ML19332E815

Forwards Response to NRC 891004 Request for Addl Info Re Decommissioning Financial Plan & Fort St Vrain Site- Specific Decommissioning Cost Estimate Basis for Preliminary Decommissioning Plan.

ML19332E815
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/01/1989
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML19332E816	List: ML19332E815 ML19332E818 ML19332E819 ML19332E821
References
P-89459, NUDOCS 8912130016
Download: ML19332E815 (17)

Text

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< 0 rubiic service-2420.W. 26th Avenue, Suite 1000, Denver, Colorado 80211

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P.O. Box 840 "

1 Denver co 80201 0840 A. Clegg Crawford e .

NcieIr okrations December 1, 1989 Fort St. Vrain c Unit No. 1 P-89d59

.m U. !S. Nuclear Regulatory Commission 1

AITH: Document Control Desk Washington, D.C. 20555 ATTN: Mr. Seyn;our H. Weiss, Director ,

Non-Power Reactor, Decommissioning and

Environmental Project Directorate Docket No. 50-267

SUBJECT:

PSC RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION

REFERENCE:

(1) NRC letter, Erickson to Crawford, dated 10/4/89-(G-89338)

(2) PSC letter, Crawfordito Weiss, dated June 30, 1989 (P-89228)'

(3) PSC letter, Crawford to Weiss, dated September t 1, 1989 (P-89342) .

Dear Mr. Weiss:

The purpose of this . letter is to respond to the NRC's Request for Additional Information (RFAI), forwarded to Public Service Company of Colorado (PSC) in Reference 1. Attachment 1 to this letter provides PSC responses to NRC questions related to PSC's Decommissioning Financial Plan, which PSC forwarded to the NRC in Reference 2. .

Attachment 2 provides PSC responses to NRC questions related to PSC's Preliminary Decor;.missioning Pl an , al so forwarded in Reference 2. i Other. attachments are provided to support PSC responses to NRC questions in Attachment 2 and are identified as follows:

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1 P 89459 Page 2 j~

December-1, 1989 Attachment 3 Fort St. Vrain (FSV) Site Specific i

Decommissioning Cost Estimate Basis for i Preliminary Decommissioning Plan (EE-DEC-0020, Rev. A, dated November 30,1989).

Attachment 4 Fort St. Vrain Survey and Analyses Results Attachment 5 Annual ' Radiological Environmental Monitoring

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Report (P-89151), dated April 20, 1989.

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Attachment 6 Fort St. Vrain Activation Analysis (EE-DEC-0010, Rev. A, dated 8/31/89).

i Attachment 7 Fort St. Vrain Plateout Analysis for Decommissioning Study (GA Document No. 909658, .

! . Issue A, dated 2/27/89).

PSC is continuing to evaluate various alternatives relative to NRC Questions No. I and 2 on the Decommissioning Financial Plan (Methods i

and Period of Funds Accumulation), and a response to the method and L period of funds accumulation would be premature at this time. PSC intends to complete its evaluation by the end of the year, and, as noted in the telephone conference call of November 1, 1989, PSC 1 desires to arrange a meeting between PSC and the NRC in early 1990 to i discuss these matters further.

1 It should be noted that PSC is still pursuing SAFSTOR as the decommissioning option selected for Fort St. Vrain (FSV). However, PSC is also evaluating the possibility of dismantlement within 10 years after defueling is complete-(referred to in -this response and attachments as "early dismantlement"). The decision to pursue early dismantlement will be influenced by cost proposals currently being

-solicited' by PSC, as well as resolution of issues surrounding shipment of FSV spent fuel to DOE Idaho.

