ML20138L123

Smud Rancho Seco Incremental Decommissioning Action Plan, Rev 0,961113

ML20138L123
Person / Time
Site:	Rancho Seco
Issue date:	11/13/1996
From:	Redeker S SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20138L112	List: ML20138L109 ML20138L123
References
NUDOCS 9702210072
Download: ML20138L123 (16)

Text

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} Sacramento Municipal Utility District j Rancho Seco '

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i i Incremental i l Decommissioning Action .

i Plan .

$ Revision 0 l November 13,1996 f

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l l Approved:

I Steve J. Redeker l Manager, Plant Closure &

) Decommissioning I

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f 9702210072 970129

, FAR ADOCK 050n0312 l W PDR

TABLE OF CONTENTS SCOPE -

3 PECOMMISSIOMMG rrRATEGY 4 INCnen._adiAL- Y --~aG=WC r_m m-,mATM3N .

5 m ean ,_; --MAL V - 3 -

5 APPLICABLE DOCIREnl 6 ORGANIZATION 6 Sm 6 l PaconAM MAMEBWFr 7 i MANAGM, FLANIC1400ES AlWDECO ' o *i- 7 INCREMENTALWTEAMLEADER 7 PLANNING ANDSCPFMILING 8  !

i i STAFF TRAINING -

S ORGANIZATIONAL RESPONSIML(TUS FOR INCREMENTAL DECOMMISSIONING 8 I

, RADIATION PastICrust 8

. MAINTENANG 9 i TECEMCALSEIMCIS 9

! OPERATIONS 10 l

TRADGNG ,. 10  ;

QUALITY AssunaNc3 10 '

LICENSING 10 l Sm DocUMINrCoerInot 11 l SEcuarrY 11 4

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lacremental Decommianlaning Action Plan i

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a PROGRAMS ANDPWem 11 l

l RADIOIDGICALCOstIn0IsPacemans 11 4 RADWASTE CONIBOLPROGRABE 12 l FROCEas CONIBOLPRDWAtt . 12 j PHYSICAL PacIECnon, AND TRAmegeG AND QUAURCATION FIans 12 j RANCHO SECOQuauryMANUAL 13 l DECONOngeGPIm 13 PROCEDURES 13 1

i. Trn,ccAL AIG **"ETY =V- - AW-Eii 13

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! CRAME SAFETY 13

OCCUPATIONAL 5amBW 14 IJLADANDOnunToincCuzases 14

} Assestos 14 i CONFIGURATIONCONIBOL 14

MATERIAL DIEF0EITEDN 14 j AssITRECOVERY 15 d

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tr_m...cr.tal Du----=t- '=.ine A.+ = paan SCOPE The currently approved Rancho Seco Decommissioning Plan outlines SMUD's strategy to decommimmian Rancho Seco. The current approach is to place Rancho Seco into a SAF3f0R configuration, with Deferred-DECON starting in approximately 2008. This action plan mndinen the currently approved Decommissioning Plan, and describes SMUD's plans to implement an

" incremental' decommissioning program. Incremental decommissioning does not significantly affect SMUD's original strategy for decommissioning Rancho Seco. SMUD will conduct incremental du- == '- ' - '=5 in accordance with the NRC's Decommissioning Rule, Pancha Seco% 10 CFR 50 license, and the l California Envirnamental Quauty Act (CEQA).

i Stati has determined that SMUD can reduce the long term risk amanciatad with i safely maintaining redinactive systems at Pancha Seco by implementing some decommissioning activities now instead of waiting untR 2008. Incremental decommissioning is now possible because alternative waste disposal epGons

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are now available. Incremental dernmmimminninginvolves diamantling lower level contaminated portions of the plant (e.g., Au-L y Boiler, Auxuiary Steam System, High and low Pressure Turbines, etc.), and disposing of the lower level y radioactive waste now.

I It also appears that incremental decommissioning may be done at a cost below l that determined by the derneminainning cost estimate. A Request for Proposal

(RFP) for radioactive waste disposal and treatment is expected to produce

! responses from competing technologies that could result in cost savings to l SMUD.

i Radwaste disposal optionsinclude:

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1. Onsite decontaminatian

2. Offsite decontaminatian i 3. Disposal at an offsite waste disposal facility

4. Sale of material through the asset recormy program

5. Ward Valley (when opened) l

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l! In incremental decommiadaaine- staff wiR survey plant components to I determine the contaminatian level. Non-contaminated material can be free-

released for asset recovery or disposal at en offsite landan. Contaminated j material will be prepared for onsite or offske decontamination, if required, and

. subsequently shipped to a disposal site.

