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Category:Letter
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September 1, 2004 Mr. Wayne Norton President Connecticut Yankee Atomic Power Company 362 Injun Hollow Road East Hampton, Connecticut 06424-3099
SUBJECT:
HADDAM NECK PLANT - RELEASE OF EAST SITE GROUNDS FROM PART 50 LICENSE
Dear Mr. Norton:
This letter is in response to your letter of April 29, 20041, as supplemented on August 18, 20042, in which you requested approval from the U.S. Nuclear Regulatory Commission (NRC) to release the East Site Grounds (survey area 9532 in the Haddam Neck License Termination Plan (LTP, approved in November 2002)) from the Haddam Neck 10 CFR Part 50 license (DPR-061)). Your letter indicated that Connecticut Yankee Atomic Power Company (CYAPCO) has reviewed and assessed the subject land area in accordance with NRC requirements and Section 1.4.2 of the LTP.
The requirements of 10 CFR 50.83, Release of part of a power reactor facility or site for unrestricted use, are not applicable in cases where there is an approved LTP. In the Statements of Consideration for section 50.83, the Commission stated that [p]artial releases following LTP approval would be governed by the LTP or changes thereto provided that the LTP contained a sufficient change process or describes staged releases of the property prior to license termination.3 Chapter 1 of the LTP describes the process for phased site releases. For unimpacted areas, section 1.4.2 of the LTP and NRCs Safety Evaluation Report4 both require CYAPCO to provide the basis for the unimpacted classification and review and assess the impacts on the following documents in preparation for releasing a portion of the site from the license:
! Updated Final Safety Analysis Report (UFSAR) and Technical Specifications
! Environmental Monitoring Program 1
CY-04-069, ADAMS Accession No. ML041320556 2
CY-04-171 3
69 Fed. Reg. 19711(April 22, 2003).
4 Safety Evaluation related to Amendment 197 to License DPR-61, dated 11/25/2002, ADAMS Accession No. ML022670388
W. Norton
! Offsite Dose Calculations Manual
! Defueled Emergency Plan
! Security Plan
! Post-Shutdown Decommissioning Activities Report
! License Termination Plan
! Ground Water Monitoring Program
! 10 CFR 100 Siting Criteria, and
! Environmental Report For the unimpacted area of the site designated survey unit 9532 in the LTP, the results were provided for NRC staff approval. Your letter provides the basis for the unimpacted determination and provides an assessment of the impacts to each of the documents listed above, and identifies the following changes to implement the phased release:
- 1. Section 2.1.1, 2.1.2 and Figure 2.1.5 of the UFSAR will be modified to describe the reduced site area and boundary lines resulting from release of survey area 9532 from license DPR-61.
- 2. The Off-Site Dose Calculation Model will be revised consistent with the site boundary change.
- 3. The LTP will be revised to describe the reduced site area.
- 4. The exclusion area for Haddam Neck Plant (HNP) extends into survey area 9532.
However, CYAPCO commits to maintain authority, in accordance with 10 CFR 100.3, over all activities conducted within 1740 feet of the Reactor Containment.
NRC Findings:
NRC inspectors and survey contractors performed an independent survey of survey area 9532, which included six soil samples and surface scans of over 1% of the survey unit. Samples were tested for cobalt-60, cesium-137, and other gamma-emitting and hard-to-detect radionuclides associated with the Haddam Neck Plant. A Final Report5, issued in July 2004, found nothing to indicate the unimpacted area was improperly classified.
By this letter, NRC approves releasing survey area 9532 from the license, as specified in your April request and subject to the following comments:
- 1. The CYAPCO exclusion area assurance procedure will be subject to inspection during site decommissioning by NRC Region 1.
- 2. Following removal from the license, in the unlikely event survey area 9532 were to become radiologically contaminated as a result of later decommissioning activities at the Haddam Neck Plant, the contamination would be considered an off-site release, and subject to 10 CFR Part 20.
5 ORISE Revised Final Report, Confirmatory Survey of the Open Land Area Survey Units at the Connecticut Yankee Haddam Neck Plan, July 2004, ADAMS Accession No.
