VPN-078-200, Trojan Nuclear Plant - Application for Termination of License
| ML050030054 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/20/2004 |
| From: | Quennoz S Portland General Electric Co |
| To: | Document Control Desk, NRC/FSME |
| References | |
| VPN-078-2004 | |
| Download: ML050030054 (5) | |
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/ PG E Portland General Electric Company Trojan Nuclear Plant 71760 Columbia River Hwvy Rainier, OR 97048 (503) 556-3713 December 20, 2004 VPN-078-2004 Trojan Nuclear Plant Docket 50-344 License NPF-1 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Application for Termination of License In accordance with 10 CFR 50.82(a)(9), this letter submits the Trojan Nuclear Plant Co-Owners" application to the Nuclear Regulatory Commission (NRC) for termination of the Trojan Nuclear Plant Facility Operating (Possession Only) License No. NPF-1. Specifically, as detailed further in this letter, Portland General Electric Company (PGE)2 has completed remaining radiological decommissioning and final radiation surveys of the Trojan Nuclear Plant facility and site in accordance with an NRC-approved license termination plan,3 and the final radiation surveys demonstrate that the facility and site meet the criteria for decommissioning and release of the site for unrestricted use that are stipulated in 10 CFR 20, Subpart E. Therefore, PGE has satisfied the requirements governing termination of a facility license that are stipulated in 10 CFR 50.82(a)(I 1), and respectfully requests that the NRC approve this application and terminate the Trojan Nuclear Plant license by March 31, 2005.
' The Trojan Nuclear Plant is jointly owned by Portland General Electric Company (PGE, 67.5 percent ownership share), the City of Eugene through the Eugene Water and Electric Board (EWEB, 30 percent ownership share), and Pacific Power and Light/PacifiCorp (PP&L, 2.5 percent ownership share). These Trojan Nuclear Plant "Co-Owners" are power reactor licensees under 10 CFR 50 for the Trojan Nuclear Plant license.
2 PGE is the principal owner and has responsibility for maintaining and decommissioning the Trojan Nuclear Plant.
3 Pursuant to 10 CFR 50.82(a)(9), the application for termination of license represented in this letter was preceded by a license termination plan that was approved by the NRC by letter dated February 12, 2001. The NRC-approved Trojan Nuclear Plant License Termination Plan is maintained in PGE Topical Report PGE-1061, "Trojan Nuclear Plant Defueled Safety Analysis Report and License Termination Plan (PGE-1078)."
ess DI Connecting People, Power and Possibilities
VPN-078-2004 December 20, 2004 Page2of5 APPLICATION FOR TERMINATION OF LICENSE 10 CFR 50.82(a)(1 1) states:
The Commission shall terminate the license ifit determines that--
(i) The remaining dismantlement has been performed in accordance with the approved license tenrination plan, and (ii) Thefinal radiation survey and associated documentation, including all assessment of dose contributions associated with parts releasedfor use before approval of the license termination plan, demonstrate that the facility and site have met the criteria for decommissioning in 10 CFR part 20, subpart E.
PGE has satisfied the criteria of 10 CFR 50.82(a)(1 l)(i) and (ii) as cited above that allow NRC termination of the Trojan Nuclear Plant license. Specifically, pursuant to 10 CFR 50.82(a)(I l)(i), PGE has completed remaining dismantlement, including radioactive component removal and/or decontamination and confirmatory final radiation surveys, in accordance with the NRC-approved Trojan Nuclear Plant License Termination Plan.
Radioactive plant components have been removed and disposed of, or have been decontaminated to levels well below regulatory site release criteria. Similarly, contaminated or activated portions of plant structures have either been decontaminated or removed and disposed of. As detailed further below, final radiation survey of the site has also been completed in accordance with the NRC-approved Trojan Nuclear Plant License Termination Plan.