PSC recognizes that this is the first Preliminary Decommissioning Plan to be submitted to NRC for review. Due to the premature nature of the FSV shutdown prior to the expiration of the facility license, much of the Preliminary Decommissioning Plan was based on reasonable assumptions and currently available information. PSC had made plans to include much of the detail requested by the NRC in this RFAI in the Proposed Decommissioning Plan, required to be submitted to the NRC within two. years following permanent cessation of operations as reported to the NRC in Reference 3. PSC has, therefore, responded to l the RFAI to the extent possible given information that is available.  ;

More detailed information will be submitted with the Proposed l Decommissioning Plan, which in accordance with 10 CFR 50.82(a), is to i be submitted to the NRC not later than August 18, 1991. j

f 1 p.~89459- Page 3 December 1,'1989 If you have any- questions, please contact Mr. M.H. . Holmes at (303) 480-6960.-

Very truly yours a& A,N A. Clegg Crawford Vice President Nuclear Operations ACC:CRB/cb Attachments cc: Regional Administrator, Region IV ATTN: Mr. T.F. Westerman, Chief i Projects Section 8 Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain  ;

Mr. Robert M. Quillen, Director Radiation Control Division Colorado Department of Health  !

4210 East 11th Avenue l Denver, CO 80220  ;

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, ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE 1 I

DEC0PtilSSIONING FINANCIAL PLAN NRC Ouestion No. 1: " Method of Funds Accumulation" NRC Ouestion No. 2: " Period of Funds Accumulation" '

(PSC is currently evaluating various alternatives related to NRC i Questions No. I and 2. PSC expects that these responses will be finalized in early 1990, at which time PSC will arrange to meet with the NRC to discuss these matters further.)_

NRC Ouestion No. 3: " Provisions of Trust Aareements" "The- NRC staff recommends that the following provisions be

. incorporated into either the trust agreement that PSC maintains for

-its external funds or license conditions:

Section IV of the trust agreements attached as Appendix A to PSC's June 30, 1989, submission should more closely conform to Section 5 of Appendix B.3 of the draft Regulatory Guide, " Assuring- the Availability of Funds for Decommissioning Nuclear Reactors" (Task DG-1003). This section has been designed to build in safeguards against withdrawals from the decommissioning fund that could be made for non-decommissioning purposes.

The final decommissioning rule requires that decommissioning funds are to be segregated from other utility assets and remain outside a utflity's control. The staff believes that the general ,

philosophy embodied in this requirement encourages the diversity of investments and the preservation of the integrity of external funds so as to better nraserve such funds for their intended

purpose. To this end, t?

v ' recommenos that trust agreements l contain explicit langunc to prohibit both self-dealing (i.e. ,

l investment in and control by the utility) and significant investment in the assets of othcr nuclear utilities."

PSC Response:

PSC is currently interviewing prospective trustees and investment managers to determine if it is possible to upgrade existing services. Selection of a trustee and investment i

manager is expected to be completed prior to the end of the first quarter of 1990. Regardless of whether a new trustee and I investment manager is selected, or the current. trustee and i investment manager is retained, PSC plans to update the trust agreements to satisfy the various requirements of the l

-Attachment 1: Page-2 to P-89459 .

, December 1, 1989  !

I decommissioning rule as well as the recommendations of draft  ;

Regulatory Guide DG 1003. Finalized trust agreements will  !

contain explicit language prohibiting "self-dealing" and significant investment in the assets of other nuclear utilities.

PSC' will. notify the NRC once the selection is finalized and trust: agreements are in place which comply with the. above cited requirements and . recommendations. Once finalized, copies of these trust agreements will be forwarded-to the NRC.

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Y ATTACHMENT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PRELIMINARY DECOPMISSIONING PLAN NRC Ouestion No. 1: Cover letter '

(Page 2) "PSC stated that they utilized'a site-specific cost estimate to establish decommissioning costs because 10 CFR 50.75(c) did not address minimum certified funding for decommissioning of HTGR's.

However, the cost study was not provided for NRC review. PSC must

~ provide a copy of the detailed cost study to support the estimated  !

decommissioning cost." '

PSC Response:

The Site Specific Decommissioning Cost Estimate can be found as Attachment 3 to this letter. The cost estimate details only those costs which are associated with decommissioning as >

identified in the Preliminary Decommissioning Plan. The cost estimate is subject to change as. PSC further refines the decommissioning scenario, timing of events, and associated costs. PSC intends to submit an updated cost estimate with the Proposed Decommissioning Plan, as required by 10 CFR 50.82(a).

