ML20035B157

Provides All Info Re Licensee Component Removal Activities, Per NRC 921208 Meeting

ML20035B157
Person / Time
Site:	Yankee Rowe
Issue date:	01/12/1992
From:	Thayer J YANKEE ATOMIC ELECTRIC CO.
To:	Fairtile M Office of Nuclear Reactor Regulation
Shared Package
ML20035B156	List: ML20035B155 ML20035B157
References
BYR-93-001, BYR-93-1, NUDOCS 9303310254
Download: ML20035B157 (16)

Text

L SD WS YANKEE ATOMICELECTRIC COMPANY

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$N 580 Main Street, Bolton, Massachusetts 01740-1398 AN KEE January 12,1992 BYR 93-001 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention:

Mr. Morton Fairtile Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support

Reference:

(a) License No. DPR-3 (Docket No. 50-29)

Subject:

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION-COMPONENT REMOVAL ACTIVITIES

Dear Mr. Fairtile:

On December 8,1992, in a publicly noticed meeting, Yankee Atomic Electric Company (YAEC) representatives met with the NRC staff in Rockville, Maryland to present and discuss YAEC's plans for equipment removal activities at the Yankee Nuclear Power Station (YNPS) prior to formal approval of the YNPS decommissioning plan. YAEC described its plan for removal of the steam generators, reactor vessel internals and the pressurizer, which are similar to components that have previously been removed from operating reactors. YAEC is considering removal of these components due to the availability of a waste disposal site at a predictable cost for disposal. If YAEC decides to proceed, the savings to consumers can be substantial, while at the same time permanently disposing of 90% of the nonfuel residual activity existing at the site.

At the conclusion of the meeting, Mr. J. Partlow requested that YAEC provide additional information on several of the topics presented during the meeting, including the following-1.

A list of the equipment that YAEC is considering for removal between now and June 30,1994, along with the schedule for completing these activities.

2.

A statement with supporting basis that the proposed activities will not preclude release of the facility for unrestricted use.

3.

A statement with supporting basis that the environmental impacts of the proposed activities are consistent with the conclusions presented in NUREG-0586,* Final 9303310254 9'30329 PDR ADOCK OMOOO29 p

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Then personally appeared before me, J. K. Thayer, who, being duly sworn, did state that he is a Vice President and Manager of Operations of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing document in the name and on behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.

Kathryn Gates Notary Public My Commission Expires January 24, 1997 1

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ne higher DECON occupational exposure has marginal significance to health e

and safety.

The 11W burial volume is typically less for SAFSTOR than DECON due to the s

decay of radioactivity from the time the plant shuts down until final dismantlement begins (burial volume reduction is recognized in the GEIS after a 50 year SAFSTOR pe-iod). This benefit is not uniquely compelling when selecting a decommissioning alternative.

In 1988, NRC amended the YNPS facility operating license to permit operation for a full 40 years from the date of issuance of the operating license (Reference 2). In the proposed change documentation (Reference 3), YAEC provided the NRC staff with an Environmental Report (ER) which addressed all important aspects of the environmental impact from operation of YNPS, including plant modifications. In granting the license extension, NRC concluded in its environmental assessment, that the plant had operated for more than 27 years with no significant radiological or non-radiological impacts, and l

that the proposed extension would not have any significant impact on the environment.

i De NRC environmental assessment included an evaluation of the following considerations:

e RadiologicalImpacts of the Hypothetical Design Basis Accident e Radiological Impacts - Annual Releases e Environmental Impact of the Uranium Fuel Cycle e Non-RadiologicalImpacts e Plant Modifications These licensing basis considerations are evaluated in the YAEC design change process which will be implemented for the component removal activities currently under evaluation by YAEC. It is fully expected that the environmental impact of the i

component removal activities will be bounded by the conclusions in the GEIS for the following reasons:

1)

The GEIS conclusions are based in part, on the assumption that programs and procedures designed to minimize emironmental impact during plant operation are fully effective during decommissioning. YAEC will ensure that these programs are maintained during all phases of decommiuioning.

a)

Occupational exposure at YNPS is controlled through existing programs and piocedures. The design change process ensures that ALARA considerations are integrated into the final design and implementation plan from the outset. The Radiation Protection and ALARA programs used during plant operation will continue through all phases of decommissioning.

