ML20137L104
| ML20137L104 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/03/1997 |
| From: | Brunetti W PUBLIC SERVICE CO. OF COLORADO |
| To: | Jim Hickey NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| P-97022, NUDOCS 9704070155 | |
| Download: ML20137L104 (20) | |
Text
6
,f '
I
!.A e'
Public Service Company of Colorado 55015th Street. Suite 700 Denver,co 802o2425s j
16805 WCR 191/2; Platteville, Colorado 8%51 pgxg303)373 7377 April 3,1997 Fort St. Vrain P-97022 i
U. S. Nuclear Regulatory Commission
)
ATTN: Document Control Desk Washington, D. C. 20555 ATfN:
Mr. John W. Hickey, Chief Decommissioning and Regulatory Issues Branch Docket No. 50-267 SUIUECT:
Proposed License Amendment to Approve Fort St. Vrain License j
Termination Plan, and Request to Terminate Facility Operating License (Possession Only) No. DPR-34
REFERENCES:
1.
PSCo Ixtter, Crawford to Weber, dated November 7,1996 (P-96093) 2.
NRC Letter, Weber to Crawford, dated September 25,1996 (G-96162)
Dear Mr. Ilickey:
This letter is submitted to address several issues related to the process of terminating the Facility Operating License (Possession Only), license number DPR-34, for the Fort St.
Vrain Nuclear Generating Station. In Reference 1, Public Service Company of Colorado (PSCo) requested that a license amendment be issued to terminate this License. After further review of the NRC's recently issued Deconunissioning Rule (61 FR 39278, dated July 29,1996), PSCo is re-submitting our request for license termination as follows:
i 1.
PSCo requests NRC approval of a proposed license amendment to approve the Fort St. Vrain license termination plan.
2.
PSCo hereby withdraws our previous request (Reference 1) to terminate the Fort St. Vrain License via a license amendment.
9704070155 970403 ~
PDR ADOCK 05000267 W
PDR s.
\\\\
s
- hp '
3 P-97022 l
April 3,1997
-Page 2 3.
PSCo requests that the NRC terminate Fort St. Vrain's Facility Operating License (Possession Only), in accordance with the provisions of 10 CFR 50.82(a).
The current status of the Fort St. Vrain decommissioning project is that all physical j
dismantlement arxl decontamination activities have been completed since March 1996. The
{
final radiation survey has been completed and the Final Survey Report was submitted in October 1996. PSCo is currently resolving any remaining issues associated with NRC i
review of the final radiation survey.
In July 1996, the NRC issued a Decommissioning Rule for Nuclear Power Reactors (61 FR 39278), which requires, in part, that licensees submit a license termination plan and that NRC approval of this license termination plan be documented in a license amendment.
PSCo obtained NRC concurrence (Reference 2) that previously approved Fort St. Vrain decommissioning documents satisfied all requirements of a license termination plan, as identified in 10 CFR 50.82(a)(9).
Proposed License Amendment PSCo requests that the NRC approve a license amendment to document approval of the Fort St. Vrain !! ense termination plan, in accordance with the requirements of 10 CFR 50.82(a)(10). Specifically, PSCo requests that a new License Condition No. 2.D.6 be added as follows:
"(6)
All re;gired elements of the Fort St. Vrain license termination plan are included in the approved Fort St. Vrain Decommissioning Plan, the l
approved ' Supplement to Applicant's Environmental Report - Post-Operating i
License Stage - Decommissioning,' and the approved Final Radiation Survey Plan. The Fort St. Vrain license termination plan is approved by License Amendment No. 89."
PSCo's proposed change to Facility Operating License No. DPR 50-267 is included in the j
following attachments to this letter:
j 4
Proposed Change to Facility Operating License Evaluation of No Significant Hazards Consideration The NRC previously stated in the Fort St. Vrain Decommissioning Order, dated November 23, 1992, that decommissioning in accordance with the Decommissioning Plan would be consistent with the regulations in 10 CFR Chapter I, would not be inimical to the common defense and securny or to the heahh and security of the public, and that it would not result
6 o'
l G
P-97022 April 3,1997 i
Page 3 in any significant environmental impact. Also, public notice was provided on March 13, 1992 (57 FR 8940) prior to issuance of the Decommissioning Order, and recently, by Federal Register notice on March 10,1997 (62 FR 10881). PSCo considers that these previous approvals and actions satisfy the requirements of 10 CFR 50.82(a)(10) for i
approval of the Fort St. Vrain license termination plan.
