ML20135B441
| ML20135B441 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/21/1996 |
| From: | Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9612050022 | |
| Download: ML20135B441 (12) | |
Text
._. _ . . _ - _ . - - . . -
f~0-/ (o p cue
- ~ UNITED STATES E
j t
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
+# November 21, 1996 LICENSEE: Detroit Edison Company FACILITY: Fermi 1 l
SUBJECT:
SUMMARY
OF SEPTEMBER 27. 1996. MEETING REGARDING STATUS OF DETROIT EDISON COMPANY'S PLANS TO DECOMMISSION ITS FERMI 1 FACILITY On September 27, 1996, the NRC staff met with Detroit Edison Company (DECO / licensee) to discuss DECO's plans to decommission its Fermi 1 facility. l Lynn Goodman. DECO's Director of Fermi 1. provided an u)date of her Initial i Decommissioning Project Plan. Ms. Goodman stated that 1er current target date i l
to provide recommended actions related to Fermi 1 to DECO's management was March 1997. NRC staff involvement with Fermi 1 facility could significantly )
increase in the later ) art of 1997, if the results of Ms. Goodman's evaluation !
recommends completing Termi 1 decommissioning over the next several years and DECO's management accepts this recommendation.
As noted in our July 7, 1996. meeting summary. Ms. Goodman had several I concerns that DECO may have problems complying with the recently revised reactor decommissioning rule due to a lack of a "grandfathering" clause in the rule. NRC's final rule revising the reactor decommissioning process was published in the Federal !Legi. ster on July 29. 1996 (61 FR 39278) and became effective on August 28, 1996. The following are DECO concerns areas and the resulting discussions:
- 1. 50.36a - Operating procedures for radwaste and control of effluents be developed. Annual report of effluents at no longer than 12-month intervals.
The licensee's general position was that the Fermi 1 facility shutdown I predates many of the rules. thus Fermi 1 was not and is still not i required to comply with the provisions of 10 CFR 50 that previously did 1 not apply. They believe this is supported by the SAFSTOR license issued in 1989 stating that Fermi 1 is in compliance with the regulations.
Further, the licensee stated that it did not believe that the Commission intended to backfit this requirement as part of revising the reactor decommissioning rule.
The licensee indicated that while it believed that requirements of 50.36a did not apply to Fermi 1. based on the permanent shutdown condition of Fermi 1. DECO already complies with most of the areas that are required by 50.36a. However, the licensee did indicate that there are some areas not covered by its program such as annual reports. The staff's position was that the Commission chose not to grandfather any facilities from any portion of the revised reactor decommissioning regulation. This position was based on the reactor decommissioning rule statement of considerations. Thus, both the licensee and staff agreed J to review the extent of compliance with 50.36a. I 040079 -
l 9612050022 961121 PDR ADOCK 05000016 h h l p PDR
)
i .
- . I i . .
j
! Meeting Summary l I
l 4
i 2. 50.36b - Environmental Monitoring. covered in license.
i ]
Both the licensee and staff agreed that no further action on the l licensee's part was. required for compliance with 50.36b. .
J l 3. 50.48(f) - Fire Protection. - !
- )
The licensee's position was that there was no licensing basis for a t i formal Fermi 1 fire protection program, in that the SAFSTOR license was ,
1 approved without a fire protection program being described in the i j licensing documents it was based on, including the staff's SER. The :
. licensee noted that there are several fire extinguishers located ,
throughout the Fermi 1 facility, but the licensee believes that based on !
the fact that the licensing bases do not include a formal Fermi 1 fire i 4
protection program. DECO is in compliance with the revised reactor j decommissioning rule. The staff did not agree with this position. The staff recommended that DECO review the facility as it exists today to i
! ensure that the material condition of the facility is the same as when l the license was amended to a " possession only" status. The licensee l should confirm that its assumptions related to the impact of fires and 1 i the licensee's ability to respond to a fire are still within the Fermi 1 l licensing bases. The staff stated that fire protection is required, but 4
- the nature of the fire protection should reflect the degree of
- radiological risk associated with Fermi 1 in its current status, and i document why no formal program is needed. The license and the staff agreed that if the decommissioning status of the facility changes, fire protection would need to be readdressed.