I During power operation, Rancho Seco shipped low level radioactive waste to waste disposal sites. The waste to be shipped during incremental l

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f Incremental Decammim*Ianine Actian Plan decommissioning will be similar lower levd radwaste. Due to the low levels of

! radioactive contaminetion involved, adherence to approved procedures, and the j use of trained individuals, risk to public and worker health and safety will be minimal. Risks associated with the transportation of the LLW will also be i

minimal. .

l This plan outlines staf!'s approach to incremental daeammissioning at Rancho l Seco. This integrated approach includes the radiatian protection, 1 i maintenance, operations, engineering, and licensing interface required to I

complete the project. Staff will develop a plant adminierative yiucedure to

implement incremental decommissioning activities. Additiannuy, staff will use

existing plant programs, or develop additional phres, to imalamaat -

l i various =W= of this plan.1his action plan, and changes to it, will be )

l conducted in accordance with the Rancho Seco nuclear safety review pmcess.

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DECOMMISSIONING STRATEGY

, The general approach to incremental decammia= Inning will be to denne an

incremental work scope of appieMma**1y one year duration. SMUD management will then measure the effectiveness can=Idering several factors, and will define additional increments to psf ==, ifit is advantageous to do so.

The evaluation and decision to perform additionalincrements will be made periodically, typically through the annual budgeting process.

Incremental decommissioning activities will include dismantling systems, equipment, and components containing low levels of radioactive contamination.

Decontamination will be minimal, but may be used if material can be ,

decontaminated easily and " free released" for unrestricted use. i

. LLW will be packaged for transport in accordance with applicable NRC and Department of Transportatian (DOT) regulatory requirements.

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Tr --- -tal Dacammi--L=iina Actian Plan INCREMENTAL DECOMMISSIONING IMPLEMENTATION The following is typical of how the incremental deon==Imataning program will be organimi and implemented:

1. Prepare alist oflowlevel contaminatert .,4 equipment, and components that staff can readily remove. Base the list primarily on systems and equipment that contain low levels of radioactive contamination. Also, include e=Hmataa of the levels of contaminatert waste, system and equipment volumes, pad ==Ing volumes, burial vahima= and wodoer radiation exposure considerations.

2. Identify the most appmpdate synerma, ~=*inmant, and components for removal and disposal Evaluate issues such as the removal daari_iny, woricer safety, overall risk, stafilnslevels/sidus maad-L schedule, unan-hour -: ^: =% and i

apacial eqil l=nant naaded

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3. ' Develop detailed unget module work packages to i=ntament in accordance with

! established plant procedures.

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4. Open and riimamarmhle systema and components, as required to confirm contaminatian levels and curie content.

5. Solicit bids for aR neeramany outside eqini-nant and services to perform the woric activities, inch _iding radwaste disposal conteii--., transportation avie ,

and disposal /burialservices. Explore alternative waste disposal techninues

and processes.

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6. Decentaminate and/or package for shipment for disposal.

7. Ship radwaste fordisposaL

8. The project will be periodicaHy evaluated against the factors discussed below, and additionalincrements implemented ifit is advantageous to do so.

1 FACTORS FOR CONTINUING INCREMENTAL DECOMMISSIONING Incremental decommissioning will continue as long as it is advantageous to do ao considering certain factors.1be following factors will be considered to detumizie the effectiveness ofincremental dE-- m!aalaning and determine ifincremental decommissioningwin continue:

In.w....=.y Decammt-- =in, w_= g r. ~

1. Envira===*=1 Risk /Es! sty: PubHc, envirnamental, and wodcer safety including, onsite handling of radwaste, as weR as offsite transpor+adan to a disposal or decontamir atinn facility.

2. Cost: Incremental demmmissioning must eLLJfreduce the annual contribution to the decornminainning trust fund.

3. Financia1 Risk: h possibGity of cost overruns built on expedence from completing previouswork modules.

4. * ^= ^- ;-g; Assess de:-- *' - '75in light of electric utility restructuringissues.

