ML20126F264
| ML20126F264 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/15/1992 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Kadak A YANKEE ATOMIC ELECTRIC CO. |
| References | |
| NUDOCS 9212300190 | |
| Download: ML20126F264 (4) | |
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December 15, 1992 L Docket No.50-029 Dr. Andrew C. Kadak, President and Chief Executive Officer Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398
Dear Dr. Kadak:
SUBJECT:
COMP 0hC1T REMOVAL ACTIVITIES AT THE VANKEE NUCLEAR POWER STATION I am responding to your letter of November 23, 1992, addressed to Dr. Murley, in which you outlined Yankee Atomic's program to remove and dispose of radioactive components at your facility prior to NRC approval of your decommissioning plan.
As you are aware, the Commission has these issues under current review and we anticipate that the Commission will provide guidance in this area. At the public meeting held on December 8, 1992, our staffs discussed these issues and we provided questions to y_ur staff regarding your proposed pre-decommissioning activities. These questions will be included in our meeting summary of the December 3,1992 meeting which will be issued shortly.
We understand that you plan to respond to our questions prior to any removal of large components or structures.
Sincereh OdEinat 6:ned by Bin f ohs Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation cc: See next page RLSIBilit)J1QN:
1 Docket File 50-029~ FMiraglia EReis PDRs BGrimes MFairtile (w/ incoming)
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- PREVIOUSLY CONCURRED /
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/ ~'o,} UNITED STATES 8" n NUCLEAR REGULATORY COMMISSION E W ASHINGTON, D. C. 20555 e
\ December 15, 1992 Do;ket No.50-029 Dr. Andrew C. Kad.2, President and Chief Executive Officer Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398
Dear Dr. Kadak:
SUBJECT:
COMPONENT REMOVAL ACTIVITIts AT THE YANKEE NUCLEAR POWER STATION I am responding to your letter of November 25, 1992, addressed to Dr. Murley, ia which you outlined Yankee Atomic's program to remove and dispose of radioactive components at your facility prior to NRC approval of your decommissioning plan.
As you are aware, the Commi.;sion has these issues under current review and we anticipate that the Commission will provide guidance in this area. At the public meeting held on December 8, 1992, our staffs discussed these issues and we provided questions to your staff regarding your proposed pre-decommissioning activities. These questions will be included in our meeting summary of the December 8, 1992 meeting which will be issued shortly.
We understand that you plan to respond-to our questions prior to any removal-of large compcnents or structures.
Sincerely,
_=; A Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation cc: See next page a
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1 Dr. Andrew C. Xadak Yankee Rowe Docket No. 50-29 CC:
Ms. Jane M.-Grant Mr. David Rodhan, Director Senior Licensing Engineer ATTN: Mr. James B. Muckerheide Yankee Atomic Electric Company Massachusetts Civil Defense Agency 580 Main Street 400 Worcester Road Bolton, Massachusetts 01740-1398 P. 0. Box 1496 Framingham. Massachusetts 01701-0317 Thomas Dignan, Esq.
Ropes and Gray Chairman, Franklin County One International Place Commission Boston, Massachusetts 02110-2624 425 Main-Street __
Greenfield, Massachusetts 03101 Mr. N. N. St. taurent Plant Superintendent Executive Director.
fankee Atomic Electric Company New England Conference of Public Star Route Utility Commissioners Rowe, Massachusetts 01367 45 Memorial Circle Augusta, Maine 04330 Resident Inspector Yankee Nuclear Power Station U.S. Nuclear Regulatory Commission P. O. Box 28 Monroe Bridge, Massachusetts 01350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Robert M. Hallisey, Director Radiation Control Program
' - Massachusetts Department of Public i Mealth 305 South Street Boston, Massachusetts 02130
! Commissioner Richard P. Cedano l Vermont Department of Public Service 120 State Street, 3rd Floor Montpelier, Vermont 05602 Mr. Jay K. Thayer Vice President and Manager of Operations i Yankee Atomic Electric Company l 580 Main Street ,
Bolton, Massachusetts 01740-1398 1
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-U.S. Nuclear Regulatory Commission Document Control Desk ?)
