ML20217J775

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Submits Reply to Discussing Decommissioning Activities at Facility.Decommissioning Requested to Be Delayed for 25 Yrs to Allow for Addl Radioactive Decay
ML20217J775
Person / Time
Site: Saxton File:GPU Nuclear icon.png
Issue date: 10/09/1997
From: Alexander Adams
NRC (Affiliation Not Assigned)
To: Tydeman J
AFFILIATION NOT ASSIGNED
References
NUDOCS 9710220015
Download: ML20217J775 (26)


Text

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NUCLEAR REGULATORY COMfAISSION WASHINOToN, D.C. 30666 4 41 4

4*****,e October 9,1997 Mr. Jim Tydeman 1402 Wall Street Saxton, PA 16678

Dear Mr. Tydeman:

This is in reply to your letter of Jum i n 1397, which discussed decommissioning activities at the Saxton Nuclear Experimentalrgeit THEF). The position put forth in your letter was that decommissioning of the SNb u prayed for up to 25 years to allow for additional radioactive decay. The timing of decomnJssioning activities is the prerogative of the ficcnsee as long as decommissioning is carried cut safely in accordance with the regulations. The staff is currently reviewing a request for license amendment from the licensees that if approved would remove the existing license restrictions on i decommissioning the SNEF. The staff expects to complete this review in the next several months.

The reguletions concerning decommissioning of nuclear power plants underwent significant amendment in August 1996. To help explain those changes, I have enclosed a portion of the transcript of the public meeting held at the Saxton Fire Hall on January 28,1997. My presentation at the public meeting described the current regulatory approach to decommissioning nuclear power plants and where Saxton fits into the process.

Your first general point was that GPU Nuclear had stated that the method used to remove major components from the containment vessel (CV) will be selected by the contractor who is awarded the job. You believe that NRC should not approve the SNEF Decommissioning Plan (DP) until the exact method of removal of the components has been specified.

Part of your second general point was that the amount of time components removed from the CV would be in the staging building (called the decommissioning support building (DSB) by the licensees) was not known because the method of preparing components for shipping will not be known until a contractor is selected to perform the work.

As discussed in the enclosed portion of the Saxton public meeting transcript, because of amendments to the decommissioning regulations, the DP has become the post shutdown decommissioning activities report (PSDAR). While the NRC staff is not required to review and approve the PSDAR, the staff examines the PSDAR and makes a determination as to whether or not it contains the information required by the regulations. The NRC staff has completed this examination and has determined that the SNEF PSDAR in combination .vith the SNEF Environmental Report meets the requirements of the regulations in 10 CFR 50.82(a)(4)(i) regarding PSDARs.

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Hr. Jim Tydeman 2 The method used by the licensees to remove components from the CV and prepare them for shipment would not need prior NRC approvalif the licensees determine from their safety analysis that component removal and shipment does not require a change in the technical specifications (TSs) or raise an unreviewed safety question (10 CFR 50.59 process discussed in the transcript). However, based on the information provided in the PSDAR and our close contact with the licensees, we willinspect the licensees' safety analysis prior to the undertaking of major tasks and will be on site to inspect during the performance of tasks if needed. The licensees may use contractors to plan and carry out these tasks but the licensees are responsible for meeting regulatory requirements.

The other part of your general second point is that the security of the staging building is minimal and poses a considerable risk to the community. You did not provide any details as to what constitutes this risk. The licensees have proposed TSs concerning security of the CV, DSB, and exclusion area. The NRC is in the process of evaluating these proposed TSs to ensure that they meet regulatory requirements as part of our review of the licensees' license amendment request.

In addition to your two general points, you raised six specific points concerning the DP.

Your first three specific points refer to what you believe are omissions in the DP discussion of further deferral of dismantlement. Your points are correct in that the items you refer to are not in the DP. However, this information is not required in the PSDAR. The timing of decommissioning a f acility is the prerogative of the licensee as long as decommissioning can be carried out in accordance with the regulations. We plan to carefully monitor the decommissioning activities of the licensees through our inspection program.

