ML20042F901

Forwards Conceptual Plan & Cost Estimates for Early Dismantlement of Fort St Vrain Pcrv, Per NRC 900315 Request

ML20042F901
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/01/1990
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20042F902	List: ML20042F901 ML20042F907
References
P-90124, NUDOCS 9005100133
Download: ML20042F901 (9)

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Public Service' co--c-P.O. Box 840 Denver CO 80201 0840 May 1, 1990-L Fort St. Vrain A Clegg Crawford; I

I Vnlt No..I vice President i

P 90124 Nucleer operations

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk

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Washington, D.C.

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4 ATTN: Mr. Seymour H. Weiss, Director t ='

Non-Power Reactor, Decommissioning and

'f C Environmental Project Directorate

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Docket No. 50-267

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SUBJECT:

PSC RESPONSE TO NRC REQUEST FOR ADDITIONAL. INFORMATION < !! E,,,* '"

PRELIMINARY DECOMMISSIONING PLAN 4 ji E,

REFERENCES:

(1) NRC letter, - Erickson to Crawford, dated March :15, 0=="

1990 (G-90035) jWI;i:

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(2)

PSC letter, Crawford to Weiss, dated June 30, 1989 (P-89228)

(3)

PSC letter, Crawford ' to Weiss, dated December 1, e

1989.(P-89459)-

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Dear Mr. Weiss:

The purpose of this letter is to-respond to the NRC's Request for Additional Information (RAI), forwarded to Public Service Company of Colorado (PSC) in Reference 1. to this letter provides

't PSC responses to NRC questions related - to PSC's Preliminary Decommissioning Plan, originally forwarded to the NRC -in Reference 2 with additional information~ provided in Reference 3. - Attachment 2 is a copy of the pertinent information prepared for PSC to evaluate the feasibility and cost of dismantling the Prestressed Concrete Reactor Vessel (PCRV).

If you have any questions related to this matter, please contact Mr.

M.H. Holmes at (303)- 480-6960.

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Very truly yours, A. Clegg Crawf d 1

Vice President Nuclear Operations j

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Public Service *

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Denver CO-80201 0840 j

May 1, 1990-.

-Fort St. Vrain A Clegg Crawford Unit No. I Vice President P-90124 Nuclear Operations -

U.S. Nuclear Regulatory ' Commission f

ATTN: Document Control Desk Washington, D.C. '20555 a

ATTN: Mr. Seymour H. Weiss, Director Non-Power Reactor, Decommissioning and-Environmental Project Directorate.

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Docket No. 50-267 j

SUBJECT:

PSC RESPONSE TO NRC REQUEST >FOR ADDITIONAL.INFORNATION -

PRELININARY DECONMISSIONING PLAN.

REFERENCES:

(1) NRC = letter, Erickson ' to Crawfori,- dated.. March 15, 1990 (G-90035)

(2)

PSC letter, Crawford to Weiss, dated ' June 30, 1989-(P-89228)-

(3)

PSC letter, Crawford to Weiss, dated December 1, 1989 (P-89459) 1

Dear Mr. Weiss:

The purpose of this letter is to respond to -the NRC's -Request for Additional Information (RAI), forwarded to Public Service Company of 1

Colorado-(PSC) in Reference 1. to this letter-provides PSC responses to NRC. questions-related-to. PSC's-Preliminary Decommissioning Plan, originally forwarded to the NRC. in' Reference 2 with additional information provided in Reference 3..is

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a copy of the pertinent information prepared' for PSC to-evaluate the feasibility and cost of dismantling-the Prestressed Concrete Reactor

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Vessel (PCRV).

If you have any questions related to this matter, please contact Mr.

t M.H. Holmes at (303) 480-6960, i

Very truly yours, 1

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A. Clegg Crawf d Vice President Nuclear Operations 3

i Licensing Review by:

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Date:

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P 90124

. i May 1, 1990-Page 2 i

ACC:CRB/cb

' Attachment cc:

Regional Administrator, Region IV i

ATTN: Mr. J.B. Baird Techr.ical Assistant

' Division of Reactor Projects

. s Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain

.Mr. Robert M. Quillin, Director I

Radiation Control Division Colorado. Department of Health 4210 East lith Avenue

' Denver, C0 Br '.20 h

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ATTACHNENT 1 TO P-90124 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORNATION RELATED TO THE FORT ST.-VRAIN-.

