ML23152A141

PR-050 and 140 - 63FR50815 - Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors

ML23152A141
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Issue date:	09/23/1998
From:	Roe J Office of Nuclear Reactor Regulation
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PR-050, PR-140, 63FR50815
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ADAMS Template: SECY-067 09/23/1998 PR-050 AND 140 -63FR50815 - FINANCIAL PROTECTION REQUIREMENTS FOR PERMANENTLY SHUTDOWN NUCLEAR POWER REACTORS PR-050 AND 140 63FR50815 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

DOCKET NO. PR-050 AND 140 (63FR50815)

In the Matter of FINANCIAL PROTECTION REQUIREMENTS FOR PERMANENTLY SHUTDOWN NUCLEAR POWER REACTORS DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 10/01/98 09/15/98 FEDERAL REGISTER NOTICE - PROPOSED RULE:

REQUEST TO SOLICIT ADDITIONAL PUBLIC COMMENT 11/02/98 10/27/98 COMMENT OF TENNESSEE VALLEY AUTHORITY (MARK J. BURZYNSKI) (

1) 11/10/98 11/03/98 COMMENT OF PORTLAND GENERAL ELECTRIC COMPANY (STEPHEN M. QUENNOZ, VICE PRESIDENT) (

2) 11/10/98 11/09/98 COMMENT OF NUCLEAR ENERGY INSTITUTE (LYNNETTE HENDRICKS, DIRECTOR) (

3)

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NUC L EAR ENERGY INST I T UTE "98 NO'/ 10 P 3 :40 Lynnette Hendricks

DIRECTOR, PLANT SUPPORT (J)

NUCLEAR GENERATION DMSION November 9, 1998 Mr. John C. Hoyle Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTON:

Dear Mr. Hoyle:

Rulemakings and Adjudications Staff Request for Comments on Proposed Rule, "Financial Protection Requirements for Permanently Shutdown Nuclear Power Plants," (63 FR 50465, September 22, 1998)

David B. Matthews, Deputy Director, NRC Division of Reactor Program Division, requested by letter dated September 11, 1998, that the Nuclear Energy Institute provide supporting cost data and analyses for our assertions regarding costs to cleanup onsite spills of liquids in the event a major tank ruptures during decommissioning. NRC specifically requested estimates of the amount of contaminated soil and the degrees of contamination used as the basis for NEI's assertion that costs to cleanup spills from a tank rupture would be far less than the

$50 million proposed by NRC for rupture of large liquid tanks and in fact far less than the $25 million of minimum coverage proposed by NEI. NEI also recommended that onsite insurance coverage be eliminated altogether when tanks contain less than 1000 gallons of contaminated liquid.

The following comments and attached report provide the technical justifications for j NEI recommended coverage levels.

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The enclosed report performed an analysis of degree of soil contamination resulting ~

from spilling 450,000 gallons of contaminated liquid over spill areas of different sizes. A larger spill area results in less concentrated soil contamination that can be left in place or landfarmed and still meet dose parameters much lower than the NRC's 25 mrem/year dose limit for release oflands for unrestricted release. The analysis assumed very small spill areas resulted in concentrations of contaminants 1776 I STREEl, NW SUITE 400 WASHINGTON DC 20006-3708 PHONE 202 739 8000 FAX 202 785 4019

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Mr. John C. Hoyle November 9, 1998 Page 2 in the top six inches of the spill that exceed concentrations that could remain in place without restrictions on future site use, i.e., the onsite landfill option.

The costs for the most likely disposal options range from $144,000 to leave contamination in place over a large spill area to $7.3 million to send soil from a small spill area to Envirocare for disposal. The highest most likely cost, $7.3 million, is far lower than NRC's estimated $50 million and NEI's conservative coverage level of $25 million.

NEI proposed elimination of coverage altogether when tanks contain less than 1000 gallons of contaminated liquids. Cleanup costs for the 1000 gallon spill are in direct proportion to the smaller volume of liquid flowing onto the soil. Like the larger spill, the highest costs for a 1000 gallon spill result from the small-spill-area scenario and the assumption that material would be contaminated to a level requiring off site disposal at Envirocare for unrestricted site release.

