ML20046B136
| ML20046B136 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/28/1993 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-57FR58727, RULE-PR-20 57FR58727-00100, 57FR58727-100, P-93060, NUDOCS 9308030155 | |
| Download: ML20046B136 (6) | |
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June 28,1993 Fort St. Vrain 1
Unit No.1 P-93060 Secretarf of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTN; Docketing and Service Branch Docket No. 50-267
SUBJECT:
Comments on NRC Rulemaking Issues Paper Regarding Radiological Criteria for Decommissioning NRC-Licensed Facilities Gentlemen:
This letter submits Public Service Company of Colorado's (PSC's) comments on the NRC's Rulemaking Issues Paper regarding radiological criteria for the decommissioning -
of NRC-licensed facilities. The NRC requested public comments on this paper by this date in 58 FR 29998, dated May 25,1993.
PSC generally endorses the nuclear industry comments being provided by NUMARC and by the Health Physics Society. In addition, we have provided certain specific viewpoints, particularly as they might apply to the decommissioning of the Fort St. Vrain Nuclear Station, where dismantlement and decontamination activities are actively in progress.
If you have any questions regarding the attached comments, please contact Mr. M. H.
Holmes at (303) 620-1701.
Sincerely, jd/h A
Don W. Warembourg Decommissioning Program Director lb 930B030155 930628 PDR PR 20.57FRDB727 PDR y
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P-93060 June 28,1993 Page 2 t
DWW/SWC Attachment cc:
w/ attachment Document Control Desk Regional' Administrator, Region IV Mr. Ramon E. Hall, Director Uranium Recovery Field Office Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Health p
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Public Service Company of Colorado's (PSC) Comments on NRC's Rulemaking Issues Paper Regarding Radiological Criteria for Decommissioning NRC-Licensed Facilities In general, we endorse NUM ARC's views and those of the Health Physics Society, and provide the following additional comments:
1.
Comments relative to returning to a background or zero dose standard, and to local citizen committee oversight of site cleanup.
Creation of local standards would likely result in protracted, expensive litigation and postponed site cleanups. As a matter of public policy, we believe that site cleanup regulations should be structured so that decommissioning resources are spent on site cleanup, not on litigation.
NRC should avoid repeating the Superfund fiasco.
Returning to zero dose is unrealistic and unreasonably onerous. Nuclear utilities need to be able to clean up their sites and end their nuclear liability. It is not good public policy to set cleanup standards so restrictive that they cannot be reasonably met and that the standards essentially require licensees to maintain their nuclear licenses indefinitely.
Public policy should encourage radioactive materials to be removed from plant sites and consolidated into licensed burial sites. Maintaining radioactive material in numerous abandoned facilities all over the country, under the control of licensees that may not have retained personnel with radioactive materials expertise, represents greater potential risks than maintaining it in licensed disposal sites.
Also, individual site maintenance, with access control provisions and facility upkeep costs, is more expensive for the licensees, for the regulatory authorities,' and ultimately the general public.
PSC encourages the practice of having local citizen oversight and review of site cleanup activities. Local citizen committee oversight comments on site cleanup plans and activities should be solicited, seriously considered and resolved.
However, the oversight of local citizen committees should not include cleanup decision making or standard setting authority.
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2.
Comments relative to EPA's risk goal approach.
1 The targeted goal that equates to 3 to 4 mrem per year is too restrictive. We l
l-disagree with use of a straight line extrapolation of cancer / exposure data, since it leads to conclusions that are unsubstantiated by reality. If the straight line extmpolation accurately represented reality, then regions with high background radiation (such as Colorado) would experience comparably higher cancer rates.
This clearly is not the case.
Public policy should be based on good scientific evidence and should not require
_i that millions of extra dollars per plant be spent to meet cleanup standards that i
have no substantiated basis and are set in large part as a political expediency.
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3.
Comments relative to the desire of state and local governments to set more stringent standards.
We support the Health Physics Society position of defining a dose limit standard and then keeping doses ALARA. Proper selection of the standard will provide an appropriate level of personnel protection without the need for establishing more stringent standards.
Local standards would allow special interest groups in certain areas to effectively j
prevent cleanup.
This is contrary to good public policy of consolidating radioactive waste in licensed burial facilities.
Standards must be consistent j
throughout the country.
l Cleanup goals should be reasonable enough to induce licensees to clean up their sites. For reasons cited above, consolidation of radioactive materials into licensed disposal facilities is preferable.
4.
Comments relative to mandating the unrestricted use option.
Nuclear licensees should have the option of being able to take future site uses into consideration in establishing the degree of cleanup.
Maintaining a site for industrial use should not require the same degree of cleanup as a site that will be i
returned to " green fields" or residential uses.
We support the option of having a less stringent dose goal (e.g.,25 mrem per year) if future use is industrial or other limited occupancy use. - Zoning restrictions would be an excellent way of preventing residential or agricultural use of decommissioned nuclear facilities.
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L Cnce a decommissioned facility is cleaned up, it should not be subject to reconsideration by regulatory authorities. Decommissioned facilities should not be left vulnerable to future dismantlement and decontamination directives, and should only be re-opened if new, substantial safety hazards are identified or significant previous commitments were not met. Otherwise licensees will have no incentive to initiate the cleanup process.
The ENTOMB option should be seriously re-evaluated. There may be some sites (such as Fort St. Vrain with its 9 foot thick monolithic concrete, shielded containment vessel) that are as good as licensed burial sites for containing radioactive materials in a manner that protects the public and allows perpetual monitoring. Also, SAFSTOR periods of up to 150 years should be considered to allow real reductions in the amount of radioactive low level waste that must be disposed. This would allow materials containing tritium, europium-152 and other radionuclides with half-lives around 10 to 15 years to decay to negligible levels.
5.
General Relative to the stated presumption in the workshops that the beneficiaries of nuclear power are the utilities and their shareholders, it is our belief that the beneficiaries of nuclear power are the customers and ratepayers of the licensed utilities. They have been provided reliable and efficient electrical power with a clean environmental record and with an excellent worker safety record. It is not sound public policy to hold the shareholders solely responsible for the perpetual care of nuclear plant sites.
Nuclear facility cleanup should be reasonably achievable. The shareholders who have borne the financial risk of nuclear plant construction and operation should not be left with an open-ended, undefined liability, but rather they should be able to derive a risk termination benefit from site cleanup activities. Otherwise the incentive to initiate site cleanup activities will be greatly reduced.
Standard setting agencies such as the NRC and EPA must make every effort to agree on a common cleanup standard, factoring the work of national and international bodies such as NCRP, ICRP, UNSCEAR and others, into their decisions.
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l Conclusion PSC submits these comments as a license holder for a facility that is being actively decommissioned. We are not just contemplating an action 20 years in the future. We have made the difficult decision to shut down our plant; we have evaluated the alternatives and decided to undertake early dismantlement; we have decided to maintain our facility for industrial use; we have met with our Public Utilities Commission and obtained their support to let the people of this generation assume the responsibility for decommissioning a facility that this generation decided to build; and we have met with numerous local citizen groups and individuals to explain our activities.
We strongly believe that cleanup goals that are reasonably achievable are in the best interests of all involved parties -- the local citizens, customers, workers, shareholders, and regulatory authorities. As a matter of public policy, we reject any proposals to make cleanup goals so unreasonably restrictive that plant cleanup cannot be undertaken, thereby passing the burden on to future generations, merely to allow activist groups to claim that nuclear plant cleanup is impossible.
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