particulate AirHSA Historical Site Assessment ISFSI Independent Spent Fuel Storage Installation LBGR Lower Bound Grey RegionLER License Event ReportLLW Low Level WasteLTP Licence Termination PlanMARSSIM Multi-Agency Radiation Survey and Site Investigation ManualMIDA Minimum Detectable ActivityMDC Minimum Detectable Concentration MDCR Minimum Detectable Count RateNPDES National Pollutant Discharge Elimination SystemNRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation ManualPAB Plant Auxiliary BuildingPTR Plant Investigation ReportPSDAR Post-Shutdown Decommissioning Activities ReportQA Quality Assurance QAP Quality Assurance ProgramQAPP Quality Assurance Program PlanQC Quality ControlRCA Radiologically Controlled AreaRESRAD RESidual RADioactivity

[Computer Code]REMP Radiological Environmental Monitoring Programxii YNPS License Tennination PlanRevision 4YNPS License Termination Plan Revision 4List of AcronymsRETS Radiological Environmental Technical Specifications RIR Radiological Incident ReportSSCs Structures,

Systems, and Components SFP Spent Fuel PitTEDE Total Effective Dose Equivalent TRU Trans-Uranics WRS Wilcoxon Rank Sum [test]YAEC Yankee Atomic Electric CompanyYNPS Yankee Nuclear Power Stationxiii YNPS License Termination PlanRevision 41 GENERAL INFORMATION Decommissioning activities for and final status survey of the YNPS site, with the exception ofthe 1SFSI and associated land areas (NOL-07, OOL-1 0-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 1-15). the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letter,NYR 2007-046 (Reference 1-16). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.1.1 Executive SummaryThe objective for decommissioning the Yankee Nuclear Power Station (YNPS) site is to reduceresidual radioactivity to levels that permit release of the site for unrestricted use and fortermination of the I OCFR50 license, in accordance with the Nuclear Regulatory Commission's (NRC's) site release criteria set forth in IOCFR20, Subpart E. The purpose of this YNPS LicenseTermination Plan (LTP) is to satisfy the requirements of IOCFR50.82, "Termination of License"(Reference 1-1) using the guidance provided in Regulatory Guide 1.179, "Standard Format andContent of License Termination Plans for Nuclear Power Reactors" (Reference 1-2). NRC staffreview guidance, in the form of NUREG-1700 (Reference 1-3) and NUREG-1757 (Reference 1-4), has also been considered.

This LTP describes the decommissioning activities that will be performed, the process forperforming the Final Status Surveys, and the method for demonstrating that the site meets thecriteria for release for unrestricted use. The LTP contains specific information on:" historical site assessment;

" site characterization;

• remaining decommissioning activities;

" site remediation plans;" final status survey design and implementation;

" dose modeling scenarios;

• update to the site-specific decommissioning cost estimate; and* supplement to the environmental report.Each section of the LTP is summarized in Section 1.4.1-1 YNPS License Termination PlanRevision 41.2 Description of the YNPS Site and Surrounding Areas1.2.1 YNPS SiteThe Yankee Nuclear Power Station (YNPS) was located at 49 Yankee Road, Rowe, in FranklinCounty, Massachusetts.

Yankee Atomic Electric Company (YAEC) is the license holder forYNPS and the YNPS Independent Spent Fuel Storage Installation (ISFSI).

The plant siteoriginally contained in the licensed area approximately 1,800 acres, and approximately 10 acreswere developed for plant use. As of August 10, 2007 (Reference 1-16), the licensed area wasreduced to those areas associated with the YNPS ISFSI, Survey Area/Units OOL-10-02, NOL-07, and NSY-10 (approximately 2 acres). The site is at the bottom of a deep valley along theDeerfield River (elevation 1022') at the southeast corner of Sherman Reservoir (also referred toas Sherman Pond). The area surrounding the site is mostly wooded with very steep slopes onboth sides of the Deerfield River. The hills on either side of the site rise about 1000 feet abovethe river and extend from 12 miles north to 8 miles southeast of the site. Sherman Reservoir served as the source of cooling water for the plant.YAEC, or TransCanada, owns all of the land located within the property boundary (see Figure 1-1), and all of the property within the controlled area is under the control of YAEC. TheTransCanada property is generally located along the Deerfield River and Sherman Reservoir.

Portions of the TransCanada are considered impacted by licensed activities and are generally located at the northeastern end of the YAEC industrial area, the southern reaches of ShermanReservoir, and the property outside of the industrial area fence located between Yankee Roadand the Deerfield River. These impacted areas are included in license termination activities.

Notable plant structures that were located on TransCanada property were the circulating waterdischarge seal pit, the Screenwell Pump House, and the meteorological tower located on apeninsula at the northeast corner of the site. The current nearest resident is locatedapproximately 0.8 miles from the former plant site (Reference 1-5).Significant features of the site are shown in Figure 1-2.1.2.2 Surrounding AreasThe following paragraphs describe the features and uses of land within 5 miles of the plant.Included is a summary of the population centers within 10 miles of the YNPS site.Major Bodies of Water: In addition to Sherman Reservoir and the Deerfield River (including tributaries and brooks feeding it), there are other major bodies of water located within 5 miles ofthe YNPS site. These include:

Sadawga Pond (184 acres), Shippee Pond (25 acres), North Pond(17 acres), and Clara Lake (12 acres) in Whittingham, Vermont; Howe Pond (42 acres) inReadsboro, Vermont; and Bear Swamp Upper Reservoir (128 acres) and Pelham Lake (89 acres)in Rowe, Massachusetts.

Industry:

There are no exclusively commercial areas within 5 miles of the plant. The onlyindustry within the area is the YNPS and the TransCanada hydroelectric stations.

TransCanada has five powerhouses within 5 miles of YNPS. There are three stations that are part of the1-2 YNPS License Termination PlanRevision 4Deerfield River Project.

They are the Harriman,

Sherman, and No. 5 Stations.

In addition theBear Swamp and Fife Brook stations are a part of the Bear Swamp Pumped storage facility.

Public Lands and Conservation Areas: There are several public lands/conservation areas within5 miles of the YNPS site. These areas offer a variety of recreational opportunities including

fishing, hunting,

boating, swimming, picnicking, and hiking.Schools:

There are two schools within 5 miles of the plant: Rowe Elementary located about 2.5miles southeast of the site on Pond Road in Rowe, Massachusetts and Readsboro Central School,located off Route 100 near the center of Readsboro, Vermont.Farms: Information was collected by YAEC to document the current nearest garden and milkanimal locations.

These locations may include farms or simply private gardens or dairyinglocations.

Table 1-1 identifies these locations by sector.Water Supplies:

Water supplies within the Deerfield River Drainage Basin, including the entirearea within 5 miles of the plant, generally consist of private wells. The only communal source ofwater within 5 miles of the plant site is Phelps Brook, which services some of the residents ofMonroe, Massachusetts.

Beyond 5 miles, downstream there are two small water supply wellsservicing local private developments:

the Deerfield River Club and Heath Stage Apartments inCharlemont, Massachusetts.

Still further downstream, the closest public water supply wells,Stillwater

Springs, are in the town of Deerfield, 20 to 25 miles south of the YNPS. Stillwater Springs has a safe yield of about 120,000 gallons per day. This well field is immediately adjacent to the Deerfield River. Another supply well, the Deerfield Well Field, off Route 116,has been closed due to contamination from nearby agricultural uses. The Quabbin Reservoir, serving the greater Boston area, is 35 to 40 miles southeast of the YNPS.Population:

The population within 10 miles of the site is estimated to be 39,300 and includes 17municipalities in two states. Table 1-2 shows the total population in each town with borderswithin 10 miles of the plant. In general, the area is rural, with North Adams being the mostpopulous municipality.

1.3 Historical Information YNPS (Docket No.50-029) achieved initial criticality in 1960 and began commercial operations in 1961. The nuclear steam supply system was a four-loop pressurized water reactor designed byWestinghouse Electric Corporation.

The original thermal power design limit of 485 MWt wasupgraded to 600 MWt in 1963. The turbine generator, also designed by Westinghouse, was ratedto produce 185 MWe.On February 26, 1992, the Yankee Atomic Electric Company (YAEC) Board of Directors decided to cease power operations permanently at YNPS. This decision was based upon thefollowing two factors:1-3 YNPS License Termination PlanRevision

41. Economic analyses indicated that shutdown of the plant before expiration of the NRCoperating license in July 2000 could produce a substantial savings to the electricity producers.

2. Significant regulatory uncertainty existed concerning the timing and cost of completion of the NRC's review of the integrity of the YNPS Reactor Pressure Vessel.On August 5, 1992, the NRC amended the YNPS Facility Operating License to a possession onlystatus.The YNPS Decommissioning Plan (Reference 1-6) was submitted March 29, 1994, and receivedfinal approval on October 28, 1996 (References 1-7 and 1-8). In May 1997, Yankee submitted tothe NRC for approval a License Termination Plan (LTP) for YNPS, pursuant toIOCFR50.82(a)(9).

The initial YNPS LTP employed a survey methodology based upon the"Manual for Conducting Radiological Surveys in Support of License Termination, (Reference 1-9)," also referred to as the Draft NUREG/CR-5849 methodology.

Subsequently theNRC, jointly with the DOD, DOE, and EPA, approved an alternate survey methodology documented in MARSSIM ("Multi-Agency Radiation Survey and Site Investigation Manual" orNUREG-1575, Reference 1-10). In May 1999, Yankee advised the NRC that it intended to shiftfrom the survey methodology in NUREG/CR-5849 to the MARSSIM methodology and,therefore, withdrew its previously submitted LTP application.

The current LTP is written toreflect the MARSSIM methodology, as well as appropriate regulatory guidance made available since the previous LTP submittal.

In 2000, Yankee created a Post-Shutdown Decommissioning Activities Report (PSDAR) withinthe Final Safety Analysis Report (FSAR). NRC Draft Regulatory Guide DG-1071 recommends that licensees with approved Decommissioning Plans (D Plans) "extract pertinent detail from thedecommissioning plan and submit a PSDAR update in the format and content specified by[DG-1071]."

Based on the NRC draft guidance, Yankee segregated, updated and condensed certain information concerning post-shutdown decommissioning activities in a manner thatconforms to the standard format and content of a PSDAR.On November 21, 2005 and August 10, 2007 (References 1-15 and 1-16), the NRC approved therelease of the majority of the site from the 10 CFR 50 License.

As a result, the only areas of thesite that remain within the control of the 10 CFR 50 License are those areas associated with theYNPS ISFSI, Survey Areas/Units OOL-10-02, NOL-07, and NSY-10.With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel andGTCC waste have been removed from the site, all decommissioning and dismantlement activities have been completed at this site.1.4 Plan Summary1.4.1 General Information This LTP has been prepared by YAEC in accordance with the requirements ofIOCFR50.82(a)(9).

The LTP is being maintained as a supplement to the YNPS FSAR to support1-4 YNPS License Ten-nination PlanRevision 4the application for a license amendment to meet 1OCFR50.82(a)(9) and IOCFR50.90.

Each ofthe sections required by 10CFR50.82(a)(9) are outlined in the subsections below.1.4.2 HSA and Site Classification The objectives of the site classification are:1. To divide the site into survey areas for classification purposes;

2. To identify the potential and known sources of radioactive contamination in systems, onstructures, in surface or subsurface soils, and in groundwater;

3. To determine the initial classification of each survey area; and4. To develop the information to support Final Status Survey design including instrument performance standards and quality requirements.

The site classification is based upon the Historical Site Assessment (HSA). The HSA consisted of a review and compilation of the following types of information:

historical

records, plant andradiological incident files, operational survey records, and annual environmental reports to theNRC. Personnel interviews were conducted with present and former plant employees andcontractors to obtain additional information regarding operational events that causedcontamination in areas or systems not designed to contain radioactive or hazardous materials.

Information from previous

surveys, including those in support of the previous Final StatusSurvey campaign, was reviewed for radiological conditions throughout the site. The radiological data collected during this process provide a basis for developing plans for remediation and FinalStatus Surveys.Operational radiation surveys and additional measurements and samples obtained duringdecommissioning activities will be used to confirm the area classification and effectiveness ofthe cleanup activities before completing the Final Status Survey.As a result of the HSA, and site classification, approximately 2170 acres of the 2200-acre plantsite have been identified as "non impacted" as defined in MARSSIM.

Tables 2-1 and 2-2provide the area classifications for the various survey areas of the YNPS site.1.4.3 Identification of Remaining Site Dismantlement Activities (As of October2013)In previous phases of decommissioning, major plant systems and components were removedfrom site buildings.

These included the steam generators, reactor vessel, and reactor coolantpiping, as well as the turbines, generator and other plant systems not serving spent fuel pitsupport functions.

After component

removal, some buildings and land areas were remediated inpreparation for the Final Status Survey and some underground and embedded piping wereremoved.

As previously discussed, LTP-related and Final Status Survey activities were halted in1-5 YNPS License Termination PlanRevision 4September 1999, based upon the availability of new survey guidance in MARSSIM.

The focusthen shifted from decommissioning activities to spent fuel storage activities.

All fuel andgreater-than-class-C (GTCC) waste was removed from the spent fuel pit and placed in storagecasks on the pad at the onsite independent spent fuel storage installation (ISFSI).

Removal ofspent fuel and GTCC waste from the pool and placement on the ISFSI pad were completed inJune 2003.YAEC, with the assistance of a demolition contractor, demolished most site structures to grade.Structural demolition debris were surveyed using site procedures that invoke the "no detectable radioactivity" criterion (consistent with the guidance in NRC Circular IEC 81-07, "Control ofRadioactively Contaminated Material")

or were subjected to a final status survey using theDCGLs, discussed in Section 6 of this LTP. Materials meeting this criterion were either used asbackfill, subject to regulations on the use of such materials by the Commonwealth ofMassachusetts, or removed offsite for disposal.

The Vapor Container was dismantled, decontaminated, and removed from the plant site. The Reactor Support Structure wasdismantled, decontaminated and removed from the plant site.With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel andGTCC waste have been removed from the site, all decommissioning and dismantlement activities have been completed at this site.1.4.4 Site Remediation PlansSection 4 of the LTP describes various methods that can be used during YNPS decommissioning to reduce radioactivity to levels meeting the NRC radiological release criteria.

This means thatlevels of radioactivity will not exceed 25 mrem/yr total effective dose equivalent (TEDE) andwill be as low as reasonably achievable (ALARA).

This section describes the methodology thatwill be used to demonstrate that the residual radioactivity has been reduced to levels incompliance with the NRC requirements.

1-6 YNPS License Termination PlanRevision 41.4.5 Final Status Survey PlanThe primary objectives of the Final Status Survey are to:* verify proper survey unit classification (or reclassify survey unit),* demonstrate that the level of residual radioactivity for each survey unit is below the releasecriterion, and* demonstrate that the potential doses from small areas of elevated activity are below therelease criterion for each survey unit.The purpose of the Final Status Survey Plan is to describe the methods that will be used inplanning, designing, conducting, and evaluating Final Status Surveys at the YNPS site todemonstrate that the site meets the NRC's radiological criteria for unrestricted use. Section 5 ofthe LTP describes the Final Status Survey Plan, which is consistent with the guidelines ofMARSSIM.

The plan also describes methods and techniques used to implement isolation controls that prevent re-contaminating previously remediated areas.1.4.6 Compliance with the Radiological Criteria for License Termination Section 6 together with Section 5, Final Status Survey Plan, describes the process that will beused to demonstrate that the YNPS site complies with the radiological criteria of 1OCFR2O.1402 for unrestricted use. YAEC has selected the RESRAD computer code (Version 6.21) to modelthe dose from soils and volumetric concrete and its counterpart, RESRAD-BUILD (Version 3.21), to model the dose from structural surfaces.

Two scenarios have been selected for use with the RESRAD family of codes for calculating theradionuclide-specific derived concentration guideline levels (DCGLs).

These scenarios are theresident farmer scenario for site soils and volumetric concrete.

The building occupancy scenariois being used for surficial contamination in structures.

DCGLs are the concentration and surfaceradioactivity limits that will be the basis for performing the Final Status Survey.1.4.7 Update of the Site-Specific Decommissioning CostsIn accordance with I OCFR50.82 (a)(9)(ii)(F),

Section 7 provides an updated, site-specific estimate of the remaining decommissioning costs. With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel and GTCC waste have been removed fromthe site, all decommissioning and dismantlement activities have been completed at this site.Section 7 also compares these estimated costs to the amount of funds presently set aside fordecommissioning and describes the methods that will ensure sufficient funds for completing decommissioning.

1.4.8 Supplement to the Environmental ReportIn accordance with I OCFR50.82 (a)(9)(ii)(G),

Section 8 demonstrates that decommissioning activities will be accomplished with no significant adverse environmental impacts.Supplement I to NUREG-0586, "Final Generic Environmental Impact Statement onDecommissioning of Nuclear Facilities (FGEIS)"

(Reference 1-11) provides an assessment of1-7 YNPS License Termination PlanRevision 4the aspects of decommissioning with the potential to impact the environment.

This assessment includes an evaluation of the significance of the impact of the activity (SMALL, MODERATE, or LARGE), as well as its applicability (generic to all or to a group of plants or site-specific).

Section 8 is focused on the evaluation of those aspects of decommissioning whose impacts couldnot be generically addressed (i.e., those determined to have site-specific impacts) and on whetherremaining license termination activities and end use of the site are bounded by prior assessments.

1.5 Partial Site Release ProcessYAEC may choose to remove specific areas from the license in a phased manner before licensetermination.

The approach for phased release and removal from the license, after approval of theLicense Termination Plan, is as follows:1. Following completion of decommissioning activities, YAEC will compile a report withthe following information for NRC review:* a description and location of the survey unit or area being surveyed;

• certification that dismantlement/decommissioning activities, as described in the LTP,have been completed for the subject building or area;* an evaluation of the potential for possible recontamination of the area and adescription of controls in place to prevent such recontamination;

• Final Status Survey results for the survey unit or area, as demonstration ofcompliance with the LTP release criteria (not applicable to areas designated as "non-impacted");

• Expected date of removal of the area from the 1OCFR50 license.2. YAEC will review and assess the impacts on the following programs and documents inpreparation for removal of a survey unit or area from the license:* Final Safety Analysis Report and Technical Specifications;

• Radiological Environmental Monitoring Program;* Offsite Dose Calculation Manual;* Defueled Emergency Plan;* Security Plan;* License Termination Plan;* Ground Water Monitoring Program;1 1OCFRI00 Siting Criteria; and* Decommissioning Environmental Report.The reviews will include an assessment to ensure that the land area(s),

and any associated building(s),

to be released will have no adverse impact on the site's ability to meet thePart 20, Subpart E, criteria for unrestricted release.

The reviews will also include the1-8 YNPS License Ten-nination PlanRevision 4impacts on the discharge of effluents and the limits of 10CFR 20, as they pertain to thepublic.3. A letter of intent to remove a portion of the property from the Part 50 license will be sentto the NRC, no later than sixty (60) days before the anticipated date for release of thesubject survey area(s).

This letter will contain a summary of the assessments performed, as described above, and, for areas designated as "impacted" will include the FSS reportfor the subject survey units(s) or area(s).4. Once the land area(s),

and any associated building(s),

have been verified ready forrelease, no additional surveys or decontamination of the subject building or area will berequired (beyond those outlined in Section 5.4.5 intended for isolation and controls) unless administrative controls to prevent recontamination are known or suspected to havebeen compromised.

Following completion of the Final Status Survey and submittal ofthe associated report, the NRC will review the report and conduct, as appropriate, theapplicable NRC confirmatory inspections.

5. Upon completion of the YNPS Decommissioning

Project, a final report will be prepared, to summarize the release of areas of the YNPS site from the IOCFR50 license.1.6 Change Criteria for the License Termination PlanYAEC is submitting this License Termination Plan as a supplement to the FSAR. Accordingly, the License Termination Plan will be updated in accordance with IOCFR50.71 (e). Once the LTPhas been approved, the following change criteria will be used, in addition to those criteriaspecified in IOCFR50.59 and IOCFR50.82(a)(6).

A change to the LTP requires NRC approvalprior to being implemented, if the change:(a) Increases the probability of making a Type I decision error above the level statedin the LTP;(b) Increases the radionuclide-specific derived concentration guideline levels(DCGLs) and related minimum detectable concentrations; (c) Increases the radioactivity level, relative to the applicable DCGL, at whichinvestigation occurs;(d) Changes the statistical test applied to one other than the Sign Test or WilcoxonRank Sum Test.(e) Results in use of a null hypothesis other than that stated in Section 5.4.1; that is,"The survey unit exceeds the release criteria."

Re-classification of survey areas from a less to a more restrictive classification (e.g., from aClass 3 to a Class 2 area) may be assigned without prior NRC notification;

however, re-1-9 YNPS License Termination PlanRevision 4classification to a less restrictive classification (e.g., Class I to a Class 2 area) and/or subdivision of a survey area will require NRC notification at least 14 days prior to implementation.

1.7 References

1-1 Title 10 to the Code of Federal Regulations, Part 50.82, "Termination of license."

1-2 Regulatory Guide 1.179, "Standard Format and Content of License Termination Plans forPower Reactors,"

dated January 1999.1-3 NUREG- 1700, Revision 1, "Standard Review Plan for Evaluating Nuclear Power ReactorLicense Termination Plans," dated April 2003.1-4 NUREG-1757, Volume 2, "Consolidated NMSS Decommissioning Guidance,"

datedSeptember 2003.1-5 Yankee Rowe Station 2002 Annual Radiological Environmental Operating Report, datedApril 28, 2003.1-6 Yankee Nuclear Power Station Decommissioning Plan, Revision 0.0.1-7 Letter, M.B. Fairtile (USNRC) to J.A. Kay (YAEC), "Order Approving theDecommissioning of the Yankee Nuclear Power Station, February 14, 1995.1-8 Letter.,

M.B Fairtile (USNRC) to J.A. Kay (YAEC), "Completion of Hearing ProcessRegarding Approval of Decommissioning Plan for the Yankee Nuclear Power Station,October 28, 1996.1-9 NUREG/CR-5849, "Manual for Conducting Radiological Surveys in Support of LicenseTermination,"

dated June 1992.1-10 NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual,"Revision 1, dated August 2000.1-11 Supplement I to NUREG-0586, "Generic Environmental Impact Statement onDecommissioning of Nuclear Facilities,"

dated November 2002.1-12 YNPS Decommissioning Environmental Report, dated December 1993.1-13 "Massachusetts:

2000, Summary Population and Housing Characteristics,"

U.S.Department of Commerce, issued September 2002.1-14 "Vermont:

2000, Summary Population and Housing Characteristics,"

U.S. Department of Commerce, issued October 2002.1-10 YNPS License Termination PlanRevision 41-15 Letter from J. Hickman (USNRC) to W. Norton (YAEC), "Yankee Nuclear PowerStation -Release of Non-Impacted Site Area from Part 50 License,"

dated November 21,2005.1-16 Letter from K. McConnell (USNRC) to W. Norton (YAEC), "Yankee Nuclear PowerStation -Release of Land from Part 50 License,"

dated August 10, 2007.1-11 YNPS License Ten-nination PlanRevision 4Table 1-1Current Nearest Resident, Garden, and Milk Animal Locations within 5 Miles of YNPS (Reference 1-5)SectorNNNENEENEEESESESSESSSWSWWSWWWNWNWNNWNearestResident (mi)3.22.72.12.31.82.11.31.21.30.80.81.31.31.51.8NearestGarden (mi)3.73.02.13.62.32.12.11.21.84.51.21.81.32.02.3NearestMilk Animal (mi)********2.0 ******* No location was identified within 5 miles of the plant.**Limited number of goats. Not able to supply enough milk for sampling.

