ML071830515

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Wayne Norton Ltr Yankee Nuclear Power Station - Release of Land from Part 50 License
ML071830515
Person / Time
Site: Yankee Rowe
Issue date: 08/10/2007
From: McConnell K I
NRC/FSME/DWMEP/DURLD
To: Norton W A
Yankee Atomic Electric Co
Hickman, John NMSS/DWMEP 301-415-3017
References
Download: ML071830515 (19)
v • d • e


Text

August 10, 2007Mr. Wayne Norton, PresidentYankee Atomic Power Company 49 Yankee Road Rowe, MA 01367

SUBJECT:

YANKEE NUCLEAR POWER STATION - RELEASE OF LAND FROM PART 50LICENSE

Dear Mr. Norton:

I am responding to your letter of March 8, 2007, in which you requested the U.S. NuclearRegulatory Commission's (NRC) approval of the acceptability of the release of a portion of the Yankee Nuclear Power Station (YNPS) site from the 10 CFR Part 50 license (DPR-3). The area to be released consists of twenty-four (24) open land survey areas, eight (8) survey areas associated with partially or fully removed structures, and one (1) subsurface soil survey area.

These areas proposed for release encompass the majority of the site, leaving only the areas associated with the Independent Spent Fuel Storage Installation, Survey Areas/Units OOL 02, NOL-07 and NSY-10, within the Part 50 License. Your letter indicated that you have reviewed and assessed the subject survey areas in accordance with Section 1.5 of the YNPS License Termination Plan (LTP) and the NRC Safety Evaluation of the LTP dated July 28, 2005, to ensure that this proposed action will have no adverse impact on the ability of the site in aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release.The NRC staff has reviewed your proposed partial site release from the license, as specified inyour March 8, 2007, letter, and finds the proposed release to be acceptable subject to the following comments:Following removal from the license, in the unlikely event the released areas were tobecome radiologically contaminated as a result of later decommissioning activities at the Yankee Nuclear Power Station Independent Spent Fuel Storage Installation, the contamination would be considered an off-site release, and subject to 10 CFR Part 20.Yankee is required to maintain $100 million in nuclear liability insurance coverage, asdescribed in Indemnity Agreement B-17, "until all the radioactive material has been removed from the location and transportation of the radioactive material from the location has ended as defined in subparagraph 5(b), Article 1, or until the Commission authorizes the termination or modification of such financial protection." Approval of this partial site release request has no impact on the terms of the indemnity agreement. In particular, it should be noted that the site location described in Item 4 of Amendment No.

3 to the indemnity agreement means the "original" 10 CFR Part 50 license site boundaries. The liability insurance coverage level shall not be reduced below the minimum $100 million amount without prior NRC approval. A copy of the staff's safety evaluation is enclosed.

W. Norton-2-The staff has reviewed the residual radioactivity values in the Final Status Survey reports andcompared them to the trigger values in the 2002 Memorandum of Understanding (MOU) between the NRC and U.S. Environmental Protection Agency (EPA) entitled, "Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites." Based on this review, the residual radioactivity in soil and groundwater at the site do not exceed the trigger values in the MOU and, as such, consultation with EPA in accordance with the MOU is not required.In accordance with 10 CFR Part 2.390 of NRC's "Rules of Practice," a copy of letter will beavailable electronically for public inspection in NRC Public Document Room, or from the Publically Available Records component of NRC's Agencywide Document Access Management System (ADAMS). ADAMS is accessible from NRC Web site: http://www.nrc.gov/reading-rm/adams.html.If you have any questions concerning this evaluation, please contact John Hickman at(301) 415-3017, or by e-mail at jbh@nrc.gov.Sincerely,/RA/Keith I. McConnell, Deputy DirectorDecommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management ProgramsDocket No.: 50-029License No.: DPR-3

Enclosure:

Safety Evaluation cc: Yankee Service List W. Norton-2-The staff has reviewed the residual radioactivity values in the Final Status Survey reports andcompared them to the trigger values in the 2002 Memorandum of Understanding (MOU) between the NRC and U.S. Environmental Protection Agency (EPA) entitled, "Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites." Based on this review, the residual radioactivity in soil and groundwater at the site do not exceed the trigger values in the MOU and, as such, consultation with EPA in accordance with the MOU is not required.In accordance with 10 CFR Part 2.390 of NRC's "Rules of Practice," a copy of letter will beavailable electronically for public inspection in NRC Public Document Room, or from the Publically Available Records component of NRC's Agencywide Document Access Management System (ADAMS). ADAMS is accessible from NRC Web site: http://www.nrc.gov/reading-rm/adams.html.If you have any questions concerning this evaluation, please contact John Hickman at(301) 415-3017, or by e-mail at jbh@nrc.gov.Sincerely,/RA/Keith I. McConnell, Deputy DirectorDecommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management ProgramsDocket No.: 50-029License No.: DPR-3

