ML20006E583
| ML20006E583 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 02/16/1990 |
| From: | Boyle R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Weiss S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9002260057 | |
| Download: ML20006E583 (4) | |
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.o LP/FSV FEB 16190 MEMORANDUM FOR: Seymour H. Weiss, Director Non. Power Reactor Decomissioning and Environmental Directorate, NRR 3
FROM:
Regis R. Boyle, Acting Chief Regulatory Branch Division of Low. Level Waste Management and Decomissioning, NMSS
SUBJECT:
REVIEW 0F FORT ST. YRAIN PRELIMINARY DECOMMISSIONING PLAN l
As agreed to in our August 3,1989, memorandum, and in agreement with the March 21, 1989 memorandum regarding the transfer of regulatory authority for reactor decommissioning, we are providing comments on Public Service Company of Colorado's response to NRC's October 4, 1989 questions on the Fort St. Vrain Preliminary Decommissioning Plan. Our attached coments address each
. response provided by Public Service Company of Colorado, t
'If you or your staff have any questions, please contact me at X-20560 l
or Larry Pittiglio at X-23438.
l Original sigacq $,
Regis R. Boyle, Acting Chief Regulatory Branch Division of Low. Level Waste Management and Decomissioning, HMSS
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Enclosure:
As stated i
Distribution: Docket 9050002673 NMSS r/f LLRB r/f LPittiglio l
TJohnson JGreeves RBangart JSurmeier PLohaus RBoyle PErickson, NRR PDR YES N
NO Category: Proprietary or CF Only ACNW YES T
NO SUBJECT ABSTRACT:
REVIEW 0F FORT ST. VRAIN RESPONSE TO NRC QUESTIONS ON PRELIMINARY DECOMMISSIONING PLAN A
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0FFICIAL RECORD COPY 9002260057 900216 PDR ADOCK 05000267 p
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COMMENTS ON PUBLIC SERVICE OF COLORAD0'S RESPONSE TO NRC'S QUESTIONS ON FORT ST. VRAIN PRELIMINARY DEC0lHISSIONING PLAN 1.
PSC Response to NRC Ouestion 1: " References" The Fort St. Vrain (FSV) facility is a unique facility and to assure sufficient funds will be available for decontamination and decommissioning as required by 10 CFR 50.75(f), the NRC needs a more detailed basis for the costs than PSC provided in their Attachment 3:
"FSV Site Specific Decommissioning Cost Estimate for Preliminary Decommissioning Plan." The decontamination and decommissioning of this facility is a unique project, and to evaluate the project, a detailed cost study providing all component costs for each activity as well as the rationale for the effort to couplete each activity is required. Additional discussion on what NRC requires to evaluate the costs of decommissioning is provided under Question 16.
2.
PSC Response to NRC Question 2: " Building and Structures" PSC's response is adequate.
3.
PSC Response to NRC Question 3:
" Major, Technical Actions" PSC's response to this question is adequate.
4 PSC Response to NRC Question 4: " Component Removal Period" PSC's response is adequate. However, the area will need to be addressed in the Proposed Deconunissioning Plan.
5.
PSC Response to NRC Question 5:. "Plateout Analysis" l
The plateout analysis provided by PSC adequately addressed NRC's concern.
6.
PSC Response to NRC Question 6: " Analysis Results" l
PSC's response is adequate.
L 7.
PSC Response to NRC Question 7:
" Activation Analysis" PSC's response is adequate.
8.
PSC Response to NRC Question 8: Reactor Components" PSC has provided the requested information. PSC's response to the question is adequate.
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9.
PSC Response to NRC Question 9:
"Safestor Issues" of PSC's response adequately addressed NRC's question.
- 10. PSC Response to NRC Question 10:
"Decon_tamination and Dismantlement Plans" The response provided by PSC is adequate for the Preliminary Decomissioning Plan; however, a more accurate nuclide analyses to characterize the components will be required before actual disposal of the material.
- 11. PSC Response to NRC Question 11:
" Decontamination and Dismantlement Plans" The response provided by PSC is adequate.
- 12. PSC Response to NRC Question 12:
" Decontamination and Dismantlement Plans" PSC's response is adequate.
- 13. PSC Response to NRC Question 13:
" Remove Loose Contamination from PCRV Internal surfaces-PSC's response is adequate.
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- 14. PSC Response to NRC Question 14:
PSC's response is adequate.
- 15. PSC Response to NRC Question 15:
"Decommissionin_q Cost Estimate" of the PSC response did address the major cost elements for i
decomissioning,
- 16. PSC Response to NRC Question 16:
" Decommissioning Cost Estimate" The cost estimate was based on the assumption that FSV would complete-defueling by October 1992. Once it is confirmed that defueling will not be completed by the original estimated date, the cost estimate should be revised to reflect this impact. Also PSC states that their contingency cost ranges from 20% to 140% for PCRV dismantlement. What is the btiis for this large range?
h PSC provided cost estimates for each major decomissioning activitiy.
However, labor and O&M costs are simply stated without detail and discussion.
Please provide the basis for these costs and a rationale for how they were determined.
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The cost estimate also needs to include the disposal cost for each activity.
The disposal costs should be computed based on waste volume and classification, and include surcharge, packaging and shipping costs.
Finally, for each separate activity all indirect costs associated with the activity need to be included.
The indirect costs would include costs for i
insurance. licensing costs, office equipment costs, cost of office space, i
contractor's profit, and other miscellaneous costs required to support the-
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activity.
If a summary sheet is provided which sumarizes all these costs components, sufficient references should be provided to support how these costs were developed.
17.
PSC Response to NRC Ouestion 17:
j PSC's responses did not include a contingency plan for waste storage if disposal capacity is not available.
PSC needs to provide a discussion i
of the storage facility that might be used and the estimated costs for it.
18.
PSC Response to NRC Question 18:
" Residual Radioactivity Criteria" i
PSC states they will use 5 uR/HR as the limit for residual
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contamination.
Please note that current residual contamination criteria are the limits in Regulatory Guide 1.86 and 5 uR/HR. We acknowledge that PSC committed to using updated limits wh E ava11able.
- 13. PSC Response to NRC Question 19: " Method to Establish a Residual Release L1m1t" PSC's response is adequate.
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