ML070950498

(PA-LR)Correspondence 04/02/07

ML070950498
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/02/2007
From:	Lynn D Entergy Corp
To:	Emch R Office of Nuclear Reactor Regulation
References
TAC MD2297
Download: ML070950498 (58)

Text

Richad Em'ch' :c'orr~e'sp~o-ndnc thtorquested Pg From: "DeWald, Lynn" <ldewald@entergy.com>

To: "Richard Emch" <RLE@nrc.gov>

Date: 04/02/2007 1:36:42 PM

Subject:

correspondence that you requested Rich, attached are two of the three documents that I think will help you answer the questions you had during our call last week. The third document is too large to include in this transmittal, so it will follow shortly. Take a look and if you need additional information please let me know. Thanks, Lynn Lynn DeWald Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, VT 05354 802-258-5526 (phone)802-258-5865 (fax)802-380-4493 (cell) c:\temp\GW}OOO01 .TMP Mail Envelope Properties (46113FIB.797:7

14231)

Subject:

Creation Date From: Created By: correspondence that you requested 04/02/2007 1:35:41 PM"DeWald, Lynn" <ldewald(aentergy.com>

ldewald(oentergy.com Recipients nrc.gov OWGWPO02.HQGWDO01 RLE (Richard Emch)Post Office OWGWPOO2.HQGWDOO1 Route nrc.gov Files Size MESSAGE 470 TEXT.htm 3907 July 2005 NRC correspondence to VY.pdf VY to NRC correspondence.pdf Mime.822 4129616 Date & Time 04/02/2007 1:35:41 PM 421881 2590317 Options Expiration Date: Priority: ReplyRequested:

Return Notification:

Concealed

Subject:

Security: None Standard No None No Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 h July 19, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plainsi NY 10601

SUBJECT:

SAFETY EVALUATION OF REQUEST TO AMEND PREVIOUS APPROVALS GRANTED PURSUANT TO 10 CFR 20.2002 -VERMONT YANKEE NUCLEAR POWER STATION (TAC NO. MC5104)

Dear Mr. Kansler:

By letter dated October 4, 2004, as supplemented on January 17, 2005, Entergy Nuclear Operations, Inc. (Entergy) submitted a request to the Nuclear Regulatory Commission (NRC) to modify previous approvals granted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 20.2002 (previously 10 CFR 20.302(a)), for on-site disposal of slightly contaminated material at Vermont Yankee Nuclear Power Station. Specifically, Entergy requested an increase of the current approved annual volume limit of 28.3 cubic meters of soil/sand to a new annual volume limit of 150 cubic meters of soiVsand.

In. addition, Entergy has requested a one-time approval for on-site disposal of the current backlog inventory of approximately 528 cubic meters of soil/sand.

The NRC staff has completed it review of the request and has determined that the proposed changes are acceptable as documented in the enclosed Safety Evaluation.

Pursuant to the provisions of 10 CFR Part 51, the NRC has published an Environmental Assessment and Finding of No Significant Impact In the Federal Register on July 19, 2005 (70 FR 41440).Sincerely, Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosure:

As stated cc w/encl: See next page Vermont Yankee Nuclear Power Station Co: Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.Washington, DC 20037-1128 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael H. Dworkin, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shelburne Falls, MA 01370 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Mr. James M. DeVincentis Manager, Ucensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide

.400 Worcester Rd.Framingham, MA 01702-5399 Jonathan M. Block, Esq.Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Vermont Yankee Nuclear Power Station cc: Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Brian O'Grady Vice President, Operations Support Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations,, Inc.440 Hamilton Avenue White Plains, NY 10601*Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc.Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL -60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.639 Loyola Avenue New Orleans, LA 70113 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ENTERGY NUCLEAR OPERATIONS, INC.VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO, 50-271

1.0 INTRODUCTION

By letter dated October 4, 2004, as supplemented on January 17, 2005, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a request to the Nuclear Regulatory Commission (NRC) to modify previous approvals granted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 20.2002 (previously 10 CFR 20.302(a)), for on-site disposal of slightly contaminated material at Vermont Yankee Nuclear Power Station (VYNPS).Specifically, Entergy requested an increase of the current approved annual volume limit of 28.3 cubic meters of soiVsand to a new annual volume limit of 150 cubic meters of soil/sand.

In addition, Entergy has requested a one-time approval for on-site disposal of the current backlog inventory of approximately 528 cubic meters of soil/sand.

2.0 REGULATORY EVALUATION

As described in 10 CFR 20.2002, "Method for obtaining approval of proposed disposal procedures," licensees are required to obtain NRC approval of proposed procedures, not otherwise authorized in the regulations, to dispose of licensed material generated in the licensee's activities.

Previous NRC approval for VYNPS on-site disposal of various slightly contaminated waste materials is documented in letters dated August 30,1989, March 4, 1996, June 18, 1997, June 15, 2000, and June 26, 2001. Based on these previous approvals, the licensee is currently authorized to dispose, In designated on-site areas, the following materials:

(1) septic waste; (2) cooling tower silt; (3) soil/sand generated from the annual winter spreading on roads and walkways; and (4) soil resulting from on-site construction-related actMtles.

Disposal of septic waste and cooling tower silt material is not limited by an annual volume, but by a total dose impact related to the radiological content of the material and the concentration of radioactivity contained within it. The combination of the soilisand generated from the annual winter spreading on roads and walkways and the soil resulting from on-site construction-related activities is currently subject to an annual volume limit of 28.3 cubic meters. The licensee's application dated October 4, 2004, proposed to increase this annual volume limit for the same materials (i.e., soil/sand) to 150 cubic meters. In addition, the application proposed a one-time disposal of the current backlog Inventory of approximately 528 cubic meters of soil/sand.

The current restrictions on the annual volume of slightly contaminated soil/sand that can be disposed on-site coupled with several plant facility projects in recent years, has resulted in the accumulation of a backlog of low-level contaminated earthen material that is awaiting disposal by land spreading on previously-approved on-site disposal areas. The current approved annual volume limit of 28.3 cubic meters of soil/sand for disposal was based on licensee estimates of soil and sand collected from road and walkway sweepings inside the Protected Area following each year's winter cleanup (i.e., current annual limit does not account for future site excavation and construction activities).

3.0 TECHNICAL EVALUATION The licensee proposes to dispose of the current backlog inventory of soiVsand and the future soil/sand material using a land spreading technique consistent with the current commitments for on-site disposal of slightly contaminated material previously approved by the NRC. The licensee will continue to use designated areas of its property approved for this waste material.Determination of the radiological dose impact of the new material has been made based on the same dose assessment models and pathway assumptions used in the previously-approved applications.

The licensee will procedurally control and maintain records of all disposals.

The following information will be recorded: 1. the radionuclide concentrations detected in the material;2. the total volume of material disposed;3. the total radioactivity in the disposal operation as well as the total radioactivity accumulated on each disposal plot at the time of spreading;

4. the plot of land on which the material was applied; and 5. dose calculations or maximum allowable accumulated activity determinations required to demonstrate that the dose values have not been exceeded.The licensee's application stdtes that the existing NRC-approved bounding dose conditions for the proposed on-site disposals will continue to be applied without change. The bounding dose conditions for the on-site disposals are as follows: 1. the annual dose to the whole body or any organ of a hypothetical maximally exposed individual will be less than 1.0 millirem (mrem) (during the period the licensee has active control over the disposal sites, i.e., during the current operating license period);2. annual doses to the whole body and any organ of an inadvertent intruder from the probable pathways of exposure will be less than 5 mrem (following the period the licensee has active control over the disposal sites); and 3. disposal operations will be at an approved on-site location.To ensure that the addition of new waste material will not exceed the bounding dose conditions for each new spreading operation, the licensee's total radioactivity and dose calculation will include all past disposals of septic waste, cooling tower silt, soil and soil/sand material on the designated disposal plots. In addition, concentration limits will be applied to the disposed material to restrict the placement of small volumes of material that may have relatively high radioactivity concentrations.

VYNPS is currently authorized to dispose of licensed material, pursuant to 10 CFR 20.2002, in two designated locations both within the site boundary security fence. The South field (approximately 1.9 acres in size) is centered approximately 1500 feet south of the reactor building.

The North field (approximately 10 acres in size) is centered approximately 2000 feet northwest of the reactor building.

The South field has been the only field utilized for disposal of licensed material to date. The licensee's application states that It Is anticipated that future disposal operations will also use the South field since sufficient margin in comparison to the approved dose limit criteria still exists for anticipated waste disposal of the existing backlog of material now in storage, plus all expected future disposals of material, assuming the same observed generation rates.The licensee performed an evaluation of the radiological impact of all past, accumulated storage inventory, and projected future waste spreading operations on the South field. The licensee assessed the dose that may be received by the maximally exposed individual during the period of plant control over the property, and to an inadvertent intruder after plant access control ends using the same pathway modeling, assumptions, and dose calculation methods that were previously approved by the NRC for the waste material.

The dose models are based on the guidance In Regulatory Guide 1.109, Revision 1.Table 26 in the attachment to the licensee's October 4, 2004, application provides the calculated maximum organ and whole-body doses, at the end of the current plant license period, based on the combination of all past disposal of waste materials, disposal of the current backlog inventory of waste material and projected annual disposal of waste materials.

The-results are summarized as follows: Individual Individual Intruder Intruder Organ Dose Whole Body Dose Organ Dose Whole Body Dose (mrem/year) (mrem/year) (mrem/year) (mrem/year)

Total Dose 0.253 0.074 1.05 0.468 Dose Limit 1 1 5 5% of Dose Limit 25.3% 7.4% 21.1% 9.4%Based on the above calculated dose rates, the NRC staff concludes that the proposed increase of the current approved annual volume limit of 28.3 cubic meters of soil/sand to a new annual volume limit of 150 cubic meters of solVsand and a one-time approval for on-site disposal of the current backlog inventory of approximately 528 cubic meters of soil/sand would result in dose rates within the bounding dose conditions for on-site disposal previously approved by the NRC.

4.0 CONCLUSION

The NRC staff finds the licensee's request for disposal of a new annual volume limit of 150 cubic meters of soiVsand and a one-time approval for on-site disposal of the current backlog inventory of approximately 528 cubic meters of soil/sand, pursuant to 10 CFR 20.2002, In the same manner, location, and within the bounding dose conditions as previously approved by the NRC, to be acceptable.

Principal Contributors:

S. Klementowicz R. Ennis Date: July 19, 2005 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.Vermont Yankee 185 Old Ferry Rd.P.O. Box 500 Brattleboro, Vt 05302 Tel 802-257-5271 October 4, 2004 Docket No. 50-271 BVY 04-110 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

References:

a) Letter, VYNPC to USNRC, "Request to Amend Previous Approval Granted Pursuant to 10 CFR 20.2002 for Disposal of Contaminated Soil", BVY 00-71, dated September 11, 2000.b) Letter, USNRC to VYNPC, "Vermont Yankee Nuclear Power Station -Safety Evaluation for an Amendment to an Approved 1 OCFR 20.2002 Application (TAC No. MA9972)", NVY 01-66, Dated June 26, 2001.c) Letter, VYNPC to USNRC, "Supplement to Request to Amend Previous Approvals Granted under 10 CFR 20.302(a) to Allow for Disposal of Contaminated Soil", BVY 00-02, dated January 4, 2000.

Subject:

Vermont Yankee Nuclear Power Station Request to Amend Previous Approval Granted Pursuant to 10CFR20.2002 for Increase of the Annual Volume Limit and One-time Spreading of Current Inventory In accordance with 10CFR20.2002 (previously 10CFR20.302(a)), Entergy Nuclear Operations, Inc. (ENO) submits this application to amend the previously granted Vermont Yankee (VY) approval to dispose of slightly contaminated soil. This application requests an increase of the current annual volume limit of 28.3 cubic meters of soil as specified in the previous approval (Reference (b)) to a new volume limit of 150 cubic meters of soil. This application also requests permission to spread the current inventory of approximately 528 cubic meters of soil as described in Attachment A in a one-time spreading activity following receipt of your approval.ENO will continue to limit the total activity spread each year to remain within the limits specified in the radiological assessment previously submitted in Reference (c).A radiological assessment of the impact of spreading the current inventory of soils and sediments located at VY is provided in Attachment A. The assessment concludes that: a) There is significant capacity remaining in the South Disposal Plot to continue to accept additional earthen materials for land spreading without exceeding established dose limitations.