5. Alternattees: 1hc avaDabDity of other de ------ '- ^ *=!rg options.

6. Waste I.e ""y. The avaBabDity of sumsining systems and components that meet site disposal criteria.

7. NRC/leglaistive estlems: Assess the e5ect of any NRC or legislative action.

8. Othernewfasters APPLICABLE DOCUMENTS 1 Title 10, Code of Federal Regulations, Part 50 (10 CFR 50), ' Domestic Licensing of Production and Utimatian FN ,

2 Decommissioning Safety Analysis Report (DSAR) 3 Permanently Defueled Technical Rpeelnentiana (PDTS) 4 Decommissioning Plan (Post Shutdown Activities Report (PSDAR) under the new dernmmianianing rule) l 5 Licensing basis documents, as described in Rancho Seco l Administrative Procedure RSAP-0901 l 6 Californic Environmental Quality Act (CEQA) Determination 7 Rancho Seco Safety Manual 8 Title 8, California Code of Regulations, " Industrial Relations" f

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! ORGANIZATION l

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6 l The existing staff organization will provide the base resources for incremental decommissioning. Specialty contractors may also be used, as appropriate. The .

! Manager, Plant Closure and Dec0 =='--8=3a= (MPCthD) is responsible for the t

overall operation and maintenance of Rancho Seco, and for ensuring the ~ safe

storage of the spent nuclear fuel. 'the MPC&D will maintain this responsibility throughout decommissioning and storage of the fuel at the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI).

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Incremental Decommissioninz Action Plan Program Management The Decommissioning / Spent Fuel Project Manager wDI be responsible for the overall spent fuel ar.d decornminainning programs at Rancho Seco. To facilitate accomplishing decommissioning activities, the MPC&D will appoint a team leader to implement incremental decammiamianing. The team leader will direct a multi-disciplined project team to develop and im *==t an integrated work plan. The project team memhers Inchule individuals matrixed from various departments within the Pancha Seco organisation. The fouowing provides's.

brief overview of the role of key staff memhers dudng incremental decommissioning.

Manager, Plant Closure and Decommissioning

The Manager, Plant Closure and Dernmmia= Inning is responsible for the ovendl i safe operation of Rancha Seco. The MPC&D has made it clear that staff must i maintain an attitude of high quality, and nuclear and occupational safety throughout the project.

incremental Decommissioning Team Leader The incremental decommissioning team leader reports to the MPC&D, and is

, responsible for the overall direction, coordination of project activities, and maintaining an attitude of high quality, and nuclear and occupational safety throughout the project. The team leader wH1 direct the line orgariimatian to

, implement the activities tracked on the incremental decommissioning

schedule. Primaryresponsibuitiesinclude:

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! 1. Nuclear and occupational safety l 2. Project budget and schedule

3. Effective interface between various required technical disciplines

4. Defining and contracting incomental work scope activities

5. Evaluating savings to the annual decomminainning trust fund contribution

6. Coordinating and conducting any required public meetings t

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PLANNING AND SCHEDUUNG  !

The incremental decommissioning team leader wiu develop an integrated i schedule that includes incremental decomminalaning activities. Plant staff will l

review the activity schedule periodirmny. In addition, the decommissioning team members will review a more detailed decammia Inning schedule during '

regular team meetings.

i The integrated schedule wiR include items such an l

1. Proceduresdevelopnaent

2. Workpackages

3. Removal of major campananta and en =t

4. Radweste packaging and shipping .

5. Decontaminarian activities

6. Equipmentstatus

7. Required training modules

! 8. Licensingactivities j 9. Outside contracts i 10. Major activities with outside agencies and' regulators STAFF TRAINING i

l Current training programs cover the basic activities involved in incremental i

decommissioning. Any additional training required will be structured in accordance with administrative procedures.

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! ORGANIZATIONAL RESPONSIBLITIES FOR MCREMENTAL

{ DECOMMISSIONING 1

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j Radiation Protection i

1 The Radiation Fri,ts.Gc,n group is responsible for radiological surveillance,

' personnel manitoring, emergency preparedness, and environmental monitoring. Typical activities and responsihnitian include

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1. Providing radiological characterization of systems, components, and i equipment

2. Providing 'As low as remannably achievabW (AIARA) radiation exposure reviews for prMures i

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3. Providing radiation protection coverage during decommissioning

operations

4. Providing input to operatinnat activities .

5. Survey removed materials to determine if the materialis radiametive waste, or can be " free-r*1emmed* tem the site

6. Maintaining the E%s.g Plan and Process Control Program

7. Vedfying decontamination efhC. ass 4 8. Radwaste packaging and transportation i

9. Radiation Protection training for workers involved in decomminainning activities l

nialnianance The Maintenance group is responsible for ongoing maintenance of the facility, as well as providing skilled craft workers to support decommissioning. Typical activities include opening systems and consponents for radiological characterization, removing equipment, components, piping, etc. from the plant, and preparing materials for transportation to the disposal facility. Specialty contractors may also be used, as appropriate.