[
f Remaining Open Issues 1
In requesting NRC approval to terminate the Fort St. Vrain license, PSCo recognizes that, l
although decommissioning and final survey activities have been completed, there are four i
remaining open issues, as follows:
The final survey. plan for the liquid effluent pathway has not yet been approved.
PSCo responded on January 31, 1997 to NRC Comments regarding this survey plan, and final resol.ition is expected in April 1997.
NRC review of the Final Survey Report is not yet complete.
PSCo
_l responded on February 27, 1997 to comments regarding this report, and final resolution is expected in April 1997.
The license termination plan has not been approved via a license amendment as required by 10 CFR 50.82(a)(10). A proposed amendment is submitted j
herewith.
l A final quarterly 10 CFR 50.59 report will be submitted to address final reports and comminnents primarily related to conclusion of the radiological environmental monitoring program. This report will be submitted by April 10,1997.
Request for License Termination Upon satisfactory resolution of the four open issues identified above, PSCo considers that all of the NRC's requirements for license termination have been satisfied, as identified in the Decommissioning Rule for Nuclear Power Reactors,10 CFR 50.82(a). Specifically, l
PSCo considers that:
t 1.
Decommissioning activities have been carried out in accordance with the approved FSV Decommissioning Plan and Decommissioning Order, and 1
i i
.i
,5
!)
I P-97022~
April 3,1997 Page 4 l
2.
The Final Survey Report and associated documentation thoroughly i
demonstrate that the Fort St. Vrain Facility and site are suitable for release for unrestricted use.
Additional discussion in support of PSCo's request for license termination is provided in l to this letter.
Based on the satisfactory completion of the NRC's requirements for license termination, PSCo requests NRC action to terminate the Fort St.
Vrain Facility Operating License (Possession Only) as soon as practical, to nunimize j
ongoing costs and obligations associated with current license requirements.
i If you have any questions concerning this submittal, please contact Mr. M. H. Holmes at (303) 571-7633.
Very truly yours, 2a.Ja '
Wa
. Brunetti President and Chief Executive Officer WIIB/SWC Attachments f
cc:
Regional Administrator, Region IV Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Public IIcalth and Environment I
?
e i
i
[
i I
t i
a
1 e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of the Facility Operating License
)
of
)
Public Service Company of Colorado
) Docket No. 50-267 Fort St. Vrain Unit No.1
)
AFFIDAVIT Wayne II. Brunetti, being first duly sworn, deposes and says: That he is President and Chief Executive Officer of Public Service Company of Colorado, the Licensee herein, that he has read the foregoing Application for Amendment to the Facility Operating License and knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge, information nr.J belief.
/bru nr
- Wayne II. Bmnetti President and Chief Executive Officer STATE OF ho or/LdC
)
COUNTY OF
)ehVer
)
Subscribed and sworn to before me, a Notary Public on this 3d day of Agi1
,199].
w Notary Publicf ~
(/
My commission expires
//- f 9
,19ff
e
9 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of the Facility Operating License
)
)
of
)
)
PUBLIC SERVICE COMPANY OF COLORADO )
Application for Amendment to the Facility Operating License License No. DPR-34 OFTHE PUBLIC SERVICE COMPANY OF COLORADO FOR TIIE FORT ST. VRAIN NUCLEAR GENERATING STATION This application for Amendment to the Facility Operating License, License No. DPR-34, is submitted for NRC review and approval.