4 50.71(e)(4) - Revision tu FSAR every 24 months.
The licensee noted that it did not maintain its Fermi 1 operational licensing bases report current after Fermi 1 permanently ceased operations, on the basis that DECO did not believe it was required to be maintained. Thus, to reconstitute this document would be costly and of little value to safety. The staff pointed out that a FSAR type document is intended to be used as the bases for performing 50.59 analyses. The staff pointed out that since the Commission did not grandfather any facility from the revised reactor decommissioning rule, decommissioning of any former power reactor facility must be accomplished-by the 50.59 process. The licensee noted that its current licensing bases are included in its license by reference. While the staff agreed that the licensee was not required to reconstitute the FSAR at this point in the Fermi 1 life cycle. the staff stated that the licensee must confirm that ,
the reference licensing documents are sufficient to define the current l condition of the facility. Also, both the staff and licensee agreed to evaluate if licensed referenced documents should be used as the bases for performing 50 59 evaluations.
1
)
l Meeting Summary 5. 50.47(a) - Emergency Planning.
The licensee's position was that 50.47(a) clearly indicates 50.47 applies to operating licenses, therefore, it does not apply to Fermi 1. j Also, following the initial decommissioning, no emergency plan was i required. The staff agreed to evaluate if the requirements of 50.47(a) are applicable to Fermi 1.
- 6. 50.54(a) - 0A program, including change process.
The licensee's position was that the Fermi 1 operating license predates the promulgation of Ap3endix B. Thus. Fermi 1 was not and is still not required to comply wit 1 the provisions of Appendix B including a change process. The staff position is that DECO needs some sort of QA program to conduct 50.59 evaluations of decommissioning activities. The staff will evaluate licensee's OA process to ensure that it will be adequate to support Fermi 1 decommissioning.
- 7. 50.54(p) - Safeguards Contingency Plan, including Appendix C of 10 CFR 73.
DECO stated that it believed that the provisions of 50.54(p) were satisfied by virtue of its current security plan which consist of fences. locks, and a site guard service. The staff agreed.
- 8. 50.54(r) on emergency plans if licensed as researcb reactor or test reactor. 50.54(q). 50.54(s). 50.54(t).and 50.54(u) on emergency plans.
See discussion above Item 5.
4
- 9. 50.54(w) - Insurance.
The licensee committed to determine if its site insurance coverage, required for Fermi 2. includes the Fermi 1 facility.
- 10. 50.54(z) - 50.72 reporting.
See related discussion on 50.72. below item 12.
- 11. 50.71(b) - Annual submittal of financial report.
l DECO stated that it believed that the provisions of 50.71(b) were satisfied by virtue of DECO submitting the required information via the Fermi 2 docket. The staff agreed.
- 12. 50.72 - Immediate notification.
The licensee's position was that the provisions of 50.72 or 50.73 do not apply to Fermi 1. The licensee took this position based on the fact i
'. Meeting Summary provided by a former NRC employee. The staff did not agree with this position but did agree to review the TS to determine if DECO's notification process was in compliance with the requirements of 50.72 and 50.73. DECO also agreed to compare the reporting criteria of the Fermi 1 TS to 50.72 and 50.73.
- 13. Appendix R of 10 CFR Part 50 - Fire protection.
DECO stated that it believed that the 3rovisions of Appendix R do not apply to a facility in a permanently slutdown condition, such as Fermi 1. The staff agreed.
Finally, the licensee committed to submit a letter documenting DECO's understanding of its compliance with the new reactor decommissioning rule.
Enclosed with this summary are copies of the licensee's handout (Enclosure 1) and the attendance list (Enclosure 2). The licensee has reviewed a draft version of this meeting summary for accuracy and their comments have been included in this final version.
