ML20128L337

Responds to to Chairman Selin Expressing Concerns Re Issues on Decommissioning of Facility

ML20128L337
Person / Time
Site:	Yankee Rowe
Issue date:	02/12/1993
From:	Murley T Office of Nuclear Reactor Regulation
To:	Hodgkins C MASSACHUSETTS, COMMONWEALTH OF
Shared Package
ML20128L341	List: ML20128L337 ML20128L354
References
NUDOCS 9302190190
Download: ML20128L337 (2)

Text

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February 12, 1993 The Honorable Christopher J. Hodgkins Hassachusetts House or' Representatives Room 34, State House Boston, Massachusetts 02133

Dear Mr. Hodgkins:

I nn responding to your Jetter of January 19, 1993, addressed to Cnairman Selin, in which you expressed concern about issues related to the decommissioning of thf Yankee Nuclear Power Station.

You wrote in support of the Citizens Awareness Network (CAN) of Shelburne Falls, Massachusetts. CAN has sent two letters to the U.S. Nuclear Regulatory Commission (NRC) to discuss its concerns over those issues at Yankee.

In responses of December 29, 1992, and January 14, 1993, (copies enclosed) the NRC discussed its review of emergency planning issues, potential accidents (including i

seismic events) related to the spent fuel pool, its findings related to current site activities, and exemptions issued by the NRC since the plant was permanently shut down.

In your letter, you raised concern that the licensee, Yankee Atomic Electric Company, has not yet filed a decommissioning plan with the NRC. Our regulations require the licensee to file this plan within 2 years of the date on which the licensee notifies the NRC of permanent cessation of operations, (February 27, 1992).

Therefore, by regulation, the plan is required by February 1994.

The licensee plans to submit the 31an late in 1993. When received by the NRC, the plan will be available tirough our Public Document Room in Greenfield, Massachusetts to any interested party.

In the interim, the NRC will review and oversee any activities at the site related to removal of major components, should the licensee decide to undertake such work in advance of decommissioning plan approval.

In the January 14, 1993 letter to CAN, the NRC stated that it will hold a public meeting in the area of the plant in the near future. We would welcome attendance by you or your staff, if you are interested in attending, please notify the NRC Project Manager, Morton Fairtilo at (301) 504-1442, who will give you a copy of the meeting notice once the schedule and location are finalized.

Sincerely, Original signed by Thctsa E. br1 oy has E. Mey, h@

9302190190 93 PDR COMMS NR Office of Nuclear Reactor Regulation CORRESPONogucg pyg

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NUCLEAR REGULATORY COMMISSION W ASHINoTON. D.C. XWIS December 29, 1992 CHMRMAN Ms. Gail D. Steinbring President Citizens Awareness Network P.O. Box 83 Shelburne Falls, Massachusetts 01370

Dear Ms. Steinbring:

l On behalf of the Commission, I as responding to your letter of November 2, 1992, in which you raised a number of concerns about the Yankee Nuclear Power Station and about the Nuclear Regulatory Commission's interactions with the nuclear industry, l

The issues of whether Yankee Atomic personnel pressured the NRC staff to approve very relaxed " restart criteria" for the Yankee Rowe facility and relaxed embrittlement standards for the nuclear industry as a whole, and whether Yankee Atomic was allowed to edit Generic Letter (GL) 92-01 in such a way as to delete any refer.nce to Yankee's attempts to minimize NRC scrutiny of reactor vessel embrittlement have elready been addressed by the NRC staff l

in a letter dated June 22, 1992, to the Union of Concerned Scientists.

I am enclosing a. copy of the letter for your information. The Commission is satisfied with the staff's handling of these matters.

