ML20066D978

Forwards Response to NRC 901217 Request for Addl Info Re Proposed Decommissioning Plan.Requests That Response to NRC Questions Re Radiation Protection Program & ALARA Be Delayed Until 30 Days After Util in Receipt of Questions

ML20066D978
Person / Time
Site:	Fort Saint Vrain
Issue date:	01/14/1991
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
P-91001, NUDOCS 9101170193
Download: ML20066D978 (6)

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Public Service' Company of Colorado P.O. Box 840 Denver co 80201 0840 January 14, 1991 Fort St. Vrain Unit No. 1 A. Clegg Crawford Vice Presdent P-91001 Nuclear Operanons U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 ATTN: Mr. Seymour H. Weiss, Director Non-Power Reactor, Decommissioning and Environmental Project Directorate Docket No. 50-267

SUBJECT:

PSC RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON THE FORT ST. VRAIN PROPOSED DECOMMISSIONING PLAN

REFERENCES:

(See attached)

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. This RAI was developed based on a preliminary NRC review of the Proposed Decommissioning Plan for Fort St. Vrain Nuclear Generating Station,_which was submitted to the NRC in Reference 2. The attachment to this letter provides PSC's response to the two NRC questions provided in Reference 1.

Subsequent to receipt of the RAI, a telephone conference call was held on January 8, 1991, between representatives of the NRC, PSC and PSC's decommissioning contractor, Westinghouse. This conference call was conducted at PSC's request to attempt to clarify the NRC's concerns regarding the radiation protection program and ALARA plans presented in the Proposed Decommissioning Plan.

During this conference call, the NRC indicated that additional detailed questions for PSC would be forthcoming with respect to the radiation protection program and ALARA. Therefore, PSC requests that its response to the radiation protection and ALARA question contained in this RAI be delayed until 30 days after PSC is in receipt of these additional detailed questions.

After completion of this conference call, a meeting has been tentatively scheduled for early February between the NRC and PSC.

PSC is pleased to have the opportunity to present its Proposed

. Decommissioning Plan to the NRC and to answer any questions the NRC may have, it is PSC's belief that this meeting will provide an opportunity for open and meaningful discussion between the two l

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P 91001 January 14, 1991 Page 2 parties, so that present and future NRC concerns can be resolved promptly and in a manner that is satisfactory to both the NRC and PSC.

If you have any questicas related to the contents of this letter, please contact Mr. M. H. Holmes at (303) 480-6960.

Very truly yMrs, W8 7)

A. Clegg Crawford f/

Vice President Nuclear Operations ACC:CRB/cb Attachments cc: Regional Administrator, Region IV ATTN: Mr. G.L. Constable, Chief Technical Sbpport Section Division of Reactor Projects Mr. J.B. Baird .

Senior Resident Inspector Fort St. Vrain Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Health 4210 East llth Avenue Denver, CO 80220

P-91001 i

January 14, 1991 i Page 3 REFERENCES (1) NRC - letter, Erickson to Crawford, dated December 17, 1990 (G-90296)

(2) PSC letter, Crawford to Weiss, dated November 5, 1990 (P-90318)

1 ATTACHMENT TO P 91001 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION i RELATED TO THE FORT ST. VRAIN i

_ PROPOSED DECOMMISSIONINO PLAN NRC Ouestion No. 1:

"As stated in our July 25, 1990 request for additional informat ton

'(RAI) on the FSV Preliminary Decommissioning Plan, the cost estimate

'must include the cost -of- each major technical action / activity and the waste disposal cost for each activity. Neither the August 27, 1990 PSC response to those questions nor the PSC November 5,1990  ;

Proposed Decommissioning Plan included the necessary level-of detaff for cost informat ton required by 10 CFR 50.82(b)(4)~ Similarly other cost estimate deficiencies identified in our July 25, 1990 RAl.

were not resolved in either of the PSC submittals.-"

PSC Response:

Subsequent to submittal of the. Proposed Decommissioning. Plan,. two additional submittals: were prepared and forwarded to the NRC on December 17. (P 90343) and December 21, 1990 (P-90362). These submittals were provided to address decommissioning cost information and provide additional -justification for use of a fixed price contracting arrangement- for decommissioning.