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5. YNPS ALARA Program The YNPS ALARA Program, as de6ned in plant administrative and implementing procedures, will be maintained and applied to all phases of decommissioning. Re Corporate Environmental Engineering Department provides input and critical review of all design changes for AIARA and Environmental issues. The following existing plant and corporate procedures will continue to be used:

e OP-8020: Implementation and Documentation of AIARA Reviews e YA-EED-400: Review of Engineering Design Change Requests and Plant Design Change Requests

6. YNPS Defueled Organization The plant organiz.ation for the permanently defueled condition is shown on the enclosed organization chart. As indicated in previous discussions with the hTC Staff, plant positions have been filled with senior level individuals. This is reflected in the enclosed table which identifies the individual average years of service on a departmental basis. It should be noted that the plant staff will be augmented, as necessary, by personnel from

- the corporate office or contractor personnel, to ensure adequate staff is available to safely complete all planned component removal activities.

i

7. Method For Fundine the Proposed Activities The following information was presented by Mr. H. T. Tracy, YAEC Vice President, Trcaurer and Chief Financial Officer, at the December 8,1992 meeting.

YAEC intends to access the YNPS decommissioning fund to pay for legitimate decommissioning activities. This is consistent with fund access requirements as specified in the YNPS Decommissioning Fund Trust Document which was previously prosided to NRC for review (Reference 4).

The fund will not be reduced below an amount estimated to place the plant in a safe condition at any time during plant modifications. In fact, as shown on the enclosed fund balance chart, the fund will continue to grow throughout the equipment removal period in 1993 and 1994.

f YAEC is presendy in the process of collecting all of the funds needed to complete decommissioning of YNPS with a projected external fund value of $713 million at the end of 1992. Furthermore, as indicated in Reference 5, YAEC has in place the l

assurance necessary to guarantee that all costs of decommissioning are paid, whether or not funds are accessed prior to approval of a decommissioning plan. In particular, YAEC has FERC approved power contracts which assure collection of all funds needed prior to final dismantlement.

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e ne activity materially or demonstrably affects the options available for decommiuioning the facility or may affect the ability to release the site for unrestricted use.

Decommissionine Option Foreclosure The NRC has concluded in its GEIS on decommissioning that both DECON and SAFSTOR are reasonable alternatives for decommissioning commerciallight water reactor facilities. Although there are advantages and disadvantages to either option, none is compelling enough to cause either option to be preferred from an environmental impact perspective.

De choice of a particular decommissioning alternative is generally driven by influences such as the availability of funds to complete decommissioning, the availability of a low level waste disposal facility for decommissioning wastes, or safety issues associated with decommissioning of a unit at a multi-unit site. The multi-unit site issue is clearly not applicable to YNPS and will not be discussed further. De impact of the remaining two considerations, on public health and safety, is discussed below.

The availability of sufficient funds could adversely affect a licensee's ability to safely decommission the facility. It may be necessary to SAFSTOR the facility until adequate funds are available to ensure completion of the process. YAEC will continue to ensure that adequate funds are available to safely complete all plant closure and decommissioning activities.

Although sufficient funds may be available to complete decommissioning, a low level waste site may not be available for disposal of decommissioning waste. This is the i

primary reason for YAEC's decision to SAFSTOR YNPS until the year 2000. Until recently, access to all of the existing LLW burial facilities was closed to out-of-compact l

generators, such as YNPS, beyond January 1,1993. De state of South Carolina has i

recently indicated that the Barnwell facility will remain open to Massachusetts generators

)

through June 30,1994. This decision allowed YAEC to consider equipment removal and 4

disposal activities designed to take full advantage of the burial site availability.

In discussing component removal activities with the NRC, the Staff questioned whether i

an activity such as removal of steam generators would preclude the SAFSTOR option because the component is no longer stored within the confines of the containment building. If such an activity were to be viewed in such a literal sense, then removal of option. Herefore, gardless of its characteristics) would indeed preclude th any component (re no component removal activitics could be conducted prior to approval of the decommissioning plan. The Commission did not intend for such a narrow l

interpretation of its guidance. On the contrary, the Commission specifically allowed for decontamination and dismantlement activities prior to approval of the decommiuioning l

plan (Reference 6). Finally, as a practical matter component removals are safely i

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References

)

1. NUREG-0586 Final Generic Environmental Impact Statement

-2.-YNPS License Amendment No.108, NYR 88-119, dated '/2/92.