[0riginal signed by]
Stewart W. Brown. Project Manager Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No. 50-16
Enclosures:
As stated l cc w/encls: See attached list
- SEE PREVIOUS CONCURRENCE DISTRIBUTION: -Central
- File LLDP r/f NMS$ r/f MBell JSurmeier RNelson LBell PUBLIC DOCLMENT IUNE:S:\DWM\LLDP\SWB\ FERMI 9.MTS To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy 0FFICE PM:LLQP f f'l E I SL:LLDP'lEl OGC 3 ,[ /Y g l BQfLDP l[f l TJohnsect',/ '
NAME SBrowM/cVf Stewis JH7ckey DATE 11/;9176 11//d/96 11//y/96 11/ )//96 Official Record Copy , I 0FFICIAL RECORD COPY ACNW: YES .__, No _ IG : YES _ NO Delete file after distribution: Yes No LSS : TES No _
Meeting Summary that Fermi 1 shutdown predates the promulgation of 50.72 and 50.73. Fermi 1 Technical Specifications (TS) include similar requirements, and oral guidance provided by a former NRC employee. The staff did not i agree with this position but did agree to review the TS to determine if l DECO's notification process was in compliance with the requirements of 50.72 and 50.73. DECO also agreed to compare the reporting criteria of the Fermi 1 TS to 50.72 and 50.73. j
- 13. Appendix R of 10 CFR Part 50 - Fire protection.
l DECO stated that it believed that the 3rovisions of Appendix R do not i apply to a facility in a permanently slutdown condition, such as i Fermi 1. The staff agreed. Finally, the licensee committed to submit a letter documenting DECO's understanding of its compliance with the new reactor decommissioning rule. Enclosed with this summary are copies of the licensee's handout (Enclosure 1) and the attendance list (Enclosure 2). The licensee has reviewed a draft version of this meeting summary for accuracy and their comments have been included in this final version.
/j$ e -_-
Stewart W. Brown. Project Manager i Low-Level Waste and Decommissioning i Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No. 50-16
Enclosures:
As stated cc w/encls: See attached list I l
September 18,1996 Initial pecommissionine Pro _iect Plan ; 1 1.) Plan, Plan, Plan before I start. Detailed planning will commence after I assume my new role. I do plan to do some non-radiological housekeeping cleanup during the decommissioning evaluation phase. 2.) Meet with NRC throughout to keep them infomied. , 3.) Establish team for evaluation.
- Modify as needed. ;
- Full and part time members.
4.) Learn the facility and its history
- Extensive walkdowns in the plant.
- Read documentation available on previous decommissioning activities at Fermi 1 and as-left status.
- Research the extent of the radiological characterization of the as-left status.
i
- Talk to all personnel on site who were involved at Fermi l to learn undocumented history.
. - Read about facility and system functions during operation. ;
- Identify state of services (e.g. lighting, power, air, water).
- Evaluate structural stability.
- Consider a party for ex-Fermi 1 employees to again gather information on its past.
- Identify hazards existing at Fermi i from above.
5.) Familiarize NRC with facility. 6.) Communicate with other facilities that are being or have been decommissioned.
- Telephone
- Their documentation, including plans.
- Selected visits.
7.) Learn more about the identified hazards.
- Potential problems.
- How to handle each hazard.
- Whether disposal available.
- Approximate cost to handle.
- What hazards are combined (e.g. contaminated sodium, contaminated asbestos).
8.) Study new rule, existing regulations and rulemaking in progress.
- Submittals, approvals.
- Restrictions on activities and spending.
- Radiological release criteria - new dose based release criteria.
Enclosure 1
September 18,1996 9.) Study previous plant specific decommissioning cost estimate. 10.) Identify and evaluate options for decommissioning i
- Leave in SAFSTOR as planned. l
- Remove radioactivity, terminate license.
- Restricted release.
- Terminate part of site's license.
l
- Remove other environmental hazards.
- Remove other industrial safety hazards. l
- Uses for remaining facilities.
; - Evaluate whether fuel pool would be usable for Fermi 2 fuel.