Enclosure:

Safety Evaluation cc: Yankee Service List DISTRIBUTION

DURLD r/f ML071830515OFFICERDB:PMDURLD:LADURLD:HPRDB:BCOGCDURLD:DDNAMEJHickmanTMixonTYoungbloodBWatsonJHullKMcConnellDATE7/3/20077/03/20077/5/20077/15/20077/18/20078/10/2007OFFICIAL RECORD COPY Yankee (Rowe) Nuclear Power Station Service List cc:

Mr. Wayne A. Norton, President & CEOYankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367Mr. Joe Bourassa, Director of Site Closure and Project Support 49 Yankee Road Rowe, MA 01367Joseph Fay, Esquire, General CounselYankee Atomic Electric Company 14 Lily Pond Road Camden, ME 04843Mr. Robert Mitchell,ISFSI Manager Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367Mr. Robert Capstick, Government AffairsYankee Atomic Energy Company 77 Lakewood Road Newton, MA 02461Mr. Gerard van Noordennen,Regulatory Affairs Manager Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367Alice Carson, Licensing EngineerYankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367Alice Carson, RSCS, Inc.12312 Milestone Manor Lane Germantown, MD 20876Robert Walker, DirectorRadiation Control Program Massachusetts Department of Public Health 305 South Street Boston, MA 02130Mr. Michael WhalenMA DPH RCP Schrafft Center 1M2A Charlestown, MA 02129Mr. Dave HowlandMassachusetts Department of Environmental Protection Western Regional Office 436 Dwight Street Springfield, MA 01103Mr. James B. MuckerheideMassachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399Peggy Sloan, AICPFranklin Regional Council of Governments 425 Main Street, Suite 20 Greenfield, MA 01301-3313David O'Brien, CommissionerVermont Department of Public Service 120 State Street, Drawer 20 Montpelier, VT 05602Diane Screnci, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Mr. Ernie Waterman, Acting ChiefChemicals Management Branch Office of Ecosystem Protection U.S. Environmental Protection Agency One Congress Street, Suite 1100 Mail Code CPT Boston, MA 02114 Mr. Anthony HonnellioU.S. Environmental Protection Agency Region 1 One Congress Street, Suite 1100, Boston, MA 02114-2023Mr. Jeff FowleyOffice of Regional Counsel U.S. Environmental Protection Agency One Congress Street, Suite 1100 Mail Code RAA Boston, MA 02114Ms. Bonnie GitlinRadiation Protection Division Office of Radiation and Indoor Air Office of Air and Radiation U.S. Environmental Protection Agency Ariel Rios Building Mail Code 66081 1200 Pennsylvania Ave, NW Washington, DC 20460Mr. Phillip NewkirkRadiation Protection Division Office of Radiation and Indoor Air Office of Air and Radiation U.S. Environmental Protection Agency Ariel Rios Office Building Mail Code 66081 1200 Pennsylvania Ave, NW Washington, DC 20460 Citizens Awareness NetworkP.O. Box 83 Shelborne Falls, MA 01370Jonathan M. BlockAttorney at Law Main Street P.O. Box 566 Putney, VT 05346-0566 1 ADAMS Accession No. ML070740494 2 ADAMS Accession No. ML043240450 3 SER related to Amendment 158 to License DPR-3, dated July 28, 2005, ADAMS Accession No. ML051310453SAFETY EVALUATION BY OFFICE OF FEDERAL AND STATE MATERIALSAND ENVIRONMENTAL MANAGEMENT PROGRAMS RELATED TO THE RELEASE OF LAND FROM FACILITY OPERATING LICENSE NO. DPR-3YANKEE ATOMIC ELECTRIC COMPANYYANKEE NUCLEAR POWER STATIONDOCKET NO. 50-02