Respectfully submitted, PUBLIC SERVICE COMPANY OF COLORADO By Wayne H. Brunetti President and Chief Executive Officer Patricia T. Smith Senior Vice President and General Counsel Attorney for Applicant
e 9
ATTACIIMENT 1 TO P-97022 PROPOSED CIIANGE TO FACILITY OPERATING LICENSE (POSSESSION ONLY) No. DPR-34 i
i 1
c '-
O PROPOSED CHANGE TO FACILITY OPERATING LICENSE (POSSESSION ONLY) No. DPP4-34 I
Add New License Condition 2.D.6, as follows:
(6)
All required elements of the Fort St. Vrain license termination plan are included in the approved Fort St. Vrain Decommissioning Plan, the Post-approved " Supplement to Applicant's Environmental Report Operating License Stage - Decommissioning," and the approved Final Radiation Survey Plan.
The Fort St. Vrain license termination plan is approved by License Amendment No. 89.
1 m
9 1
ATTACIIMENT 2 TO P-97022 EVALUATION OF NO SIGNIFICANT IIAZARDS CONSIDERATION I
a
EVALUATION OF NO SIGNIFICANT HAZARDS CONSIDERATION FOR A PROPOSED AMENDMENT TO FACILITY OPERATING LICENSE (POSSESSION ONLY) NO. DPR-34 TO APPROVE THE FORT ST. VRAIN LICENSE TERMINATION PLAN I.
Introduction Public Service Company of Colorado (PSCo) is requesting NRC approval to amend the Fort St. Vrain Facility Operating License (Possession Only) to approve the Fort St. Vrain license termination plan. Approval of this license amendment will satisfy the requirements of 10 CFR 50.82(a)(10), as required prior to actual termination of the License.
Pursuant to 10 CFR 50.91, each application for amendment to an operating license must be reviewed to determine if the proposed change involves a significant hazards consideration.
The NRC has provided standards for determining whether a significant hazards consideration exists, in 10 CFR 50.92(c). A proposed amendment to an operating license i
for a facility involves no significant hazards consideration if the change to the facility in accordance with the proposed amendment would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated, or 2.
Create the possibility of a new or different kind of accident from any accident previously evaluated, or 3.
Involve a significant reduction in a margin of safety.
PSCo has reviewed the proposed license amendment to approve the Fort St. Vrain license termination plan, and has determined that it does not involve a significant hazards consideration. The basis for this determination is provided below.
Evaluation of No Significant Hazards Consideration Page 2 11.
Background
In July 1996, the NRC issued a Decommissioning Rule for Nuclear Power Reactors (61 FR 39278). Two key requirements included in this Decommissioning Rule are:
10 CFR 50.82(a)(9) requires licensees to submit a license termination plan, and 10 CFR 50.82(a)(10) requires that licensees obtain NRC approval of their license termination plan, by a license amendment.
PSCo had undertaken the decommissioning of Fort St. Vrain in advance of the 1996 Decommissioning Rule, and had not developed any one document specifically referred to as a license termination plan. However, the Fort St. Vrain Decommissioning Plan and several other documents had been previously approved by the NRC and satisfied all the elements of a license termination plan identified in 10 CFR 50.82(a)(9). PSCo transmitted a letter on August 22,1996 (Borst to Weber, P-96073), in which PSCo itemized all the requirements of a license termination plan and documented that each requirement was satisfied by a previously submitted and approved document, as follows:
10 CFR 50.82(a)(9)(ii) states that a license termination plan must include:
(A)
A site characterization - Site characterization measurement results are provided in the Fort St. Vrain Decommissioning Plan, Section 3.1, " Facility Radiological Status." The NRC approved this Decommissioning Plan in the Fort St. Vrain Decommissioning Order, issued on November 23, 1992 (Erickson to Crawford, G-92244).
(B)
Idennfication of remaining dismantlement activities - Dismantlement activities are fully described in the Fort St. Vrain Decommissioning Plan, Section 2.3, " Decommissioning Activities and Planning."
(C)
Plans for site remediation - PSCo's plans for site cleanup are described in the Fort St. Vrain Decommissioning Plan, Section 2.3, " Decommissioning Activities and Planning."
(D)
Detailed plans for the final radiation survey - Detailed plans and survey methodologies are fully described in the Fort St. Vrain Final Survey Plan, approved by the NRC on January 26,1995 (Pittiglio to Crawford, G-J020).
