ML24053A259
| ML24053A259 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/01/2024 |
| From: | Reactor Decommissioning Branch |
| To: | |
| Shared Package | |
| ML24053A165 | List: |
| References | |
| Download: ML24053A259 (3) | |
Text
Vermont Yankee License Termination Plan Acceptance Review Observations 1
Information Provided Observation 4 includes a large-scale topographic map of the surrounding region.
The LTP did not contain a topographic map of the site. Enclosure 14 did have a large-scale topographical map for the region, but the map did not illustrate elevation contours and features of the site.
LTP Chapter 2 provided some elevation data for floors in the Turbine, Reactor, and Radwaste buildings.
The LTP did not contain basement slab elevations for buildings and subsurface structures.
Several figures of the site and survey units are provided in Chapters 1 and 2.
Several figures in Chapter 2 of survey units did not contain a scale, some did not contain a north arrow, or inset illustrating direction, and at least one figure had a misaligned north arrow (Figure 2-35). Figure 1-2, which was rotated, did not contain a north arrow or a scale.
LTP Section 5.4.4.7 indicated that wells in the groundwater monitoring program would be used to demonstrate existing groundwater contamination will be below the derived concentrations of U.S>
Environmental Protection Agencys maximum contaminant level drinking water criteria (40 CFR 141). LTP Table 2-9 provided groundwater sample results from the 2020-2022 period.
The LTP did not provide (i) reconciliation of the site-specific radionuclide list in LTP Table 6-1 with the radionuclides measured in the groundwater monitoring program listed in LTP Table 2-9 (in particular, the highly mobile radionuclides C-14 and Tc-99), or a basis for excluding some radionuclides in LTP Table 6-1 from consideration for groundwater, (ii) a plan for evaluating the trend of groundwater results and selection of input values for the FSS that considers perturbations from demolition activities that potentially may lead to releases reaching the groundwater system, (iii) justification for the well data being representative of maximum concentrations at the site, and (vi) sufficient information for staff to determine if the reporting of laboratory results is consistent with NUREG-1576 Chapter 20, or justification for an alternative reporting approach.
Figure 2.49, ERA Sample Locations and Figure 2.50, WRA Soil Sample Locations provide what appears to be sample locations for the ERA Open Land Area and the WRA Open Land Area, respectively.
A readable map of sampling locations for survey areas ERA and WRA with appropriate legends and markings is not included.
A matrix of samples concrete samples collected in the Turbine Building by Area, Wall, and Floor is provided in Table 2-6 Turbine Building Sample Locations. Is provided.
A map of the sampling locations for each room or area in the turbine building where concrete samples was collected is not provided.
Section 5.1.3.2 discusses survey preparation, mentions four types of surveys:
remediation, turnover, an equivalent evaluation, and FSS.
A description of equivalent evaluations and their application is not included.
Table 5-1 DCGLs by Radionuclide and Medium Type" is mislabeled to infer only soil DCGLs but includes structural DCGLs.
In Table 5-1 DCGL contents do not reflect what is presented in the table.
Table 5-4, "Investigation Levels" includes the investigation levels by survey unit class.
The LTP does not include a discussion on how the 3 statistical parameter-based value for the Class 1 Direct IL. The Class 3 Scan IL does not describe how the "detectable above background" value will be determined.
Section 5.4.5.4.8, Pipe Survey Instrumentation, provides a general overview of the piping survey instruments and the survey coverage for Class 1 piping.
The LTP does not describe the calibration process for embedded/buried piping instrumentation or a detailed discussion of the radiological survey process for embedded/buried piping interiors.
Vermont Yankee License Termination Plan Acceptance Review Observations 2
Information Provided Observation LTP Chapter 6 indicates that the areal extent of the contaminated area was set equal to the plants protected area. LTP Figure 2.12 indicates potentially contaminated areas outside of the protected area.
The LTP does not appear to address the difference between the modeled and actual contaminated areas. The sensitivity analysis for soil DCGL values does not vary the area of the contaminated zone.
Section 5.2.1.3, "Post-remediation Surveying," discusses the use of ISOCS in place of scanning if MDCs allow for detection below the DCGL. ISOCS is also proposed for determining the presence of subsurface contamination triggering investigation in Section 5.4.3.2, "Volumetric Sampling."
Information on ISOCS including a description of the instruments, calibration, operational checks, sensitivity, and sampling methods with a demonstration that the instruments and methods have adequate sensitivity is not included.
LTP Section 5.3.4 mentions the possible use of background subtraction when implementing the sign test.
The LTP does not include a discussion of how background subtraction values will be determined (e.g. material or instrument background).
Section 5.8, "Final Status Survey Program Quality (QAPP)" provides an overview of the quality assurance program.
The LTP contains limited details contains limited details of key components of FSS quality assurance program, including QC replicate surveys, field blanks and spiked samples, split samples, third-party analysis and sample recounts.
The historical site assessment notes identifying a discrete particle from washout of the Turbine Building HVAC exhaust.
Staff recently issued Information Notice 2024-01, Minimization and Control of Contamination involving Discrete radioactive Particles at decommissioning facilities, which may be beneficial for future revisions of the application.
LTP section 8.5.2.12 briefly discusses cultural and historic resources and describes the procedures in place to protect cultural resources that may be discovered during decommissioning activities.
The LTP does not provide site-specific information about historic and cultural resources or discussion about any communications with the State Historic Preservation Office or tribes. The LTP does not include reference to any cultural resources surveys or investigations that may have been done at the site. The LTP also does not mention whether any evaluation has been undertaken to determine if the plant itself is eligible for listing on the National Register of Historic Places. Finally, the LTP mentions but does not provide a reference or link to the environmental review procedures discussed in section 8.5.2.12.
LTP section 8.5.2.7 discusses the threatened and endangered (T&E) species that were identified in the 2007 Supplemental EIS for VY power station.
The LTP describes the T&E species identified in 2007 but does not describe any T&E species listed or proposed since 2007 that could be present at the site.
LTP section 8 contains descriptive information about the site and enclosure 14 provides an area map showing the site location.
Section 8 of the LTP does not include a figure of the site identifying current structures or features, natural features, and regulatory or any other site boundaries applicable to decommissioning activities.