ML20154Q407

Forwards Request for Addl Info Re Proposed Tech Specs Changes,Decommissioning Plan & Environ Rept to Delete Authority to Operate Facility

ML20154Q407
Person / Time
Site:	Dresden
Issue date:	09/27/1988
From:	Erickson P Office of Nuclear Reactor Regulation
To:	Morgan W COMMONWEALTH EDISON CO.
References
NUDOCS 8810030389
Download: ML20154Q407 (8)

Text

. _- . . -

September 27, 1988 Docket No. 50-10 Mr. W. E. Morgan Nuclear Licensing Administrator Commonwealth Edison Company One First National Plaza Post Office Box 767 Chicago, Illinois 60690-0767

Dear Mr. Morgan:

a .

i

SUBJECT:

DRESDEN UNIT-1 DECOMMISSIONING PLAN AND TECHNICAL SPECIFICATIONS -

REQUEST FOR ADDITIONAL INFORMATION By letter dated January 7,1986 you provided proposed Technical Specification (TS) changes and an amendment to delete authority to operate Dresden Unit 1.

i By letter dated July 23, 1986 we issued Amendment No. 36 to revise License No. DPR-2 to possession-only status. We also advised you that action on the 1

balance of your application would be taken following your submittal of a safety L analysis and/or a Decommissioning Plan. By letters dated December 22, 1987 as j revised April O,1988 you submitted your proposed Decommissioning Plan and j Environmental Report.

l j We have reviewed your proposed TS, Decommissioning Plan and Environmental Report and have determined that we need additional information to proceed.

Please provide your response to the enclosed request for additional i j information by November 20, 1988.

I Sincerely, i a ,

4 /s/

Peter B. Erickson, Project Manager I Standardization and Non-Power i Reactor Project Directorate l l Division of Reactor Projects - III, IV, l

Y and Special Projects ,

j Office of Nuclear Reactor Regulation ,

I

Enclosure:

As stated

cc

See next page i

, DISTRIBUTION:

. sectet rife 1 NRC & Local PDRs .

j PDSNP Reading

. EHylton  !

1 PErickson OFof ,

I CMiller '

EJordan BGrimes gC0g g DBj9& o I;(

W PNV OGC-Rockville ACRS(10) i

1. OA

. PD PDSNP & PDSNP  !

I '

E on PEricks6n:cw Chiller

/p/88 094f7/88 09/ty/88 i <

o ner,

'# o, UNITED $TATEs

!, a NUCLEAR REGULATORY COMMISSION 4% WASHINGTON, D. C. 20666

-l k..../

c September 27, 1988 Docket No. 50-10 '

Mr. W. E. Morgan Nuclear Licensing Administrator comonwealth Edison Company One First National Plaza Post Office Box 767 Chicago, Illinois 60690-0767

SUBJECT:

DRESDEN UNii -

W ISSIONING PLAN AND TECHNICAL SPECIFICATIONS -

REQUEST FOR i. "*t. INFORMATION By letter dated January /,198t, sou provided proposed Technical Specification (TS) changes and an amendment to delete authority to operate Dresden Unit 1.

By letter dated July 23, 1986 we issued Amendment No. 36 to revise License '

No. DPR-2 to possession-only status. We also advised you that action on the balance of your application would be taken following your submittal of a safety analysis and/or a Decomissioning Plan. By litters dated December 22, 1987 as revised April 29, 1988 you submitted your proposed Decommissioning Plan and i Environmental Report.

We have reviewed your proposed TS, Decomissioning Plan and Environmental Report and have determined that we need additional information to proceed.

Please provide your response to the enclosed request for additional information by November 20, 1988.

Sincerely, ,  ;

cL4etm A &

Peter B. Erickson, Project Manager  ;

Standardization and Non-Power  ;

Reactor Project Directorate  !

Division of Reactor Projects - !!!, IV, l V and Special Projects '

Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page l

l

Mr. W. E. Morgan Dresden Nuclear Power Station Commonwealth Edison Company CC:

Michael I. Miller, Esq.