Costs for the 1000-gallon, small-spill-area scenario can be derived directly from the large spill scenario. Because the amount of contaminated water released from the 1000 gallon tank is more than two orders of magnitude less than the 450,000 gallon spill, the spill area and amount of material that would need to be removed would be at least two orders of magnitude smaller than the smallest spill area for the 450,000 gallon spill. On this basis the highest cost for the smallest spill area for the 450,000 gallon scenario, $7.3 million, could be reduced by two orders of magnitude for the 1000 gallon spill resulting in a cost of $73,000. It would not be necessary or financially prudent to purchase special nuclear insurance or even to self insure for onsite cleanup costs of this magnitude.

If we can be of any further assistance in clarifying the basis for our proposed levels of insurance coverage please call me at (202 739-8109) or Paul Genoa at (202 739-8034).

Sincerely, Lynnette Hendricks Enclosure c: Dave Matthews, Deputy Director, Division of Reactor Program Management, NRC NEI Decommissioning Working Group NEI Decommissioning Issues Task Force NEI Financial Issues Task Force

Analysis of the Potential Cost Impact of a Ruptured Borated Water Storage Tank at a Permanently Shutdown Nuclear Power Plant Fina/, Report November 6, 1998 Prepared by Vance & Associates, Inc.

PO Box 997 Ruidoso, NM 88345 Principal Investigator J. N. Vance Prepared for Nuclear Energy Institute 1776 I Street, Suite 400 Washington, DC 20006-3708

TABLE OF CONTENTS Section Introduction Summary and Conclusions Discussion References LIST OF FIGURES Figure 1

2 Cost versus Spill Area.........................................

Area, Volume and Concentration Relationships........,.............

LIST OFT ABLES Tuhk 1

2 Summary of Cleanup and Disposal Costs for the Rupture of a Major Tanlc for Onsite Disposal Options Summary of Cleanup and Disposal Costs for the Rupture of a Major Tank for Offsite Disposal Options 11 page number 1

2 4

11 page number 2

6 page number 3

3

Analysis of the Potential Cost Impact of a Ruptured Borated Water Storage Tank at a Permanently Shutdown Nuclear Power Plant Introduction In October, 1997 the NRC published a proposed rule for "Financial Protection Requirements for Permanently Shutdown Nuclear Power Plants." Included in the risks posed by a shutdown plant was the potential cost of cleaning up contaminated soil from a posrulated rupture of a large slightly contaminated water storage tank, such as a Borated Water Storage Tan1c The extent and cost of the clean up of the soil was based on an estimate provided by SMUD for the rupture of a 450,000 gallon tank at the Rancho Seco Plant. SMUD estimated the cost for the clean up and disposal of the soil to be approximately $25 million, based on a 1991 disposal cost at Barnwell of $150 per cubic foot of soil. The NRC increased this estimate to $54 million to account for the current disposal charge at Barnwell of $320 per cubic foot and added another $54 million to account for the cost of onsite groundwater characterization and monitoring.

The purpose of this analysis is to re-examine the ruptured tank scenario to determine if the NRC estimate is overly conservative, with regard to the soil volume assumed to be contaminated, the disposal charge and the resulting cleanup costs. This analysis examines the feasibility of: (1) reducing the volume of soil requiring disposal by leaving soils in place that have residual contamination significantly below decommissioning levels and (2) using less costly disposal methods such as disposal at Envirocare and/or disposal methods allowed under a 10 CFR 20.302 exemption.

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Summary and Conclusions The spill area associated with the rupture of a large contaminated water tank could vary widely among plants depending on the site and soil characteristics in the area surrounding the storage tank. For spill areas larger than approximately 480,000 square feet, the concentrations of Cs-137 on the soil are low enough that the soil could be left in place at a cost of $120,000 for the survey cost of the spill area. For spill areas smaller than 480,000 square feet, the clean up and disposal costs could be as high as $331,000 for a landfarming disposal option, $442,000 for onsite landfill disposal option and $14.5M for transportation and disposal in the Envirocare facility in Utah. These costs also include the site survey costs. Because of the smaller volumes of contaminated soil associated with smaller spill areas, the costs for all of the disposal options will decrease as the spill area decreases. At spill areas sinaller than approximately 240,000 square feet, the landfarming disposal option may not be an acceptable alternative because the potential dose to a future resident are calculated to exceed the conservative 10 mrem/yr assumed for this study. The remaining two alternatives, onsite landfill and Envirocare, would be acceptable alternatives even with the smallest spill area envisioned for this event. Figure 1 shows the cleanup and disposal costs as function of spill area for all three disposal options.