1-12 YNPS License Termination PlanRevision 4Table 1-2Permanent Population Estimates for Municipalities within10 Miles of the Yankee Nuclear Power Station1980 Census 1990 Census 2000 Census(Ref 1-12) (Ref 1-12) (Ref 1-13 and 1-14)Massachusetts Adams 10,381 9,445 8,809Clarksburg 1,871 1,745 1,686Florida 730 732 676North Adams 18,063 16,797 14,681Savoy 644 634 705Buckland 1,864 1,928 1,996Charlemont 1,149 1,249 1,358Colrain 1,552 1,757 1,813Hawley 280 317 336Heath 482 716 805Monroe 179 115 93Rowe 336 387 351VermontHalifax 488 782 782Whitingham 1,043 1,298 1,298Wilmington 1,808 1,968 2,225Readsboro 638 762 809Stamford 773 773 8131-13 YNPS License Termination PlanRevision 4[7I1-14 YNPS License Termination PlanRevision 4Figure 1-2Historical Site Design1-15 YNrS License Termination Plan Revision 4Sherman Reservoir

.. .............I--.---ILEGENDYankee Rowe Property BoundaryCurrent FencesFamner Fences.Rerns and Strearns300 Meter BuoferAround ISFSIWaterbottes Areas Retained Woe Part So LicenseNote: Fourer strcetneno and plantfeatres shown for reference.

These no longer ewist.N0 ISO 300 600FeetiNN ..- -.. ....., .Yankee Nuclear Power StationROWE, 141-16FIGURE 1-3Current 10 CFR Part 50Licensed Site BoundaryB.,- -l -.ode Gr. .O" ieled o o010-e easche SeetMWebFi: lnllS..d1-16 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 42 SITE CLASSIFICATION Decommissioning activities for and final status survey of the YNPS site, with the exception ofthe ISFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.2.1 Historical Site Assessment and Survey Area Delineation 2.1.1 Approach and Rationale The Historical Site Assessment (HSA) (Reference 2-1) for the Yankee Nuclear Power Station(YNPS) documents those events and circumstances occurring during the history of the facilitythat contributed to the contamination of the site environs above background levels. Information relevant to changes in the radiological status of the site following publication of the HSA will beconsidered a part of the continuing characterization evaluations (see Section 2.6). Thecontinuing evaluations include ongoing decommissioning activities, the expansion of the sitegroundwater investigation and evaluations of subsurface contamination.

The results of theongoing investigations into the extent of subsurface contamination will drive continuing remediation and/or mitigation efforts as appropriate.

The HSA approach collected, organized and evaluated information that described the YNPS sitein terms of physical configuration and the extent to which the site was radioactively contaminated as a result of plant operations and decommissioning activities.

The HSAinformation was used to bound and classify survey areas. The boundaries of the identified surveyareas as depicted in Figures 2-1a, 2-lb and 2-2 were selected based on operational historyincluding recorded significant events, common radiological profiles and where appropriate, parcel ownership boundaries.

The preliminary survey area classifications and sizes are shown inTable 2-1 for structures and Table 2-2 for open land areas. Survey areas for structures will bebroken into multiple survey units where appropriate in order to meet the survey unit sizelimitations recommended by NUREG-1575 (Reference 2-2). All open land survey areaboundaries have been sized to meet the NUREG-1575 size limitation constraints.

The general criteria used to classify the identified survey areas was drawn from the regulatory guidance ofNUREG-1575 (MARSSIM) as follows:2-1 YNPS License Termination PlanRevision 4Non-impacted Area: Area where there is no reasonable possibility (extremely low probability) of residual contamination.

Non-impacted areas are typically off-site and may be used asbackground reference areas.Impacted Area: Any area that is not classified as non-impacted.

Areas with a possibility ofcontaining residual radioactivity in excess of natural background or fallout levels. Allimpacted areas must be classified as Class 1, 2 or 3 as described in NUREG-1575.

Class 1 Area: An area that is projected to require a Class 1 final status survey. Impacted areasthat have, or had prior to remediation, a potential for radioactive contamination (based onsite operating history) or known contamination (based on previous radiological surveys)above the DCGL. Size limitations are 100 sq. m. for structures and 2000 sq. m. openland areas.Class 2 Area: Impacted areas that have, or had prior to remediation, a potential for radioactive contamination or known contamination, but are not expected to exceed the DCGL. Sizelimitations are >100 sq. m. and <1000 sq. m. for structures and > 2000 sq. m. and_< 10,000 sq. m. for open land areas.Class 3 Area: Impacted areas that are not expected to contain any residual radioactivity, or areexpected to contain levels of residual radioactivity at a small fraction of the DCGL, basedon site operating history and previous radiological surveys.

There are no size limitations for Class 3 areas.The collection and evaluation of site radiological information is conducted under approved siteprocedures.

The output of this process is in the form of information generated for each surveyarea that will be used in the preparation of survey plans. Information generated for each surveyarea contains a detailed operational

history, the current radiological status, an evaluation ofradionuclide past and current translocation pathways that have been or continue to be operableand a description and status of decommissioning work performed.

Thedecommissioning workdescription includes the results or status of any subsurface characterization or remediation efforts.The general process for integration of the HSA with continuing characterization and Final StatusSurvey is shown in the following flowchart.

2-2 YNPS License Termination PlanRevision 4Process for Integrating HSA with Characterization and FSSReview YNPS operational history and identify significant events contributing tocontamination of the site.Establish Survey Area boundaries based on common history.Assemble available historical reference documentation into Survey Area packages.

Assign Survey Area Classification.

Publish Historical Site Assessment Document.

Obtain Site-Specific DCGL's.Update Survey Area packages as decommissioning activities progress.

Include resultsof continuing characterization activities and document progress of remediation/

mitigation of sub-surface survey areas.End-state of decommissioning attained.

All areas below appropriate DCGL's.Evaluate Data Quality in survey area packages using DQO/DQA process and preparecharacterization survey plans.Obtain additional characterization data if necessary and document turn-over surveys.Begin Final Status Survey process.2-3 YNPS License Termination PlanRevision 4Over the operational history of the YNPS site, the term "remediation" was often used to refer toany process involving the removal of radioactive media. For the purpose of license termination activities, "remediation" is narrowly defined as efforts specifically conducted to reduce thequantity or concentration of radioactivity to a level below the appropriate Derived Concentration Guideline Level (DCGL). Other processes may be referred to as "mitigation" or routinedecommissioning activities.

2.1.2 Historical Boundaries of the SiteThe YNPS site consisted of about 2,200 acres on both sides of the Deerfield River in the townsof Rowe and Monroe, in Franklin County, Commonwealth of Massachusetts.

Figure 1-1 showsthe historical boundary of the site and historical plant exclusion area.The "YAEC Deed Study Project Rowe and Monroe, Massachusetts,"

dated December 18,1998,(Reference 2-3) provides information concerning properties that make up the YAEC site andcurrent abutments.

YAEC or TransCanada own all of the land located within the property boundary.

All of theproperty within the controlled area boundary is under the control of YAEC. The TransCanada property is generally located along the Deerfield River and Sherman Reservoir.

Portions of theTransCanada property are considered impacted by licensed activities and are generally located atthe northeastern end of the YAEC industrial area, the southern reaches of Sherman Reservoir andthe property outside of the industrial area fence located between Yankee Road and the Deerfield River. These impacted areas are included in license termination activities.

Notable impactedplant structures on the TransCanada property within the former site industrial area included thecirculating water discharge seal pit, the Screenwell Pump House, and the meteorological towerlocated on peninsula at the northeast corner of the site.No public secondary roads traverse the controlled area.During the early site history, a public rail line ran through the industrial area. This rail line andthe associated spur facilitated early construction and spent fuel shipments.

Currently, there areno rail lines that traverse or are adjacent to the YNPS site.Most of the site area is wooded with very steep grades on both sides of the Deerfield River.Features of the site include the the YNPS Independent Spent Fuel Storage Installation (ISFSI),the TransCanada Sherman Station hydroelectric plant, Sherman Reservoir and Dam, thetransmission lines running through the site, and the Yankee Administration Building.

2-4 YNPS License Termination PlanRevision 42.1.3 Documents ReviewedIn performing the YNPS Historical Site Assessment (HSA) the following documents werereviewed:

• License and Technical Specifications

-Technical Specification Changes-License amendments

• Original Plant Design-Function and purpose of systems and structures

-Plant operating parameters

-Plant operating procedures

• Original Plant Construction Drawings and Photographs

-Specifications for systems and structures

-Field Changes/as built drawings-. Site Conditions

• Plant Operating History-Abnormal Operating Reports (AOR)-Licensee Event Reports (LER)-Plant Information Reports (PIR)-Radiological Occurrence Reports (ROR)-Radiological Incident Reports (RIR)-Condition Reports (CR)-Plant Operating Procedures Regarding Spills and Unplanned Releases-Plant Operations Logbooks-Radiological Environmental Monitoring Program and Radiological Environmental Technical Specification Reports (REMP & RETS)-Monthly Plant Operations Reports-Semi-Annual Plant Operations Reports* Work Control Documents and Site Modifications

-Job Orders-Plant Alterations

-Engineering Design Change Requests (EDCR)-Plant Modifications

-Maintenance Requests* Radiological Surveys and Assessments

-Radiological surveys performed in support of normal plant operations andmaintenance

-Radiological surveys performed in support of special plant operations andmaintenance

-Radiological assessments performed in response to radioactive spills orevents2-5 YNPS License Termination PlanRevision 4-Scoping and characterization surveys performed as part of Decommissioning Plan development

-Remediation support surveys conducted during decommissioning activities

-Surveys conducted under the guidance of NUREG/CR-5849 (Reference 2-4)* The historical evaluations performed for the previously submitted LTP.* The YAEC Decommissioning Plan-Decommissioning Work Plans-Secondary Side Work Plans-Engineering Change Notifications

-Field Change Notifications

-Temporary Change Requests* The documented radiological end point of decommissioning activities

• Documentation of remediation area stabilization and restoration activities.

2.1.4 Property Inspections The YNPS site is at an advanced stage of decommissioning with only those plant systemsnecessary to support the ISFSI and portions of the site remaining in service (e.g., potable water,sanitary sewers, construction electrical power, fire protection and storm sewers).

Plantoperations, maintenance and security personnel continue to occupy portions of the site in supportof the YNPS ISFSI operations and maintenance.

Due to the advanced state of decommissioning, these activities have a minimal risk of spreading radioactive contamination.

Historically, decontamination processes were performed on certain site structures and systems ofthe former YNPS as part of site decommissioning activities under the site Decommissioning Plan. These processes included application of chemical paint strippers, dry ice (carbon dioxide)blasting, steel shot blasting and mechanical removal techniques (including rota-peen tools,needle guns, reciprocating chipping hammers and jackhammers).

In addition, both the east andwest storm drain system catch basins have routinely been cleaned of accumulated sediment.

Sediment socks were installed at each catch basin to curtail the build up of sediment in the stormdrain system.Surveys were performed in those areas where decommissioning activities had been completed inaccordance with the protocols established under the previously submitted and withdrawn LicenseTermination Plan (Reference 2-5). Controls were instituted and maintained to preserve theradiological condition of most of these areas, and routine surveys are performed in all of theseareas to verify that the radiological condition of these areas was not adversely impacted byongoing plant operation, maintenance, or fuel transfer activities.

Decommissioning activities have resulted in the disturbance and/or excavation of soils in certainsurvey areas. Extensive soil evaluations were performed in support of soil excavation.

The soilexcavations were associated with removal of sub-grade components/systems and sitemodifications necessary for the construction of the ISFSI and the upgrade of security measuresaround the spent fuel pool. Piles of excavated soil were located in several areas of the site.2-6 YNPS License Termination PlanRevision 4Controls were in place to track the location of these soils from the point of origin (excavation) through temporary onsite storage to final disposition.

Disturbed/excavated soils, evaluated andverified by sampling and analysis protocols to be non-detectable for radiological constituents (below environmental Lower Limit of Detection

[LLD] level for soils) were used as backfill insome excavated areas. Excavated soils contaminated above a Guide Line Value (GLV) protocolwere packaged and disposed of as radioactive waste. This protocol allowed some soilscontaminated above background to be used as backfill in some locations.

Retrospectively, thecriterion is lower than the proposed DCGL. As these areas were evaluated for survey planning, the backfilled soil results were evaluated against the soil DCGL for mitigation action.During the evaluation of survey areas, walk-downs of each area were performed to document thetypes of survey media remaining or expected to remain at end-state.

The walk-downs alsodocumented the current decommissioning status of the area and identified any potential radionuclide translocation pathways that impacted that area or contiguous survey areas. Suchpathways include ongoing decommissioning activities or environmental transport

pathways, suchas sub-surface migration of radioactivity by surface water infiltration, wind, surface water run-off or wildlife.

2.1.5 Personnel Interviews At the time of plant shutdown in 1992, personnel interviews were conducted as a part of an exitinterview process.

Since that time personnel have provided additional information on plantoperations and practices when additional data was needed.2.2 History and Current Status2.2.1 Licensing HistoryYankee Atomic Electric Company is the holder of Yankee Nuclear Power Station FacilityOperating License DPR-3 issued under the authority of the Atomic Energy Commission (AEC).Yankee Nuclear Power Station achieved initial criticality in 1960 and began commercial operations in 1961. The original thermal power design limit of 485Mwt was upgraded to600Mwt in 1963.On February 26, 1992, the YAEC Board of Directors decided to cease power operations permanently at YNPS. On August 5, 1992 the NRC amended the YNPS Facility Operating License to a possession only status.The YNPS Decommissioning Plan (Reference 2-6) was submitted March 29, 1994 and receivedfinal approval in October 28, 1996. In May 1997, Yankee submitted to the NRC for approval aLicense Termination Plan (LTP) for YNPS, pursuant to I OCFR50.82(a)(9).

The initial YNPSLTP employed a survey methodology based upon NUREG/CR-5849.

Subsequently the NRC,jointly with the DOD, DOE, and EPA, approved an alternate survey methodology documented inNUREG-1575 (Reference 2-2). In May 1999, Yankee advised the NRC that it intended to shiftfrom the survey methodology in NUREG/CR-5849 to the NUREG-1 575 methodology, andwithdrew its previously submitted LTP application.

2-7 YNPS License Ten-nination PlanRevision 4In 2000, Yankee created a Post-Shutdown Decommissioning Activities Report (PSDAR) withinthe Final Safety Analysis Report (FSAR). NRC Draft Regulatory Guide DG-1071 recommends that licensees with approved Decommissioning Plans (D Plans) "extract pertinent detail from thedecommissioning plan and submit a PSDAR update in the format and content specified by [DG-107 1]." Based on the NRC draft guidance, Yankee segregated, updated and condensed certaininformation concerning post-shutdown decommissioning activities in a manner that conforms tothe standard format and content of a PSDAR. The current LTP is written to reflect the NUREG-1575 (MARSSIM) methodology, as well as regulatory guidance made available since theprevious LTP submittal.

Decommissioning activities completed as of May 1997 had removed the majority of systems andcomponents not required to support the storage of spent fuel in the spent fuel pool. Detailedplanning for the transfer of spent fuel from the Spent Fuel Pit began in February 2000. In June2003 the transfer of all fuel and Greater Than Class "C" waste from the Spent Fuel Pit to theISFS1 was completed.

On November 21, 2005 and August 10, 2007 (References 2-27 and 2-26), the NRC approved therelease of the majority of the site from the 10 CFR 50 License.

As a result, the only areas of thesite that remain within the control of the 10 CFR 50 License are those areas associated with theYNPS ISFSL, Survey Areas/Units OOL-10-02, NOL-07, and NSY-10.With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel andGTCC waste have been removed from the site, all decommissioning and dismantlement activities have been completed at this site.2.2.2 Regulatory Involvement The NRC monitors YNPS site activities using inspectors from Region I offices to perform onsiteinspections.

Periodic calls are also held with NRC headquarters and Region I staff to monitorplant status and decommissioning progress.

The NRC is notified of any incidents on site per theexisting protocol established with NRC Region I and NRC reporting regulations.

The decommissioning of the YNPS site is also being performed under various Federal, State andlocal requirements in addition to the NRC regulations.

For example, YNPS is subject to 29 CFR1910 and 1926 (Reference 2-7) for worker health and safety protection under OSHA regulations.

Asbestos and lead-based paint handling and removal are subject to OSHA regulations citedabove, and EPA regulations 40 CFR Part 61, Subpart M (Reference 2-8). State and EPArequirements will be met for PCB paint removal activities.

YNPS will also be required to meetthe state standards for surface water and groundwater.

The Commonwealth of Massachusetts Department of Public Health also has state radiological remediation standards.

Compliance with the state standards is not addressed in this document.

This issue will be addressed in separate correspondence with the Commonwealth.

2-8 YNPS License Termination PlanRevision 4Permits and approvals from, or notifications to, several State (Commonwealth) and localagencies are required for safety and environmental protection purposes.

Some of these are forspecific decommissioning activities, and others are for existing YNPS site facilities and ongoingactivities that are necessary to support decommissioning.

The following is a partial listing ofpermits and approvals that were required for decommissioning activities.

A smaller subset ofthese permits and approvals will be required to decommission the ISFSI and the remaining landareas.* Air emissions from the burning of diesel fuel are regulated by the Commonwealth ofMassachusetts Department of Environmental Protection, Air Quality Control Division.

• Non-radioactive liquid effluents are administered by the Commonwealth ofMassachusetts Department of Environmental Protection, Division of Water Pollution Control.* Liquid effluents are controlled under the National Pollutant Discharge Elimination System (NPDES permit) under the EPA and State (Commonwealth) approvals.

• Building permits may be required by the Town of Rowe, Massachusetts, for temporary field office facilities constructed on the plant site to support decommissioning activities.

The Town of Rowe uses the Uniform Building Code for evaluating building permitapplications.

• The site make-up water wells are operated under permits from the Commonwealth ofMassachusetts Department of Environmental Protection, Division of Water Supply.* Hazardous waste generation is regulated by the Commonwealth of Massachusetts Department of Environmental Protection, Division of Hazardous Waste. Notification ofthe generator status and annual reporting are conducted in accordance with Massachusetts regulations.

• The Commonwealth of Massachusetts, Department of Labor and Industries, Division ofIndustrial Safety, regulates the installation, removal and encapsulation of friable asbestos-containing materials and lead-based paint. All non-radiological solid waste will behandled and disposed of in accordance with State and local rules and regulations.

• The Commonwealth of Massachusetts, Department of Public Health, Radiological Control Program, and the Vermont State Health Department, Division of Occupational and Radiological Health, are notified in advance of all placarded shipments of radioactive waste. In addition, the Governors of all affected States receive advance notifications inaccordance with 10 CFR 71.97, "Advance notification of shipment of nuclear waste."" Licenses are required for radio communications by the Federal Communications Commission.

• PCB paints will be removed from all exposed concrete surfaces as required by theAlternate Method of Disposal Authorization (AMDA) requirements prior to demolition of the structures as authorized by the EPA on October 8, 2002 and subsequent changesthereto.2-9 YNPS License Termination PlanRevision 42.2.3 Description of Operations Impacting Site Radiological StatusNormal plant operations were expected to result in contamination of certain areas of the site andthese areas were designed to contain such material;

however, early in the plant life, certainevents and conditions resulted in radioactive material being deposited in other locations.

As aresult, the plant design and operational procedures evolved to accommodate or eliminate thesecircumstances.

Review of the early operational history of the site drew heavily on the PlantSuperintendent's "Monthly Operating Reports".

The following principal events and circumstances, listed in chronological order, contributed tothe residual contamination that needs to be address during decommissioning.

• Release of elemental silver and nickel into the reactor coolant due to mechanical wearand corrosion from the initial set of control rods resulted in distribution of radioactive silver in plant systems and on equipment used during the first refueling.

[circa 1960's]* Storage of the refueling equipment and prepared radioactive waste outdoors resulted indistribution of contamination, including radioactive silver, within the RCA yard area.* Snow removal activities performed in the RCA caused a redistribution of accumulated surface contamination to the areas outside the RCA where snow was relocated.

• Rain falling on the surface of yard areas in the RCA caused redistribution of thecontamination into low areas of the RCA and into the storm drain system.* Leaks in the radioactive systems in the Ion Exchange (IX) Pit resulted in contamination of the water in the IX Pit. A defect in the construction of the IX Pit concrete allowed thecontaminated water to leak, resulting in contamination of the subsurface soils, asphalt andconcrete around the IX Pit and adjoining structures.

" Wear on internal valve components made of stellite resulted in the introduction of wearparticles into the reactor primary system. These particles were activated to gammaemitting Co-60 during plant power operations.

Some particles associated with fuelfragments were also generated during plant operations.

Maintenance on primary systemcomponents resulted in the distribution of these activated particles onto tools andequipment.

Although not a frequent occurrence, Co-60 particles have been identified andremoved during surveys of the yard area. The particles associated with fuel fragments have not been identified in open yard areas but were mostly confined to controlled contamination areas.* A failure of a check valve allowed a backflow of shutdown cooling water to enter the sealwater system resulting in contamination of the normally clean seal water system up toand including the vent port on the PAB roof.2-10 YNPS License Termination PlanRevision 4* Out of doors decontamination facilities (North and South decontamination pads) resultedin contamination of the soils around the pads." The repair of a damaged reactor cooling pump motor on the normally clean turbine deckresulted in contamination of the turbine building generally and on the turbine deck andcontrol room specifically.

• In the mid 1970s YNPS converted from stainless steel to zirconium clad fuel pins. Someof the zirconium fuel pins failed in the reactor due to vibrational stress from water jetting.The pin failure resulted in a release of fuel pellets directly into the reactor coolant system.This event changed the isotopic mix within the Reactor Coolant System. In particular, detectable quantities of fission products such as Cs-137 and Cs-134 were dispersed throughout the primary side plant systems and the fuel handling facility for the first timein the plant operating history.* During a refueling outage in 1981, while relocating the reactor head to its outside storagelocation, the reactor head made contact with the wall above the equipment hatch in theVapor Container.

The impact dislodged particulate radioactivity adhered to the under sideof the reactor head. This resulted in contamination of the RCA yard area under andaround the equipment hatch.* Construction of the original PCA storage facility included a PVC drainpipe thatconnected the PCA storage building to the Waste Disposal Building.

The PVC pipe jointsfailed allowing liquid to flow from the drainpipe into the surrounding soil.* The use of an underwater plasma torch to section the reactor intemals resulted in therelease of highly radioactive cutting debris into the shield tank cavity shield water. Thischanged the radionuclide mix of the residual contamination in the shield tank cavity and,to a certain extent, in the Spent Fuel Pit.The storage of spent nuclear fuel and GTCC waste at the ISFSI until the material is removedfrom site is not expected to result in any releases of radioactive material and minimalcontamination of the ISFSI Vertical Concrete Casks and ISFSI Storage Pad due to activation.

Currently, the spent nuclear fuel and GTCC waste are sealed in welded canisters.

2.2.4 History of Unplanned EventsAs part of the HSA, a comprehensive review of all recorded events documented as havingoccurred outside the normal operational condition was performed to capture those events whichcontributed to the contamination of the site. These events were typically documented in theformat suitable for reporting to regulatory authorities such as Abnormal Occurrence Reports(AOR's),

submitted during the early site history, and Plant Incident Reports (PIR's) or LicenseeEvent Reports (LER's),

submitted through the remainder of plant life. Where available, theinformation in these reports was supplemented by supporting documentation concerning theevents in the form of plant memos and radiological survey data.2-11 YNPS License Termination Plan Revision 42.2.4.1 Unplanned Gaseous ReleasesOver the lifetime of the plant, a number of unplanned gaseous release events occurred.

Shortdescriptions of these gaseous events as described in AOR/PIR/LER's are documented in theHSA. A careful review of these unplanned discharges did not reveal any unmonitored particulate component that could have significantly contributed to the long-term contamination of the site or its environs.

