ML20195B355

Comment on Proposed Rules 10CFR50 & 140 Re Financial Requirements for Permanently Shutdown Nuclear Power Reactors

ML20195B355
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/03/1998
From:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR50815, RULE-PR-140, RULE-PR-50 63FR50815-00002, 63FR50815-2, VPN-069-98, VPN-69-98, NUDOCS 9811160103
Download: ML20195B355 (3)

Text

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Trojan Nudear Plant iii 71760 Columbia Riwr Hwy v

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(503)556-3713 Ct VPN-069-98 AD. t -

2 Trojan Nuclear Plant Docket 50-344 License NPF-1 Secretary, U. S. Nuclear Regulatory Commission l

- Attention: Rulemaking and Adjudications Staff Washington, DC 20555-0001 Request for Additional Comment on Financial Requirements for Permanently Shutdown Nuclear Power Reactors, 63FR50815 Proposed Rules, Dated September 23,1998 The subject Federal Register Notice identified the NRC request for comment on the potential cost of cleanup for an on-site spill from a large vessel (>1000 gal) containing radioactive liquid and the appropriate level ofinsurance coverage.

Portland General Electric (PGE) makes the following comments in response to the subject request:

1. PGE obtained an exemption from certain requirements of 10 CFR 50.54(w) for the Trojan Nuclear Plant as identified in a letter with the attached exemption from Mr.

Michael T. Masnik, Senior Project Manager, Non-Power Reactors and Decommissioning Project Directorate, Division of Operating Reactor Support, Office of Nuclear Reactor Regulation to Mr. James E. Cross, Vice President and Chief Nuclear Officer, Portland General Electric Company, Exemption From Certain Requirements of 10 CFR 50.54(w),

For Trojan Nuclear Plant (TAC NO. M86979) dated November 17.1993. The NRC granted the full exemption to 10 CFR 50.54(w) pursuant to 10 CFR 50.12. The exemption, however, requires PGE to continue to maintain a minimum of $5 million in I

insurance or be capable of demonstrating self-insurance for the amount.

2. PGE has drained all outside tanks containing radioactive fluids, therefore, the NRC postulated on-site spill from a large vessel (>1000 gallons) containing radioactive liquid as the defining event for determining insurance coverage is not applicable.

9811160103 981103 PDR PR 50 63FR50815 PDR ,

Connecting People, Power and Possibilities

l-VPN-069-98 November 3,1998 Page 2 of 3 l

3. All piping systems normally containing radioactive fluids, with the exception of the Modular Spent Fuel Pool Cooling System, have been drained as a result of l decommissioning activities. PGE's radwaste system has the capacity to store approximately 6,000 gallons of radioactive waste in one tank that is segmented into two compartments capable of containing approximately 3,000 gallons each. This tank is located inside a room within the Auxiliary Building. Should a leak or rupture occur causing spillage of the tank contents, the radioactive liquids would be confined within the building. The possibility of soil contamination does not exist due to the location of the l tanks within the building and administrative controls in place at Trojan.

i 4. The small amounts of radioactive liquids generated at Trojan during the decontamination l and decommissioning activities are processed and removed in accordance with Trojan approved procedures. Therefore, even should there be any type of radioactive liquid waste spills at Trojan, the cost of cleanup would be very small relative to the $5 million self-insurance PGE maintains.

Therefore, based upon the comments above, PGE proposes that the NRC grandfather licensees under previous rule exemptions to this proposed rule. Since the previous actions by the NRC Staff relate to the applicability of the current rule to the Trojan facility and the rule change is forward looking, the Trojan staffis of the opinion that the rule change is not intended to apply to plants similar to Trojan. Specifically, the final rule should have a provision that excludes from the scope of the rule any facility that has received NRC exemptions related to the application of 10 CFR 50.54(w).

The analysis associated with the Trojan exemption request identified the spent fuel pool water inventory loss or fuel handling type of events as limiting events. The NRC and PGE analyses of these events reflect that financial requirements for on-site cleanup costs are approximately $5 million. The proposed new rule,62 FR 58690, dated October 30,1997, has introduced a liquid radioactive inventory incident as an additional criteria. This represents imposition of new requirements not currently being applied to the Trojan facility. The backfit analysis discussion does not reflect these new requirements for fac.ilities that have exemptions to the existing rules.

In the case of 10 CFR 50.54(w) on-site stabilization fund requirements, the proposed rule represents a factor of 10 increase in insurance requirements for the Trojan facility. The I

additional premium costs would create a negative impact on decommissioning ftmds. The proposed on-site insurance protection requirement of $50 million is not consistent with past NRC Staff actions and is not needed to ensure the protection of the public health and safety.

VPN-069-98 November 3,1998 Page 3 of 3 Should you have any questions, please contact Joel Westvold, Manager Nuclear Regulatory i AfTairs, (503) 556-6485, or e-mail: Joel_Westvold@pgn.com.

1 Sincerely,

/ny_:;s M = = =

Stephen M. Quennoz Vice President Nuclear And Thermal Operations SMQ/JDW:rp c: - C. J. Haughney, NRC, NMSS L. H. Thonus, NRC, NRR R. A. Scarano, NRC Region IV David Stewart-Smith, OOE l

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