91.0INTRODUCTION

Yankee Nuclear Power Station (YNPS) was permanently shutdown on October 1, 1991. The DECON decommissioning plan was approved in February 1995 and the plant has completed dismantlement under 10 CFR 50.59. The licensee completed construction of an on-site Independent Spent Fuel Storage Installation (ISFSI) under a general license. The ISFSI became fully operational with the transfer of the last canister containing Greater Than Class C (GTCC) material in June 2003. The ISFSI contains fifteen canisters of spent fuel and one canister of GTCC material.By letter dated March 8, 2007 1, Yankee Atomic Electric Company (YAEC, the licensee)requested U.S. Nuclear Regulatory Commission (NRC) approval of the acceptability of the release of a portion of the YNPS site from the 10 CFR Part 50 license (DPR-3). The area consists of twenty-four (24) open land survey areas, eight (8) survey areas associated with partially or fully removed structures, and one (1) subsurface soil survey area. These areas encompass the majority of the site, leaving only the areas associated with the ISFSI, Survey Areas/Units OOL-10-02, NOL-07 and NSY-10, within the Part 50 License. YAEC indicated that they have reviewed and assessed the subject survey areas in accordance with Section 1.5 of the YNPS License Termination Plan (LTP) 2 and the NRC Safety Evaluation (SE) 3 of the LTPdated July 28, 2005, to ensure that this proposed action will have no adverse impact on the ability of the site in aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release.2.0EVALUATION2.1Applicable RequirementsChapter 1 of the LTP describes the process for phased site releases prior to licensetermination. Section 1.5 of the LTP requires YAEC to complete the following:1.Following completion of decommissioning activities, YAEC will compile a reportwith the following information for NRC review: *a description and location of the survey unit or area being surveyed;*certification that dismantlement/decommissioning activities, as describedin the LTP, have been completed for the subject building or area;*an evaluation of the potential for possible recontamination of the area anda description of controls in place to prevent such recontamination;*Final Status Survey (FSS) results for the survey unit or area, asdemonstration of compliance with the LTP release criteria (not applicable to areas designated as "nonimpacted");*Expected date of removal of the area from the 10 CFR 50 license.2.YAEC will review and assess the impacts on the following programs anddocuments in preparation 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;
  • Security Plan;
  • License Termination Plan;
  • Ground Water Monitoring Program;
  • 10CFR100 Siting Criteria; and
  • Decommissioning Environmental Report.The reviews will include an assessment to ensure that the land area(s), and anyassociated building(s), to be released will have no adverse impact on the site's ability to meet the Part 20, Subpart E, criteria for unrestricted release. The reviews will also include the impacts on the discharge of effluents and the limits of 10CFR 20, as they pertain to the public.3.A letter of intent to remove a portion of the property from the Part 50 license willbe sent to the NRC, no later than sixty (60) days before the anticipated date for release of the subject 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 report for the subject survey units(s) or area(s).4.Once the land area(s), and any associated building(s), have been verified readyfor release, no additional surveys or decontamination of the subject building or area will be required (beyond those outlined in Section 5.4.5 intended for isolation and controls) unless administrative controls to prevent recontamination are known or suspected to have been compromised. Following completion of the Final Status Survey and submittal of the associated report, the NRC will review the report and conduct, as appropriate, the applicable NRC confirmatory inspections.5.Upon completion of the YNPS Decommissioning Project, a final report will beprepared, to summarize the release of areas of the YNPS site from the

10 CFR 50 license. 4 ADAMS Accession Number ML070470130 5 ADAMS Accession Number ML070160490 6 ADAMS Accession Number ML070160537 7 ADAMS Accession Number ML070470110 8 ADAMS Accession Number ML063340250Accordingly, because the approved LTP includes the phased site release process set forthabove, the 10 CFR § 50.83 partial site release requirements are not applicable here.2.2Area to be Released and FSS ResultsThe area the licensee intends to release consists of twenty-four (24) open land survey areas,eight (8) survey areas associated with partially or fully removed structures, and one (1) subsurface soil survey area. This area encompasses the majority of the site, leaving only the areas associated with the ISFSI, Survey Areas/Units OOL- 10-02, NOL-07 and NSY-10, within the Part 50 License. The specific survey areas to be released are described below:AUX-01: AUX-01 consisted of the remaining Primary Auxiliary Building (PAB) walls that liewithin the spent fuel pool excavation footprint. The PAB was located in the former Radiological Controlled Area (RCA) and designed to contain the radiological constituents resulting from operation of the primary (radioactive) systems of the YNPS. The FSS Report for this area was submitted on May 11, 2006 4.AUX-02: AUX-02 consists of that portion of the PAB that was not designed to contain portionsof the primary (radioactive) operating systems of the plant. AUX-02 is located within the former RCA. The FSS Report for this area was submitted on September 7, 2006 5.BRT-01: Survey Area BRT-01 consists of the reinforced concrete structures that comprise thefoundations and support pedestals of the sixteen Vapor Container (VC) supports and the eight Reactor Support Structures (RSS) that remained after demolition of the VC and RSS. The FSS Report for this area was submitted on August 28, 2006 6.NOL-01: NOL-01 consists of open land areas and includes the site of the former Spent FuelPool, Ion Exchange Pit, Vapor Container Elevator Foundation, the North and South Decontamination Pads and Fuel Transfer Enclosure. Decommissioning of the area resulted in the complete excavation of the land area and the encompassed structures. NOL-01 is located within the former RCA. The FSS Report for this area was submitted on March 30, 2006 7.NOL-02: The NOL-02 Survey Area is an open land area comprised of the previous site of theNew Fuel Vault, surrounding areas east of the former Spent Fuel Pool and the Northeast UpperRCA Yard. Sub-surface systems that traversed or connected within the Survey Area include electrical, storm drain, fuel oil and auxiliary service water, fire protection, and radioactive liquid drain and transfer lines. The FSS Report for this area was submitted on November 20, 2006

