ML20210D957
| ML20210D957 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/15/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | Berkow H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20210D960 | List: |
| References | |
| VP-86-0118, VP-86-118, NUDOCS 8609220061 | |
| Download: ML20210D957 (8) | |
Text
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September 15, 1986 VP-86-Oll8 Mr. Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing - B U.
S.
Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Berkow:
Reference:
1)
Enrico Fermi Atomic Power Plant Unit No. 1 NRC Docket No. 50-16 NRC License No. DPR-9 2)
NRC to Detroit Edison Letter " Request for Additional Information", dated May 22, 1986 3)
Detroit Edison to NRC Letter, " Amendment Request for Extension of the ' Possession Only' License for Fermi 1",
NE-85-0714, dated May 17, 1985 4)
" Retirement of the Enrico Fermi Atomic Power Plant", Power Reactor Development Company, March, 1974 5)
Power Reactor Development Company, Docket No. 50-16, Fermi Unit No. 1, Amendment to Facility Operating License, Amendment No. 7, License No. DPR-9, July 1,
1974 6)
" Draft Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities", NUREG-0586, January, 1981 7)
Detroit Edison to URC Letter,
" Supplemental Information on Fermi 1",
VP-86-0092, dated July 23, 1986 8)
The Detroit Edison Company, Docket No.
50-16, Enrico Formi Atomic Power Plant Unit No. 1, Amendment No. 8 License No.
DPR-9, January 23, 1976 lh00 8609220061 860915 ADOCK0500g6 g
DR
Mr. Herbert N. Berkow September 15, 1986 VP-86-Oll8 Page 2
Subject:
Recuest for Additional Information as Outlined in 10CFR51. 4 5 f b) for Fermi 1 By letter dated May 22, 1986, (Reference 2), Detroit Edison was requested to provide the NRC with information as described-in 10CFR51.45(b) relating to the Enrico Fermi Atomic Power Plant Unit No. 1 (Fermi 1).
The NRC has identified this information as being required for the preparation of an Environmental Statement for the proposed amendment to extend NRC License No. DPR-9 for 40 years to March 2025 (Reference 3).
Pursuant to NRC regulations 10CFR51.20(a) an environmental impact statement is required for Licensing and Regulatory actions that meet at least one of the following criteria:
(1) The proposed action is a major Federal action significantly affecting the quality of the human environment.
(2) The proposed action involves a matter which the Commission, in the exercise of its discretion, has determined should be covered by an environmental impact statement.
Detroit Edison believes that the preparation o'f an Environmental Statement relating to Reference 3 is of little practical benefit to the Commission and is contrary to previous guidance from the AEC as indicated in Chapter 4.0 of Reference 4, and Attachment 1 to this letter.
As indicated in Exhibits 4.1 and 4.2 of, the decision to decommission Fermi 1 was made on November 27, 1972, as the result of a directive from the AEC dated March 31, 1972, requesting Power Reactor Development Company (PRDC) to provide, in addition to other information, estimated costs " based on a proposed plan for decommissioning and maintenance of the plant in perpetuity".
It is clear from the correspondence presented in Attachment 1 at the time Fermi 1 was being decommissioned, the AEC was requesting information and Technical Specifications (Reference 5) that would essentially place Fermi 1 in what is presently defined by the NRC as SAFSTOR (Reference 6).
As developed in Reference 7, the significant environmental impact associated with Fermi 1 occurred during 1973 through 1975 when the major elements of the decommissioning plan were implemented and radioactive components were being dismantled, cut up, and shipped offsite. Ninety-six percent of the total cumulative dose
c Mr. H2rbart N. Barkow September 15, 1986 VP-86-0118 Page 3 associated with 1973 through 1985 was recorded during the 3-year period 1973 through 1975.
During the 40-year extension requested, an annual dose of 0.04 man-rem is estimated for maintenance, repair, and surveillance activities, resulting in a total dose of 1.6 man-rem.