NRC Ouestion No. 2: "Buildina and Structures"

'(Page 2-3, Section 2.1.1)' "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."

PSC Response:

This statement was based on operating history and- knowledge of past and . future plant activities. Recent surveys, analysis results, and radiological environmental monitoring results are

-included as Attachments 4 and 5 which support PSC's assumptions that the turbine building, cooling towers, and electrical switchyard do not contain any radioactive components which may require an evaluation as part of the Preliminary Decommissioning Plan. A detailed discussion explaining and documenting the basis for this assumption is provided in the following paragraphs.

Fort St. Vrain (FSV) was designed such that systems within the turbine building do not directly interface with radioactive systems.. Regular sampling of the Condensate System (System 31) and the turbine building sump, combined with weekly radiation and contamination surveys, confirms the absence of radioactive 1

3 Attachment 2 Page 2

.to P-89459

, December 1, 1989 material in the form of loose and fixed surface contamination or radiation areas' resulting from operation of the reactor plant.

The only exceptions are Health- Physics controlled areas established for temporary storage of contaminated- equipment, laboratories for counting radiological samples, and designated  :

storage spaces for radioactive calibration sources. In each of )

these cases, PSC believes only minor time and resources should be required to release these areas for unrestricted use.

Cooling towers are periodically sampled to test for the presence '

of licensed radioactive material. The results of these samples confirm that radioactivity levels are' either below or only 3 slightly- above minimum detectable levels of the most' sensitive l PSC instrumentation. It is PSC's experience - that the activity which is detected is due to naturally-occurring radioactive material in the form of U-238 and Th-232 found in the. sediment i from makeup water obtained from both surface and subsurface i sources.

The electrical switchyard is composed of transformers and electrical switching equipment. None of these components contain licensed radioactive material by design, nor is there a  ;

flow path for . licensed radioactive material to pass to the i switchyard, except by atmospheric release. The radiological  !

environmental monitoring program has not detected a buildup of i radioactive material in the environment immediately surrounding Fort St. Vrain as a -result of plant operation.

4 NRC Ouestion No. 3: "Ma.ior Technical Actions" (Page 3-1) "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 50.75(f)(2), Section 3 should i also contain a preliminary estimate of occupational exposure  !

associated with major decommissioning tasks and the basis for the i estimate."

PSC Response:

l Attachment 3, Site Specific Decommissioning Cost Estimate,  ;

L provides the radiation exposure estimate assaciated with PCRV i decontamination and dismantlement. The exposure estimates included in this attachment were based on a conceptual plan

! prepared for PSC to evaluate early dismantlement. Radiation levels used as the basis for estimating occupational exposure l were derived from Attachment 6, FSV Activation Analysis.

, Results of -the conceptual plan indicated that (1) if PCRV l

dismantlement were to occur 5 years after shutdown, the associated occupational exposure would be 1178 man-Rem, and (2) if PCRV dismantlement were delayed and occurred 15 years af ter l

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F Attachment'2 Page 3 to P-89459  ;

December 1, 1989 shutdown,4mpational exposure would decrease to 348 man-Rem.  ;

PSC, using nuclide data from Attachment 6 and the estimated I occupational exposures from the conceptual plan, estimates that total occupational exposure would be less than 3 man-Rem if PCRV i

dismantlement were delayed until 2043 (55= years after shutdown). '

For systems external to the PCRV, detailed occupational exposure estimates have not yet been prepared. PSC plans to prepare 4 occupational exposure estimates associated with decontamination and dismantlement of these systems in conjunction.with system planning, as' detailed in PSC's response to NRC Question No. 4, 1 and which PSC plans to provide with the Proposed Decommissioning P1an.

Although detailed estimates have not been prepared for dismantling contaminated systems external to the PCRu, no ,

appreciable occupational exposures are anticipated. This assumption 'is based on over 15 years of experience in maintaining and operating these systems. Exposure resulting from these external systems during operating activities has been ,

very low, as reported in Section 2.2 of the Preliminary Decommissioning Plan.