TechnicalServlees The Technical Services group pre 4ks en.% and design services, and resolves other technical issues required to support decomminaianing.

Technical Services' typical responmMties include:

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1. Developingincremental decommissioning work scope activities

2. Defining work scope boundaries ,

3. Supporting dismantlement and decontaminatian. (D80) activities  !

4. Developing required procedures,

5. Resolving ongoing technlen1 issues 1

6. Implementing an asset recovery program

7. Implementing the configuration control psogram l

8. Crane safety oversight I

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Inc . _...=.tal Mr ... . .t Anine Ax*__. Plan Operations The Operations group is responsible for the overaR safe operation of the plant.

Operations will drain, de-energize, and ensure proper clearances for systems involved in incremental deca ==i-Aing Operations staff may also assist in other decommi--Maine work scope activities including equipment access, status and condition.

Training The Training group establishes training r%4- -- .2- and ensures the proper training of individuals conducting -f+=-='"=N QualityAssurance The Quality Assurance group is responsible for indanaadently assessing decommissioning activities to ensure comaHance with mgulatory requAsts. -

A planned and .iA=Mc approach to imp - == ting the QA i%idwts will provide confidence that the decommissioning project wS1 meet procedure and licensing requhements, and SMUD'h high P*ta== for quality.

Licensing The Licensing group is responsible for cown .ating the interface with the l

i Nuclear Regulatory cammimmian (NRC), and controDing corispondence with outside regulatory agracI*s.

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! Typical Licensing group activities include:

l 1. Preparing and submitting the site anacine Post Shutdown Activities

report (PSDAR) and associated envirnnmental reports

! 2. Interfacing with the NRC to resolve halag and other techrdcal I issues l 3. Rev'~Aag and addren=Ing industry hmms learned l 4. Commitment tracidng

5. Conducting procedure reviews to ensmeTechnical Specincation l compuance

6. Preparing / reviewing required nuclear safety reviews of

-decommissioning activities I

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Incremental Decommiaskalas Action Plan Site Document Control The Site Document Control (SDC) gmup maintains and controls all an*In**dng and licensing basis documents in accordance with approved records )

management procedures. SDC maintains the contmDed copies of all design drawings, change notices, IIcan=Ing basis documents, and plant procedures.

Security The Security group is responsible for site accurity during routine, emergency, and contingency operations. Typical activities include:

1. Developing and revising security procedures, es necessary

2. Training security personnel on requhed prouaduits

3. Implementing the Physical Security and Physical Protection plans, and the associated Training and Qualhh- (11kQ) Plans

! PROGRAMS AND PROCEDURES RadiologicalControls Progrape The objectives of the Radiological Controls Pmgram are to control radiatinn l hazards, avoid accidental radiation exposures, meet regulatory dose limits, and l maintain doses to workers and the public As-law-As-Reasonably-Achievable (ALARA). The Radiation Protection Plan and associated implementing -

, procedures provide guidance and specify appropriate methods and tachata.ues

, to ensure that staff will accomplish incremental derneminainning activities in j accordance with sound radiological control prineim and in compliance with applicable regulatory requirements.

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l The team leader will ensure that the Radiological Controls Program is

integrated into all radiological activities. The Radiological Controls Program and

the Rancho Seco AIARA program will maintain personnel radiatian doses as-low-as-reasonably-achievable throughout the denanminainning process. '

l Fundamental to meeting the objectives of the Radiological Controls and ALARA j Programs is that each individual involved in radiological activities takes responsibility for procedure compliance and maintaining their own dose ALARA. Workers must remain aware of potential radiological hazards, and l comply with all radiation protection good practices.

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, Additional aspects of the Radiological Controls Prsy.ru include:

i e Process Control Program e Radwaste Contml Program

! e Radiation ProtectionTraining

. Radiological Respiratory Protection Program

! e Emergency Plan i e Radiological Euvir----- ntal Monitoring Program (REMP)

{ e Offsite Dose Calculatinn Manual (ODCM)

Radweste ControlPsopase

! The Radwaste Contml Program provides practices that help to reduce the "

I production of radiaactive waste. The incremental daeammi--8' ming team leader i' will strongly encourage the minimintian of redweste. The Radweste Control

] Program also includes the transfer, shipping, and disposal of radiametive

. material to ensure compliance with safety and renntatary requirements.

