ML19262A015
| ML19262A015 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1979 |
| From: | Schwartz S NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 7910260141 | |
| Download: ML19262A015 (51) | |
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NUCLE AR REGULATORY COMMISSION
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IN THE MATTER OF:
WORKSHOP FOR STATE REVIEW OF THE NUCLEAR REGUIATORY COMMISSION'S DECOMMISSIONING n
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, Place, -. Columbia, South Carolina Date -
Friday, 14. September 1979 Pages 1 - 50 l
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(202) 347 37C0 ACE-FEDERAL REPORTERS,INC.
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NATIONWIDE COVERAGE-DAILY
1 WORKSHOP FOR STATE REVIEW OF THE NUCLEAR 2
m REGULATORY CO!iMISSION'S DECOMMISSIONING 3
POLICY 4
5 PLENARY SESSION 14 September, 1979 6
7 8
Assembly Room Carolina Inn 9
Assembly Street Columbia, South Carolina 10 11 12 Met, pursuant to notice, at 9:00 a.m.
13 m
S 14 BEFORE:
15 MR. SHELDON SCHWARTZ Moderator 16 Office of State Programs Nuclear Regulatory Commission COMMITTEE CHAIPliEN:
18 Committee A:
Richard Wilson, Assistant Attorney 19 General, South Carolina 20 Committee B:
William McGorum, Ohio Power Siting Commis sion 21 Committee C:
Gerald Parker, Massachusetts U
Radiation Program 23 Committee D:
Delegate Steven Sklar, Maryland 24 1216 138
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1 TABLE OF C0NTENTS n
3 Closing Plenary 4
Remarks by Moderator Schwart:
Pages 3 -4 5
6 Committee Reports 7
By :1r. Wilson 4-15 8
By Mr. IkcGorum 15-22 9
10 By Mr. Parker 23-31 11 By Delegate Sklar 32-42 12 13 Comments from Audience Pages 42-50 (g
14 15 16 17 18 19 20 21 22 23 "4
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1 PROCEED INGS 9:20 a.m.
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MODERATOR SCHMARTZ :
Nell, here we 4
are; the hearty have made it through two and a half 5
days and long nights, I think, o f some f airly 6
intensive discussions and negotiations.
And some of 7
you spent a lot of time doing other things too.
8 I would like to thank you all for the 9
perserverance through some f airly dif ficult discussions 10 and negotiations and for sticking to it.
11 I have taken a quick look at some of the 12 draft reports, and I think you have done an excellent 13 job considering the amount of material that you had m
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14 to go through, the amount of support that you had from 15 NRC.* In some cases, it just wasn't enough of us 16 around to answer all of your questions when you had 17 them on thne.
And I apologize for that.
18 I think everybody is in the room, so I think 19 I might as well just let this morning flow.
What we will do is each of the working 20 21 group Chairmen will present the results of the 22 deliberations yesterday and this morning.
I will then i
23 ask or the Chairman will ask if there are any views 24 of that group that were not taken into consideration in F
25 the report.
And I am sure there will be response from
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NRC on some of the questions, perhaps not to solve 2
th6 prcblem or the situation as it is outlined in the 3
report, but more to understand what you mean by some 4
of the comraents.
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5 Following each of the working group reports, 6
I will then entertain any statement from any of the 1
observers.
And then we will just close and thank 8
everybody a~nd beat it to the plane.
9 Are there any questions at this point?
10 (No response. )
11 MODERATOR SCHWARTZ :
Good.
Me will 12 go with the first group, Workshop A, the Blue Group.
13 They had a lot of esprit de corp.
They said, "Let's
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14 go Blue Group."
!. thought it was a football game at 15 one point in time.
16 Rick Wilson.
XXX 17 COMMITTEE A REPORT 18 19 MR. WILSON:
Thank you, Shelly.
20 At the outset, let me make on behalf of the 21 group a..short disclaimer and say that these are *:.e et views of state of ficials but they are not necessarily 23 cfficial state views.
So, these are personal opinions 24 that you are going to be hearing.
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25 The first question. regarding the technical L
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1 and staff reports' adequacy, the following comments 2
were supplied by the members.