With respect to the decision by the NRC staff to permit Yankee to terminate its off-site emergency plan, the staff's review of this action was very extensive and included five rounds of requests for additional information related to accident analyses. The staff not only reviewed credible accidents related to Yankee Rowe in its shutdown and defueled status but also examined i

the effects of releases beyond design basis events; for example, releases resulting from postulated water loss from the spent fuel pool. During the Systematic Evaluation Program of older plants, com)leted for Yankee in 1987, the staff confirmed that the seismic analysis of t1e fuel pool was adequate, l

in the most recent review, the staff found that because of the time elapsed l

since shut down and the low density of fuel storage, the off-site consequences I

of even beyond-design-basis events would result in off-site exposures of less l

than the Environmental Protection Agency Protective Action Guidelines.

In l

addition, th6 staff concluded that the Defueled Emergency Plan (DEP) provides l

an acceptable emergency-program for the Yankee Nuclear Power Station in its permanently shut down status and reasonable assurance that adequate protective l

measures can and will be taken in the unlikely event of a radiological accident at the facility. The DEP requires the licensee to maintain a substantial emergency preparedness staff and agreements with off-site

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organizations such as medical facilities and police and fire departments until such time as the reactor fuel is removed from the spent fuel storage pool.

S We have reviewed your comment "that the reactor is being allowed to carry i

l on a wide range of decontamination techniques, many of which continue to o

release radionuclides into the Deerfield River."

The decontamination P

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methods which have been used at Yankee have resulted either in solid waste products that cannot reach the river or in liquid wastes that are processed through the existing Radwaste System in compliance with NRC requirements. The Itcensee maintained an excellent record of compliance with NRC rnulations regarding airborne and liquid releases to the environment while tae plant was in operation. Now that the plant is shut down, all pre-decommissioning 1

activities have:been undertaken under the same radiological controls andt i

gaseous _ and liquid effluent release criteria as those Ln effect when the plant was in operation.

The NRC recently reviewed the licensee's liquid effluent release data from July 1991 through November 1H2 and concluded that 11guld,

l releases during this period were well below allowa,ble limits.- The NRC a'se-i reviewed the 19g1 Radiation Environmental Program documentation and noted neither abnormal levels of radioactivity nor any-adverse trends to the a

environment.

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.You also urged the NRC to completely address potential reactor vesself

-i embrittlement problems at other operating nuclear plants in the United States.

J We are already in the process of doing so. As a result of our evaluation of-the Yankee Rowe vessel, the staff issued GL 92-01 to all reactor licensees.

This generic letter is only part of a larger ongoing program that will ensure that licensees are complying with existing reou ations and_ other NRC guidance-such as GL 88-11, 'NRC Position on Radiation Embrittlement of Reactor Vessel-Materials and its !apact on Plant Operation."

j Regarding your request that we halt any further decontamination work' at Ysnken and hold full public hearings,'you should be aware that.in the past'four.-

months, the NRC has issued six license amendments to-Yankee and has publi_cly.

noticed a seventh.

Each _of these actions has provided the public an 1

opportunity to intervene.or coment. We have not~ received any comments or petitions to intervene.- As required by our regulations NRC also confers with 4

the Comonwealth of Massachusetts State Liaison-Official before the NRC staff f

issues such license amendments. We are considering a public meeting in the vicinity of the plant early in 1993 to provids:information to the public on-r NRC's review of decomunissioning in general-and'on expected site activities:

which will occur prior to the licensee's submittal of a decosmissioning-plan j

in late-1993.

I hope these comments have helped to resolve your concerns.

If you have further questions, members of the NRC staff are available to discuss these J

issues in more detail. As a starting point,-you may want to contact Morton 8. Fairtile, the NRC Project Manager _.for the Yankee Rowe facility, at (301)504-1442.

Sincerely, Kenneth-C. Rogers p

Acting Chairman h

Enclosure:

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NRC letter of June 22, 1992

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January 14, 1993 Hs. Gail D. Steinbring President Citizens Awareness Network P.O. Box 83 Shelburne Falls, Massachusetts 01370

Dear Ms. Steinbring:

I am responding to your letter of December 21, 1992, addressed to.

Chairman Selin, in which you expressed concern about. Issues regarding the Yankee Nuclear Power Station-(Yankee), some of which you raised in your

)revious letter of November 2,1992. On December 29, 1992, the U.S. Nuclear Regulatory Commission (NRC) issued its response to your November 2 letter after carefully reviewing the issues you discussed.