PRELININARY PLc0MMISSIONING PLAN 1

NRC Ouestion No. 1:

"The Fort St. Vrain (FSV) facility is' a _ unique facility and to assure.

sufficient funds will -be available for decontamination and i

decommissioning as required by 10 CFR 50.75(f), the NRC needs a more 7

detailed basis for 'the costs than PSC provided in - Attachmenti 3...

The cost study should provide' a11' component costs for each activity as well as the rationale for the effort to-complete each activity.

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PSC cost estimate was based on the assumption-thatFSV would complete.

defueling by October 1992.

If.it is' confirmed that defueling will-l 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 basis for this large range?

t PSC provided cost estimates for each major decomissioning-activity.

However, labor and O&M costs ~ are simply ' stated without detail and discussion. Please provide the basis for these costs and a rationale l

for how they are determined.

The cost estimate also needs to include'the waste disposal cos't 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 cost for insurance, licensing cost, office equipment cost, cost of office ' space, contractor's' profit, and other I

miscellaneous costs required to-support the ' activity.

If a summary sheet is provided which sumarizes all' these -cost components, y

sufficient references should be provided to support:how these costs

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were developed.

PSC Resoonse:

' I a.

Provide the NRC with a more detailed basis for the costs:

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As noted in Reference 2, PSC plans to dismantle.and decommission Fort St. Vrain following a 55-year SAFSTOR period, that would:

end in' approximately 2043.

In the final Decommissioning -Rule,.

4 the NRC acknowledged that "for decommissioning plans in which the major dismantlement activities are delayed by first placing the facility in storage, planning for these delayed activities may be less detailed."

[10 CFR 50.82(d)]

Rather, this dismantlement plan may be prepared and submitted nearer the time of actual dismantlement and decommissioning, when costs for the

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Attachment to-P-90124 o

May 1, 1990 Page 2 prbjected-plan. may be more accurately - estimat'ed. 'Without. the detailed dismantlement plan, the cost information requested by the NRC cannot.be provided.

Although PSC has not prepared a detailed dismantlement plan,-'a detailed scoping evaluation was performed to determine the feasibility of dismantling the PCRV and L removing PCRV-internal.

components..This scoping. evaluation is provided asLAttachment '

of this submittal..

It should: be recognized that the analysis-r performed forz PSC is an evaluation. only, and provides only one -

of the many feasible 1 alternatives for PSC' to dismantle the PCRV 4

and perform ' site release activities.

This evaluation ' outlines the planning activities necessary to accomplish decommissioning, as well as provides estimates 'of manpower and other resources -

necessary.

Approximate volumes.and disposal costs.

of' radioactive waste are estimated for each task.- Indirect support-manpower' and 'correspondingEcosts are also. estimated - and. are i

provided in the attachment.-

i b.

Revise the Cost Estimate if Defuelina is not Comolete by October 1992:

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At'the ) resent time, PSC still plans to complete defueling prior.

to Octo>er 1992.

Once the decision was made - to permanently ' shut - down and decommission Fort St. Vrain, time motion. studies were performed-t_

to identify critical paths for; defueling, ' including critical a

equipment.

Evaluations were L performed -to determine

'if l

L alternative sor redundant _ methods could be implemented - to.

accelerate the defuding process..As.a result of these studies, several modifications have been made on the ' Reactor Building Fuel Deck to improve reliability and efficiency of fuel handling activities.

Several modifications : have-also been made-to l

provide additional equipment (jib-cranes, mini-Auxiliary l

Transfer Casks to handle shipping cask lids, 'and' construction' of additional loading ports) to allow additional locations to load-.

the spent fuel-shipping casks and perform Fuel Handling Machine (FHM) maintenance.

I The end result of these activities is an accelerated-defueling schedule which will allow PSC to complete defueling of Fort St'.

Vrain prior to October 1992.. PSC will update the>NRC!regarding its ability to meet the October 1992 defueling completion date in the Proposed Decommissioning Plan, scheduled-to be submitted to the NRC in the fourth quarter 1990.

c.

Basis for the larae ranae of continaencies (20% to 140%):

Cost estimate contingencies were originally forwarded in-Reference 3.

Major cost estimate assumptions were identified on L

Page 3 of 41, which stated that a contingency.of 25% was assumed

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Attachment to P-90124 May 1, 1990 Page 3' i

forEall costs 1 except those for PCRV dismantlement,- where contingencies ranged from 20% to 140%.