,Q-
{
i
~ Evaluation of No Significant Hazards Consideration-j Page 3 i
f (E)
A description of the end use of the site, if restricted - PSCo is requesting.
approval to release' the site for unrestricted use, as supported by the Final j
Survey Report. PSCo has completed the first of a multi-phase project to f
repower the site with natural gas-fired equipment.
Fort St. Vrain f
repowering plans were identified in the Fort St. Vrain Decommissioning l
- Plan, Section 1.1,
" Description of Decommissioning Plan and-l Decommissioning Alternative," and Section 3.4, " Accident Analysis."
i
~(F)
An updated site-specifc estimate of remaining decommissioning costs -
.i Decommissioning cost estimates are provided in the Fort St. Vrain l
Decommissioning Plan, Section 5 " Decommissioning Fixed Price Contract i
and Funding Plan."
(G)
A supplement to the environmental report, pursuant to D51.53, describing l
any new information or sigmpcant environmental change associated with the i
licensee's proposed termination activities - A detailed evaluation of the environmental impacts associated with decommissioning activities is provided in the Fort St. Vrain " Supplement to Applicant's Environmental Report - Post-Operating License Stage - Decommissioning." The NRC j
approved this Supplement and issued a Finding Of No Significant Impac:
with the Decommissioning Order, dated November 23,1992.
(
E
?
).
l As noted above, the approved Decommissioning Plan satisfies most of the elements of a j
license termination plan required by 10 CFR 50.82(a)(9), and the remaining requirements l
i are satisfied by the approved " Supplement to Applicant's Environmental Report - Post-l Operating License Stage - Deconunissioning," and the approved Final Survey Plan. The i
NRC concluded that all required elements of a license termination plan had been satisfied for Fort St. Vrain, in a letter dated September 25,1996 (Weber to Crawford, G-96162).
After the Final Radiation Survey Report was submitted to the NRC, PSCo requested that the NRC terminate the Fort St. Vrain Facility Operating License (Possession Only), by a j
license amendment (PSco letter, Crawford to Weber, dated November 7,1996, P-96073).
J Upon further review of the revised 10 CFR 50.82(a)(10) requirements, it was determined l
more appropriate to reques: that the NRC approve the Fort St.-Vrain license termination j
plan by a license amendment. After approval of this license amendment, and after all i
technical issues have been satisfied, then the Fort St. Vrain license can be terminated j
without additional license modifications.
e L
5
. =
s Evaluation of No Significant llazards Consideration Page 4 III.
Proposed Change PSCo proposes to add a new License Condition 2.D.6, as follows:
t (6)
All required elements of the Fort St. Vrain license termination plan are included in the approved Fort St. Vrain Decommissioning Plan, the Post-approved " Supplement to Applicant's Environmental Report Operating License Stage - Decommissioning," and the approved Final Radiation Survey Plan. The Fort St. Vrain license termination plan is approved by License Amendment No. 89.
IV.
Evaluation of No Significant Ilazards Considerations As described above, all requirements of a license termination plan have been satisfied for Fort St. Vrain by decommissioning documentation that has already been approved by the NRC. Also, opportunity for public comment was offered on March 13,1992 (57 FR 8940), prior to issuance of the Fort St. Vrain Decommissioning Order, and recently by Federal Register notice dated March 10,1997 (62 FR 10881). Approving this license termination plan by a license amendment endorses these previous approvals and satisfies the requirements of 10 CFR 50.82(a)(10).
Therefore, approval of the Fort St. Vrain license termination plan by a license amendment would involve No Significant IIazards Consideration, as described in 10 CFR 50.92, as follows:
1.
Approval of the Fort St. Vrain license termination plan would not involve a I
significant increase in the probability or consequences of an accident previously evaluated. Accident analyses are included in the approved Decommissioning Plan, i
which is part of the license termination plan. Approval of the license termination plan by license amendment does not alter or revise any facility or equipment operating conditions, and would therefore not affect any previous accident analyses.
i Currently, as documented in the Fort St. Vrain Final Survey Report, all radioactive material in excess of the Fort St. Vrain site release criteria has been removed from i
the facility. None of the radioactive materials involved in accidents analyzed in the Decommissioning Plan remain on-site, and therefore there is no possibility of a significant increase in the probability or consequences of an accident previously evaluated.