Natural decay during this time will reduce the remaining radioactive inventory to approximately 10% of its present value. (Reference 7)
In conclusion, Detroit Edison believes that an Environmental Statement is not required for the issuance of the amendment to extend NRC License No. DPR-9 for 40 years to March 2025 as stated in the following paragraphs:
a.
The proposed amendment is not a major Federal action significantly affecting the quality of the human environment since the significant environmental impact associated with Fermi 1 occurred during 1973 through 1975.
b.
The ACC/NRC has previously approved the decommissioning plans and maintenance of the Fermi 1 facility via Attachment 1 and References 5 and 8, and the provisions of 10CFR50.59.
c.
The proposed amendment does not:
1.
Create additional irreversible conditions 2.
Involve a significant hazards consideration since the maintenance of the Fermi l facility until the year 2025 does not:
(a)
Require the addition of more elements to the decommissioning plan as submitted in ERDA-NP-0047 and in Attachment 1 and fully implemented as of the fourth quarter of 1984.
(b)
Involve a significant increase in the probability or consequences of an accident previously evaluated.
o o
Mr. Herbert.N. Berkow September 15, 1986 VP-86-Oll8 Page 4
.(c)
Create the possibility of a new or different type of accident from any previously evaluated.
(d )
Involve a significant reduction in the margin of safety.
3.
Involve a significant change in the type or increase the amounts of any effluents that may be released offsite:
(a)
No changes to the Fermi 1 Technical Specifications are required which includes the weekly, monthly, and semi-annual surveillances.
(b)
No significant change has occurred in the results of the environmental sampling regime over the past several years indicating there are no significant releases to the environment attributable to Fermi 1.
(c)
Natural decay of the radioactive inventory available for release over the 40-year period will reduce the radioactivity available for offsite release.
4.
Involve a significant increase in individual or cumulative occupational radiation exposure:
(a)
Ninety-six percent (20.5 man-rem) of the total cumulative dose from 1973-1985 (21.3 man-rem) was recorded during the 3-year period 1973-1975.
(b)
One percent (0.2 man-rem) of the total cumulative dose was recorded during the interim 6-year period of 1976-1981 as a result of surveillance and maintenance activities.
(c)
Three percent (0.6 man-rem) of the total cumulative dose was recorded during the 4-year period 1982-1985 as a result of the sodium drumming and shipping operations.
e Mr. Herbert N. Borkow September 15, 1986 VP-86-0118 Page 5 (d )
Two point eight percent (1.6 man-ren) of the total cumulative dose to date (21.3 man-rem) is estimated for the additional maintenance, repair, and surveillance activities over the,40-year period, resulting in an annual dose of 0.04 man-rem.
d.
The proposed 40-year extension:
1.
Increases significantly the area beyond the present area of the Fermi l facility that is within the release criteria for unrestricted access (5 microRem per hour at one meter for reactor-generated gamma emitting isotopes).
2.
Decrease significantly the remaining radioactive inventory due to natural decay.
Based on the above conclusions and.the fact that the proposed scendment is a 40-year extension of the present facility status and does not include or specifically refer to decommissioning plans as stated in 10CFR51.20 (b) (5), Detroit Edison believes it is not necessary to submit information in accordance with 10CFR51.45(b) since previously submitted documentation and approvals by the AEC/NRC included in principle the maintenance of the Fermi 1 facility for an unlimited time.
Should you have any further questions regarding this subject, please contact Ms. E. F. Madsen at (313) 586-4205.
Sincerely,
/1 f
_g Attachment cc:
Mr. J. Eckert (Monroe County OCP)
Mr. P. D.
Erickson Mr. D. Hahn (State Health Department)
Mr. W. G. Rogers USNRC Document Control Desk Washington, D. C.
20555
bt AcMmEt0T b I..,.