3. YNPS Proposed Change No. 207, FYR 87-095, dated 9/15/87

4. Decommissioning Funding Assurance Report and Certificatioh BYR 90-102, dated 7/25/90

5. Letter to NRC on YNPS Component Removal Activities;-BYR 92-109, dated 11/25/92.

-?

i

- 4

6. NRC letter to YAEC transmitting License Amendment No.142 (POL), dated 8/5/92 4

7. NRC letter to YAEC, " Meeting Summary-Discussion of prop ~osed site work Under 10 i

CFR 50.59 Prior to NRC Approval of Decommissioning Plant dated 12/23/92 i

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(#5 xEARL Y NSSS COMPONENT REMOVALM

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g 2 e c t r' i c ACTIVITY 01 01 01 01 01 01 01 01 OCT JAN APR JUL OCT JAN APH JUL 92 93 93 93 93 94 94 94 9 Time 'io w 1111 1111111111111111i1 111111111111111111l PROJECT PLANNING 111111111111!!!I11 NRC S/G SAR REVIE W 111111111111111111 TOOL PHOCUREMENT ASBEE TOS ABATEF ENT S/G RE ADVAL G PZ 1 REMOVAL 111111111111111111. 11111111111111111l l11111111111J S/G 184 + PZR SHIPPING 11 111111111111111111 Il S/G 28 3 SHIPPING 1111111111111 8

ALL S/ G OUT OF \\ C 8

VC C _EAN-UP C0 4PLETED 1111111111111111 111111111111111111 111111111111111111 ! INTERNALU SHIPMENTS TO BARNWf LL 1111111111111111111111!!111111 !!1111111111111111 1 VC CLEAN-UP CLlMPLETED 8 MA NAGEMEtlT COMMITME NT DATES A

FINAL TRANSPORT PL AN 8

S/G S 11PPING 00 :UMENTS 8

TOOL PROCUREMENT BARNHELL CLOSING A

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YNPS STAFF EXPERIENCE DATA f

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Department Average IndMdual Years Administration 18.4 Maintenance 18 3 l

1 Operations 13.5-t Radiation Protection 13.2 Chemistry 18.4 Technical Services 17.6 Quality Assurance 6.0 j

Notes-i

1. This table is based on YNPS organization as of Januazy 1,1993.

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.YA]NEE January 12,1992 BYR 93-001

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United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 I

Attention:

Mr. Morton Fairtile Senior Prcject Manager I

Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support l

Reference:

(a) License No. DPR-3 (Docket No. 50-29)

Subject:

RESPONSE TO NRC REQUEST FOR ADDITIONAL IhTORMATION-COMPONENT REMOVAL ACTIVITIES

Dear Mr. Fairtile:

/

On December S,1992, in a publicly noticed meeting, Yankee Atomic Electric Company (YAEC) representatives met with the NRC staff in Rockville, Maryland to present and discuss YAEC's plans for equipment removal activities at the Yankee Nuclear Power Station (YNPS) prior to formal approval of the YNPS decommissioning plan. YAEC described its plan for rernoval of the steam generators, reactor vessel internals and the pressurizer, which are similar to components that have previously been removed from operating reactors. YAEC is considering removal of these components due to the availability of a waste disposal site at a predictable cost for disposal. If YAEC decides to proceed, the savings to consumers can be substantial, while at the same time permanently disposing of 90% of the n'onfuel residual activity existing at the site.

At the conclusion of the meeting, Mr. J. Partlow requested that YAEC provide additional information on several of the topics presented during the meeting, including the following:

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A list of the equipment that YAEC is considering for removal between now and l

June 30,1994, along with the schedule for completing these activities.

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2.

A statement with supporting basis that the proposed activities will not preclude release of the facility for unrestricted use.

3.

A statement with supporting basis that the environmental impacts of the proposed

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activities are consistent with the conclusions presented in NUREG-0586,' Final b

9303310254 930329 t

PDR ADOCK 0500o029 p

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U. S. Nuc';ar Regulatory Commiuion

("l Page 2 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities".

4.

A description of the Engineering Design Change process that YAEC uses to design and implement plant modifications.

5.

A description of the YNPS ALARA Program.

6.

