ML20127D496
| ML20127D496 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/12/1993 |
| From: | Thayer J YANKEE ATOMIC ELECTRIC CO. |
| To: | Fairtile M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| BYR-93-001, BYR-93-1, NUDOCS 9301150245 | |
| Download: ML20127D496 (16) | |
Text
.. YANKEE ATOMC ELECTMC COWANY %%"Q2M?"
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-) b80 Main Sticot, Bolton, Massachusetts 01NO-1393 January 12,1992
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llY R 93-001 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention: hir. hiorton Fairtile Senior Project hianager Non Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support
Reference:
(a) License No. DPR 3 (Docket No. 50 29)
Subject:
RESPONSE TO NRC REQUliST FOR ADDITIONAL INFORhiATION-COhiPONENT REhiOVAL ACTWITIES
Dear Mr. Fairtile:
On December 8,1992, in a publicly noticed meeting, Yankee Atomic Electric Company (YAEC) representatives met with the NRC staff in Rockville, hiaryland to present and discuss YAEC's plans for equipment removal activities at the Yankee Nuclear Power Station (YNPS) prior to formal approval of the YNPS decommissioning plan. YAEC described its plan for removal of the steam generators, reactor vessel internals and the pressurizer, which are similar to components that have previously been removed from operating reactors. YAEC is considering removal of these components due to the availability of a waste disposal site at a predictable cost for disposal. If YAEC decides to proceed, the savings to consumers can be substantial, while at the same time permanently disposing of 90% of the nonfuel residual activity existing at the site.
At the conclusion of the meeting, Mr. J. Partlow requested that YAEC provide additional information on several of the topics presented during the meeting, including the following:
- 1. A list of the equipment that YAEC is considering for removal between now and June 30,1994, along with the schedule for completing these activities.
- 2. A statement with supporting basis that the proposed activities will not preclude release of the facility for unrestricted use.
- 3. A statement with supporting basis that the environmental impacts of the proposed activities are consistent with the conclusions presented in NUREG-0586," Final 9g115024593oi3p p ADOCK 05000o29 r llg PDR
U.' S. Nuclear llegulatory Commission Page 2 Generic Environmental Impact Statement on Deconunissioning of Nuclear Facilities".
- 4. A description of the Engineering Design Change process that YAEC uses to design and implement plant modifications.
- 5. A description of the YNPS Al Al(A Program.
- 6. A summary of the permanently defueled facility organization and associated personnel qualifications.
- 7. A description of the method for funding the proposed activities.
- 8. A description of YAIIC's plans for informing the public about equipment removal and other decommissioning plans for the facility.
- 9. A discussion of the removal activities currently under consideration relative to foreclosure of available decommissioning options.
- 10. A description of the YAEC Ouality Assurance Program The Staff's request for additional information was reiterated in the NRC's Meeting Summary transmitted by letter to YAEC dated December 23,1992.
We have addressed each of the above items in Attachment 1. We trust this information will be useful in understanding the various aspects of YAEC's plans as described at the December 8,1992 meeting.
If you have any questions or require additional information, please contact us.
Very truly yours,
. n K. Thayer Vice President and Manager of Operations Encl.
U. S. Nuclear Regulatory Commission Page 3 i
cot 440NWEALTH OF MASSACHUSETTS)
)ss i WORCESTER COUNTY ) .
Then personally appeared before me, J. K. Thayer, who, being duly sworn, did state that he is a Vice President and Manager of Operations of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing d0cument in the name ,
and on behalf of Yankee Atomic Electric Company and that the ~
statements therein are true to the best of his knowledge and be11ef.
0 t .u,s... . f,A12K)
Kathryn Gates Notary Public' My Commission Expires January 24, 1997 !
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AllachmenL1 1.Scopp_qGemoval Atihilles tuuter Conal!knitino .
YAEC is currently evaluating removal of the following components:
e Steam Generators (4) e Ileactor Vessel Internals e Pressurizer The preliminary schedule for completing these activities is enclosed with this attachment.
Note that YAEC currently plans to conduct the necessary analyses supporting certification of the steam generators and pressurizer as their own shipping containers under the provisions of 10 CFR 71.12. Timely review and approval by the NRC staff of the shipping container configuration is essential for successful project completion.
- 2. IMense of the Facility for Unrestrkl.ed Use By definition, decommissioning means to safely remove the facility from service and to remove radioactivity to residual levels permitting release of the facility for unrestricted use. All of the removal activities being considered must be completed in order to release the facility for unrestricted use regardless of the decommissioning alternative chosen. None of the proposed activities will preclude the facility from being released.