A detailed study of planned particulate releases during the operating history of YNPS ispresented in Section 2.5 as partial justification for the non-impacted status of a majority of theYAEC owned property.

This study considered the impact of the particulate emissions from theprimary vent stack. In this study (Ref. 2-13) it was presumed that the radioactive wasteincinerator operated until 1964. The four years of batch incinerator emissions were considered to be of negligible impact when compared to the particulate releases from the primary vent stackover the life of the plant. Follow-up investigation of the history of the radioactive wasteincinerator revealed that the incinerator actually operated until 1975. The particulate emissions from the radioactive waste incinerator were re-evaluated, and this re-evaluation also concluded that operation of the incinerator has had an insignificant impact on site environs (Ref. 2-18).During the interim storage period, the potential for an unplanned gaseous release of radioactive material does not exist.2.2.4.2 Unplanned Liquid ReleasesSeveral AOR's and PIR's reviewed documented unplanned liquid releases that resulted incontamination of the site grounds, buildings and subsurface locations.

When subsurface contamination investigations were not performed due to inaccessibility or were not completed tothe level suitable for license termination, these locations are targeted for continuing characterization investigation.

Table 2-3 provides a listing of the events identified by the HSAthat have resulted in contamination of the site. Appendix 2A provides a brief summary of eachevent based on documentation prepared at the time of the incidents and an assessment of whichsurvey areas were impacted by the events.During the interim storage period, the potential for an unplanned liquid release of radioactive material does not exist.2.3 Findings2.3.1 OverviewAs described in Section 2.1.1 above, the preliminary boundaries of the survey areas depicted onFigures 2-1a, 2-1b and 2-2 were selected based upon operational radiological history.

Anin-depth assessment of the operational history performed during compilation of the H1SA wasused to bound and classify the survey areas in accordance with the guidance of NUREG-1575.

Survey area classifications are shown in Figures 2-3 and 2-4 in a color-coded site map format.Table 2-1 and Table 2-2 list the survey area dimensions and their classifications in a tabularformat.2-12 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 4Generally, of the approximately 2200 acres of land that comprise the YNPS site, fewer than 30acres was impacted by plant operations.

The majority of these 30 acres is minimally impactedand, as such, is classified as a group of Class 3 open land survey areas. The Class 3 open landsurvey areas identified at a distance from the site industrial area are areas that received

material, primarily soil, from locations within the plant that are impacted areas. The survey areas that formthe perimeter of the impacted areas of the site proper were classified as Class 3 open land surveyareas and account for the potential translocation pathways of site-related radioactivity into thesurrounding environment by winds, surface water, groundwater, and wildlife intrusion.

The Class 2 open land survey areas that abut the Class I open land survey areas are potentially contaminated or known to be contaminated, but are not expected to exceed the DCGL. Thiscreates a buffer zone that will receive a higher level of assessment based upon its likelihood tocontain radioactivity at some fraction of DCGL.Class I open land survey areas are identified based upon historical information indicating thepotential presence of radioactivity at levels greater than DCGL. Table 2-5 summarizes theradiological conditions of open land areas, the associated MARSSIM classifications, and thetotal land area by survey area. The radiological condition of each area is expressed as theminimum, maximum and mean of the sum of fractions of a DCGL for soils.Subsurface soils and subsurface structures/systems located within or that traverse an open landsurvey area will be evaluated separately as part of the continuing characterization processdescribed in Section 2.6 of this document.

All YNPS structures associated with the site were considered impacted to some extent by plantoperations and are located within an impacted land survey area. The majority of the structures were demolished to grade with the debris being removed from site or used as back fill. Theremaining portions of the structures will consist of reinforced concrete floor slabs, foundations and sub-grade structures.

The floor slabs, adjoining interior walls and above grade exterior wallsmay all be included within a given survey unit dependent on surface area size limitations.

Thesub-grade reinforced concrete walls and undersides of floor slabs will be investigated separately.

Table 2-1 summarizes the structure survey area classifications and the total interior area to besurveyed.

A summary of the current radiological conditions of structures and buildings tabulated by survey area is presented in Table 2-4. This information was further evaluated in consideration of the decommissioning activities previously performed, the potential impact of futuredecommissioning activities, and the projected end-state of the site at conclusion of alldecommissioning activities in order to select the preliminary classification status.With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel andGTCC waste have been removed from the site, all decommissioning and dismantlement activities have been completed at this site2-13 YNPS License Termination PlanRevision 42.3.2 Radionuclides of Concern at YNPSAn analysis has been performed to determine the radionuclides that have potential dosesignificance at License Termination (Reference 2-9). This analysis has used three sources ofradionuclide data to assure that all significant nuclides associated with plant operations areidentified.

The sources are selected Part 61 analyses representing several media types spanning atime period from pre-shutdown to the present, radionuclide distributions identified in the YNPSDecommissioning Plan (Reference 2-6) and source term information from NRC published reports.

The significant radionuclides identified from the Part 61 analyses encompassed thoseidentified from the latter two sources.

The final listing of potentially significant radionuclides isshown on Table 2-6.2.4 Impacted Area Assessments The summary assessments provided in Appendices 2B and 2C of this section include adescription, key elements of the history, contaminated media and an evaluation of the principle radionuclides expected to be present in the areas that remain within the control of the 10 CFR 50license.

The summary also includes a current decommissioning status and a description of thework remaining to be done to attain the anticipated end-state.

A survey area classification statement is provided at the end of each assessment.

None of the impacted areas were classified based on the results of scoping or preliminary characterization data. The classifications

assigned, based on historical activities performed in these survey areas alone, are substantiated by the large quantity of scoping data available in the form of soil sample analyses and surveydata. Summaries of the sampling data as shown on Tables 2-4 and 2-5 are compiled frominformation detailed in the YNPS HSA. More detailed descriptions, histories and the radiological status of each of these survey areas are also contained within the YNPS HSA.2.4.1 Buildings, Structures and Open Land Areas Inside the RCAOn November 21, 2005 and August 10, 2007 (References 2-27 and 2-26), the NRC approved therelease of the majority of the site from the 10 CFR 50 License.

As a result, the only areas of thesite that remain within the control of the 10 CFR 50 License are those areas associated with theYNPS ISFSI, Survey Areas/Units OOL- 10-02, NOL-07, and NSY- 10.The following designations are used in identifying survey areas inside of the RCA (Figures 2-3and 2-4):NOL Open Land Areas Inside the RCANSY Yard Structures Inside the RCASummary individual survey area assessments for those areas that remain within the 10 CFR 50License are described in Appendix 2B. NSY-10 and NOL-07 are the ISFSI Pad and the openland area immediately surrounding this structure.

The area was excavated to prepare a suitablesurface for the new concrete pad structure.

The soils removed from this excavation wereevaluated by composite sampling and found to contain only naturally occurring radionuclides.

2-14 YNPS License Termination Plan Revision 4The pad and surrounding land have been assigned a Class 3 status pending further evaluations following the final disposition of the spent fuel containers.

2.4.2 Buildings, Structures and Open Land Areas Outside of the RCAOn November 21, 2005 and August 10, 2007 (References 2-27 and 2-26), the NRC approved therelease of the majority of the site from the 10 CFR 50 License.

As a result, the only areas of thesite that remain within the control of the 10 CFR 50 License are those areas associated with theYNPS ISFSI, Survey Areas/Units OOL-10-02, NOL-07, and NSY-10.The following designation is used in identifying the remaining survey area outside of the RCA(Figures 2-3 and 2-4):OOL Open Land Areas Outside the RCAThe Summary individual Survey Area assessment for the area that remains within the 10 CFR 50License is described in Appendix 2C. In general, the impacted areas immediately outside theconfines of the historical RCA have been assigned a NUREG-1 575 Class 2 status. These bufferzones are areas where radionuclides may have migrated beyond the RCA boundary due toenvironmental or other translocation vectors.The remaining impacted area is assigned a Class 3 status. This area is not expected to containradioactivity in excess of a small fraction of the appropriate DCGL.2.5 Non-Impacted Area Justification On November 21, 2005 and August 10, 2007 (References 2-27 and 2-26), the NRC approved therelease of the majority of the site from the 10 CFR 50 License.

As a result, the only areas of thesite that remain within the control of the 10 CFR 50 License are those areas associated with theYNPS ISFSI, Survey Areas/Units OOL-10-02, NOL-07, and NSY-10.2.5.1 Non-Impacted Area Description The majority of the land surrounding the industrial area of the site was classified as non-impacted according to MARSSIM criteria.

This portion of the site is open land consisting ofapproximately 2170 acres. The non-impacted land surrounds the industrial area and all otherroutinely utilized areas. The non-impacted area is bounded on the east and south by MonroeState Forest, on the southeast by TransCanada

property, on the west by Readsboro Road (withthe exception of an 89 acre plot on Kingsley Hill Road), and on the north by theMassachusetts/Vermont state line. The non-impacted area was not involved in plant operations and consists mostly of rugged terrain which is forested'and undisturbed.

Power lines traverse the2-15 YNPS License Termination PlanRevision 4area in a northeast by east direction (see Figure 2-5). The general site is shown on USGS mapRowe, Massachusetts-Vermont (Reference 2-10).2.5.2 Decommissioning Activities There were no decommissioning or remediation activities performed in the non-impacted area.Most of the area is forested.

The power line right-of-way is cleared of trees.2.5.3 Basis of Area Classification The survey unit is classified as "non-impacted" because there is no reasonable possibility ofresidual contamination based upon the following (References 2-11, 2-12 and 2-13):" Samples collected as part of the Radiological Environmental Monitoring Program (REMP)throughout the plant's operational and post-operational history show no evidence of anysignificant radiological impact due to plant operations;

• Aerial photographs from 1966, 1970, 1974, 1980, 1981, 1982, 1989, and 1990 show noevidence of soil disturbance;

" A conservative evaluation of the impact of particulate effluents to soils outside of theindustrial area using a Gaussian dispersion/deposition model substantiates the conclusion thatthis source of plant-derived radioactive material would be expected to contribute (at amaximum) a very small fraction of the DCGL. Beyond the impacted area boundary, concentrations of this plant-derived radioactive material would be non-detectable andindistinguishable from background;

• A statistical comparison of soil sample analytical data from the non-impacted area and anenvironmentally equivalent reference area (unaffected by plant releases) was performed.

2.5.4 Occurrence of Anthropogenic Radionuclides in the Environmental

Background

According to the National Council on Radiation Protection and Measurements (References 2-14,2-15 and 2-16), radionuclides present in environmental background are both naturally occurring and man-made.

Carbon-14 is introduced cosmogenically and by the atmospheric detonation ofnuclear weapons.

Tritium is also introduced cosmogenically and through atmospheric detonation of nuclear weapons.

Cesium- 137 and Strontium-90 are fission products that occur in theenvironment as a result of atmospheric nuclear weapon detonations.

The range of concentrations of Cs- 137 in environmental background due to fall-out fromatmospheric atomic device testing is easily detectable in soil. Both Cs-137 and Sr-90 are fissionproducts with similar half-lives.

Accordingly, it is expected that Sr-90 due to fall-out from2-16 YNPS License Termination PlanRevision 4atmospheric testing would also occur in the environment where weapons derived Cs-137 ispresent.2.5.5 Evaluation of the Impact of Elevated Releases of Particulate Radioactive MaterialCovering the operating history of YNPS, YRC-1 178 (Reference 2-11) provides a conservative evaluation of the deposition of particulate activity in gaseous effluents on soils in the impactedarea downwind of the Primary Vent Stack (OOL-08, a historical survey area that has beenreleased from the 10 CFR 50 License).

The study examined Semi-Annual Effluent Reports andMonthly Operating Reports that contain the total activity, by radionuclide, released from theplant in particulate form of gaseous effluents.

The particulate fraction released from the PrimaryVent Stack is determined from analyses of the waste gas discharge.

The gaseous fraction of theeffluent was disregarded when considering the impact to soils since there is no expectation thatthis fraction would be deposited.

The individual radionuclide activity annual data were decay-corrected to the time of YRC-I 178 (1998). A conservative atmospheric deposition factor wasdeveloped and applied to the decay-corrected particulate fraction of released activity todetermine the maximum residual deposition on an area extending 100-200 meters beyond theindustrial area boundary.

The long-term average deposition factor was derived from plantspecific meteorological and structural data and was determined to be 8.79E-08m-2.Soilradioactivity concentrations based on a penetration depth of 15 cm and a density of 1.6 gm/ccwere calculated to be:* Sr-90: 2.56E-4 pCi/g* Cs-134: 4.91E-7 pCi/g* Cs-137: 1.01E-4 pCi/g" Co-60: 1.3 1E-4 pCi/gThese values are below the expected site-specific DCGLs and minimum detectable activities (MVDAs).

These projections demonstrate that the concentration of gaseous effluent-derived radioactive material in area OOL-08 (an impacted area) is expected to be much less than the soilDCGLs. Since the non-impacted area is further from the source, plant-derived radioactive material concentrations would be even lower than those typical of survey area OOL-08 (ahistorical survey area that has been released from the 10 CFR 50 License).

2.5.6 Statistical Evaluations 2.5.6.1 Description of Reference AreasCesium-l137 derived from atmospheric nuclear weapon detonations occurs in all land areas,regardless of their proximity to YNPS. In order to assess properly the impact of plant operations alone on the non-impacted area of the site, the contribution from this source of Cs-137 must bequantified.

To that end, reference areas that were not reasonably expected to contain plant-derived Cs-137 were identified.

Reference 2-17 describes the selection

criteria, sampling2-17 YNPS License Termination PlanRevision 4protocol, and summary results for these reference background areas. The areas selected were inthe vicinity surrounding Pelham Lake. This area was selected for the following reasons:* It is the direction of least prevalent winds, and therefore has the least likelihood ofhaving been impacted by YNPS air effluents.

• It is in a separate valley and there is no known surface or groundwater communication between the two valleys.

Therefore it most likely has not been impacted by liquideffluents.

• It has soil and flora typical of the non-impacted survey area surrounding the YNPS site.2.5.6.2 Approach and Methodology for Evaluation of the Non-Impacted AreaThirty (30) surface soil samples were collected from the non-impacted area in August 1998. Thelocations of each sample point and the general location of the plant site relative to the surveyarea are presented in Figure 2-5. Sixty surface soil samples were also obtained (in 1996) from aselected reference area beyond the boundaries of the YNPS-owned property as described inSection 2.5.6.1.

The means and maximum values of the reference background area and the non-impacted areas compare favorably with the global concentrations of Cs- 137 found fromatmospheric deposition in topsoil.Two types of statistical tests were performed to evaluate whether the soils from the non-impacted area contain excess Cs-137 relative to the soil samples from the reference area. These analysesare presented in Reference 2-11. The Student t-test was used to compare the mean values of thetwo data sets. The second test was a single-tailed Fisher's "F-Test" of the variances of theCs-137 concentrations in the reference area and the non-impacted area. This comparison is alsoknown as the Analysis of Variance or the Variance Ratio. The test compares the variances ofboth data sets.Additional statistical analyses were performed on the shapes of the sample distribution toprovide additional evidence that these two distributions may have the same source. These weretests for skewness and normality.

These tests indicated that the parameters for the data sets arealike.2.5.7 SummaryThe classification of the area as non-impacted is based upon historical photographs, results ofRadiological Environmental Monitoring Program surveys, particulate gaseous effluentdeposition modeling and a statistical analysis of Cs-137 soil concentrations relative to a set ofbackground reference areas.2-18 YNPS License Termination PlanRevision 42.6 Investigation of Subsurface Contamination Subsurface radioactivity is residual radioactivity that is underneath structures such as buildingfloors/foundations or that is covered with soil or some other material.

The reasons for this vary.Survey area information, as presented in the YNPS HSA, is the primary resource for identifying areas that may require subsurface investigation.

Appropriate samples will be obtained to identify the depth at which contamination, if any, aboveDCGL limits occurs. The evaluation of soil under concrete and asphalt will also be addressed.

Survey plans will be developed for sampling of soil under contaminated slabs, especially at thelocation of expansion joints, cracks, and other potential contamination pathways from theconcrete surface to the sub-slab soil.Subsurface investigations will include collection of soil cores. Evaluation of these cores mayinclude segregating them into smaller increments, based upon measurements from fieldscreening techniques.

Figure 2-6 illustrates the locations where targeted subsurface investigations will be performed.

Finding activity in subsurface soil above the DCGL willprompt further investigation in order to determine the horizontal and vertical extent of thecontamination.

The investigation will continue until the area of contamination is well defined.This is generally accomplished when the activity in soil from peripheral cores is less than theDCGL. The conclusion in that case is that the investigation has bounded the extent ofcontamination.

All subsurface areas known to be impacted will be investigated and soilradioactivity levels will be reduced to less than the soil DCGL.Following the remediation/mitigation of all targeted subsurface locations and as part of the finalstatus survey program, a series of systematic subsurface borings will be conducted in the areadelineated in Figure 2-6. Radiological evaluations of volumetric material in the vertical columnat each subsurface survey location will be performed to substantiate the evaluation that allsubsurface locations have been identified and are below the clean-up criteria.

2.7 Investigation of Groundwater Contamination 2.7.1 HistoryThe basic site geology has been well documented in licensing studies and documents.

Figure2-7 illustrates the locations of groundwater monitoring wells. The first site monitoring wells, B-1and B-3, were installed within the Radiologically Controlled Area (RCA) in December 1977 andOctober 1979, respectively.

Well B-3 was used to monitor groundwater level, and no sampleswere analyzed for radionuclides.

Well B-3 was closed in January 1997.Following the decision to terminate plant operation, monitoring wells CB-1, -2, -3, and -4, andCW-1, -2, -3, -4, -5, and -6 were installed just down gradient of locations where spills or leaksare known to have occurred.

The location, extent and impact of leaks resulting in thecontamination of the site are discussed in the Historical Site Assessment and have beensummarized in previous subsections of this LTP.2-19 YNPS License Termination PlanRevision 4The YNPS Radiological Environmental Monitoring Program (REMP) has identified tritium inSherman Spring. Tritium was also identified in samples routinely drawn for REMP frommonitoring well B-1. The identification of H-3 in the groundwater as a substance of concern wasdocumented in the YNPS Decommissioning Plan; however, recent samples have not detectedtritium in Sherman Spring.The additional wells installed after 1993 further defined the extent of H-3 migration beneath theplant industrial area and toward the Deerfield River and Sherman Dam. Analyses for H-3 fromwells, along with REMP results for Sherman Spring, provided a working model for groundwater flow in the shallow outwash aquifer beneath the site. They also served as a basis to help locateadditional monitoring wells (CB-6, -8, -9, CW-7, and -8) installed in 1994 to further definegeneral groundwater flow and the H-3 plume at the site. The shape of the H-3 plume, based onanalyses from the above wells, is shown in Figure 2-8.Additional core borings that serve as draw points for groundwater samples (CB-5, -7, -8, -10,and -12, and CW-10) were installed up gradient or cross-gradient of the PAB/SFP/IX Pitcomplex, in impacted locations beneath building slabs. While these are not actual monitoring wells with installed

screens, they do provide scoping type groundwater data when water ispresent within the bore holes.A series of deep-bedrock wells were installed during the summer of 2003 in order to investigate the possible existence of a deep plume of contamination.

The wells currently in existence, thatwere installed prior to 2003, are at the level of the glacial outwash or in unfractured till. Thesewells monitor the concentration of the radionuclides in the groundwater to depths of about 30-70feet. The new wells investigated depths to bedrock which ranged from 43 to 280 feet.Figure 2-7 shows the location of bedrock monitoring wells (MWIOO-107).

The designation

'A','B', or 'C' for these wells signifies

outwash, bedrock, or intermediate depth wells, respectively.

Intermediate wells were installed at depths where aquifers were encountered that yielded positivetritium results.2.7.2 Evaluation of Historical DataFigure 2-8 shows data for H-3 insamples taken from wells near the plant structures.

CB-I IA was installed in the PAB following detection of H-3 in the standing water that wasexposed during removal of the concrete floor in that building in 1997. Subsequent samples fromthat well revealed elevated H-3 concentrations in a highly localized zone. Several newmonitoring wells were placed in the vicinity of that well to allow sampling of that area.A document had been prepared to address the set of groundwater data existing as of 2001(Reference 2-19). This document was reviewed, and the review and resulting recommendations were documented in Reference 2-20. These recommendations led to revisions to thegroundwater monitoring program.2-20 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 42.7.3 Groundwater Monitoring ProgramThe NRC provided the following conclusions regarding the Groundwater Compliance Plan in theSafety Evaluation Report issued on August 10, 2007 (Reference 2-26)."As documented in Final Groundwater Condition Report dated February 15, 2007,YAEC has calculated the maximum concentration in the resident farmer's well as of April2007 to be 8150 pCi/L, well below the 20,000 pCi/L limit."The staff reviewed YAEC's confirmation of groundwater compliance dated April 24,2007, for the YNPS. In that document, YAEC demonstrated license termination compliance for the groundwater at the YNPS site as specified in its Groundwater Compliance Plan dated August 31, 2006."This demonstration included the following items:* A summary of the five quarters of radiological sampling data for 53 monitoring wells and Sherman Spring,* Confirmation that no radionuclides other than tritium have been detected in thegroundwater exceeding License Amendment No. 158 action levels, and* Confirmation that tritium concentrations in a resident farmer's well nearmonitoring well MW-107C is less than the EPA's MCL (20,000 pCi/L)."In addition, YAEC committed in its Groundwater Compliance Plan to provide astatistical trend analysis of tritium at each monitoring site for the five quarters.

All themonitoring sites except monitoring well MW-1I OC had a stable or downward trend fortritium during this time period. The tritium in well MW- I OC has increased slightly overthis time period from 1,160 to 2,040 pCi/L, which is approximately 10 percent of thetritium MCL. The staff did not consider this upward trend significant.

"The NRC has reviewed the licensee's groundwater sampling documents and analysisand agrees that the acceptance level, as documented in the LTP, has been met andtherefore, groundwater compliance with the release criteria has been achieved."

2.8 Continuing Characterization Activities (as of October 2013)With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel andGTCC waste have been removed from the site, all decommissioning and dismantlement activities have been completed at this site.2-21 YNPS License Termination PlanRevision 42.8.1 Introduction Surveys of impacted site structures and open land areas will be performed to support final statussurveys for surfaces, materials, and soils that will remain at the time of license termination.

Thisincludes concrete building floors at ground level, concrete building foundation walls andfootings below ground level, asphalt covering the soil in open areas, and soil. Some of the soilsto be characterized are located beneath the concrete floors and asphalt.

Materials from structures will be dispositioned either under the free release criteria (consistent with the guidance of NRCCircular IEC-81-07, "Control of Radioactively Contaminated Material")

or FSS and may be usedas backfill.

Sub-grade structures that are not part of a designated structural survey area (e.g.,concrete support structures) will be evaluated within the overlying open land survey area orsubsurface survey area when they are potentially impacted by the migration of sub-surface contamination.

Confirmatory spot checks on other such sub-surface structures or objects willvalidate a non-impacted status where appropriate.

The remaining investigation activities are of two general types:* Survey used to determine the presence of radioactivity (impacted or non-impacted),

or" Survey performed with final status survey quality requirements that may be used as afinal status survey if the release criteria are met.In the case of the first type of survey, the quality requirements invoked will be specific to thepurpose of the investigation.

If the survey will be used in support of FSS design elements, thenthe data quality objective (DQO) process typically applied to the FSS plan design will be appliedto this survey.2.8.2 Characterization Survey Plans Prepared Under a Quality Assurance ProjectPlan (QAPP)Characterization Survey planning includes review of the Historical Site Assessment (HSA),scoping survey data, DCGLs, and other relevant information supporting the initial classification of the survey area or unit.The DQO process described in MARSSIM is implemented by generation of a survey plan. TheDQO process is a series of planning steps for establishing criteria for data quality and developing survey designs.