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November 6, 1998 2

Table 1 summarizes the maximum expected cleanup costs for onsite disposal options from a major tank rupture. -

Table 1 Summary of Cleanup and Disposal Costs for the Rupture of a Major Tank for Onsite Disposal Options Spill Area, sq ft Maximum Total Cost Disposal Method

>480,000

$144,000 In-situ 480,000 to 240,000

$331,000 Landfarming 240,000 to 100,000

$233,000 Landfill It should be noted that the assumptions used in the analysis for the onsite disposal options are considered conservative. The conservatism assumptions include: (1) the 10 mrem/yr dose for any person residing on the site compared to an allowable dose of 25 mrem/yr, (2) a 6" contaminated soil depth, (3) a large occupancy factor for the assumed future site resident and (4) the assumption of no runoff from the site.

Obviously onsite disposal, if available, offers the lowest cost alternatives and would, therefore, be the preferred disposal choice. However, if onsite disposal is not available and offsite disposal is selected as the disposal option, the cleanup and disposal costs are summarized in Table 2.

Table 2 Summary of Cleanup and Disposal Costs for the Rupture of a Major Tank for Offsite Disposal Options Spill Area, sq ft Maximum Total Cost DisJ)OSal Method

>480,000

$18M Envirocare 480,000 to 240,000

$14.5M Envirocare 240,000 to 100,000

$7.3M Envirocare The conclusion from the above analysis is that the costs of the cleanup of a hypothetical spill from a large contaminated water storage tank are significantly smaller than the cost assumed by Prepared for NE1 Vance d: Associates 3

November 6, 1998

the NRC in the proposed rule. The analysis also suggests that it would be beneficial to remove the Cs-137 from any storage tank, by the use of commonplace treatment technologies such as zeolites. The concentration of Cs-137 could be reduced by one to two orders of magnitude by such a treatment method. Soil contamination from the rupture of a tank with concentrations of Cs-137 at or below detection levels would clearly be at levels where the contaminated soil could be left in place.

Discussion In 1991, SMUD submitted an exemption request that included an estimate of the clean up costs for the postulated rupture of the 450,000 gallon Borated Water Storage Tank. The estimate was based on an assumed volume of contaminated soil of 150,000 cubic feet. This value was derived by assuming that 18 inches of gravel and 2 feet of the underlying soil in the area of the ruptured tank would be removed and shipped to Barnwell for disposal at a charge of $150 per cubic foot. Only tritium and cesium-137 were identified as the long-lived radionuclides

• contributing to the contamination in the ruptured tank scenario. Tritium in the water that percolates into the soil will either evaporate or migrate to groundwater and will, therefore, not contn'bute to the contamination of soil. Cesium-137 will adsorb on the soil as the water percolates through the soil giving rise to the contamination of the soil.

The estimate of the area of the spill would normally be the starting point for an analysis of the clean up cost. However, the area of the spill (and the corresponding volume of contaminated soil) will vary considerably from site to site, depending on the porosity of the soil, the slope of the site, the extent of vegetation cover on the soil and the proximity of the storage tank to natural water sources such as rivers, lakes, etc.

The greater the porosity of the soil and vegetation cover, the smaller will be the spill area. Likewise runoff to a water source will reduce the spill area and the radionuclide inventory available for deposition on the soil.

Because of the fixed radionuclide inventory in the storage tank, it can be seen that the larger the spill area, the larger the volume of contaminated soil, but the smaller the radionuclide concentration on the contaminated soil. Conversely, the smaller the area, the smaller the Prepand for NEl Vance & Amx:iates 4

November 6, 1998

volume of contaminated soil and the higher the radionuclide concentration. Of course, it also follows that the higher the radionuclide concentration the greater the potential for more expensive disposal or cleanup methods.

The approach taken in this analysis was to determine the volume and radionuclide concentration associated with different spill areas. Then disposal or cleanup methods were postulated as a function of the concentration of the radionuclide, including leaving the contaminated soil in place if the projected dose is significantly less than the decommissioning residual levels. Cleanup costs were then developed by combining the contaminated soil volumes with the disposal costs.

For the purposes of this analysis it was assumed that there would be no runoff and accordingly the entire radionuclide inventory was assumed to be deposited on the soil in the spill event.