- 3. Environmut1111 impftst of the Proposed Removal Activilles The NRC requested that YAEC evaluate the environmentalimpact of the proposed activl ties relative to the conclusions in the NRC Final Generic Environmental Impact Statement (GEIS), (NUREG 0586, Reference 1). The important GEIS conclusions, as they relcte to component removal activities being considered by YAEC, are discussed below.
In the GEIS, the NRC concluded the following:
e The environmental impact of decommissioning nuclear facilities is similar to or less than those during construction and operation.
e Both DECON and SAFSTOR are reasonable alternatives for decommissioning light water power reactors.
e The occupational exposurc for DECON is higher than for SAFSTOR, but similar to routine operation.
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e The higher DECON accupational exposure has marginal significance to health ,
and efety.
e The LLW harial volume is typically less for SAFSTOR than DECON due to the decay of radioactivity from the time the plant shuts down until final dismantlement begins (hurial volume reduction is recognized in the GEIS after a 50 year SAFSTOR period). This benefit is not uniquely compelling when selecting a decommissioning alternative, in 1988, NRC amended the YNPS facility operating license to permit operation for a full 40 years from the date of issuance of the operating license (Reference 2). In the proposed change documentation (Reference 3), YAEC provided the NRC staff with an Enviromnenial Report (ER) which addressed all important aspects of the environmental -
impact from operation of YNPS, including plant modifications. In granting the license extemion, NRC concluded in its environmental assessment, that the plant had operated for more than 27 years with no significant radiological or non radiological impacts, and that the proposed extension would not have any significant impact on the environment.
The NRC environmental assessment included an evaluation of the following considerations:
e Radiological impacts of the flypothetical Design Basis Accident e Radiological Impacts - Annual Releases e Environmental Impact of the Uranium Fuel Cycle o Non-Radiological impacts e Plant Modifications These licensing basis considerations are evaluated in the YAEC design change process which will be implemented for the component removal activities currently under _
evaluation by YAEC It is fully expected that the environmental impact of the component removal activities will be bounded by the conclusions in the GEIS for the following reasons:
, 1) The GEIS conclusions are based in part, on the assumption that programs and
, procedures designed tc. minimize environmental impact during plant operation are fully effective during decommissioning. YAEC will ensure that these programs are maintained during all phases of decommissioning.
a) Occupational exposure at YNPS is controlled through existing programs and procedures. The design change process ensures that ALARA considerations are integrated into the final design and implementation plan f;om the outset. The Radiation Protection and ALARA programs used during plant operation will continue through all phases of decommissioning.
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b) The YNPS Environtnental Monitoring Program will continue to be implemented through all phases of decommissioning. Plant effluent discharges will continue to be controlled and monitored under existing programs and procedures.
c) lloth hquid and sollJ radwaste processing, handling, packaging and transportation will continue to be controlled by existing programs and >
procedures.
- 2) The potential environmental impacts of postulated accidents are thoroughly evaluated and documented during the design change development process. The ,
safety evaluation, conducted in accordance with 10 CFR 50.59, and in conjunction with the design change development will ensure that the proposed activities requiring NRC approval prior to implementation are properly identified and <
documented.
- 3) The activities under consideration have been completed under 10 CFR 50.59 by operating facilities using a process similar to the YAEC design change process.
All of the programs and procedures discussed in this section have been the subject of numerous NRC inspections and audits, and have been demonstrated to be adequate.
These programs and procedures will be maintained, reviewed periodically, and updated throughout all phases of the decommissior.ing process as required by the Plant Technical Specifications and/or Plant Administrative Procedures.
Based on the above discussion, it is expected that the environmental impacts of the component removal activities, currently under consideration by YAEC, will be consistent with and bounded by the conclusions in the GEIS. YAEC will document the environmental evaluation, including all necessary analyses, to demonstrate compliance with the GEIS conclusions, in the Engineering Design Change Documentation Package for the plant modification activities.
- 4. DescripJion of the Yankee Engineerine Design Change Process As indicated ln our discussions with the staff on December 8,1992, YAEC will continue to utilize the same engineering design change process employed during plant operation, and currently employed by YAUC in its services to operating nuclear plants in New England. This process has been the subject of numerous NRC and industry inspections and audits. The NRC Regional Office has access to all plant engineering, design and operation procedures, records and documentation.