Your fourth specific point (also numbered as 3) is that there is no mention of how the temporary opening in the CV will be sealed. Also there is no estimated dose of contamination release before temporary seals are made. Related to this is your sixth specific point (numbered as 5) where you ask what type of covering will be used for the opening in the CV and the method of attachment. During the NRC review of the DP, a question similar to this was asked of the licensees. The licensees answered that the specific method of sealing the CV was not known at that time; however, the method chosen would not affect releases assumed in the accident analysis and would provide the same degree of environmental boundary that existed prior to installation of the opening. As part of a license amendment request under evaluation by NRC, the NRC staff is reviewing the design and operation of the new CV/DSB ventilation system. We asked the licensees to provide additional detail on the operatior' of the system such as operation of the system with the CV open and the performance of the system with the CV resealed after component removal. The licensees' response to this question will be evaluated as part of the review of the licensees' amendment request.

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Mr. Jim Tydeman 3 October 9, 1997 Your fifth (numbered as 4) specific point is that there is no mention made in the DP of where grouting of components will occur if grouting is performed in response to questions from the NRC staff, the licensees stated that grouting of components would be performed only to fill volds in the components if needed to meet the requirements of the waste disposal site that the components are shipped to. All shipments of radioactive material from the site must meet the applicable transportation regulations and the license requirements of the waste disposal site. For these reasons the timing and location of grouting of components is not a significant issue in the current review of the licensees' proposed license amendment. However, NRC Inspectors will be present for the shipment of significant components from the Sexton site.

l l l hope that our reply to your letter has enhanced your understanding of the decommissioning regulatory process and proposed activities at the SNEF. If I can answer i any additional questions, please contact me at 301 415 1127.

Sincerely, Original signed by:

Alexander Adams, Jr., Senior Project Manager Non Power Reactors and Decommissioning Project Directorate Divislun of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50146

Enclosure:

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Mr. Jim Tydeman 3 Your fifth (numbered as 4) specific point is that there is no mention made in the DP of where grouting of components will occur if grouting is performed. In response to questions from the NRC staff, the licensees stated that grouting of components would be performed only to fill volds in the components if needed to meet the requirements of the waste disposal site that the components are shipped to. All shipments of radioactive material from the site must meet the applicable transportation regulations and the license I requirements of the waste disposal site. For these reasons the timing and location of grouting of components is not a significant issue in the current review of the licensees' l

' proposed license amendment. However, NRC inspectors will be present for the shipment of significant components from the Saxton site.

I hope that our reply to your letter has enhanced your understanding of the decommissioning regulatory process and proposed activities at the SNEF. If I can answer any additional questions, please contact me at 301 415 1127.

Sincerely, M

Alexander Adams, Jr., S lor roject Manager Non Power Reactors and ommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-146

Enclosure:

As stated

y 1 are very concerned. Our county is your hands.

2 And the thir that I think of is 3 credibility. W re looking to your credibility to 4

provip-u's th a safe process.

5 Al?

6 MR. ADAMS: Thank you. Can everybody hear me?

7 Good evening. My name is Al Adams, I'm the

! 8 NRC licensing project manager for the Saxton facility. I 9 work in the Rockville, Maryland, NRC he dquarters.

10 I have a number of other NRC people with me.

11 I'd like to introduce them. Also from the Rockville 12 office is Mike Masnik. He is the acting section chief of 13 thedecommissioningsectionofthenon-h$f[Mr(dreactors, 14 anddecommissioningprojecth((dN*r.**

15 Also with us is Paul Harris, he is a licensing 16 project manager in our office. We have with us, also, 17 Eugene Holler. He is an attorney from NRC headquarters le with the office of the General Counsel.

19 Lee Thonus, he is a project manager from our 20 project office at TF'ee Mile Island. From the NRC region 21 1 office in King of Prussia, Pennsylvania, is Thomas 22 Dragoun, a project scientist who is responsible for the 23 inspection program at Saxton, and John White, who is Tom's 24 supervisor, and chief of the radiation safety branch.