3 Most participants indicated that, before 4
they would be prepared to comment in detail, however, 5
the full report should ce made available to them.
Much 6
of the material available to them now is in the form of 7
summary reports which, of course, did not permit de-8 tailed examination of the adequacy of the underlying 9
analyses.
10 Some participants had questions concerning 11 costs of decommissioning.
For example, what is in-12 cluded in the costs?
How would site specificity 13 affect costs?
14 Although this workshop dealt with the NRC 55 licensed facilities, participants felt that all nuclear is facilities should be required to have a decommissioning 17 program.
We did agree with that.
18 Some participants wanted a better introduction 19 to staff reports.
In other words, what are the issues 20 being considered?
What are ranges of choices, and so on.
21 In-house documents such as staff draft reports 22 in contrast to public. draft reports should be available 23 for state review, particularly if their comments are
-s 24 being sought now.
For example, it would have been most 25
' helpful? fo. the six states with Low Level Waste burial C
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sites to have had an advance, indeed any, opportunity 2
to review the staff report regarding those facilities, 3
particularly referring to NUREG-0570.
It was evident 4
that, in the summary report on low level waste facilities 5
water pathways of potential contamination were not ade-6 quately discussed.
7 However, the full report, we are advised, did 8
do so.
Nevertheless, we were unable to conduct a full 9
evaluation of the subject without that data.
This was 10 also true in most of the other technical and staff 11 reports.
12 It is also recommended that a report be pre-13 pared whic: deals with the design construction aspects
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14 of new facilities and their relationship to decom-15 missioning, specifically referencing those features which are intended to facilitate future decommissioning.
16 17 As to Question 2, which involves the early 18 rulemaking viability, the group concluded that early 19 notice of rulemaking is not only viable but very de-20 sirable and, perhaps, even essential.
21 There should be even more liaison and co-51 ordination with " agreement" states.
23 The items which might be addressed in the 1,,,.
rulemaking;should be made available to ' states at an 24
$5 early'date'in. order to provide the necessary lead time Y
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1 to allow for new legislation and other lengthy im-2 plementation efforts.
3 As to Question 3, which involves the five 4
major issues and their correctness, the group concluded 5
that, although the five major issues presented by the 6
staff generally cover most aspects of decommissioning, 7
the availability and the responsibility for making dis-8 posal sites availacle is considered to be an additional P
major issue which should be addressed.
10 Most technical issues were addressed but the 11 institutional issue concerning the period over which 12 control can be maintained over the decommissioning site 13 and the program needs further consideration.
EPA and k.
14 NRC should get together and address this issue as fully 15 as possible.
16 The potential problems resulting from dif-17 ferent federal agencies having jur sdiction should also 18 be addressed, and an effort made by them to harmonize 19 conflicting provisions when they exist.
20 Future uses for decommissioned sites should 21 also be addressed with additional discussion on con-22 ditional versus unrestricted use.
23 y The assumption that a sufficient number of 24 adequate disposal sites will be available should be t
'25 reco!1sidebed.
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As to Question 4, regarding the timing 2
classifications, the group concluded that the timing 3
classification for the half life of about five years should be clarified in terms of the niobium and nickel 4
5 build-up in reactors.
Clarification is also needed re-garding the concentration limitations for the " critical /
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abundant" nuclides.
8 In Question 5 regarding the suggested al-lowable modes, the group stated that flexibility for 9
modifying the decommissioning mode should be provided.
10 11 More detail is requested on the extent of monitoring 12 and surveillance.
13 Question 6 regards the planning requirement.
Our response to the question of, Is the suggested 14 plannh.ngrequirementsatisfactory,wasno.
This re-15 quirement should make clear the need for periodic up-16 17 dating of plans to account for any financial or techno-18 logical changes, among other things, which might occur 19 over time.
The planning requirement should also include 20 an identification of disposal sites and a contingency 21 22 plan if sites are not made available.
23 Proprietary information should be protected 24 when present.
The level of detail for record keeping 25 l
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I regarding as built conditions should be adequate to 2
assure the integrity of decommissioning requirements 3
but should not be unnecessarily burdensome of the li-4 censee.