The goals of this process are to provide a more effective survey design and abasis for judging the usability of the data prior to collection.

DQOs are statements intended toclarify the survey objectives, define the types of data to be collected, and specify the limits onthe decision errors used as a basis for establishing data requirements.

The impetus of this DQOplanning process is a Quality Assurance Project Plan (QAPP). This QAPP integrates all technical and quality aspects of the project and details how these elements will be implemented.

The survey design includes the selection of instruments and techniques needed to provide scans,static measurements, and samples of the proper quality and quantity to allow decisions to bemade regarding the suitability of the current MARSSIM area classification.

Technical basis2-22 YNPS License Termination PlanRevision 4documents will be developed as needed to justify the use of the measurement methods and toassess instrument detection limits.Approved site procedures for field and laboratory instrument calibration and operation, surveytechniques and reporting, data entry and management, and training and qualification of personnel will ensure that the plan is implemented consistently and according to applicable standards.

2.8.3 Characterization Survey PlansThe purpose of a Characterization Survey Plan is to describe the methods to be used in theplanning, design, execution, and evaluation of characterization surveys.

The "as found"condition of a given survey area is documented in the survey area classification packages.

Thesepackages contain sufficiently detailed information on the operational history and currentdecommissioning status to allow generation of a Characterization Survey Plan or to use theexisting data provided it is qualified to be adequate as characterization data. If the completed classification package indicates that additional characterization is required to investigate potential presence of plant-derived radionuclides on the exterior of sub-grade surfaces or beneaththe concrete floor of the end state structure, the results of such investigations will be included inthe survey area classification information.

2.9 References

2-1. YAEC Historical Site Assessment.

2-2 NUREG-1575:

Multi-Agency Radiation Survey and Site Investigation Manual,Revision 1, dated August 2000.2-3 YAEC Deed Study Project Rowe and Monroe, Massachusetts, dated December 18, 1998.2-4 DRAFT NUREG/CR-5849 (ORAU 92/C57):

"Manual for Conducting Radiological Surveys in Support of License Termination,"

by J.D. Berger, dated June 1992.2-5 YAEC License Termination Plan, dated December 1997.2-6 YNPS Decommissioning Plan, dated March 29, 19942-7 Title 29 Code of Federal Regulations, "Labor."2-8 Title 40 Code of Federal Regulations, "Protection of Environment."

2-9 Technical Basis Document YA-REPT-00-001-03, Radionuclide Selection for DCGLDetermination, dated November 5, 2003.2-23 YNPS License Termination Plan Revision 42-10 USGS topographic quadrangle Rowe, Massachusetts

-Vermont, 42072-F7-TM-025, dated 1990.2-11 Technical Basis Document YA-REPT-00-006-03.,

"Statistical Evaluation of Non-Impacted Area, Evaluation of 137Cs Concentration in Soils of Non-impacted andReference Areas in the Vicinity of YNPS."2-12 EG&G 10617-1233, UC-702, "An Aerial Radiological Survey of the Yankee RoweNuclear Power Station and Surrounding Area," EG&G Energy Measurements, datedSeptember 1993.2-13 YRC-1 178, Radionuclide Soil Concentrations Surrounding YNPS Resulting fromGaseous Release During Plant Operation, dated March,1998.

2-14 NCRP Report 47 "Tritium Measurement Techniques,"

dated May 28, 1976.2-15 NCRP Report 50 "Environmental Radiation Measurements,"

dated December 27, 1976.2-16 NCRP Report 81 "Carbon-14 in the Environment,"

dated May 15, 1985.2-17 RP 98-20, "Technical Basis Document for Background Concentrations of Cesium-137 inSoil and Sediment,"

RP 98-20, dated March 3, 1998.2-18 YA-REPT-00-002-04, "Evaluation of Effluent Releases from Onsite Incineration ofWaste," dated May 24, 2004.2-19 DESD-TD-YR-02-001, "Site Ground Water Data Collection for YNPSDecommissioning,"

dated February 2002.2-20 Letter L02-91, from Eric L. Darois (RSCS) to Greg Babineau (YAEC), datedDecember 12, 2002.2-21 YA-REPT-01-005-03, "Yankee Nuclear Power Station Report of Radionuclides inGroundwater, Rev. 1 (Third Quarter 2003, Interim),"

dated January 2004.2-22 YA-REPT-00-004-04, "Hydrogeological Report of 2003 Supplemental Investigation,"

dated March 15, 2004.2-24 YNPS License Termination PlanRevision 42-23 BYR 2006-074, "Submittal of Groundwater compliance Plan for License Termination atYNPS," dated August 31, 2006.2-24 BYR 2007-016, "Final Groundwater Condition Report,"

dated February 15, 2007.2-25 BYR 2007-034, "Confirmation of Groundwater Compliance,"

dated April 25, 2007.2-26 NYR 2007-046, Letter from K. McConnell (USNRC) to W. Norton (YAEC), "YankeeNuclear Power Station -Release of Land from Part 50 License,"

dated August 10, 2007.2-27 Letter from J. Hickman (USNRC) to W. Norton (YAEC), "Yankee Nuclear PowerStation -Release of Non-Impacted Site Area from Part 50 License,"

dated November 21,2005.2-25 YNPS License Termination PlanRevision 4Table 2-1Floor and Total Area of Buildings and FeaturesSURVEV AREA DESCRIPTION NMARSSIM FLOOR TOTAL AREA RATIO (total:CLASS AREA (m2) (12) I floor)NSY-10 IISFS 3 985 1078 1.09* Survey area designations apply to structures that will remain intact.2-26 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 4TABLE 2-2Area of Open Land Survey AreasSURVEY AREA DESCRIPTION MARSSIM AREA (m2)CLASSOOL- 10 ISFSI/ACCESS, EXCLUSION ZONE, BUFFER ZONE 2 8408NOL-07 ISFSI RCA YARD 3 17172-27 YNPS License Termination PlanRevision 4Table 2-3AOR I PIR List of Unplanned Liquid ReleasesThis list addresses unplanned liquid releases that impacted survey areas that have been releasedfrom the 10 CFR 50 License.

This information is being retained to establish that there were nounplanned releases that impacted the survey areas that remain within the license (i.e., OOL-10-2, NSY-10, and NOL-7).Impacted Survey AOR/ Description Area PIR #NOL-2/NOL-5 61-15 Radioactive Spill -9/20/61NOL-l/NOL-2 and 63-12 Shield Tank Cavity Fill Water Spill -9/18/63NSY-2OOL-5/OOL-6 63-17 De-watering Pump Packing Leakage -10/8/63AUX-1 64-08 Seal Water Tank Spill -9/3/64NOL-I/NSY-2 and 64-13 IX Pit High Level -Leakage Coming Up through PavementI-OOL-5/OOL-6 10/3/64SFP-1/NOL-l/

66-07 Spent Fuel Pit Water Spill -9/27/66OOL-1OOL-5/OOL-6 66-08 Abnormal Activity in Storm Drain -9/27/66NOL-1/OOL-l 66-09 Hose Failure -11/1/66NSY-7 68-01 Waste Hold-up Tank Moat Spill -1/16/68NOL-1 thru 6 75-07 Yard Area Contamination

-7/16/75NOL-2 77-16 Service Building Radioactive Sump Transfer Line Puncture

-12/21/77NOL-2/NSY-2 80-09 Resin Spill -8/6/80NOL-1/NOL-6 81-09 Contamination of Yard Area During Rx Head Removal -5/15/81OOL-12/OOL-13 and OOL-1WST-1/WST-2 84-16 Drain Pipe Failure2 -9/10/84and WST-3NOL-1 94-03 Leakage from Frozen Fuel Chute Dewatering Line 2/17& 18/94NOL-1 94-09 NST Tell-Tales/Fuel Chute Dewatering Line 2/23/94Routine leakage points, paths for subsurface contamination.

2-28 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 4TABLE 2-4Current Radiological Conditions of Buildings in the Industrial Area by Survey AreaSurvey Description Nominal Nominal loosearea exposure rate surface(jar/hr) contamination (dpm/100cm2)

NSY-10 ISFSI 2000-5000

<1000Note: The entry in BOLD in the table is currently in use.2-29 YNPS License Termination PlanRevision 4Table 2-5Summary of Radiological Conditions of Open Land Areas(SOF = Sum of Fractions of Proposed Soil DCGLs as submitted)

• SURVEY DESCRIPTION MARSSIM MEDIUM SOF SOF SOFAREA CLASS (min) (max) (mean)OOL-10 ISFSI/Access, Exclusion Zone, Buffer 2 Soil 0.010 1.202 0.089ZoneNOL-07 ISFSI RCA Yard 3 Soil 0.012 0.054 0.023* Statistics (min, max and mean) are based upon 10 mrem/yr DCGLs and are biased high sincesample results are not decay corrected and only samples with results greater than 2 sigma areincluded in the evaluated population.

2-30 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 4Table 2-6Radionuclides of Concern At YNPSRadionuclide Half-Life (in years)H-3 1.228E01C-14 5.730E03Fe-55 2.700E00Co-60 5.271E00Ni-63 1.001E02Sr-90 2.860E01Nb-94 2.030E04Tc-99 2.130E05Ag-l108m 1.270E02Sb-125 2.770E00Cs-134 2.062E00Cs-137 3.017E01Eu- 152 1.360E0Eu-154 8.800E00Eu-155 4.960E00Pu-238 8.775E01Pu-239,240 2.413E04Pu-241 1.440E01Am-241 4.322E02Cm-243,244 2.850E012-31 YNPS License Termination PlanRevision 4Appendix 2ASummaries of the Significant Events Leading toLong-Term Contamination of the YNPS Site(Presented in LTP Table 2-3)2A-I YNPS License Termination PlanRevision 4This list addresses events that impacted the site, including survey areas that have been releasedfrom control in accordance with 10 CFR 50 License.

This information is being retained toestablish that the impact on the survey areas that remain within the license (i.e., OOL-I 0-2,NSY- 10, and NOL-7).AOR 61-15: Radioactive Spill -9/20/61A half-liter container of reactor coolant water was dropped on the asphalt in the Potentially Contaminated Area between the Primary Auxiliary Building and the Waste Disposal Building.

The sample contained approximately 35 ýtCi (specific radionuclide data not available).

The spillwas absorbed using absorbent paper and the area decontaminated by mopping.

The fixedcontamination remaining was approximately 0.05 mr/hr at 1 inch from the pavement.

Impacted Areas NOL-02/ NOL-05AOR 63-12: Shield Tank Cavity Fill Water Spill -9/18/63A one-half inch sampling valve located over the IX Pit was inadvertently left open while fillingthe shield tank cavity. This resulted in a spill of approximately 10 gallons of water from theSafety Injection Tank. A portion of the spill ran off the deck of the pit and onto a section of theblacktop surface to the west of the pit. The radiation level in the immediate area was 70-100mr/hr measured at one inch. Contamination levels were 106 to 107 dpm (specific radionuclide data not available) over areas of several square inches. Run off water resulted in contamination levels of 20-60,000 dpm/ft2 (Sic).Impacted Areas NOL-01/NOL-02 Impacted Structures NSY-02AOR 63-17: De-watering Pump Packing Leakage -10/8/63A water leak from the fuel chute de-watering pump was routed, via a small utility hose, to a 30gallon collection drum placed in a storm drain catch basin (ECB-005) located between therailroad tracks and the NE comer of the spent fuel pit. It was determined that the bottom rim ofthe barrel was corroded, and water was leaking from the bottom of the barrel. At the time theleak was identified, six to eight inches of water had accumulated in the barrel with activity of 6 x10-5 ýCi/ml (specific radionuclide data not available).

It was believed only a small amount ofwater was leaked to the storm system.Impacted Areas OOL-05/OOL-06/NOL-01 Impacted Sub-surface Areas/Structures

-East Storm Drain SystemAOR 64-08: Seal Water Tank Spill -9/3/64Shutdown cooling pump seals leaked reactor coolant water and back-flowed into the seal watertank. This caused the tank to overflow through the vent connection, into the common reliefvalve discharge line and onto the Primary Auxiliary Building roof. An estimated 35 gallons ofwater containing a total activity of 270 ýtCi (specific radionuclide data not available) wasreleased.

The Roof Drain System drained into the Storm Drain System via a sub-surface pipingconnection.

A sample of the storm drain (WCB-009) was determined to contain I x 10-6 luCi/ml.The predominant isotopes were Co-58, Co-60 and Mn-54 (distribution of the radionuclides in thesample not available).

Service Water was diverted to the storm drain to flush the system.Impacted Areas -AUX-02 Roof and Roof Drain SystemImpacted Sub-surface Areas/Structures

-West Storm Drain System2A-2 YNPS License Termination PlanRevision 4AOR 64-13: Leakage from Ion Exchange Pit -10/3/64After filling the Ion Exchange Pit to its normal operating level, the operator failed to close the fillvalve. Water continued to flow into the pit from the Primary Water Storage Tank by gravityfeed. Later, the operator noticed water seeping through the blacktop on the west side of the pit,diagnosed the cause and closed the valve. The water on the blacktop was sampled and was foundto contain radioactivity.

The radionuclides and concentrations identified were: Ag-i 1Oim at 5 x10"7 p.Ci/ml and Co-60 at I x 10-6 ptCi/ml.

The blacktop was rinsed down with Service Water tothe storm drain (ECB-005).

Impacted Areas NSY-02/NOL-01/OOL-05/OOL-06 Impacted Sub-surface Areas/Structures

-East Storm Drain System internal and external topiping (backfill)

/ SFP-02 sub-floor

/ NSY-09 /AUX-01 North external perimeter (backfill)

/SFP-01 West external perimeter (backfill)

/ BRT-01 Eastern external perimeter AOR 66-7: Spent Fuel Pit Water Spill -9/27/66A two-inch priming valve for the Spent Fuel Pit (SFP) cooling and purification pump was leftopen; however an upstream valve isolating make up water to the Low Pressure Surge Tank(LPST) was correctly closed. The LPST make up pump was started to provide make up water toa hose connection located between the two valves to wash down a shipping cask as it wasremoved from the pit. Water flowed through the open priming valve to the SFP in sufficient quantity to result in actuation of the high level alarm. The reason for the high level alarm was notimmediately determined and by the time the reason was identified water had overflowed fromthe SFP. Approximately 33 gallons of water flowed down the SFP exterior wall, over a smallsection of asphalt paving and into an immediately adjacent storm drain, ECB-005.

A continuous service water flush of the east side culvert system (ECB-005) was initiated and continued for a24 hour period. This occurrence resulted in a total release of 4 jiCi gross P3-7 and 670 ptCi oftritium (more specific radionuclide data not available).

Impacted Areas SFP-01 North external wall /NOL-01/OOL-01 Impacted Sub-surface Areas/Structures East Storm Drain System internal and external topiping (backfill between SFP-01 and ECB-005)AOR 66-8: Abnormal Activity in Storm Drain -9/27/66Water from the west storm drain culvert was sampled (the SFP water released discussed abovedischarged to the east side only). An average of two samples from the west side showed grossactivity of 6.7 x 10-7 pCi/ml (specific radionuclide data not available).

Investigation found arelief valve on the safety injection tank heating system to be slowly leaking into a floor drain inthe PAB. The floor drains in that section of the building were traced to discharge to a stormdrain located on the outside of the building (WCB-009).

Further investigation indicated that therelief valve leak could not have existed for more than one day and that the maximum volume didnot exceed eight gallons during that period. A sample of culvert water collected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> afterthe occurrence indicated a gross activity of 1.2 x 10-8 ýtCi/ml and tritium activity of 5.1 x 10-5pCi/ml. This occurrence resulted in a total release of 0.8 pCi gross P-y and 3.32 mCi tritium.Impacted Area -OOL-05/OOL-06 Impacted Sub-surface Areas/Structures

-West Storm Drain system2A-3 YNPS License Termination PlanRevision 4AOR 66-9: Hose Failure -11/1/66The hose used for a routine draining of the fuel chute pump discharge line burst. Less than 10gallons of contaminated water flowed into a storm drain served by the east culvert (ECB-005).

Approximately 10 gallons of water with an activity of 3.0 x 10-3 jCi/ml (for a total of 113 40Ci)was released.

The spill area was flushed with service water. The east culvert was sampled afterthe spill.Impacted Areas -NOL-01/OOL-01 Impacted Sub-surface Areas/Structures

-East Storm Drain systemAOR 68-1: Waste Holdup Tank Moat Spill -1/16/68The suction line from the waste hold-up tank was found to be frozen. Approximately 200gallons of water spilled from a valve bonnet failure caused by the freezing of the suction line. Atotal of 520 ltCi P3-7 and 698 mCi tritium were spilled into the moat. The spill was contained within the moat structure.

Impacted Structures

-NSY-07PIR 75-7: Yard Area Contamination 7/16/75An area of land near the Ion Exchange Pit was identified with a contamination level ofapproximately 500,000 dpm. Over the next few days, the entire restricted area was surveyed.

Fourteen areas, ten of which were in areas previously identified as a "clean area," were found tobe contaminated at levels greater than 1000 dpm/100 cm2.Most of the contamination wasremoved, and the remaining contamination was sealed in place using asphalt sealer and coveredwith clean soil.Impacted Areas -NOL-01 through NOL-06 and SVC-03Impacted Sub-surface Areas/Structures

-SVC-03 beneath slab in old RCA access alleyPIR 77-16: Service Building Radioactive Sump Transfer Line Puncture

-12/21/77A boring bit inadvertently punctured the 2.5 inch stainless steel line leading from the ServiceBuilding Sump Tanks to the PAB while conducting core borings inside the Radiation ControlArea. The sump line ran at a depth of 15 feet underground, where the damage occurred, and theboring depth was 61.5 feet. The damage was not detected until the next day when the sumppump started and water issued from the borehole.

The sump pump ran through two cyclesresulting in 20 gallons of water discharged from the rupture.

The water contained the following:

Radionuclide Total Activity, gCi Concentration,

.Ci/ml Fraction of MPC1-131 16.50 2.18 x 10-4 3.631-133 2.76 3.65 x 10` 0.18Cs-134 0.34 4.46 x 10-6 0.01Cs-137 0.50 6.67 x 10-6 0.02Co-60 0.58 7.69 x 10-6 0.01No measurable levels of activity were released offsite or to the storm drain. The line wasrepaired, and a sand and concrete casing was poured around it.Impacted Areas -NOL-02Impacted Sub-surface Areas/Structures

-Soils surrounding perforation and transfer linebackfill/Soils to a depth of 61.5 feet and below along the bore hole.2A-4 YNPS License Termination PlanRevision 4PIR 80-9: Resin Spill -8/6/80A hose developed a pinhole leak, while pumping resin to a cask. The failure of the hose allowedthe release of several gallons of water and one quart of resin. A 15 foot by 20 foot area of theRCA yard was contaminated.

Radiation readings on contact with the resin were I mrad/hr andthe spilled liquid reading were up to several hundred thousand dpm/1 00 cm2 (sic) (specific radionuclide data not available).

Decontamination included removal and disposal of some of theblacktop.

Impacted Areas -NOL-02/NSY-02 Impacted Sub-surface Areas/Structures

-South and East exterior walls of NSY-02. The sub-slab area of NSY-02 (IX-pit) was also impacted due to transfer of contamination by surfacewater (i.e., water used in decontamination and rainwater) into cracks between asphalt andIX Pit walls.PIR 81-9: Contamination of Yard Area During Reactor Head Removal -5/15/81While positioning the reactor vessel head over the equipment hatch in preparation to lower thehead through the equipment hatch, the reactor head made contact with the shield wall. Thisresulted in the spread of removable radioactivity outside of the Vapor Container (VC).Removable radioactivity immediately below the equipment hatch was 200 mrad/hr beta. Thetotal activity released to the ground was approximately 250 ptCi, with approximately I 0iCi(specific radionuclide data not available) discharged to Sherman Pond. The area was cleaned,but due to rainfall trace radioactive material levels were detected in the east storm drains.Impacted Areas -NOL-01/NOL-06/OOL-12/OOL-13 Impacted Sub-surface Areas/Structures

-BRT-01/in cracks and crevices under VCEquipment Hatch and along rails/ties in OOL-12 and OOL-13 and the East Storm DrainSystem due to surface water run-off.PIR 84-16: Drain Pipe Failure -9/10/84An excavated drainpipe from the Potentially Contaminated Area (PCA) storage building to theWaste Disposal building was found to be leaking.

Soil samples from around the pipe identified the presence of Co-60 and Cs- 137 and the excavation of the pipe continued.

The area ofmaximum contamination was measured at 25-35 mR/hr (specific radionuclide data notavailable),

with a hot spot of 29,300 pCi/gm Co-60 in this same area. The pipe from the edge ofthe old PCA (Potentially Contaminated Area) building to the edge of the waste disposal buildingand approximately 420 ft3 of dirt and rock were removed as radioactive waste. The soilremaining at the bottom of the excavation contained Co-60 at an average concentration of 30pCi/gm.Impacted Areas -WST-01/WST-02/WST-03 Impacted Sub-surface Areas/Structures

-WST-02 at a depth in excess of 9 feet below grade,activity remains potentially in excess of the soil DCGL. WST-03 at ash dewatering sump indrumming pit. Decommissioning standards had not yet been developed at the time thispartial remediation was performed.

Radiological decay since 1984 may have reduced theradionuclide concentration below the soil DCGL. Further scoping data will be collected below the 9 foot clean backfill to confirm this evaluated condition.

2A-5 YNPS License Termination PlanRevision 4PIR 94-03 & 94-09.Leakage from Frozen Fuel Chute Dewatering Line and NST Tell-tales On February 17 and 18, 1994, a fuel chute dewatering line and a neutron shield tank telltale drainline ruptured due to freezing.

A 3.5 liter sample from the fuel chute line indicated 1000 net cpm,and a sample from the NST telltale line indicated the presence of Co-60 and Cs-137. The groundbelow the rupture, as well as the area adjacent to the railroad tracks and pumpback house,showed no contamination.

However, the snow pile along the south side of the rails by the newfuel vault indicated the presence of Co-60, Cs-137 and Mn-54. All snow piles with positiveradiation measurements were sent to the rad drains and the areas de-posted.

Impacted Area -NOL-012A-6 YNPS License Termination PlanRevision 4Appendix 2BImpacted Area Assessments Structures and Open Land Areas Inside of the RCA of the YNPS(including Initial Classification) 2B-1 YNPS License Termination Plan Revision 4Buildings and Structures ISFSI Pad (NSY-10)Description:

NSY-10 is the ISFSI Pad, constructed in 1999 on the former location of the PoleBarn. NSY-10 is bounded entirely by NOL-07. The design and function of the VCC is such thatno contamination of the ISFSI should result from their presence on the ISFSI.History:

Prior to 1999, this location was used for storage of materials and equipment some ofwhich were radioactive materials.

During construction of the ISFSI pad, a radiological assessment of some areas north of the pad (notably the NOL-03 and NOL-04 yard areas and theabove grade exterior walls of structures within them) was performed using a technologically advanced method. The assessment was performed in anticipation that area background would beimpacted by transfer of the fuel to the ISFSI pad. The ISFSI pad is now occupied by loadedVCC. The transportation of the loaded VCC was performed under strict controls to ensure thatthe transport process would not contaminate the ISFSI. The ISFSI is surveyed on a routine basisand it is anticipated to remain non-contaminated as a result of the presence of the VCC. Shouldfuture surveys identify the presence of contamination on the ISFSI pad then the survey area maybe re-classified.

