ML20117C728

Discusses Impact of Final Decommissioning Rule & Requests NRC Concurrence That Requirements to Submit & Obtain Approval of License Termination Plan Have Been Satisfied

ML20117C728
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/22/1996
From:	Borst F PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-96073, NUDOCS 9608280016
Download: ML20117C728 (6)

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S eubiic 16805 WCR service-191/2; Platteville, Colorado 8%51

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August 22,1996 Fort St. Vrain P-96073 U.S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D.C. 20555 ATrN: Mr. Michael F. Weber, Chaf Decommissioning and Regulatory Issues Branch Docket No. 50-267 SUBIECT: Impact of Final Decommissioning Rule on Fort St. Vrain Decommissioning

REFERENCES:

See Reference List on Page 6

Dear Mr. Weber:

This letter outlines Public Service Company of Colorado's review of the NRC's new Decommissioning Rule (Revisions to 10 CFR Parts 2, 50, and 51, 61 CFR 39278, dated July 29,1996, Reference 1), and requests NRC concurrence that the requirements to submit and obtain approval of a license termination plan have been satisfied for the Fort St. Vrain (FSV) decommissioning project.

Decommissioning activities at the Fort St. Vrain Station have been in progress since August 1992 and are nearing completion. PSCo is planning to submit the third and final part of the final survey report by the end of September 1996, and at that time we intend to request that the NRC terminate our 10 CFR Part 50 license.

In accordance with the new Decommissioning Rule,10 CFR 50.82(a)(9) requires that an l I

application for termination of license must be accompanied or preceded by a license termination plan to be submitted for NRC approval. PSCo considers that the decommissioning documentation previously submitted to the NRC, to obtain authorization to begin decommissioning activities, satisfies the requirements of a license termination ll plan. Further, we consider that the NRC has already approved these plans and provided i sufficient opportunity for public comment.

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P-96073 August 22,1996 Page 2

! Each of the requirements of 10 CFR 50.82(a)(9), and the manner in which they have i been satisfied, are addressed below: l I

(i) M license termination plan must be a supplement to the FSAR or

l. equivalent and must be submitted at least 2 years before termination ofthe license

! date. \

. As described below, PSCo considers that all of the required elements of a license ,

termination plan were submitted to the NRC far in advance of the 2 year  !

j requirement. The FSV Proposed Decommissioning Plan (PDP) included most of

] the license termination plan information and, upon its approval, superseded the 2

FSAR in its entirety. The PDP was initially submitted in November 1990 l

} (Reference 2). PSCo also submitted a set of proposed Decommissioning Technical Specifications in December 1990 (Reference 3). The decommissioning ,

supplement to FSV's Environmental Report was submitted in July 1991 ij (Reference 4). After numerous clarifications and revisions, these documents i were approved by the NRC in November 1992 (Reference 5). With our current

plans to submit a request in 1996 for termination of the FSV operating license, these submittals satisfied the 2 year requirement.

i (ii) M license tennination plan must include -

(A) A site characterization; i

PSCo performed an Initial Radiological Site Characterization which I

included over 20,000 measurements at over 5000 survey locations. The results of this characterization effort are provided in the FSV

Decommissioning Plan, Section 3.1, " Facility Radiological Status," and

were also provided to the NRC in a February 1992 letter (Reference 6).

I i The final radiological status of the facility is being documented in a final . J i survey report. This report documents that the facility has been thoroughly l surveyed and that all surfaces meet the acceptance criteria. 1

\ (B) Identifcation of remaining dismantlement activities:  ;

4 Dismantlement activities are fully described in the FSV Decommissioning Plan, Section 2.3, " Decommissioning Activities and Planning." This

! description has been updated on an annual basis as appropriate. Upon

. submittal of the last part of the final survey report, there will be no remaining dismantlement activities. )

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! August 22,1996

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(C) Plansfor site remediation; I 4 i i

PSCo's plans for site cleanup are described in Section 2.3 of the FSV  ;

i Decommissioning Plan, and essentially involve the radiological i decontamination necessary to meet the site acceptance criteria to allow release for unrestricted use. Upon submittal of the last part of the final l survey report, there will be no remaining site remediation activities.

, (D) Detailed plansfor thepnal radiation survey; )

4 )

! PSCo's plans for the final radiation survey were originally provided in the

] FSV Decommissioning Plan, Section 4, " Final Radiation Survey Plan."

i After further discussion with the NRC, a more detailed final radiation l j survey plan was developed and submitted for approval in February 1994 '

. (Reference 7). The NRC approved the detailed final radiation survey plan

, in January 1995 (Reference 8). The final radiation survey effort will be i complete after the NRC reviews' and confirms the results of the final i survey.

(E) A description of the end use of the site, if restricted;

! PSCO is decontaminating and disposing of radioactive materials so that the FSV facility can be surveyed and released without restrictions on future

! use. The site is being repowered as a natural gas-fueled generating-

!. facility, with a useful lifetime of at least 15 years. One combustion i turbine generator has already been installed and placed in commercial

operation and a heat recovery steam generator will be installed, with

- construction scheduled to begin in September 1996. Our intent to repower j the site with non-nuclear fueled equipment was identified in the Proposed Decommissioning Plan (Reference 2).