8. 9 ADAMS Accession Number ML063120097 10 ADAMS Accession Number ML070160541 11 ADAMS Accession Number ML062970047 12 ADAMS Accession Number ML063070487 13 ADAMS Accession Number ML070470124 14 ADAMS Accession Number ML070160273NOL-03: Survey Area NOL-03 was originally a survey unit consisting of a portion of the OldPCA Storage Building. During the FSS of sub-area NOL-03-01, however, it was discovered that the unit would not pass FSS and a management decision directed the complete removal of the structure. As a result the final NOL-03 consisted of an open land area within the southeast section of the RCA yard. The FSS Report for this area was submitted on November 3, 2006 9.NOL-04: NOL-04 is a open land area in the southeast portion of the former RCA. The FSSReport for this area was submitted on August 31, 2006 10.NOL-05: Survey Area NOL-05 consists of the exposed land area remaining from the demolitionof the concrete pad associated with the RCA Warehouse, Waste Disposal Building, and Radioactive Waste Compactor Building and the remaining remnants from demolition of the PCA-1 bathtub foundation. The footprint includes miscellaneous excavations which expose underlying soil and/or concrete remnants, and the exposed soil grade. The FSS Report for this area was submitted on October 5, 2006 11.NOL-06: Survey Area NOL-06 is a open land area within the former RCA on the west andsouthwest sides of where the reactor and VC were present. Portions of the reactor support structure ring and mat foundations were present in, but not part of, this survey unit. The FSS Report for this area was submitted on October 31, 2006 12.NSY-12: Survey Area NSY-12 consists of a single Survey Unit, NSY-12-01, which comprisesthe base for Tank-1 and a subsurface pipe chase that connected the Tank-1 base to the Auxiliary Boiler Room in the Turbine Building. NSY-12 is part of the original plant structure.