25 From the Region 1 public affairs office, is NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.

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1 Nail Shochen. Ccn I hovo tha noxt olido, plocco? .

4 2 The purpose of tonight's meeting is to provide 3 you with some information on the decommissioning of 4 nuclear reactors, to share with your our experiences in 5 the oversight of decommissioning activities, to explain 6 the Commission's regulations on decommissioning, and where 7 the Saxton facility fits into the regulatory framework, 8 and to allow the licensee to discuss the decommissioning 9 of Saxton, 10 First a few words about NRC. NRC was formed 11 in 1975, succeeding the Atomic Energy Commission, to 12 regulate the various commercial and institutional uses of 13 nuclear energy.

14 NRC has responsibility to protect public 15 health and safety. We accomplish this by three principal 16 regulatory functions.

17 We establish standards and regulations, we 18 issue licenses for facilities and users of nuclear 19 material, and we inspect facilities and users to assure 20 compliance with the requirements.

21 NRC places high priority on keeping the public 22 informed of its work. This is the reason for being here 23 today.

24 At this point it might be helpf,ul to explain 25 some terms that come up frequently, when discussing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.

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9 1 decommissioning. Two of these terms are " radioactive 2 activation and radioactive contamination."

3 Radioactive activation is the process of 4 inducing radioactivity, or making something radioactive by 5 irradiation. Activation can only occur when the reactor 6 is operated, and only in material near the reactor core o

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7 that interacts with the neutrons produced by operation of 8 the reactor.

9 Steel that is inside the reactor vessel, and 10 has been irradjated by neutrons during the time the plant 11 operated, becomes activated.

12 Radioactive contamination is the deposition of 13 radioactive material in a place where it is not desired.

14 For example, the inside of a pump may be 15 contaminated on its surfaces by contact with elements in 16 water that were activated when the water passed through 17 the neutron field in the core of the operating reactor.

la The pump could be decontaminated by removing 19 the radioactive contamination by washing. This T

20 decontamination process may produce some radioactive waste 21 that is d'.smosed of, off-site, but may allow the pump to 22 be released for unrestricted use.

23 On the other hand, no amount of scrubbing on 24 the surface of activated metal in the reactor vessel will 25 remove the atoms scattered :hroughout the interior of the NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.

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1 matcl th0t havo b com] rcdiocctivo duo to cetivation.

2 That piece of metal will have to be physically 3 dismantledanddisposedN/off-site. Items that are 4 activated or contaminated or both are found at the Saxton 5 facility.

6 Two other terms that may be used frequently 7 during a discussion of decommissioning are " radioactive a decay and half life."

9 The nucleus of a radioactive atom is unstable, 10 and wants to disintegrat.e by the emission of charged 11 particles, or photons. This is called radioactive decay.

12 The amount of time it takes for radioactive 13 substance to lose half of its activity by radioactive 14 decay is the half-life.

15 For example, a common element found in the 16 steel used in reactors is cobalt. The radioactive 17 activation of cobalt usually produces a radioactive 18 isotope of cobalt called cobalt 60.

19 It has a half-life of about five and a quarter 20 years, and decays into non-radioactive nickel. As an 21 example, if we assume there was 100 ounces of cobalt 60 at 22 Saxton when it shut down in May 1972, there would be about 23 four ounces of Cobalt 60 today, and about 96 ounces of 24 nickel.

25 This means that 96 percent of Cobalt 60 will NEAL R. GROSS COURT REPORTERS AND TRANSCR:BERS 1323 RHODE ISLAND AVE., N W.

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., 11 1 doesy cway ov0r o p;riod of 25 yacrs.

2 Now I would like to talk, in general, about 3 decommissioning of reactors. There are definite stages in 4 the life of a nuclear reactor, including planning, 5 construction, licensing, operation, and finally 6 decommissioning and license termination. ,

7 The purpose of decommissioning is to remove l l

8 the facility safely from service, and reduce residual 9 radioactivity at the facility and site to a level that 10 permits the release of the site, and termination of the l 11 NRC license.