BVY 04-110 / Page 2 b) The existing inventory of waste soils in storage can be placed on the South Disposal Plot without exceeding dose impact limits previously established for a single disposal field.c) The continued use of the South Disposal Plot will not exceed the limiting dose criteria established in the VY Offsite Dose Calculation Manual.d) The approved dose impact methodology used to determine compliance With the on-site spreading dose limits are not driven by the volume of waste material disposed of, but by the total radioactivity content of the material that is spread over a fixed disposal plot area (1.9 acres for the South Disposal Plot). The dose modeling conservatively assumes that all radioactivity spread on the field remains in the top 15 centimeter surface layer, even after subsequent additions are placed on the same field area. Existing limits on the concentration of radioactivity in waste media provides protection from small volumes of "hot or high specific activity materials from being spread on the disposal field.The results of all disposal operations will continue to be reported in the Annual Radioactive Effluent Release Report. The combined radiological impact, for all on-site disposal operations, will continue to be limited to a total body or organ dose of a maximally exposed member of the public of less than one mrem/year during the period of active VY control of the site, or less than five mrem/year to an inadvertent intruder after termination of active site control.Upon receipt of your approval, this request as well as the basis for approval will be incorporated into the VY Offsite Dose Calculation Manual.There are no new commitments being made in this submittal.

We trust that the information contained in the submittal is sufficient.

However, should you have any questions or require further information concerning this matter, please contact me at (802) 258-4236.Sincerely, Jae .DeVincentis Manager, Licensing Vermont Yankee Nuclear Power Station Attachment (1)cc: USNRC Regional Administrator-Region 1 USNRC Resident Inspector

-VYNPS USNRC Project Manager-VYNPS Vermont Department of Public Service Attachment to BVY 04-110 Docket No. 50-271 Assessment of On-Site Disposal of Contaminated Stored Soils by Land Spreading Entergy Nuclear Operations, Inc.Vermont Yankee Nuclear Power Station TABLE OF CONTENTS Page No.Table of Contents 2 List of Tables 3 1.0 Evaluation Objective 4 1.1 Background 4 2.0 Summary of Results 6 3.0 Method of Evaluation 7 3.1 Waste Characterization 7 3.2 Soil Disposal and Administrative Procedure Requirements 8 3.3 Disposal Plot Characteristics 9 3.4 Radiological Impact Methodology 9 4.0 Assumptions and Inputs 12 5.0 Evaluations 14 5.1 Case Study I (Past Spreading Impacts) 14 5.2 Case Study II (Stored Soil/Sand Inventory Impacts) 14 5.3 Case Study III (Projected Future Spreading Impacts) 15 6.0 Results / Conclusions 17 7.0 References 34 Appendix A: Security Fence Upgrade Soil Pile #2002-01 A-1 Appendix B: Security Fence Upgrade Soil Pile #2002-02 B-I Appendix C: Security Fence Upgrade Soil Pile #2002-03 C-I Appendix D: 2001 protected Area Road Sweeping Pile D-I Appendix E: 2001 HWC Soil Excavations E-I Appendix F: 1996 Soil Remnants Analysis -Security Fence Upgrade F-I Appendix G: Record of Most Recent Spreadings (2003) on South Disposal Field 0-1 2 List of Tables Table # Title Page 1 Inventory of Contaminated Soil Piles In Storage (December 2003) 8 2 Site Specific Control Period Dose Conversion Factors 12 3 Site Specific Intruder Dose Conversion Factors 13 4 Record of Septic/CT Silt/Construction Soil Radioactive Material Spreading Each Year on the South Disposal Field 19 5 Record of Septic Waste Only for Radioactive Material Spreading Each Year on the South Disposal Field 20 6 Record of Cooling Tower Silt Only for Radioactive Material Spreading Each Year on the South Disposal Field 21 7 Record of Construction Soil/Sand Waste Only for Radioactive Material Spreading Each Year on the South Disposal Field 21 8 Cs-i 37 in Storage Piles after Last Spreading in 2003 22 9 Co-60 in Storage Piles after Last Spreading in 2003 23 10 Zn-65 in Storage Piles after Last Spreading in 2003 24 11 Mn-54 in Storage Piles after Last Spreading in 2003 25 12 Soil/Sand Storage: Total Activity to be Spread on 6/1/04 and Decayed to 2013 26...13 Projection of Additional Septic/Silt/Soil-Sand at Current Generation Rates to 2013 26 14 Projection of Additional Sand/Soil Mix 27 15 Projection of additional Cooling Tower Silt 27 16 Projection of Additional Septic Waste 27 17 Projected 1 Yr Septage & Silt Spreading for 6/1/04 and decayed to 2013 28 18 Current Total Spreading as of 11/4/03 & How Much Remains at 6/1/04 and 2013 28 19 Current Spreading Totals Plus Total Projected Future Spreadings to 2013 29 20 Radioactivity Content from Existing Materials 29 21 Past Spreading Control Period Dose Only (No Stored Material or Future Additions) 30 22 Past Spreading Only (No Stored Materials or Future Additions)

Intruder Dose 30 at End of Plant Operations in 2013 23 Control Period Dose: Past Spreadings

& Current Stored Soil Material Inventory 31 24 Past Spreading

& Current Stored Soil Inventory Intruder Dose at End Plant Ops 31 25 Dose Impact from Spreading of Current Inventory of Stored Material Only 32 26 Past, Stored Material and Projected Future Disposal (all septage/silt/soils)

Doses at End of Plant License 33 3 1.0 EVALUATION OBJECTIVE Current restrictions on the annual volume of slightly contaminated soil (1000 & or 28.3 M3 ) that can be disposed of on-site (ODCM, Appendix I, Reference 1), coupled with several plant facility construction projects in recent years, has resulted in the accumulation of a back-log of low level contaminated earthen material that is awaiting to be dispositioned by land spreading on previously approved on-site disposal areas.The objective of this assessment is to present the data and formal evaluation to demonstrate that the proposed one time disposal of the existing accumulated backlog of soil / sand materials (as of November 2003) without regards to the annual soil volume limit, will meet the existing dose objective boundary conditions as approved by the NRC for septic waste, Cooling Tower silt and other earthen type materials (Reference 1), even if use of the same disposal field for future spreading is assumed to continue over the remaining plant operating license.The established dose based boundary conditions (NRC approved) for disposal and accumulation of low-level contaminated septic waste, Cooling Tower silts and soil/sand mixes on designated plots within the VY site boundary will continue to be applied without change. These dose limit criteria are taken from Appendix B of Reference 1, and are:* The dose to the whole body or any organ of a hypothetical maximally exposed individual must be less than 1.0 mrem/yr during the period that VY has active control over the disposal plots (plant operating life).9 The doses to the whole body and any organ of an inadvertent intruder following the period of active plant control over the property from the probable pathways of exposure is less than 5 mrern/yr.* Disposal operations must be at one of the approved on-site locations.

1.1 Background

In 1989, Vermont Yankee Nuclear Power Corporation requested from the NRC permission to routinely dispose of slightly contaminated septic waste in designated on-site areas in accordance with IOCFR20.302(a).

Approval from the NRC was granted on August 30, 1989, provided that the request and analysis be permanently incorporated into the plant's Offsite Dose Calculation Manual (ODCM). Revision 9 to the ODCM (Appendix B) incorporated the assessment and the approval of methods utilized for on-site disposal of slightly contaminated sewage sludge by land spreading.

The approval allowed for the existing septic inventory to be disposed of on-site along with future quantities anticipated to be generated as part of routine system maintenance.

For purposes of demonstrating that future addition of waste materials could be added to the disposal plots, the radiological analysis projected an annual generation rate of about 18,600 gallons of sewage containing about 1400 kg of solid materials that might require on-site spreading.

NRC permission for these future disposals was granted as long as both the projected dose (for both current and all past disposal operations) and radionuclide concentration limits (5 10% of the I OCFR20, Appendix B, Table II, concentration values) are satisfied.

No specific limit on annual volume of septic waste that could be disposed of was included in the approval.In 1995, Vermont Yankee requested from the NRC that the previous authorization for on-site disposal of septic waste be amended to permit the on-site disposal of slightly contaminated Cooling 4 Tower silt material.

The application analyzed the expected radiological impact from both the existing inventory at that time of about 14,000 ft 3 (-396 in 3) of accumulated silt, along with an operating cycle (18 months) generation rate of about 4000 ft 3 (_I 13 in 3). The NRC returned their safety evaluation, dated March 4, 1996, granting approval for the proposed silt disposal.

Similar to the sewage waste disposal, NRC acceptance required that all disposal operations be conducted such that both the projected dose (for both current and all past disposal operations) and radionuclide concentration limits are satisfied.

The soil concentration limits (for any sample) were based on limiting external annual dose to 25 mrem assuming continuous occupancy on an infinite plot at that concentration uniformly spread to a 15 cm depth. No specific limit on annual volume of Cooling Tower silt that could be disposed of was included in the approval.

The NRC also required that any further modification to the proposed action have prior NRC staff approval.In 1999 (with a supplemental filing in 2000), Vermont Yankee filed a third request under 10 CFR 20.2002 with the NRC to amend the previously approved applications for on-site land disposal of slightly contaminated earth ty~e materials (septic sludge andl Cooling Tower silt) to include approximately 900 Wt (25.5 m ) of accumulated contaminated soil generated during construction activities within the VY Protected Area. Sampling of the soil revealed low levels of radioactivity that were similar in radionuclides and activity levels to the septic waste and Cooling Tower silts previously encountered.

The request to the NRC for this additional material also indicated that additional amounts of contaminated soil / sand associated with road sweepings following winter sanding of road and walkways in the Protected Area could result in an estimated 1000 ft 3 per year (28.3 Mn 3 e year) that might need to be disposed of as slightly contaminated materials.

The NRC requested that the initial submittal (1999) of the soil spreading 20.2002 application include an analysis that evaluated projected future additions of an estimated annual volume of soil being added to the designated disposal plots. This information was required if Vermont Yankee intended to use the 20.2002 soil disposal application for approval to dispose of potential future volumes (i.e., not just a one-time disposal application) of low level contaminated soil in the same manner as already approved for septic waste and Cooling Tower silt. Vermont Yankee revised its application by adding an analysis for a projected annual volume of 1000 ft, or equivalently 28.3 Mn 3 , Of contaminated soil starting in the year 2000 and continuing on a yearly basis until end of plant license in 2013. At the end of the projected disposal stream, the accumulated buildup of contamination from all sources (septic waste, Cooling Tower silt and soil / sand mixes) on the disposal field was evaluated for both the dose impact to the critical receptor at the end of the control period and the assumed intruder.

These dose impacts were found acceptable when compared against the original on-site spreading dose acceptance criteria of 1 mremi/yr (Control Period) and 5 mremlyr (Intruder Scenario).

The 1000 WO (28.3 Mn 3) annual generation rate of soil was based on plant staff estimates that approximately that amount of soil and sand is collected from road and walkway sweepings inside the Protected Area following each year's winter clean-up as part of routine maintenance.