PCRV dismantlement activities, and, assumptions used in. the sensitivity analysis are contained in Attachment B, Section'2.6, of ' Reference.

3.

Possible ranges -for-the contingencies' associated with PCRV dismantlement are identified.in: Table B-6 of Attachment B.

In all' cases,. PSC has assumed..the-worst : casa i igh' range) t varianceL (contingency) in preparingt the cost estucate. for - PCRV -

dismantlement.

The major issues affecting the. broad range t of contingencies for the PCRV dismantlement' are addressed in the:

following paragraphs..

As part of the PCRV dismantlement analysis, ~.a.' cost-sensitivity analysis was performed (seeL Attachment - 2 of this submittal,.

-Sections 5.6'.2 and A.5.6.2) to determine how project costs would q

vary with critical parameters: radwaste volume, labor, equipment i

and services, radwaste transportation' and radwaste disposal.

The following table is reproduced from Attachment 2:

Table 5-7 COST VARIANCE FOR CRITICAL PARAMETERS l

DESCRIPTION-lltqh Lpy:-

Radwaste Volume

+18%

-16%-

j Manual Labor

+20%-

-25%

Nonmanual Labor

+35%:

-0%

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Equipment and Services

+25%

-10%

Radwaste Transportation

+140%

-20%'

Radwaste Disposal

_ +100%

-17%

RadWaste Volume:

Uncertainties in projections' of radioactive waste quantities is based on a number of factors applied to the-1 analysis of neutron activation of PCRV materials.

Neutron streaming through penetrations in the top head and core support floor could add appreciably to the : activation of. concrete and steel in the top head and the lower PCRV cavity.

j Manual Labor:- Labor rates for current agreement: union building trades were-used for the development of manual labor costs for.

Uncertainties include (1) the availability' and demand for skilled union craft experienced in the nuclear i

industry,. (2) premiums for the relatively hazardous nature of-the work and short project duration, and (3) increases in work effort due to unplanned events.

Labor rates may vary depending on the prime contractor.

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' Attach' ment to P-90124-May 1, 1990 Page 4

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Nonmanual-Labor:

Use of>.

project.

management -

system-a significantly different than that assumed in. Attachment 2, or--

the occurrence of unforeseeable management or engineering requirements, could increase nonmanual labor costs.

Eouioment'and Services: ' Estimates were made based on sufficient-quantities and durations to perform the _ work in an efficient and -

uninterrupted manner.

Uncertainties: include:

(1) abnormal changeout of failed parts;- (2) above-normal. changeout of ' rented :

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equipment;E (3) enhanced or? reduced -requirements. for redundancy -

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.in safety related systems; (4).- abnormal usage L of consumables;.

L (5) s1ower' ' or -

faster-subcontractor.

performance; (6).

I unpredictable effects of supply - and demand 'for equipment, J

materials, and services; and (7)-. changes in regulatory climate i

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which change project requirements.

l RadWaste Transoortation:

' Costs : vary with::.(1) the' distance between the project site. and the disposal site; (2)Rfees t imposed -

by. regulatory agencies and disposal site. operators; 'and (3) supply. and demand factors affecting waste 7 transportation business when decommissioning is performed.- It is 'noted that-the maximum variance (+140%) was - based on the. possibility - of shipping waste to Richland, Washington.

RadWaste pisoosal:

Variables considered : included:

(1) the number of licensed disposal sites within. an economically viable transportation distance; '(2) existing agreements with disposal site operators;- (3) waste' volume and volume discount' possibilities;;(4) regulatory agency. fees;.and (5) disposal site fees, surcharges and taxes.

d.

Provide the Waste Disposal: Costs for'Each Activity:, Tables 5-2 and, A5-2 provide,a compilation of the

origins, volumes.and weights of.~ radioactively contaminated wastes generated during PCRV dismantlementL activities.-

It was estimated in Section 4.8.3 of Attachment 2 that' approximately-27,000 cubic feet of radioactive waste will be transported :to the low level radioactive waste disposal. site.

A value' of $150 '

per cubic foot was used Lin. determining ' disposal costs ' for -each task, which is much 'more conservative than _the. current. disposal cost of $30 - $35 per cubic foot, to allow for the uncertainty.

of the Low level Waste Site when this study was performed.in

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1988.

e.

