ML20247J683

Forwards Comments on Facility Preliminary Decommissioning Plan,Per 890803 & 21 Memos Re Transfer of Regulatory Authority for Reactor Decommissioning

ML20247J683
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/18/1989
From:	Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Weiss S Office of Nuclear Reactor Regulation
References
NUDOCS 8909200252
Download: ML20247J683 (5)

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' s SEP 181989 MEMORANDUN' FOR: Seymour H. Weiss, Director Non-Power Reactor

? 3 Decommissioning and Environmental'

. Directorate,;NRR FROM: . Michael J. Bell, Chief Regulatory Branch Division of Low-Level Waste Management and Decommissioning, NMSS

SUBJECT:

REVIEW 0F FORT ST. VRAIN PRELIMINARY DECOMMISSIONING PLAN As agrecd to in our August 3,1989 memorandum, and in agreement with the March

. 21, 1989 cemorandum regarding the transfer of regulatory authority for reactor decommissioning, we are providing comments on the Fort St. Vrain Preliminary Decommissioning Plan.

If you, or any of your staff, have any questions please contact me at X-20560 or Larry.Pittiglio on X-23438.

b Michael J. Bell, Chief Regulatory Branch Division of Low-Level Waste Management and Decommissioning, NMSS

Enclosure:

As stated Distribution: fdittieffd566$s5E#

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-ACRS Yes 7T7 No /-/

SUBJECT ABSTRACTi~ REVIEW OF TURT ST. VRAIN PRELIMINARY DECOMMISSIONING PLAN

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1 FORT ST. VRAIN PRELIMINARY DECOMMISSIONING PLAN Docket No. 50-267 Bases of Review The Fort St. Vrain Preliminary Decommissioning Plan, was reviewed against the specific provisions of 10 CFR 50.75(f), Draft Regulatory Guide DG-1003 entitled " Assuring the Availability of Funds for Decommissioning Nuclear Reactors" and Draft Regulatorv Guide DG-1005 entitled " Standard Format and Content for Decommissioning i: 2ns for Nuclear Reactors." While we realize draft DG-1005 was developed ta provide guidance on the information required in a Decommissioning Plan, the section in this document entitled " Preliminary Decommissioning Plan" specifically identifies the areas to be addressed in a Preliminary Decommissioning Plan.

1. Page 1; " References" PSC stated that they utilized a site-specific cost estimate to establish decommissioning costs because 10 CFR 50.75(c) did not address HTGR's minimum certified funding for decommissioning. However, the cost study was not provided for our review. PSC needs to provide a copy of the detail 6d cost study for NRC to be able to evaluate the basis for the estimated decommissioning cost.

2. Page 2-3, Section 2.1.1; " Buildings and Structures" Section 2.1.1 states that the turbine building, cooling towers and electrical switchyard do not contain any radioactive components which require an evaluation as part of the Preliminary Decommissioning Plan.

PSC should provide survey data and other information to support this statement.

3. Page 3.1, Section 3; " Major Technical Actions" Section 3 of the Preliminary Decommissioning Plan lists the major technical actions involved in the Fort St. Vrain decommissioning. To demonstrate that these actions will be carried out safely in accordance with 10 CFR Part 50.75(f)(2), Section 3 should also contain a preliminary estimate of occupational exposure associated with major decommissioning tasks and the basis for the estimate.

4. Page 3-5, Section 3.2.2; " Component Removal Period" The total decommissioning costs will depend en which contaminated systems

. located outside the PCRV will be abandoned or disposed of as low-level waste. Tne Preliminary Decommissioning Plan should include an identification of how each contaminated system is expected to be handled.

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5. Page 3-7, Section 3.3.2; " Disposition of Spent Fuel (Segment 9)"

This section states that-PSC is actively pursuing other options for the disposal of Segment 9, which would negate the need for storage of spent  !

fuel in fuel storage wells or independent spent fuel storage installations.

If PSC is successful in having Segment 9 frzadiately disposed of offsite, what will be the impact on the SAFSTOR option?

6. Page 3-8, Section 3.4.1.1, "Plateout Analysis"

The referenced Plateout Analysis Report, General Atomic Report

! No. GA909658, should be provided. The nuclide distribution analysis should discuss the d.eoretical and measurement bases used.

7. Page '3-10, Section 3.4.1.3; " Analysis Results" How do the fission product plateout concentrations given in Table 3-1 compare with actual measurements? Are there data for other nuclides?

8. Page 3-10, Section 3.4.2.1; " Activation Analysis" The referenced Activation Analysis Report (NDG-89-0189) should be provided.

9. Page 3-15, Section, 3.5; " Reactor Components" The Preliminary Decommissioning Plan states that an analysis shows the regional constraint devices are expected to be not Greater-than-Class C radioactive wastes. A copy of this analysis should be provided, as well as any other nuclide analysis performed on reactor components, including the control rod drive orifice assemblies, absorber strings, and helium circulators. These analyses should describe the reactor component materials and the neutron fluxes to which the components were exposed.