This is the only type of earthen materials that has a specific annual volume limit associated with it in addition to the projected dose and concentration limits associated with the disposal of septic waste and Cooling Tower silt. No volume estimate for unidentified future site excavation and construction' activities was provided.5 2.0

SUMMARY

OF RESULTS The evaluation of the radiological impact of all past, accumulated storage inventory, and projected future waste spreading operations on a single disposal plot (1.9 acres at South end of site) have indicated the following results and conclosions: " All past spreading of septic waste, Cooling Tower silt, and soil/sand mixes through the end of 2003 have resulted in a maximum organ dose to a critical receptor (control Period use)that accounts for only 13.7% of the I mrem/year limit. With respect to the Intruder dose limit of 5 torem/year, all past spreadings through the end of 2003 account for only 7.2% of* the maximum organ dose to the limiting receptor at the end of plant license.* The impact from the projected spreading of the existing waste materials in storage is estimated to account for only 5.3% of the I mrem/ywar Control Period dose limit, or only 17.7% of the same limit when all past spreadings are combined with the materials currently in storage (as of the end of November 2003). The maximum Intruder organ dose from all past spreading and stored materials is 0.456 mrern/yr, or 9.1% of the 5 mren/yr Intruder scenario dose limit. These results indicate that the existing inventory of waste materials in storage can be placed on the South disposal plot without exceeding dose impact limits previously established for a single disposal field.* Assuming the same annual average generation rate of radioactivity in waste materials (septage/silt/soil) that has been observed over the last fourteen years is added to all past waste spreadings and stored soil commitments, the projected dose at the end of the current plant licensing period (year 2013) yields a limiting maximum critical receptor dose (for either the control period or inadvertent intruder) equivalent to only 25.3% of the most restrictive annual dose limit (associated with the I mrem/year limit for the maximum organ during the Control Period). This finding demonstrates that the continued use of the South disposal plot, even with the addition of 18,653 ft 3 of slightly contaminated soil currently in storage, will not exceed the approved limiting dose criteria established in the ODCM." The dose impact methodology used to determine compliance with the on-site spreading dose limits are not driven by the volume of waste material disposed of, but by the total radioactivity content of the material.

Existing limits on the concentration of radioactivity in waste media provides protection from small volumes of "hot" or high specific activity materials from being spread on the disposal field.6 3.0 METHOD OF EVALUATION The method of evaluating the impacts from the on-site spreading is the same as used and approved in the original exemption request made to *the NRC under I OCFR2O.302 for septic waste and which has been applied in all subsequent amendment requests for additional types of earthen materials to be disposed by land spreading on-site. The pathway and dose models found in Regulatory Guide 1.109 (Reference

2) are employed in performing the -radiological dose impact assessment.

The application of the dose models begins with the characterization of the waste materials that are to be subject to the dose evaluation.

3.1 Waste Characterization The existing accumulated soil / sand that has created a backlog of accumulated material over the last several years is identified on Table 1, along with the estimated volume and origination of material.The soil materials were primarily derived from excavation acotivities associated with the construction of new security fences along the plant's Protected Area boundary and the construction of new plant installations associated with the capability to perform hydrogen water chemistry treatment of the plant's coolant system. Also included are road treatment sands used for winter traction inside the protected area.The soil / sand mix is typical of fill material containing light to dark brown poorly sorted soils with.some small stones, and may include small incidental pieces of asphalt. The soil was removed from its original location by shovel, backhoe and front-end loader, and placed into dump trucks for transport to the temporary storage area located between the Cooling Towers where it was deposited on the ground surface and covered to prevent erosion. This location was se 'lected because it was away from areas routinely occupied by plant staff, and could easily be controlled.

The most probable source of the low levels of radioactive contamination is due to the presence of below detectable removable contamination redistributed by foot traffic from inside the plant to walkways and parking areas. Subsequent surface runoff carries the contamination to nearby exposed soil near the Protected Area boundary where it accumulates over time to low-level detectable concentrations.

Down wash and deposition of particulate activity released from the plant's Primary Vent Stack as part of routine gaseous emissions may also have contributed to the low levels of detectable activity.For potential future disposal volumes of sand and soil, the current volume limit (1000 ft 3 [28.3 m ODCM Appendix H, Reference

1) was based on the expected rate of road sand used for winter road and walkway traction, but did not anticipate or reflect the potential for future site construction activities that could excavate soils on-site that also contain low levels of plant related radioactivity.

The present inventory of stored soil / sand between the Cooling Towers includes approximately 18,653 ft (528 in') of material of which only 3.3% or 616 ft 3 (17.4 Mn) originated as roadway sweepings.

In accordance with Appendixes B and F of the ODCM, disposal of septic waste and Cooling Tower silt material is not limited by an annual volume limit but by total dose impact related to the radioactivity content of the silt and the concentration of radioactivity contained within it, Currently, only soils / sand mixtures have an annual on-site disposal limit equal to 1000 ft 3 (28.3 m 3).7 Table I Inventory of Contaminated Soil Piles In Storage (December 2003)Overall Overall Max Pile description Length width Height Estimated Volume ft ft inches fiA3 (1) 2002-01. Security'Fence Upgrade 75 21 44 4,679 (2) 2002-02: Security Fence Upgrade 75 28 60 9,000 (3) 2002-03: Security Fence Upgrade 39 22 42 2,457 (4) Sand Sweepings (inside protected area) 16 11 42 616 (5) 2001 HWC Soils Excavation 38 11 42 931 (6) 1996 Soil Remnants from Fence Upgrade 24 6.4 84 970 total Vol. (WA3) 18,653 3.2 Soil Disposal and Administrative Procedure Requirements The method of soil/sand disposal of the existing backlog inventory will use the technique of land spreading in a manner consistent with the current commitments for the on-site disposal of septic waste and Cooling Tower silts as approved by the NRC and implemented in Appendices B and F of the Vermont Yankee ODCM (Referencel).

The accumulation of radioactivity on the disposal plot for this proposed soil spreading operation will be treated as if Cooling Tower silt or septic waste was being disposed of since the characteristics of all these residual solids are similar (earthen-type matter). The South field (approximately 1.9 acres in size) has been used for all past disposal operations and is expected to be used for the placement of the existing backlog (see Table I above)of approximately 18,653 ft 3 (528 m 3) of soil and all annual projected future disposals of septic waste, Cooling Tower silt, and low-level contaminated soil volumes through the end of the plant's current operating license (year 2013). Determination of the radiological dose impact has been made based on the same models and pathway assumptions as indicated in Appendix B of the Vermont Yankee ODCM and approved as part of the original disposal analysis application for septic waste.Both the existing accumulated and future potential soil material will be dispersed using typical agricultural dry bulk surface spreading practices in approved disposal areas on site. Incidental pieces of asphalt and large stones that are picked up with the soil will be screened out before the soil/sand is spread.Records of the disposal that will be maintained include the following (as prescribed in Reference 1, Appendix B): (a) the radionuclide concentrations detected in the soil/sand (measured to environmental lower limits of detection)(b) the total volume of material disposed of (c) the total radioactivity in the disposal operation as well as the total accumulated on each disposal plot at the time of spreading (d) the plot on which the soil was applied, and 8 (e) dose calculations or maximum allowable accumulated activity determinations required to demonstrate that the dose lim its imposed on the land spreading operations have not been exceeded.To ensure that the addition of the soil containing the radioactivity will not exceed the boundary conditions, the total radioactivity and dose calculation will include all past disposal operations of septic waste, Cooling Tower silt and soil/sand decay-corrected to the date of the latest spreading placed on the designated disposal plots. In addition, concentration limits applied to the disposal of earthen type materials (dry soil) restrict the placement of small volumes of materials that have relatively high radioactivity concentrations.

Any farmer leasing land used for the disposal of soil will be notified of the applicable restrictions placed on the site due to the spreading of low level contaminated material.

These restrictions are the same as detailed for septic waste spreading as given in Reference 1.The disposal operation of the soil piles will follow the applicable Vermont Yankee procedures to maintain doses as low as reasonably achievable and within the specific dose criteria as previously approved for septic and Cooling Tower silt waste disposal.3.3 Disposal Plot Characteristics All designated disposal sites (six different plots) are located on the Entergy Nuclear Northeast Vermont Yankee plant site and are within the site boundary security fence. The South field consists of approximately 1.9 acres and is centered approximately 1500 feet South of the Reactor Building.This field has been the only one of the NRC approved fields that has actually been utilized for this purpose to-date. It is anticipated that future disposal operations will also utilize the South field since sufficient margin in comparison to the approved dose limit criteria still exists for anticipated waste disposal of the existing backlog of soil now in storage, plus all expected future disposals of septic waste, Cooling Tower silt and soil!/ sand mixes assuming the same observed generation rates (see Tables 13 through 19) persist to the end of the plant license in 2013.In addition to the South field, the north end of the- site has an additional ten acre parcel centered approximately 2,000 feet northwest of the Reactor Building.

Prior assessments have demonstrated that a single plot of about 2 acres is sufficient to meet routine or expected disposal needs. Therefore the northern site could be subdivided into 5 plots if additional capacity was needed.3.4 Radioloajeal Impact Methodology The amount of radioactivity added to any of the disposal fields is procedurally controlled to insure that doses are maintained within the prior approved limits of the boundary conditions (see Section 1.0 above).To assess the dose received (after the spreading of the existing 18,65 3 W1 [528 in 3] along with both past recorded disposal applications, plus projected future applications) by the maximally exposed individual during the period of plant control, and to an inadvertent intruder after plant control of access ends (reference year of 2013), the same pathway modeling, assumptions and dose calculation methods as approved for septic waste, Cooling Tower silt and past soil / sand disposals are used.9 These dose models implement the methods and dose conversion factors as provided in Regulatory Guide 1.109 (Reference 2).The following six potential pathways were identified and included in the analysis: (a) Standing on contaminated ground, (b) Inhalation of resuspended radioactivity, (c) Ingestion of leafy vegetables, (d) Ingestion of stored vegetables, (e) Ingestion of meat, and (f) Ingestion of cow's milk Both the maximum individual and inadvertent intruder are assumed to be exposed to these pathways, with the difference between them being the occupancy time. The basic assumptions used in the radiological analyses include: (a) Direct exposure to ground contamination and inhalation of resuspended radioactivity from the ground by movement of air is for a period of 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> per year during the Vermont Yankee active control of the disposal sites and continuous thereafter.

The 104-hour interval is representative of a farmer's time spent on a plot of land (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per week for 6 months). The resuspension factor for soil material on the ground back into the air is taken as 1.0E-05 based on an assumption that the disposal field will display characteristics similar to semiarid grassland experimental results. [NUREG-75/014; WASH- 1400,"Reactor Safety Study", Appendix VI, Table VI E-3; USNRC, October 1975](b) For the purpose of projecting and illustrating the magnitude of dose impacts over the remaining life of the plant, it is assumed that future disposals of septic, silt and soil material will be placed annually on the same field at the annual average radioactivity levels observed for these waste streams over the past fourteen years. The future disposals will also consist of the annual average radioactivity content observed in the accumulated soil/sand materials collected over the last several years that involved site facility construction projects that has lead to the existing backlog. The maximum individual dose impact from the buildup of disposed material occurs at the same time (2013) for both the Control Period and Intruder scenarios.(c) For the analysis of the radiological impact during the Vermont Yankee active control of the disposal sites until 2013, no plowing is assumed to take place and all dispersed radioactive material remains on the surface forming a source of unshielded direct radiation.(d) The crop exposure time was changed from 2160 hours0.025 days <br />0.6 hours <br />0.00357 weeks <br />8.2188e-4 months <br /> to 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to reflect the condition that no radioactive material is dispersed directly on crops for human or animal consumption.

Crop contamination is only through root uptake.(e) The deposition on crops of resuspended radioactivity is insignificant.

10 (f) Most of the pathway data and usage factors used in the analysis are the same as those used in the Vermont Yankee's ODCM assessment of off-site radiological impacts from routine releases.

The fraction of stored vegetables grown on the contaminated land was conservatively increased from 0.76 to 1.0 (at present no vegetable crops for human consumption are grown on any of the approved disposal plots). Also, the soil exposure time to account for buildup was changed from the standard 15 years (given in Reference

2) to 1 year.(g) It is conservatively assumed that Vermont Yankee relinquishes control of the disposal sites after the current operating license expires in 2013 (i.e., the source term accumulated on a single disposal plot applies also for the inadvertent intruder at that time).(h) For the analysis of the impact after Vermont Yankee control of the site is relinquished, the radioactive material is plowed under and. forms a uniform mix with the top six inches of the soil, but, nonetheless, undergoes resuspension in the air at the same rate as the unplowed surface contamination.