Data were extracted from NUREG/CR-4289 [Ref. 1] on measured radionuclide concentrations in soil around nuclear plants from spills. The data indicate that the concentrations of radionuclides in contaminated soils generally reside in the top few inches and that the concentrations fall off rapidly with depth. This pattern is shown by the data for two plants taken from NUREG/CR-4289 as shown 1below.

Plant A Plant B PrtJ}(llld for NEl Vance &: Auodatu Depth of Sample Centimeters Inches 2

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2.36 10 3.94 14 5.51 4

1.57 8

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Co-60 Cs-137 pCi/g pCi/g 306 88.9 67.0 21.4 15.0 4.9 7.9 2.7 35.7 1.68 4.7 0.31 26.0 3.63 2.5 0.34 4.1 6.48 1.24 2.87 0.17 0.19 0.02 0.10 November 6, 1998

Although these data suggest that the top 2 to 4 inches would contain virtually all of the cesium, it was assumed that the radionuclide inventory from the spill would be deposited in the top 6 inches of soil over the spill area.

The inventory of Cs-137 in the BWST tank is assumed to be 0.06 curies which is the inventory assumed by the NRC in the proposed rule. This inventory corresponds to a concentration of 3.53 E-5 µCi/cc in the water. Data from other plants indicate that this is a reasonable value.

Figure 2 shows the relationship between the spill area, the volume of contaminated soil and the concentration of Cs-137 on the soil.

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0 u There are several methcxls that could be considered for the cleanup or disposal of the contaminated soil. There are different costs and concentration limits associated with each of the methods.

fupandferNEI Vance d: Anociates 6

Navember 6, 1998

The disposal/cleanup methods considered for this analysis are as follows:

in-situ landjanning onsite disposal disposal at Envirocare 's facility The in-situ method involves leaving the soil in place following the spill event, if the Cs-137 concentrations are at or below regulatory residual contamination levels for site decommissioning. This would be the lowest cost alternative. To determine the Cs-137 concentration that would correspond to an acceptable residual contamination level, the computer code RESRAD [Ref. 2] was used to estimate the dose to an individual occupying the site after release by the utility. The assumptions used for the RESRAD computer runs are as follows:

Contaminated Area Depth of Soil Contamination Dose Limit Occupancy and shielding factor Annual Rainfall Annual Percolation Time from Spill to Occupancy 100,000 sq ft 6 inches 10 mrem/yr 0.60 39.4 inches 15.7 inches 5 years The assumed dose limit of 10 mrem/yr is considered conservative when compared to the decommissioning residual dose limit of 25 mrem/yr. The results from the RESRAD analysis indicate that the external dose from ground shine is the dominant dose pathway by 2 to 3 orders of magnitude over inhalation and ingestion pathways and groundwater pathways. The estimated dose from 1 pCi/g of Cs-137 on contaminated soil at 5 years after the spill event is 1.83 mrem/yr. Thus, at a dose limit of 10 mrem/yr the allowable residual Cs-137 concentration on the soil would be 5.5 pCi/g. From Figure 2 this concentration corresponds to a spill area of approximately 480,000 sq ft (approximately 11 acres). For a spill of this size or larger, the contaminated soil would not be removed and accordingly any cleanup costs would be small ( < $0.25M, mainly for survey costs and perhaps some removal of small "hot" spots).

PrqJand for NE]

Vance &: A.uodatu November 6, 1998 7

In the onsite landfarming disposal alternative, the contaminated soil would be removed from the spill area and spread over non-contaminated soil at a depth of 3 to 4 inches. Then the contaminated soil is mixed with the non-contaminated soil by digging to a depth of approxima~ly 6 inches. This has the effect of reducing the dose by a factor of 2 or increasing the allowable cesium concentration by a factor of 2 over the in-situ case. The maximum allowable concentration of Cs-137 for onsite disposal by landfarming would be 11 pCi/g. The cost for removal and disposal of the contaminated soil by landfarming is estimated to be $0.88 per cubic foot. This estimate is based on actual experience by a utility that has used landfarming under a 20.302 exemption. The cost for cleanup and disposal of the 240,000 cubic feet of contaminated soil from a 480,000 square foot spill using the landfarming disposal option is $211,000.

Disposal by land.farming would be an acceptable disposal alternative down to a spill area of approximately 240,000 square feet. At spill areas smaller than this, the Cs-137 concentrations would be too large to allow disposal by landfarming: For spills smaller than 240,000 square feet, an alternative disposal methcxl such as a onsite landfill *or disposal at Envirocare's Utah facility could be used. The Cs-137 concentration limit for the disposal of materials in the Envirocare facility is 560 pCi/g. The cost for transportation and disposal at the Envirocare facility is estimated at $601 per cubic foot ($40/ft' and $20/ft'). The removal and disposal cost for the cleanup of a 240,000 square foot spill using the Envirocare _disposal optio:° is $7.3M.