Identify All Indirect Costs Associated For Each Separate Activity:

Indirect costs are defined as."nonmanual labor" in Section 5.2.

and estimated costs are provided in Tables. 5-4 and _ AS-4 of' i.

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Attachment to P-90124 l

May 1, 1990

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NRC-Ouestion No.-2:

The response provided by PSC is adequate for the Preliminary Decommissioning Plant however, a more accurate nuclide analyses to -

characterize the components will be required-before ' actual disposal of the material.-

8 PSC Response:

j PSC recognizes that the current. activation ~ analyses -. require

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validation prior to commencing dismantlement and decommissioning activities.

PSC intends to perform characterization of the PCRV ' > ~

at some1 future date in order to accurately determine actual-activation depths and obtain samples to allow accurate nuclide characterization, t,

As. noted-previously,. preparation ;of the dismantlement plan can '

be deferred until a later date - nearer' the time. of actual 1

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dismantlement and decommissioning.

Further-details' for performing these nuclide analyses; will be included with that detailed dismantlement, plan.

NRC Ouestion No. 3:

PSC's responses did not include a contingency plan for waste storage if disposal capacity is not available.

PSC needs to provide a discussion of the storage facility that might be used ~and the estimated costs for it.

PSC Response:

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As noted in Section 4.2 of. Reference 3, the Beatty, Nevada, disposal facility is currently licensed 'and operational, with sufficient capacity to serve the Rocky Mountain Compact's needs until at least December 31, 1992.

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The Rocky Mountain Compact, of which Colorado is.a member state, is currently negotiating with the Northwest Compact to effect-an-1 agreement which will allow member ~ states of the Rocky Mountain Compact to ship LLRW to the Hanford' Regional. Disposal Site,, at a

Richland, Washington.

To that end, legislation has-been signed in the state of Washington to enter into aJ1ong-term contract to accept LLRW from the Rocky Mountain Compact.

PSC estimates that i

a final contract ' will' be approved between--the. Rocky-Mountain Conipact and the Northwest Compact-within one-year.

1 PSC is obviously interested in the progress of these negotiations, and will' notify the NRC of any significant action in this area.

Additionally, the NRC will be updated on the

<f status of these negotiations when -PSC submits its Proposed Decommissioning ' Plan, scheduled to be submitted in the fourth e

quarter of 1990.

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y Attachment to P-90124 May 1, 1990 Page 6 In the unlikely event that an> agreement with the Northwest--

Compact is not concluded, PSC has-the option to temporarily store LLRW generated at Fort St..Vrain onsite for up to 5 years, 1

following-performance of a review in accordance with 10- CFR 50.59.

If the negotiations fail and this option: become's '

I necessary, PSC will provide l the NRC. with revised ' contingency pl ans.

. Lastly, in Reference 2, PSC committed-to periodically review the!

Proposed Decommissioning.' Plan activities in conjunction with-cost estimate and fundi _ng ' plan reviews _ over the - SAFSTOR period '

to verify the validity of both the cost estimate and the funding:

_s plan.

PSC 'will keep _' the NRC apprised of any changes.: inn the; ability to ship -LLRW, as well: as any: future changes in PSC's-

contingency plans, j

NRC Ouestion No. 4r

-j PSC states they will use. S uR/HR above background as 'the Ilmit' for residual contaminstfon.

.Please: not-that-current.'

residual contamination criteria are the limits in Regulatory Guide 1.86 And 5' 1

n uR/HR above background as measured at;one meter.^ We acknowledge that-PSC committed to using updated limits'when available.' NUREG-CR 5512, i

January 1990

" Residual Radioactive.

Contamination-From i

Decommissioning" - provides a technical basis for ~ calculating - the residual radioactive contamination L limits allowable for unrestricted-release of decommissioned facilities.

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PSC Response:-

PSC acknowledges that the criteria of Regulatory: Guide:1.86 are applicable to establish residual contamination criteria-for site release.

Please-be advised that PSC has, for planning _-and cost.

estimating _ purposes, utilized. Regulatory Guide l.861 and the NRC-recommended guideline of L 5L microR/hr, at one meter, for reactor generated, gamma-emitting isotopes.'

PSC - believes - that a

utilization of this guidance provides a conservative basis for ~

the planning phase and cost estimate of the Fort _ St. Vrain

-Preliminary Decommissioning Plan.

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