5 A contingency program for unexpected costs 6
during decommissioning should be further analyzed.
It 7
was also suggested that contingency planning of alterna-a tives in disposal methods be considered.
Such.altern.a-9 tives must be generally available, since such problems 10 would most likely be generic in application.
11 The next question, 7,
also includes a dis-12 cussion of number 12 and regards financial assurance 13 approaches.
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14 The group concluded that no funding alterna-
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15 tive should, at this time, be excluded.
Indeed, we 16 recommend that the suggested alternatives not be ex-17 clusive or in any way limit the states in considering 18 and approving, if appropriate, other alternatives which 19 may be identified.
20 In the consideration of financial assurance 21 alternatives, different approaches may be required for 22
" agreement" and "non-agreement" states, fuel cycle faci-23 lities, economically regulated power reactors, states 24 or state agencies who would assume responsibility, and F
25 so on.
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Municipal or state bonds may also be an 2
option to be considered in appropriate circumstances.
3 The relative roles of NRC and the st.es in approving a financial assurance program should also be 4
developed, with a view toward permitting the states maxi-5 6
mum flexibility in determining appropriate methods of 7
assurance in each case.
3 The estimated costs of decommissioning, in 9
other words, what is concluded and what assumptions underly the estimates, may need more talidation parti-10 eularly when dealing with a particular installation 11 12 whi.ch is prematurely shut down, such as in West Valley, 13 New York.
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14 It was also noted that a state which sets 15 more stringent radiation standards than those proposed 16 by NRC and EPA may have a very significant impact on 17 costs.
18 Furthermore, consideration should be given to 19 requiring regulatory agencies, both state and federal, 20 to bear some financial responsibility for their regula-21 tory actions and approvals when funding is inadequate.
22 However, there was disagreement on this point to the g
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~ extenti that official state certification of a licensee's 24 financial ability might not be thoroughly binding and 25 whether it even should be.
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i The monitoring of expenditures during the 2
decommissioning program should be carried out b'y an in-3 dependent auditing body from the state or federal 4
government in order to assure the effective and efficient 5
use of already available funds and thereby minimize the 6
possibility of cost overruns.
Such overruns should be 7
borne by the licensee with the state or federal govern -
8 ment bearing a secondary responsibility.
9 The estimated costs of decommissioning should 10 be updated on a regular basis and the financial assurance 11 program modified accordingly.
12 All operating facilities should be covered by 13 regulations with none given a "grandf ather clause" ex-14 emption.
Some funding problems are anticipated with some 15 facilities which may require special consideration, 16 however.
17 As to Question 8, which regards the radio-18 active residues and the 5 mrem /Yr. cose, the group con-19 cluded that the data base was lacking to suggest a 20 particular dose limitation for radioactive residues.
21 Resolution or clarification of apparently 22 incongruous standards by EPA and NRC is needed and 23 should be given a.very high priority.
24 As to Question 9 which invoIves the draft g
25 of.the Environmental. Impact Statement, the group noted v
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that only a preliminary draft of the summary ch the I
2 EIS is available, therefore the qun3 tion is somewhat 3
premature.
The participants will need to see the entire 4
draft statement before attempting to render any reliable 5
judgments as to its adequacy.
6 The point at which the decommissioning begins 7
and the normal operating cycle ends needs detailed 8
clarification in order to assure the proper allocation 9
of decommissioning costs to decommissioning activities 10 as opposed to those related to operaticaal shutdown.
11 It is also recommended that solidification of 12 all. liquid waste be required as a matter of policy be-13 fore transport off site.
7/
14 As to Question 10 which regards the regula-15 tory changes which may be required, the group noted that 16 the states should be involved in the decommissioning 17 planning and procedures for a particular facility from 18 the very beginning.
This should be applicable to all 19 states whether agreement states or net.
20
-Compatible regulations should be draf ted to 21 assure-that financial responsibility for decommissioning 22 is maintained during a licenseditransfer from federal 23 to state authority.
24 A delineation of federal an'd state responsi-25 bilities. at every stage of decommissioning should be h
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made.