Contamination

1. Radionuclides Potentially Present:

The primary radionuclides of concern for survey areaNSY-10 are Co-60, Cs-137, Sr-90.2. Media: Reinforced

concrete, surface soil, sub-surface soil3. Continued Investigation:

Reinforced

concrete, surface soil, sub-surface soil subsurface systems.Decommissioning/Decontamination Activities

1. Performed:

Decommissioning work performed under DWPs included removal of thePole Barn and re-grading of the surface to facilitate ISFSI pad and road construction.

Soils removed from the area were deposited primarily in Survey Areas OOL-07 andOOL-09. Soils from the roadway approach area were deposited in Survey Areas OOL-02and OOL-10..2. Planned:

Planned decommissioning activities will depend on the results of theinvestigation conducted when the ISFSI is taken out of service.3. Anticipated End State Configuration:

The end state configuration of NSY-10 anticipated to include:* Reinforced concrete structures

• Subsurface concrete structures

• Subsurface soil.Classification Statement:

Based upon the radiological condition of this survey area identified inthe operating history and as a result of the decommissioning activities performed to date, surveyarea NSY-10 is identified as a Class 3 Area.2B1-2 YNPS License Termination Plan Revision 4Open Land AreasISFSI RCA Yard (NOL-07)Description:

NOL-07 is the land area that bounds the ISFSI pad and bounded entirely byOOL-10History:

NOL-07 was constructed at the same time as the ISFSI. A comprehensive radiological assessment of this area was performed prior to construction of the ISFSI. Previously this areawas used as a material storage area. Some of this material was later identified as radioactive material.

A survey of this area under the guidelines of NUREG/CR-5849 was conducted prior tograding.

Samples have been taken of each load of soils removed from the area. These samplesshowed no detectable activity.

All soils removed from the area were deposited in survey areasOOL-07 (Class 2) and OOL-09 (Class 3).Contamination:

1. Radionuclides Potentially Present:

The primary radionuclides of concern for survey areaNOL-07 are Co-60, Cs-137, and Sr-90.2. Media: Surface and subsurface soil.3. Continued Investigation:

Continued investigation will not be performed until the spentfuel and waste stored on the ISFSI has been removed.Decommissioning/Decontamination Activities

1. Performed:

Dismantlement of a pole barn structure and non-rad material storage area.The area was then graded in preparation for construction of the ISFSI pad. New concretewas used in the structure.

Fuel Storage Casks have been placed on the pad and are intheir final configuration.

2. Planned:

Future decommissioning activities are dependent upon the results of continued investigations

3. Anticipated End State Configuration:

A soil surface configuration suitable for survey.Subsurface structures requiring survey will be sufficiently exposed to allow survey.Classification Statement:

Based upon the current/best information indicating the radiological conditions and on conditions and events identified in the operating

history, survey area NOL-07is identified as a Class 3 Area. It is not expected that any radioactive material will leave theconfines of the fuel casks and residual contamination after removal of the fuel casks isanticipated to be a small fraction of the DCGLs.213-3 YNPS License Termination PlanRevision 4Appendix 2CImpacted Area Assessments Buildings, Structures and Open Land Areas Outside of the RCA of the YNPS(including Initial Classification) 2C-1 YNPS License Termination PlanRevision 4Buildings and Structures NoneOpen Land Areas Outside of the RCA (OOL)ISFSI Pad Access Zone (OOL-10)Description:

OOL- 10 consists of the land area owned by YAEC.History:

Survey Area OOL- 10 is the buffer zone around the RCA and, as such, has the potential to have become contaminated.

Contamination:

1. Radionuclides Potentially Present:

The primary radionuclides of concern for survey areaOOL-10 are Co-60, Cs-137, Sr-90, Ag-108m and H-3.2. Media: Surface and subsurface soil, surface water and groundwater.

3. Continued Investigation:

Continued investigation will be necessary to assess surface andsubsurface soil surface water and groundwater.

Decommissioning/Decontamination Activities

1. Performed:

Decommissioning activities performed in OOL- 10 consist of soil removal toadjust the grade of the ISFSI fuel transfer haul road.2. Planned:

Future-decommissioning activities may include removal of certain soils andmaterials depending upon the results of the continuing investigation.

3. Anticipated End State Configuration:

A soil surface configuration suitable for survey andaccess to surface water and groundwater.

Classification Statement:

Based upon the current/best information indicating the radiological conditions and on conditions and events identified in the operating

history, survey area OOL- 10is identified as a Class 2 Area.2C-2 YNPS License Termination PlanRevision 43 IDENTIFICATION OF REMAINING SITEDISMANTLEMENT ACTIVITIES Decommissioning activities for and final status survey of the YNPS site, with the exception ofthe ISFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.3.1 Introduction and General Considerations In accordance with IOCFR50.82(a)(9)(ii)(B),

Reference 3-1, the License Termination Plan (LTP)must identify the major dismantlement activities that remain. Included in this information areestimates of occupational radiation dose associated with those activities and estimates ofprojected volumes of radioactive waste. These activities are undertaken pursuant to the current1OCFR50 license, are consistent with the PSDAR (Reference 3-2), and do not depend uponapproval of the LTP to proceed.YAEC intends to release the YNPS site for unrestricted use, and its primary goals are todecommission the YNPS safely and to maintain continued safe storage of spent fuel, until it isremoved from the site. YAEC will decontaminate and dismantle YNPS in accordance with theDECON alternative, as described in the NRC's Final Generic Environmental Impact Statement (NUREG-0586 and its supplements, Reference 3-3). Completion of the DECON option iscontingent upon continued access to one or more low-level waste disposal sites.Decommissioning activities at YNPS are being conducted in accordance with the YNPSPSDAR, YDQAP, FSAR, Technical Specifications, Part 50 license, and the requirements ofIOCFR50.82(a)(6) and (a)(7). As such, the conduct of the decommissioning activities described herein is not dependent upon approval of the LTP. In addition, YAEC does not foresee any ofthe specific decommissioning activities described herein as resulting in the need for prior NRCapproval upon evaluation under I OCFR50.59.

These activities are being conducted inaccordance with existing program and procedures which have been reviewed by the NRC,including:

YNPS Radiation Protection

Program, Occupational Safety Program, Radioactive andNon-Radioactive Waste Management Programs and the Decommissioning Quality Assurance Plan. Activities conducted during decommissioning do not pose any greater radiological orsafety risk than those conducted during plant operation and refueling.

Nonetheless, if anyactivity requires prior NRC approval under I OCFR50.59(c)(2) or a change to the YNPSTechnical Specifications or license, a submittal will be made to the NRC for review and approvalbefore implementing the activity in question.

3-1 YNPS License Termination PlanRevision 43.2 Decommissioning Approach (as of October 2013)Decommissioning activities are being completed in three phases:Phase 1: Mechanically/electrically isolate the Spent Fuel Pool, remove SSCs not supporting fuelstorage, and remove fuel and GTCC waste from the SFP,Phase 2: Dismantlement and disposition of remaining

systems, structures, and components (SSCs), andPhase 3: Termination of the Part 50 license.As discussed herein, Phase 1 has been completed.

Phase 2 activities are ongoing and their statusis described in this section.

Phase 3 is intended to occur following completion of all radiological decommissioning activities associated with the site including the YNPS ISFSI.The following are general decontamination and dismantlement considerations that are beingincorporated, as appropriate, into the activities for decommissioning the systems, components and structures at YNPS. With the exception of decommissioning activities at the ISFSI to beundertaken when all fuel and GTCC waste have been removed from the site, alldecommissioning and dismantlement activities have been completed at this site.* Radiological characterization survey data has been used to identify the systems,structures, and components to be decontaminated and dismantled.

The extent ofcontamination associated with the remaining SSCs associated with the ISFSI is presented in Table 3-1." Detailed decommissioning work documents for decommissioning the ISFSI will bedeveloped,

reviewed, and approved in accordance with project and plant programs andprocedures.

• Plant tag-out procedures will be used to de-energize electrical and control equipment.

Radiation Protection procedures will be used to ensure compliance with radiological requirements for contamination control and worker protection and ALARA programs.

Occupation safety standards will be observed.

" Components will be identified prior to removal.

The components are then removed usingthe techniques and methods as specified in the decommissioning work packages.

Components are either decontaminated or shipped to a low-level radioactive wastedisposal facility or, if appropriate, shipped to an approved landfill.

• Contaminated structural steel components, on which a volume reduction process is beingapplied, may be moved to a processing area and packaged into containers for shipment toan off-site waste processing facility.

3-2 YNPS License Termination PlanRevision 4* Remaining portions of basements and slabs will be perforated to allow for groundwater and/or surface water infiltration.

" Remaining buried contaminated components (e.g., piping, drains, and conduit) are beingexcavated.

After excavation, the components will be examined to ensure that they arephysically sound prior to cutting and removal.

Most buried contaminated piping islocated in steel conduits (i.e., pipes enclosed in pipes). Contamination controls will bemodified as necessary if the components are significantly degraded.

" After completion of decommissioning and/or remediation activities and prior to finalstatus survey, isolation and controls will be implemented as described in Section 5.4.5.* A final status survey will be performed to verify removal of contamination to belowrelease levels.* Coatings will be removed, as required by local, state, and federal regulations.

PCB paintswill be removed from exposed concrete surfaces as required by the Alternate Method ofDisposal Authorization (AMDA) requirements prior to demolition of the structure, asauthorized by the EPA on October 8, 2002 (Reference 3-4) and subsequent changesthereto.3.2.1 Phase 1 Activities Since 1993 Yankee has removed and disposed of the steam generators, pressurizer, and thereactor vessel. The reactor vessel internals, which are greater-than-Class-C (GTCC) waste,remain onsite and are stored at the site's independent spent fuel storage installation (ISFSI).The Spent Fuel Pit (SFP) and other systems associated with fuel storage were electrically andmechanically isolated to create a Spent Fuel "Island" that would not be adversely impacted byother decommissioning activities.

The majority of systems and components not required tosupport the storage of spent fuel have been dismantled and disposed of in accordance with theYNPS Decommissioning Plan and Final Safety Analysis Report. The status of plant SSCs, as ofJuly 2003 is provided in Table 3-2.Once a Spent Fuel "Island" was established, the focus of site activities shifted to the removal ofspent fuel and GTCC waste from the SFP, to the ISFSI. Movement of the fuel and the non-fuelGTCC waste from the SFP to the ISFSI was completed in June 2003.3.2.2 Phase 2 Activities After removing the spent fuel and GTCC waste from the SFP, the remaining components of thesystems listed below were dismantled and decontaminated.

• Temporary Waste Water Processing System," Radiation Monitoring System,* Ventilation Systems (Including Vapor Container Ventilation and Purge System),3-3 YNPS License Termination PlanRevision 4* Fuel Handling Equipment System,* SFP Cooling and Purification System,* Auxiliary Service Water System,* Demineralized Water System,* Compressed Air System,* Electrical System,* Heating System, and" Fire Protection and Detection SystemAfter removing systems and components from an area or building, contaminated

concrete, steel,and other building materials are being decontaminated or removed.

The structures listed belowwere decontaminated and/or dismantled during the decommissioning of the SFP Island.* Yard Area Crane and Support Structure,

• Vapor Container (VC),* Reactor Support Structure,

" VC Polar Crane,* Radiation Shielding,

• Pipe Chases,* Fuel Transfer Chute,* Ion Exchange Pit," Primary Vent Stack," Spent Fuel Pit and SFP Building,

" New Fuel Vault," Primary Auxiliary

Building,

• Waste Disposal

Building,

• Safe Shutdown System Building,

• Potentially Contaminated Area (PCA) Storage Buildings and Warehouse,

• Compactor Building* Service Building and Fuel Transfer Enclosure,

• Miscellaneous Storage Tanks and* Meteorological Tower.Upon the completion of Phase 2 activities, all systems and components will have been removedfrom plant buildings and yard areas (including those supporting spent fuel and GTCC storage inthe ISFSI) and disposed of at the appropriate facility.

In general, above grade portions of sitebuildings and the ISFSI Storage Pad will be remediated, if necessary, and demolished.

Below-grade portions of site structures (elevation 1022'-8" and below) were remediated to meet the siterelease criteria or are being removed.

Building demolition debris that has been determined tocontain "no detectable radioactivity" or has passed a final status survey may be used as backfillon site. Details concerning dismantlement and remediation efforts are provided in thesubsections to follow.Following submittal of the License Termination Plan, Final Status Surveys will be conducted toverify that structures and open land areas meet the release criteria.

Independent verification of3-4 YNPS License Termination PlanRevision 4the results by the NRC will allow for the release of the individual surveyed structures and openland areas. In order to facilitate remediation, the facility superstructures may be demolished before remediating substructure and soils beneath the structures.

Measures, as described in LTPSection 5.4.5, will be implemented to prevent recontamination of surveyed areas prior to finalstatus survey.General decontamination and dismantlement considerations are given in Section 3.2; however,specific decontamination and dismantlement considerations for applicable remaining ISFSIsystems, structures, and components are given in the following sections.

The contamination status for the remaining systems is provided in Table 3-1. Also, the description and status ofremaining SSCs are presented in Sections 3.2.2.1 (Systems and Components) and 3.2.2.2(Structures).

3.2.2.1 Systems and Components 3.2.2.1.1 Electrical SystemThe on-site electrical system is powered by a Massachusetts Electric Line. The system consistsof a transformer, auto throw-over switch, distribution panels and the necessary associated equipment to support ISFSI operations.

Backup power for portions of the plant electrical systemis provided automatically during a loss of offsite power via a 175 kW Security Diesel Generator.

Electrical System components associated with the Gatehouse and ISFSI will remain to supportstorage and monitoring of spent fuel at the ISFSI. There are currently no decommissioning ordismantlement considerations specific to the Electrical System.3.2.2.1.2 Heating SystemTemporary heating may be required during area and building dismantlement activities.

HeatingSystem components associated with the Gatehouse will remain to support storage and monitoring of spent fuel at the ISFSI.There are currently no decommissioning or dismantlement considerations specific to the HeatingSystem.3.2.2.2 Structures Decommissioning of the ISFSI consists primarily of the disposal of the concrete canisteroverpacks, provided they are not shipped with the spent fuel casks and disposal of the ISFS1storage pad. The overpack design minimizes neutron activation, thereby generating minimalradioactive waste. This waste should qualify for disposal at a low-level radioactive wastedisposal site. Currently, the decommissioning cost estimate assumes that the material comprising the Vertical Concrete Casks and the ISFSi storage pad are demolished and shipped offsite to alow-level radioactive waste disposal site.3-5 YNPS License Termination PlanRevision 43.2.3 Phase 3 Activities The final phase of decommissioning will take place after all spent fuel and GTCC waste isremoved from the site and the dismantlement and decontamination of the ISFSI is complete.

Inthe interim, spent fuel and GTCC will be stored in the ISFSI.Decommissioning of the ISFSI consists primarily of the disposal of the concrete canisteroverpacks, provided they are not shipped with the spent fuel casks. The overpack designminimizes neutron activation, thereby generating minimal radioactive waste. This waste shouldqualify for disposal at a low-level radioactive waste disposal site.As indicated in Section 1 of the LTP, YAEC may decide to remove some portions of the sitefrom the license before license termination.

For those areas the process outlined in Section 1.5will be followed.

Termination of the license will occur after the last stage of final status surveyand independent NRC verification (i.e., on the grounds and SSCs associated with the ISFSI).3.3 Decommissioning Schedule (as of October 2013)YAEC completed the second phase of dismantlement and decontamination and final statussurveys and License reduction in August 2007. The design and construction of a dry cask storagefacility was completed in 2001. Fuel transfer activities commenced in 2002 and were completed in 2003. Following the transfer of spent fuel and GTCC waste from the SFP, decommissioning of the SFP island was completed over a period of approximately three years, including finalstatus surveys.

The dry cask storage facility is expected to be operated from 2002 to 2031, whenthe last fuel assembly is assumed to be taken off-site.

Using this assumption, the YNPS licensewill be terminated after the dry cask storage facility is decommissioned (scheduled to occur in2033). Updates will be provided to the NRC through current interactions with the NRC Region Ipersonnel.

3.4 Radiological Impacts of Decommissioning (as of October 2013)The decommissioning activities are being conducted under the provisions of the YNPS Radiation Protection Program and Radioactive Waste Management Program.

These programs continue tobe implemented as described in the YNPS FSAR. The Radiation Protection Programimplements the regulatory requirements of I OCFR20 through approved plant procedures established to maintain radiation exposures ALARA. The Radioactive Waste Management Program controls generation, characterization, processing,

handling, shipping and disposal ofradioactive wastes per the approved YNPS Radiation Protection

Program, Process ControlProgram, and plant procedures.

During the storage period, there will be little, if any, radioactive waste removed or shipped from the site.The current Radiation Protection Program (described in FSAR Section 507), Waste Management Program (FSAR Section 508) and Offsite Dose Calculation Manual will be used to protectworkers and the public during the various decontamination and decommissioning activities.

These well-established programs are routinely inspected by the NRC to ensure that workers, thepublic, and the environment are protected during facility decommissioning activities.

It is alsoimportant to note that most decommissioning activities involve very similar radiation protection 3-6 YNPS License Termination PlanRevision 4and waste management considerations as those encountered during plant operations.

Asdescribed in the PSDAR, the YNPS decommissioning will be accomplished with no significant adverse environmental impacts in that:* The postulated impacts associated with the method chosen, DECON, have already beenconsidered in the Final Generic Environmental Impact Statement (FGEIS).* There are no unique aspects of the plant or decommissioning techniques to be utilizedthat would invalidate the conclusions reached in the FGEIS.* The methods to be employed to dismantle and decontaminate the site are standardconstruction based techniques fully considered in the FGEIS.* The site-specific person-rem estimate for all decommissioning activities has beenconservatively calculated using methods similar to and consistent with those in theFGEIS.3.4.1 Occupational ExposureThe total radiation exposure impact for decommissioning was estimated in the Decommissioning Plan, Reference 3-5, to be approximately 744 person-rem (see breakdown in Table 3-3). Thisestimate was re-evaluated in 1996, resulting in a lower value of 580 person-rem (see also Table3-3). The final radiation exposure for decommissioning of the YNPS was 594 person-rem.

Theradiation exposure associated with the decommissioning of the ISFSI will be managed, so thatdoses to workers and the public are minimized and federal regulations regarding doses and doserates are met.Radiation exposure to off-site individuals for expected conditions, or from postulated accidents is bounded by the EPA's Protective Action Guidelines and NRC regulation.

The publicexposure due to radiological effluents will continue to remain well below the I0CFR20 limitsand the ALARA dose objectives of 1 OCFR50, Appendix I. This conclusion is supported by theYNPS Annual Effluent Release Reports in which individual doses to members of the public arecalculated for station liquid and gaseous effluents.

3.4.2 Radioactive Waste Projections No significant impacts are expected from the disposal of low-level radioactive waste (LLW).The total volume of the YNPS low-level radioactive waste for disposal was estimated in theDecommissioning Plan to be approximately 132,000 ft3.A total volume of approximately 1,670,000 ft3 of LLW was shipped from the YNPS site for off-site disposal.

A significant portion of this waste contained very low levels of radioactivity (DOT exempt) and was created asa result of remediation activities to satisfy EPA clean-up requirements for PCBs, to satisfy theMassachusetts Department of Public Health (DPH) radiological release criteria of 10 mrem/year and to meet the Massachusetts Contingency Plan regulations for non-radiological release criteriaunder the Department of Environmental Protection (DEP) requirements.

The volume of LLWthat would have been required to be disposed of to satisfy the NRC 25 mrem/year release criteriawould have been a significantly lower volume, in the 300,000 ft3 range, significantly below the3-7 YNPS License Termination PlanRevision 4FGEIS estimate of 647,670 ft3 for a reference PWR. The current decommissioning cost estimateassumes that the material (concrete and steel) associated with the Vertical Concrete Casks andthe ISFSI Storage Pad will be shipped off-site as low-level radioactive waste. The volume ofthis material was not included in the original estimate.

However, this material is not expected tobe required to be removed to meet the NRC 25 mrem/year release criteria.

3.5 References

3-1 Title 10 to the Code of Federal Regulations, Part 50.82, "Termination of license."

3-2 YNPS Post-Shutdown Decommissioning Activities Report, dated October 2013.3-3 Supplement 1 to NUREG-0586, "Generic Environmental Impact Statement onDecommissioning of Nuclear Facilities,"

dated November 2002.3-4 Letter from R.W. Varney, Region Administrator, EPA Region 1, to J. Kay, Regulatory

Affairs, Yankee, Extension of Amended (as of January 6, 1999) Alternative Method ofDisposal Authorization for PCB Paint Removal, dated October 8, 2002.3-5 YNPS Decommissioning Environmental Report, dated December 1993.3-6 USNRC Atomic Safety and Licensing Board Docket No. 50-029-DCOM, Supplemental Affidavit of Russell A. Mellor, September 3, 1996.3-7 Memorandum RP-03-045 from Greg Babineau to Jim Kay, dated November 19, 2003.3-8 YNPS License Termination PlanRevision 4Table 3-1Remaining Contaminated Plant Systems(as of October 2013)The Vertical Concrete Casks and ISFSI Storage Pad are expected to be contaminated due toneutron activation.

The decommissioning cost estimate assumes that the material comprising theVertical Concrete Casks and the ISFSI Storage Pad are dismantled and disposed of as low levelradioactive waste.3-9 YNPS License Termination PlanRevision 4Table 3-2Status of Plant SSCs as of October 2013SSC StatusReactor Vessel Removed.'

Steam Generators Removed.Main Coolant System Removed.Pressure Control and Relief System Removed.Charging and Volume Control System Removed.Chemical Shutdown System Removed.Purification System Removed.Component Cooling System Removed.Primary Plant Corrosion Control System Removed.Primary Plant Sample System Removed.Waste Disposal System Removed.Shutdown Cooling System Removed.Primary Plant Vent and Drain System Removed.Emergency Core Cooling System Removed.Radiation Monitoring System Removed.VC Ventilation and Purge System Removed.VC Heating and Cooling System Removed.Post-Accident Hydrogen Control System Removed.Containment Isolation System Removed.Fuel Handling Equipment System RemovedSFP Cooling and Purification System Removed.Main Steam System Removed.Feedwater System Removed.Steam Generator Blowdown System Removed.Emergency Feedwater System Removed.Service Water System Removed.Demineralized Water System Removed.Compressed Air System Removed.Electrical System Partially

removed, portions inservice.Heating System Partially

removed, portions inservice.Ventilation System Removed.Fire Protection and Detection System RemovedPrimary Pump Seal Water System Removed."Removed" SSCs have been physically removed from the site and disposed of in appropriate disposal facilities.

3-10 YNPS License Termination PlanRevision 4Table 3-2Status of Plant SSCs as of October 2013SSC StatusSafe Shutdown System Removed.Water Cleanup System Removed.Vapor Container Removed.Reactor Support Removed.Vapor Container Polar Crane Removed.Radiation Shielding Removed.Neutron Shield Tank Removed.Pipe Chases Removed.Fuel Transfer Chute Removed.Yard Area Crane and Support Structure Removed.Ion Exchange Pit Removed.Primary Vent Stack Removed.Spent Fuel Pit and Spent Fuel Pit Building Removed.New Fuel Vault Removed.Primary Auxiliary Building Removed.Diesel Generator Building Removed.Waste Disposal Building Removed.Safe Shutdown System Building Removed.Potentially Contaminated Area (PCA) Storage Removed.Buildings I and 2 and Warehouse Compactor Building Removed.Service Building Removed.Miscellaneous Tanks Removed.Meteorological Tower Abandoned in place.ISFS1 Vertical Concrete Casks and Storage Pad In service3-11 YNPS License Termination PlanRevision 4Table 3-3Historical Radiation Exposure Projections Associated withthe Former YNPSActivity Exposure (Person-rem)

Original

Estimate, Revised Estimate, Reference 3-5 Reference 3-6Component Removal Project" Asbestos Abatement 73 76* Steam Generators and 62 59Pressurizer

• Reactor Vessel Internals 25 92Subtotal 160 227Fuel Transfer 41 41Dismantlement

• Reactor Vessel 48 33* Main Coolant System 50 36" Other Systems in Vapor 84 48Container

• Balance of Plant Systems 98 48* Asbestos Abatement 90 55* Structures 50 28* Miscellaneous 82 56Subtotal 502 304Transportation 41 7Plant Effluents

<1 <1Total 744 5793-12 YNPS License Termination PlanRevision 44 SITE REMEDIATION PLANSDecommissioning activities for and final status survey of the YNPS site, with the exception ofthe ISFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.4.1 Introduction In accordance with IOCFR50.82 (a)(9)(ii)(C)

(Reference 4-1), the LTP must provide the "plansfor site remediation."