Sidley and Austin One First National Plaza Chicago, Illinois 60603 Mr. J. Eenigenburg Plant Superintendent Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 U. S. Nuclear Regulatory Commission Resident Inspectors Office

. Dresder Station Rural Route #1 Morris, Illinois 60450 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Regional Administrator Nuclear Regulatory Commission, Region III l 799 Roosevelt Road, Bldg. f4 1 Glen Ellyn, Illinois 60137 '

Mr. Michael E. Parker, Chief Division of Engineering Illinois Department of Nuclear Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 l

I l

F ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION FOR ORE 5 DEN STATION UNIT 1 DECOMMISSIONING COMMONWEALTH EDISON  :

DOCKET NO.50-010 Decommissioning Plan

1. Your letter dated February 25, 1977, described the storage of radioactively contaminated soil in an excavation at the Dresden Unit 1 HPCI and waste treatment facilities. Indicate the present status of this contaminated aree, tabulate concentrations vs location and the total inventory for each radionuclide. Also, provide direct radiation measurements of soil in micro R/hr above background, as measured one meter from the surface of the contaminated soil area. Estimate the maximum radiation levels that would exist if the layer of uncontaminated soil were removed. State your l ..

schedule for removal of the contaminated soil such that levels of radioactivity would be acceptable for release to unrestricted access.

Currently, we have accepted 5 micro R/hr above natural background for gamma emitting radionuclides as measured one meter above an unshield soil surface.

2. We understand that much of the liquid waste produced from the 1984 chemical cleaning of the primary loop is still on-site in unprocessed form. Plans

' for processing and disposing of this waste should be provided, along with information on volume, activity by nuclide, waste classification, and (

3 chelate content. Any necessary change to the process control program, the quality control prograr, or the transportation packaging program should be submitted. The plan for disposal of the chelate chemical cleaning waste ,

a should demonstrate assurance of disposal at an arid LLW disposal site '

, prior to termination of access to such facilities. l Similar information should be submitted for any other significant quantity of radioactive waste currently on-site. ,

t Costs for dealing with the significant quantities of stored wastes should  !

be accounted for in the overall decommissioning cost analysis. I

3. Wastes to be produced in preparation for the "dormancy" period should be i fully characterized in Section 2. Information should be provided on volume, activity content by nuclide, concentrations, processing plans, waste classification, and chelate content if any. Mixed wastes should be l identified if present. This should be done for each contaminated waste source listed in Section 2.1.1, "SAFSTOR" Operations, and for each waste stream during the dormancy period described in Section 2.1.2, "Dormancy."

4. The internal funding method proposed, as well as the amount of financial surety provided, is not consistent with 10 CFR Part 50.75 of the i

' Coer. mission's final decommissioning regulations of June 27,1988(53FR l 24049). A financial surety method consistent with those regulations must be submitted.

I i

2-1 <

l

5. The cost figures given for decomissioning Dresden Unit 1 appear to be inconsistent. A figure of $108 million is given in Table 4.2 and stated to be in 1985 dollars while a figure of $110 million is given in Table 4.3 and stated to be in 1987 dollars.

6. Section 4.2 states that the Dresden Unit I decomissioning cost estimate  !

in Table 4.2 does not include interest, inflation, or tax effects, but that l these factors are accounted for in the financial plan described in Section '

l 4.3. The only cost figure provided is $150 million per unit which appears I to be an average of the Table 4.3 estimates for all 11 CECO units. The l

effects of interest, inflation, and taxes, and other influences on the Dresden 1 decommissioning cost should be analyzed and provided.

7. No basis is provided for the estimated decomissioning cost for Dresden Unit 1 other than a reference to a 1985 study by TLG Engineering. A fully detailed basis for the estimated cost of decomissioning Dresden 1 should be supplied unless the default amount prescribed in the final decommis-sioning regulations (10 CFR Part 50.75C) is to be used for financial assurance purposes. This information should take into account the apparent uncertainty as to when final dismantling and decontamination will I actually occur.

l l 8. Costs during the SAFSTOR or dormancy period (Section 4) are stated as l being treated as operating costs. The rationale for treating these costs l other than as straight decomissioning costs should be fully described, l and consistency with the new decomissioning regulations should be demonstrated.