In the Proposed Decommissioning- Plan, PSC plans to include.

further refinements of estimated radiation exposure based on specific radiological survey information and a scheduled plan for dismantling components and systems internal and external to the PCRV.

NRC Ouestion No. 4: " Component Removal Period" (Page ' 3-5, Section 3.2.2) "The total decommissioning costs will depend on which contaminated systems located outside the PCRV will be abandoned or disposed of as low-level waste. The Preliminary <

Decommissioning. Plan should include an identification of how each contaminated system is expected to be handled."

PSC Response:

A brief description of the contaminated systems, proposed disposition, and assumed costs for decontamination and/or dismantlement can be found in the Site Specific Decommissioning Cost Estimate (Attachment 3). Existing survey data was used as the basis for estimating . waste volumes and dismantlement costs of the radioactive systems. .Because decontamination options may be limited and options for abandonment (due to low radiation and contamination levels) are not certain, a combination of decontamination and dismantlement was assumed for the Preliminary Decommissioning Plan cost estimate.

As noted previously, systems external to the PCRV do not have significant amounts of activation products or contamination

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' Attachment 2' Page 4-to-P-89459

.. December 1, 1989 present.- Based on over 15 years of experience in maintaining g.

and:operati.ng these systems, radioactive contamination of these systems (and therefore waste generated during dismantlement) is expected to be low. Additionally, PSC plans to perform decontamination flushes of these systems prior to dismantlement.

Due to the preliminary nature of decisions concerning the disposition of contaminated systems during decommissioning, detailed- plans for the disposition of individual contaminated systems are not available at this . time. Contaminated systems are being- evaluated on a case-by-case basis to determine the best ' method to decontaminate or dismantle each system. The ultimate disposition of each system is subject to change and PSC plans to discuss further plans in the Proposed Decommissioning P1an.  !

i NRC Ouestion No. 5: "Plateout Analysis" (Page 3-8, Section 3.4.1.1) "The referenced Plateout Analysis .

Report, General Atomic Report 110. GA909658, should be provided. The nuclide distribution analysis should discuts the theoretical and l measurement bases used."

PSC Response-1 The referenced analysis, GA909658, "FSV Plateout Analysis for  !

Decommissioning" is included as Attachment 7 to this letter.

The report discusses the theoretical bases, analytical models and measured data comparisons used in the analysis, i

As - noted in the Preliminary Decommissioning Plan, results of this plateout analysis are preliminkry in nature. PSC intends to continue to evaluate the validity of these analyses results .

as components are removed. Any finalized estimates ~ of '

concentrations of plateout nuclides on snajor PCRV and plant components will be included in the Prooosed Decommissioning .

Pl an . -i NRC Ouestion No. 6: " Analysis Results" (Page ^3-10, Section 3.4.1.3) "How do the fission product i concentrations' given in Table 3-1 compare with actual measurements? '

Are there data for other nuclides?"

PSC Response.i Comparisons of predicted plateout concentration a-d measured  ;

data were made from a circulator removed during the July 5th, 1988, shutdown. Detailed results of these comparisons are provided in Section 4, Page 25, of GA909658, "FSV Plateout Analysis for Decommissioning" (Attachment 7). Six nuclides from measured data were compared to predicted concentrations:

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5 Attachment 2 Page 5 to P-89459 December 1,'1989 Kr-85m, Xe-138, Cs-134, Cs-137, I-131, and Sr-90. In general,.

the predicted and measured plateout activities were .in agreement.

NRC Ouestion No. 7: " Activation Analysis" (Page 3-10, 'Section 3.4.2.1) "The referenced Activation Analysis Report (NDG-89-0189) should be provided."  %

PSC Response:

The document referenced in Section 3.4.2.1 l(NDG-89-0189) is an internal PSC memo summarizing the results .of the activation analysis. The actual activation analysis and results are.

documented in EE DEC-0010 "FSV Activation Analysis". This document and applicable appendices (or portions of appendices) are provided as Attachment 6 to this letter.