The week before we received your December 21, 1992 letter, a re)resentative of the Citizens Awareness Network (CAN) contacted the NRC by telepione and requested that CAN be add to the NRC Service List; you also mentioned in your letter that you wanted to receive documents-in a timely fashion. On December 15, 1992, the NRC added CAN to the NRC Service List for-Yankee.

In your letter you expressed concern about notification of the public on proposed exemptions.

For most exemptions that were issued to Yankee to date, the NRC, in accordance with 10 CFR Part 51 of the NRC regulations,.publi'hed an Environmental Assessment (EA), prior to issuance of the exemptions.

However, exemptions related to insurance, indemnity or safeguards do not.

require an EA.

You will receive EAs in the future through the inclusion of CAN on the NRC Service List.

Documents issued by the licensee may be obtained from the local public document room (LPDR) in Greenfield, Massachusetts. The manager of our LPDR Program has informed my staff that microfiche and microfiche address summaries will be available at the LPDR within 2 to 3 weeks after the NRC headquarters-1 staff receives a submittal.

If you have access problems, you may call. the LPDR Programs at NRC headquarters at 1-800-638-8081, a toll free number.

In your December 21, 1992 letter, you expressed a concern about exemptions issued by the NRC to Yankee for cert ain programs at the plant.

In our response to the November 2, 1992 letter, we discussed our bases for issuing _

the emergency preparedness exemptiens.- We have-also issued e.xemptions for'.

containment leak testing, updates to the final safety analysis. report, and the-

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safeguards. program. =You requested that we rescind all recently approved exemptions and halt reactor dismantling until a decommissioning plan is approved. Before-issuing these exemptions, the NRC performed extensive safety and environmental reviews to ensure that the reliefs maintained adequate

' levels of public health and safety and environmental. protection. -We considered the permanently shutdown and defueled status of the plant. The NRC has issued similar exemptions to the licensees for the Fort St. Vrain, Rancho Seco, and Shoreham~ plants when these plants were in the same phase of 1

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Hs. Gail D. Steinbring January 14, 1993 the decomissioning process as Yankee is now.

Your two letters do not contain any new information that would prompt us to reopen those reviews.

1 You also raised a concern about the NRC signaling Yankee that it may begin dismantling the reactor and shipping highly radioactive components offsite.

While one of the components, the reactor internals, that Yankee wants to ship l

to a low-level waste disposal facility is " highly radioactive" it still qualifies as low-level waste.

Similar components have been shipped by Yankee and other licensees in the past, as have been steam generators. With respect to licensee plans for removal of such components, the NRC staff has requested in its letter of December 15, 1992, and in the meeting summary of December 23, 1992, more detailed information about the proposed licensee activities in this area.

Both documents are enclosed. The information requested from the licensee includes an analysis of pre-decommissioning activities to demonstrate that they are within the bounds of the NRC Final Generic-Environmental Statement and an evaluation of how the proposed component-removal process would not preclude decommissioning alternatives nor future unrestricted site access.

In your second letter you reemphasized your desire for a public hearing on decommissioning issues at Yankee. We plan to have a public meeting in the local area when we have received the requested information. The NRC project manager will keep you apprised of our plans for this meeting.

My staff is available to discuss these or other concerns that you may have.

You may contact Morton B. fairtile, the NRC Project Manager for this facility, at (301) 504-1442.

Sincerely,

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Office of Nuclear Reactor Regulation

Enclosures:

1.

NRC Letter of December 15, 1992 2.

Heeting Summary of December 23, 1992 L

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Ms. Gail D. Steinbring January 14, 1993 the decomissioning process as Yankee is now.

Your two letters do not contain any new information that would prompt us to reopen those reviews.

You also raised a concern about the NRC signaling Yankee that it may begin dismantling the reactor and shipping highly radioactive components offsite.