9. We have found the financial assurance aspects of the decommissioning plan {

for Dresden to be deficient. The Commission recently voted to disallow  !

use of the internal reserve method of setting aside funds for decomis- i sioning. Because Comonwealth Edison has been using and proposes to l continue using the internal reserve method of funding for Dresden Unit I l (Dresden Unit 1 Decommissioning Plan, p. 26), Comonwealth Edison's approach is essentially incompatible with current Comission policy.

Notwithstanding the policy expressed in the final rule to treat plants )

already shutdown on a case-by-case basis, we have cone'uded that internal reserve should not be allowed for Dresden Unit 1 or other shutdown power plants. Therefore, we ask that Commonwealth Edison redraf t its funding plan for Dresden Unit 1 to stipulate that all decommissioning funds for Dresden Unit 1 be placed in an external account as described in both the proposed decomissioning rule and in NUREG-0584, Rev. 3 (Assuring the Availability of Funds for Decommissioning Nuclear Facilities). For f unds already accumulated in an internal reserve, Comonwealth Edison Could either transfer then to an external account or start from a zero balance by assuming that any funds accumulated so far in an internal reserve will l

not be credited to its decommissioning reserve. >

10. P. 27. It is stated that, "The estimated costs of decomissioning one ,

unit are approximately $150 million (stated in 1987 dollars) as detailed l in Table 4.3." However, Table 4.3 (p. 31) in91cated that the estimated Dresden Unit I decomissioning cost in 1987 dollars is $110 million.

This discrepancy should be explained or revised.

l

11. P. 27. There is no provision for inflation or amortization schedules showing the annual rate of collection of funds over the life of the decommissioning process. If Commonwealth Edison chooses not to consider inflation in its current estimates, it should at least indicate how frequently it plans to update decommissioning cost estimates for Dresden Unit 1 and adjust its amortization schedule accordingly. Similarly, there is no discussion of assumptions concerning projected earnings on the -

decommissioning fund, which should be provided whether an internal or an j external fund is being used. Comonwealth Edison should provide this information.

12. P. 30. Table 4.2 provides a summary of estimated Dresden Unit 1 decorrnis-sioning costs. Although these figures appear reasonable, there is no detail backing them up. We request that Comnonwealth Edison provide this detail in their next submission or provide funding assurance for the

.. amount specified in 10 CFR Part 50.75(c).

13. A local area map defining the unrestricted areas used for offsite dose calculations for gaseous and liquid effluents should be included in the TS.

In addition, a site map clearly defining the restricted area pursuant to 10 CFR 20.3(a)(14) should be included, r

14 a) Provide a table showing Dresden Unit 1 personnel exposure experiences for the years 1978 thru 1988 indicating the man-rem exposures b plant system, regardless of how these exposures were o>tained (ye.g.,

duringnormaloperations, maintenance,repairorrefuelingactivities) and by whom (e.g., by plant operations personnel, plant maintenance personnel, contractor /vendorpersonnel,etc.).

b) Provide a similar table for tne SAF510s p iod. Provide discussion l which confirms that your ALARA program will maintain the state-of-the- ,

art for reducing personnel exposures to a minimum. '

15. Revise Section 5.8 to show the design features of the monitoring system  :

for the SAFSTOR decomissioning. Include the offsite and onsite environ- I mental monitoring stations. '

16. In accordance with Section 12.5, NUREG-0800, confirm that your health  ;

physics procedures for performing bioassay during the SAFSTOR period i will conform to the recommendations of Regulatory Guide 8.26. "Application of Bioassay for Fission and Activation Products,' or submit equivalent bioassay criteria.  !

17. Are you contemplating spent fuel pin consolidation onsite prior to shipment I to the Federal High Level Waste Repository? If so, provide estimates of the expected occupational radiation exposures involved, of the volume of i low level waste generated, and the contribution of this activity to gaseous j and liquid radioactivity releases to the environment.

l l

l l

o

-4.