Evaluation of No Signincant
' Hazards Consideration Page 5 2.
Approval of the Fort St. Vrain license termination plan would not create the possibility of a new or different kind of accident from any accident previously evaluated. Approval of the license termination plan by license amendment endorses previously approved plans and activities, does not introduce any new or different activities or processes, and does not create the possibility of a new or different kind of accident from accidents previously evaluated.
Currently, as documented in the Fort St. Vrain Final Survey Report, all residual radioactive material complies with the site release criteria. All credible future-use scenarios have been evaluated and determined to result in no personal exposures greater than the site release criteria (i.e.,10 mrem per year, as identined in Section 3.3 of the Fort St. Vrain Final Survey Plan for the soil and water pathway), and no new or different plant operating modes or facility uses are created.
3.
Approval of the Fort St. Vrain license termination plan would not involve a signincant reduction in a margin of safety. Approval of the license termination plan by license amendment does not affect in any way the previously approved plans or the previously completed site activities associated with releasing the Fort St. Vrain facility for unrestricted use.
As documented in the Final Survey Report, all site release criteria were satis 6ed, with considerable margin.
The Final Survey Report provides graphical representations of total surface activity, residual surface activity, and exposure rate measurements, and the results clearly indicate that residual radioactive material remaining at the Fort St. Vrain facility is well below the site release criteria.
Based upon the preceding evnluation, PSCo has determined that approval of the Fort St.
Vrain license tennination plan by a license amendment, as proposed herein, does not involve a Significant liazards Consideration as described in 10 CFR 50.92(c).
i Environmental Evaluation PSCo also determined that approval of the Fort St. Vrain license termination plan by a license amendment will not result in any signincant environmental impacts, consistent with the NRC's Ondings in the Fort St. Vrain Decommissioning Order.
l i
i 6
h i
as.-
e+,er,#eu mee e-vi--m' re p--
w c-
=
+w e'su
-e we-mui
v.
t l
l i
i ATTACHMENT 3 TO P-97022 I
TERMINATION OF THE FORT ST. VRAIN FACILITY OPERATING LICENSE (POSSESSION ONLY)
LICENSE NO. DPR-34 s
\\
TERMINATION OF THE FORT ST. VRAIN FACILITY OPERATING LICENSE (POSSESSION ONLY)
- LICENSE NO. DPR-34 I.
Introducdan i
Public Service Company of Colorado (PSCo) is requesting NRC action to terminate the Fort St. Vrain Facility Operating License (Possession Only). This evaluation provides additional information and justification for this request. PSCo considers that regulatory and license requirements have been satisfactorily completed, as described in the following discussion.
II.
Background
The Fort St. Vrain Nuclear Generating Station was the first and only commercial-sized High Temperature Gas-Cooled Reactor in the United States. Its initial criticality occurred in 1974 and it generated electricity from 1976 through 1989.
In August 1989, the Fort St. Vrain Nuclear Generating Station was sliut down for the final time, due to failures in control rod drive mechanisms and steam generator ring headers. In November 1990, PSCo submitted a Proposed Decommissioning Plan, and requested NRC approval of the early dismantlement (DECON) decommissioning alternative. As part of the Foposed Decommissioning Plan, PSCo indicated its plans to re-power the generating station with natural gas-fired equipment.
The DECON alternative for decommissioning Fort St. Vrain involved five major activities:
1.
Removal of the Prestressed Concrete Reactor Vessel (PCRV) internal radioactive components remaining after defueling the reactor.
2.
Decontamination and/or dismantlement of those portions of the ICRV structure and radioactive balance-of-plant systems which exceed limits for unrestricted release of residual radioactive materials.
3.
Shipment of all radioactive waste off-site for disposal.
4.
Completion of a final site radiation survey to confinn that all site areas can be released for unrestricted use.