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- 5. YNPS AIABA Piuggin)
The YNPS ALARA Program, as defined in plant administrative and implementing i procedures, will be maintained and applied to all phases of decommissioning. The Corporate Environmental Engineering Department provides input and critical review of all design changes for ALARA and Environmental issues. The follmving existing plant and corporate procedures will continue to be used:
e OP 8020: Implementation and Documentation of AIARA Reviews e YA EED-400: Review of Engineering Design Change Requests and Plant Design Change Requests
- 6. YNPS I)efuded Organluttkw The plant organization for the permanently defueled condition is shown on the enclosed organization chart. As indicated in previous discussions with the NRC Staff, plant positions have been filled with senior level individuals. This is reflected in the enclosed table which identifies the individual average years of service on a departmental basis. It should be noted that the plant staff will be augmented, as necessary, by personnel from the corporate office or contractor personnel, to ensure adequate staff is available to safely complete all planned component removal activities.
- 7. Method For Fundine the Prooosed Activille3 The following information was presented by Mr.11. T. Tracy, YAEC Vice President, Treasurer and Chief Financial Officer, at the December 8,1992 meeting.
YAEC intends to access the YNPS decommissioning fund to pay for legitimate decommissioning activities This is consistent with fund access requirements as specified in the YNPS Decommissioning Fund Trust Document which was previously provided to NRC for review (Reference 4). ,
The fund will not be reduced below an amount estimated to place the plant in a safe condition at any time during plant modifications. In fact, as shown on the enclosed fund balance chart, the fund will continue to grow throughout the equipment removal period in 1993 and 1994.
YAEC is presently in the process of collecting all of the funds needed to complete decommissioning of YNPS with a projected external fund value of $71.3 million at the end of 1992. Furthermore, as indicated in Reference 5, 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 FERC approved power contracts which assure collection of all funds needed prior to final dismantlement.
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- 8. YNpS _1)ccommissioningyphlic Information Progrej The YAEC Public Affairs Department is currently developing a comprehensive public information program regarding decommissioning activities. The program willinclude the following:
- 1) Meetings with local, state, and federal elected officials,
- 2) Meetings with representatives of federal, state, and local agencies which are responsible for public health and safety,
- 3) Public information forum (s) held in the vicinity of the plant site,
- 4) liriefings to the local, regional, and/or national news media, and
- 5) Slide presentation (s), information packets, and news media kits.
YAEC will ensure dissemination of information to elected officials, general public, and news media regarding activities which YAEC believes would clicit public interest.
YAEC anticipates that the first public forum will be held in the first quarter of 1993.
In addition, YAEC will be working with the administration of the Greenfield Community College to improve the organization and documentation access capabilities in the Public Document lloom at the college.
9.fhirification of Maior Artisity Definition and Foreclosure of Decommissioning Alternatives Maior ArthDy. f As indicated in our letter of November 25,1992, (Reference 5) and as discussed in detail during the December 8,1992 meeting with the NRC staff, a major activity is one which requires NRC approval prior to implementation for one or more of the following reasons:
e The activity is determined to involve an unreviewed safety question as defined in 10 CFR 50.59 e The activity requires a change to the Plant Technical Specifications e The activity will substantially increase the cost of decommissioning the facility Page 5
e e The activity materially or demonstrably affects the options available for decommissioning the facility or may affect the ability to release the site for unrestricted use.
_IAgommissionine Opilon Fo_rrtLqmrf r
The NRC has concluded in its GEIS on decommissioning that both DECON and SAFSTOR are reasonable alternatives for decommissioning commercial light water reactor facilities. Although there are advantages and disadvantages to either option, none is compelling enough to cause either option to be preferred from an environmental impact perspective.
The choice of a particular decommissioning alternative is generally driven by influences such as the availability of funds to complete decommissioning, the availability of a low level waste disposal facility for decommissioning wastes, or safety issues associated with decommissioning of a unit at a multi unit site. The multi-unit site issue is clearly not applicable to YNPS and will not be discussed further. The impact of the remaining two considerations, on public health and safety, is discussed below.
The availability of sufficient funds could adversely affect a licensee's ability to safely decommission the facility. It may be necessary to SAFSTOR the facility until adequate funds are available to ensure completion of the process. YAEC will continue to ensure that adequate funds are available to safely complete all plant closure and decommissioning activities.