Pursuant to 10 CFR 50.82(a)(1 1)(ii), the final radiation survey and associated documentation demonstrate that the Trojan Nuclear Plant facility and site have met the criteria for decommissioning in 10 CFR 20, Subpart E. Details of the final radiation survey results are documented in Trojan Nuclear Plant Final Survey Reports that have been submitted to the NRC for review and approval (see table on the following page). The potential presence of residual radioactivity from groundwater sources of drinking water is addressed by and documented in a report entitled "Trojan Nuclear Plant Groundwater Report," which demonstrates that there is no significant concentration of residual radioactivity from plant operations in the groundwater.
Collectively, these reports document the conclusion that the facility and site meet the radiological criteria in 10 CFR 20.1402 for release of the site for unrestricted use.4 Submittal details associated with the Trojan Nuclear Plant Final Survey Reports and the Trojan Nuclear Plant Groundwater Report are provided in the table below.
4 Pursuant to 10 CFR 20.1402, "[a] site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA)."
VPN-078-2004 December 20, 2004 Page 3 of 5 Title Submittal Date Letter No.
NRC Approval Date Final Survey Report for October 30, 1996 VPN-067-96 November 26, 1996 Trojan ISFSI Site__
Final Survey Report for October 31, 2003 VPN-059-2003 Containment Building and and September 22, 2004 Interior March 11, 2004 VPN-028-2004 Final Survey Report for Main Steam Support Structure, Electrical March 30, 2004 VPN-026-2004 September 23, 2004 Penetration Area, and Steam Generator Blowdown Building Final Survey Report for Turbine Building and October 12, 2004 VPN-057-2004 October 28, 2004 Control Building Interiors Final Survey Report for November 10, 2004 VPN-063-2004 December 2, 2004 Embedded Piping Final Survey Report for Remaining Plant Secondary November 22, 2004 VPN-069-2004 December 2,2004 Systems Final Survey Report for Auxiliary Building Interior December 3, 2004 VPN-071-2004 Pending Final Survey Report for December 15, 2004 VPN-073-2004 Pending Fuel Building Interior Final Survey Report for Spent Fuel Pool Impacted December 16, 2004 VPN-076-2004 Pending Areas Final Survey Report for Support Facilities and Site December 20, 2004 VPN-077-2004 Pending Grounds Trojan Nuclear Plant NA; See Revision 1 Groundwater Report, January 27, 2003 VPN-003-2003 Approval Revision 0 Trojan Nuclear Plant May 5, 2004 VPN-037-2004 Groundwater Report, and and August 19, 2004 Revision 1 August 12,2004 VPN-048-2004 As indicated above, the Trojan Nuclear Plant Final Survey Reports document that the residual radioactivity associated with facility structures, systems, and components and site grounds meets the dose (25 mrem/yr) and ALARA criteria specified in 10 CFR 20.1402. It is noted that the final radiation survey of the portion of the site that now is the Trojan ISFSI site was conducted prior to the establishment of the current 10 CFR 20.1402 radiological release criteria. As reflected in the NRC-approved Final Survey Report for the Trojan ISFSI Site, survey results verified that residual radioactivity from Trojan Nuclear Plant operations was well below the
VPN-078-2004 December 20, 2004 Page 4 of 5 NRC-approved release criteria in effect at the time. It is further noted that the Trojan ISFSI site area will undergo separate and complete final radiation surveys as part of Trojan ISFSI site decommissioning pursuant to 10 CFR 72.54 (or its descendant) following transport of the Trojan ISFSI stored contents to an off-site repository. Thus, this area will be re-verified to meet the applicable radiological release criteria prior to its release.