. As- noted in the Preliminary- Decommissioning Plan, results of this plateout analysis are preliminary in nature. Analyses results will be verified by' analyzing samples of irradiated PCRV-components . as the components are removed. Estimates - of the.

total radioactive material inventory in .the PCRV will be included in the. Proposed Decommissioning Plan.

NRC Ouestion No. 8: " Reactor Components" (Page 3-15, Section 3.5) "The Preliminary Decommissioning P1an

-states that an analysi3 ^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."

PSC Resoonse:

Tne analysis which predicted the isotopic composition of the region constraint devices and other components is provided as Attachment 6, "FSV Activation Analysis". Appendix B of Attachment 6 provides the material composition of each component used in the analysis. Attachment 6, Appendix C, provides the isotopic composition of irradiated components. The calculated neutron fluxes used in the analysis are provided in Figures 5 through 7 of the cited report. Portions of Attachment 6, Appendix A, have been included to show the one-dimensional analytical models used for the PCRV and internal components.

These models should be used in conjunction with Figures 5 through 7 to determine the neutron flux associated with a particular component.

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' Attachment 2 Pege 6 to P-89459. .

. December ~1, 1989  :

Evaluation o f- these analysis results indicates that all components inside the PCRV are not Greater-than Class C wastes, with the exception of the -center-column metal clad reflector blocks, located in each of the the 37 regions.

No specific analyses were performed for the helium circulators and control rod absorber strings since nuclide data is readily available (due to the removal of these-components- from the PCRV during recent outages). Nuclide data collected during removal of these components. indicates that remaining circulators and '

absorber strings are not expected to be Greater-than-Class C wastes.

NRC Ouestion No. 9: "SAFSTOR Issues" (Page 3-19, Section 3. 6) "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."

PSC Resoonse:

A short discussion of the systems required for SAFSTOR and the associated costs are included in Attachment 3, the Site Specific Decommissioning Cost Estimate. The specific configuration of these systems has not been determined at this time, but PSC intends to include this level of detail in the Proposed Decommissioning Plan.

NRC Ouestion No. 10: " Decontamination and Dismantlement Plans" (Page 3-20,- Section 3.7) "A list of components expected to be disposed of as radioactive waste is presented. The nuclide analyses l, performed to characterize these components should be provided."

l l- PSC Resoonse:

The list of components on page 3-20, Section 3.7, of the Preliminary Decommissioning Plan were characterized by both the I activation analysis (Attachment 6) and the plateout analysis L

' (Attachment 7). The components listed are those internal PCRV components which would exceed the surface' contamination limits given in Regulatory Guide 1.86, " Termination of Operating L Licenses for - Nuclear ' Reactors", and/or would exceed the

! recommended residual radioactivity release guidelines of 5 L

microR/hr at one meter, for reactor generated, gamma-emitting isotopes.

The activation analysis performed to characterize those components listed on page 3-20 of the Preliminary Decommissioning Plan may not be detailed or accurate enough to

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Attachment 2 Page.7 '

to P-89459 '

December I', 1989 L characterize materials for the purpose of 10 CFR 61 waste classification. It is anticipated that a more accurate material

, . characterization may be necessary prior to disposal of material l as radioactive waste. l NRC Ouestion No. 11: " Decontamination and~ Dismantlement Plans" l

j (Page 3-20, Section 3.7) "The preliminary decomiss toning 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."

PSC Resoonse:

As discussed in the - Preliminary Decommissioning Plan, a conceptual plan and associated cost estimate were prepared and used as the basis for the PCRV dismantlement costs. A summary of these plans was included in the Preliminary Decommissioning l Plan-(Section3.7). A further breakdown of the costs which were E- developed as a result of this conceptual plan can be found in l

Attachment 3, the Site Specific Decommissioning Cost Estimate.

.NRC Ouestion No. 12:

{ (Page3-21,Section3.7) "A listing is provided of components in the li PCRV that will be decontaminated and dismantled. .A conceptual plan Ifor these activities is discussed in Section 3.7. The plans for 1

decontamination and dismantlement of components outside the PCRV.

'should also be'provided to establish a cost estimate."

PSC Response:

(See PSC response to NRC Question No. 4.)