(F) An updated site-specife estimate of remaining decommissioning costs; and

A detailed site specific estimate of costs associated with decommissioning

the FSV site was submitted to the NRC in June 1991 (Reference 9). This cost estimate was referenced in the NRC's safety evaluation provided with i the Decommissioning Order (Reference 5) and is addressed in the FSV

, Decommissioning Plan, Section 5, " Decommissioning Fixed Price 4

Contract and Funding Plan." The June 1991 cost estimate has been revised several times to reflect project changes, and was most recently 4 revised in the 1994 update of the Decommissioning Plan. A financial i

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P-96073 August 22,1996 Page 4 assurance mechanism is being maintained to ensure adequate financing for completion of the decommissioning project, as required by 10 CFR 50.75.-

i (G) A supplement to the environmental report, pursuant to $51.53, describing any new irgformation or significant environmental change associated with the licensee's proposed termination activities.

2 A Supplement to Applicant's Environmental Report - Post Operating

License Stage - Decommissioning, was submitted for NRC approval in i- July 1991 (Refemnce 4). This supplemental report evaluated the environmental impacts of decommissioning activities, including the transporting and disposal of low' level radioactive waste, and the release of radionuclides to the environs. The NRC prepared an Environmental Assessment and issued a Finding of No Significant Impact in November 1992 (Reference 5).

(iii) The NRC shall notice receipt ofthe license tennination plan and make the license termination plan available for public comment. The NRC shall also schedule a public meeting in the vicinity of the licensee'sfacility upon receipt of the license tennination plan. The NRC shall publish a notice in the Federal Register and in aforum, such as local newspapers, which is readily accessible i to individuals in the vicinity of the site, announcing the date, time and location of the meeting, along with a briefdescription of the purpose of the meeting.

l After PSCo submitted the Proposed Decommissioning Plan, the NRC published a Notice of Consideration ofIssuance of Orders Authorizing Decommissioning and Termination of Possession Only License in the Federal Register on March 13,1992 (57 FR 8940). As described in the FSV Decommissioning Order (Reference 5), no comments or requests for hearing' were received. ,

Also, the NRC published a Notice of Issuance of Environmental Assessment in the Federal Register on November 23,1992 (57 FR 55004).

With regards to public meetings, the NRC and PSCo have discussed on several occasions plans to conduct public meetings in the Platteville, Colorado area, which is the closest community to the FSV site. - The NRC has initiated contact with the Platteville Town Administrator regarding these public meetings and current plans are to conduct one public meeting in late 1996, and a second public meeting most likely in the Spring of 1997. It is noted that PSCo has provided decommissioning planning and status information to the public throughout the decommissioning project, through meetings with county commissioners and the local town council, and through neighborhood newsletters.

P-96073  ;

August 22,1996 l Page 5 PSCO considers that the public was provided notice of PSCo's decommissioning j plans and that appropriate planning efforts are in progress to conduct public meetings in the vicinity of the site, prior to license termination. 1 l

Rated on the above, PSCO requests NRC concurrence with our understanding that all elements of a license termination plan (as required by the NRC's new Decommissioning Rule) have been submitted and approved by the NRC, and that all requirements for public notice and for public meetings either have been satisfied or are currently in the NRC's planning process.

l If you have any questions regarding this information, please contact Mr. M. H. Holmes i at (303) 620-1701.

Sincerely, l

[udeMd b18F Frederick Borst Decommissioning Program Director I

FJB/SWC cc: Regional Administrator, Region IV Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Public Health and Environment

i P-96073 August 22,1996 Page 6 REFERENCES FOR P-96073

1. Decommissioning of Nuclear Power Reactors,10 CFR Parts 2, 50, and 51, Final Rule, dated July 29,1996, 61 FR 39278-39304

2. PSCo Ietter, Crawford to Weiss, dated November 5,1990 (P-90318), Fort St.

Vrain Piups.e4 Decommissioning Plan

3. PSCO letter, Crawford to Weiss, dated December 21,1990 (P-90367),

Decommissioning Technical Specifications

4. PSCo letter, Crawford to Weiss, dated July 10,1991 (P-91219), Supplement to Applicant's Environmental Report - Post Operating License Stage

5. NRC Ietter, Erickson to Crawford, dated November 23,1992 (G-92244),~ Order to Authorize Decommissioning of Fort St. Vrain and Amendment No. 85 to Possession Only License No. DPR-34

6. PSCo Letter, Warembourg to Weiss, dated February 5,1992 (P-92036), Initial Site Characterization Program Results

7. PSCo letter, Warembourg to Austin, dated February 17,1994 (P-94019), Final Survey Plan for Site Release

8. NRC Letter, Pittiglio to Crawford, dated January 26,1995 (G-95020), Response to NRC Comments on the Final Survey Plan for Site Release for Fort St. Vrain Nuclear Generating Station

9. PSCo letter, Crawford to Weiss, dated June 6,1991 (P-91198), Fort St. Vrain Decommissioning Cost Estimate

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