In the disposal alternative of onsite landfill, a trench would be constructed for the contaminated soil. The contaminated soil would be covered with a 2 to 3 foot thick layer of uncontaminated soil. The exposure pathways for this disposal alternative are to a potential intruder, such as those described for the IMP ACTS-BRC computer code. This computer code. was used to 1Tue disposal prices for disposal at the Envirocare facility are negotiated with individual customers and are, therefore, not available in a published pricing schedule. However, discussions with utilities that have contacted Envirocare indicate that the cost for disposal of large volumes of contaminated soil would likely be in the range of $39 to

$50/ft3.

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November 6, 1998

estimate the potential doses to an intruder that may excavate into the contaminated soil after the site has been release for other uses. The version of the IMPACTS-BRC code used is the version that was modified by an EPRI contractor as described in the EPRI Report NP-5679

[Ref. 3]. The results from the IMPACTS-BRC analysis at 5 years after the spill indicate that at 10 mrem/yr the maximum allowable concentration of Cs-137 is 25.6 pCi/g. The onsite disposal alternative would be acceptable down to the smallest spill area envisioned for a spill of this magnitude. The cost for onsite landfill is estimated at $1.34/ cubic foot of contaminated soil. The disposal cost for a spill of approximately 480,000 square feet would be $322,000.

The cost for surveying the spill area is estimated at $0.20 per square foot plus $24,000 for soil sample collection and gamma spectroscopy measurements. It is assumed that the entire spill area would be surveyed initially to determine the extent of the cleanup, if any, that would be required. Soil samples would be collected for gamma spectroscopy measurements to confirm the depth of the contamination and to correlate with the radiation measurements from the spill area survey. It is assumed that up 100 soil samples would be collected and subjected to gamma spectroscopy measurements regardless of the size of the spill area.

Because the tritium would not be retained on the soil, the tritium would either infiltrate the soil and contribute to groundwater recharge or would evaporate in an evapotranspiration process.

The NRC has estimated that the tritium concentration in groundwater would be less than drinking water standards and, therefore, any treatment for tritium contamination would be unnecessary. The NRC estimated that $54M would be required to monitor groundwater to ensure that the drinking water standard was not exceeded. This estimate seems excessive for a monitoring effort that is intended to confirm that the hydrology models used in the analysis are reasonably accurate. Because tritium is the contaminant of interest in the analysis, the model should only reflect groundwater flow which should not be overly complex. For such an effort the number of wells required to be drilled would not be extensive. In addition, the depth of the wells should also not be excessive for nuclear plant sites because of the proximity to surface water sources. It is estimated that a more limited monitoring effort could be performed for $100,000 to $200,000.

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November 6, 1998

References

1.

Abel, K. H., et al., "Residual Radionuclide Contamination Within and Around Commercial Nuclear Power Plant," NUREG/CR-4289, U.S. Nuclear Regulatory Commission, February, 1986.

2.

Gilbert, C. Yu, Y. C. Yuan, A. J. Zielen, M. J. Jusko, A. Wallo ill, "RESRAD Computer Code Collection, " CCC-552, ORNL-RSIC.

3.

S. Murphy and V. C. Rogers, "Assessment of the IMPACTS-BRC Code,>>

EPRI, NP-5679, May, 1989.

Prepared for NE/

Vance d: AJsociatu 10 Nuvember 6, 1998

Portland General Electric Company Trojan Nuclear Plant 71760 Columbia River Hwy Rainier OR 97048 (503) 556-3713 Secretary, U.S. Nuclear Regulatory Commission Attention: Rulemaking and Adjudications Staff Washington, DC 20555-0001 "98 0

DOCKET NUMBE PROPOSED RULE S [} J-- / L/ tJ DOCKETED U'i1~r1 C (t3FYl SOH5 NOV 1D p 3 : o ember 3, 1998 VPN-069-98 TroJan Nuclear Plant Docket 50-344 License NPF-1 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 of insurance 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)datedNovember 17, 1993. TheNRC granted the full exemption to 10 CFR 50.54(w) pursuant to IO CFR 50.12. The exemption, however, requires PGE to continue to maintain a minimum of $5 million in 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 (> I 000 gallons) containing radioactive liquid as the defining event for determining insurance coverage is not applicable.