NRC Ouestion No. 13: " Remove Loose Contamination from PCRV Internal Surfaces" N (Page 3-22, Section 3.7.2) "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."

PSC Resoonse:

The depth of removed concrete discussed in Section 3.7.2 was calculated in the activation analysis (Attachment 6). At 60 years after shutdown, it was predicted that approximately 18-inches of concrete from the top head, 10-inches from the radial concrete, and 8-inches of concrete from the core support floor would require removal to meet the recommended residual radioactivity release guidelines of 5 microR/hr at one meter, for reactor generated, gamma-emitting isotopes. The cost to

i'  : Attachment 2 Page '8

'to P-89459 December-1, 1989 remove and dispose of this concrete is estimated to be approximately $3,800,000 (1989 dollars).

NRC Ouestion No. li:

(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." ,

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PSC Resoonse:

These costs are outlined in Attachment l 3, the Site Specific Decommissioning Cost Estimate.

NRC Ouestion No. 15: "Decomissionina Cost Estimate" (Page 3-35, Section 3.8) "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)."

PSC Response:

L PSC has been evaluating the present decommissioning scenario for the past two years and the Preliminary Decommissioning Plan cost

estimate was compiled at the beginning of 1989. The NRC's Draft Regulatory Guide was forwarded to PSC by the NRC on June 5, 1989-(G-89199), and was not available when this cost estimate was prepared. It was PSC's decision not to revise the cost estimate, since such a revision would' have caused delay .in submittal of 'PSC's Preliminary Decommissioning Plan and since the Draft Regulatory Guide was still in the process' of undergoing industry review and comment.

PSC has reviewed the contents of the Draft Regulatory Guide and ,

confirmed ..that all of the major cost elements- listed in the cited sections of Draft Regulatory Guide DG-1003 are included in Attachment 3, the Site Specific Decommissioning Cost Estimate.

The major elements include the following:

- Planning and preparation costs Decontamination and dismantling costs

- Packaging, shipment and burial costs

- Final radiation survey costs l

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December 1, 1989 l NRC Ouestion No. 16: "Deconnissionina Cost Estimate" (Page 3-36, - Table 3-3) "A breakout of costs as is recommended in

, DG-1003 should be provided. Eee Comment No. (15)."

PSC Resoonse: ,

As stated in the response to NRC Question No.15, PSC did not have Draft Regulatory Guide DG-1003 available at the time of preparation of the Site Specific Decommissioning Cost Estimate.

In addition, PSC recognizes that no format . is specified in DG-1003 for a breakout of costs; rather a list of cost factors is provided which should be considered by the licensee.

However, the Site Specific Decommissioning Cus,t Estimate (Attachment 3) is formatted in a manner wherein the major cost elements can.be readily identified.

NRC Ouestion No. 17:

(Page'4-2, Sections 4.2.1 and 4.2.2) These sections ..." discuss the low-level radwaste management plan and status of disposal facilities.

In order to assess the current situation with regard to disposal of low-level radioactive waste in accordance with 10 CFR 50.75(f)(3),

Section 4.2 should include a preliminary estimate of low-level radwaste quantities including projected 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."

PSC' Response:

For those systems and components inside the PCRV, low-level waste volumes are identified in . Attachment 3, nuclides are identified in Attachments 6 and 7, and waste classifications

-based on isotopic compositions identified in Attachment 6 indicate that all components inside the PCRV are not Greater-than-Class C wastes, with the exception of tn

' center-column metal clad reflector blocks, located in each of lf the.the 37 regions (see PSC response to NRC Question No. 8) .

For those systems and components located outside the PCRV, estimates of low-level waste volumes are identified in Attachment 3. Nuclides in systems external to the PCRV originate from inside the PCRV, Therefore, nuclides in systems external to the PCRV will not differ from those identified Attachments 6 and 7. All wastes generated to date from external systems at FSV have been classified as Class A wastes in

! accordance with 10 CFR 61. Any wastes generated from external l systems in the future during decontamination and dismantlement activities are also expected to be Class A wastes.

