ML050690289

Request for Additional Information (RAI) Regarding Final Status Survey FSS Supplement No. 5

ML050690289
Person / Time
Site:	Maine Yankee
Issue date:	03/13/2005
From:	Gillen D NRC/NMSS/DWMEP/DD
To:	Meisner M Maine Yankee Atomic Power Co
References
Download: ML050690289 (8)

Text

March 13, 2005 Mr. Michael J. Meisner, Chief Nuclear Officer Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, Maine 04578-4922

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING FINAL STATUS SURVEY (FSS) SUPPLEMENT NO. 5 On December 7, 2004, Maine Yankee Atomic Power Company (MY) submitted Final Status Survey (FSS) Supplement No. 5, for U.S. Nuclear Regulatory Commission (NRC) review and approval. FSS Supplement No. 5 includes the following 15 survey units:

FA-100 Containment Building (5 survey units)

FB-0800 Fuel Oil Storage Building FR-0110 PAB Alleyway (5 survey units)

FR-0230 X1A and X1B Transformer Pad FR-0500 Bailey Point (2 survey units)

FR-1000 Foxbird Island (1 survey unit)

The attachment provides the staffs comments requiring resolution before the U.S. Nuclear Regulatory Commission (NRC) approval of FSS Supplement No. 5. NRCs request for additional information is the result of: (1) missing or insufficient technical information; or (2) missing or insufficient basis for technical conclusions. Maine Yankee is requested to provide the information identified in the attachment. NRC staff discussed the technical issues with Maine Yankee staff on March 2, 2005. A schedule for Maine Yankees resubmittal of the survey information, and NRC subsequent review, will be established during an upcoming biweekly teleconference.

In accordance with 10 CFR 2.390 of the NRC's "Rules of General Applicability," a copy of this letter will be available electronically in the NRC Public Document Room or from the Publically

Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

Questions regarding this letter should be directed to John Buckley at 301-415-6607.

Sincerely,

/RA/

Daniel M. Gillen, Deputy Director Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-309 License No.: DPR-36

Attachment:

As stated cc: See next page

Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

Questions regarding this letter should be directed to John Buckley at 301-415-6607.

Sincerely,

/RA/

Daniel M. Gillen, Deputy Director Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-309 License No.: DPR-36

Attachment:

As stated cc: See next page DISTRIBUTION:

DWMEP r/f DCD r/f MRoberts, RI RBellamy, RI MY Distribution List ML050690289 *See previous concurrence OFFICE DCD* DCD* DCD* DCD* DCD NAME JBuckley BWatson TMixon CCraig DGillen DATE 3/09/05 3/09/05 3/10/05 3/10/05 3/13/05 OFFICIAL RECORD COPY

Maine Yankee Atomic Power Plant Service List cc:

Thomas G. Dignan, Jr., Esquire Mr. Patrick J. Dostie Ropes & Gray State of Maine Nuclear Safety One International Place Inspector Boston, MA 02110-2624 Maine Yankee Atomic Power Company 321 Old Ferry Road Ms. Paula Craighead, Esquire Wiscasset, ME 04578-4922 State Nuclear Safety Advisor State Planning Office Mr. William Henries, Director State House Station #38 Engineering Augusta, ME 04333 Maine Yankee Atomic Power Company 321 Old Ferry Road Mr. P. L. Anderson, Project Manager Wiscasset, ME 04578-4922 Yankee Atomic Electric Company 580 Main Street Mr. Paul Bemis Bolton, MA 01740-1398 Stone & Webster Engineering &

Construction First Selectman of Wiscasset c/o Maine Yankee Atomic Power Company Municipal Building P.O. Box 727 U.S. Route 1 Bailey Point Road & Old Ferry Road Wiscasset, ME 04578 Wiscasset, ME 04578 Friends of the Coast Mr. Mark Roberts P.O. Box 98 U.S. Nuclear Regulatory Commission Edgecomb, ME 04556 475 Allendale Road King of Prussia, PA 19406 Mr. Jonathan M. Block Attorney at Law David Lewis, Esquire P.O. Box 566 Shaw Pittman Putney, VT 05346-0566 2300 North Street, NW Washington, DC 20037 Joseph Fay, Esquire Maine Yankee Atomic power Company 321 Old Ferry Road Wiscasset, ME 04578-4922