, 12 The focus of the NRC is limited solely to the i

13 safe removal of the radiological hazards resulting from i

14 the operation and use of the facility, 15 For example, if the licensee has 16 decontaminated structures to levels that meet the release 17 criteria, it is possible that a site could be released and 18 the license terminated, with structures remaining on-site.

19 At that point, the fact that a licensee may or 20 may not choose to spend additional funds to remove 21 buildings from a site, is c utside our regulatory 22 oversight.

23 One aspect of decommissioning is removing the 24 facility safely from servi"... At Saxton, the facility was 25 removed from service in the early 1970's. Once a facility NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE.. N W.

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1 parm2nsntly coccoo operctions, thi oyotems at tho fccility 2 of continuing regulatory concern, are principally those 3 used for the safe storage of irradiated spent fuel.

4 At Saxton, the fuel and some other radioactive 5 components were removed from the facility during the 1972 l I

6 to 1974 time frame. i 1

7 In 1975 the facility was placed into a form of  ;

8 long-term storage, that is now called SAFSTOR, to allow 9 radioactive decay <s! activated and contaminated 10 componer.ts.

11 once the residual levels of radioactive 12 materials are reduced to below certain criteria, either by 13 decontamination or dismantlement and disposal off-site, license 14 the MAC for the facility and si can be terminated.

15 Before the license is terminated, the licensee 16 has to perform an extensive final survey that proves to 17 the NRC that the site is clean enough to terminate the 18 license.

19 The NRC may do a confirmatory survey, to be 20 certain that the site is clean enough. Once the license 21 is terminated, the NRC no longer has any regulatory 22 oversight over the facility or site.

23 This is the ultimate goal of decommissioning, 24 termination of the license.

25 So to summarize, decommissioning is the NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISt.AND AVE., N W.

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,. 13 removal of the facility from service, and the reduction 1:

1 4

2 the levels of radioactivity at the facility and the site, 3 to levels that will ultimately result in the termination L 4 of the license, i

5 NRC oversight activities relate directly to l 6 the proper decontamination and dismantlement of the 7 facility, to protect public health and safety.

8 Now that I've provided some background on

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9 decommissioning I would like to-talk a little about our  !

10 experiences with decommissioning reactors in the United i

11 States.

12 We have had 15 nuclear power reactors 13 permanently cease operations and begin decommissioning 14 since the early 1960s. Also, about 80 research and test 15 reactors have been decommissioned, and have had their l'6 licenses terminated.

17 I have put a fer selected facilities on the is slide. There has been a fa raunt of experience in the 19 area of decommissioning. A number of nuclear power plants 20 licensed by NRC are in long-term storage. The condition 21 is called SAFSTOR.

22 Some nuclear. power plants are actively being 23 dismantled, and one, the Shoreham plant, has had its 24 license terminated.

25 The Fort St. VrLin plant in Colorado is also NEAL R. GROSS court REPORTERS AND TRANSCRSERS 1323 RHoDE ISLAND AVE., N W.

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1 vary cloco to hoving ito licenco termincted. Trojen end 2 Yankee Rowe are currently undergoing active 3 decommissioning.

4 Shippingport was under Departmr,t of Energy ,

5 jurisdiction, but is another example that decommissioning 6 can be completed safely.

7 Please note that Saxton, which was licensed 8 for power levels up to about 35 megawatts, is much smaller 9 than some of the other facilities we have dealt with.

10 NRC also has a number of experienced personnel 11 who are working on oversight of decommissioning 12 activities. Some of these people are with us today.

13 For example, Mike Masnik and Lee Thonus were 14 involved in the oversight of the clean up of Three Mile 15' Island Unit II for many years. And Mike is the project 16 manager for the Trojan nuclear plant, which is now 17 undergoing active decommissioning.