A summary of the penneerr.ly defueled facility organization and associated personnel qualifications.

7.

A description of the method for funding the proposed activities.

8.

A description of YAECs plans for informing the public about equipment removal and other decommissioning plans for the facility.

9.

A discussion of the removal activities currently under consideration relative to foreclosure of available decommissioning options.

10.

A description of the YAEC Quality Assurance Program The Staffs request for additional information was reiterated in the NRCs Meeting Summary transmitted by letter to YAEC dated December 23,1992.

We have addressed each of the above items in Attachment 1. We trust this information will be useful in understanding the various aspects of YAECs plans as described at the December 8,1992 meeting.

If you have any questions or require additional information, please contact us.

Very truly yours, n

K. Thayer Vice President and Manager of Operations Encl.

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Then personally appeared before me, J. K. Thayer, who, being duly sworn, did state that he is a Vice President and Manager of 1

Operations of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing' document in the name

.(

and on behalf of Yankee Atomic Electric Company and that the statements therein are true to ' the best of his knowledge and i

belief, s

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JA Kathryn Gates Notary Public l

My Commission Expires January 24, 1997-i 1

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Attachment i

1. Scope of Removal ActMties under Consideration YAEC is currently evaluating removal of the following components:

e Steam Generators (4) e Reactor Vessel Internals e Pressurizer The preliminary schedule for completing these activities is enclosed with this attachment.

Note that YAEC currently plans to conduct the necessary analyses supporting certification of the steam generators and pressurizer as their own shipping containers under the provisions of 10 CFR 71.12. Timely review and approval by the hPC staff of the shipping contairer configuration is essential for successful project completion.

2. Release of the Facility for Unrestricted Use By definition, decommissioning means to safely remove the facility from service and to remove radioactivity to residual levels permitting release of the facility for unrestricted use. All of the removal activities being considered must be completed in order to release the facility for unrestricted use regardless of the decommissioning alternative chosen. None of the proposed activities will preclude the facility from being released.

3. Environmental impact of the Proposed Removal ActMties The NRC requested that YAEC evaluate the environmentalimpact of the proposed activities relative to the conclusions in the NRC Final Generic Environmental Impact Statement (GEIS), (NUREG-0586, Reference 1). The important GEIS conclusions, as they relate to component removal activities being considered by YAEC, are discussed below.

In the GEIS, the NRC concluded the following:

e The environmental impact of decommissioning nuclear facilities is similar to or less than those during construction and operation.

e Both DECON and SAFSTOR are reasonable alternatives for decommiuioning light water power reactors.

e The occupational exposure for DECON is higher than for SAFSTOR, but similar to routine operation.

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'Ibe higher DECON occupational exposure has marginal significance to health e

and safety.

The 1.LW burial volume is typically less for SAFSTOR than DECON due to the e

decay of radioactivity from the time the plant shuts down until final dismantlement begins (burial volume reduction is recognized in the GEIS after a p

50 year SAFSTOR period). This benefit is not uniquely compelling when selecting a decommissioning alternative.

In 1988, NRC amended the YNPS facility operating license to permit operation for a full 40 years from the date of issuance of the operating license (Reference 2). In the proposed change documentation (Reference 3), YAEC provided the NRC staff with an i

Environmental Report (ER) which addressed all important aspects of the emironmental impact from operation of YNPS, including plant modifications. In granting the license extension, NRC concluded in its environmental assessment, that the plant had operated for more than 27 years with no significant radiological or non radiological impacts, and that the proposed extension would not have any significant impact on the environment.

The NRC environmental assessment included an evaluation of the following considerations:

e RadiologicalImpacts of the Hypothetical Design Basis Accident e Radiological Impacts - Annual Releases e Environmental Impact of the Uranium Fuel Cycle e Non-RadiologicalImpacts e Plant Modifications These licensing basis considerations are evaluated in the YAEC design change process which will be implemented for the component removal activities currently under evaluation by YAEC. It is fully expected that the environmental impact of the component removal activities will be bounded by the conclusions in the GEIS for the following reasons:

1)

The GEIS conclusions are based in part, on the assumption that programs and procedures designed to minimize environmental impact during plant operation are fully effective during decommissioning. YAEC will ensure that these programs are maintained during all phases of decommissioning.

a)

Occupational exposure at YNPS is controlled through existing programs and piocedures. The design change process ensures that ALARA considerations are integrated into the final design and implementation plan from the outset. The Radiation Protection and ALARA programs used during plant operation will continue through all phases of decommissioning.

