ML20125D836
| ML20125D836 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/24/1992 |
| From: | Hock D PUBLIC SERVICE CO. OF COLORADO |
| To: | Selin I, The Chairman NRC COMMISSION (OCM) |
| References | |
| P-92308, NUDOCS 9212160059 | |
| Download: ML20125D836 (2) | |
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s hPublic Service' 2"=1 November 25,1992 Fort St. Vnin Unit No.1 P 92308 Chairman Ivan Selin U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Docket No. 50 267
SUBJECT:
Fort St. Vrain Decommissioning, Request for Exemption from Revised Radiation Protection Stamlards
Dear Chairman Selin:
On June 25,1992, you challenged the NUMARC Board of Directors and the nuclear industry to identify NRC actions that result in unnecessary expenditures of resources.
I am responding to that challenge by identifying that the imposition of a completely new set of radiation protecdon standards for the Fort St. Vrain decommissioning project would involve an unnecessary expenditure of substantial remurces for Public Service Company of Colorado, without any corresponding benefit to pub'ic health and safety.
Nuclear licensees are required to implement the revised radiation protection standards in 10 CFR Part 20 by January 1,1994. At that time, the Fort St. Vrain decommissioning project will be approximately 40 percent complete. Only an estimated exposure of 260 person rem will remain for the last two years of the decommissioning project, which is less than typical annual exposures at an operating Light Water Reactor plant.
We have determined that implementing the revised 10 CFR 20 standards would cost approximately $5 million. The benefits from this effort do not support this ecst at Fort St. Vrain. The Fort St. Vrain decommissioning project administrative limit for worker total doses is already less than the 5 rem per year limit in the revised 10 CFR 20 standards. Other qualitative benefits cited by the NRC, such as upgrading the radiation protection standards, are long term benefits that would not be realized during the remaining duration of the Fcrt St. Vrain decommissioning project.
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P-92308 November 25,1992 Page 2 To allow us to ibcus our management resources on the safe and ef6cient dismantlement and decontamination of Fort St. Vrain, we are sending under separate cover a request for exemption from the requirements of the revised 10 CFR 20 radiation protection standards. We consider that this request is warranted for this project in that the health and safety of our workers and the public would be protected by the continued use of the existing radiation protection program.
NRC approval of the exemption, given the implementation costs versus the minimal benents to be gained, would be consistent with your recent challenge to the industry.
I appreciate your efforts to avoid unnecessary regulatory burdens and I request your support for a reasonable, comprehensive radiation protection program for the Fort St.
Vrain decommissioning project. In order to avoid initiating programs and procedure revisions required to meet the January 1,1994 implementation date, and to avoid the substantial costs associated with this effort, we are requesting NRC approval of our exemption request by March 15, 1993. Please do not hesitate to contact me at (303) 294-8788 if you have any questions regarding this matter.
Respectfully yours, t
I D. D. Hock
(
Chairman, President and Chief Executive Officer p h gy, CI L
DDH/SWC Date:
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cc:
Commissioner Kenneth C. Rogers Commissioner James R. Certiss Commissioner Forrest J. Remick Commissioner Gail DePlanque James M. Taylor, EDO, USNRC Thomas E. Murley, NRR, USNRC Robert M. Bernero, NMSS, USNRC Robert M. Quillin, CDH Joseph Colvin, President, NUMARC
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