ML20237B626
| ML20237B626 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/06/1998 |
| From: | Borst F PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR25527, RTR-NUREG-1625 63FR25527-00004, 63FR25527-4, P-98009, NUDOCS 9808190115 | |
| Download: ML20237B626 (6) | |
Text
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g 17122 WCR 191/2; Platteville, Colorado 80651 hih5 August 6,1998 Fort St. Vrain P-98009 Chief, Rules Review and Directives Branch Office of Administration Mail Stop T6-D59 U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Docket No. 50-267
SUBJECT:
Comments on NUREG-1625 (Draft), " Proposed Standard Technical Spe.idcations for Permaisently Defueled Westinghouse Plants" Gentlemen:
This letkr submits Public Service Company of Colorado's (PSCo) comments on the NRC s Proposed Standard Technical Specifications for Permanently Defueled
" westinghouse Plants, NUREG-1625 (Draft). The NRC noticed this draft NUREG in 63 FR 25527 dated May 8,1998, and requested public comments by August 6,1998.
PSCo's comments are provided in the attachment to this letter.
PSCo has successfully decommissioned the Fort St. Vrain Nuclear Station and submits the attached comments based on our experience with tlie Fort St. Vrain Decommissioning Technical Specifications.
Our experience in performing decommissioning accident analyses, identifying technical specification requirements based on these accident analyses, and in implementing technical specification administrative controls during a deconunissioning project is directly applicable to my nuclear reactor decommissioning project. Some of the systems and components associated with the Fort St. Vrain High Temperature Gas-Cooled Resctor were different from those in a Westinghouse Pressurized Water Reacter, and these unique items are not addressed in PSCo's attsched Comments.
PSCo appreciates the opportunity to comment on these Proposed Standard Technical Specifications for Pernunently Defueled Westinghouse Plants.
We hope that our l
comments can be helpful in providing a consistent set of technical specifications for plants
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l that have permanently shutdown, during the time periods from shutdown, through qent fuel storage in a spent fuel pool, after spent fuel transfer to an Independent Spent Fuel Storage Installation, and during dismantlement and final decommissioning activities.
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If you have any questions regarding these comments, please contact Mr. M. H. Holmes at (303) 571-7633.
l l-Sincerely, (k'
- W Frederi -J Borst Foit St. rain ISFSI Manager Attachment FJB/SWC l
cc:
Document Control Desk j'
Regional Administrator, Region IV Jan Hagers, DOE Idaho Operations Office l
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ATTACIIMENT TO 1
P-98009 i
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PUBLIC SERVICE COMPANY OF COLORADO COMMENTS ON NUREG-1625 (DRAFT)
PROPOSED STANDARD TECHNICAL SPECIFICATIONS FOR PERMANENTLYDEFUELED WESTINGHOUSE PLANTS Public Service Company of Colorado's (PSCo) comments on Draft NUREG-1625 are based on the understanding that these Technical Specifications would apply through the period of active dismantlement (whether during DECON or after a SAFSTOR period),
and up to the time of eventual license termination. Our comments rellect our own Lessons Learned from the decommissioning of Fort St. Vrain, as follows:
1.
PSCo disagrees with basing Permanently Defueled Technical Specifications (PDTS) on the Commission's principle that " Technical Specifications are intended to impose conditions or limitations on reactor operation necessary to avoid an 'immediate threat to public health and safety.' " While this philosophy works fine for protecting the public against accidents involving spent fuel, it leaves the Technical Specifications virtually silent for reactor dismantlement projects where spent fuel is in dry storage.
2.
PSCo considers that the foundational basis for Technical Specifications during l
dismantlement activities should be to keep site boundary doses less than a small fraction (i.e.,10 percent) of the EPA Protective Action Guidelines (PAG) which, combined with actions to shrink the Emergency Planning Zone (EPZ), will thereby eliminate the need for offsite emergency response capability.
For example, site specific dismantlement accident analyses can establish which component handling activities will require confinement and filtered ventilation to ensure that site boundary doses are less than a small fraction of the EPA PAGs in the event of an accidental load drop.
PSCo used this philosophy during development of the Fort St. Vrain Decommissioning Technical Specifications; we shrunk our EPZ, performed accident analyses for various dismantlement load drop scenarios and repowering construction accidents, and proposed LCOs only for equipment and conditions relied upon in the accident analyses to ensure that j
public dose consequences were less than a small fraction of the EPA PAGs.
3.
PSCo agrees that the PDTS do not need to include an LCO for area radiation monitors in the reactor building or waste packaging areas, although the NRC
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required that this be included in the Fort St. Vrain Decommissioning Technica:
1 Specifications.
A strong radiation protection program includes sufficient detectors to monitor dismantlement and waste packaging activities.
4.