18 Gene Holler is a legal expert on 19 decommissioning rules and regulations, and has worked with 20 our group on many decommissioning issues. I have been 21 project manager for 11 decommissionings and 9 license 22 terninations.

23 In the region, Tom Dragoun has been the 24 inspector for three decommissionings and two license 25 terminations.

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15 1 On my slids about ths ototus of shut down 2 reactors, I show that we have some facilities that are in 1

3 long-term storage, or in decontamination and 4 dismantlement.

5 our regulations require licensees to establish 6 if dismantlement should begin immediately, or if the 7 facility can be stored in a safe, stable condition for 8 some period of time, before the licensee begins 9 dismantlement.

10 The licensee may even conduct a partial 11 dismantlement, followed by a storage period, ending with 12 final dismantlement. This is the path that Saxton has 13 taken, l

14 Our regulations say that under normal 15 circumstances, the licensee has 60 years after shutdown to 16 complete decommissioning.

17 The decision to dismantle immediately or place 18 the facility in storage is a licensee decision. This 19 decision is reviewed by the NRC to ensure that whatever 20 approach is planned, there is acceptable assurance that it 21 would be conducted safely.

22 NRC performed the generic environmental impact 23 study that looked at decommissioning options, and we 1 determined that as long as the licensee complied with our 25 regulations, either opti:n, or a combination of options NEAL R. GROSS CoVRT REPORTERS AND TRANSCRISERS 1323 RHoDE ISLAND AVE., N W.

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16 1 could be occcptcblo. ,

2 One of the principal reasons for arriving at 3 this conclusion is because the risk to public health and 4 safety, and to the environment associated with licensee 5 activities at nuclear reactor facilities undergoing 6 decommissioning, io significantly less than when the plant 7 was operating.

8 The risk at Saxton significantly decreased 9 with the cassation of operations, and the removal of fuel 10 from the site, and continues to decrease during the 11 storage period, due to radioactive decay.

12 This reduction in risk is so significant, that 13 many of the regulatory requirements associated with plant 14 operation are no longer needed.

15 For example, many of the detailed technical 16 requirements applicable only to an operating plant, such 17 as operating parameters and surveillance requirements were 18 gradually removed from the license starting in 1972, based 19 on a detailed evaluation by the NRC staff of the risk.

20 so to summarize, there have been a number of 21 reactors in the United states that have been permanently

22 shutdown, are in the process of decommissioning, and have l

l 23 completed decommissioning and undergone license l 24 termination.

25 Decommissioning is a well established and l

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,. 17 1 undarctood process, and the NRC staff has considerable 2 experience on the oversight of these activities.

3 There is a reduction in regulatory 4 requirements on licensees as decommissioning progresnes.

5 This reduction is based on the significant reduction in 6 risk to the public due to permanent cessation of reactor 7 operation.

8 I next want to talk a littAe about the 9 regulations governing decommissioning. The 10 decommissioning regulations are in addition to other 11 regulations that the licensee must follow, such as those 12 related to radiation safety.

13 Comprehensive regulations dealing with reactor 14 decommissioning were promulgated in 1988.

15 Based on the experience gained over the next seven years, 16 the Commission extensively revised the regulations of 17 1996, 18 In July of 1996, the NRC published a final 19 rule making that substantially changed the decommissioning a

20 process. I will discuss the relationship of the 21 regulations to the Saxton decommissioning process.

22 The regulations require that each power 23 reactor licensee submit a preliminary decommissioning cost 24 estimate about 5 years prior to the projected end of 25 operations.

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l-18 1 obviously, in tha caso of Saxton, tha rocetor ,

a 2 was permanently shut down before/prelin.inary cost estimate 3 was even required by the regulations.

4 However, they still have been collecting the 5 funds necessary for decommissioning the facility, and have 6 submitted decommissioning cost estimates to NRC.

7 The licensee is required to submit a written ,

8 certification to the NRC within 30 days of the decision to 9 permanently cease operations. And, again, when the fuel 10 has been permanently removed from the reactor vessel.