However, for direct ground plane exposure the self-shielding due to the six-inch plow layer reduces the surface dose rate, by about a factor of four.As shown in Reference I (Appendix B) for the original analysis in septic waste, the liquid tansmport and exposure pathway was found to be an insignificant contributor to the dose. Restrictions on the placement of the disposal plots put them at significant distances from wet lands, potable well supplies, and surface waters (Connecticut River). Therefore, the liquid pathway is not considered in this analysis.The dose models and methods used to generate deposition values and accumulated activity over the operating life of the plant are documented in Reference I (Appendixes B and F). Table 18 presents the radioactivity that currently exists on the South field after the last spreading event, which occurred on November 4, 2003. Table 18 also indicates the residual radioactivity that would remain on South field at the end of the plant operating period (2013) if no additional disposals we're to take place.I1I 4.0 ASSUMPTIONS AND INPUTS 1) The volume of the accumulated soil / sand currently in storage between the Cooling Towers (as of December, 2003) was estimated from field measurements of-length, width, height and general shape of each pile taken in 2003. The estimated volume of each pile is summarized on Table 1.2) The radioactivity content of each pile was determined by averaging the numerious grab samples (typically 30 samples per pile) collected for characterization of the soil material collected.

Appendixes A through F provide the individual results of positive analysis for plant related radionuclides.

Laboratory analyses were performed either by Vermont Yankee or the AREVA-Framatome (formerly the Yankee Atomic / Duke Engineering)

Environmental laboratory with samples counted with respect to the NRC environmental LLD requirements as indicated in the VY ODCM.3) Appendix G provides the total accumulated radioactivity on the South disposal Plot (1.9 acres) decayed to the date of the last spreading of.waste materials of November 4, 2003.4) Dose Conversion Factors (DCF) specific to the land spreading of materials at Vermont Yankee were taken from the VY ODCM, Appendix F, Tables 11 and 12 (Reference 1).These DCF's were based on the same dosimetric models and input parameters as used in the original analysis of septic waste spreading at VY and which was approved by the NRC for inclusion in the ODCM as Appendix B. Section 3.2 of this calculation provides an outline of the key aspects of the dose model and assumptions used. The following-(Tables 2 & 3) listing notes these site specific dose conversion factors for both the Control Period and the Intruder scenario for the nuclides detected as positive in one or more of the sample analyses.Table 2 Site Specific Control Period Dose Conversion Factors Max Organ Whole Body Isotope IndlvlduallOrgan DCF Control DCF Control Half-Life Decay Constant (A)(mremlyr- (mrem/yr-'

days Yr-1 liCilacre) pCUacre)Mn-54 Adult/GI-LLI 3.75E-04 1.93E-04 3.125E+02 8.113E-01 Co-80 Teen/Lung 7.17E-04 5.31E-04 1.925E+03 1.315E-01 Zn-65 Child/Liver 1.64E-02 1.03E-02 2.438E+02 1.038E+00 Cs-134 Child/Liver 3.18E-03 1.28E-03 7.531E+02 3.356E-01 Cs-137 Child/Bone 2.66E-03 7.02E..04 1.102E+04 2.290E-02 Ce-141 Teen/Lung 1.54E-04 1.50E-05 3.250E+01 7.788E+00 Ce-1i44 Teen/Lung 6.00E-04 2.44E-05 284.6 8.888E-01 12 Table 3 Site Specific Intruder Dose Conversion Factors Max Organ DCF Intruder Whole Body DCF Intruder Isotope Mn-54 Co-60 Zn-65 Cs-134 Cs-137 Ce-141 Ce-144 (mrem/yr-piCi/acre) (mrem/yr-pCi/acre)

Teen/Lung Teen/Lung Child/Liver Child/Liver Child/Bone Teen/Lung Teen/Lung 1.02E-02 3.19E-02 1.89E-02 1.21E-02 6.98E-03 1.21 E-02 5.OOE-02 3.12E-03 9.09E-03 1.25E-02 9.36E-03 3.85E-03 3.44E-04 1 .52E-03 13 5.0 EVALUATIONS In order to demonstrate compliance with the boundary dose conditions as stated in the ODCM, the critical organ and whole body dose from all pathways to the maximally exposed individual during Vermont Yankee Control Period and to the Inadvertent Intruder (for time periods following the end of the current operating plant license scheduled for 2013) were calculated for several scenarios (case studies) or combinations of disposal options. The dose calculations were performed using the site-specific dose factors for detected radionuclides as presented in Tables 2 and 3 (obtain from the VY ODCM, Appendix F, Tables 11 and 12). The objective is to demonstrate that the addition of the existing soil/sand materials currently in storage will not cause the radiological dose limits for materials spread on the South disposal field to be exceeded, even if it is assumed that all projected future annual disposals of septic waste, cooling tower silt and excavated soils/roadway sand containing the observed historical levels of plant related radionuclides are also placed on the same disposal plot.5.1 Case Study I (Past Spreading Impacts)The first case study (Case I) evaluated the spreading related dose impact associated with the past septic, Cooling Tower silt and soil spreading activity only. Table 4 shows the annual history and total amount of radioactivity in septic, silt and soil/sand waste materials by radionuclide that has been spread on the South field for the past 14 years (last spreading on'l 1/4/03). These radioactivity disposal values were taken from the past spreading records. Using (multiplying) the dose conversion factors listed on Tables 2 and 3 along with the total accumulated radioactivity content on the South disposal plot as of the last waste spreading in 2003 as shown on Table 18, the committed dose impact is found on Tables 21 and 22 for the Control Period dose as of the last spreading on November 4, 2003, as well as the Intruder Dose projected to 2013 from all materials currently spread on the South disposal plot. This assessment assumes no other material is spread on the disposal plot in the future, and therefore represents the existing dose commitments from all past spreadings.

This establishes the dose margin in comparison to the Control Period and Intruder dose limits still available for the South disposal plot.5.2 Case Study II (Stored Soil/Sand Inventory Impacts)The second case study (Case II) looks at the spreading dose impact (Control Period and the Intruder impact at the end of plant license) first from the radioactivity associated with the existing soil in storage (18,653 W 3 as indicated on Table 1) between the Cooling Towers, and then in combination with all past spreadings in order to demonstrate that the single south disposal plot can accommodate the current backlog of soil now being stored if it were all spread on top of all past disposals.

Table 18 indicates the total accumulated septic, silt and soil activity per radionuclide remaining on the disposal plot as of the last spreading (11/04103), as well as decayed to the projected reference date (6/1/04) for the spreading of all existing soil being held in storage, and to the projected end of the current plant license in 2013.Tables 8, 9, 10 and 11 provide the estimate of radioactivity content in each of the storage piles of soil/sand being held between the Cooling Towers for the detected nuclides Cs-1 37, Co-60, Zn-65, and Mn-54, respectively.

The activity concentrations are based on multiple grab samples collected 14 from each of the six separate storage piles, and are taken from the grab sample laboratory radiological analyses for each of the storage piles provided in Appendixes A through F. The average Cs-I 37 concentration in each of the soil piles was determined by including in the average the minimum detectable concentration (MDC) of each radionuclide because most of the samples indicated a positive concentration for Cs-137. This slightly biases the assessment towards a conservative upper bound estimate of the potential activity in the pile since the use of the MDC does not represent the existence of positive measured activity in the sample, but is treated as such. For the other detected radionuclides (Co-60, Zn-65 and Mn-54), this biasing of the data was not applied since the occurrence of positive values only represented a small fraction of the total number of samples taken. The total activity determination for each pile is then calculated by taking the average measured concentration times the measured soil density times the estimated volume of the storage pile, correcting for decay time between the date of the sample analysis date to the estimated date of field disposal (6/1/04).

This calculated total radionuclide activity value for each pile is assumed to be placed on the single 1.9 acre South disposal plot with the resulting surface concentration (uCi/acre) for the projected disposal calculated for each pile and totaled for all six piles currently in storage. The estimated average concentration for each of the four detected radionuclides is decay corrected from the date of the sample collection to June 1, 2004, as the reference date for estimating dose impacts from the proposed disposal of the accumulated material in storage. Table 12 summarizes the radioactivity associated with the soil/sand in storage decayed to June 1, 2004, and to the estimated end of the current plant license in 2013 for determining the Intruder dose impact at that time. Table 20 combines the radioactivity content of all soil/sand materials stored between the Cooling Towers with all remaining activity previously spread on the South disposal plot, decayed to 2013 for use in determining the Intruder dose at the end of plant license.Table 23 applies the dose conversion factors from Table 2 for maximum organ and whole body doses with the projected activity on the South disposal plot from Tables 12, 18 and 20 to find the Control Period dose for all past material spreadings, stored material additions, and the sum total of past spreadings and proposed stored material additions.

Table 24 illustrates the same dose impact combination of waste streams as applied to the site Intruder at the end of plant license. The combination of all past spreadings and the current stored soil material results in a maximum organ dose of only 17.7 % (0.177 mrem/yr) of the I mrem/yr Control Period dose limit. The maximum Intruder organ dose is estimated to be 0.456 mrem/yr or 9.1% of the 5 mrem/yr Intruder scenario dose limit. For comparison, Table 25 indicates that the maximum organ dose during the Control Period from only the inventory of 18,653 fV of soil/sand is estimated to be 0.0526 mrem/yr, or 5.3%of the 1 mrem/yr dose limit.5.3 Case Study III (Projected Future Spreading Imoacts)The third case study (Case 1II) projects what the likely annual spreading additions of earthen material from all sources (septic waste, Cooling Tower silt, soil/sand mixes) would be based on historical records, combined with the existing 18,653 fW 3 (528 M 3) of material in storage, in order to determine the long term acceptability of the South disposal plot to continue to be used for all waste spreading applications.

Based on the historical spreading data listed in Table 4, Tables 5, 6 and 7 show the total accumulated septic waste, Cooling Tower silt and soil/sand annual average field spreading surface concentrations by radionuclide and waste source, respectively.

This data breakdown is used in this disposal case study to predict future disposal rates to be applied to the South disposal plot. Table 13 provides a 15 summary of the buildup of future spreadings over time after 2004 from all three waste streams (Septic waste, Cooling Tower silt, and soil/sand mixes), which could be projected to accumulate on the South disposal plot by 2013. The annual disposal quantity for each waste stream is based on the average annual disposal quantity observed for each stream since on-site disposal was originally approved in .1990. The total of all three streams (septic waste, Cooling Tower silt, and soil/sand) is taken to be representative of the future generation rate for each year from 2004 until 2013. The last column of Table 13 indicates the decay corrected accumulated activity on the South disposal plot from only additions to the South field from all future waste earthen materials.

Tables 14, 15 and 16 provide additional detail of the projected annual and accumulated materials by waste stream (i.e., sand/soil mix, Cooling Tower silt and septic waste). The buildup equation used in Tables 13 through 18 accounts for both annual additions to the field as well as decay over this in-growth period is given by: Acti (t) -Actl (a) * (1- El" I)/(l -E)Where: Acti (t) the total activity of radionuclide "i" (uCi) remaining at the end of the buildup period, t (years).Acti (a) the annual radioactivity addition of nuclide "i" to the disposal plot in uCi.The values for projected future additions are based on the annual average value observed for that nuclide for the specific disposal stream (i.e., septic waste, cooling tower slit, soil/sand).

E exp(-Xi At)= is the decay constant for the selected radionuclide "i" (1/year)At = time interval between applications

= I year.In addition, Case Study II above evaluated the radiological impact from the disposal of the existing inventory of soil projected for mid-year, 2004 (including all past waste spreading operations), the total impact for 2004 should also include a projected disposal of both septic waste and Cooling Tower silt from one year's operation.