Aspects of waste minimintinn include:

4 l 1. Work planning l 2. Contaminatian contn4 l 3. Controlling the amount of tools and ecrdamaat entering contaminated l areas i 4. Employee training l 5. Ongoing assessment of program effAGvwess

Process ControlPrograse i

j The decommissioning staff win conduct ;" radweste handling activities in accordance with the Rancho Seco Process Contml Program (PCP). The PCP

! provides assurance that all radwaste is prnce==ed and pach-ed to meet j Federal regulations, state regalattaan, and disposal site criteria.

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i i Physical Protection, and Transing and Qualmca6an Pians The Rancho Seco Longterm Defineled Condition Physical Security Plan and Training and Qualifkation Plan describe the overall security policies and j outline the specific criteria that allindividuals must follow when entering the Industrial and Protected Areas at Rancho Seco.

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Y .- ---- .02? Deca =*at--'=8a= A+ :. Plan Rancho Seco Qua0tynmuel 1

SMUD has established and knplemented a Quality Assurance (QA) program I based on the criteriain 10 CFR 50, Appendix B. The gpverning document for  !

i this program is the NRC-approved Rancho Seco Quality Manual (RSQM). l l Administrative procedures '=F - ==t the RSQM. The objective of the QA program is to comply with the criteria as yd in 10 CFR 50, Appandiv B, j and with QA program requirements referenced in Regulatory Guides and ANSI

standards. Staff willapply the RSQM to acen-mimmianing activities, as

appropriate.

i DecomndesioningMan i The Decoinmissioning Plan addresses the current SAFSTOR strategy for decommissioning Rancho Seco.

l l Procedures Plant staff will develop an overall incremental dernmmiaminning procedure.

Additionally, staff may use existing work control procedures, or develop additional procedures, to ir= lament various e pact = of the decammi-Waing project.

TECHNICAL and SAFETY CONSIDERA110NS Crane Safety Technical Services has F L y responsibGity for completing activities necessary to ensu.e that staff uses certified cranes that meet Cal OSHA requirements. in addition, Technical Services is responsible for associated crane safety issues including defining safe load paths; preparation of load handling procedures and guidelines for allags and =yrcial lifting devices; and '

specifying the use of nwehanient or electrical interlocks, or asiminiatrative controls required when lifting large loads. Crane movement activities during incremental de:-- = 'n'=N will be contmiled so as not to interfere with the dry fuel transfer campaign.

Maintenance is remna==thle for crane operation, and maintaining crane operator certification. Maintenance is dse responsible for periodic inspection and maintenance on the crane.

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'v. inn w_=. Plan OccupationalSafety Rancho Seco staff wB comply with the District and Rancho Seco Safety Manuals, and appropriate sections of Title 8, California Code of Regulations, "Indusra t i l Real h a=?

Lead and OtherTexic Coetings Rancho Seco staff wB mr.ove, handle, and control exposure to lead and other toxic coatings in accordance with the District Safety Program Manual SMUD will provide annual training to individuals who work with lead or other tende coatings. Speciahy contractors may be used, as appropriate, operating under  !

their procedures.

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Rancho Seco staff wB conduct asbestos i-.1, hanAHng and expogure control in acccians with the District Safety Program Manual Specialty j

i contractors may be used, as appropriate, worldng under their pivcedurea.

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l Configuration Controf

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Plant staff will conduct Rancho Seco's configuration management program in accordance with approved administrative procedures. The configuration management program provides controls to ensure that chanaam to aciacted i structures, systems, cosnponents, and computer software conform to licenae l l requirements. .

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Radiation Protection wE survey materials removed during incremental decommissioning to demmine if the material is radianctive waste, or can be

" free-released

• hom the site. RP will survey all pedaahny contaminated i materials being removed during incremental d 8-%ine RP will then i

determine if the material meets the relemaa limits WMad in site l administrative procedures.

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! E - -- =.tal M. _ . . . . .E =.e., g____ g, l Asset Recovery t

Systems, equipment, and components no longer needed to remain Ainctional or j

rm=la in place will be available for the asset recovery program. Reducing j

radwaste through an asset ik.si program will save on waste burial costs, j and reduce the ultimate bustlen of decommiamianing.

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