11 Because the Saxton license was permanently, 12 modified in 1972 to allow possession but not operation of 13 the facility, the rules specify that the required 14 certif3 cations have been submitted.

15 Saxton had started down the path for 16 decommissioning and license termination, under 17 decommissioning regulations that the NRC issued in 1988.

18 A decommissioning plan to decontaminate the 19 containment vessel and its structures, systems and 20 components, was submitted to NRC in February of 1996, 21 followed by a decommissioning environmental report, and 22 proposed decommissioning technical specifications.

23 The staff had these documents under review When 24 with a planned completion date of late fall 1996. Vfth 25 the proposed amendment to NRC's decommissioning  ;

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19 on l~ regulations were published 1A July 29, 1996, the licensee 2 requested that the review of the decommissioning plan and 3 related documents be suspended, because of changes to the 4 regulations which eliminated the requirement to submit a 5 decommissioning plan, and the requirement that NRC review 6 the plan.

7 The 1996 regulations state that within two 8 years of permanently ceasing operations, the licensee must 9 submit a post-shutdown decommissioning activities report, 10 called a PSDAR, to the NRC with a copy to the affeeted 11 states.

12 The purpose of the PSDAR is to provide the NRC 13 staff with sufficient information to assure the proper NRC 14 oversight of any significant decommissioning activities, 15 to require the licensee to examine its plans for the 16 funding of the decommissioning activities, and to require 17 the licensee to examine its plans for decommissioning to 18 assure that the activities will not result in 19 environmental impacts that have not been previedly ,

20 considered.

21 For licensees like Saxton, that had a 22 decommissioning plan under review by NRC, the regulations 23 state that the decommissioning plan is considered to be 24 the PSDAR.

. 25 Tne PSDAR must include a description of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.

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I planned decommissioning activities, along with a schedule J

2 for their accomplishment, an estimate of expected costs, 3 and a discussion that provides the reasons for concluding ,

1 4 that the environmental impacts associated with site

]

5 specific decommissioning activities will be bounded by 6 previously issued environmental impact statements.

7 "/he 1996 regulations require the NRC to notice 8 the receipt. of the PSDAR in the Federal Register, and make 9- it available to the public.

10 We are also required to hold a meeting in the 3

11 vicinity of the nuclear site, to allow the licensee an 4

] 12 opportunity to present their plans for decommissioning of i

13 the facility, to describe the role of the NRC in the j 14 decommissioning of the facility, and to listen and respond

15 to questions from members of the pulic.

1

+

in 16 This notice appeared pp the Federal Register

[ 17 on December 19, 1996. This is why we are here tonight, i

18 The licensee is prohibited from undertaking

19 any major decommissioning activities until 90 days after i

i 20 they submit the PSDAR. Major decommissioning activities i- 21 are those activities that result in permanent removal of i

22 major radioactive components, permanent modifications to i

23 the containment, or result in dismantling components for 24 shipment that contain large amounts of radioactive 25- material. We call it, containing greater than class c i NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVE., N W.

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21 1 wtoto.

2 Major components are those such as the reactor ,

3 vessel, steam generators, pressurizers, large bore reactor '

4 coolant system piping, and other large components that are 5 radioactive to a comparable degree.

6 The purpose of the 90 day period is to allow 7 sufficient time for the NRC staff to examine the PSDAR, to 8 publish notification of its receipt in the Federal 9 Register, to hold a public meeting in the vicinity of the 10 facility, to discuss the licensee's plans, and to conduct 11 any necessary safety inspections prior to the initiation 12 of major decommissioning activities.

13 Under the 1996 rule the NRC staff is not 14 required to review and approve the PSDAR. As I stated 15 earlier, the PSDAR must contain a description of planned 16 decommissioning activities, along with a schedule for 17 their accomplishment, an estimate of expected costs, and a 18 discussion that prevides the reasons for concluding that 19 the environmental impacts associated, y%Nhd'hk'e 4 specific 20 decommissioning activities, will be bounded by previously 21 issued environmental impact statements.