Table 17 combines one year's generation of both septage and silt for assumed spreading in 2004, plus subsequent decay to 2013.Table 26 combines the site-specific dose conversion factors from Tables 2 and 3 for the Control Period and Intruder scenario, respectively, with all previously spread radioactivity on the South disposal plot (Table 18) with both the proposed disposal of the existing soil stored inventory (Table 12) and projected annual additions of earth type waste materials based on the observed average annual generation rate (Tables 13 through 17). Table 19 provides a summary of accumulated radioactivity on the South field from the past spreading, materials in storage and future annual disposals on the same plot out to the assumed end of plant license, which corresponds to the Intruder dose scenario time frame. The resulting doses to the maximum organ and whole body of the maximum individual at the end of plant license (Table 26) reflects the maximum expected impact from all past and future disposals being placed on the South disposal field.16 6.0 RESULTS / CONCLUSIONS The evaluation of the radiological impact of all past, accumulated storage inventory, and projected future waste spreading operations on the 1.9 acre South disposal plot have shown that the existing field is being operated within the previously approved dose limit criteria.

The specific findings include: 1. For Case Study I (Past Spreading Impacts), Table 21 shows that after 14 years of spreading septic waste, Cooling Tower silt, and soil/sand mixes on the a single, 1.9 acre disposal plot the committed dose impact results in a maximum organ dose to a critical receptor (Control Period use) that accounts for only 13.7% of the I mrem/year limit. With respect to the Intruder dose limit of 5 mrem/year at the end of assumed active property control (i.e., end of plant license assumed for dose projection purposes), Table 22 indicates that all past spreadings through the end of 2003 account for only 7.2% of the maximum organ dose to the limiting receptor at the end of plant license. These finding illustrate that there is significant capacity remaining in the South disposal plot to continue to accept additional.earthen materials that are suitable for land spreading without exceeding established dose limitations.

2. Table 23 shows that the impact from the projected spreading of the existing 18,653 ft 3 of soil/sand material in storage is estimated to account for only 5.3% of the 1 mrem/yeat Control Period dose limit, or only 17.7% of the same limit when all past spreadings are combined with the materials currently in storage (as of the end of November 2003). The maximum Intruder organ dose from all past spreading and stored materials is calculated to be 0.456 mremlyr (Table 24), or 9.1% of the 5 mrem/yr Intruder scenario dose limit. These results indicate that the existing inventory of waste materials in storage can be placed on the South disposal plot without exceeding dose impact limits previously established for a single disposal field, or using a significant proportion of the South disposal plot's capacity to receive additional materials for disposal in the future.3. Assuming the same annual average generation rate of radioactivity in waste materials (septage/silt/soil) that has been observed over the last 14 years is added each year through 2013 to all past waste spreadings (including the stored soils inventory) already committed to the South disposal plot, Table 26 indicates that the projected dose at the end of the current plant licensing period (year 2013) yields a limiting maximum critical receptor dose (for either the control period or inadvertent intruder) equivalent to only 25.3% of the most restrictive annual dose limit (associated with the 1 mrem/year limit for the maximum organ during the Control Period). This finding demonstrates that the continued use of the South disposal plot, even with the addition of 18,653 ft 3 of slightly contaminated soil currently in storage, will not exceed the approved limiting dose criteria established in the ODCM.4. The approved dose impact methodology used to determine compliance with the on-site spreading dose limits are not driven by the volume of waste material disposed of, but by the total radioactivity content of the material that is spread over a fixed disposal plot area (1.9 acres for the South field). The dose modeling assumes that all radioactivity spread on the field remains in the top 15 cm surface layer of soil, even after subsequent additions are 17 placed on the same field area. Existing limits on the concentration of radioactivity in waste media provides protection from small volumes of "hot" or high specific activity materials from being spread on the disposal field.18 Table 4 Record of Septic / Cooling Tower Slit I Construction Soil Radioactive Material Spreading Each Year on the South Disposal Field Year Spreading Material Mn-54 CO-60 Zn-65 CS-134 Cs-137 Ce-141 Year Date Type (uCac) uCVacre) (uCi'ecre) (uCifacr) (uCi/ecre) (uCl/aae)1990 10/31/90 Septage 0 3.89 0 0 0.26 0 11/20/90 Septage 0.17 2.03 0.41 0 0.29 1.40E-08 1991 none 0 0 0 0 0 0 1992 10119/92 Septage 0.1i 1.73 0.52 0.05 0.32 0.006 1993 11014193 Septage 0.05 1.A1 0.21 0 0.3 0 1994 06/14/94 Septage 0.08 0.43 0 0 0.09 0 1995 06/29/96 Septage 0 0.88 0 0 0 0 1996 none 0 0 0 0 0 0 1997 06/18/97 Septage 0.12 1 0 0 0.19 0 1998 07/30198 Septage 0.14 0.72 0.09 0 0.12 0 09/18198 CT St 0 0 0 0 30.87 0 1999 07115/99 Septage 0.11 1.47 0.2 .0 0.25 0 2000 08/09/00 Septage* 0 0 0 0 0 0 10/24/00 CT Slt 0.117 0.68 0 0 0 0 10/24/00 SoiVSand 0 0,602 0 0 3.698 0 2001 06-20-01 Septage 0 4.070 1.088 0 0.156 0.089 09/25/01 Soil/Sand 0 0 0 0 1.4 0 2002 06/21/02 Septage 0.01 0.04 0 0.001 0.01 0 11/111/02 Soil/Sand 0 0 0 0 1.37 0 2003 07/01103 Septage 0 1.03 0 0 0 0 10/25/03 Septage 0 0.12 0 0 0 0 11/04/03 Soil/Sand 0 0 0 0 1.34 0 11/04/03 CT Silit 0 0.256 0 0 0 0 Average Activity/yr (uCi/acre):

0.06 1.45 0.18 0.0036 2.90 0.01 (Over 14 year spreading history)Average activity (uClyr) 0.123 2.76 0.342 0.007 5.52 0.013 disposed of on 1.9 acre field each year* No radioactivity detected in septic waste samples.4 19 Table 5 Record of SepticWaste Only for Radioactive Material Spreading Each Year on the South Disposal Field Year Spreading Material Mn-54 Co-W0 Zn-W5 Cs-134 Os-137 Ce-141 Date Type (uCi/acre) (uCi/acre) (uCi/acre) (uCifacre) (uCi/acre) (uCi/acre) 1990 10/31/90 Septage 0 3.89 0 0 0.26 0 11/20/90 Septage 0.17 2.03 0.41 0 0.29 1.40E-08 1991 none 0 0 0 0 0 0 1992 10/19/92 Septage 0.11 1.73 0.62 0.05 0.32 0.006 1993 10/14/93 Septage 0.05 1.41 0.21 0 0.3 0 1994 06/14194 Septage 0.08 0.43 0 0 0.09 0 1995 08/29/95 Septage 0 0.88 0 0 0 0 1996 none 0 0 0 0 0 0 1997 06/18/97 Septage 0.12 1 0 0 0.19 0 1998 07130/98 Septage 0.14 0.72 0.09 0 0.12 0 1999 07/15199 Septage 0.11 1.47 0.2 0 0.25 0 2000 08/09/00 Septage* 0 0 0 0 0 0 2001 06-20-01 Septage 0 4.078 1.088 0 0.156 0.089 2002 06/21/02 Septage 0.01 0.04 0 0.001 0.01 -0 2003 07/01/03 Septage 1.03" 0 0 0 0 10/25/03 Septage 0 0.12 0 0 0 0 Average Activity/yr (uCVacre):

0.06 1.34 0.18 0.004 0.14 0.01 (Over 14 year spreading history)Average activity (uCi/yr) 0.107 2.56 0.342 0.007 0.27 0.013 disposed of on 1.9 acre field each year I No radioactivity detected in septic waste samples.

Table 6 Record of Cooling Tower Silt Waste Only for Radioactive Material Spreading Each Year on the South Disposal Field Year Spreading Material Mn-54 Co-60 Zn-65 Cs-134 Cs-137 Ce-141 Date Type (uCifacre) (uCi/acme) (uCi/acre) (uCVacre) (uCi/acre) (uClfacre) 1998 09118/98 Silt 0 0 0 0 30.87 0 2000 10/24/00 Silt 0.117 0.68 0 0 0 0 2003 11/04/03 Silt 0 0,256 0 0 0 0 Average Activity/yr (uCi/acre) 0.004 0.030 0.000 0.000 0.996 0.000 (31 year silt generation history)Average activity (uCi/yr) 0.007 0,057 0.000 0.000 1.892 0.000 disposed of on 1.9 acre field Note: Cooling Tower yearly average is over 31 years of operation since the first disposal In 1998 included all accumulated material since plant startup Table 7 Record of Construction Soil/Sand Waste Only for Radioactive Material Spreading Each Year on the South Disposal Field Spreading Material Mn-54 Co-60 Zn-65 Cs-i134 Cs-1 37 Ce-141 Date Type (uCi/acre) (uCiacre) (uCVacre) (uCi/acre) (uCitacre) (uCi/acre) 2000 10/24/00 Soll/Sand 0 0.602 0 0 3.698 0 2001 09/26101 SoilSand 0 0 0 0 1.4 0 2002 11/11/02 Soil/Sand 0 0 0 0 1.37 0 2003 11/04/03 Soil/Sand 0 0 0 0 1.34 0 Average Activity/yr (uCVacme):

0.00 0.15 0.00 0.00 1.95 0.00 Average activity (uCl/yr) disposed of 0.00 0.29 0.00 0.00 3.71 0.00 on 1.9 acre field per year Note: Soil/road sand yearly average is over only the 4 years of operation since that is the period of material collection.

21 Table 8 Cesium -137 in storage Piles after Last Spreading 2003*Activity decayed to 06101/04 Pile description Estimated Date of Decay time Aver. Cs- Measured Total Cs- Aver. Cs- Cs-1 37 % Cs-1 37 Volume Analysis to 6/1104 137 Conc.(w density 137 137 applied to of total/LLD) No (decayed)

Conc.(w/ 1.9 acre decay (w /LLD) LLD) field decayed ftA3 years uCi/gm gm/cc uCI uCI/gm uCil/acre 2002-01: Security Fence Upgrade 4,679 05/06/02 2.08 7.12E-08 1.07 9.82E+00 6.79E-08 6.07E+00 31.48%2002-02: Security Fence Upgrade 9,000 06/04/02 2.00 4,18E-08 1.11 1.13E+01 3.99E-08 5.94E+00 36.95%Park Lot Sweep (inside protected 616 11/02/01 2.58 4.802-08 1.56 1.23E+00 4.52E-08 6.48E-01 4.03%area)2001 HWC Soils Excavation 931 10122/01 2.58 5.41E-08 1.057 1.42E+00 5.101-08 7.48E-01 4.65%1996 Remnants( mixed contain. + 970 04/13/95 8.13 9.22E-08 1.7 3.57E+00 7.65E-08 1.88E+00 11.69%non-cont)2002-03 Security Fence Chunks & 2,457 12/16/02 1.54 4.11E-08 1.24 3.42E+00 3.97E-08 1.80E+00 11.20%soil mix totals =18,653 Average a 5.81E-08 total = -3.06E+01 5.34E-08 1.61E+01 100.00%* Note: Soil analysis data provided in Appendixes A through F.22 Table 9 Cobalt -60 in Storage Plies after Last Spreading in 2003*Activity decayed to 06101/04 Pile description Estimated Date of Decay Aver.Co-60 Measured Total Co-60 Aver. Co-60 Co-60 % Co-60 Volume Analysis time to Conc., no density (decayed)

Conc., decayed applied to 1.9 of total 611104 decay acre field ftA3 years uClI/gm gm/cc uCi uC/gm uCtIacre 2002-01: Security Fence Upgrade 4,679 05/06/02 2.08 0.OOE+00 1.07 0.OOE+00 0.OOE+00 0.00E+00 0.00%2002-02: Security Fence Upgrade 9,000 06/04/02 2.00 0.OOE+00 1.11 0.OOE+00 0.OOE+00 0.OOE+00 0.00%Park Lot Sweep (inside protected area) 618 11102/01 2.58 8.72E-09 1.56 1.e9E-01 8.22E-09 8.90E-02 33.01%2001 HWC Soils Excavation 931 10/22101 2.58 0.OOE+00 1.057 0.OOE+00 0.OOE+00 0.OOE+00 0.00%1998 Remnants( mixed contani. + non- 970 04/13/95 8.13 2.14E-08 1.7 3.43E-01 1.78E-08 1.81E-01 66.99%oant)2002-03 Security Fence Chunks & soil 2,457 12/16/02 1.54 0.00E+00 1.24 0.00E+00 0.OOE+00 0.OOE+00 0.00%mix total$ = 18,653 average = 5.02E-09 total = 5.12E-01 4.33E-09 2.70E-01 100.00%* Note: Soil analysis data provided in Appendixes A through F.23 Table 10 Zinc -65 in Storage Piles after Last Spreading in 2003*Activity decayed to 06101104 Pile description Estimated Date of Decay Aver. Zn- Measured Volume Analysis time to 65 Conc., density 611/04 no decay Total Zn-65 Aver. Zn-65 Zn-65 % Zn-65 (decayed)

Conc., applied to of total decayed 1.9 acre field ftA3 years uCi/gm gm/cc uCi uC!,rn uCVacre 2002-01: Security Fence Upgrade 4,679 05/06102 2.08 0.OQE+00 1.07 0.00E+00 0.OOE+00 O.OOE+00 0.00%2002-02: Security Fence Upgrade 9,000 06/04102 2.00 3.87E-09 1.11 1.05E+00 3.70E-09 5.50E-01 95.04%Park Lot Sweep (inside protected area) 616 11/02101 2.58 0.OOE+00 1.56 0.00E+00 0.OOE+00 0.00E+00 0.00%2001 FVWC Soils Excavation 931 10/22101 2.58 2.08E-09 1.057 5.46E-02 1.96E-09 2.87E-02.