These plans must include the provisions to meet the criteria from SubpartE of I OCFR20 (Reference 4-2) before the site may be released for unrestricted use:" Annual total effective dose equivalent to the average member of the critical group notto exceed 25 mrem, and" The dose to the public must be "as low as reasonably achievable,"

or ALARA.Decontamination and dismantlement (D&D) activities are being conducted in accordance withthe YNPS Radiation Protection, Safety and Waste Management

Programs, which are well estab-lished and frequently inspected.

Changes made to the programs for D&D activities aredocumented and processed in accordance with existing plant administrative procedures and1 OCFR50.59, as appropriate.

This section describes the methodologies and criteria that will be used to perform activities toremove residual radioactivity and to demonstrate compliance with the ALARA criterion, required by 1OCFR20.

More specific detail regarding remediation activities may be found inSection 3.4.2 Remediation ActionsRemediation actions may be required to reduce the radioactivity levels below the applicable cleanup criteria as provided in Sections 5 and 6. The specific remedial actions depend on thetype of area under consideration.

These area types are categorized as one of the following:

• Soils/sediment 4-1 YNPS License Termination PlanRevision 45 FINAL STATUS SURVEY PLANDecommissioning activities for and final status survey of the YNPS site, with the exception ofthe ISFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.5.1 Introduction The FSS (FSS) Plan describes the methods for planning, designing, conducting, and evaluating FSS at the YNPS site. These surveys serve as key elements to demonstrate that the dose fromresidual radioactivity is less than the maximum annual dose criterion for license termination forunrestricted use specified in I OCFR20.1402 (Reference 5-1 ). The additional requirement ofI OCFR20.1402, that residual radioactivity at the site be reduced to levels that are as low asreasonably achievable (ALARA),

is addressed in Section 4. The FSS Plan was developed usingthe guidance ofNUREG-1575, "The Multi-Agency Radiological Site Survey and Investigation Manual (MARSSIM)"

(Reference 5-2); Regulatory Guide 1.179, "Standard Format and Contentof License Termination Plans for Nuclear Power Reactors" (Reference 5-3); NUREG-1727, "NMSS Decommissioning Standard Review Plan," (Reference 5-4); and NUREG-1757, Volume2, "Consolidated NMSS Decommissioning Guidance,"

(Reference 5-5).The FSS process described in the survey plan adheres to the guidance of MARSSIM.

However,advanced survey technologies may be used to conduct radiological surveys that can scan thesurface and record the results.

This survey plan allows for the use of these advancedtechnologies, where survey quality and efficiency can be increased, as long as the survey resultsare at least equivalent, in terms of their statistical significance, to those that would have beenobtained using the non-parametric sampling methods of MARSSIM.

In cases where advancedsurvey technologies are to be used, a technical evaluation will be developed to describe thetechnology to be used and to demonstrate how the technology meets the objectives of the survey.These technical evaluations will be referenced, as appropriate, in FSS Reports and will beavailable for NRC review. Notification will be made to the NRC prior to the use of advancedinstruments or technologies.

5-1 YNPS License Termination Plan Revision 46 COMPLIANCE WITH THE RADIOLOGICAL CRITERIAFOR LICENSE TERMINATION Decommissioning activities for and final status survey of the YNPS site, with the exception ofthe ISFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.6.1 Site Release Criteria6.1.1 Radiological Criteria for Unrestricted UseThe site release criteria for the Yankee Nuclear Power Station (YNPS) site are the NRC'sradiological criteria for unrestricted use given in 10 CFR 20.1402 (Reference 6-1):" Dose Criterion:

The residual radioactivity that is distinguishable from background radiation results in a Total Effective Dose Equivalent (TEDE) to an average member of the criticalgroup that does not exceed 25 mrem/year, including that from groundwater sources; and* ALARA Criterion:

The residual radioactivity has been reduced to levels that are as low asreasonably achievable (ALARA).6.1.2 Conditions Satisfying the Site Release CriteriaLevels of residual radioactivity that correspond to the allowable radiation dose and ALARAlevels described above are calculated by analysis of various scenarios and pathways (e.g., directradiation, inhalation, ingestion) through which exposures could be reasonably expected to occur.LTP Section 2.3.2 discusses the radionuclides for which derived concentration guideline levels(DCGLs) must be calculated.

These DCGLs form the basis for the following conditions which,when met, satisfy the site release criteria as prescribed in 10 CFR 20.1402:" The average residual radioactivity above background is less than or equal to the DCGL.* Individual measurements representing small areas of residual radioactivity that exceedthe DCGL, do not exceed the elevated measurement comparison DCGL. The elevatedmeasurement comparison DCGL (DCGLEMC) is described in Section 5.4.6.3.6-1 YNPS License Termination PlanRevision IYNPS License Termination Plan Revision 1Tab;e 1- 1Remaining Room/Walls Dimensions Building Area Width Length HeightFt/in Meters Ft/in Meters Ft/in MetersPAB TK-30 in (PAB Basement)

Room 12'-6" 3.81E+00 15'-6" 4.72E+00 18'-6" 5.64E+00PAB TK-27 (PAB Basement)

Room 10'-2" 3.1OE+00 15'-6" 4.72E+00 18'-6" 5.64E+00PAB South Wall (G-Line) 133'-0"*

4.05E+01 13'-0" 3.96E+00PAB East Wall (2-Line to Fa) 17'-0" 5.18E+00 13'-0" 3.96E+00I-X PIT Southernmost Wall 33'-0" 1.O1E+01 14'-8" 4.47E+001-X PIT Easternmost Wall (Total Length) 31'-10" 9.70E+00 14'-8" 4.47E+00SFP Spent Fuel Pool 16'-6" 5.03E+00 33'-8" 1.03E+01 14'-8" 4.47E+00New Fuel Vault New Fuel Storage (South Wall) 15'-0" 4.57E+00 13'-6" 4.1I E+00Safe Shutdown Pipe Chase Cubicle 4'-0" 1.22E+00 4'-0" 1.22E+00 8'-0" 2.44E+00Waste Vault Waste Transfer Pit Cubicle 9'-0" 2.74E+00 14'-0" 4.27E+00 9'-10" 3.OOE+00Elevator Pit Elevator Pit Cubicle 7'-10" 2.39E+00 9'-0" 2.74E+00 6'-6" 1.98E+00Waste Disposal Pipe Chase Cubicle 5'-0" 1.52E+00 1 1'-10" 3.6 1E+00 10'-1," 3.07E+00Waste Disposal Distillate Heat Exchanger Cubicle 9'-0" 2.74E+00 16'-0" 4.88E+00 7'-0" 2.13E+00Waste Disposal Evaporator Cubicle 10'-6" 3.20E+00 16'-0" 4.88E+00 7'-0" 2.13E+00Waste Disposal Drumming Pit Cubicle 10'-4" 3.15E+00 27'-0" 8.23E+00 7'-0" 2.13E+00PAB PAB Back Stairwell Pit Cubicle 11'-4" 3.45E+00 13'-0" 3.96E+00 8'-2" 2.49E+00Average Wall Length (meters)

= 4.44E+00Average Wall Height (meters)

= 3.51E+00* As previously noted, the south (G-Line) wall of the PAB is excluded from the calculation of average wall length.6F-4 YNPS License Tennination PlanRevision ITable 1- 2Remaining Structures and Drawing Reference Building Room/Wall/Pit Room/Wall Drawing Reference Wall Drawing Reference Wall Height Drawing Reference Width Length (Note 1)PAB Drain Collecting Tank Room (TK-30) 12' 6" PAB 9699-FC-40D 15'6" PAB 9699-RC-40A 1022' 8"-1004' 2=18' 6" PAB 9699-FM-57A PAB Gravity Drain Tank Room (TK-27) 10' 2" PAB 9699-FC-40D 15' 6" PAB 9699-RC-40A 1022' 8"-1004' 2"=l8' 6" PAB 9699-FM-57A PAB South Wall (G-Line) 133' 0" PAB 9699-FR-16A 1035' 8" -1022' 8' =13' 0" PAB 9699-FM-57A PAB East Wall (2-Line to Fa) 17' 0" PAB 9699-FR-16A 1035' 8" -1022' 8' =13' 0" PAB 9699-FM-57A I-X PIT Southemmost Wall 33' 0" I-X Pit 9699-FM-35B 1035' 8" -1021' 0" =14' 8" I-X Pit 9699-FM-35B I-X PIT Eastemmost Wall F to E 25' 6" PAB 9699-FM-57A 1035' 8" -1021' 0" =14' 8" I-X Pit 9699-FM-35B I-X PIT Eastemmost Wall E to Wall End 6'4" I-X Pit 9699-FM-35B I-X PIT Eastemmost Wall (Total Length) 31' 10"SFP Spent Fuel Pool 16' 6" Fuel Pit 9699-FM-21A 33' 8" Fuel Pit 9699-FM-21A 1022' 8" -1008' 0" =14' 8" Fuel Pit 9699-FC-45B New Fuel Vault New Fuel Storage (South Wall) 15' 0" PAB 9699-FM-57A 1035' 0" -1021' 6" =13' 6" Fuel Pit 9699-FM-21A Safe Shutdown Pipe Chase (555) 4' 0" CES Rev.1 85005-F-1001 4'0" CES Rev. I 85005-F-1001 1034' 0" -1026'0" = 8' 0" CES Rev.l 85005-F-1001 Waste Vault Waste Transfer Pump Pit (underground) 910" 9699-FC-50C 14' 0" 9699-FC-50C 1020' 6" -1010' 8" --9' 10" 9699-FC-50C Elevator Pit Elevator Pit 7' 10" PAB 9699-FC-43A 9'0" PAB 9699-FC-43A 1022' 8'- 1016' 2" =6' 6" PAB 9699-FC-43A Waste Disposal Pipe Chase Cubicle 5'0" Waste Disp.9699-FA-17A I1' 10" Waste Disp.9699-FA-I 7A 1035' 8" -1025' 7" = 10' 1" Waste Disp.9699-FA-17A Waste Disposal Distillate Heat Exchanger Cubicle 9'0" Waste Disp.9699-FA-17A 16' 0" Waste Disp.9699-FA-I 7A 1035' 8" -1028' 8" = 70" Waste Disp.9699-FA-17A Waste Disposal Evaporator Cubicle 10' 6" Waste Disp.9699-FA-17A 16'0' Waste Disp.9699-FA-I 7A 1035' 8" -1028' 8" = 70" Waste Disp.9699-FA-17A Waste Disposal Drumming Pit Cubicle 10' 4" Waste Disp.9699-FA-17A 27' 0" Waste Disp.9699-FA-I 7A 1035' 8" -1028' 8" = 70" Waste Disp.9699-FA-17A PAB Back of PAB Stairwell Pit Cubicle 11 4" PAB 9699 RC-40B 13' 0" PAB 9699 RC-40B 1035' 8" -1027' 6' = 8'2" PAB 9699-FM-57B Note 1: Top/ceiling height elevation is from DEMCO work scope Ref. I617-5 YNPS License Termination PlanRevision I2. Source Configuration NUREG/CR-6755 (Ref. 2), Section 4.1, describes three principal assumptions inherent in the BuildingOccupancy scenario:

a fixed room area, uniform surface contamination, and the receptor location at the centerof the floor at a height of I m. The configuration of the receptor and sources is illustrated in Figure 2-1. TheRESRAD- BUILD input parameters, receptor location and center of source coordinates, are provided inTable 2-1.Figure 2-1Configuration of Source and Receptor Locations for RESRAD-BUILD Model...........................

z-------------------

Table 2-1Receptor and Center of Source Locations, metersSource # Source Description X AxisXY zI Floor 2.22 2.22 02 West Wall 0 2.22 1.763 North Wall 2.22 4.44 1.764 East Wall 4.44 2.22 1.765 South Wall 2.22 0 1.76Receptor Location 2.22 2.22 16F-6 YNPS License Termination PlanRevision I3. Direct Ingestion RateThe source specific input parameter, Direct Ingestion Rate, is described in RESRAD-BUILD as the directingestion rate of the source by any receptor in the room. Direct ingestion is possible only if the receptor andthe source are in the same room and represents the fraction of the source ingested per hour.NUREG/CR-5512, Volume 3, (Ref. 3) defines the average ingestion rate of 1.1 E-4 m2/hr as representative for the average individual in an industrial setting.

The Direct Ingestion Rate for use in the BuildingOccupancy Scenario is calculated based upon the total room surface area (source area). The surface area isequal to sum of the surface area of four walls (15.58 m2 per wall, as discussed in Section 1) plus the surfacearea of the floor (19.71 M2, as discussed in Section 1).Direct Ingestion Rate = Average Ingestion Rate / Source Area= (1.IE-04 m2/hr) / ((4 x 15.58 M2) + 19.71 M2)= (1.IE-04 m2/hr) / (82.03 M2)= 1.34E-06 hr1-The direct ingestion defined in this manner used in conjunction with an indirect ingestion rate set to zero,adequately models the Building Occupancy Ingestion pathway.

References:

1 Attachment E to the "Contract for the Performance of Demolition and Disposal and Related Services, Byand Between DEMCO, Inc. and Yankee Atomic Electric Company,"

dated February 28, 2003.2. NUREG/CR-6755, "Technical Basis for Calculating Radiation Doses for the Building Occupancy Scenario Using the Probabilistic RESRAD-BUILD 3.0 Code," February.

2002 (ANL/EAD/TM/02-1).

3. NUREG/CR-5512, "Residual Radioactive Contamination from Decommissioning,"

Volume 3:"Parameter

Analysis, Draft Report for Comment,"

October 1999 (SAND99-2148).

6F-7 YNPS License Tennination PlanRevision IYNPS License Termination Plan Revision 1This page intentionally left blank.6F-8 YNPS License Termination PlanRevision 47 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTSDecommissioning activities for and final status survey of the YNPS site, with the exception ofthe ISFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.7.1 Summary of Decommissioning Cost EstimateThe current Federal Energy Regulatory Commission (FERC) approved decommissioning costestimate (December 2012) and cost estimate for management of spent fuel and GTCC waste isbased on the Stipulation and Settlement Agreement between YAEC and the Connecticut PublicUtilities Regulatory Authority, the Connecticut Office of Consumer

Counsel, the Maine PublicUtilities Commission, the Maine Office of Public Advocate, the Massachusetts Department ofPublic Utilities, and the Attorney General of Massachusetts dated April 30, 2013.This cost estimate includes the cost associated with the projected ISFSI decommissioning costsand a funding assumption of 15 years of operations costs to manage spent fuel and GTCC waste.A funding mechanism provides that damage awards and settlement proceeds that YAEC receivesin future phases of its litigation with the Department of Energy (DOE) will be applied tomaintain the adequacy of the Nuclear Decommissioning Trust (NDT) to cover 15 years of ISFSIoperations (as well as all other projected decommissioning costs). In addition, YAEC has theright to resume collection of decommissioning charges from its customers subject to thesubmittal of a proposal under section 205 of the Federal Power Act, if needed.YAEC has an account within its NDT entitled, "ISFSI Radiological Decom," that segregates thefunds for radiological decommissioning of the ISFSI from the larger balance of funds forongoing management of spent fuel and GTCC waste held in the NDT.The assumptions of the current decommissioning cost estimate are discussed in theDecommissioning Funding Plan submitted to the NRC on December 17, 2012 in accordance with 10 CFR 72.30(b)(2).

The decommissioning cost estimate incorporates the most recentassumptions with respect to the remaining decommissioning activities and related costs (i.e.,those associated with the Yankee Nuclear Power Plant ISFSI). The total un-escalated costestimate for decommissioning the ISFSI, including contingency is $9.8 million, which includes$8.5 million for radiological removal and $1.3 million for non-radiological removal.

Thedecommissioning cost estimate is in 2013 dollars.7-1 YNPS License Termination PlanRevision 4YAEC will continue to inform the NRC regarding the status of this funding by complying withthe obligations defined in: 1) 10 CFR 50.75(f)(1) and (2) to submit an annual Decommissioning Funding Status Report; 2) 10 CFR 50.82(a)(8)(v) to submit an annual financial assurance statusreport regarding decommissioning funding;

3) 10 CFR 72.30(c) to resubmit thedecommissioning funding plan at intervals not to exceed three years; and 4) The scheduleprovided in the PSDAR will be maintained in accordance with 10 CFR 50.82(a)(7).

7.2 References

7-1 Letter from C. Pizzella (YAEC) to U.S. Nuclear Regulatory Commission, BYR 2012-043, "Independent Spent Fuel Storage Installation Decommissioning Funding Plan,"dated December 17, 2012.7-2 Letter from Alston & Bird LLP to Federal Energy Regulatory Commission, "YankeeAtomic Electric Company Docket No. ERI3- -000," dated May 1, 2013.7-2 YNPS License Termination Plan Revision 48 SUPPLEMENT TO THE ENVIRONMENTAL REPORTDecommissioning activities for and final status survey of the YNPS site, with the exception ofthe I SFSI and associated land areas (NOL-07, OOL-10-02, and NSY-10),

were completed as ofJanuary 2007. By letter dated November 21, 2005 (Reference 2-27), the NRC approved removalof the non-impacted land areas from the Part 50 License.

Subsequently, the NRC approved theremoval of the impacted areas of the site with the exception of the areas associated with theISFSI (FSS Survey Areas NOL-07, NSY-10, and OOL-10-02) from the Part 50 license via letterNYR 2007-046 (Reference 2-26). The information included in this section of the LicenseTermination Plan (LTP) includes historical information regarding the decommissioning of theYNPS that will be maintained in its current form. This information will be reviewed, and revisedas necessary, at the time of initiating the decommissioning activities for the ISFSI and associated land areas to ensure that appropriate information is available for the implementation of finalstatus survey activities for the ISFSI and termination of the Part 50 License for the YNPS site.8.1 Introduction 8.1.1 OverviewA decommissioning environmental report (Reference 8-1), dated December 1993, was preparedfor the YNPS site, in conjunction with the plant's Decommissioning Plan. This report concluded that the environmental impacts of decommissioning activities are small and bounded by thepreviously issued Final Generic Environmental Impact Statement (FGEIS) issued by the NuclearRegulatory Commission as NUREG-0586 (Reference 8-2) and by the YNPS environmental assessment, associated with construction period recapture.

In 1997, a License Termination Plan(LTP) was prepared and submitted to the NRC but was later withdrawn, following the release ofMARSSIM guidance (Reference 8-3). In 2002, activities associated with the LTP restarted usingMARSSIM and other updated guidance.

The purpose of this section of the LTP is to describe any new information on significant environmental impacts associated with site-specific license termination activities and todetermine if these impacts are within the scope of the environmental impacts previously evaluated either generically or on a site-specific basis by:I. the environmental impact statement developed in support of the original

facility,

2. the environmental impacts described in conjunction with the Decommissioning Plan (andPSDAR) related to decommissioning activities, or3. the Final Generic Environmental Impact Statement addressing decommissioning (NUREG-0586).

The NRC has issued guidance associated with the impacts of decommissioning, including Supplement I to NUREG-0586 (Reference 8-4). Supplement I to NUREG-0586 focuses on theimpacts of decommissioning nuclear power reactors licensed by the NRC, unlike the 1988FGEIS, which took a broad look at decommissioning of a variety of sites and activities.

Supplement I to NUREG-0586 is intended to consider, in a comprehensive manner, all aspectsrelated to the radiological decommissioning of nuclear reactor facilities.

Supplement I uses an8-1 YNPS License Termination PlanRevision 4approach that defines a measure of significance and severity of potential environmental impactsand an applicability of these impacts to a variety of facilities.

The significance of an impact isdescribed as being SMALL, MODERATE, or LARGE. The applicability of impacts is described as being generic or site-specific.

These terms are clearly defined in Section 4 of Supplement I toNUREG-0586.

Table H-1, located in Appendix H to Supplement 1 of NUREG-0586, provides a listing ofactivities for which the NRC has generically determined that no environmental impacts exist.Because these activities have already been determined not to result in environmental

impacts, nofurther review is required in connection with the LTP.Table H-2 provides a summary of the decommissioning activities and associated environmental issues that have been determined to have potential impacts.

As stated in Section 4.3 ofSupplement I to the FGEIS, if these plant-specific impacts fall within the scope of theenvironmental impacts previously identified and evaluated by the NRC staff, these activities canbe performed without further evaluation.

The issues identified in Table H-2 to be evaluated forplant-specific impacts are:* Onsite/offsite land use* Water use" Water quality" Air quality" Aquatic ecology" Terrestrial ecology" Threatened and endangered species* Radiological

• Radiological accidents

" Occupational

• Socioeconomics

• Environmental justice* Cultural impacts* Aesthetics

• Noise* Transportation

• Irretrievable resources.

According to Supplement I to NUREG-0586, the NRC assessed the impacts of each of theseissues using data from previous studies and environmental reviews in addition to information obtained during site visits and provided by plants undergoing decommissioning.

The NRC thenexamined the cumulative impacts of decommissioning activities and other past, present, andreasonably foreseeable future activities at the sites. After analyzing the issues, the NRCdetermined the impact of each and assigned a significance level (SMALL, MODERATE, orLARGE).8-2 YNPS License Termination PlanRevision 4The NRC also determined whether the analysis of the environmental issues could be applied toall plants. Each environmental issue identified was assigned one of the following two categories:

generic or site-specific.

Generic issues met the following three criteria:

1. The environmental impacts associated with the issue have been determined to apply to allplants, or, for some issues, to a group of plants of a specific size, specific locations, orhaving a specific type of cooling system or site characteristic.

2. A single significance criterion (SMALL, MODERATE, or LARGE) has been assigned todescribe the impacts.3. Mitigation of adverse impacts associated with the issue has been considered in theanalysis, and it has been determined that additional plant-specific mitigation measures arelikely not to be sufficiently beneficial to warrant implementation.

LIf one or more of the above criteria cannot be met, the issue is considered to be "site-specific" and a site-specific evaluation of the issue is required.

Table 8-1 summarizes the NRC's findingswith respect to applicability and impact of the identified environmental issues pertinent todecommissioning.

Decommissioning and license termination activities at YNPS fall within the range of activities evaluated for the FGEIS and NUREG-0586, Supplement

1. For those issues identified as"generic" in Table 8-1, the NRC's prior conclusions bound environmental impacts at YNPS fromdecommissioning and license termination.

The LTP addresses the issues identified in Table 8-1 as "site-specific."

In addition, consistent with RG 1.179, the review focuses on any new information or significant environmental changeassociated with site-specific termination issues. Impacts associated with site-specific termination activities have been compared to previously analyzed decommissioning and termination activities, in this LTP and its references.

The proposed termination activities related to the enduse of the site do not result in significant environmental changes that are not bounded by the site-specific decommissioning activities described in the Decommissioning Plan, PSDAR, theFGEIS, or NUREG-0586.

Note that the review and conclusion in this Section relate only to activities and impactsassociated with termination of the NRC license.

YNPS is conducting other site characterization for non-radiological remediation and site restoration, which are not part of the licensetermination activities and are outside of the scope of NRC regulation.