4 - Look at requirements for risk assessment for members ofpublic. - 11.) Establish documentation and filing system. 1 12.) Identify what services would need to be installed to perform decommissioning. 13.) Identify any unique problems for Fern $i 1 and potential solutions.
- How will operating facility on site affect ability to do release surveys?
- What part of site would be released? Would any part be transferred to Fenni 2 license?
- Impact of decommissioning activities on Fenni 2 - physically, managerially -6d personnel resources.
l
- Will sodium lead to different dismantling or cleanup techniques?
- Maintain use of training facilities for Fermi 2 during decommissioning.
14.) Identify and perform any additional characterization needed. < - Develop characterization plan.
- Perform characterization.
- Determine residualinventory.
- Prepare report.
! 15.) Identify resource (personnel and money) requirements for various options and evaluate. 16.) Select goal /end product based on evaluation.
- Present to management for approval.
17.) Establish decommissioning team.
-Leader - Me -Licensing Expertise -Electrical Engineer
-Radiological Personnel -Structural Engineer -Specialists to tap into
-Femii 1 Expert -Waste Personnel -Industrial Safet/
September 18,1996 18.) Brief Media, including tour of Fermi i 19.) Prepare updated Post Shutdown Decommissioning Activities Report for selected alternative.
- Evaluate various methodologies and techniques.
- Prepare QA, RP, ALARA plans.
- Address any new accident scenarios and provisions for decommissioning activities, including emergency planning.
- Address environmental aspects.
- Submit report and any license amendments to NRC for 90 day review. j 20.) Public meeting on planned activities.
21.) Determine need for and obtain any other permits / approvals.
- Michigan
- Frenchtown
- Waste Disposal (e.g. waste site permit).
- May need waste profiles. l 22.) Prepare waste plan
- See if buyer or recycler for any waste.
- Detennine how to best package waste to save money.
- Detennine waste reduction techniques and equipment.
i l 23.) Prepare detailed work activity plans.
- Discuss with NRC.
24.) Prepare detailed cost estimates. 25.) Develop schedule. l 26.) Determine if mobile laboratory needed. 27.) Detennine release criteria l
- Work with NRC.
28.) Prepare health and safety plan. 29.) Identify and order specialized equipment. 30.) Prepare procedures. 31.) Readiness review.
September 18,1996 32.) Mobilize work force and equipment.
- Determine selection criteria.
- Select personnel.
- Provide training
- Determine and establish radiological controls.
- Install any needed services.
33.) Perform decommissioning.
- Decontamination
- Dismanticment
- Radiation Protection Support.
- Environmental Monitoring.
- Waste volume reduction.
- Waste processing and shipment.
34.) Plan final release survey. 35.) Propose Termination Fian at least 2 years before planned license temiination.
. - Site Charactorrcations.
- Identification of remaining decommissioning activities.
- Plans for site remediation.
- Detailed plans for final radation survey.
- A description of end use of site.
- Updated estimate of remaining decommissioning costs.
- Supplement to environmental report.
- Submit for NRC approval.
- 36) Public meeting.
4
- 37) Demobilize most of work force.
. 38.) Perfomt final release survey. 39.) Prepare and submit final reports
- Final survey report.
- Data package.
- Final project report.
40.) Independent Verification Survey. 41.) License Termination.