4,96%1996 Remnants( mixed contain. + non- 970 04/13/95 8.13 0.00E+00 1.7 0.00E+00 0.OOE+00 0.00E+00 0.00%cont)2002-03 Security Fence Chunks & soil 2,457 12116102 1.54 0.00E+00 1.24 0.OOE+00 0.00E+00 0.OOE+00 0.00%mix totals =18,653 Average = 9.92E-10 total =1.10E+00 9.43E-10 5.79E-01 100.00%* Note: Soil analysis data provided in Appendixes A through F.24 S-, ....~

Table 11 Mn-54 in Storage Piles after Last Spreading In 2003*Estimated Date of Decay Aver. Mn-54 Volume Analysis time to Cono,, no 6/1104 decay Activity decayed to 06/01/04 Pile description Measured Total Mn-54 Aver. Mn-54 Mn-54 % Mn-54 density (decayed)

Conc., applied to of total decayed 1.9 acre field flA3 years uCvgm gm/cc uCi uCIlgm uCl/acre 2002-01: Security Fence Upgrade 4,679 05/06/02 2.08 2.09E-09 1.07 2.82E-01 1 .99E-09 1.49E-01 69.78%2002-02: Security Fence Upgrade 9,000 06/0402 2.00 0.00E+00 1.11 0.00E+O0 0.OOE+0O 0.00o+O0 0.00%Park Lot Sweep (inhide protected area) 616 11102/01 2.58 4.77E-09 1.56 1.22E-01 4.50E-09 6.44E-02 30.22%2001 HWC Soils Excavation 931 10/22/01 2.58 O.OOE+00 1.057 0.OOE+00 0.OOE+00 Q.OOE+00 0.00%1996 Remnants (mixed contain. + non- 970 04/13/95 8.13 0.OOE+00 1.7 0.OOE+00 0.OOE+00 0.OOE+00 0.00%cont)2002-03 Security Fence Chunks & soil mix 2,457 12/16/02 1.54 0.00E+00 1.24 0.OOE+00 0.00E+00 0.OOE+O0 0.00%totals a 18,653 Averagez 1.14E-09 total = 4.05E-01 1.08E-09 2.13E-01 100.00%* Note: Soil analysis data provided in Appendixes A through F.25 Table 12 Soil/Sand in Storage Total Activity to be spread on 611104 and decayed to 2013 ASotC>/lfO4 Qa (Ucitacre)*

Decay Time to 6Q1/2013 (yrs)Isotope lamda 1/yr Mn-54 0.8113 0.213 Co-60 0.1315 0.270 Zn-65 1.0382 0.579 Cs-1 34 0.3356 0.000 Cs137 0.0229 16.1 Ce-141 7.7883 0.000 9 9 9 9 9 9 0a 1,44E-04 8.27E-4)2 5.07E-05 0.00E+00 1.31 E+'01 0.00E+00* Note: Qa.values from Table 8 (Cs-137), Table 9 (Co-60), Table 10 (Zn-65), and Table I I (Mn-54)Table 13 Projection of Additional Septic, silt, and soil/sand at Current Generation Rates to 2013 Annual Septic Annual Silt Addition I Addition Annual Soil/Sand Addition Qa (uCi/acre)

Annual Total Additions Qa (uCi/acrel Additional Accumulation at end of 9 years Qe (uCi/acre)

Isotope lamda l1yr Qa (uCi/acre)

I Qa (uCi/acre)

Mn-54 0.8113 0.056 0.0038 0.043 0.103 0.185 Co-60 0.1315 1.345 0.0302 0.174 1.549 8.183 Zn-65 1.0382 0.180 0.0000 0.116 0.296 0.458 Cs-134 0.3356 0.004 0.0000 0.000 0.004 0.012 Cs137 0.0229 0.142 0.9958 4.782 5.919 43.767 Ce-141 7.7883 0.007 0.0000 0.000 0.007 0.007 26 Table 14 Projection of Additional Sand/Soil Mix At Historical Generation Rates To Year 2013 (9 years after 2004)Projected Annual Soil/Sand Additions Accumulated Sand/Soil to Field at end of 9 years Isotope lamda 1yr Qa (uCil.acre)Qe...c

.Mn-54 0.8113 426E-02 7.65E-02 Co-60 0.1315 1.74E-01 9.21E-01 Zn-65 1.0382 1.16E-01 1.79E-01 Cs-134 0.3356 O.OOE+00 0.O0E+00 Cs137 0.0229 4,78E+00 3,54E+01 Ce-141 7.7883 O.OOE+00 O.OOE+00 Table 15 Projection of Additional Cooling Tower (CT) Silt At Historical Generation Rates To Year 2013 (9 years after 2004)Projected Annual CT Accumulated CT Silt at Silt Additions to Field end of 9 years Isotope lamda l/yr Qa (uCllacre)

Qe (uCilacre)

Mn-54 0.8113 3.77E-03 6.78E-03 Co-60 0.1315 3.02E-02 1.69E-01 Zn-65 1.0382 O.OOE+00 O.OOE+00 Cs-134 0.3356 0.OOE+00 O.OOE+00 Cs137 0.0229 9.96E-01 7.36E+00 Ce-141 7.7883 O.OOE+00 0.OOE+00 Table 16 Projection of Additional Septic Waste At Historical Generation Rates To Year 2013 (9 years after 2004)Projected Annual Septic Accumulated Septic Additions to Field Waste at end of 9 years Isotope lamda I/yr Qa (uCilacre)

Qe (uCi/acre)

Mn-54 0.8113 5.64E-02 1.01E-01 Co-60 0,1315 1.34E+00 7.1OE+00 Zn-65 1.0382 1.80E-01 2.78E-01 Cs-134 0.3356 3.64E-03 1.19E-02 Cs137 0.0229 1.42E-O1 1.05E+O0 Ce-141 7.7883 6.79E-03 8.79E-03 27 Table 17 Projected 1 Yr Septage + Silt Spreading for 611/04 and decayed to 2013 As of 6(1104 Decay Time to As of 2013 Isotope lamda 1/yr Qa (uCi/acre) 6/1112013 Ga (uCi/acre)

Mn-54 CO-60 Zn-65 Cs-134 Cs137 Ce-141 0.8113 0.1315 1.0382 0.3356 0.0229 7.7883 0.060 1.375 0.180 0.004 1.138 0.007 9 9 9 9 9 9 4.06E-05 4.21E-01 1.57E-05 1 .78E-04 9.26E-01 2.45E-33 Table 18 Current Total Spreadings as of 1114/03 and How much Remains at 611/04 and 2013 As of 11/4103 Decay Time to As of 6/1/04 Decay Time to As of 2013 lameda QaQa0421 (r) Qa Isotope 1/yr Qa (uCl/acre) 6/1/04 (yrs) (uCacre) 2013 (yrs) (uCi/acre)

Mn-54 0.8113 0.241 0.5753 0.151 9 1.02E-04 Co-80 0.1315 16.33 0.5753 15.140 9 4.64 Zn-65 1.0382 1.47 0.5753 0.809 9 7.08E-05 Cs-134 0.3356 0.00063 0.5753 0.001 9 2.53E.05 Cs137 0.0229 38.18 0.5753 37.68 9 30.66 Ce-141 7.7883 8,80E-10 0.5753 1.OE-11 9 3.60E-42 Data Taken from Plant Disposal Records 28 Table 19 Current Spreading Totals Plus Total Projected Future Spreadings to 2013 All Current Field Art. Stored Soil/sand 1 Yr Future Total all Activity Septage+silt Spreading TtlalAtvt Decayed to 2013" Decayed to Decayed to *Decayed to 2013- 2013- 2013- Decayed to 2013 Isotope (uCilacre) (uCilacre) (uCi/acre) (uCi/acre) (uCi/acre)

Mn-54 1.02E-04 1.44E-04 4.08E-05 0.185 1.-5E-01 Co-60 4.636 8.27E-02 0.421 8.183 1.33E+01 Zn-65 7.08E-05 5.07E-05 1.57E-05 0.458 4.58E-01 Cs-134 2.53E-05 0.00E+00 1.78E-04 0.012 1.21E-02 Cs137 30.66 13.10 0.926 43.767 8.85E401 Ce-141 3.60E-42 O.OOE+00 2.45E-33 0.007 6.79E-03 Notes:

• Activity Concentration from Table 18.*

• Activity Concentration from Table 12.* ** Activity Concentration from Table 15, 16 and 17.***** Activity Concentration from Table 13 and 14.Table 20 Radioactivity Content from Existing Materials (Past Spreadings

& Stored Materials Only)End Plant Operations for Intruder Dose: End Date 6/1/2013 9 years Last Application Date 6/1/2004 Decay duration to end of Plant Operations:

Total Activity on Total Activity Past Material Stored Total Past +South Field decayed to Spread only Material to be Material plus storage year 2013 up to 1114103 Spread decayedto Isotope piles (uCilacre)° (uCl/acre) decayed to 2013 decayed to 2013 (uCa/acre) 2013 (__1_4_(uCVacre) (uCi/acre)

Mn-54 0.364 2.46E-04 1.02E-04 1.44E-04 2.46E-04 Co-60 15.41 4.72E+00 4.64E+00 8.27E-02 4.72E+00 Zn-65 1.388 1.21E-O4 7.08E-05 5.07E-05 1.21E-04 Cs-134 0.001 2-53E-05 2.53E-05 0*OUE+00 2.53E-05 Cs-137 53.78 4.38E+01 3.OGE+01 1.31E+01 4.38E+01 Ce-141 1.0E-11 3.60E-42 3.60E-42., 0.00E+00 3.60E-42* Includes all material spread as of 11/4/03 decay corected to the indicated date..29 Table 21 Past Spreading Control Period Doses As of H1/04/03 (No Stored Material or Future Additions Included)Isotope Total Activity Remaining on South Field as of 11/04/03 uCVacre Max Organ Existing Material from Past Spreading Mrem/year Whole Body Existing Material from Past Spreading Mrem/year Mn-54 0,241 9.04E-05 4.65E-05 Co-60 16.33 1.17E-02 8.67E-03 Zn-65 1.47 2.41E-02 1.51E-02 Cs-134 0.00063 2.00E-06 8.06E-07 Cs-137 38.18 1.02E-01 2.68E-02 Ce-141 8.8E-10 1.36E-13 1.32E-14 Total Dose = 1.37E-01 5.07E-02 Dose Umlt per field =% of Dose 13.7% 5.1%limit Table 22 Past Spreading Intruder Period Doses At End of Plant License in 2013 (No Stored Material or Future Additions Included after 11/4/03)Isotope Total Activity Total Activity Max Organ Whole Body Remaining on Remaining on Existing Material Existing Material South Field as South Field from Past from Past of 11104/03 decayed Spreading Spreading corrected to 2013 uCi/acre uCi/acre Mrem/year Mrenmyear Mn-54 0.241 1.02E-04 1.04E-06 3,18E-07 CO-60 16.33 4.636 1.48E-01 4.21E-02 Zn-65 1.47 7.08E-05 1.34E-06 8.85E-07 Cs-134 0.00063 2.53E-05 3.07E-07 2.37E-07 Cs-137 38.18 30.66 2.14E-01 1.18E-01 Ce-141 8.8E-10 3.60E-42 4.36E-44 1.24E-45 Total Dose =Dose Limit per field =% of Dose limit 3.62E--01 5 7.2%1.60E-01 5 3.2%30 Table 23 Control Period Dose: Past Spreading