While one of the components, the reactor internals, that Yankee wants to ship to a low-level waste disposal facility is " highly radioactive' it still qualifies as low-level waste.

Similar components have been shipped by Yankee and other licensees in the past, as have been steam generators. With respect to licensee plans for removal of such components, the NRC staff has requested in its letter of December 15, 1992, and in the meeting sumary of December 23, 1992, more detailed information about the proposed licensee activities in this area.

Both documents are enclosed. The information requested from the licensee includes an analysis of pre-decomissioning activities to demonstrate that they are within the bounds of the NRC Final Generic Environmental Statement and an evaluation of how the proposed component removal process would not preclude decomissioning alternatives nor future unrestricted site access.

In your second letter you reemphasized your desire for a public hearing on decomissioning issues at Yankee. We plan to have a public meeting in the local area when we have received the requested information. The NRC project manager will keep you apprised of our plans for this meeting.

My staff is available to discuss these or other concerns that you may have.

You may contact Morton B. Fairtile, the NRC Project Manager for this facility, at (301) 504-1442.

original stEned by Sincerely, IhmasI.1htrier, Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1.

NRC Letter of December 15, 1992 2.

Meeting Summary of December 23, 1992 DISTRIBUT10N:[STEINB2.MBf] (Action diskette-lb)

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December 15, 1992 Docket No.50-029 Dr. Andrew C. Kadak, President and Chief Executive Officer Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398

SUBJECT:

COMPONENTREMOVALACTIVITIESATTHEYANKEENUCLIARPOWERSTATION I am responding to your letter of November 25, 1992, addressed to Dr. Hurley, in which you outlined Yankee Atomic's program to remove and dispose of radioactive components at your facility prior to NRC approval of your decomissioning plan.

As you are aware, the Comission has these issues under current review and we anticipate that the Comission 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 mceting sumary 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 components or structures.

Sincerely,

_ _ -N Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation cc:

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Deceber 23, 1992 Docket No.50-029 LifENSEE:

YANKEE ATOMIC ELECTRIC COMPANY i

FACILITY:

YANKEE NUCLEAR POWER STATION-

SUBJECT:

MEETING

SUMMARY

- DISCUSSION OF PROPOSED SITE WORK UNDER 10 CFR 50.59 PRIOR TO NRC APPROVAL OF DECOMMISSIONING PLAN meeting at the NRC headquarters in Rockville,t their request, came in for a On Tuesday, December 8, 1992, the licensee a Maryland to discuss the subject topic.

The meeting, primarily, was a presentation by the' licensee covering-the following agenda:

Activities in Progress Implementation of Changes Interaction with NRC Access to Funds The licensee used the enclosed set of slides (Eoclosure 1) in the '

presentation.

James Partlow, NRR Associate. Director for Projects, opened the meeting by-stating that the work the Itcensee may perform prior to staff approval of the Decommissioning Plan (D-Plan) is still under policy review and development by the Comission.

The licensee is planning to remove, prior to approval of the D-Plan, the following components under the -provisions of.10 CFR 50.59:

the reactor pressure vessel internals, the four steam generators, and the ptessurizer.

The staff requested that the following additional information be submitted to the-NRC:

l (1)

An analysis of pre-decommissioning activities demonstrating that the environmental impacts of such activities, when integrated with planned decommissioning activities, are within the bounds of the l

' Final Generic Environmental Impact Statement.." published by the' l

NRC in August.1988 as NUREG-0586.

(2)

An ovaluation of how the proposed component removal process under 10 CFR 50.59 would not preclude decommissioning alternatives, including.the objective of futura unrestricted access to.the site.

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(3)

A letter providing data on future facility staff size and staff qualifications, in particular Health Physics staff and Management staff.

(4)

A detailed descriptien of the design change (EDCR) method, and the ALARA (radiation protection) program.

(5)

Plans and schedules for site work proposed prior to approval of the D-Plan and the funding plan to cover this interim site work (including cost estimates).

