ML20065L518

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Addresses Delays in Approval of Util 891121 Application for Possession Only License
ML20065L518
Person / Time
Site: Fort Saint Vrain 
Issue date: 10/05/1990
From: Hock D
PUBLIC SERVICE CO. OF COLORADO
To: Carr K
NRC COMMISSION (OCM)
Shared Package
ML19336C510 List:
References
NUDOCS 9012070107
Download: ML20065L518 (4)


Text

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O Pubi c serv ce-

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October 5,1990 Fort St. Vrein D.D. HOCK ENE$N 3

Chairman Kenneth M. Carr V. S. Nuclear Regulatory Commission Washington, D. C.

20555 Docket No. 50-267

SUBJECT:

FortSt.VrainPossessionOnlyLicense(POL)

Dear Chairman Carr:

I was. in attendance at INPO's CEO Conference on November 1-3, 1989, and I listened to your challenge to the V.

S.

nuclear industry to bring specific examples to your ettention if e utility has "a problem with the way we are doing business".

There have been prolonged deleys in the NRC's approval of a Possession Only License (POL) for the Fort St.

Vrain Nuclear Generating Station. The Public Service Compeny of Colorado (PSC) now finds that this matter is in need of your immediate ettentien if our shareholders are to avoid unnecessary delay costs in decomissioning Fort St. Vrain exceeding $2.5 million per month.

During the prolonged NRC review of the Fort St. Vrain POL application, PSC has basically exhausted the possibilities for " working around" the need for a POL to proceed with decommissioning preperations.

It should be emphasized that MC's plant closure and decommissioning preparation activities under a POL will not preclude any of the three decommissioning options, i.e., DECON, SAFSTOR, or ENTOMB.

The specifics of this matter are as follows.

PSC submitted a Possession Only License application for Fort St.

Vrein on November 21, 1989.

The specific wording and content of the POL application was discussed with Mr. Peter Erickson, the NRC Fort St. Vrain Project Manager, and the NRC legal staff prior to submittel.

To date, there have been no disputed issues surrounding the wording or content -of the POL application.

The first delay involved the noticing of the POL application in the Federal Register. A two month delay in issuing the Federal Register notice occurred early in 1990.

PSC was finally informed by Mr.

Erickson on March 13,

1990, that we would have to submit an

" environmental analysis" and address " replacement power" before the Federal Register notice could be published.

PSC submitted the environmental analysis on April 25, 1990, and the POL application was noticed in the Federal Register on May 16, 1990.

(Please note that in Public Service Company's opinion Mr. Peter Erickson has done an exemplary job of processing the POL application.)

O]0/0

P-90304 Page 2 October 5, 1990 s

The Federal Register notice ccment period expired on June 14, 1990.

There were no public coments on the Fort St. Vrain POL application, or any other e.*oressions of public interest in this matter.

The NRC technical and le931 staffs have concluded their reviews of the Fort St.

Vrain POL oplication and are apparently setisfied The POL application concluded that maintaining the plant permanently shutdown would increase margins of safety.

The environmental analysis concluded that the environmental impacts associated with the permanent shutdown of Fort St. Vrain, including replacement power considerations, are minimal and generally beneficial.

PSC has submitted, and the NRC has had under review since June 1989, a preliminary decommissioning plan for Fort St. Vrain.

I met witt you and each of the other Comissioners in March and April of 199 and explained that Fort St. Vrain is not being shutdown for_ political reasons.

Fort St. Vrain cannot be restarted due to technical considerations, and it would be financially imprudent to make any further attempts to operate the plcnt.

Furthermore, the Department

- of Energy has submitted to PSC the attached letter dated April 16, 1990, requesting various Fort St. Vrain components for research to enhance the safety of future reacter designs.

- In summary, since the end of June 1990, everything has been in place for the NRC's approval of the Fort St. Vrain POL application.

However, three additional months have now passed and no action on the Fort St. -Vrain POL application has - been forthcoming.