5.-
Termination of the 10 CFR 50 operating license.
Ev' luation of License Termination a
Page 2 i
Possession Only License In recognition of PSCo's decision to permanently shut down the Fort St. Vrain Nuclear Generating Station, the NRC issued a " Possession Only" amendment to the Facility Operating License in May 1991, authorizing PSCo to possess but not operate the Fort St. Vrain nuclear facility.
l Spent Fuel Disposition Before decommissioning could begin, all spent nuclear fuel had to be removed from the Prestressed Concrete Reactor Vessel (PCRV). PSCo licensed and constructed an Independent Spent Fuel Storage Installation (ISFSI), in accordance with the requirements of 10 CFR 72.
Fort St. Vrain's spent fuel was transferred to the ISFSI from December 1991 to June 1992.
In February 1996, the Department of Energy assumed title to Fort St Vrain's spent fuel, and undertook the process of transferring the license for this facility from PSCo to the Department of Energy.
Decommissioning Authorization in November 1992, the NRC approved the Fort St. Vrain Decommissioning Plan and issued a Decommissioning Order authorizing PSCo to decommission the Fort St. Vrain Nuclear Generating Station. This Order stated that the Decommissioning Plan replaced the Safety Analysis Report in its entirety, and that PSCo was authorized to (i) make changes in the facility or procedures as described in the Decommissioning Plan and (ii) conduct tests, or experiments without prior NRC approval provided they did not involve a change in the Decommissioning Technical Specifications or an unreviewed safety question. A quarterly report describing any such changes, tests, or experiments, including a summary of the safety evaluations, was also required by the Order. In addition to the requirements of the Order, PSCo has provided annual updates to the Decommissioning Plan throughout the decommissioning project.
Satisfaction of Decommissioning Technical Specification Requirements The Fort St. Vrain Decommissioning Plan analyzed eight postulated accidents that could potentially have resulted in radiation exposures to members of the public at the site boundary, as follows:
i Contaminated concrete rubble drop Conversion (re-powering) construction near PCRV dismantlement lleavy load drop Fire Loss of PCRV shielding water
Evaluation of License Termination Page 3 y
Loss of power Natural disasters Steam generator primary module drop l
l In order to maintain site boundary doses less than a small fraction of the EPA Protective-4 Action Guidelines, certain of these postulated accidents relied upon plant features such as Reactor. Building filtered ventilation and confinement-integrity.
The Decommissioning Technical Specifications were written to ensure operability of essential plant equipment for as j
long as it was relied upon by the accident analyses, and to then permit an orderly reduction in l
requirements and eventual dismaatlement of associated equipment, as necessary. Specifically, the transition out of Decommissioning Technical Specification requirements occurred as l
i follows:
i LC 3.1, Reactor Building Confinement Integrity, was maintained as long as activated j
graphite components remained within the Reactor Building. These requirements were j
l satisfied and the Limiting Condition was exited on April 11,1994.
i LC 3.2, Reactor Building Ventilation Exhaust System, was maintained as long as activated graphite components remained. within the Reactor Building.
These j
requirements were satisfied and the Limiting Condition was exited on April 11,1994.
i LC 3.3, Radiation Monitoring Instrumentation, was maintained as long as material l
I remained within the Reactor Building that could exceed the most limiting monitor i
setpoint of 15 mR/hr, Radioactive material that could exceed this setpcint was removed from the Reactor Building and the Limiting Condition was exited on June l
i.
24,1996.
i
)
LC 3.4, PCRV Shield Water Tritium Concentration, was maintained as long as shield 4
water remained within the PCRV. The last shield water was released from the PCRV and the Limiting Condition was exited on October 17,1995.
l AC 5,11, Natural Gas Restriction, was maintained as long as activated graphite components remained within the Reactor Building. These requirements were satisfied 4
and the Limiting Condition was exited on April 11,1994.
l t
It is also noteworthy that the Decommissioning Plan projected the expenditure of 433 person-l
_ Rem, with an estimated time in radiologically controlled areas of 233,100 person-hours. The c
Westinghouse Team implemented a very effective program to keep occupational doses as low as reasonably. achievable (ALARA), and the actual cumulative exposure was 380 person-Rem, while actual time in radiologically controlled areas substantially exceeded the original l
estimate at over 800,800 person-hours, j
I 1
p>
i Ev'aluation of License Termination Page 4 Final Survey Plan Although the Decomtra, !oning Plan included a chapter describing PSCo's plans for conducting a final radiation survey, a more detailed plan was submitted for NRC approval, using the guidance in Draft NUREG/CR-5849. The Fort St. Vrain Final Survey Plan was submitted in February 1994 and was approved in January 1995.