OTHER LICENSE TERMINATION CONSIDERATIONS Nuclear liability financial protection As a holder of a license issued under 10 CFR 50 for the Trojan Nuclear Plant, PGE currently maintains nuclear liability financial protection for the Trojan Nuclear Plant as required by 10 CFR 140.1 1(a)(4). By letter dated November 2, 1995, the NRC approved a PGE request for exemption from the requirements of 10 CFR 140.1 1(a)(4) that allowed PGE to reduce the Trojan Nuclear Plant primary financial protection required by 10 CFR 140.1 1(a)(4) from S200 million to $100 million, and to no longer participate in the industry retrospective rating plan (secondary level financial protection) for the Trojan Nuclear Plant. By PGE Letter VPN-01 0-2003 submitted to the NRC on February 28, 2003, PGE requested further exemption from the requirements of 10 CFR 140.11 (a)(4). This additional exemption would have allowed PGE to further reduce the Trojan Nuclear Plant primary financial protection required by 10 CFR 140.1 1(a)(4) from $100 million to $25 million to reflect the transfer of Trojan spent nuclear fuel from the Spent Fuel Pool to the Trojan ISFSI. The NRC denied this request by letter dated December 2, 2004. Thus, PGE continues to maintain $100 million in nuclear liability insurance coverage for the Trojan Nuclear Plant.
The NRC's December 2, 2004, denial of PGE's request for further reduction in liability insurance coverage was preceded by SECY-04-0176 dated September 29, 2004, and associated Staff Requirements Memorandum (SRM) dated October 29, 2004. The SECY and SRM both supported denial of exemption requests for liability insurance coverage reductions below a level of$ 100 million for facilities that have completed the transfer of spent nuclear fuel to an ISFSI.
SECY-04-0176 and the NRC's December 2, 2004, denial of PGE's exemption request acknowledge the fact that 10 CFR 72 does not require liability insurance for ISFSIs. However, the NRC indicated in these documents that a liability insurance coverage level of$ 100 million is an appropriate minimum amount that should be required of a licensee facility with spent nuclear fuel stored on site in an ISFSI.
Based on this and on recent NRC indications that formal nuclear liability coverage requirements for 10 CFR 72 ISFSI licensees may be forthcoming, PGE has elected to continue the current
$100 million level of facility liability insurance coverage following Trojan Nuclear Plant license termination. Furthermore, PGE will maintain a minimum of $100 million in nuclear liability insurance coverage for the Trojan ISFSI unless further reduction is allowed by the NRC via future rulemaking or other regulatory and/or licensing issuance. This PGE commitment to the NRC will be incorporated into the Trojan ISFSI Safety Analysis Report to ensure that the
VPN-078-2004 December 20, 2004 Page 5 of 5 liability insurance coverage level maintained for the Trojan ISFSI will not be reduced below the minimum $100 million amount without priorNRC approval.
Record Fonrarding Requirements In preparation for termination of the Trojan Nuclear Plant license, PGE has reviewed the requirements of 10 CFR 50, as well as those contained in 10 CFR 20, 10 CFR 30, 10 CFR 40, and 10 CFR 70, and has identified several regulations requiring the forwarding of specified records to the appropriate NRC Regional Office prior to license termination. In PGE letter VPN-074-2004 to the NRC Region IV office dated December 20, 2004, PGE addresses these record forwarding requirements and documents the manner in which they are satisfied.
SUMMARY
Based on the above, PGE has satisfied the requirements governing termination of a facility license that are stipulated in 10 CFR 50.82(a)(I 1). Therefore, on behalf of the Trojan Co-Owners, PGE respectfully requests that the NRC approve this application and terminate the Trojan Nuclear Plant license by March 31, 2005.
If there are any questions regarding this letter, please contact Mr. Jerry D. Reid of my staff at (503) 556-6474.
Sincerely, Stephen M. Quennoz Vice President, Generation C:
J. V. Everett, NRC Region IV R. J. Evans, NRC Region IV J. T. Buckley, NRC, NMSS C. M. Regan, NRC, NMSS, SFPO U.S. NRC Document Control Desk D. Stewart-Smith, ODOE A. Bless, ODOE K. D. Beeson, EWEB E. M. Burton, PacifiCorp R. N. Sherman, BPA