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- 4. 0 DECOMMISSIONING PLAN DEVELOPMENT I
The decommissioning plan of the EF-1 plant was greatly influenced by the following factors:
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Use of the Fermi-1 turbine for peaking power by The I
Detroit Edison Company utilizing a fossil-fueled boiler I
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Installation by Detroit Edison of two 1100 Mwe boiling e
water reactors adjacent to the EF-1 plant site I
e The $4 million retirement fund held in reserve by PRDC.
The final plan evolved through three submittals of such a plan to the AEC.*
The first submittal (Exhibit 4.1) containing the rudiments of the retirement plan was in, reply to a directive from the AEC (Exhibit 4.2) to prepare "an itemization 'of estimated costs to place the reactor in the proposed decommissioned condition (including costs to package, transport, and reprocess fuel and costs for burial of the axial and radial blankets),
a statement of the assumptions made in arriving at these costs to maintain the reactor in a proposed decommissioned condition. These estimated I
costs should be based on a proposed plan for decommissioning and main-tenance of the plant in perpetuity. " The major retirement activities and the plan for maintenance of the plant in perpetuity formed the framework I
of the decommissioning program. These activities are summarized below:
1.
Return of the leased enriched uranium to the USAEC l
2.
Transfer of the primary sodium to the sodium storage tanks where the sodium will be allowed to freeze 3.
Chemical treatment of the residual sodium in the primary system to a passive material 4.
Dismantling of miscellaneous contaminated equipment presently outside the reactor building and storage of such equipment in the equipment decay tanks within the reactor building 5.
Installation of monitoring instrumentation in the sodium storage tank building, the reactor building, and the transfer tank vault All PRDC correspondence with the AEC concerning the decommissioning plan for EF-1 is copied herein and made an integral part of this section designated Exhibits 4.1 through 4. 6.
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5.
Installation of monitoring instrumentation in the sodium storage tank building, the reacter building, and the transfer tank vault E'
6.
Retention of the radial blanket subassemblies in the reactor vessel and storage of the axial blanket seg-ments in a concrete vault in the fuel and repair building 7.
Permanent closure of all penetrations in the reactor i
building except the personnel air lock and those ac-commodating several electrical and instrumentation leads used for monitoring 8.
Plant maintenance in perpetuity including 8.1 Installation of instrumentation to promptly identify the existence of potentially deleterious conditions 8.2 Storage of the radioactive materials within buildings having high integrity 8.3 Continuing periodic surveillance.
The second submittal to the AEC (Exhibit 4.3) was the first plan to detail the major retirement tasks and was prefaced with a request to the AEC to approve in principle two major tasks which would result in substantial costs over the previously submitted plan if not approved.
These two tasks were (1) the onsite storage of the radial blanket sub-assemblies and (2) onsite storage of all radioactive sodium.
[
Other significant items not included in the first submittal were s '-
(1) offsite burial of the axial blanket segments, (2) removal of sodium from the secondary sodium system for sale and passivation of the resi-dual sodium so that secondary system components could be salvaged or scrapped, (3) reactor auxiliary and fuel handling systems to be either cleaned of significant contamination or the access to such systems restricted, (4) fencing of the facility to be left as is or rerouted for easier I
access to uncontaminated areas, (5) retention of legally required and other significant documents, and (6) establishment of administrative controls for authorized entry to restricted areas and for preparation of environ-I mental, unusual events, and annual status reports.
On January 22, 1973, the AEC issued another directive (Exhibit 4. 4)
I to the effect that the EF-1 decommissioning schedule should include plans L
for the removal and offsite disposal of primary and secondary sodium and I
- 4. 2
blanket materials. In reply to this directive, the finalized retirement plan was submitted on September 24,1973 (see Exhibit 4. 5) and the AEC was requested to approve this plan with regard to concept and scope so that negotiations with Detroit Edison could be completed for transfer of PRDC's Part 50 license. A letter from the AEC indicating such approval (Exhibit 4.6) was issued on November 30, 1973.
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