The FSS Report for this area was submitted on May 11, 2006 13.OMB-06: Survey Area OMB-06 consists of the remains of the concrete structure located at thedischarge end of the circulating water system known as the Seal Pit. The Seal Pit wasextensively characterized with a combination of sediment samples, concrete core samples, gamma scans, beta scans and beta fixed measurements. The FSS Report for this area was submitted on August 9, 2006 14.OOL-01: OOL-01 is described as Sherman Pond Sediment. OOL-01 Survey Areaencompasses the Sherman Reservoir, the Seal Pit Cove, the East Storm Drain System Discharge, and Circulating Water System Discharge and up to and including part of the 15 ADAMS Accession Number ML070160457 16 ADAMS Accession Number ML070820489 17 ADAMS Accession Number ML063480355 18 ADAMS Accession Number ML070160100 19 ADAMS Accession Number ML063350106 20 ADAMS Accession Number ML070030540 21 ADAMS Accession Number ML063480355shoreline of the reservoir. The entire Survey Area OOL-01 is situated underwater. The FSSReport for this area was submitted on January 4, 2007 15, and revised on March 7, 2007 16.OOL-02: The OOL-02 Survey Area is in the original non-RCA portion of the YNPS site insidethe security fence, which is owned by YAEC. OOL-02 includes the area of the site known as the Non-Rad Yard Area, the Turbine Building footprint and the Service Building footprint and the area surrounding the security access building. The FSS Report for this area was submitted on December 4, 2006 17.OOL-03: Survey Area OOL-03 is comprised of the area of the site known as the ShermanReservoir Dam & South Shoreline including the surface area of the Sherman Dam and the south shoreline of Sherman Reservoir, which is property owned by TransCanada. OOL-03 consists of soil, asphalt and vegetation. The FSS Report for this area was submitted on January 5, 2007 18.OOL-04: Survey Area OOL-04 consists of open land surface area surrounding Sherman Station(a hydroelectric plant). The land is owned by TransCanada. It is primarily open land area with some brush, some grass and a small amount of asphalt. It surrounds the hydroelectric power station on three sides, and includes a substation and breakers for the power coming from the hydro station. It also includes open land area stretching east to west along the north end of the site. The FSS Report for this area was submitted on November 21, 2006 19.OOL-05: The OOL-05 Survey Area is the area of the site known as the USGen, (now TransCanada) Deerfield River Frontage. OOL-05 consists of the TransCanada owned land area located between the YAEC property and the Deerfield River. The FSS Report for this area was submitted on December 14, 2006 20.OOL-06: OOL-06 consists of the land area west of the site and is comprised of soil and asphalt.The land is level to steeply sloping and ranges from heavily wooded to open land. The FSS Report for this area was submitted on December 4, 2006 21.OOL-07: Survey Area OOL-07 included a pile of soil that was released from the YNPS industrialarea during the construction of the ISFSI pad and placed in the mid-level parking lot. OOL-07 also included the personnel parking area which was used to stockpile soil, from excavations in 22 ADAMS Accession Number ML062970013 23 ADAMS Accession Number ML070030522 24 ADAMS Accession Number ML062930080 25 ADAMS Accession Number ML063210484 26 ADAMS Accession Number ML063120133 27 ADAMS Accession Number ML062990103the industrial area, awaiting thermal desorption. The FSS Report for this area was submittedon October 6, 2006 22.OOL-08: The OOL-08 Survey Area is open land areas along the western, south-western, andsouthern perimeter of the former industrial area. The FSS Report for this area was submitted on December 19, 2006 23.OOL-09: The OOL-09 Survey Area is in the area of the site known as the SoutheastConstruction Fill Area (SCFA). The SCFA was not part of the plant RCA and there were no sub-surface systems that traversed or connected within the survey unit. Survey Unit OOL-09 includes partially wooded and open land area. The FSS Report for this area was submitted on October 23, 2006 24.OOL-10: The OOL-10 Survey Area includes the perimeter of the ISFSI up to the "security"fence. This survey area is composed of sod, grasses, and asphalt, in an open land area located within the western portion of the RCA buffer zone, and an open land area that was on the west and south side (outside) of the former RCA. A portion of OOL-10, Survey Unit OOL-10-02 is not included in this release request and will remain within the Part 50 license to act asbuffer for and to facilitate eventual ISFSI decommissioning activities. The FSS Report for this area was submitted on November 13, 2006 25.OOL-11: The OOL-11 Survey Area in unused open land area on the east side of the formerRCA. This survey area includes a narrow strip of land located between the Northeastern Upper RCA Yard and the southwest face of the adjacent hill side and a narrow strip of open land located between Southeastern Upper RCA Yard and the southwest face of the adjacent hill side. The FSS Report for this area was submitted on November 3, 2006 26.OOL-12: OOL-12 is an open land area, in the northeast portion of the Yankee Rowe site. Thearea included a rail spur which was used for transport of radioactive waste, including spent fuel and irradiated reactor internals hardware. The area was also a main path for personnel and material traffic into and out of the RCA. Systems that traversed or connected within the survey unit include the Auxiliary Service Water System, the Fire Protection System and electrical conduits. During decommissioning, OOL-12 was the site of the Truck Monitor system. The FSS Report for this area was submitted on October 19, 2006 27.OOL-13: OOL-13-01 is a section of the Sherman Reservoir bank near the rail spur terminus. Itis located adjacent to and down slope of the former location of the RCA and is currently owned 28 ADAMS Accession Numbers ML070160540 and ML062780397 29 ADAMS Accession Number ML063060048 30 ADAMS Accession Number ML070160270 31 ADAMS Accession Number ML070160522 32 ADAMS Accession Number ML063480590 33 ADAMS Accession Number ML063340143by TransCanada (formerly owned by US Gen). The FSS Report for this area was submitted onSeptember 26, 2006 28.OOL-14: Survey Area OOL-14 (Wheeler Brook Frontage) consists of an open land area whichis owned by TransCanada, at the northeast perimeter of the industrial area. There are no sub-surface systems that traverse or connect within OOL-14, and the area was considered to be minimally impacted by site activities given that it was at a distance from the RCA, and was not accessible by vehicular traffic. The majority of OOL-14 is heavily wooded. The FSS Report for this area was submitted on October 23, 2006 29.OOL-15: Survey Area OOL-15 consists of open land northeast of the plant site. The property isowned by TransCanada and extends north from the TransCanada/YAEC property line to the Sherman Reservoir shore. There are no sub-surface systems or plant structures within area OOL-15. The area was not accessible by vehicle traffic, nor was it used for storing radioactive material or for processing/packaging radioactive waste. The FSS Report for this area was submitted on August 9, 2006 30.OOL-16: Survey Unit OOL-16, known as the Furlon House Lot, is the site of the former visitorscenter. OOL-16-01 is entirely bounded by non-impacted YAEC-owned property. OOL-16-01 was never part of the RCA, did not contain any radioactive systems and no decommissioning activities were performed in this area. The FSS Report for this area was submitted on September 18, 2006 31.OOL-17: OOL-17 is an open land area comprised of stone fill and soil. The land area is locatedin the non-RCA portion of the site and is entirely bounded by non-impacted YAEC owned property. Survey area OOL-17 contains soil that was excavated during construction activities at the YNPS site and was used as a personnel parking area. The FSS Report for this area was submitted on December 1, 2006 32.OOL-18: Survey Area OOL-18 consists of an open land area, comprised of packed soil. Thereare no sub-surface systems that traverse or connect within OOL-18. This land area is located in the non-RCA portion of the site and has been used for temporary storage of roll-off containers. The FSS Report for this area was submitted on November 13, 2006