PSC letter P-90362, dated December 21, 1990, provides the ,

proprietary--information identified and referenced in Tables 51, 5-2  !

and 5 3 of the Proposed Decommissioning Plan, originally forwarded to the NRC h on November 5, 1990. This'- information includes a breakdowns of_ radioactive waste packaging, shipping and- disposal costs as-requested by the NRC RAI of July 25, 1990 (G-90168). This cost breakdown :is provided' in' support of- a detailed breakdown of -

radioactive ; waste information, which was provided to ' the NRC in Tables: 3.3-1.through 3.3-6 of the Proposed Decommissioning Plan.

Tables inchded in the plan identified approximate curie content and pre- and : post-reduced volume estimates, expected contact radiation

' levels,- proposed volume -reduction; techniques to be used, waste classification, and expected type- and -number of 'shipp_ing- containers.

The NRC RAI of-251 July 1990 (G 90168)- requested that disposal costs be -based on waste- volume and classification. . i

PSC letter P-90343,- dated December .17, 1990, provided additional detailed information and justification - on PSC's approach to-

- establishing the cost of decommissioning, use of a fixed price contract, and provided a detailed work breakdown. In this letter as l- well as-the original proposed plan, PSC committed to provide the NRC with additional cost detail when contract negotiations between PSC

and-the. decommissioning contractor (the Westinghouse team) have been -

completed.

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Attacliment-to P-91001 ,

January, 14, 1991  ;

Page 2- a Four attachments were submitted with this letter, and included the

.following information:-

o Attachment 1, Decommissioning Financial Assurance for Fort St. Vrain,- provides supplemental justification related to the acceptability of PSC's use of its decommissioning cost estimate based on the competitive bid process and award of a

_ firm fixed price contract.

• o- Attachment 2, PSC Competitive Bid-Process and Award of fixed Price Contract, provides a detailed summary of the process used by PSC to fully define the scope of the decommissioning effort and to select its decommissioning contractor.

o Attachment 3 Comparison -of PSC Decommissioning Cost Breakdown -with Regulatory Requirements and Guidelines, contains a detailed comparison of the contents of the Fort ,

St. Vrain Proposed Decommissioning Plan with existing

-regulatory requirements and guidance.

~

-o Attachment 4, Proposed Work Breakdown Structure for the Fort ,

'St. Vrain Decommissioning Project, provides the proposed - 1 Level?IV project breakdown. PSC and the Westinghouse team-propose- to provide a cost for each of- the items listed in -

this proposed outline.

In reviewing PSC's response (P-90262, dated August 27, 1990) to the NRC RAI dated July 25 1990 (G-90168), it was noted that PSC'

-committed to provide the following information:

-(l) details on the amounts.of-special form radioactive waste,

. if- any.

(2) details of the asbestos removal program for radioactive systems, and expected costs of -asbestos- removal and

-disposal.-

(3)- specific costs- associated with performing the final site survey.

PSC will provide an update of _ this: information when . additional

- information is -submitted .in response to the' forthcoming de, tailed questions on = the radiation protection program and ALARA ' plan.

Additionally, PSC will update-the NRC on -information-provided in the Proposed Decommissioning ~ Plan regarding- disposal- of low. level

- radioactive waste, e &8 +- m- FW

Attachment to P-91001 January 14, 1991 Page 3 NRC Ouestion No. 2;.

"The proposed Decomissioning Plan does not adequately address the ALARA princip1= and controls, procedures and equipment to protect employees and e public health and safety during decommissioning as required by ll 3R Part 20 and 10 CFR 50.82(b)(2)."

PSC Respons.q1.

In the telephone conference call between the NRC, PSC and Westinghouse on January 8, 1991, more detailed concerns were provided to PSC regarding the radiation protection program and the ALARA plan provided in Section 3.2 of the Proposed Decommissioning Pl an, in addition to guidance provided in the conference call, the NRC stated that additional detailed questions would be forthcoming in these areas. As noted in the cover letter, PSC requests that its response to this question and any proposed revision to the radiation protection program and ALARA plan be delayed to incorporate any revisions that may' be necessary as a result of these detailed questions.

Criteria contained within NRC Regulatory Guides 8.8, "In forrration Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As low As Is Reasonably Achievable" (June 1978), and Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As low As Is Reasonably Achtevable" were evaluated during the preparation of the Fort St.

Vrain Proposed Decommissioning Plan. However, no direct correlation exists between the individual elements of the Regulatory Guides and the sections of the Proposed Decommissioning Plan. PSC and the Westinghouse - team will compare the Proposed Decommissioning Plan with the guidance provided in NRC Regulatory Guides 8.8 and 8.10, and incorporate the results of this comparison in PSC's response to the detailed questions on the radiation protection and ALARA programs when they are received from the NRC.

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