10. Page 3-19, Section 3.6; "SAFSTOR Issues"

{ The Preliminary Decommissioning Plan states that the fire protection and electric power systems, as a minimum, will be needed during SAFSTOR. The cost estimate should identify those systems required for operation during the SAFSTOR period and the costs associated with those systems.

11. Page 3-20, Section 3.7; " Decontamination ar.d Dismantlement Plans" A list of components expected to be disposed of as radioactive waste is presented. The nuclide analyses performed to characterize these components should be provided.

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( J,'. 1 Fort St. Vrain Decommissioning Plan 12. Page 3-20. Section 3.7; " Decontamination and Dismantlement Plans" The preliminary decommissioning plan states that it is premature to detail the decontamination and dismantlement methods. However, a conceptual discussion sufficient to estimate decommissioning costs is needed and should be provided.

13. Page 3-21, Section 3.7; " Decontamination and Dismantlement Plans" A listing is provided of components in the PCRV that will be decontaminated and dismantled. A conceptual plan for these activities is discussed in Section 3.7. The plans for decontamination and dismantlement of components outside the PCRV should also be provided to establish a cost estimate.

14. Page 3-22, Section 3.7,2; " Remove Loose Contamination from PCRV Internal Surfaces" The depth of removed concrete should be provided with the basis for selecting this value. The costs to remove this material and dispose of it should also be provided.

15. Pages 3-22 through 3-35, Sections 3.7.3 through 3.7.24; The costs associated with the decontamination, removal, and disposal of PCRV materials should be provided.

16. Page 3.35, Section 8; " Decommissioning Cost Estimate" Section 3.8 provides a listing of decommissioning cost estimates for the principal decommissioning periods. In order to demonstrate that reasonable assurance will be provided that funds will be available for decommissioning as required by 10 CFR 50.75(f), Section 3.8 should include the major cost elements listed in Regulatory Position C.1.4.1 through C.1.4.4 of Draft Regulatory Guide DG-1003, " Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (May 1989).

17. Page 3-36, Table 3-3; " Decommissioning Cost-Estimate" A breakout of costs as is recommended in DG-1003 should be provided. See Comment No. 16.

18. Page 4-2, Sections 4.2.1 and 4.2.2 Sections 4.2.1 and 4.2.2 discuss the low-level radwaste management plan and status of disposal facilities. In order to assess the current osal of low-level radioactive waste in situation accordance with withregard 10 CFRto50.75 disp (f)(3), Section 4.2 should include a preliminary estimate of low-level radwaste quantities including projected

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F Fort St. Vrain Decommissioning Plan volumes, radionuclides, and waste classification, and information on any significant quantities of special waste such as mixed waste and chelates. Based on the estimate, Section 4.2 should then consider the current and projected available means for disposal of this waste. If the State of Colorado is unable to provide disposal capacity for wastes, what storage provisions are planned as a contingency.

19. Page 5-1, Section 5; " Residual Radioactivity Criteria" The use of the surface contamination levels specified in Table I of Regulatory Guide 1.86 is acceptable for the structures to remain on the site following license termination. In addition to rieeting the levels in Regulatory Guide 1.86, the NRC staff has also recomended the use of an exposure rate of 5 uR/h above background measured at 1 m from the surfaces as an acceptable criterion for the release of structures that will remain on site following license termination.

The decicion to release material from the site for disposal in an unlicensed disposal facility during all operations through license termination should be based on the criterion of no measurable contamination. Information Notice No. 85-92 and IE Circular No. 81-07 have previously addressed this issue. However, the NRC staff considers the state-of-the-art detection capabilities for beta-gamma and alpha surface activities to be lower than those in IE Circular No. 81-07. The current dejection level for beta-gama contamination is approximately 1500 dpm/100 cm . Thecurrentdejectionlevelforalphacontaminationis approximately 100 dpm/100 cm . Measurements at these levels should be made at detector scan rate not to exceed 5 cm/sec.

The NRC staff is developing interim guidance for surface and soil contamination levels which is to be available by the end of 1989.

This guidance will provide the basis for establishing residual contamination levels for activated materials, contaminated soils, and surface contamination levels based on a specific dose criterion -

established by the Comission. Until the interim guidance is issued, the above guidance should be followed.

20. Page 5.2, Section 5.3; " Method to Establish a Residual Release Limit" Section 5.3 discusses the method that PSC intends to use to develop PSC's proposed limit for residual radioactivity. However, in addressing release for unrestricted use, Section 5.3 should consider the existing regulatory criteria in this area. At this time, the guidance, provided in Question No.19, should be used until the interim guidance is issued by NRC.

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