33. 34 ADAMS Accession Number ML063480590 35 ADAMS Accession Number ML070160544 36 ADAMS Accession Number ML070400322 37 ADAMS Accession Number ML070470121 38 ADAMS Accession Number ML070220076 39 ADAMS Accession Number ML070380132 40 ADAMS Accession Number ML070590301 41 ADAMS Accession Number ML070650191 42 ADAMS Accession Number ML070940670SSS-01: The SSS-01 Survey Area is comprised of statistical samples in subsurface soil in theindustrial area footprint surveyed to a depth of 3 meters (or until refusal). The FSS Report for this area was submitted on December 1, 2006 34.SVC-01: SVC-01 is comprised of the Service Building foundation that was exposed duringexcavation campaigns to remove radiologically contaminated soil and PCB contaminated soil from the "alley way". The FSS Report for this area was submitted on September 21, 2006 35.TBN-01: TBN-01 consists of the remaining concrete floors and exposed foundations of theformer Turbine Building and the Circulating Water discharge piping. All above grade structures have been demolished and removed, as well as portions of the floors and foundations of the Turbine Building. TBN-01 is located outside of the former RCA. The FSS Report for this area was submitted on February 20, 2006 36.WST-01: Survey Area WST-01 is comprised of the reinforced concrete foundation of the 'OldPotentially Contaminated Area Storage Building' as well as the remaining concrete partial walls exposed during the excavation of Survey Unit NOL-05. WST-01 was used, during plant operation, as a decontamination facility and as a storage area for heavily contaminated items.

WST-01 is located within the former RCA. The FSS Report for this area was submitted on April 17, 2006 37.The NRC has previously reviewed the FSS reports, and the licensee's responses to NRCcomments on the FSS reports, for the areas to be released and determined that the FSS reports are acceptable. The NRC review of the FSS reports is documented in letters dated January 25, 2007 38, February 20, 2007 39, March 2, 2007 40, March 16, 2007 41, and April 5, 2007 42.Multiple other survey areas were identified in the LTP for which no FSS reports were submitted. These include survey areas NYS-01 thru NYS-09, NYS-11, NYS-13, OMB-01, OMB-03 thru OMB-05, SFP-01, SFP-02, SVC-02, and SVC-03. These survey areas were for structural foundations which the licensee chose to remove from the site rather than leave in place.

Survey areas WST-002 thru WST-04, were included in WST-01. Survey areas NOL-07, NSY- 10, and OOL-10-02 will be addressed when the ISFSI is decommissioned and will remain aspart of the license area until then.2.3Remaining Dismantlement / Decommissioning ActivitiesWith the exception of decommissioning activities at the ISFSI to be undertaken when all fuelhas been removed, all decommissioning and dismantlement activities have been completed at this site. Thus, no dismantlement activities are required in the survey areas to be released.