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- Attachment 2 Page 20 to,P-89459~  ;

'DecemberL1 , 1989 Regarding information on any significant

, waste ~-(such as mixed waste and chelates),' quantities it is PSC's goal cf special that radioactive waste which also contains hazardous substances will not knowingly be- generated without' first determining the '

reliable availability of a ' vendor capable of processing or treating such waste. PSC is aware of several vendors presently capable of processing or treating a limited range of mixed wastes. Vendor contacts indicate this service will be expanding in the future in response to customer needs. In the event mixed wastes are generated in' the future and processing or treatment .

options are not available, PSC is investigating the process required to obtain a Resource Conversation and Recovery Act-(RCRA) Part A and Part B permit for_ storage of mixed waste. -

Chelates have not been used in the past in radioactive systems at Fort St. Vrain, and no future need is per:eived. This does not imply a PSC commitment that chelates will not be used, should it be determined that they are the best solution to a future problem.

It is PSC's position that the State of Colorado is responsible -

for assuring adequate disposal capacity to meet the needs of radioactive waste generators within Colorado and the Rocky Mountain Compact. Possible non-availability of a low level <

radioactive waste site may prompt a decision by PSC to expedite decommissioning activities to ensure a site is available to' process FSV low-level radioactive waste.

If a waste site is not available by 1993, PSC has the following options: (1) seek agreement with Colorado to have the State take title to low-level- radioactive waste and provide storage; (2) construct and license onsite storage- capacity; or (3) through the Rocky Mountain Compact Board, negotiate radioactive waste i disposal capacity with disposal sites outside-this- compact.

NRC Ouestion No. 18: " Residual Radioactivity Criteria" 1

(Page-5-1, Section 5) "The liRC staff is developing inter)m guidance l for surface and soil contamination levels. This guidance will l provide the basis for ostablishing residual contamination levels for  ;

activated materials, contaminated soils, and surface contamination levels based on a specific dose criterion established by the l Commission. Until the interim guidance is issued, the above guidance 'l should be followed." 1 PSC Resoonse:

J The PSC decommissioning cost estimate is based on decontamination to the recommended residual radioactivity release guideline of 5 microR/hr at one meter, for reactor generated, gamma-emitting isotopes, based on previous l discussions witn the NRC. )

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-Attachment 2 Page.ll

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. December 1, 1989 PSC L notes, however, that the limits recommended for use by the NRC- have. not been formally promulgated by the EPA, nor has the .

NRC issued any interim standards. In the absence of such formally promulgated guidance, PSC does not intend to adopt the limits of 5 microR/hr as the basis for . the residual

<4 radioactivity, release limit in the Fort St. Vrain Preliminary Decommissioning . Plan. It is not PSC's intent to establish a precedent for the nuclear utility industry- by establishing a limit for site release which has not undergone industry review and comment.

Although formal or interim guidance has not yet been promulgated, it is PSC's opinion that such guidance will be forthcoming 'within the next 5 years. Based on : current decommissioning plans, PSC application for Fort St. Vrain site release for unrestricted use should not occur prior to the time that these standards will be issued. Therefore, once. a NRC or EPA limit has been formally established and codified, PSC plans to officially incorporate this limit into its decommissioning plans for Fort St. Vrain and use the limit .as the basis for decontamination and site release.

NPC Ouestion No. 19: " Method to Establish a Residual Release Livt"

(Page 5-2, Section 5.3) "Section 5.3 discusses the method thit PSC intends to use to develop it's proposed limit for residual

. radioactivity. However, in addressing release for unrestricted use, Section 5.3 should reference the existing regulatory criteria as discussed in item (18) above. You will be informed of any changes in our criteria."

PSC Resocnse:

\

The recomended residual radioactivity release guideline of 5 microR/hr at one meter, for reactor generated, gamma-emitting.

itotopes was used as the basis for the cost estimate.

s.

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H ATTACHMENT 3 FORT ST. VRAIN SITE SPECIFIC DECOPMISSIONING COST ESTIMATE Basis for Preliminary Decomissioning Plan (EE-DEC-0020, Rev. A, dated November 30,1989),

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