ML20056E585

Submits Comments on Interim Rule Re Fee for Svcs to Support FEMA Offsite Radiological Emergency Preparedness Program (44CFR354)

ML20056E585
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/16/1993
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Federal Emergency Management Agency
References
FRN-58FR35770 P-93083, NUDOCS 9308240301
Download: ML20056E585 (2)

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I O rubiic service  :: ' i 16805 WCR 19 1/2; Platteville, Colorado 80651 i

August 16, 1993  ;

Fort St. Vrain Unit No. 1 P-93083 j l

Rules Docket Clerk  ;

office of the General Counsel  !

Federal Emergency Management Agency Room 840 500 C Street,SW  !

Washington, DC 20472 ,

i Docket No. 50-267 ,

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SUBJECT:

44 CFR Part 354 " Fee for Services to Support FEMA's  ;

Offsite Radiological Emergency Preparedness Program"; 58 FR 35770; July 1, 1993; ' Interim Rule l

'and Request for Comments

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REFERENCE:

" Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-520/1-75-001-A, U.S. Environmental Protection Agency, January 1990

.1 Gentlemen: -l This letter submits comments from the Public Service Company of-Colorado (PSC) on the interim rule regarding the fee for services to support FEMA's offsite radiological emergency preparedness program (44 CFR Part 354).

PSC owns the Fort St. Vrain Nuclear Station (FSV), and is currently in the process of actively decommissioning this facility. All irradiated nuclear fuel has been transferred from the FSV Reactor Building to PSC's . Independent- Spent Fuel Storage Installation (ISFSI), ' located approximately 1/4 mile north of the FSV Reactor' ,

The accident analyses documented Building. in- 'the FSV-Decommissioning Plan and in the ISFSI Safety Analysis Report, both of which have been reviewed and approved by the U.S. Nuclear Regulatory Commission, have determined that no credible accident at the FSV plant or at the -ISFSI has the potential- for producing offsite radiological dose consequences that could exceed a small 9308?40301 930816-PDR I \J ADOCK 05000267 F PDR- &}

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. August 16, 1993 Page 2 fraction of the EPA Protective Action Guidelines (the Referenced document). Therefore, it has been concluden that offsite assistance is not required to address potential accitent conditions at the FSV site.

PSC offers the following comment on the interim rule regarding the fee for services to support FEMA's offsite radiological emergency preparedness program (44 CFR Part 354):

Section 354.2(a) of the interim rule, Scope, should clearly state that " Nuclear facilities which the NRC has determined per Appendix A to Part 354,Section III.A, have no potential for significant accidental offsite radiological releases, and therefore require no FEMA site-specific or generic services, are not required to pay FEMA fees."

Many permanently shutdown and defueled nuclear facilities, which have possession-only licenses or approved decommissioning plans, have no potential to create accidents requiring offsite emergency response planning. These permanently shutdown facilities typically have no means of generating further revenue, and should not be required to pay for FEMA services which they do not need or use.

If you have any questions concerning this PSC comment, please contact Mr. M. H. Holmes at (303) 620-1701.

Sincerely,

"[ht Edit Don W. Warembourg Decommissioning Program Director DWW/JRJ cc: Mr. John H. Austin, Chief Decommissioning and Regulatory Issues Branch Regional Administrator, Region IV Mr. Ramon E. Hall, Director Uranium Recovery Field Office Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Health

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