Mr. Ted C. Feigenbaum President and Chief Executive Office Maine Yankee Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922 W. Clough Toppan, P.E., Director Division of Health Engineering Department of of Human Services

1. 10 State House Station Augusta, ME 04333 Mr. Michael J. Meisner Chief Nuclear Officer Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922

Maine Yankee Final Status Survey (FSS) Supplement 5 Request for Additional Information Comment FA-0100 SU 1 Containment Walls During the May 24-27, 2004 site inspection, The Oak Ridge Institute for Science and Education (ORISE), performed in-process surveys of the Containment Building walls from the -2 ft elevation up to the 17 ft elevation. Neither NRC nor ORISE were informed during the inspection about the use of the lockdown coating on the Containment Building walls. As result of the NRCs review of the release records for FA-0100 SU1 Containment Walls, the staff requested and reviewed Maine Yankee Memorandum GDP 006, Rev. 0, dated August 18, 2003, and Rev. 1 dated May 20, 2004, regarding "Detector Efficiency Reduction due to "Lockdown." While the staff has no technical issues with the memorandum, the staff is concerned about Maine Yankees failure to communicate the application of "lockdown" to the staff, and the revision to the Maine Yankee technical evaluation which occurred four days before the inspection. The staff has determined that the "lockdown applications will have an impact on the ORISE survey findings. As a result, the ORISE Report dated October 20, 2004, will be amended and re-issued using reduced instrument efficiencies.

Request for Additional Information FA-0100 SU 2 Containment Floors FSS - Release Record FA-0100 Survey Unit 2 is a Class 1 area. LTP Section 5.4.1 requires the performance of 100% Scan Survey for Class 1 areas in accordance with MARISSM. In addition, LTP Section 5.5.1 (a & d) require sampling or surveys to determine contamination at depth. During the May 24-27 site inspection, the staff observed large deep holes in the floors principally near the pedestals, where the flow-able concrete placed during original plant construction left voids. In addition, the staff noted that in some areas the metal liner was missing and the floor was bare concrete. The holes in the floor are not mentioned in the release record nor is survey information provided that specifically corresponds to these configuration anomalies. Please provide survey data to demonstrate these areas were scanned to comply with the 100% scan requirement.

In addition, the staff observed significant quantities of water on the containment floor which required a significant effort by Maine Yankee to dry prior to performing FSSs of floor surfaces.

Given the influx of water onto the containment floor and observing the water under the steel liner, the potential for migration of contamination existed. Please provide (gamma) surveys of the areas (either in conjunction with the FSS or from the Remediation Phase) that demonstrate that no significant contamination at depth was present under the metal liner.

Attachment

FA-0100 SU 4 Containment Building In Core Instrument (ICI) Sump and Access Tunnel In FA-0100 SU4, Table 2, Sample Location 15 has a negative value of -580 cpm equating to

-1395 dpm/100 cm2. This measurement appears to be excessively negative and does not appear to be a valid sample measurement within the data set presented. Please justify the quality of the sample measurement and validity of the measurement within the data set.

FA-0100 SU 5 Containment Penetrations On October 14, 2004, Maine Yankee submitted an addendum to FSS Supplement 1. In this addendum, Table 2A, information is provided on how and where various features not included in the scope of FSS Supplement 1 will be dispositioned. Table 2A indicates that a number of penetrations from the Spray Building will be surveyed with the survey units from Supplement 5.

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

• Survey of 10 inch penetration from FA-1700 SU3 in FA-0100 SU5.

• Survey of 10 inch penetration from FA-1700 SU4 in FA-0100 SU5.