Particular attention should be given to the 2
permissible scope of NRC reviews of state approved 3
financial assurances.
4 Regulations also should provide for a full i
5 spectrum of enforcement sanctions against violators of 6
decommissioning procedures.
7 Guidelines should also be developed for dose 8
modeling whereby wholebody dose can be determined from 9
concentration and volume of radioactivity on site.
10 As to Question 11 which regards the state 11 changes in their regulatory programs, the group noted 12 that a review of state constitutional powers and legis-13 lative authority and procedures should be conducted.
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14 Requirements for legislation, of course, will vary from 15 state to state but it was generally agreed that attention 16 should be paid to assuring that state regulations are 17 compatible with federal regulations at the point of 18 transfer of responsibility.
11 The responsible state agency should be speci-20 fically designated to administer state responsibilities 21 and exercise appropriate authority.
State regulations, Z!
however, should provide for flexibility in conducting 23 state regulatory duties.over the course of years.
.There 24 should also be no question that the administering state
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-has the requisite-authority to impose appropriate 9
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financial arrangements.
The integrity of furds dedi-2 cated for decommissioning should be protected by law.
3 The last section that we treated is not 4
really number 12, although-you have it on your draft 5
before you.
These are additional comments that we do 6
submit for your consideration.
7 First, it was felt that facilities which have 8
a premature shutdown,and closing should be decontaminated 9
to the same' level as would be required in planned de-10 commissioning, for example, Three Mile Island.
That 11 should be the goal, to get it down to the same level.
12 Next, it was suggested that a procedure should 13 be developed whereby the costs associated with an un-s 14 planned shutdown which results in premature decom-15 missioning can be allocated to the remedial program and 16 to the normal decommissioning.
17 Lastly, it was felt that decommissioTed 18 federal facilities should meet the same radiation stan-19 dards for decommissioning as all other facilities, for 2
example, Department of Defense as well as Department of 21 Energy and other federal agencies.
21 With that, I would just like to thank our 23 group members for their cooperation, and the efforts and 24 hard work they did put in, and Shelly for inviting us and 5
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state officials to the NRC.
I think this is a good 2
effort, and we do applaud the efforts of the NRC in this 3
regard.
Thank you.
4 MODERATOR SCHWARTZ:
Rick, thank you so much 5
for a vary detailed report.
You and your group are to be 6
congratulated.
7 For those who don't have copies of the draft 8
reports, there are some on the back table.
9 Are there any comments from Rick's group that 10 were not included, and someone wants to include in the 11 record?
12 (No response.)
13 Good.
We'll go on, then, to Group B, the m
14 Green Group.
Bill McGorum.
t 15 Bill, I wish maybe you would spend a couple 16 of seconds.
I went in there with your group a few times 17 and I heard you counting down, one through ten, and saw 18 hands popping up.
I just couldn't figure out what was 19 going on.
It seemed like a unique way to get concensus.
20 Will you spend a couple of seconds talking about it?
21 COMMITTEE B REPORT 22 23 MR. MCGORUM:
Thank. you, Shelly.
24 Ladies and gentlemen, I woul'd like to say just 7
25 a couple things by way of introduction, if I might.
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I would like to point out somethi.ig that you, Shelly, 2
already know, that the Green people have a long histo';y 3
of dedicated, unselfish and hi</hly effective public 4
service.
They have developed, over this period of time, 5
a certainly well-deserved reputation for developing 6
sound, sensible and constructive solutions to complex 7
public policy problems.
8 I don't want to embarrass any one of these 9
individuals by singling out him or her for commendation 10 but I would, however, like to ask if the Green people 11 would simply stand up and be recognized.
Would you 12 please do that?
13 We have also discovered here, during this R
i 14 conference, that there is a difference between green
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15 and lime.
I call this to your attention and also, green 16 and blue, Shelly.
17 I would like to say, too, that we do have a 18 tape of most of the proceedings which is in the very 19 safe custody, I might add, of Ralph Luther of Connecticut 20 so, if you don't believe anything we say, Ralph can 21 probably prove that we did say it.