Page 2

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b)

. The YNFS Environmental Monitoring Program will continue to be implemented through all phases of decommissioning. Plant ef0uent -

discharges will continue to be controlled and monitored under existing programs and procedures.

c)

Both liquid and solid radwaste processing, handling, packaging and transportation will continue to be controlled by existing programs and procedures.

2)

The potential environmental impacts of postulated accidents are thoroughly evaluated and documented during the design change velopment process. The t

safety evaluation, conducted in accordance with 10

_50.59, and in conjunction with the design change development will ensure that the proposed activities requiring NRC approval prior to implementation are properly identified and ~

documented.

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... fan 3)

The activities under consideration have been completed upder 10 CFR 50.59 by operating facilities using a process similar to the YAECdisign change process.

.th All of the programs and procedures discussed in this se'c' tion hav~e been the subject of t

numerous NRC inspections and audits, and have been demonstrated to be adequate.

These programs and procedures will be maintained, reviewed periodically, and updated throughout all phases of the decommissioning process as required by the Plant Technical i

Specifications and/or Plant Administrative Procedures.

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Based on the above discussion,it is expected that the environmentalimpacts of the component removal activities, currently under consideration by YAEC, will be consistent with and bounded by the conclusions in the GEIS. YAEC will document the environmental evaluation, including all necessary analyses,.to demonstrate compliance with the GEIS conclusions, in the Engineering Design Change Documentation Package for the plant modification activities.

4. Description of the Yankee Engineerine Design Chanee Process, As indicated in our discussions with the staff on December 8,'1992, YAEC will continue to utilize the same engineering design change process employed during plant operation, and currently employed by YAEC in its services to operating nuclear plants in New England. ' Ibis process has been the subject of numerous NRC and industry inspections 4

and audits. The NRC Regional Office has access to all plant engineering, design and operation procedures, records and documentation.

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5. YSTS ALARA Program The YNPS ALARA Program, as defined in plant administrative and implementing procedures, will be maintained and applied to all phases of decomminioning. The.

Corporate Environmental Engineering Department provides input and critical review of --

all design changes for ALARA and Environmental issues. The following existing plant i

and corporate procedures will continue to be used:

e OP-8020: Implementation and Documentation of AIARA Reviews e YA-EED-400: Review of Engineering Design Change Requests and Plant Design j

Change Requests

6. YNPS Defueled Organization The plant organization for the permanently defueled condition is shown on the enclosed I

organization chart. _ As indicated in previous discussions with the NRC Staff, plant j

positions have been filled with senior level individuals.- This is reflected in the enclosed

-l table which identifies the individual average years of service on a departmental basis. It should be noted that the plant staff will be augmented, as necessary, by personnel from the corporate office or contractor personnel, to ensure adequate staff is available to safely complete all planned component removal activities.

i

7. Method For Funding the Proposed Activities 1

The following information was presented by Mr. H. T. Tracy, YAEC Vice President, I

Treasurer and Chief Financial Officer, at the December 8,1992 meeting.

YAEC intends to access the YNPS decommissioning fund to pay for legitimate l

decommissioning activities. This is consistent with fund access requirements as speci5ed.

in the YNPS Decommissioning Fund Trust Document which was previously provided to NRC for review (Reference 4).

j l

The fund will not be reduced below an amount estimated to place the plant in a safe l

condition at any time during plant modifications. In fact, as shown on the enclosed fund balance chart, the fund will continue to grow throughout the equipment removal period l

in 1993 and 1994.

YAEC is presently in the process of collecting all of the funds needed to complete

)

decommissioning of YNPS with a projected external fund value of $71.3 million at the-i end of 1992. Furthermore, as indicated in Reference 5, YAEC has in place the assurance necessary to guarantee that all costs of decommiuioning are paid, whether or not funds are accessed prior to approval of a decommissioning plan. In particular, YAEC has FERC approved power contracts which assure collection of all funds needed prior to final dismantlement.