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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 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 tanks within the building and administrative controls in place at Trojan.

4.

The small amounts of radioactive liquids generated at Trojan during the decontamination 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 staff is 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 facilities 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 additional premium costs would create a negative impact on decommissioning funds. 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 Paiie 3 of3 Should you have any questions, please contact Joel Westvold, Manager Nuclear Regulatory Affairs, (503) 556-6485, or e-mail: Joel_ Westvold@pgn.com.

SMQ/JDW:rp c:

C. J. Haughney, NRC, NMSS L. H. Thonus, NRC, NRR R. A. Scarano, NRC Region IV David Stewart-Smith, OOE Sincerely, Stephen M. Quennoz Vice President Nuclear And Thermal Operations

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(~3FR50fl5 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 October 27, 1998 Secretary U.S. Nuclear Regulatory Commission A TIN: Rulemakings and Adjudications Staff Washington, D.C. 20555-0001 Gentlemen:

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F-AD, NUCLEAR REGULATORY COMMISSION (NRC) - REQUEST FOR COMMENTS ON FINANCIAL PROTECTION REQUIREMENTS FOR PERMANENTLY SHUTDOWN NUCLEAR POWER REACTORS TVA is pleased to provide comments in response to NRC's Federal Register notice dated September 23, 1998 (volume 63, number 184, page 50815) regarding financial protection requirements for permanently shutdown nuclear power reactors.

Background

On October 30, 1997, the NRC published for comment proposed amendments to its regulations to allow licensees of permanently shutdown nuclear power reactors to reduce onsite and off site insurance coverage under certain conditions (62 FR 58690). In a late comment letter submitted on April 17, 1998, the Nuclear Energy Institute (NEI) argued that the required level of onsite insurance coverage should he lowered to $25 milJion. ln NEI's view, $25 million would be adequate for onsite cleanup costs for radioactive liquid spills. The NRC proposed rulemaking would require $50 million insurance coverage.

The NRC used a postulated rupture of a 450,000 gallon borated water storage tank as the defining event for determining the required insurance coverage. NEI also proposed that the requirement for onsite insurance be eliminated if less than 1000 gallons of contaminated liquid were onsite.

NEI based its recommendation on a model that apportioned the removal of the contaminated soil to various disposal facilities according to the degree of contamination.

Hence, under the NEI's model, some soil would be sent to a Barnwell-type facility, some to a lower cost facility like Envirocare, and some soil could be left onsite under the Commission's decommissioning regulation. NEI stated that under this type of parceling of contaminated soil, $25 million of onsite insurance coverage would be more than V

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. Page 2 October 27, 1998 adequate to cover cleanup' of any postulated radioactive spill. NEI further stated that there has never been a spill in the operating history of commercial nuclear power plants that resulted in remediation costs of $50 million. However, NEI did not provide any specific cost figures, estimates of the amount or degree of soil contamination, or analyses, to support its recommendation to lower the onsite insurance coverage to $25 million.

NRC Request for Comments The NRC requested public comment on the potential cost of cleanup of the onsite spill from a large vessel (>1000 gal) containing radioactive liquid and the appropriate level of insurance coverage. The NRC also has requested NEI to-provide further information supporting its assessment of the costs of cleaning up a large (> 1000 gal) onsite spill of radioactive material and its basis for recommending that onsite coverage sp.ould be reduced to zero when there is less than 1000 gallons of radioactive liquid onsite.

TV A Comments

1. TV A believes that potential cost of cleanup of the onsite spill from a large vessel

(>1000 gal) containing radioactive liquid would be approximately $1.5 million. This estimate is based on a recent spill at one of our facilities that involved approximately 6,000 gallons of radioactive water. About 3,000 gallons of that water got outside the building and contaminated some ground and asphalt. The* contaminated materials were dug up, and the contaminated soil was boxed for storage and/or disposal. The direct cleanup cost was abput $300,000. In addition, the disposal costs for approximately 120 boxes of contaminated soil would cost an additional $1 million.

I

2. NRC should not require insurance coverage in excess of the $25 million proposed by NEI.

3. NRC should provide an option of self-financing in lieu of mandatory insurance coverage.

U.S. Nuclear Regulatory Commission Page3 October 27, 1998 TV A appreciates the opportunity to provide comments on this important subject and looks forward to working with the NRC in the future. If you have any questions, please contact me at (423) 751-2508.