Washington DC 20555 Attention: Dr. Thomas E. Murley, Director '
I office-of Nuclear Reactor Regulation 4 1
Reference:
License No. DPR-3. (Docket-No. 50-29)' -
Subject:
_ COMPONENT REMOVAL ACTIVITIES 1 1
Dear Dr. Murley:
-1 1
On August 5, 1991 the Nuclear Regulatory. Commission -(NRC) issued Amendment 9 , 142 to the Facility Operating License for th'e .
Yankee Nuclear'Pcwer Station (YNPS). This amendment modified the.- ,
YNPS operating license to a possession only license :(POL)l. - In- ~1
~the letter transmitting the POL, the NRC stated that Yankee Atomic Electric Company (YAEC) could proceediwith certain decommissioning activities. prior to the decommissicning plan being approved. In particular, the'NRC stated the following:
"It should be noted that although the NRC must approve the decor.missioning alternative and major structural ch:.nges to radioactive components of the facility, Yankee-Atomic Electric' Company may proceed with-activities'(such as additional decontamination, component disascembly, and shipment and storage of spent. fuel), if these activities:: (1) are: permitted by .
the POL'and 10 CFR 50.59,_and (2) do not materially and J demonstrably affect the methods or options available for decommissioning or substantially increase the cost
- of decomninsioning."
The NRC has thus far_ issued this same' guidance to Fort.St. Vrain, Shoreham, Rancho Seco,_and San Onofre. _Since YNPS has received
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its-POL,-discussions have been held with the Staff regarding YAEC's implementation of?the guidance. The Staff recommended that YAEC identify, in writing, the process it proposes to use in-light of the Commission guidance provided in the POL transmittal 1 Letter, M..Fairtile, U.S. . Nuclear Regtlatory Commission to~
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J.. Grant, Yankee Atomic Electric Company, August 5, 1992 h[h '
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U.S. Nuclear Regulatory Commission November 25, 1992 Page 2 letter. The fellowing, which is the response to that recommendation, delineates how Y)EC will apply the above guidance.
"...NRC must approve the decqmmissioninc alternative..."
10 CFR 50.82 requires that licensees suhait a proposed decommissioning plan within two years after permanent cessation of operations. 10 CFR 50.82(b) states that the proposed decommissioning plan must include "...(the): choice of the alternative for decommissioning..." 10 CFR 50.82 (b). (1) (1)_ states that "...(for] an electric utility licensee, an alternative is acceptable if it provides_for completion of decommissioning _
within 60 years."
As e::plained in" NUREG-0586- ,
" Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities,"2 reasonable decommissioning alternatives are-identified as immediate dismantlement (DECON), safe storage followed by dismantlement-(SAFSTOR) , and entombment (FNTOMB) . (Note: ENTOMB is not a
-viable alternative in light of the 60-year limit imposed by'10 CFR 50.82 (b) (1) (i) . ) ,
YAEC has scheduled submittal of the YNPS decommissioning plan for.
late August 1993, which is approximately six months pricr to the required schedule =for submittal. YAEC proposes to place-the plant into SAFSTOR until the year 2000, at which time YAEC will begin final dismantlement.
"...NRg__must approve... major ptructural chances to radioactive
. com.ponents of the facility. 2" In the Sup CFR 50.82,plementary Information the NRC responded to atocomment the 1988 rule noted which change on it that 10 was unclear what activities.should not be started prior to epproval of decommissioning plans. In response,-the NRC stated -
the following:
2 NUREG-0586, " Final Generic Environmental Impact Statement' on Decommissioning of Nuclear. Facilities," U.S. Nuclear Regulatory Commission, August 1988 a
Final Rule, " General Requirements- for Decommissioning Nuclear Facilities," Federal Register, Volume 53, Page 24025, June 27, 1988 9 ee't
I U.S. Nuclear Regulatory Commission November 25, 1992 page 3
" ...it should be noted that Section 50.59 permits a holder of an operating license to carry out certain activities without prior commission approval unless these activities involve a change in the technical specifications or an unreviewed safety question.