The Final Survey Report documents that the Fort St. Vrain facility has been decontaminated and satis 0es the acceptance criteria for unrestricted use. There are approximately 220,000 final measurements included in the Final Survey Report, and the total number of survey measurements, including characterization surveys, investigation surveys, and remediation surveys, is over 400,000 measurements. The Final Survey Report was submitted in three phases, on May 31, August 9, and October 30, 1996.
With the completion of these submittals, PSCo considers that (as required for license termination by 10 CFR 50.82(a)(11)):
1.
Deconunissioning activities have been carried out in accordance with the approved FSV Decommissioning Plan and Decommissioning Order, and 2.
The Final Survey Report and associated documentation thoroughly demonstrate that the Fort St. Vrain facility and site are suitable for release for unrestricted use.
III.
Evaluation of License Termination As described above, the completion of decommissioning and the final radiation survey report demonstrates that:
Final site release criteria have been met, There are no remaining radiological hazards, There are no more possible accidents that could result in radiation exposures to members of the public (including potential future site workers) in excess of site release criteria, There are no more radiological liquid or gaseous effluents to release, and There are no more solid radioactive waste materials to release.
PSCo and the NRC are not planning to terminate the Fort St. Vrain Facility Operating License (Possession Only) by an amendment, and therefore, an evaluation of the actual license termination for No Significant Ilazards Considerations is not required by 10 CFR 50.91. Since termination of the license is a major licensing action, and as a further measure of the acceptability of this action, PSCo has determined that it would involve No Significant llazards Considerations, as described in 10 CFR 50.92, as follows:
0 Evaluation of License Termination Page 5 1.
Termination of the license would not involve a significant increase in the probability or consequences of an accident previously evaluated, because all radioactive material in excess of the Fort St. Vrain site release criteria has been removed from the facility.
None of the radioactive materials involved in accidents analyzed in the Decommissioning Plan remain on-site, and therefore there are no previously evaluated accidents that could result in radiation doses.
2.
Termination of the license would not create the possibility of a new or different kind of accident from any accident previously evaluated because all residual radioactive material complies with the site release criteria. All credible future-use scenarios have been evaluated and determined to result in no personal exposures greater than the site release criteria (i.e.,10 mrem per year, as identified in Section 3.3 of the Fort St.
Vrain Final Survey Plan for the soil and water pathway), and no new or different plant operating modes or facility uses are created.
3.
Termination of the license would not involve a significant reduction in a margin of safety because all site release criteria were satisfied, with considerable margin. The Final Survey Report provides graphical representations of total surface activity, residual surface activity, and exposure rate measurements, and the results clearly indicate that residual radioactive material remaining at the Fort St. Vrain facility is well below the site release criteria.
The Fort St. Vrain facility will remain within the PSCo system as an operating generating
^
station. The re-powering project is well underway with the first natural gas-fired combustion turbine already in commercial service, generating about 130 MW. Installation of a heat recovery steam generator is also in progress. The final condition of the entire Fort St. Vrain facility, including the Reactor Building and previously contaminated areas, is suitable for unrestricted use.
]
Based upon the preceding evaluation, PSCo has determined that termination of the Foo St.
Vrain Facility Operating License (Possession Only) does not involve a Significant Hazards I
Consideration as described in 10 CFR 50.92(c).
Environmental Evaluation PSCo also determined that termination of the Fat St. Vrain Facility Operating License (Possession Only) will not result in any significant environmental impacts, consistent with the NRC's findings in the Fort St. Vrain Decommissioning Order.