.1 Page 4

8. YNPS Decommissionine Public Information Program

__The YAEC Public Affairs Department is currently developing a comprehensive public information program regarding decommissioning activities. The program willinclude the following:

1)

Meetings with local, state, and federal elected of5cials, 2)

Meetings with representatives of federal, state, and local agencies which are responsible for public health and safety, 5

3)

Public information forum (s) held in the vicinity of the plant site, 4)

Briefings to the local, regional, and/or national news media, and l

5)

Slide presentation (s), information packets, and news media kits.

YAEC will ensure dissemination of information to elected offcials, general public, and news media regarding activities which YAEC believes would elicit public interest.

YAEC anticipates that the first public forum will be held in the first quarter of 1993.

In addition, YAEC will be working with the administration of the Greenfield Community College to improve the organization and documentation access capabilities in the Public Document Room at the college.

l

9. Clarification of Maior Activitv Dennition and Foreclosure of Decommissionine Alternatives Maior Activity As indicated in our letter of November 25,1992, (Reference 5) and as discussed in detail during the December 8,1992 meeting with the NRC staff, a major activity is one which requires NRC approval prior to implementation for one or more of the following reasons:

i The activity is determined to involve an unreviewed safety question as deEned in e

10 CFR 50.59 i

The activity requires a change to the Plant Technical Specifications e

The activity will substantially increase the cost of decommissioning the facility i

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The activity materially or demonstrably affects the options available for decommiuioning the facility or may affect the ability to release the site for unrestricted use.

Decommissionine Option Foreclosure ne NRC has concluded in its GEIS on decommissioning that both DECON and SAFSTOR are reasonable alternatives for decommissioning commercial light water reactor facilities. Although there are advantages and disadvantages to either option, none is compelling enough to cause either option to be preferred from an environmental impact perspective.

The choice of a particular decommissioning alternative is generally driven by influences such as the availability of funds to complete decommissioning, the availability of a low level waste disposal facility for decommissioning wastes, or safety issues associated with decommissioning of a unit at a multi-unit site. De multi-unit site issue is clearly not applicable to YNPS and will not be discussed further. The impact of the remaining two considerations, on public health and safety, is discussed below.

He availability of sufficient funds could adversely affect a licensee's ability to safely decommission the facility. It may be necessary to SAFSTOR the facility until adequate funds are available to ensure completion of the process. YAEC will continue to ensure that adequate funds are available to safely complete all plant closure and decommissioning activities.

Although sufficient funds may be available to complete decommissioning, a low level waste site may not be available for disposal of decommissioning waste. This is the primary reason for YAEC's decision to SAFSTOR YNPS until the year 2000. Until recently, access to all of the existing LLW burial facilities was closed to out-of-compact generators, such as YNPS, beyond January 1,1993. The state of South Carolina has recently indicated that the Barnwell facility will remain open to Massachusetts generators through June 30,1994. This decision allowed YAEC to consider equipment removal and disposal activities designed to take full advantage of the burial site availability.

In discussing component removal activities with the NRC, the Staff questioned whether an activity such as removal of steam generators would preclude the SAFSTOR option because the component is no longer stored within the confines of the containment

]

building. If such an activity were to be viewed in such a literal sense, then removal of any component (regardless of its characteristics) would indeed preclude the SAFSTOR option. Therefore, no component removal activities could be conducted prior to approval of the decommissioning plan. The Commission did not intend for such a narrow interpretation of its guidance. On the contrary, the Commission specifically allowed for decontamination and dismantlement activities prior to approval of the decomminioning plan (Reference 6). Finally, as a practical matter component removals are safely Page 6 I

perforined for operating reactors. It seems logical to conclude that in the permanent plant shutdown condition, the components can be removed as safely.

The primary objective of the SAFSTOR alternative is to preclude inadvertent public exposure or inadvertent spread of contamination while awaiting final dismantlement.

This objective remains as long as the plant contains radioactivity above residual levels permitting unrestricted use of the facility. This safety objective continues until the final radiation surveys are completed to demonstrate that the radioactivity has been removed to residual levels permitting unrestricted use of the facility. Therefore, appropriate controls, programs, procedures, systems, structures and components necessary to preclude inadvertent exposure or spread of contamination must be maintained until the site is released for unrestricted use.

Removal of these components clearly does not foreclose the SAFSTOR option since the need to protect the worker, the public and the environment will remain after the components are removed, and until the site has been restored to residuallevels permitting unrestricted use of the facility and termination of the license.