• Survey of 2 inch penetration from FA-1700 SU5 in FA-0100 SU5.

• Surveys of the 5 penetrations thru the south wall (from FA1700 SU2) and the 5 penetrations thru south wall (from FA-1700 SU8). Table 2A indicates that these penetrations will be surveyed as part of alleyway east-west excavations (FR-0110 SU3).

Based on information in Supplement 5, alleyway east-west excavations are included in FR-0110, not FR-0111 (identified as soil remedation survey unit areas). Further, these 10 penetrations do not appear to be included in the east-west excavations FR-0111 SU3.

Please provide survey data for the above referenced penetrations.

FR-0110 Survey Units 1, 2, 3, 4 PAB Excavated Areas from PAB to CSB The FSS design for these four survey units is based on the assumption that the soil nuclide fractions for Cs-137 and Co-60 are 0.890 and 0.009, respectively, as provided in Section 2.5.3, Nuclide Profile, Table 2-11, of the LTP. Consistent with this profile, Table 2-2 of FSS-RR for FR-0110 Survey Units 1-4, lists the scan MDC as 5.9 pCi/g for Cs-137 (per LTP Table 5-6).

Information presented in the FSS-RRs suggests that significantly more Co-60 may be present in the soil than was anticipated. It is not clear from the FSS-RR that the FSS design adequately considered the potential for Co-60 and other contaminants in the soil. Therefore, it is not clear that appropriate measurements were performed to demonstrate compliance with requirements.

Basis:

Section B of the FSS-RR for FR-0110 Survey Units 1-4 states that the soil survey was suspended in late 2002 and resumed during the spring of 2003. At this time, it was determined that radioactivity had migrated into the remaining soil from the open, abandoned pipes in the excavation. The nuclide profile for contaminants in the abandoned pipe is not addressed in the FSS-RRs. However, FSS-RR Table 2, Direct Measurements data (see summary table below) indicates that the ratio of Co-60 to Cs-137 is approximately 1, for Survey Units 1-4. This ratio indicates that the Co-60 fractional activity for Survey Units 1-4 is higher than the 0.009 listed in LTP Table 2-11.

FR-0110 Co-60 Table 2 Cs-137 Table 2 Ratio Survey Unit Mean pCi/g Mean pCi/g Cobalt:Cesium 1 0.251 0.259 0.97 2 0.149 0.119 1.25 3 0.267 0.282 0.95 4 0.18 0.38 0.47 Average 0.21 0.26 0.81 LTP Table 2.8, Nuclide Fractions for Contaminated Concrete Surfaces Special Areas, which includes the PAB pipe tunnel, identifies fractions for Co-60 and CS-137 as 0.368 and 0.289, respectively, which results in a ratio of approximately 1. The FSS-RR data appears to be more consistent with the nuclide fractions in LTP Table 2.8 As noted in the FSS-RRs Table 1, Survey Unit Design Parameters, the survey design is based on a DCGL for Cs-137. A scan MDC of 5.9 pCi/g for Cs-137, from LTP Table 5-6, is listed in FSS-RR Table 2-2, as being utilized for FR-0110 Survey Units 1-4. The 5.9 pCi/g scan MDC exceeds the DCGLEMC for Co-60 shown in Table 2-2 as 3.3, 5.2, 5.8 and 3.3 pCi/g for Survey Units 1-4, respectively. A scan MDC for Co-60 is not provided.

In addition, the use of the scan MDC based solely on Cs-137 is non-conservative. According to NUREG 1507, Table 6.4, the scan MDC for Co-60 should be approximately twice the scan MDC for Cs-137, given that the efficiency of the SPA3 detector is less than half for the higher energy Co-60 gamma energies. In NUREG-1507, a 2 in. X 2 in. NaI detectors response for Co-60 is 430 cpm per microR/hr versus 900 cpm microR/hr for Cs-137.

Please justify the design for these survey units and the adequacy of the measurements performed.