ML042170277.
W. Norton
- 3. NRC staff suggests that for future phased release submittals, the licensee consider the use of Appendix L Worksheet in NUREG-1757, Volume 26, to assist in the evaluation process.
If you have any questions, you may contact me at (301) 415-6721.
Sincerely,
/RA/
Theodore Smith, Project Manager Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-213 License No.: DPR-61 DISTRIBUTION: See next page PUBLIC 6
NUREG-1757, Vol. 2, Consolidated NMSS Decommissioning Guidance:
Characterization, Survey and Determination of Radiological Criteria, http://www.nrc.gov/materials/decommissioning/ml003682132.pdf.
Connecticut Yankee Atomic Power Company Mr. Allan Johanson, Assistant Director Mr. T. W. Bennet, Jr.
Office of Policy and Management Vice President and Chief Financial Officer Policy Development and Planning Division Connecticut Yankee Atomic Power Company 450 Capitol Avenue- MS# 52 ERN 19 Midstate Drive P.O. Box Bo 341441 Auburn, MA 01501 Hartford, CT 06134-1441 Dr. E. L. Wilds, Jr. Director Regional Administrator, Region I Monitoring and Radiation Division U.S. Nuclear Regulatory Commission Connecticut Department of Environmental 475 Allendale Road Protection King of Prussia, PA 19406 79 Elm Street Hartford, CT 06106-5127 Board of Selectmen Town Office Building Ms. Rosemary Bassilakis Haddam, CT 06438 Citizens Awareness Network 54 Old Turnpike Road Mr. Wayne Norton Haddam, CT 06438 President and Chief Executive Officer Connecticut Yankee Atomic Power Company Mr. Terry Schwennesen 362 Injun Hollow Road Vice President and Director of East Hampton, Ct 06424-3099 Generation Investments New England Power Company Mr. R. Gad, III c/o National Grid CYAPCO Counsel 25 Research Drive Ropes & Gray Westborough, MA 01582 One International Place Boston, MA 02110-2624 Mr. Gerry P. van Noordennen Regulatory Affairs Manager Mr. K. J. Heider Northeast Utilities service Company Vice President - Operations and 362 Injun Hollow Road Decommissioning East Hampton, CT 06424-3099 Connecticut Yankee Atomic Power Company 362 Injun Hollow Road Mr. Randall L. Speck East Hampton, CT 06424-3099 Kaye, Scholer, Fierman, Hayes & Handler, LLP The McPherson Building Ms. Deborah B. Katz, President 901 Fifteenth Street, NW Suite 1100 Citizens Awareness Network Washington, DC 20005-2327 P.O. Box 83 Shelburne Falls, MA 01370-0083 Mr. Bruce D. Kenyon Chief Executive Officer Mr. R. M. Mitchell Connecticut Yankee Atomic Power Company Unit Manager 362 Injun Hollow Road Connecticut Yankee Atomic Power Company East Hampton, CT 06424-3099 362 Injun Hollow Road East Hampton, CT 06424-3099
W. Norton
- 3. NRC staff suggests that for future phased release submittals, the licensee consider the use of Appendix L Worksheet in NUREG-1757, Volume 27, to assist in the evaluation process.
If you have any questions, you may contact me at (301) 415-6721.
Sincerely,
/RA/
Theodore Smith, Project Manager Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-213 License No.: DPR-61 DISTRIBUTION: See next page PUBLIC ADAMS Accession Numbers: ML042510091 Incoming: ML041320556 Response: C:\MyFiles\Copies\revised HNP unimpacted release.wpd
- See previous concurrence OFFICE DWMEP/DD DWMEP/DD DWMEP/DD OGC DWMEP/DD NAME TSmith* DSchmidt* CCraig* STreby* DGillen DATE 8/18/2004 8/20/2004 8/24/2004 8/31/2004 9/01/2004 OFFICIAL RECORD COPY 7
NUREG-1757, Vol. 2, Consolidated NMSS Decommissioning Guidance:
Characterization, Survey and Determination of Radiological Criteria, http://www.nrc.gov/materials/decommissioning/ml003682132.pdf.