Sincerely,

~i:tr*

Manager Nuclear Licensing cc: U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Mr. A. W. De Agazio, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Ronald W. Hernan, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Robert E. Martin, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 9C: 'Continued on page 4

U.S. Nuclear Regulatory Commission Page4 October 27, 1998 cc: Mr. George J. Mencinsky Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 NRC Resident Inspector Watts Bar Nuclear Plant 1

1260 Nuclear Plant Road Spring City, Tennessee 37381

DOCKET NUMBER PROPOSED RULE 50 + / L/ 0 (p3F'R508l5 NUCLEAR REGULA TORY COMMISSION 10 CFR Parts 50 and 140 RI N 3150-AF79 Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors, AGENCY: Nuclear Regulatory Commission.

ACTION: Proposed Rule: Request To Solicit Additional Public Comment DOCKETED USNRC

[7590-01-P]

"98 OCT -1 Al 1 :24

SUMMARY

On October 30, 1997, the Nuclear Regulatory Commission (NRC) published for comment proposed amendments to its regulations to allow licensees of permanently shutdown nuclear power reactors to reduce onsite and offsite insurance coverage under certain conditions (62 FR 58690). In a late comment letter submitted on April 17, 1998, the Nuclear Energy Institute (NEI) argued that the required level of onsite insurance coverage should be lowered to

$25 million. In NEl's view, $25 million would be adequate for on-site cleanup costs for radioactive liquid spills. The NRC proposed rulemaking would require $50 million insurance coverage. The NRC used a postulated rupture of a 450,000 gallon borated water storage tank as the defining event for determining the required insurance coverage. NEI also proposed that the requirement for onsite insurance be eliminated if less than 1000 gallons of contaminated liquid were onsite.

NEI based its recommendation on a model that-apportioned the removal of the contaminated soil to various disposal facilities according to the degree of contamination.

Hence, under the NEl's model, some soil would be sent to a Barnwell type facility, some to a lower cost facility like Envirocare, and some soil could be left on site under the Commission's decommissioning regulation. NEI stated that under this type of parceling of contaminated soil,

$25 million of onsite insurance coverage would be more than adequate to cover cleanup of any postulated radioactive spill. NEI further stated that there has never been a spill in the operating history of commercial nuclear power plants that resulted in remediation costs of $50 million.

However, NEI did not provide any specific cost figures, estimates of the amount or degree of soil contamination, or analyses, to support its recommendation to lower the onsite insurance coverage to $25 million.

The NRC is requesting public comment on the potential cost of cleanup of the on-site spill from a large vessel (>1000 gal) containing radioactive liquid and the appropriate level of insurance coverage. The NRC also has requested NEI to provide further information supporting its assessment of the costs of cleaning up a large ( >1000 gal) on-site spill of radioactive material and its basis for recommending that onsite coverage should be reduced to zero when there is less than 1000 gallons of radioactive liquid on site.

Yl~ qi IC/C/8' DATES: The comment period expires (45 days after publicatio1,).

ADDRESSES: Send comments by mail addressed to the Secretary, U.S. Nuclear Regulatory Commission, Attention: Rulemakings and Adjudications Staff, Washington, DC 20555-0001.

Hand deliver comments to 11555 Rockville Pike, Rockville, Maryland, between 7:30 a.m. and 4:15 p.m. on Federal workdays.

You may also provide comments by way of the NRC's interactive rulemaking web site through the NRC home page (http://www.nrc.gov). This site provides the capability to upload comments as files (any format) if your web browser supports that function. For information about the interactive rulemaking site, contact Ms. Carol Gallagher, 301-415-5905, e-mail CAG@nrc.gov.

Certain documents related to this rulemaking, including NEl's comments, may be examined at the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC. These documents also may be viewed and downloaded electronically through the int~ractive rulemaking website established by NRC for this rulemaking.

FOR FURTHER INFORMATION CONTACT: George J. Mencinsky, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, telephone:

(301) 415-3093, e-mail GJM@nrc.gov.

. l5~

~\\uA Dated at Rockville, Maryland, this day of

, 1998.

For the Nuclear Regulatory Commission.

W. Roe, Acting Director iv ion of Reactor Program Management ce of Nuclear Reactor Regulation