18. Describe the treatment and monitoring to be provided for effluents from i the refueling building ventilation exhaust, liquid waste storage tankage vent exhaust, hot lab vent exhaust, hot machine shop vent exhaust, radwaste treatment building ventilation exhaust, the high-level solid radioactive waste storage vaults, the low-level waste storage building, the low-level waste handling building, and any other pathway for the release of radio-  ;

i active materials. i

19. Provide an estimate of the number of employees required for the SAFSTOR decomissioning time period. Provide a breakdown by permanent and ,

contractor workers of the employees required. If this number is not i expected to be relatively stable, give estimate of changes anticipated.

20. Provide a description of fission and corrosion prodnet sources in the (a) movement of fuel from the core spentfuelpool(SFP))waterfrom:

intothepool,and(b defective fuel stored in the pool. Include a listing of the radionuclides and their concentrations (expressed in uCi/mL) deco The radionuclides of interest should expectedb'I"80Co, include 5 Co, g ssioning137 Cs, and Cs.

21. Provideadescriptionofradioactivematerialsthagmaybecogeairborne j as a result of failed fuel and evaporation (e. Kr, and I

, Theradionuclidedescriptionshouldincludecablatedormeasuredconcen-H,respectively). i l trations expected during decomissioning.

22. Provide a description of the dose rate at the surface of the pool water l

from the fuel assen611es, control rods, burnable poison rods or any I miscellaneous materials that may be stored in the pool. l

23. Discuss the manner in which occupational exposure will be kept ALARA during s the decomissioning. Include the need for and the manner in which cleaning l of the crud on the SFP walls will be performed to reduce exposure rates in l

, the SFP area.

j 24. The radionuclide inventory data provided are insufficient to determine waste I j processing requirements, waste volumes, waste classification, or identify special wastes such as oils or chelates. As requested earlier in connection with Section 2, a complete characterization of waste to be generated, i processed, and disposed during the SAFSTOR phase of decomissioning is '

needed.

25. In Section 7.1 it is stated that waste volume estimates assume a 40 to 60 percent void fraction in the waste containers. To maximize stability in a low-level waste disposal unit it is necessary to minimize voids in waste l

6 packages to the extent practicable. It is unclear whether the assumed voids are based on incomplete container filling or on the odd-shaped nature of rubble ar;d scrap wastes. In any case efforts should be made to

' minimize voids so that long-tem stability can be achieved at disposal sites.

i

1

. e 5-

26. Note 1 on p. 53 states that most wastes from the dormancy period can be disposed at Dresden Units 2 or 3. We assume this means that wastes generated would be processed and shipped from Units 2 or 3 rather than disposed at Units 2 or 3. These wastes should be identified and accounted for as Unit I wastes.

27. In Section 7.4 nonradioactive wastes are briefly discussed. Criteria that will be used for separating nonradioactive from radioactive wastes should be specified. Also, the administrative programs and equipment to be used to ensure these wastes are properly separated should be described.

Technical Specifications

1) Offsite dosimeters should have their location documented on a map as part

, of the TS.

Offsitewatersamplingshouldbespecified(locationandradionuclide).

The sampling should be in a downstream location with respect to surface water and groundwater.

4 Onsite sampling should be described as to radionuclides sampled and the location.

2) TS (Section 5.0) should include training on 10 CFR Parts 19, 20, 61 and 71 as a minimum. A retraining frequency should be specified.

3) The procedure list (Section 5.0) should include calibration instruments, effluent releases, transportation and emergency plan implementing procedures.

4) In Section 5 the licensee has deleted the requirement to retain records of radioactive shipments. We consider these records should be retained for the currently required period of five years.

5) In a letter, dated December 10, 1987, the licensee responded to an allegation concerning potential degradation of the fuel racks and concrete structure as a result of stagnant conditions in the spent fuel pool for over two years. This led to the growth of micro-organisms which could corpromise the safe storage of the Dresden Unit 1 fuel due to microbial influenced corrosion. The Decommissioning Plan and Technical Specifications should address the corrective action taken to assure safe spent fuel storage.

Specifically, the Technical Specifications should address source and quality of makeup water and emergency makeup water and operability of spent fuel pool cleanup system including quality of spent fuel pool water.

I

6) Define GSEP in paragraph A of page B.3/4.2-2.

1 1