& Current Stored Soil Inventory (as of 611104)Isotope Max Organ Whole Body Max Organ Whole Body Max Organ Whole Body Existing Existing Stored All Past All Past Material from Material from Materal to be Stored Material Spreading Spreading Past Past be to be Spread Plus Stored Plus Stored Spreading Spreading Spread Inventory Inventory Mrem/year Mrem/year MrerfyeaL Mrem/year Mrem~ear Mr-ea...Mn-54 5.67E-05 2.92E-05 7.99E-05 4.11E-05 1.37E-04 7.03E-05 Co-60 1.09E-02 8.04E-03 1.94E-04 1.43E-04 1.10E-02 8.18E-03 Zn-65 1.33E-02 8.33E-03 9.50E-03 5.96E-03 228E-02 1.43k-02 Cs-134 1.65E-06 6.65E-07 0.00E+00 0.00E-100 1.65E-06 6.65E-07 Cs-137 11.00E-01 2.65E-02 4.28E-02 1..13E-02 1.43E-01 3.78E-02 Ce-141 1.54E-15 1.50E-16 0.OOE+00 0.OOE+00 1.54E-15 1;50E-16 Total Dose = 1.24E-01 4.29E-02 5.26E-02 1.752-02 1.77E-01 6.03E-02 Dose Limit 1 1 1 1 per field =% of Dose 12.4% 4.3% 5.3% 1.7% 17.7% 6.0%limit ._-Table 24 Past Spreading

& Stored Soil Inventory (No Future Additions)

Intruder Dose at End of Plant License in 2013 Isotope Max Organ Whole Body Max Organ Whole Body Max Organ Whole Body Existing Existing Stored Stored AlS Past ASr Past Material from Material from Material to be Material to be Spreading Spreading Past Past Spread Spread Pus Stored Plus Sored Spreading Spreading Inventory Inventory Mrem/year Mrem/year Mrem/year Mrem/year Mrem/year Mrem year Mn-54 Co-60 Zn-6, Cs-134 Cs-1 37 Ce-141 1.04E-08 1.48E-01 1.34E-06 3.07E-07 2.14E-01 4.36E-44 3.18E-07 4.21E-02 8.85E-07 2.37E-07 1.18E-01 1.24E-45 1 .47E-06 2.64E-03 9.58E-07 O.OOE+0O 9.14E-02 0.002+00 4.48E-07 7.52E-04 6.33E-07 0.00E+00 5.04E-02 0.00E+00 2.502-06 1.51E-01 2.30E-06 3.07E-07 3.05E-01 4.36E-44 4.56E-01 5 7.661-07 4.29E-02 1.52E-06 2.37E-07 1.68E-01 1.25E-45 2.11E-01 5+Total Dose =Dose Limit per field -% of Dose limit 3.62E-01 5 7.2%1.602-01 5 3.2%9.41 E-02 5 1.9%5.12E-02 5 100%4.2%J ___________________

.1 _________

~31 Table 25 Dose Impact from Spreading of Current Inventory of Stored Material Only*Total Stored Waste Max Organ Whole Body Max Organ Whole Body % Contribution

% Contribution Max Activity Max organ organ Isotope As of 06101/04-Control (06/01/04)

Control (6/01104)

Intruder (2013) Intruder (2013) by isotope by isotope (uCI/acre) mrem/year mrermlyear mrern/year mrenmyr Intruder Dose Control Period Dose Mn-54 2.13E-01 7.99E-05 4.11 E-05 1.47E-06 4.48E-07 0.00% 0.032%Co-60 2.70E-01 1.94E-04 1.43E-04 2-64E-03 7.52E-04 0.25% 0.077%Zn-65 5.79E-01 9.50E-03 5.96E-03 9.58E-07 6.33E-07 0.00% 3.760%Cs-134 0.OOE+00 0,00E+00 0.OOE+00 0.OOE+00 0.00E+00 0.0000% 0.0000%Cs-137 1.61 E+01 4.28E-02 1.133E-02 9.14E-02 5.04E-02 8.7% 17.0%Ce-141 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.00E+00 0.0000% 0.0000%Ce-144 0.00E+00 0.00E+O0 0,OOE+00 0.00E+00 0.00E+00 0.0000% 0.0000%Total Dose a 5.26E-02 1.75E-02 9.41 E-02 5.12E-02 8.9% 20.8%Dose Limit = 1 1 5 5% of Dose ULmit 5.3% 1.7% 1.9% 1.0%Includes only Stored soil/sand materials collected as of end of 2003 (See Table 1)" Total Activity values from Table 12.32 Table 26 Past, Stored Materials and Projected Future Disposal (all septage/silt and soils) Doses at End of Plant License*Total Waste Max. Organ Whole Body Max. Organ Whole Body % % Contribution Activity Contribution Max organ Max organ Isotope In 2013- Control Control Intruder Intruder by isotope by isotope (uCi/acre) mrenmyear mrem/year mrern/year mremlyr Intruder Dose Control Period Dose Mn-54 1.86E-01 6.94E-05 3.57E-05 1.89E-03 5.77E-04 0.18% 0.027%Co-60 1.33E+01 9.54E-03 7.06E-03 4.24E-01 1.21E-01 40.30% 3.776%Zn-65 4.58E-01 7.51E-03 4.72E-03 8.66E-03 5.73E-03 0.82% 2.974%Cs-134 1.21E-02 3.85E-05 1.55E-05 1.46E-04 1.13E-04 0.0139% 0,0152%Cs-137 8.85E-+01 2.35E-01 6.21E-02 6.18E-01 3.41E-01 58.7% 932%Ce-141 6.79E-03 1.05E-06 1.02E-07 8.22E-05 2.34E-06 0.0078% 0.0004%Ce-144 0.00E+00 O.00E+00 O.OOE+00 0.OOE+00 0.00E+00 0.0000% 0.0000%Total Dose = 2.53E-01 7.40E-02 1.05E+00 4.68E-01 100.0% "100.0%Dose Umit 1 1 5 5% of Dose Umit 25.3% 7.4% 21.1% 9.4%* Includes all past spreadings, soil stored Between Cooling Towers (as of 11/4/03), and all annual projected additions of septage/sitsoll.

-Total Activity values from last column of Table 19.33 REFERENCES (1) Vermont Yankee Off site Dose Calculation Manual (ODCM), Revision 30, including the following appendixes: (i) Appendix B, "Approval of Criteria for Disposal of Slightly Contaminated Septic Waste On-Site at Vermont Yankee" (Included NRC approval letter dated August 30, 1989, VY request for approval dated June 28, 1989 with Attachments I and I1.)(ii) Appendix F, "Approval Pursuant to I OCFR20.2002 For Onsite Disposal of Cooling Tower Silt" (Included NRC approval letter dated March 4, 1996, VY Request for Approval dated August 30, 1995.)(iii) Appendix H, "Request to Amend Previous Approvals Granted Under 1 OCFR20.302(a) for Disposal of Contaminated Septic Waste and Cooling Tower Silt to Allow for Disposal of Contaminated Soil" datýd June 23, 1999, with supplements dated January 4,2000, and June 15, 2000.(2) USNRC Regulatory Guide 1.109, Rev.1; "Calculation of Annul Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 40, Appendix I," dated October 1997.34 Appendix A Security Fence Upgrade Soil Pile #2002-01 Density from samples data Soil Analysis Data Sample Cs137 Cs-137 LLD Mn-54 detected (uCilgm) Volume (cc) wet weight location # detected reported (gm)(uCi/gm) (uCi/gm)3B 5.76E-08 1200 1266 3F 1.16E-07 1200 1062 4A 7,76E-08 1200 1393 4B 5.62E-08 1200 1512 4D 4.81E-08 1200 1483 4F 1.15E-07 1200 1137 5A 6,95E-08 1200 1390 5D 1.84E-07 1200 1194 5F 1.72E-07 5.86E-08 1200 1051 1A 3.93E-08 1200 985 1 B 5.97E-08 1200 1335 1C 2.92E-08 1200 1188 1 D 7.39E-08 1200 1355" 1E 3.65E-08 1200 1686 1F 4,18E-08 1200 1294 2A 6.83E-08 1200 1240 2B 8.53E-08 1200 1043 2C 4.88E-08 1200 1171 2D 4.16E-08 1200 1420 2E 3.43E-08 1200 1304 2F 4.75E-08 1200 1360 3A 8.35E-08 1200 1189 3C 9.59E-08 1200 1348 3E 5.65E-08 1200 1073 4C 4.44E-08 1200 1486 4E 9.37E-08 1200 1057 5B 723E-08 1200 1428 5C 4.53E-08 1200 1551 wVL Positive Ave. =4.06E-08 averages Density Density 1200 1285.75 1.07 gm/cc 1071.46 kg/m3 Positive & LLD ave. =7.12E-08 A-]

Appendix B Security Fence Upgrade Soil Pile # 2002-02 Soil Analysis data Density from Sample Data Sample Cs137 Cs-137 LLD Zn-65 detected (uCi/gm) Volume wet location detected reported (ml) weight# (uCi/gm) (ucVgm) (gin)A3 3.98E-08 1200 1388 A4 6.93E-08 1200 1221 A5 4.53E-08 1200 1278 A6 4.69E-08 1200 1249 A7 4.04E-08 1200 1335 A8 7.29E-08 1200 1274 B1 4.06E-08 7.73E-08 1200 1392 B2 3-02E-08 1200 1404 83 4.08E-08 1200 1313 B4 3.34E-08 1200 1230 85 3.38E-08 1200 1241 B6 2.13E-08 1200 1299 87 4.24E-08 1200 1297 B8 3.73E-08 1200 1475 C3 3.90E-08 1200 1696 C4 4.25E-08 1200 1329 C5 4.06E-08 1200 1318 C6 4.14E-08 1200 1230 C7 4.60E-08 1200 1335 D7 3.22E-08 1200 1294 wtd positive ave.5.09E-09 average density 1200 1329.9 1.11 gm/cc 1108.25 kg/m3 Positive & LLD ave. =4.18E-08 B-I Appendix C Security Fence Upgrade Soil Pile # 2002-03 Soil Analysis Data Density from samples data Sample Cs137 Cs-137 LLD Volume (ml) Wet weight location # detected reported (gm)(uC Igm) (uCygm) ....... ........I 3.OOE-08 1000 1348 2 3.46E-08 1100 1424 3 2.58E-08 1100 1410 4 3.72E-08 1100 1410 5 3.84E-08 1000 1034 6 4.58E-08 1200 1108 7 3.14E-08 1000 1526 8 4.29E-08 1000 1532 9 5.42E-08 1000 1086 10 5.OOE-08 1000 1289 11 5.68E-08 1000 1185 12 4.62E-08 1000 1135 average density 1041.67 1290.58 1.24 gm/cc wt positive aver.=3.2E-09 1238.96 kglm3 Positive & LLD ave. =4.11EE-08 C-!