The non-radiological activities are addressed in an environmental closure plan that was submitted to the Massachusetts Department of Environmental Protection acting as the lead agency. Other agencies, such as theEPA, are also routinely involved in aspects of non-radiological site remediation.

8-3 YNPS License Termination PlanRevision 48.1.2 Proposed Site Conditions at the Time of License Termination The YNPS site is intended to be released for unrestricted use, under the radiological releasecriteria of I OCFR20.1402 (Reference 8-5) upon termination of its NRC license.

Sections 3 and 4of this LTP discuss in greater detail the activities that have been completed, those ongoing andremaining, and the proposed final state of the site.At the time of license termination, the site will be a backfilled and graded land area, with thepotential for selected above grade structures to remain. In general, structures were demolished tosite elevation 1022'-8" with the demolition debris passing final status survey or meeting the "nodetectable" criteria able to be used as backfill onsite. Any remaining slabs will be perforated, toallow groundwater to flow through.In general buried piping and utilities were removed.

Any buried piping or utilities that remainwere evaluated and surveyed in place, as appropriate, in accordance with plant procedures toensure that no detectable radioactivity exists.8.1.3 Remaining Dismantlement and Decommissioning Activities YAEC originally submitted a Decommissioning Plan (Reference 8-7), which was approved inFebruary of 1995. In accordance with Regulatory Guide 1.185 (Reference 8-8), licensees withapproved decommissioning plans were permitted to "replace their decommissioning plans with a.Post-Shutdown Decommissioning Activities Report (PSDAR) update that uses the format andcontent specified in this document."

YAEC later elected to relocate pertinent information to aPSDAR (Reference 8-9) conforming to the guidance of Regulatory Guide 1.185.YAEC continues to implement the DECON alternative as the most appropriate alternative fordecommissioning the YNPS site. Evaluation of the environmental effects of the DECONalternative is contained in NUREG-0586 and its supplement.

8.1.3.1 General Description of Decommissioning Activities Since 1993 YAEC has removed and disposed of the steam generators, pressurizer, reactor vesseland reactor vessel internals.

Portions of the reactor vessel internals are considered to be greater-than-Class-C (GTCC) waste and are stored in the ISFSI.As indicated in the PSDAR, the decommissioning activities are being completed in three phases:* The first phase of decommissioning consisted of mechanically and electrically isolating the Spent Fuel Pit, removing of any systems and components that did not support fuelstorage in the SFP or subsequent decommissioning, and moving spent fuel and GTCC tothe ISFSI. The first phase of decommissioning was completed when the spent fuel andall GTCC waste was removed from the SFP in June of 2003.* The second phase of decommissioning involves the dismantlement and de-contamination of remaining

systems, structures, and components (SSCs. This phase of8-4 YNPS License Termination PlanRevision 4decommissioning is ongoing.

With the exception of decommissioning activities at theISFSI to be undertaken when all fuel and GTCC waste have been removed from the site,all decommissioning and dismantlement activities have been completed at this site.* The final phase of decommissioning is the termination of the possession only license.A more detailed discussion of the activities to be performed in each of the phases is provided inSection 3 of this LTP8.1.3.2 Other Decommissioning Considerations The PSDAR discusses other decommissioning considerations, including decontamination anddismantlement

methods, storage and removal of spent fuel and GTCC waste, and site restoration.

8.1.3.3 General Decommissioning Activities Related to Removal of Radiological Components and Structures Site structures and components were removed using techniques and methods appropriate for theparticular circumstances and were consistent with Decommissioning Work Packages.

Openingsin structures were typically covered or sealed to minimize the spread of contamination.

Components were moved to an area for processing or volume reduction and/or packaging intocontainers, so that they can then be shipped to a processing facility for decontamination or to alow-level radioactive waste disposal facility.

Buried contaminated components weredecontaminated to meet the free release criteria or were excavated and removed for disposal.

8.1.3.3.1 Decontamination MethodsContaminated systems and components were removed and sent to an offsite processing facilityor to a low-level radioactive waste disposal facility.

Onsite decontamination of systems andcomponents was generally limited to those activities needed to maintain personnel exposureALARA, to expedite equipment

removal, and to minimize the spread of contamination.

Application of coating and hand wiping were the preferred methods for stabilizing or removingloose surface contamination.

If other methods were employed (e.g., grit blasting, high-pressure washing),

airborne contamination control and waste processing systems are used, as necessary, to control and monitor any release of contamination.

Contaminated and activated

concrete, as well as other contaminated materials, were removed andsent to a low-level radioactive waste disposal facility.

Concrete removal methods, such asscabbling and scarifying, controlled concrete removal depth in order to minimize the wastevolume produced.

Vacuuming the dust and debris effluent with HEPA filtration minimized theneed for additional respiratory protection control measures.

YAEC considered newdecommissioning techniques and technologies, as appropriate.

8-5 YNPS License Termination PlanRevision 48.1.3.3.2 Dismantlement MethodsYAEC used two basic dismantlement methods:* Mechanical methods:

Mechanical methods machine the surface of the material that isbeing cut. Typically, these methods are capable of cutting remotely without generating significant amounts of airborne contamination.

This attribute makes mechanical methodsattractive for removing most of the contaminated piping, components, and equipment.

• Thermal methods:

Thermal methods melt or vaporize the surface of the material beingcut. The cutting debris is transported from the cut region with a gas jet or water spray.Although thermal methods are more expedient than mechanical

methods, they have largepower requirements and generate airborne contamination when applied to contaminated systems in an air environment.

However, thermal methods can be used with a cuttingstation and air filtration.

For these reasons, application of thermal cutting methods oncontaminated

systems, structures or equipment is being restricted to areas that can beeasily sealed, filtered, or maintained under water. Appropriate lead paint removalcontrols must also be implemented when using thermal cutting methods.8.1.3.3.3 Special ProgramsThere were no special or unusual programs related to the decommissioning of YNPS. Allprocedures and processes used at YNPS were consistent with those considered in the FGEIS andits supplement.

8.1.3.3.4 Removal ofLL Wand Compaction or Incineration LLW was being processed in accordance with plant procedures and sent to LLW disposalfacilities.

While no incineration occurred onsite, YAEC used an offsite licensed facility.

8.1.3.3.5 Soil Remediation Soils and pavement were being surveyed and characterized in accordance with the siteradiological characterization program.

As necessary, soils, and pavement were remediated (i.e.,removed, processed and disposed of at a licensed facility) if determined to contain contamination levels above the site release criteria.

8.1.3.3.6 Processing and Disposal Site Locations Currently, there are several facilities available for (1) processing of waste materials to achievevolume reduction prior to disposal or (2) disposal of low-level radioactive waste.8-6 YNPS License Termination PlanRevision 48.1.3.3.7 Removal of Mixed WastesMixed wastes were managed according to all applicable federal and state regulations, including NRC handling,

storage, and transportation regulations.

Mixed wastes from YNPS weretransported only by authorized and licensed transporters and shipped only to authorized andlicensed facilities.

YAEC used an appropriate approved process to render the mixed waste non-hazardous.

8.1.3.3.8 Storage/Removal of Spent Fuel and GTCC Waste and Decommissioning ofthe ISFSIYAEC will store spent fuel and GTCC waste in the ISFSI, until the DOE takes title to suchwastes. Movement of fuel to the ISFSI began in June of 2002 and was completed in June of2003. GTCC wastes were moved to the ISFSI in June of 2003.YAEC cannot make a precise determination of when spent fuel and GTCC wastes will beremoved from the YNPS site. Currently, YAEC expects that turnover to the DOE of spent fueland GTCC wastes will be completed in 2031.Following the removal of the spent fuel and GTCC waste from the YNPS site, the VerticalConcrete Casks and ISFSI Storage Pad will be removed as low-level radioactive waste.8.1.3.3.9 LTP, Final Status Survey, and Site Release CriteriaThe ultimate goal of decommissioning the YNPS site is to release it for unrestricted use. Thisrequires assurance that future uses of the site, after license termination, will not expose membersof the general public to unacceptable levels of radiation.

Section I provides a history of previous LTP and final status survey (also referred to as the finalradiological survey) activities.

Consistent with a commitment made in the PSDAR, this LTPuses the guidance of NUREG-1700 to address the I OCFR20 criteria for license termination.

Final status surveys will then be conducted to verify that structures and open land areas meet therelease criteria.

An independent NRC contractor will then conduct a verification survey, therebyallowing unrestricted release of the site. After final status survey and NRC verification, some ofthe remaining surveyed structures and open land areas may be removed from the license.

YAECwill then maintain control over the site until license termination.

With the exception of decommissioning activities at the ISFSI to be undertaken when all fuel and GTCCwaste have been removed from the site, all decommissioning and dismantlement activities have beencompleted at this site.8.1.3.3.10 Site Restoration Following termination of the YNPS possession-only license by the NRC, YAEC will completethe final site restoration activities.

The remaining site areas will be graded and landscaped asnecessary.

8-7 YNPS License Termination PlanRevision 48.1.3.4 Schedule of Decommissioning Activities The current schedule for decommissioning activities is provided in Section 3 of this LTP.Planning sequences and dates are based upon current knowledge and could change in the future.Yankee will continue to inform the NRC of all major changes to the planned decommissioning activities in accordance with I OCFR50.82(a)(7).

8.1.3.5 Conclusions Regarding Environmental Impact Included in the PSDARThe PSDAR included a discussion of environmental impacts from decommissioning the YNPS.These conclusions were based largely upon the information provided in the YNPSDecommissioning Environmental Report (DER). The DER was based upon NUREG-0586, "Final Generic Environmental Impact Statement (FGEIS) on Decommissioning of NuclearFacilities" and the site-specific environmental assessment from the re-capture of the construction time period.The PSDAR concluded that the impacts due to decommissioning would be bounded by thepreviously issued environmental impacts statements.

This was principally due to the following reasons:* The postulated impacts associated with the method chosen, DECON, have already beenconsidered in the FGEIS." There are no unique aspects of the plant or decommissioning techniques to be utilizedthat would invalidate the conclusions reached in the FGEIS.* The methods to be employed to dismantle and decontaminate the site are standardconstruction-based techniques fully considered in the FGEIS." The site-specific person-rem estimate for all decommissioning activities has beenconservatively calculated using methods similar to those used in the FGEIS.Specifically, the review concluded that the YAEC decommissioning will result in generally positive environmental

effects, in that:* Radiological sources that create the potential for radiation exposure to site workers andthe public will be eliminated.

" The site will be returned to a condition that will be acceptable for unrestricted use." The thermal impact on the Deerfield River from facility operations will be eliminated.

• Noise levels in the vicinity of the facility will be reduced.* Hazardous material and chemicals will be removed.8-8 YNPS License Termination PlanRevision 4* Local traffic will be reduced (fewer employees, contractors and materials shipments thanrequired to support an operating nuclear power plant).Furthermore, the YNPS decommissioning will be accomplished with no significant adverseenvironmental impacts in that:* No site-specific factors pertaining to YNPS will alter the conclusions of the FGEIS.* Radiation dose to the public will be minimal." Radiation dose to decommissioning workers will be a fraction of the operating exposure.

• Decommissioning is not an imminent health or safety problem and will generally have apositive environmental impact.The Decommissioning Plan estimated the total radiation exposure impact for decommissioning to be 744 person-rem.

This estimate was re-evaluated in 1996, resulting in a lower value of 580person-rem (Reference 8-9). The actual exposure, through December 31, 2002, fordecommissioning activities is 555 person-rem (Reference 8-10).Radiation exposure due to transportation of radioactive waste has been conservatively estimated to be approximately 7 person-rem.

This value is bounded by the FGEIS value of 100 person-rem of occupational exposure for transport of radioactive material.

In Supplement I to NUREG0586, the very low activity waste dose rates were considered to be so low that they did not haveto be considered in the transportation dose estimate.

All of the material associated with the VCCsand the ISFSI storage pad that will be shipped to a low-level radioactive waste site is considered to be very low activity waste.Radiation exposure to offsite individuals for expected conditions, or from postulated accidents isbounded by the Environmental Protection Agency's Protective Action Guidelines and NRCregulations.

The public exposure due to radiological effluents will continue to remain wellbelow the 10CFRPart 20 limits and the ALARA dose objectives of 1OCFR50, Appendix I. Thisconclusion is supported by the YNPS Annual Effluent Release Reports in which individual dosesto members of the public are calculated for station liquid and gaseous effluents.

No significant impacts are expected from the disposal of low-level radioactive waste (LLW).The total volume of YNPS LLW for disposal was estimated in the Decommissioning Plan to beapproximately 132,000 cubic feet. A total volume of approximately 1,670,000 ft3 of LLW wasshipped from the YNPS site for off-site disposal during decommissiong of the plant. Asignificant portion of this waste contained very low levels of radioactivity (DOT exempt) andwas created as a result of remediation activities to satisfy EPA cleanup requirements for PCBs, tosatisfy the Massachusetts Department of Public Health (DPH) radiological release criteria of 10mRem/year and to meet the Massachusetts Contingency Plan regulations for non-radiological release criteria under the Department of Environmental Protection (DEP) requirements.

Thevolume of LLW that would have been required to be disposed of to satisfy the NRC's 25mRem/year 8-9 YNPS License Termination PlanRevision 4release criteria would have been a significantly lower volume in the 300,000 ft3 range,significantly below the FGEIS estimate of 647,670 ft3 for a reference PWR.The decommissioning cost estimate assumes that all of the material associated with the VCCsand the ISFSI storage pad will be shipped offsite as low-level radioactive waste. This assumption was made to maximize the cost of disposal of radioactive materials in the decommissioning costestimate.

YAEC does not anticipate that this material would be required to be disposed of tosatisfy the NRC's 25 mRem/year release criteria.

Since the approval of the Decommissioning Plan and the issuance of the Decommissioning Environmental Report, YNPS has identified the presence of polychlorinated biphenyls (PCBs)from some paint coatings in soil. As in the case of radiologically contaminated lead paint,asbestos, and other hazardous materials, contaminated paint that contains PCBs will be managedaccording to all applicable federal and state regulations.

No significant environmental impacts are anticipated in the event that LLW is required to betemporarily stored onsite because adequate storage space exists and LLW storage will be inaccordance with all applicable federal and state regulations.

Extending the storage period from2022 through 2031 does not have a significant impact, because all applicable federal and stateregulations will be met.The non-radiological environmental impacts from decommissioning are temporary and are notsignificant.

The largest occupational risk associated with decommissioning YNPS is related tothe risk of industrial accidents.

The primary environmental effects are short term: smallincreases in noise levels and fugitive dust in the immediate vicinity of the site, as well as trucktraffic to and from the site for hauling equipment and waste. No socioeconomic

impacts, otherthan those associated with the cessation of operations (loss of jobs and taxes) have beenidentified.

Also, no significant impacts to local culture, terrestrial or aquatic resources, such asthe Sherman Reservoir and Deerfield River have been identified.

8.2 Analysis of Site-Specific Issues8.2.1 Onsite-Offsite Land Uses8.2.1.1 Onsite Land UsesThe environmental impacts associated with onsite land uses have been determined by the NRC tobe generically applicable with a SMALL impact. The NRC's analysis of the environmental impacts of onsite land uses is documented in Section 4.3.1 of Supplement I to NUREG-0586.

YNPS is located on a 2200 acre site, of which approximately 10 acres have been developed forplant use. Decommissioning activities involve the same areas used during initial construction and during operations.

The use of a small fraction of the total site area land impacted bydecommissioning and the re-use of areas used during initial construction are consistent with theNRC's assumptions in Supplement I to NUREG-0586, and thus there are no significant environmental impacts associated with YNPS decommissioning.

8-10 YNPS License Termination PlanRevision 4YAEC has identified no new information or significant environmental change associated withthe site-specific termination activities related to the end use of the site.8.2.1.2 Offsite Land UsesOnly areas within the existing site boundary (i.e., the area that remains within the control of the10 CFR 50 License) will be used to support decommissioning and license termination activities (such as temporary storage areas and staging areas). As discussed previously in this section, andin detail in Section 5, isolation and control measures will be instituted to prevent the spread ofcontamination.

These measures will also be monitored to ensure their effectiveness.

Thus, noenvironmental impacts associated with the use of offsite lands are anticipated from YNPSdecommissioning and license termination activities.

8.2.2 Water UseThe environmental impacts associated with water use, during decommissioning, have beendetermined by the NRC to be generically applicable with a SMALL impact. The NRC's analysisof the environmental impacts of water use is documented in Section 4.3.2 of Supplement I toNUREG-0586.

During plant operation, an average of 0.4 million gallons of water per day from the ShermanReservoir was used to cool plants systems.

Water use was discussed in the "Environmental Assessment by the U.S. Nuclear Regulatory Commission, Related to the Request to Authorize Facility Decommissioning,"

dated December 14, 1994 (Reference 8-12). At that point in thedecommissioning

project, water usage was estimated to be less than 1% of the average waterusage during operations.

Since 1994, a number of systems that contributed to water usage have been removed fromoperation.

Section 3 of this LTP describes those water-containing systems that have beenremoved from service or drained and identifies the systems remaining in operation.

Only a fewsystems remain, and as described in Supplement 1 to NUREG-0586, the operational demands forcooling and make-up water have been eliminated with the removal of spent fuel and GTCCwaste from the spent fuel pit.Use of water for decontamination of systems such as the Reactor Coolant System and the SpentFuel Pit are addressed in the FGEIS. Other water usage, such as for dust abatement, are similarto those that occurred during construction of the plant. In addition, potable water fordecommissioning contractor staff is being provided via bottled water, and sanitary services areprovided by portable toilet facilities, thus minimizing the impacts on the on-site water supply.In summary, the conditions for YNPS decommissioning are consistent with the assumptions ofSupplement 1 to the FGEIS, and thus there are no significant environmental impacts associated with water use during the decommissioning of the YNPS. YAEC has not identified any newinformation or significant environmental change associated with the site-specific termination activities related to the end use of the site.8.2.3 Water QualityThe environmental impacts associated with surface water quality have been determined by theNRC to be generically applicable with a SMALL impact. The NRC's analysis of the8-11 YNPS License Termination PlanRevision 4environmental impacts of surface water quality is documented in Section 4.3.3 of Supplement 1to NUREG-0586.

All discharges are controlled under the National Pollutant Discharge Elimination System(NPDES) permit (Reference 8-13). This permit is issued jointly by the U.S. Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (MDEP). The Offsite Dose Calculation Manual (Reference 8-14) also addresses limitations ondoses to members of the public from liquid effluent and requires that they be maintained belowthe limits in:* IOCFR50, Appendix 1;S10OCFR20, Appendix B, Table 2, Column 1; and* 40CFR190.

Radiological impacts are being assessed and monitored by use of on- and offsite groundwater monitoring wells for aquifers that discharge to Sherman Reservoir, including monitoring Sherman Spring. Currently the levels of radionuclides in these well samples, with the exception of tritium, are below the EPA's drinking water MCLs. A detailed discussion about thegroundwater assessments (completed and planned) and available data are provided in Section 2of this LTP.As previously discussed, site buildings are being removed to ground level at 1022'-8",

andbasements are being cleaned to meet the appropriate DCGLs. These basements are also beingperforated to allow equilibrium with the water table, and soils are being used to backfill theholes. Concrete debris from demolition of the buildings may be used as backfill onsite if itpasses a final status survey or meet the "no detectable" criteria.

A "beneficial use determination" (BUD) to use this concrete as backfill is being filled with the State of Massachusetts Department of Environmental Protection.

As a part of the BUD approval, the DEP must make the conclusion that the reuse will not cause significant risk or impact or create a nuisance condition.

The conditions for YNPS decommissioning are consistent with the assumptions of Supplement Ito the FGEIS, and thus there are no significant environmental impacts associated with surfacewater quality during the decommissioning of YNPS. YAEC has not identified any newinformation or significant environmental change associated with the site-specific termination activities related to the end use of the site.8.2.4 Air QualityThe environmental impacts of decommissioning associated with air quality have beendetermined by the NRC to be generically applicable with a SMALL impact. The NRC's analysisof the environmental impacts of air quality is documented in Section 4.3.4 of Supplement 1 tothe FGEIS.8-12 YNPS License Termination PlanRevision 4Supplement 1 to the FGEIS identifies the following decommissioning activities as having thepotential for non-radiological impacts on airquality:

" Worker transportation to and from the site,* Dismantling of systems and removal of equipment,

• Movement and open storage of materials onsite,* Demolition of buildings and structures, and" Shipment of material and debris to offsite locations.

Worker transportation:

Consistent with the assumptions in the FGEIS, the work force at YNPShas decreased from the time the plant ceased operation.

The work force will further decrease asdecommissioning nears completion.

There will and have been occasional increases duringspecific decontamination and decommissioning activities.

The work force duringdecommissioning is smaller than that associated with plant construction and refueling at YNPS.Accordingly, the adverse changes in air quality, associated with changes in workertransportation, will not be detectable and are not destabilizing.

Dismantling systems and removal of equipment:

Generation of particulate matter associated with the physical activities of dismantlement and by the release of gases from systems duringremoval are potential sources that could impact air quality.

Methods and provisions areavailable to minimize fugitive dust (e.g., wet suppression and chemical stabilization agents) andto minimize airborne contamination in buildings (e.g., isolation of areas and HEPA filtration).

Local filtration systems can also be used when activities are located in areas that are notventilated to the plant stack, and are likely to generate airborne radioactivity.

Thus, it is highlyunlikely that particulate matter generated during decommissioning and released to theenvironment will be detectable offsite.

Any refrigerants will be disposed of in accordance withthe applicable state and federal regulations.

Movement and open storage of materials onsite: Movement of equipment and open storage ofmaterials during decommissioning may result in fugitive dust. Provisions as discussed in Section3 and identified above can mitigate these effects.

Thus, it is highly unlikely that particulate matter generated as a result of movement or storage of material onsite will be detectable offsite.Demolition of buildings or structures:

As discussed in the FGEIS, demolition of structures andbuildings on the YNPS site may result in a temporary increase in fugitive dust. The controlled dismantlement and packaging of site components and structures will minimize the potential forfugitive dust from becoming an ambient air quality concern during decommissioning.

Fugitivedust from demolition of buildings and structures generally involves large particles that settlequickly.

Dust and smaller particles will be controlled using mitigation methods such as wetsuppression.

Thus, it is highly unlikely that particulate matter generated as a result of building orstructure demolition will be detectable offsite.Shipments of material to an offsite location:

Material, debris, and equipment will be removedfrom the site during decommissioning.

Although the remaining number of shipments to be sentduring decommissioning is relatively large, these shipments are taking place over a couple ofyears, and thus the average number of shipments per day is relatively small. As stated in the8-13 YNPS License Tennination PlanRevision 4FGEIS, it is unlikely that the emissions associated with the small number of daily shipments would be detectable offsite.Air effluent released from the site is monitored in accordance with the Offsite Dose Calculation Manual (ODCM) which sets limits on doses caused by effluents, based upon the ALARA (as lowas reasonably achievable) objectives of IOCFR50.34a, IOCFR50.36a, and Section IV.B.1 ofAppendix I to 1 OCFR50. Effluents are reported annually to the NRC.Based upon the above considerations, it has been determined that the conclusions of the FGEISare applicable to YNPS, and decommissioning of YNPS will not noticeably affect offsite airquality.

YAEC has not identified any new information or significant environmental changeassociated with the site-specific termination activities related to the end use of the site.8.2.5 Aquatic Ecology8.2.5.1 Activities Within the Operational AreaThe environmental impacts associated with aquatic ecology for decommissioning activities within the operational area have been determined by the NRC to be generically applicable with aSMALL impact. The NRC's analysis of the environmental impacts of aquatic ecology foractivities within the operational area is documented in Section 4.3.5 of Supplement I toNUREG-0586.