The ISFSI and immediately surrounding areas are to be retained under the Part 50 license.2.4Controls to Prevent RecontaminationThe only remaining source of potential recontamination of the area to be released is the ISFSI. The YNPS spent fuel at the ISFSI is stored in the NAC-MPC System. The NAC-MPC System is a sealed and leak-tight spent fuel storage system. YAEC completed in-process inspections and tests during fabrication and sealing of the canisters. Consequently, there is no release of radioactive material during normal conditions of storage. The structural analysis of the canister for off-normal and accident conditions of storage, which is presented in Chapter 10 of the NAC-MPC Final Safety Analysis Report (FSAR), shows that the canister is not breached in any of the evaluated events. Consequently, there is no release of radioactive material during off-normal and accident conditions of storage that could impact the areas proposed for release.2.5Impact of Proposed Partial Site Release on Programs and Documents2.5.1FSARThe proposed release will require minor changes to Section 300, "Environmental SiteCharacteristics" and to Figure 300-1, "Site Boundary and Plant Exclusion Area" of the Decommissioning FSAR. The changes need to (1) describe the reduced site area resulting from the removal of the subject survey area from the Part 50 License; and (2) identify the new site boundary on Figure 300-1. The licensee has stated that this revision will be performed.2.5.2Technical SpecificationsThe YNPS Defueled Technical Specifications are not impacted by the release of the subjectsurvey areas, as a size and description of the site are not included in the Technical Specifications. The survey and release processes are consistent with the LTP and associated License Condition. The ISFSI Technical Specifications, associated with allowable surfacecontamination on the cask after loading, were based upon limiting the dose at 100 m due to a total mechanistic release of the surface contamination. The partial site release will not affect the basis for this Technical Specification, as the assumed 100 m dose point is within the 300 m owner controlled boundary that will continue to be maintained for the ISFSI after partial site release has been implemented.2.5.3Radiological Environmental Monitoring ProgramGaseous, liquid, and solid radwaste systems associated with the operation of YNPS have beenremoved and disposed. Site decommissioning activities have been concluded for the site (except those required in the future for the ISFSI), and discharges of radioactive material 43 ADAMS Accession Number ML071510133(gaseous or liquid) are no longer made. Accordingly, the Environmental Monitoring Programhas been revised to address monitoring associated only with the ISFSI which is to be retained under the Part 50 license. Therefore, the Environmental Monitoring Program will not be affected by the release of the proposed areas.2.5.4Offsite Dose Calculation Manual (ODCM)Gaseous, liquid, and solid radwaste systems associated with the operation of YNPS have beenremoved and disposed. Site decommissioning activities have been concluded for the site (except those required in the future for the ISFSI), and discharges of radioactive material (gaseous or liquid) are no longer made. Recently, the National Pollutant Discharge Elimination System (NPDES) permit for the site was terminated. Accordingly, the ODCM was revised to address the ISFSI only. Monitoring in accordance with the ODCM continues and will not be impacted by the proposed partial site release. Therefore, the ODCM will not be affected by release of the proposed areas.2.5.5Defueled Emergency PlanAs the former nuclear plant has been dismantled and decommissioned, the Emergency Plan forthe site has been reduced to address the ISFSI only. The ISFSI Emergency Plan describes the location of the ISFSI, the Radiologically Controlled and Protected Areas, and the 300 m Owner Controlled Area. None of these locations/areas will be affected by the proposed partial site release. Although portions of the owner controlled area are included in the area proposed for partial site release, YAEC will continue to maintain control of this area. Therefore, the emergency Plan will not be affected by release of the proposed areas.2.5.6Security PlanThe security plan addresses the materials stored at the ISFSI and will not be affected by therelease of the proposed areas.2.5.7License Termination PlanThe licensee has committed to make a revision to the LTP to revise the area of the site stillunder the Part 50 license. Otherwise the proposed release does not impact the LTP.2.5.8GroundwaterThe Groundwater Monitoring Program is intended to integrate all aspects of groundwatercharacterization, monitoring and remediation required to support unrestricted release of the YNPS site. The LTP includes a commitment that prior to license termination, YAEC must demonstrate that the maximum tritium concentration in a resident farmer's well (consistent with dose modeling assumptions) is less than the U.S. Environmental Protection Agency's (EPA's) maximum contaminant limit (MCL) (20,000 pCi/L for tritium). As documented in Final Groundwater Condition Report dated February 15, 2007 43, YAEC has calculated the maximum 44 ADAMS Accession Number ML071640142 45 ADAMS Accession Number ML071280543 46 ADAMS Accession Number ML070080200concentration in the resident farmer's well as of April 2007 to be 8150 pCi/L, well below the20,000 pCi/L limit.In the course of the staff's review, questions were raised regarding the quantity of water drawnfrom the worst case well. By e-mail dated March 27, 2007 44, the licensee provided acomparison analysis for the tritium concentration without water drawn for irrigation. The analysis indicated negligible difference in concentration. The staff has reviewed the analysis and has no further concerns.The staff reviewed YAEC's confirmation of groundwater compliance dated April 24, 2007 45, forthe 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 46.This demonstration included the following items:A summary of the five quarters of radiological sampling data for 53 monitoring wells andSherman 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 near monitoring wellMW-107C is less than the EPA's MCL (20,000 pCi/L).In addition, YAEC committed in its Groundwater Compliance Plan to provide a statistical trendanalysis of tritium at each monitoring site for the five quarters. All the monitoring sites except monitoring well MW-110C had a stable or downward trend for tritium during this time period.

The tritium in well MW-110C has increased slightly over this time period from 1,160 to 2,040 pCi/L, which is approximately 10 percent of the tritium MCL. The staff did not consider this upward trend significant.The NRC has reviewed the licensee's groundwater sampling documents and analysis andagrees that the acceptance level, as documented in the LTP, has been met and therefore, groundwater compliance with the release criteria has been achieved.2.5.910 CFR 100 Siting Criteria10 CFR Part 100 addresses design and environmental aspects to be considered in siting apower reactor. 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 be addressed. 47 ADAMS Accession Number ML040360630 48 ADAMS Accession Number ML051360081 49 ADAMS Accession Number ML051330130 50 ADAMS Accession Number ML051330139 51 ADAMS Accession Number ML051390312 52 ADAMS Accession Number ML061530379 53 ADAMS Accession Number ML061530383 54 ADAMS Accession Number ML061530393 55 ADAMS Accession Number ML061530402 56 ADAMS Accession Number ML061530412 57 ADAMS Accession Number ML061530421 58 ADAMS Accession Number ML071230672 59 ADAMS Accession Number ML0712306432.5.10Decommissioning Environmental ReportThe licensee evaluated the environmental impacts as documented in the YankeeDecommissioning Environmental Report and Supplement 1 to NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" during preparation of the LTP. The information contained within the LTP was determined to be consistent or bounded by the information in the Yankee Decommissioning Environmental Report and Supplement 1 to NUREG-0586. The partial site release process was included in the LTP, and this partial site release is being proposed consistent with the process in the LTP. Therefore, the Yankee Decommissioning Environmental Report and conclusions in Section 8 of the LTP concerning Supplement 1 to NUREG-0586 are not impacted by the proposed partial site release.2.6NRC Inspections and Confirmatory SurveysNRC survey contractors from the Oak Ridge Institute for Science and Education (ORISE)performed multiple in-process and confirmatory surveys of the radiological conditions at YNPS during decommissioning. ORISE also performed confirmatory analysis of samples from YNPS.