PSCo agrees that PDTS requirements should be written to be self-deleting as plant shutdown and decommissioning activities progress.
The Applicability Statements for all LCOs are well written so that the LCOs will no longer apply either after 6 months after the reactor has been permanently shut down (for LCOs related to control of airborne fission products) or after removal of irradiated fuel I
Public Service Company of Colorado Comments on NUREG-1625 Page 2 assemblies from the fuel storage pool.
The Fort St. Vrain Applicability Statements for LCOs for filtered ventilation and containment allowed these LCOs to be deleted after removal of the more activated components that could have released significant radioactivity if they were accidentally dropped. This ensured that ventilation capability was maintained when relied upon but it also allowed for the eventual dismantlement of this system.
5.
PSCo considers that Administrative Controls should also be written to be self-deleting. As decommissioning activities progress and radioactive materials are removed, the need for many of the programs required by the Administrative Controls diminishes.
Maintaining administrative programs is expensive.
Licensees may find that their staff levels are driven by the need to maintain programs that have no useful purpose, but that are required by the PDTS. At Fort St. Vrain, nine months elapsed from submittal of the final survey report to l
termination of the license. PSCo had already documented that the facility met the decommissioning criteria for unrestricted use, but we still had to maintain an access control program, a radiation protection program, an emergency response program, and a fire protection program, and we also had to perform QA audits on these programs. PSCo suggests the following:
Staffing requirements should be relaxed after all spent fuel has been removed from the fuel storage pool (e.g., transferred to an ISFSI). In Table 5.2.2-1, there is no need for a Shift Supervisor at all times with no irradiated fuel left.
Licensees should be given flexibility to reduce operating staff requirements, particularly during back shifts and weekends when there are no decommissioning activities in progress and when there are no fuel considerations.
l The Radiation Protection Program requirement in AC 5.7.1 should be j
revised to clarify what is meant by the statement that the RP Program be maintained and adhered to during "all operations involving personnel radiation exposure." PSCo considers that once radiation levels are reduced to the point where personnel radiation dosimetry is no longer required by 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose, then the licensee may consider that there are no more " operations involving personnel radiation exposure" and the Radiation Protection Program may be discontinued.
The ODCM (AC 5.7.3), Radioactive Effluent Controls Program (AC j
5.7.4), and the Radiological Environmental Monitoring Progam (AC 5.7.5) should be required only until completion of the last effluent release.
I Eventually the gaseous and liquid radioactive waste systems will have to be l
dismantled. After radioactive effluent releases are completed, there is no J
reason to continue the ODCM s;.rveillances. The REMP monitors for l
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Public Service Company of Colorado Comments on NUREG-1625 Page 3 I
effectiveness of efDuent controls, and after completion of efDuent releases,
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this program may also be discontinued.
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The Annual Radiological Environmental Operating and Radioactive EfDuent j
Release Reports (AC 5.8.2,5.8.3) should be required only until completion of the last effluent release. Final reports should be prepared, after which these reports should be discontinued.
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1 The defueled facility security plan required in AC 5.6.1.b should be allowed to be an access control plan after all irradiated nuclear fuel has been removed (e.g., transferred to an ISFSI). Also, the access control plan should then only be required as long as there are radiologically controlled areas on site or as long as the Radiation Protection Program is in effect (see c~unent on AC 5.7.1 above). After all spent fuel has been removed and after there are no radiation hazards, then only an industrial security j
program is required and this should not be a PDTS requirement.
The Fire Protection Program description in AC 5.7.7 should allow the program to be discontinued (or phased down to a non-PDTS, industrial fire protection program) after there is no irradiated fuel or radioactive material to protect.
The Fuel Storage Pool water chemistry, cooling and makeup requirements in AC 5.7.8 and 5.7.9 should be clarified to state that they only apply as long as irradiated fuel remains in the pool. After spent fuel has been transferred to an ISFSI these programs may be discontinued.
l Records retention requirements in AC 5.9.1 and 5.9.2 should be revised to 1
state that the retention period of 3 or 5 years does not apply after license i
termination. As written, the lifetime records required in AC 5.9.3 may be
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discarded when the license is terminated, whereas the 3-and 5-year records i
listed in AC 5.9.1 and 5.9.2 need to be retained. Ilowever, the 3-and 5-year records identified in AC 5.9.1 and 5.9.2 are less significant than the lifetime records identified in AC 5.9.3 and are less important to retain during an extended post-license termination retention period.
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In the Bases discussion B 3.3.1, on page B 3.3-3, the Applicability discussion j
should be revised to include a statement that after (6] months the fission product l
inventory of the fuel will have decayed to the point that OPERABILITY of the f
accident mitigation equipment is no longer required. This statement is included i
in all other Bases for LCOs that may be discontinued after 6 months.
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