Fundamental to this discussion is the fact that either decommissioning alternative, DECON or SAFSTOR is acceptable provided it is implemented in such a way that protects the public, worker and the environment during execution, and ultimately results in release of the facility for unrestricted use. The choice of either alternative will i

generally be made because of extenuating circumstances surrounding a licensee's unique situation at the time the decision is made to cease power operations and begin decommissioning.

In reality, the decommissioning alternatives dermed and evaluated in the GEIS are identical relative to safety objective, environmental impact, and ultimate disposition of the facility. The issue of foreclosure of a particular option should be viewed in the context of ensuring the common safety objectives, and ultimate site release goals are met. These objectives can be satisfied for many decommissioning activities, under the POL license authority, and prior to approval of the decommissioning plan.

Ouality Assurance Progs _n; YAEC will apply the existing quality assurance program requirements as defined in the Yankee Quality Assurance Program Manual YOOAP-1A, to all applicable portions of the design chance program as currently defined in Corporate, Project and Plant procedures.

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i References

1. NUREG-0586 Final Generic Environmental Impact Statement

-2cYNPS Ucense Amendment No.108, NYR 88-119, dated /2/92.-

3. YNPS Proposed Change No. 207, FYR 87-095, date'd 9/15/87

4. Decommissioning Funding Assurance Report and Certificatioh BYR 90-102, dated -

7/25/90 43

5. Letter to NRC on YNPS Component Removal Activities?BYR 92-109, dated 11/25/92.

,d

-4

6. NRC letter to YAEC transmitting License Amendment No.142 (POL), dated 8/5/92 i

i i

7. NRC letter to YAEC, " Meeting Summary-Discussion of progiosed site work Under 10 CFR 50.59 Prior to NRC Approval of Decommissioning Plant dated 12/23/92

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Enclosure A.

Preliminary Component Removal Project Schedule B.

YNPS Organization C.

YNPS Staff Experience Data D.

Decommissioning Fund Balance Chart i

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g:.,-93 XEARL Y NSSS COMPONENT REMOVALM E 2" 3_,

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t2ectcic Co

_mam - e ACTIVITY 01 01 01 01 01 01 01 01 OCT JAN APR JUL OCT JAN APR JUL 92 93 93 93 93 94 94 94

$ Time 10w 1111 111111111111111lll 1111111111111111111 PROJECT PLANNING R11111111111111111 NRC S/G SAR REVIE H 111111111111111111 TOOL Ph0CUREMENT ASBESTOS ABATEF ENT S/G RE 40 VAL G PZ 1 REMOVAL 1111111111111111111 111111111111111111 l111111111111 S/G 184 + PZR SHIPPING 11111111111111111111 11 S/G 2S 3 SHIPPING 1111111111111 8

ALL S/ G OUT OF \\ C 8

VC C!_EAN-UP C0 4PLETED 1111ll11111111ll 111111111111111111 11111111111111llll l INTERNALS SHIPMENTS TO BARNWEL L 11111111111 111111111111111111 1111111111111111111 VC CLEAN-UP C[lMPLETED A MANAGEMENT COMMITM[.NT DATES A

FINAL TRANSPORT PL AN A

S/G s iIPPING 00 :UMENTS 8

TOOL PROCUREMENT BARNHELL CLOSING A "g.d!!=*

Bar Chart Key:

Ear]y Dates

,,..., " ' " " ' ~ "

(IID=Cr= t t i e e I

PERMAN ENTLY DEFUELED ORGANIZATION PLANT SUPERINTENDENT QUALITY ASSURANCE I

I ADMINISTRATIVE ASSISTANT MAINTENANCE SERVICES SUPERINTENDENT HEALTH &

MECHANICAL RADIATION

, SAFETY MAINTENANCE PROTECTION OPERATIONS ADMINISTRATION I&C E

CHEMISTRY STORES MA NCE MAINTENANCE TECHNICAL SECURITY ENGINEERING SERVICES TRAINING (DF9067Uttt0

4

o y

YNPS STAFF EXPERIENCE DATA i

Department Average Individual Years Administration 18.4 Maintenance 18 3 Operations 13.5 i

Radiation Protection 13.2 Chemistry 18.4 i

Technical Services 17.6 l

Quality Assurance 6.0 Notes:

l

1. This table is based on YNPS organization as of January 1,1993.

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