22- The staff examines the PSDAR, and makes a 23 determination as to whether or not it provides the 24 information required by=the regulations. In addition, the 25 staff considers comments received from members of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.

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1 public.

J 2 If the information provided is not consistent 3 with the requirements of the 1996 rule, then the NRC staff 4 will require the licensee to amend their submittal, prior F

5 to allowing major decommissioning activities.

6 If the licensee's submittal complies with the 7 information requirements of the 1996 rule, then the NRC 8 staff will document this in a memorandum that will be 9 placed on the docket.

10 For the Saxton facility, the staff is in the 11 process of comparing the information contained in the 12 decommissioning plan, which turned into the PSDAR, with 13 the informational requirements stated in the 1996 rule.

l 14 As I stated earlier, one of the reasons for 15 this meeting is to listen and respond to questions from 16 the public. Your questions and comments tonight, as well 17 as any written comments, will be considered by the staff, 18 and addressed in a memorandum the staff will place on the 19 Saxton docket.

20 The staff hopes to complete determination of 21 the licensee's compliance with the regulations, and 22 considerations-of public comments, by the end of March, 23 Although the Saxton PSDAR was considered to be 24 submitted more than 90 days ago, the licensee has not 25 started any major $ecommissioning activities.

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t 23 1 Thio io baccuoo tharo 10 o requirement in the 2 Saxton license that GPU shall not dismantle or dispose of 3 the facility, or property occupied by the facility, 4 without prior approval of the Commission.

5 The technical specifications state that the 6 licensee is prohibited from taking any action which 7 results in alteration of the containment vessel, removal i

l 8 of major radioactive components, or results in dismantling l 9 of components.

10 These requirements can only be changed by 11 amendment of the facility license. The licensee submitted 12 a request for license amendment to change these 13 requirements, and make other changes to the license and l'4 technical specifications to support decommissioning 15 activities.

16 ThelicenseealsosubmittedanYhkhhhsafety 17 analysis report, which described the current facility 18 condition,and$p)N4etheaccidentanalysis, to include 19 accident scenarios applicable to active decommissioning 20 conditions.

the 21 The NRC staf f currently has/ proposed changes 22 to the facility license and technical specifications under 23 review. The staff is also reviewing the e "' nmental 24 report that was submitted with the decommiss ening plan.

25 This environmental report is now being used to NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE, NW.

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1 cupport tho environm:ntel occaccment which tho NRC will .,

2 prepare for decommissioning activities that will occur 3 after the license amendment is granted.

4 This license amendment request will be noticed 5 in the Federal Register, providing for a 30 day comment 6 period, and an opportunity to request a hearing.

7 The licensee's application and NRC 8 correspondence related to it, can be found in the local 9 public document room for Saxton, located in the Saxton 10 public library.

11 After approval of the license amendment, the 12 licensee could begin to perform major decommissioning 13 activities without specific NRC approval, using a process 14 described in the Commissions regulations, contained in the 15 Code of Federal Regulations, Title 10, Section 50.59, also 16 know as 10 CFR 50.59.

17 10 CFR 50.59 allows licensees to take certain 18 actions without getting prior approval from the 19 Commission, unless the action requires a change in the 20 technical specifications, or raises an unreviewed safety 21 question.

22 The licensee has to perform a review to 23 determine if they can take the action they want without 24 prior NRC approval. The review also contains 25 j:astification if the licensee determines that no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.

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j 25 l 1 unreviewed safety question exists, i

2 The licensee is required to maintain records l 3 of their reviews, and send in reports to NRC. The 4 licensee's process for performing these reviews, and the 5 reviews themselves, are carefully evaluated during NRC 6 inspections.

7 The new rule also imposed some additional 8 requirements on decommissioning activities by the 9 licensee. The licensee is prohibited from performing any 10 decommissioning activity that would foreclose the release 11 of the site for possible unrestricted use, result in 12 significant environmentnl impacts not previously reviewed, 13 or result in there no longer being reasonable assurance 14 that adequate funds will be available for decommissioning.

