ML20056D103
| ML20056D103 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 07/15/1993 |
| From: | Weiss S Office of Nuclear Reactor Regulation |
| To: | Thayer J YANKEE ATOMIC ELECTRIC CO. |
| References | |
| TAC-M86283, NUDOCS 9308030396 | |
| Download: ML20056D103 (5) | |
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July 15, 1993 Docket No.50-029 Mr. Jay K. Thayer Vice President and Manager of Operations Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398
Dear Mr. Thayer:
SUBJECT:
ACTIVITIES PRIOR TO DECOMMISSIONING PLAN APPROVAL (TAC NO. M86283)
Your letter of April 23, 1993, provided the methodology by nich Yankee Atomic Electric Company (YAEC) proposes to meet the criteria and guidance provided in our letter of March 29, 1993, regarding activities prior to NRC approval of the decommissioning plan (D-plan) for the Yankee Nuclear Power Station. These activities consist of the removal and shipment to a low level waste disposal site of the four steam generators, pressurizer and reactor vessel internals.
The NRC staff then requested a public meeting with the YAEC staff that was held on June 9,1993, at a site near the plant. The purpose of this meeting was to discuss your proposals in the YAEC April 23 letter.
The NRC participants requested information regarding your methodology in estimating occupational and public radiation exposures due to your decommissioning program and in particular to activities prior to approval of the D-plan. We also asked questions on your 10 CFR 50.59 safety analysis preparation process in regard to decommissioning.
The NRC subsequently sent these requests for additional information to YAEC in a letter dated June 16, 1993.
You promptly answered in a letter dated June 17, 1993, as supplemented on June 24, 1993.
We have completed our review of this additional information and found it responsive to our requests.
The March 29, 1993 NRC letter provided criteria for proposed activities prior to D-plan approval.
Namely, that licensees should be allowed to undertake any decommissioning activity that does not:
(a) foreclose the release of the site for possible unrestricted use; (b) significantly increase decommissioning costs; (c) cause any environmental impact not previously evaluated; or (d) violate the terms of the existing facility license or 10 CFR 50.59 applied to the existing license.
1 In regard to criterion (a) above, a YAEC letter of January 12, 1993, had previously supplied this information. This letter stated that all of the removal activities must be completed in order to release the facility for i
unrestricted use regardless of the decommissioning alternative chosen and that none of the proposed activities would preclude the facility from being released. The staff agrees with the YAEC assessment.
Based on the above, we conclude that YAEC would not foreclose the release of the site for possible unrestricted use by removing the specified components prior to NRC approval of the D-plan.
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Jay K. Thayer 2-In regard to criterion (b), your April 23 letter stated that the estimated costs for the proposed activities are several million dollars less than the cost estimate provided to and approved by the Federal Energy Regulatory Commission, your governing rate setting authority.
In addition, you have established a cost monitoring and control program to ensure that you remain within budget and maintain ongoing compliance with criterion (b).
In your letter of April 8,1993, YAEC stated that the decommissioning fund will grow by about $3 million during the component removal program.
Your letter of March 25, 1993, indicated that for unforeseen occurrences YAEC included a
$3 million contingency item in the program, based upon the hypothetical assumption that the low level waste disposal facility in South Carolina l
refused to accept a shipment, and the components had to be returned to the i
plant site for SAFSTOR. Based on the above, we conclude that YAEC has i
installed sufficiently prudent controls so that the component removal program should not significantly increase the cost of decommissioning.
Proposed compliance with criterion (c) is provided in the YAEC April 23 letter.
The licensee states, adopting the language of the Final Generic Environmental Impact Statement (GEIS), NUREG-0586, that the environmental impact of decommissioning nuclear facilities is similar or less than that during construction and operation.
YAEC also stated that they will verify that the proposed activity is bounded by the GEIS and by criterion (c). On September 15, 1987, the licensee submitted an Environmental Report (ER) as part of an application for license extension to recapture time during the construction period. The ER addressed the radiological and non-radiological effects of continued operation on both onsite and offsite environments; the
. radiological impact of the uranium fuel cycle and plant modifications; and the programs, practices and procedures in place to monitor and control the impacts.
YAEC has committed, in the April 23 letter, to use the ER as part of the basis for ongoing environmental reviews of the proposed component removal i
program. The licensee will maintain documentation of each review, which is subject to NRC audit.
In their June 17, 1993 submittal, YAEC stated that cumulative radiation exposure environmental impacts for both component removal j
and subsequent decommissioning activities would be documented and maintained j
within GEIS guidelines. As part of this review, the staff also considered the radiological impacts of such component removal at this time versus deferred removal in the year 2000 when the current license expires. Using data supplied by the licensee, which was reviewed by the staff and found to be l
nservative, the staff concluded that these activities, if carried out at the
[
esent time, would have radiological impacts within the envelope of the GEIS.
I ised on the above, we conclude that the licensee has in place an adequate program to ensure compliance with criterion (c).
Criterion (d) states that the activity should not violate the terms of the existing facility license or 10 CFR 50.59 as applied to the existing license.
The staff performed a review of the Possession Only License (POL) No. DPR-3, the Technical Specifications contained in Appendix A of the license and exemptions issued by the NRC since the plant was permanently shut down. Based i
on this review, the staff concludes that the proposed activities are consistent with the terms of the existing facility license.