Repeated inquiries to the NRC staff indicate that the POL matter is before the NRC Commissioners. Mr. Clegg Crawford, my Vice President,. Nuclear Operations, was given very little information when he attempted to i

. discuss the POL matter with the individual Comissioners in person on August 3,1990.. You personally stated, Chairman Carr, that you would not discuss' POLS.

Mr.:. James Taylor.

EDO, indicated to Mr. Crawford that the Commissioners would most likely resolve the POL matter in a meeting concerning Shoreham on September 21, 1990. The September 21, 1990-meeting was subsequently postponed until October 2,1990 by the NRC, On-October.2,1990,theCommissionmeetingtodiscussShoreham(and' presumably POLS) was cancelled by your office without explanation.

To the best 'ofL our knowledge' th'e're are no issues or concerns l

regarding the Fort St. Vrain POL application that have not been L

addressed - and ~ resolved to everyone's satisfaction.

Linking of the l

Fort St. Vrain POL application to any situation or concerns regarding1 l

the Shoreham plant. is-inappropriate, and does nothing to enhance safety-or resolve environmental' concerns.

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P-90304 Page 3 October 5,199f.

As explained in the attached NRC letter from Fr. Partlow to Mr.

Tipton of NUMARC dated September 10,

1990, the NRC views decommissioning as a three phase process.

Fort St. Vrain has been in the first phase for ovsr a year now, and we need NRC approval of the POL application to move into phase two. Since Fort St. Vrain is not in the rate base, any further delays will result in escalating costs to PSC shareholders for decommissioning the Fort St. Vrain plant at a rate exceeding $2.5 million per month.

For a regulatory agency to unnecessarily impose such a burden on our shareholders, without any associated enhancements to safety or the environment,. is arbitrary, uncalled for and unfair.

I request that you respond to this concern at the earliest possible date, and that you and tie other Commissioners give this matter your immediate and personal attention.

Please do not hesitate to contact meat (303)571-7211 if there is anything we can do to bring this matter to en immediate conclusion.

Respectfully yours, k

D. D. Hock Chairman, President and Chief Executive Officer DDH/MHH:tmk Attachments cc: Commissioner Kenneth C. Rogers, USNRC Commissioner James R. Curtiss, USNRC Commissioner Forrest J. Remick, USNRC James M. Taylor, EDO, USNRC James G. Partlow, NRR, USNRC Seymour H. Weiss, NRR, USNRC Peter B. Erickson, NRR, USNRC Document Control Desk USNRC Thomas E. Tipton, Director, NUMAR.C i

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Department of Energy

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Idaho Operations Office 786 DOE Place S '" v *g Idaho Falls, Idaho 83402 April 16,1990 Mr. H. L. Brey Technology Transfer Manager Public Service Company of Colorado Suite 1000 2420 West 26th Avenue Denver, CO 80211

Dear Mr. Brey:

The Department of Energy (DOE) has identified the components at Fort St. Vrain (FSV) Nuclear Generating Station that may provide beneficial knowledge for the design, construction, operation and decommissioning of the New Production Reactor (NPR) Modular High Temperature Gas-Cooled Reactor (MHTGR).

The DOE-sponsored FSV Technology Transfer program Technical Working Group (TWG),

has identified the following components which are proposed for removal from FSV and follow up post irradiation examination (PIE).

1.

Primary System Plateout Probe 2.

Steam Generator Main Steam Ring Header 3.

Steam Generator Bimetallic Weld Samples 4

Control Rod Absorber String 5.

Control Rod Drive Mechanism 6.

Fuel Test Elements 7.

High Temperature Helium Purification System Components This is neither an all inclusive list of FSV components that may be of interest to NPR, nor does it represent a comitment that all of these components will be examined.

Some items may be deleted from this list and additional items may be added as the design of the NPR-MHTGR progresses.

Sin.ce rely,

P. J Dirkmaat, Acting INEL NPR Project Manager cc:

J. K. Eggebroten, FSV J. D. Nulton, NP-43 H. Zeile, EG&G S. Franks, NP-43 i

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