15 16 Once the staff has amended the license and 17 examined the PSDAR, the regulatory road is clear for the 18_ licensee to begin decommissioning in earnest.

19 The NRC staff will be actively involved in on-20 site inspections, and reviewing licensee documentation of 21 the safety basis of their activities.

22 The NRC staff would continue to have interactions with the 23 public and the affected states.

24 Two years prior to the planned termination of license 25- the license, the licensee would submit a ILc4VW44 i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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1 termination plan. The license termination plan will .

2 include a site characterization, identifdcation of 3 remaining dismantlement activities, plans for site 4 remediaticn, detailed plans for the site termination 5 radiation survey, a description of the end-use of the 6 site, if restricted, an updated site-specific estimate of 7 remaining decommissioning costs, and if needed, a

'l supplement to the environmental report, describing any new 9 information or significant environmental change associated 10 with the licensee's proposed termination activities.

11 The NRC staff will notin the receipt of the 12 license termination plan in the Federal Register, make the 13 plan available for public comment, and afford an 14 opportunity for a hearing on the plan.

15 The NRC will also hold a public meeting in the 16 vicinity of the site, to allow the licensee to explain the 17 license termination plan t0 the public, to discuss the 18 remaining NRC setivities associated with terminating the 19 license, and to allow the public to ask questions.

20 NRC approval of the license termination plan 21 will be made by license amendment, which would authorize <

22 implementation of the license termination plan.

23 The licensee then continues to clean up the 24 site and perform the final radiation survey. The NRC 25 staff will continue to provide oversight during this NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE.. N W.

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27 t-l' procaco, cnd rotoins the option of parforming our own s

2 confirmatory survey of the site.

3 The Commission shall terminate t9e license if 4 it determines that the remaining activities have been 5 performed in accordance with the approved license 6 termination plan, and the terminal radiation survey, and 7 the associated documentat. ion demonstrates that the 8 facility and site are suittble for release.

9 So this is the decommissioning process that 10 Saxton will follow. There are a few aspects of this 11 process that are unique to Saxton. Saxton will probably 12 be the first license taken to termination under these new I

13. regulations.

14 Your questions and your comments are always 15 welcome. Here is the mailing address, phone number, fax 16 number, and electronic mail address for Tom and myself.

17 I would now like to introduce you to John 18 White from NRC Region 2 who will tell you about the 19 decommissioning inspection process, and what will happen 20 at Saxton when decommissioning activity starts.

21 After John speaks, we will be happy to taxe 22 questions about our presentatiens.

23 ITE: Good evening. My name is John 24 White, I'm Chief of the adiation Safety Branch, NRC 25 Region 1.

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i 1 I'd liko to take thic opportunity to ro- .

s <

2 intro ce you to Tom Dragoun. Relative to the inspection 3 process at NRC conducts, has conducted in the past her 4 at Saxton, nd will conduct in the future, Mr. Tom Dr oun 5 is the princi 1 inspector. He is a senior project 6 scientist in the C Region 1, and he is responsi e for 7 the coordination a the conduct of most of the inspection 8 activities that will e conducted here at Sax on.

9 Just a cou e of minutes to ex ain the 10 inspection process that intend for Sa on. Relative to 11 decommissioning, the purpos of our i pection process ,is 12 generally to obtain informati n, by direct observation, 13 and to directly verify that the censee is, in fact, 14 conducting decommissioning act'vi ies in a safe manner.

15 That is our pri ipal c neern, and our 16 principal objective relat ve to our i pection program.

17 In most fa ilities that und go 18 decommissioning, sp t fuel is part of th procsss, and is 19 a major aspect of our inspection effort, bec use this fuel 20 is still high1 radioactive, and is remaining n-site in a

21. spent-fuel p ol.

22 In the case of Saxton -- in the case o 23 Saxton, his is not a factor. As Al pointed out, th fuel 24 at Sa ton was removed from site some 25 years ago, so 25 the e is no fuel remaining at Saxton.

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