Any new wetland areas created as a result of the ISFSI construction will remainduring decommissioning.

8.2.5.2 Activities Outside of the Operational AreaThe FGEIS identifies generation of runoff due to ground disturbances and surface erosion ashaving the potential to impact aquatic resources.

Provisions will be made to reduce surfaceerosion and runoff.It is understood that decommissioning of shoreline and in-water structures has the potential toimpact aquatic habitats and biota. YAEC will consult with regulatory and resource agencies toobtain permits and plan activities to minimize the duration and extent of these impacts.Regardless, impacts would be limited to those areas previously disturbed during construction andoperation, and these areas would be expected to re-colonize as they did following initialconstruction.

Thus, even considering the removal of shoreline and in-water structures, theimpacts of decommissioning on aquatic ecology are minimal.YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the end use of the site.8.2.6 Terrestrial Ecology8.2.6.1 Activities Within the Operational AreaThe environmental impacts of decommissioning associated with terrestrial ecology for activities within the operational area have been determined by the NRC to be generically applicable with aSMALL impact. The NRC's analysis of the environmental impacts of terrestrial ecology for8-14 YNPS License Termination PlanRevision 4activities within the operational area is documented in Section 4.3.6 of Supplement 1 to theFGEIS.8.2.6.2 Activities Outside the Operational AreaOnly areas within the existing site boundary (i.e., the area that remains within the control of the10 CFR 50 Licensing) will be used to support decommissioning and license termination activities (such as temporary storage areas and staging areas). These areas are within those areasthat were disturbed during initial construction.

The FGEIS states that terrestrial habitatsdisturbed during the construction of the site often continue to be of low habitat quality duringoperation and decommissioning.

As discussed previously in this section, and in detail in Section 5, isolation and control measureswill be instituted to prevent the spread of contamination, and these measures will be monitored toensure their effectiveness.

Because the YNPS site has been in active decommissioning since thedecision to permanently close the facility was made, it is reasonable to conclude that areasdisturbed during the construction and operation of the plant have not become new sensitive areaswith respect to terrestrial biota. Thus, no environmental impacts associated with the use ofoffsite lands are anticipated from YNPS decommissioning and license termination activities related to the end use of the site.8.2.7 Threatened and Endangered SpeciesWhile the YNPS site consists of over 2000 acres of land, only a small fraction consisting ofapproximately 10 acres has been developed for plant use. During planning and construction ofthe independent spent fuel storage facility (which is adjacent to the areas beingdecommissioned),

the Natural Heritage and Endangered Species Program (NHESP),

an agencyof the Department of Fisheries,

Wildlife, and Environmental Law Enforcement, was contacted toreview impacts.

This review included activities associated with the installation of the ISFSI pad,road improvements, and improvements to the present storm water system. The NHESP haddetermined that the activities do not occur within the actual habitat of a state-protected rarewildlife species (Reference 8-15).However, during recent field surveys to complete the mapping and to characterize naturalcommunities, a late-larval spring salamander (Gyrinophilusporphyriticus) was identified on theYAEC property.

It was found at the northeast end of the property, in one of the headwater channels of Wheeler Brook and very near the property line (which is also theMassachusetts/Vermont State Line) in a forestry management area.The spring salamander is a species of Special Concern in Massachusetts.

This status means thatit is a species that has either been documented as suffering a decline that could threaten thespecies if allowed to continue or which occurs in small numbers or with a very restricted distribution in the state.The implications of this species occurring on the site are fairly minimal since (1) this speciesoccurs in a habitat that is already provided a high level of protection under the Massachusetts Wetlands Protection Act and (2) spring salamanders hardly ever stray far from their homestreams.

Standard best forestry practices include limiting stream crossings, retain tree cover8-15 YNPS License Termination PlanRevision 4adjacent to streams, and prohibit activities (such as skidding or brush piling) in streams.

Noevidence of any past forest management activities affecting habitat in this stream was observedduring the survey and future forest management activities are not expected to require alteration of the stream.Only a very small section of Wheeler Brook comes close to the industrial portion of the property, less than 200 feet. In that area, Wheeler Brook is generally of lower gradient than preferred bythe spring salamander.

Therefore, decommissioning and license termination activities at theYNPS site are not expected to affect the spring salamander.

Thus, decommissioning and license termination activities at the YNPS site does not adversely impact threatened or endangered species.8.2.8 Radiological 8.2.8.1 Activities Resulting in Occupational Doses to WorkersThe environmental impacts associated with radiological activities resulting in occupational dosesto worker have been determined by the NRC to be generically applicable with a SMALL impact,because of the existence of guidance regulating doses to workers (IOCFR20) which remainapplicable to the YNPS. The NRC's analysis of the environmental impacts of radiological activities resulting in occupational doses to workers is documented in Section 4.3.8 ofSupplement I to NUREG-0586.

8.2.8.2 Activities Resulting in Doses to the PublicThe environmental impacts associated with radiological activities resulting in doses to the publichave been determined by the NRC to be generically applicable with a SMALL impact, becauseof the existence of guidance regulating and documenting doses to members of the public(IOCFR20).

The NRC's analysis of the environmental impacts of radiological activities resulting in doses to the public is documented in Section 4.3.8 of Supplement I to NUREG-0586.

YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the end use of the site.Potential doses to the public following license termination are not covered by the Supplement tothe FGEIS but were evaluated during promulgation of rulemaking for the radiological criteria forlicense termination (IOCFR20.1402).

The basis for public health and safety considerations associated with the license termination rule is discussed in NUREG-1496.

8.2.9 Radiological Accidents The environmental impacts associated with radiological accidents have been determined by theNRC to be generically applicable with a SMALL impact. The NRC's analysis of theenvironmental impacts of radiological accidents is documented in Section 4.3.9 of Supplement 1to NUREG-0586.

YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the end use of the site.The NRC concluded that radiological

impacts, due to accidents, are considered to beundetectable and non-destabilizing, in the National Environmental Policy Act (NEPA) sense, ifthe doses remain within regulatory limits. The YNPS FSAR provides a summary of the8-16 YNPS License Termination PlanRevision 4evaluation of plant transients that have a potential impact on both occupational and public safetyand health. The risk of accidents resulting in a significant radiological release duringdecommissioning activities is considerably less than during plant operations.

The analysis of decommissioning events includes all phases of decommissioning activities:

decontamination, dismantlement, packaging,

storage, radioactive materials

handling, and licensetermination activities (including final status surveys).

The following radiological events wereidentified as having the potential to affect public health and safety:* Decommissioning activity events.* Loss of support system events, including loss of offsite power, cooling water andcompressed air.* Fire and explosion events." External events.* Spent fuel storage events.YAEC requested and received an exemption from the emergency preparedness requirements ofI OCFR50.47 (Reference 8-16); however, approval of the exemptibn request was predicated onthe absence of any accidents where the offsite dose consequences could exceed the EPAprotective action guidelines (PAGs). Releases resulting from accidents postulated in thedecommissioning accident analysis were evaluated using the EPA PAGs as an upper limit andfound to be bounded by this criterion.

Use of the EPA PAGs as an administrative limit alsoensure that postulated accident offsite doses are significantly less than the I OCFRI 00 reference values. This exemption was confirmed by the NRC in an exemption issued on May 7, 2013(Reference 8-25) and re-issued on August 15, 2013 (Reference 8-26).On August 10, 2007 (Reference 2-26), the NRC approved the release of the majority of landfrom the 10 CFR 50 License.

In the August 10, 2007 Safety Evaluation Report, the NRC stated:"10 CFR Part 100 addresses design and environmental aspects to be considered in siting a powerreactor.

Decommissioning of the YNPS power reactor portion of the site has been completed.

Only the ISFSI and a 300 m boundary will remain after this proposed partial site release.Therefore, the criteria of 10 CFR Part 100 no longer apply to this site and need not beaddressed."

Thus, the associated impacts on the environment are minimal.8.2.10 Occupational IssuesThe environmental impacts of occupational issues have been determined by the NRC to begenerically applicable with a SMALL impact. The NRC's analysis of the environmental impactsof occupational issues is documented in Section 4.3.10 of Supplement I to NUREG-0586.

YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the end use of the site.8-17 YNPS License Termination PlanRevision 4As Supplement I to the FGEIS indicates, the Occupational Safety and Health Act of 1970 wasenacted to protect the health of workers, and applicable regulations are administered by theOccupational Safety and Heath Administration (OSHA). YNPS is subject to 29 CFR 1910 and1926 for worker health and safety protection under OSH1A regulations.

These requirements areimplemented under existing plant programs and procedures.

8.2.11 Socioeconomic ImpactsThe environmental impacts of socioeconomic impacts have been determined by the NRC to begenerically applicable with a SMALL impact. The NRC's analysis of the environmental impactsof socioeconomic impacts is documented in Section 4.3.12 of Supplement I to NUREG-0586.

The impacts that are observed by the community are primarily those resulting from plant closurerather than from decommissioning, although some decommissioning activities began veryshortly after closure.

These impacts occur either through changes in employment levels andlocal demands for housing and infrastructure, or through decline of the local tax base and theability of local government entities to provide public services.

Supplement I to NUREG-0586 states that decommissioning, itself, has no impact on the tax base and no detectable impact on thedemand for public services.

Additionally Supplement I to NUREG-0586 concludes that the effects of employment changeson population growth are:1. not detectable if population changes (reductions or increases) are less than 3% per year,2. detectable but not destabilizing if the population change is between 3% and 5%, and3. de-stabilizing if the population change is greater than 5% per year.Table 8-2 shows the change in population over the last two decades.

For the decade 1990 to2000, which includes the period of shutdown and partial decommissioning, the overall change inpopulation in the vicinity of the site was a 5% decrease over this ten-year period. The averageannual population change, based upon the data from 1990 and 2000, does not exceed the NRC'sthreshold of 3%, and thus signifies that the changes are neither detectable nor destabilizing.

Thus no significant socioeconomic impacts are associated with YNPS decommissioning andlicense termination activities related to the end use of the site.8.2.12 Environmental JusticeRadioactive waste shipments, from the site to an interstate

highway, traverse a six-county areaincluding the following counties:

Berkshire,

Franklin, and Hampshire in Massachusetts; Bennington in Vermont; and Columbia and Rensselear in New York. The total population ofthis area is approximately 611,400 people. The number of minority (non-white) persons isabout 7% of the total population, and the percentage of people below the poverty level is about9% of the total population.

The area is generally rural along the shipping routes. These datawere derived from the Bureau of the Census 2000 Reports (References 8-17, 8-18, and 8-19).Environmental Justice was addressed by the NRC during the review and approval of the YNPSDecommissioning Plan (Reference 8-20). The NRC concluded that there are no significant environmental impacts associated with the proposed decommissioning activity that would have a8-18 YNPS License Termination PlanRevision 4significant effect on the quality of the human environment.

The NRC included consideration ofthe transportation of radioactive wastes from the YNPS site to the interstate transportation corridor (both rail and highway) and concluded that such transportation will not have adisproportionate effect on minority or low income populations.

These conclusions remain valid. The types of decommissioning and license termination activities, conducted or planned at YNPS, are not significantly different than those described inthe Decommissioning Plan and the assumptions related to affected populations remain valid,considering the information from the 2000 Census, presented above. Thus, there are noenvironmental justice impacts introduced by decommissioning or license termination.

8.2.13 Cultural and Historic Resource Impacts8.2.13.1 Activities Within the Operational AreaThe environmental impacts associated with cultural and historic resource impacts from activities within the operational area have been determined by the NRC to be generically applicable with aSMALL impact. The NRC's analysis of the environmental impacts of cultural and historicresource impacts from activities within the operational area is documented in Section 4.3.14 ofSupplement I to NUREG-0586.

YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the enduse of the site.8.2.13.2 Activities Outside the Operational AreaAn independent review of files from the Massachusetts Historic Commission, the Massachusetts State Archives, and the State House Library was performed to determine the significance ofbuildings and areas in the vicinity of the YNPS site. There are no historic or cultural resources which are listed in the National Register of Historic Places within five miles of the plant(References 8-21, 8-22, 8-23 and 8-24). The Hoosac Tunnel, just beyond five miles of the site tothe southwest, is designated as a National Register Property.

The closest locale considered tohave local historic significance is the Brigham Young birthplace monument located inWhitingham,

Vermont, approximately five miles northeast of YNPS. The Sherman DamDevelopment District (including individual structures) and the Monroe Bridge Development/

Glassine Paper Company/Deerfield Dam District (including individual structures) have beendeemed eligible to be on the State Register of Historic Places. The YNPS structures have notbeen identified as a historic site or asset, and decommissioning and license termination activities will not involve or impact any site or structure listed in the State Register of Historic Places.8.2.14 Aesthetics The environmental impacts associated with aesthetics have been determined by the NRC to begenerically applicable with a SMALL impact. The NRC's analysis of the environmental impactsof aesthetics is documented in Section 4.3.15 of Supplement I to NUREG-0586.

Aesthetic resources include natural and man-made landscapes and the way the two areintegrated.

As a part of construction and operation of the facility, the landscape was previously altered.

Decommissioning activities will be conducted onsite, both inside and outside ofexisting buildings (in the case of dismantlement or shipping activities).

The NRC has concluded that any visual intrusion resulting from decommissioning will be temporary and would serve to8-19 YNPS License Termination PlanRevision 4reduce the aesthetic impacts of the facility.

YAEC will use best management practices to controlmany of the potentially adverse impacts of decommissioning on aesthetics (such as dust andnoise), as discussed in other sections.

YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the end use of the site.8.2.15 NoiseThe environmental impacts associated with noise have been determined by the NRC to begenerically applicable with a SMALL impact. The NRC's analysis of the environmental impactsof noise is documented in Section 4.3.16 of Supplement 1 to NUREG-0586.

As stated in the "Environmental Assessment by the U.S. Nuclear Regulatory Commission, Related to the Request to Authorize Facility Decommissioning,"

dated December 14, 1994,decommissioning activities at YNPS will add minimally to the ambient noise of the surrounding environment, beyond the security fence.Decommissioning activities will, in general, be intermittent and temporary, and limited to arelatively small portion of the entire YNPS site. Noise is attenuated by the mature forestssurrounding the plant. During fall and winter, absence of foliage will allow some additional transmission of noise, and, to the areas north and west of the plant, the presence of ShermanReservoir will allow some transmission of noise over the water before attenuation by forest.However, a review of wildlife species existing in the vicinity of the plant indicates anassemblage consistent with that found within similar regional habitats.

This indicates that thenoise levels generated at YNPS during decommissioning have added only minimally to theambient noise levels and have had a negligible effect on the vicinity and the environment.

YAEC has not identified any new information or significant environmental change associated with the site-specific termination activities related to the end use of the site.8.2.16 Transportation The environmental issue of transportation has been determined by the NRC to be generically applicable with a SMALL impact. The NRC's analysis of the environmental impacts oftransportation is documented in Section 4.3.17 of Supplement I to NUREG-0586.

The number of shipments and the volume of waste shipped are greater during decommissioning than during operations.

In Supplement I to the FGEIS, the public health and safety impacts oftransportation of radioactive wastes are evaluated on the basis of compliance with regulation.

The NRC has concluded that compliance with regulation is adequate to protect the public againstunreasonable risk from the transportation of radioactive materials.

The supplement to the FGEISnotes that the evaluation leading to that conclusion was based, in part, on information inNUREG-0170 and that recent re-evaluation of transportation risks, using updated information and assessment tools, found that risks are lower than those estimated in NUREG-01

70. BecauseYNPS will comply with all applicable regulations when shipping radioactive wastes fromdecommissioning, the effects of transportation of that radioactive waste on public health andsafety are considered to be neither detectable nor destabilizing.

8-20 YNPS License Termination PlanRevision 4Non-radiological impacts of transportation include increased traffic and wear and tear onroadways.

Because the average number of shipments from the site will be relatively small, therewill be no significant effect on traffic flow or road wear. Additionally, because of the industry's emphasis on training and adherence to established procedures, truck accident rates for activities at nuclear facilities has been lower than the national average for similar activities.

The NRC hasconcluded that impacts of transportation accidents would neither be detectable nor destabilizing.

Thus, transportation of wastes associated with the YNPS decommissioning and licensetermination activities do not present significant adverse impacts.8.2.17 Irretrievable Resources The environmental issue of irretrievable resources has been determined by the NRC to begenerically applicable with a SMALL impact. The NRC's analysis of the environmental impactsof irretrievable resources is documented in Section 4.3.18 of Supplement 1 to NUREG-0586.

Supplement 1 to the FGEIS indicates that land associated with a site released for unrestricted useis available for other uses, regardless of whether or not the decommissioning process returnedthe land to an open space or to an industrial complex.

Thus the land resource would not beconsidered "irretrievable."

The Supplement to the FGEIS evaluated other irretrievable resources such as the materials/equipment used to decontaminate the facilities and the fuel usedfor construction machinery and for transporting wastes and concluded these resources are minor.Thus, the impact of decommissioning and license termination on irretrievable resources isneither detectable nor destabilizing.

8.3 References

8-1 YNPS Decommissioning Environmental Report.,

dated December 1993.8-2 NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning ofNuclear Facilities,"

dated August 1988.8-3 NUREG-1575, NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual,"

Revision 1, dated August 2000.8-4 Supplement I to NUREG-0586, "Generic Environmental Impact Statement onDecommissioning of Nuclear Facilities,"

dated November 2002.8-5 Title 10 to the Code of Federal Regulations, Subpart E to Part 20.8-6 Attachment E to the "Contract for the Performance of Demolition and Disposal andRelated Services, By and Between DEMCO, Inc. and Yankee Atomic ElectricCompany,"

dated February 28, 20038-7 Yankee Nuclear Power Station Decommissioning Plan, Revision 0.0.8-21 YNPS License Termination PlanRevision 48-8 Regulatory Guide 1.185, "Standard Format and Content for Post-shutdown Decommissioning Activities Report,"

dated July 2000.8-9 YNPS Post-Shutdown Decommissioning Activities Report, dated June 2003.8-10 USNRC Atomic Safety and Licensing Board Docket No. 50-029-DCOM, Supplemental Affidavit of Russell A. Mellor, September 3, 1996.8-11 Memorandum RP-03-045 from Greg Babineau to Jim Kay, dated November 19, 2003.8-12 "Environmental Assessment by the U.S. Nuclear Regulatory Commission, Related to theRequest to Authorize Facility Decommissioning,"

dated December 14, 1994.8-13 R. Janson (EPA) to J. A. Kay (YNPS), dated July 29, 2003, "Issuance of NPDES PermitNo. MA0004367.

8-14 Offsite Dose Calculation Manual, Revision 15.8-15 NHESP 99-5798, "Installation of an on-site storage pad, road improvements, andimprovements to present storm water system,"

dated November 30, 1999, from PatriciaHuckery, NHESP Wetlands Environmental Review to the Rowe Conservation Commission.

8-16 NYR 92-144, Exemption From IOCFR Part 50 -Appendix E -Emergency Preparedness Training Exercises at the Yankee Nuclear Power Station (TAC No. M83415),

M. B.Fairtile (USNRC) to J. M. Grant, July 24, 1992.8-17 "Massachusetts:

2000, Summary Population and Housing Characteristics,"

U.S.Department of Commerce, issued September 20028-18 "Vermont:

2000, Summary Population and Housing Characteristics,"

U.S. Department of Commerce, issued October 2002.8-19 "New York: 2000, Summary Population and Housing Characteristics,"

U.S. Department of Commerce, issued July 2002.8-20 NRC Letter, "Order Approving the Decommissioning Plan and Authorizing Decommissioning of the Yankee Nuclear Power Station,"

dated February 14, 1995.8-21 State Register of Historic Places/1988, Massachusetts Historical Commission.

8-22 BYR 2003-063 "Project Notification Form, Request for Determination of No AdverseEffect,"

from Gregg Demers and John McTigue, ERM, to Brona Simon, Massachusetts Historical Commission, dated July 11, 2003.8-23 National Register Survey Books, Bennington County and Windham County Listings, Vermont Division of Historic Preservation.

8-22 YNPS License Termination PlanRevision 48-24 Deerfield River Project, Deerfield River, Vermont and Massachusetts-Information forthe Initial Stage of Consultation FERC Project No. 2323, Volumes I and II, New EnglandPower Company, March 1988.8-25 Letter from M. D. Lombard (USNRC) to R. Mitchell (YAEC), "Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E,and Section 50.47 of Title 10 of the Code of Federal Regulations for the Yankee RowePlant (TAC No. L24662),"

dated May 7, 2013.8-26 Letter from J. M. Goshen (USNRC) to R. Mitchell (YAEC), "Revised Response toExemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50Appendix E, and Section 50.47 of Title 10 of the Code of Federal Regulations for theYankee Rowe Plant (TAC No. L24662),"

dated August 15, 2013.8-23 YNPS License Termination PlanRevision 4YNPS License Termination Plan Revision 4Table 8-1Summary of Environmental Impacts from Decommissioning Issue Generic Impact LTP SectionOnsite-Offsite Land Uses 8.2.1* Onsite Land Uses Yes Small 8.2.1.1" Offsite Land Uses No Site-Specific 8.2.1.2Water Use Yes Small 8.2.2Water Quality Yes Small 8.2.3Air Quality Yes Small 8.2.4Aquatic Ecology 8.2.5" Activities within the operational area* Yes Small 8.2.5.1" Activities outside the operational area No Site-Specific 8.2.5.2Terrestrial Ecology 8.2.6* Within the operational area Yes Small 8.2.6.1* Outside the operational area No Site-Specific 8.2.6.2Threatened and Endangered Species No Site-Specific 8.2.7Radiological 8.2.8* Activities resulting in occupational doses Yes Small 8.2.8.1to workers* Activities resulting in doses to the public Yes Small 8.2.8.2Radiological accidents Yes Small 8.2.9Occupational issues Yes Small 8.2.10Cost N/A N/At 7Socioeconomic Yes Small 8.2.11Environmental Justice No Site-Specific 8.2.12Cultural and Historic Resource Impacts 8.2.13" Activities within the operational area Yes Small 8.2.13.1" Activities outside the operational area No Site-Specific 8.2.13.2Aesthetics Yes Small 8.2.14Noise Yes Small 8.2.15Transportation Yes Small 8.2.16Irretrievable Resources Yes Small 8.2.17.The operational area is defined as the portion of the plant site where most or all of the site activities occur, such as reactor operation, materials and equipment

storage, parking, substation operation, facilityservice, and maintenance.

This includes areas within the protected area fences, the intake, discharge,

cooling, and associated structures as well as surrounding paved, graveled, maintained landscape, or othermaintained areas.I A decommissioning cost assessment is not a specific National Environmental Policy Act (NEPA)requirement.

8-24 YNPS License Termination PlanRevision 4Table 8-2Population Changes in the Vicinity of YNPSLocation 1980 1990 2000 % change % change(Ref 8-1) (Ref 8-1) (Ref 8-17 & in decade in decade8-18) before shutdown including shutdownMassachusetts Adams 10,381 9,445 8,809 -9% -7%Clarksburg 1,871 1,745 1,686 -7% -3%Florida 730 732 676 0% -8%North Adams 18,063 16,797 14,681 -7% -13%Savoy 644 634 705 -2% 11%Buckland 1,864 1,928 1,996 3% 4%Charlemont 1,149 1,249 1,358 9% 9%Colrain 1,552 1,757 1,813 13% 3%Hawley 280 317 336 13% 6%Heath 482 716 805 49% 12%Monroe 179 115 93 -36% -19%Rowe 336 387 351 15% -9%VermontHalifax 488 782 782 60% 0%Whitingham 1,043 1,298 1,29824% 0%Wilmington 1,808 1,968 2,225 9% 13%Readsboro 638 762 809 19% 6%Stamford 773 773 813 0% 5%Overall 42,281 41,405 39,236 -2% -5%8-25