However, when there is a change in the technical specifications or an unrcviewed safety question, Secticn 50.59 requires the holder of an operating license to submit an application for amendment to the-license pursuant to Section 50.90. Section 50.59 (a) (2) contains criteria as tc what-is deemed to be an unreviewed safety issue.. The amendments contained in this rulemakinc do not alter a licensee's capability to conduct activities under Section 50.59. Although the Commission must approve the decommissioning alternative and major structural changes to radioactive components of the facility or other major changes, the licensee may proceed with some activities such as decontaminatica, minor component disassembly, and shipment end storage of spent fuel if these activities are permitted by the operating license and/or 50.59."
(Enphasis added.)
Given the guidance above, YAEC will use the following approach to determining if a proposed activity is a major structural change or other major change.
The statement "...although the Commissicn must approve., major j structural changes to radioactive components...or other major chr.go" must be read in the context of the preceding sentence which clearly states that a licensee's ability to conduct ac .vities under Section 50.59 is not altered by the cited rulcaaking. Therefore, a " major structural change" or " major change" must be a change that results in either an unreviewed safety question or a change to the technical specifications.
Such an interpretation ensures that the POL licensing basis, which has been approved by NRC, is preserved, thus providing continued protection for public health and safety.
". . . f YAEC) may proceed with activities. . .i f tilese activities: (1) are permitted by the POL..."
This guidance is consistent with that implemented during power operations. Whenever activities were performed during power operations (including outages), the activities had to be permitted by the operating license. YAEC will ensure that all POL license conditions are met,
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November 25, 1992 Page 4
"...rYAEC1 may Droceed with activities. . .if these activities t -(1}f are permitted bv. . 10 CFR 50. 59, . . ."
The purpose of 10 CFR 50.59 is to preserve the licensing--basis I which has been reviewed and approved.by the NRC,othus ensuring public health and safety. For a facility-that has been i permanently shutdown and defueled, the licensing basis includes i documents such as the POL, FSAR, technical specifications, amendments, exemptions, and other correspondence: regarding1the -
permanently shutdown and defueled condition.. Licensing basis documents are reviewed as appropriate by.YAEC as part of'the-safety evaluation process. YAEC conducts safety evaluations using the guidance of NSAC-125, " Guidelines for.10 CFR 50.59 Safety Evaluations,"* for which YAEC was a major _ contributor.
YAEC implements the guidance-of NSAC-125 through' detailed procedures. Previous NRC inspections'and reviews have focused on both the adequacy and the implementation of those procedures in-- c performing safety evaluations.
In implementing the 50.59 process, YAEC will continue:to-consider the impacts of the proposed activity to ensure compliance'with existing requirements. programs, procedures, and other applicable-licensing bases.
"...fYAEC] mav-proceed with' activities...if these activities:
...(2) do not materially and demonstrably affect'the' methods or:
ootf.ons available for decommissionina...":
NUREG-0586 identifies reasonable decommissioning alternatives as DECON,.SAFSTOR, and ENTOMB. The question arises ~as to1whether-
" methods or options" as identified in the-guidance above and
" reasonable decommissioning-alternatives" are one in the'same; For purposes of implementing the NRC guidance,_the term " methods-
- or options" must be considered _one in.the same:as " reasonable decommissioning alternatives." If'" methods or options" were _
L interpreted instead to include variations to DECON, SAFSTOR, and
!; ENTOMB alternatives, then an infinite number of methods or L options would exist, thus_ precluding-the conduct of_any pre-decommissioning plan' activities (major or minor) . The Commission i- did not intend for such an interpretation as the Commission'has reviewed each POL request to:date (i.e. Lacrosse, Shoreham, Ft.