Althou, sufficient funds may be available to complete decommissioning, a low level waste site may not be available for disposal of decommissioning waste. Tids is the primary reason for YAEC's decision to SAFSTOR YNPS until the year 2000. Until recently, access to all of the existing LLW burial facilities was closed to out-of compact generators, such as YNPS, beyond January 1,1993. The state of South Carolina has recently indicated that the 13arnwell facility will remain open to Massachusetts generators through June 30,1994. This decision allowed YAEC to consider equipment removal and disposal activities designed to take full advantage of the burial site availability, in discussing component removal activities with the NRC, the Staff questioned whether an activity such as removal of steam generators would preclude the SAFSTOR option because the component is no longer stored within the confines of the containment building. If such an activity were to be viewed in such a literal sense, then removal of any component (regardless of its characteristics) would indeed preclude the SAFSTOR option. Therefore, no component removal activities could be conducted prior to approval of the decommissioning plan. The Commission did not intend for such a narrow interpretation of its guidance. On the contrary, the Commission specifically allowed for decontamination and dismantlement activities prior to approval of the decommissioning plan (Reference 6). Finally, as a practical matter component removals are safely Page 6
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performed for operating reactors. it seems logical to conclude that in the permanent plant shutdown condition, the components can be removed as safely.
The primary objective of the SAFSTOlt alternative is to preclude inadvertent public exposure or inadvertent spread of contamination while awaiting final dismantlement.
This objective remains as long as the plant contains radioactivity above residual levels permitting unrestricted use of the facility. This safety objective continues until the final radiation surveys are completed to demonstrate that the radioactivity has been removed to residual levels permitting unrestricted use of the facility. Therefore, appropriate controls, programs, procedures, systems, structures and components necessary to preclude inadvertent exposure or spread of contamination must be maintained until the site is released for unrestricted use.
Itemoval of these components clearly does not foreclose the SAFSTOR option since the need to protect the worker, the public and the environment will remain after the components are removed, and until the site has been restored to residual levels permitting unrestricted use of the facility and termination of the license.
Fundamental to this discussion is the fact that either decommissioning alternative, DECON or SAFSTOR is acceptable provided it is implemented in such a way that protects the public, worker and the environment during execution, and ultimately results in release of the facility for unrestricted use. The choice of either alternative will generally be made because of extenuating circumstances surrounding a licensee's unique situation at the time the decision is made to cease power operations and begin decommissioning.
In reality, the decommissioning alternatives defined and evaluated in the GEIS are identical relative to safety objective, environmental impact, and ultimate disposition of the facility. The issue of foreclosure of a particular option should be viewed in the context of ensuring the common safety objectives, and ultimate site release goals are met. 'Ihese objectives can be satisfied for many decommissioning activities, under the POL license authority, and prior to approval of the decommissioning plan.
.Qtwlty Assurqnce Progran)
YAEC will apply the existing quality assurance program requirements as defined in the Yankee Ouality Assurance Program Manual YOOAP 1A, to all applicable portions of the design chance program as currently defined in Corporate, Project and Plant procedures, Page 7
o' Mem'sn
- 1. NUltEG 0586 Final Generic linvironmeltlal impact Statement
- 2. YNPS 1icense Amendment No.108, NYR 88119, dated 6/2/92. )
- 3. YNPS Proposed Change No. 207, FYR 87 095, dated 9/15/87
- 4. Decommissioning Funding Assurance Report and Certification llYR 90-102, dated 7/25/90
- 5. letter to NRC on YNPS Component Removal Activities, IlYR 92109, dated i 11/25/92. ,
- 6. NRC letter to YAIIC transmitting IJcense Amendment No.142 (POL), dated 8/5/92
- 7. NRC letter to YA!!C," Meeting Summary Dise'assion of proposed site work Under 10 CFR 50.59 Prior to NRC Approval of Decommissioning Plan", dated 12/23/92 P
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i EttGhtutte A. Preliminary Component 1(emoval Project Schedule 11 YNPS Organization C. - YNPS Staff Experience Data D. Decommissioning Fund llalance Chart b
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PER VIAN EN I _Y DEFU E _ED ORGANIZAIION '. -
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PLANT SUPERINTENDENT QUALITY .
ASSURANCE I I ADMINISTRATIVE ASSISTANT SERVICES MAINTENANCE SUPERINTENDENT !
HEALTH & _
MECHANICAL _ RADIATION SAFETY MAINTENANCE PROTECTION ADMINISTRATION -
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YNI'S STAFF EXPEILl_ENCE DATA Department Average Individual Years Administration 18.4 Maintenance 18.3 Operations 13.5 Radiation Protection 13.2 Chemistry 18.4 Technical Services 17.6 Quality Assurance 6.0 Notes:
1 This table is based on YNPS organization as of January 1,1993, t
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DECOMMISSIONING TRUST FUND BALANCES MILLIONS MILLIONS . ; -- -300 300 ,
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