Appendix D 2001 Protected Area Road Sweeping Pile Soil Analysis Data Density from Sample Data Sample Cs137 Cs-137 LLD Co-60 Co-60 LLD Mn-54 Volume (ml) wet locatio detected reported detected reported detected weight n # (uCi/gm) (uCi/gm) (uCivgm) (uCilgm) (uCi/gm) (9m)I 6.55E-08 5.36E-08 1000 1435 2 3.43E-08 4.24E-08 1100 1753 3 2.91E-08 3.03E-08 1000 1550 4 4.83E-08 4.95E-08 1000 1615 5 6.37E-08 7.83E-08 1000 1657 6 3.67E-08 4.10E-08 1000 1609 7 1.96E-08 3.13E-08 1000 1565 8 1000 1650 9 3.11E-08 2.26E-08 1000 1439 10 6.09E-08 6.05E-08 1005 1762 11 4.07E-08 4.63E-08 1000 1421 12 4.75E-08 2.35E-08 1.23E-08 1000 1454 13 7.14E-08 4.30E-08 1000 1561 14 4.04E-08 3.22E-08 1000 1659 15 6.65E-08 6.47E-08 5.92E-08 1000 1503 16 4.20E-08 3.73E-08 1000 1607 17 4.69E-08 3.13E-08 1000 1536 18 5.05E-08 6.21E-08 1000 1594 19 5.45E-08 5.59E-08 1000 1474 20 6.25E-08 3.62E-08 2.38E-08 1000 1427 wt 3.17E-08 8.72E-09 4.77E-09 average 1005.2 1563.5 positive ave.=density 1.56 gm/cc Positive & LLD 4.80E-08 4.43E-08 1555.4 kg/m3 ave.=D-1 Appendix E 2001 HWC Soil Excavations Sol] Analysis Data Density from Samnle data Cs137 Cs-137 LLD Zn-65 wet Sample detected reported detected Volume weight location # (uCi/gm) (uCi/gm) (uCi/gm) (ml) (gi)1 4.09E-08 1000 1099 2 6 11E-08 1000 1043 3 6.04E-08 1000 1007 4 4.78E-08 1000 1008 5 5.30E-08 1000 1103 6 5.77E-08 1000 1025 7 5.94E-08 1000 956 8 4.75E-08 1000 957 9 5.05E-08 1000 976 10 6.16E-08 1000 1050 11 5.54E-08 1000 1043 12 6.50E-08 1000 1126 13 3.44E-08 1000 1141 14 5.67E-08 1000 997 15 5.26E-08 1000 1105 16 5.80E-08 1000 1190 17 5.58E-08 na 1000 1040 18 5.29E-08 1000 1141 19 5.85E-08 1000 1050 20 5.20E-08 1000 1073 wt positive ave.= 1.95E-08 average= 1000 1056.5 Positive & LLD ave.= 5.41 E-08 density = 1.0565 gmlcc 1056.5 kg/m3 E-I Appendix F 1996 Soil Remnants Analysis -Security Fence Upgrade The attached report ('Radioactivity Analyses for Soil Piles Stored Between Cooling Towers", REG-] 15/96, dated July 15, 1996) indicates that two soil piles totaling 4000 f 3 were collected in 1995 and stored between the Cooling Towers. Even though the larger of the two piles (3100 ft 3) did not indicate any detectable plant related radioactivity, the two piles were eventually combined with portions disposed of by land spreading on the South disposal plot as annual disposal volume limits for soil/sand mixes permitted.

The remnants of the piles currently contain about 970 W of material.

For the estimated concentration of Cs-137 in the combined piles, concentration values from Tables I and 3 were averaged in proportion to there volumes as shown: Cs- 137: 900 Wt at an average concentration of 328 pCi/kg 3100 i3 with no detectable activity (average absolute value = I I pCi/kg)Average concentration (weighted ave,) = 900 fle

• 328Wi/kg +- 3100 ft

• I I pCi/kg 900ftW + 3100 fe 82.33 pCi/kg (dry)Therefore, on a wet weight basis applicable to the measured volume of the remaining pile of soil between the Cooling Towers, the weighted average concentration for Cs-137 is:= 82.33 pCi/kg

• Ikg/1000g

• IE-06 uCi/pCi

• 1.12 wet/dryvolume ratio-9.22 F-08 uCi/gm (wet) for Cs-I 37 For Co-60;Average concentration (weighted ave.) = 900 t

• 85 Ci/kg + 3100 fe

• 0,034 DCi/k 900 1 + 3100 fe-19.15 pCi/kg On a wet weight basis applicable to the measured volume of the remaining pile of soil between the Cooling Towers, the weighted average concentration for Co-60 is:-19.5 pCi/kg lkg/1000g

• IE-06 uCipCi

• 1.12 wet/dry volume ratio-2.14 E-08 uCi/gm (wet) for Co-60.F-I MEMORANDUM YANKEE ATOMIC- BOLTON To 0.D. Weyman Date July 15, 1996 Group # REG-1 15/96 From M. S. Strum W.O.#Subject Radioactivity Analyses for Soil Piles Stored Between the Cooling .M.S.#Towers File # vnoilac.doc REFERENqF-S (1) Environmental Laboratory Analysis Reports Sample Numbers G22636 through 022735, soil -Fence and Repaving.

Referaete Dait 4/13/95.BACKGROUN Site area cqstuoA activities have generated m'o piles of soil fotm the proected wa that were plae bewn the plat's cooliag towors pending radilo ical assesuuedt and final diaposal disposition.

One pile w-as estimated at 3100 cubic feet and was initially marked as havig come from sectuity fence exa valien. The second pilcý estimated at about 900 cubic feel was placed direay south offthe first pile and cast ofte 14,000 cubic feet ofcooling tuvr silt also s d bgwe the towerL This mecrid pile vw inicially desioased as comig fian repaviAg activitiss. (Note that these designa iris may hare beeo rversed with the repaving activity gemratiog th 3 100 cubic feet ofmaterial aid the security fetce e=vatioc generating the 900 cubic feewt of materia3.)

As we discussed last week, I'm forwarding copies oft laboratory analyses (Refarece I) for two piles of dut uransty located irmmeditely east of the cooling tower silt pile betwee the plains, cooling towers.The 31l0 cubic foot pile was sampled by colecting 30 composite rab sampies (022696 through G22715) takn at equal distances log its 82 foot length (die pile is about 15.5 feet wide and 4 fet hgh at As peak). Each composite sample im consist of 3 Znrb adiquots taken on the kk top; and eightde of the pile at each reference distance starting hom the pile's north end. The comment field on each analysis report indicates a sample location relative to the north end of t p& As an mcanple, samplo G22691 has a comment of 6-15.0, indicating the 6th sample taken at a distanoe of 13.0 feocaN the north end of the pile.Tables I and 2 sununanze the results of the ganuna isotopic analyses for Cs-137 and Co-60. Now of the 30 cemnposite indicated aiy positive Cesium or Cobalt, or any other plant rated radionuclide.

As a consequcae this pile appears tobe fire from any radioactivity cominamiio The 900 cubic foot pile was sampled in the same manner as above, wt a total of 20 composite samples

("22716 through 022735). Table 3 shows that both Cs-I 37 and Co-60 was detected in all or- lost ofthe grab smples, indicatng that potiv plantslated radioactivity exists in soil, ndthat 10CFRM0.2002 approval for disposal will be needed.F-2 REG-]15/96, July 15, 1996 Page 2 Please call at your conveisce to discuss the next steps =my to handle the 900 cubic foot pile.MatkS. SU=wn Lead Radiologica Enmgie Evi~romnmta Boo-icnng Dqcp-t Atnachments R. Marcello P. M. Marian 1-3 Table 1 Vermont Yankee Soil Analysis E-Lab soil data for 3100 ft3 soil marked as"Fence" line construction material Cs-137 (pCiikq dry)Conc. + -sigma 3 sigma MOC Sam~ple I.D.1-1.4 2-4.1 3-6.8 4-9.6 5-12.3 6-15.0 7.17.8 8.20.5 9-23.2 10-26.0 11-28.7 12-31.4 13-34,2 14-38.9 15-39.6 16-42.4 17-45.1 18-47.8 19-50.6 20-53.3 21-56.0 22-58.8 23-61.5 24-64.2 25-"7.0 26-69.7 27-72.4 28-75.2 29-77.9 30-80.6 9 33 33-9 20 16-41-6-6 17 11-14-12 22-12 15 12 17-33-42 26 26 30 18 28 48 33 48 37 9 63 66 78 69 63 57 78 63 99 69 48 63 63 54 66 54 84 63 60 69 108 81 75 75 78 69 69 69 75 87 70 108 48 78 74 89 91 73 69 110 86 120 80 60 82 83 59 87 64 9s 77 84 94 130 93 86 89 89 73 76 70 84 100 86 130 b9 Average: 11 Max. value: 48 Min. value: -42 F-4 Table 2 Vermont Yankee Soil Analysis E-Lab soil data for 3100 ft3 soil marked as"Fence" line cnstruction material Co-60 IoCi/kg dry)Sample Conc. i -sigma 3 sigma MOC ID.D 1-1.4 10 18 64 70 2-4.1 -12 23 69 100 3-6.8 -11 21 63 97 4-9.6 39 30 90 100 5-12.3 1 21 63 86 6-15.0 32 18 54 57 7.17.8 -S0 25 75 120 8.20.5 16 15 45 56 9-23.2 43 28 84 91 10-26.0 -17 23 69 97 11-28.7 -13 21 63 93 12-31.4 -4 20 60 84 13-34.2 -2. 17 51 76 14-36.9 4 25 75 98 15-39,6 -15 24 72 100 16-42.4 -39 28 84 120 17-45.1 -17 23 6a 100 18-47.8 -14 29 87 130 19-50.6 -9 1i 54 82 20-53.3 37 22 66 72 21-56.0 17 27 81 140 22-58.8 5 30 90 120 23-61.5 7 28 84 110 24-64.2 -10 19 57 90 25-"7.0 27 27 81 98 26-09.7 1 29 87 120 27-72.4 16 21 63 79 28-75.2 6 25 75 98 29-77.9 -8 32 96 130 30-80.6 -27 23 69 110 Average: 0 24 71 97 Max. value: 43 32 96 140 Min. value. -60 15 45 66 F-5 Table 3 Vermont Yankee So"l Analysis E-Lab Analysis of soll from 900 ft3 pile initial marked 'repaving dirt" Sample i.0.1-1.1 2-3.3 3-5.5 4-7.7 6-9.9 6-12.1 7-14.3 a-16.5 9-18.7 10-20.9 11-2.0 12-4.2 13-6.4 14-8.8 15-10.8 18-13 17-18.2 10-17.4 19-19.6 20-21.8 Cs-I 37 (pCI/kg dryO Positive AcT.Conc. +- sigma 3 sigma > 3 sigma Co-60 (pCi/kg dry) Positive Act Con, +-. sigma 3 sigma > 3 sigma 234 522 337 291 348 135 107 222 ISO 209 810 378 810 376 331 253 150 247 326 235 53 57 43 29 51 28 24 44 37 61 a1 38 24 22 33 12 to 56 32 39 f6 12 159 171 129 87 153 78 72 132 111 153 153 114 198 72 6a 99 38 90 165 98 positive positive positive positive positive positive positive positive positive positive poshive positive positive positive positive positive positive postrve positive positive 49 143 37 111 47 73 82 140 92 118 114 106 124 02 87 5 67 105 54 100 38 29 21 17 29 23 15 28 21 31 21 21 27 13 12 22 9 17 40 23 114 87 63 51 87 69 45 84 63 93 83 63 81 39 36 66 27 51 120 69 NO positive NO positive NO positive positive positive positive positive positive positive positive positive positive NO positive positive ND positive Average: 320 Max. value: 810 Min. value: 107 85 143 5 23 40 9 F-6 Appendix G Record for Last Spreadings (2003) on South Disposal Field G-1 Total Recorded Spreading Data for 2003 Serial # Spreading Media Mn-54 Co-60 Zn-65 Cs-134 Cs-137 C*-141 Ce-144 Date Type (uCi/acre) (uCi/acre) (uCi/acre) (uCi/acre) (uCi/acre) (uCi/acre) (uCi/acre) 2003-01 7-1-3 Septic -1.03 .....2003-02 10-25-03 Septic -0.12 -----2003-03 11-4-03 Sand/soil

.... 1.34 --2003-04 11-4-03 CTSilt -0.256 ..-... ..Total -1.41 -- -1.34 ....G-2