An attendance list is provided as Enclosure 2.

hhv.4. Tmshfo Norton B. Fairtile, Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

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u Hs. Jane M. Grant Yankee Rowe Docket No. 50-29 CC:

Dr. Andrew C. Kadak, President Mr. David Rodham, Director and Chief Executive Office ATTH: Mr. James B. Huckerheide Yankee Atomic Electric Company Massachusetts Civil Defense Agency 580 Main Street 400 Worcester Road Bolton, Massachusetts 01740-1398 P. O. 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. H. St. Laurent Plant Superintendent Executive Director Yankee 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 Citizens Awareness Network U.S. Nuclear Regulatory Commission P. O. Box 83 P. O. Box 28 Shelburne Falls, Massachusetts 01370 Honroe Bridge, Massachusetts 01350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Robert H. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 305 South Street Boston, Massachusetts 02130 Commissioner Richard P. Cedano Vermont Department of Public Service 120 State Street, 3rd Floor Montpelier, Vermont 05602 Mr. Jay K. Thayer Vice President and Manager of Operations Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398

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SUCH AS SITE CHARACTERIZATION, FINAL SURVEY o, -

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'4:

-g,y i s3 ii Yankee Atomic'Meetine list of Attendees December 8; 1992 HAst Oroanization Jim Partlow

-NRC/NRR Associate Directori

. Mort-Fairtile

NRR/ DORS /0NDO

L. Cunningham NRR/PRPB Bob Wood NRR/ILPB' Stewart Brown NRR/0NDD Dan O'Neal NRR/DNDD Pete.Erickson NRR/0NDD Rtchard Dudley

--NkC/NRR, Larry Bell NRR/NMSS i

John-Austin NRR/NMSS Ed Reis-

-NRC/0GC Joseph Nick NRC/ Reg I/DRSS/FRPS; Neil Perry NRC Region I-SRI: Yankee Rowe H.-T.1Tracy Jr.

' Yankee Atomic J..K.1Thayer

-Yankee Atomic-Russell A. Mellor

. Yankee Atomici K. J. Heider:

-Yankee Atomic-Jane M. Grant

. Yankee-Atomic Patrick Sheldon:

Yankee Atomic Theresa Meisenheimer Bechtel/SERCHf Judith Sikorski Bechtel/SERCH Gene Gena Winston & Strawn r

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EDO Principal Correspondence Control FROM:

DUE:

EDO CONTROL: 0008514 DOC DT: 01/19/93 FINAL REPLY:

Christopher J. Hodgkins Meccachusetts House of Represtentatives TO:

Chairman Selin FOR SIGNATURE OF:

• • GRN CRC NO: 93-0063 DESC:

ROUTING:

REQUEST FOR PUBLIC HEARINGS TO DISCUS"-

"H E Taylor DECOMMISSIONING PROCESS FOR YANKEE ATOMIC Sniezek Thompson DATE: 01/20/93 Blaha Knubel ASSIGNED TO:

CONTACT:

Bernero, NMSS NRR Murley TTMartin, RI Kammerer, SP SPECIAL INSTRUCTIONS OR REMARKS:

Scinto, OGC FOR APPROPRIATE ACTION O l '!L

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i OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET t

PAPER NUMBER:

-CRC-93-0063 LOGGING DATE: Jan 28 93 ACTION OFFICE:

EDO AUTHOR:

CHRISTOPHER HODGKINS AFFILIATION:

MA (MASSACHUSETTS)

ADDRESSEE:

CHAIRMAN SELIN LETTER DATE:

Jan 19 93 FILE CODE: IDR-5 YANKEE ATOMIC

SUBJECT:

REQ FOR PUBLIC HEARINGS TO DISCUSS THE DECOMISSIONING PROCESS FOR YANKEE ATOMIC ACTION:

Appropriate DISTRIBUTION:

CHAIRMAN, COMRS, OGC, DSB, RF SPECIAL HANDLING: NONE CONSTITUENT:

NOTES:

DATE DUE:

SIGNATURE:

DATE SIGNED:

AFFILIATION:

acc't Off. EDO

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