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j Jay X. Thayer 3-July 15, 1993 The licensee was asked in the NRC letters of March 29 and June 16 to describe the manner in which they intend to implement the 10 CFR 50.59 plant trodification process in the permanently shutdown condition and in particular how they would treat fire and earthquake hazards.
In addition, YAEC was asked to describe their process for change approval and how it will ensure continuing compliance with the March 29 criteria.
The YAEC April 23, June 17, and June 24 letters provided a detailed program description of the 50.59 process now in use including a description of the controlling procedures and the changes to the procedures that have been made or are in the process of being made in order to comply with the criteria in the NRC March 29 letter and the provisions of the POL. The licensee stated that the design change process has always included and will continue to include fire hazards and seismic loads. The staff in an inspection performed from January 25-28, 1993, (Yankee Rowe Inspection Report 50-29/93-01 dated March 9, 1993) found the 50.59 process to be in accordance with NRC rules and the safety analyses prepared by the licensee to be comprehensive.
Based on our review of the YAEC submittals and the results of the NRC inspection, we conclude that the licensee is properly implementing the 50.59 process and has suitable procedures in place, or in preparation, to ensure continuing compliance with the March 29 criteria.
The staff plans future inspections of these programs.
Our March 29, 1993 letter also included an individual criterion regarding the YAEC use of decommissioning trust funds before approval of the D-plan for the removal cost of the specified components.
By letter dated April 16, 1993, we advised that we did not object to such use of decommissioning trust funds.
Our approval was based on licensee submittals of March 5, March 25 and April 8, 1993.
The staff concludes that the licensee has properly addressed all of the criteria and guidance in our March 29, 1993 letter and provided an adequate response to our June 16, 1993 letter. Therefore, the staff does not object to the proposed component removal activities prior to NRC approval of the j
decommissioning plan.
Sincerely, KD+
e.our H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation cc:
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Jay K. Thayer 3-The licensee was asked in the NRC letters of March 29 and June 16 to describe the manner in which they intend to implement the 10 CFR 50.59 plant modification process in the permanently shutdown condition and in particular how they would treat fire and earthquake hazards.
In addition, YAEC was asked to describe their process for change approval and how it will ensure continuing compliance with the March 29 criteria. The YAEC April 23, June 17, and June 24 letters provided a detailed program description of the 50.59 process now in use including a description of the controlling procedures and the changes to the procedures that have been made or are in the process of being made in order to comply with the criteria in the NRC March 29 letter and the provisions of the POL. The licensee stated that the design change process has always included and will continue to include fire hazarde and seismic loads. The staff in an inspection performed from January 25-28, 1993, (Yankee Rowe Inspection Report 50-29/93-01 dated March 9, 1993) found the 50.59 process to be in accordance with NRC rules and the safety analyses prepared by the licensee to be comprehensive.
Based on our review of the YAEC submittals and the results of the NRC inspection, we conclude that the licensee is properly implementing the 50.59 process and has suitable procedures in place, or in preparation, to ensure continuing compliance with the March 29 criteria.
The staff plans future inspections of these programs.
Our March 29, 1993 letter also included an individual criterion regarding the YAEC use of decommissioning trust funds before approval of the D-plan for the removal cost of the specified components.
By letter dated April 16, 1993, we advised that we did not object to such use of decommissioning trust funds.
Our approval was based on licensee submittals of March 5, March 25 and April 8, 1993.
The staff concludes that the licensee has properly addressed all of the criteria and guidance in our March 29, 1993 letter and provided an adequate response to our June 16, 1993 letter. Therefore, the staff does not object to the proposed component removal activities prior to NRC approval of the decommissioning plan.
Sincerely, Seymour H. bleiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation cc: See next page
Jay K. Thayer Yankee Rowe Docket No. 50-29 cc:
i Dr. Andrew C. Kadak, President Chairman, Franklin County and Chief Executive Office Commission Yankee Atomic Electric Company 425 Main Street i
580 Main Street Greenfield, Massachusetts 03101 Bolton, Massachusetts 01740-1398 Executive Director Thomas Dignan, Esq.
New England Conference of Public Ropes and Gray Utility Commissioners One International Place 45 Memorial Circle Boston, Massachusetts 02110-2624 Augusta, Maine 04330 Mr. N. N. St. Laurent Citizens Awareness Network Plant Superintendent P. O. Box 83 i
Yankee Atomic Electric Company Shelburne Falls, Massachusetts 01370 Star Route Rowe, Massachusetts 01367 Resident Inspector Vermont Yankee Nuclear Power Station Regional Administrator, Region I U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission P. O. Box 176 475 Allendale Road Vernon, Vermont 05354 King of Prussia, Pennsylvania 19406 Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 305 South Street Boston, Massachusetts 02130 Commissioner Richard P. Sedano Vermont Department of Public Service 120 State Street, 3rd Floor Montpelier, Vermont 05602 Mr. David Rodham, Director ATTN: Mr. James B. Muckerheide Massachusetts Civil Defense Agency 400 Worcester Road P. O. Box 1496 Framingham, Massachusetts 01701-0317 Ms. Jane M. Grant Senior Licensing Engineer d
Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398