Samples were tested by gamma spectroscopy for Co-60, Cs-137, and other (Hard-to-Detect) gamma-emitting radionuclides associated with the YNPS. Reports of ORISE surveys and sample analyses were provided on December 24, 2003 47, February 16, 2005 48, February 23, 2005 49, March 30, 2005 50, April 30, 2005 51, October 12, 2005 52, October 12, 2005 53, December2, 2005 54, December 9, 2005 55, January 25, 2006 56, March 13, 2006 57, August 17, 2006 58, andJanuary 10, 2007

59. 60 ADAMS Accession Number ML040430204 61 ADAMS Accession Number ML042640103 62 ADAMS Accession Number ML051400350 63 ADAMS Accession Number ML052910375 64 ADAMS Accession Number ML061660446 65 ADAMS Accession Number ML071860234 66 ADAMS Accession Number ML070220076NRC inspections of Yankee decommissioning activities are documented in inspection reportsdated February 12, 2004 60, September 20, 2004 61, May 20, 2005 62, October 18, 2005 63, June13, 2006 64, and July 2, 2007 65.The inspectors reviewed the licensee's survey results, the licensee's survey methodology, andthe licensee's plans for demonstrating that the survey results would demonstrate that structures and areas met acceptable radiological levels for release. The inspectors and NRC staff also reviewed confirmatory and in-process radiation and contamination surveys conducted by ORISE. Confirmatory surveys provide confidence that the licensee's survey results are representative of the conditions for that survey unit. In-process surveys provide confidence that the licensee's survey results are accurate. Based on the data review, discussions and observations, the inspector observed that the licensee had in place methods for demonstrating compliance with the release criteria. The inspector found that the licensee had in place a methodology in which the survey results were used to assess the radiological condition of the structures in order to determine whether further remediation was required, or the structures were suitable for demolition.An issue that was identified during ORISE surveys was related to identified areas of elevatedactivity at some locations which were due to discrete small particles of radioactive material.

The licensee began a review of their survey procedures relative to the identification of the "hot particles" and the dose significance of the particles. This issue involved the use of in situ gamma spectroscopy by the licensee that was reviewed and evaluated by the NRC Office of Nuclear Material Safety and Safeguards and determined to be acceptable by letter dated January 25, 2007

66. In addition to the independent in-process surveys, the inspectors also splitseveral samples with the licensee to assess the licensee's capability to characterize various areas and structures of the site prior to remediation and FSSs. The samples were analyzed by the NRC's contract laboratory, ORISE. The results indicated that the licensee correctly characterized systems and structures prior to remediation and FSSs.In summary, NRC Inspections and ORISE Confirmatory Surveys, corroborated that theradiological conditions of the open land areas survey units that are proposed to be released, met the approved site-specific DCGLs, and that YNPS's laboratory data were consistent and in agreement with the ORISE's analytical results.2.6.1.Groundwater Monitoring 67 ADAMS Accession Number ML071450240The NRC staff collected split groundwater samples from monitoring wells on December 11 - 13,2006, at the YNPS near Rowe, Massachusetts. ORISE, the NRC's independent laboratory, performed the following analytical analyses on these samples: gross alpha, gross beta, tritium, strontium-90, carbon-14, and gamma spectrometry (Co-58, Co-60, Cs-134, and Cs-137)

(ORISE, 2007. Report For Analyses of Ten Water Samples From Yankee Rowe in Rowe, Massachusetts dated February 14, 2007 67). A comparison of the analytical results for the splitgroundwater samples (i.e., the NRC and YAEC groundwater samples for the above wells) indicates a close correspondence. The NRC staff has concluded that the licensee's laboratory analyses and field sampling procedures are adequate. Therefore, the NRC staff has concluded that YAEC's radiological analytical program was adequately measuring the occurrence of site-generated radionuclides in the groundwater.3.0ConclusionsNRC's review of the licensee LTP determined that the proposed DCGLs would ensure that the10 CFR 20, Subpart E, release criteria would be met. NRC review of the FSS reports determined that the reports were consistent with and demonstrated compliance with the LTP and the FSS results demonstrate that the survey areas to be released meet the radiological criteria for unrestricted release. Review of the licensee's submittal requesting the release adequately addressed the criteria as provided in the LTP. NRC inspections and confirmatory measurements substantiated that the licensee's decommissioning and FSS programs adequately assessed the radiological conditions at the site. Therefore, the NRC approves releasing the subject survey areas from the license, as specified in YAEC's March 8, 2007,request.Principal Contributor: John B. Hickman Date: August 10, 2007

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