St. Vrain, Rancho Seco, YNPS', and San Onofre) and has each tinc l
NSAC-125, " Guidelines for 10 CFR 50.59 Safety Evaluations,"
June 1989 F
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U.S. Nuclear Regulatory Commission November 25, 1992 Page 5 approved the amendment package that specifically states that licensees can proceed with certain activities prior to NRC approval of a decommissioning plan. Therefore, the guidance provided above should be read in the context of " reasonable decommissioning alternatives," that is, DECON, SAFSTOR, and ENTOMB. (As noted before, ENTOMB is not a viable option given the 60-year limit imposed by 10 CFR 50. 82 (b) (1) (i) . )
In determining whether a proposed activity materially car demonstrably affects the decommissioning alternatives, YAEC will determine whether the activity forecloses any of the three alternatives or affects the ability to restore the site to
" unrestricted" use. For example, the evaluation will ensure that if a component removal activity is conducted, the capability to place the plant in SAFSTOR is still maintained. Noting that the intent of SAFSTOR is to preclude inadvertent exposure of the public to radiation and inadvertent spread of contamination, the evaluation will ensure that appropriate structural barriers and administrative controls intended to preclude such events are maintained. The evaluation will also ensure that equipment will remain available to support future decommissioning activities or that acceptable alternatives will be available.
The evaluation of an activity may indicate that implementation of the activity would foreclose an option available for decommissioning. For example, removal of the vapor container (VC) steel shell could adversely impact the viability of a SAFSTOR option. The VC shell is a structural barrier that will -
be relied upon during the SAFSTOR period to prevent tho inadvertent spread of contamination. Conversely, removal and disposal of a component within the VC, such as a steam generator, does not impact the ability of the plant to be placed and maintained in a SAFSTOR condition, nor does it af'.ect the ability to release the site for " unrestricted" use. Protection of the public is unaffected by the removal and disposal.
H...rYAEC] may proceed with activities. . .if t'aese activflles: i
...(2) do not...substantially increase the cost of decommissioning 2" YAEC believes that this requirement is a significant component of the evaluation of activities considered during plant closure. It is essential to ensure that sufficient funds will be. available to complete safely all activities related to the release of the site for unrestricted use. YAEC will compare the cost associated with the activity with the decommissioning cost estimate (basis of the FERC rate case). All reasonable tangible and intangible costs will be considered. The activity will not be initiated if it is not economically prudent to do so.
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U.S. Nuclear Regulatory Commission November 25, 1992 Page 6 Access to Decommissioninc Fundinc YAEC will access available decommissioning funds for only those activities which are legitimate decommissioning activities. YAEC is in the process of collecting all funds needed to complete decommissioning. Furthermore, YAEC has in place the assurance necessary to guarantee that all costs of decommissioning are paid, whether or not funds are accessed prior to approval of a decommissioning plan. In particular, YAEC has in place FERC-approved power contracts which assure collection of all funds needed prior to final dismantlement. YAEC also has a FERC-approved schedule for collection of those funds and a process for adjusting the collection of funds as necessary. Based upon the the collection schedule and anticipated expenditures related to component disassembly prior to approval of a decommissioning _
plan, the fund will not be reduced below the amount estimated to place the plant in a SAFSTOR condition.
Eummary YAEC intends to proceed with plant closure activities using the guidance discussed above. YAEC recognizes that additional guidance based upon a Commission Briefing held on November 24, 1992 will be provided to the industry in the near future. YAEC believes the approach described above is consistent with the intent of the discussions held at that briefing. If you have any-questions regarding the above information, please contact me at 508-779-6711.
Sincerely, YANKEE ATOMIC ELECTRIC COMPANY L
y K. Thayer Vice President and Managar of Operations c: M. Fairtile, NRC R. Dudley, NRC S. Weiss, NRC J. Partlow, NRC ,
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Tac er//7 DORS Division of Operating Reactor Support ACTION ASSIGNMENT Number: 92-142 Date: 12/1/92
Subject:
" Component Removal Activities" Ysec letter to Murley re:
(YELTICK: 0920276)
Action Requested: Prepare letter response for B.K. Grimes signature Assigned to:
- ODNP(section) *(individual)
Expected Completion Date: to B.K.G. by 12/16/92 Extended Completion Date: <
' Actual Completion Date: <
[ Completion date upon submittal of completed action)
Remarks and/or Documentation of Completed Action:
I-
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