_ -.. .. ~_- . - - - . =_ - . . . - - . - - . - _ . .. . .. .. - l
. .. j LIST OF ATTENDEES 1 MEETING WITH DETROIT EDISON REPRESENTATIVES i
4 FERMI UNIT No. I ROCKVILLE. MARYLAND - a i SEPTEMBER 27. 1996 - i ! HMiE AFFILIATION i Lynne Goodman Detroit Edison Company 1
- Peter Marquardt Detroit Edison Company I Michael Weber NRC/MNSS/DWM/LLDP ,
t Larry Bell NRC/NMSS/DWM/LLDP l Richard Dudley NRC/NRR/DRPM/PDND Stephen Lewis NRC/0GC Stewart Brown NRC/MNSS/DWM/LLDP l } l B. Snyder Public Observer I J i l 4
- Enclosure 2 l
i i I
]
~
i ) Detroit Edison Company, Fermi-1 Facility Docket No. 50-16, License No. OPR-9 i Mr. Douglas Gipse (313) 586-5201 Flint Watt, P.E., Chief
- Senior Vice F . dent, Nuclear Bureau of Environmental i Ms. Lynne Good an (313) 586-4097 and Occupational Health
! Director - Termi 1 Michigan Department of Public Health j Mr. Robert Nurcerk (313) 586-4211 , 1 Detroit Edison Company 3423 N. Logan Street ' 6400 North Dixie Highway P.O. Box 30195 Newport, MI 48166 Lansing, MI 48909 (517) 335-8259 i Mr. Ronald C. Callen (517) 334-6245 i Adv. Planning Review Section 1 Michigan Public Service Commission j 6545 Mercantile Way i P.O. Box 30221 i Lansing, MI 48909
-John Flynn, Esq. (313) 237-7725
- ' Senior Attorney Detroit Edison Company i 2000 Second Avenue j Detroit, MI 48226 i Mr. George Bruchmann (517) 335-8200 i Division of Radiological Health i
{ Nuclear Facilities and Environmental j , Monitoring Section Office P.O. Box 30035 i Lansing, MI 48909 1 t Mr. Cornelius O'Keefe (313) 586-2798 U.S. Nuclear Regulatory Commission i Resident Inspector's Office
- 6450 W. Dixie Highway Newport, MI 48166 l _ Monroe County Office of (313) 243-7058
- Civil Preparedness 963 South Raisinville Monroe, MI 48161 i
j Regional Administrator, Region III (708) 829-9657 1 Michael Jordan, Chief Projects Branch No. 7 (708) 829-9637 i U.S. Nuclear Regulatory Commission i -799 Roosevelt Road Glen Ellyn, IL 60137 I J
. Meeting Summary 1 #
provided by.a former NRC employee. The staff did not agree with this position but did agree to review the TS to determine if Deco's notification process was in compliance with the requirements of 50.72 and 50.73. Deco also agreed to compare the reporting criteria of the Fermi 1 TS to 50.72 and 50.73.
- 13. Appendix R of 10 CFR Part 50 - Fire protect' ion.
DECO stated that it believed that the provisions of Appendix R do not apply to a facility in a permanently shutdown condition, such as ' Fermi 1. The staff agreed. Finally, the licensee committed to submit a letter documenting Deco's understanding of its compliance with the new reactor decommissioning rule. Enclosed with this summary are copies of the licensee's handout (Enclosure 1) and the attendance list (Enclosure 2). The licensee has reviewed a draft version of this meeting summary and their comments have been included in this final version. } Stewart W. Brown, Project Manager Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety 4 and Safeguards Docket No. 50-16 , l
Enclosures:
As stated ' cc w/encls: See attached list
*SEE PREVIOUS CONCURRENCE
, DISTRIBUTION: Central File LLDP r/f NMSS r/f MBell JSurmeier RNelson TCJohnson PUBLIC MWeber TJohnson 'p hvW ch k C % DoctaENT IWWE St\DWM\LLDP\SWB\FERM19.MTS / 0 M without I To receive a copy of this document, indicate y the" ox:/fo1" - Copy oIethtb bC
" ' ' 'M g a g'M "E" - Copy with attacKment/ enclosure attachment / enclosure "N" - No copy 0FFICE PM:LLDP ml E SL:LLDP lE OGC, /j ~M BC:LLDP l l j NAIE Strown/c W ) TJohnson SLewis MWeber '
DATE 11/ 4 /96 11/ /% 11//5?96 11/ /96 Official Record Copy ) 0FFICIAL RECORD COPY ACWW YES _,,,_ ho ,_. IG YES _,,_, NO Delete file after distribution: Yes __, No _ LS$ 2 YES ,_. WO _,_,,,,}}