22 I would also lika to say that we in the Green 23 Group here, simply have no disclaimers or, as far as I 24 know, any minority reports.
We simply ~ stand on our 25 report as submitted.
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I might also add, and then I am going to 2
finish my comments, that these comments in our report, 3
you will understand, are simply very terse summariza-
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4 tions.
We have'done this deliberately so you and your 5
staff will not have to spend a great deal of time trying 6
to figure out what it was that we said.
7 Now, quickly, down through the questions.
8 Question number 1 dealing with technical and 9
staff reports.
Our response was that the group felt 10 that the reports are generally adequate, certainly a 11 major improvement over last year, with three specific 12 exceptions.
13 We felt that possibly there was an inadequate
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14 basis for comparing risks associated with exposure to 15 various levels of residual radiation.
16 There was no clear, we felt, specification 17 of what happens to decontaminated material when it is 18 removed to burial sites for the purpose of decem-19 missioning.
20 And, finally, the issues in the financial 21 area, we felt, are well identified as issues.
- However, 22 several members of the group disagreed with some of the 23 conclusions drawn and felt that the costs for the esti-24 mates of decommissi.,.u.ng may be unreali'stically low,
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particularly'for their particular states.
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Question 2, the major goal of early rule-2 making, is it viable?
The group felt that most of the 3
major components necessary are certainly available and 4
were presented to us the first day.
Therefore, the 5
group can endorse the start of rulemaking for early 1980 6
which, I understand, is your objective.
7 Question 3, on the major issues, the group
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8 felt that the five major issues identified are correctly 9
chosen.
They also felt that a sixth issue should be 10 added, namely continuing long-term-responsibility.
11 Question 4 regarding timing classifications, 12 are they useful and adequate.
This group felt, I think, l's somewhat similar to the Blue Group, that the labels are S
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In probably confusing from a decision-making viewpoint and 15 did suggest that those labels which now talk about a 16 half life of five years should be understood to mean 17 a thirty-year period for decay; thirty years should be 18 understood to mean a hundred-year period for decay and 19-that the thirty years should be understood to mean an 20 infinite period.
21 On the fifth question, allowable modes for 22 timing classification, are-they satisfactory, the 23 group simply. felt that the modes are satisfactory.
24 Number 6, planning requiremehts.
The group 25 felt that, for those facilities in which decommissioning
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is terminal, the following should be added.
2 There should be review of existing facilities 3
to assure conformance to initial planning requirements.
4 By this, they meant for those facilities that are already
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5 in operation, we should go back and review and make sure 6
to' bring them up to the same starting point that we 7
would for, maybe, a new facility.
8 And then, that a separate item should be added 9
under the plans, both " Initial Plans" and " Final Plans" 10 should have added the element of cost as a consideration.
11 Question 7, are the suggested financial as-12 surance approaches acceptable?
This, possibly as in 13 most groups, was one.of our longest discussions and one m(
14 of our longest responses.
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15 The group felt that the alternative financial 16 assurance approaches which were listed--I think there 17 were six of them--were generally okay except that we 18 felt that a couple things should be changed.
The 19 "unfunded" we felt should be " unsegregated" and we felt 20 that the insurance should be expanded to include not 21 only for " pooling" and also "self"' insurance, either 22 the utility itself or the state itself.
23 Going beyond that, the group felt somewhat 24 similar to the Blue Group that the list was not exhau'stive
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financial approaches.
These other approaches may well 2
be combinations or modifications of the six basic ap-3 proaches listed above.
4 I think, in our view, we saw these six things 5
as modules, if you will.
You could take these modules 6
and put them together into maybe, who knows, 397 dif-7 ferent combinations or permutations.
8 The group also felt that attention should be 9
give'n to the differences between public utility type 10 facilities and other non-public utility type facilities.
11 Additionally, the group felt that the financial ap-12 proaches listed above, namely, the six, should not nec-13 essarily be prioritized even though, to list them, one
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14 has to come first and one has to come last.
In viewing s
15 those, there shouldn't appear to be any degree of 16 priority.
17 Question 8, limit of radioactive residues.
18 The group was fully in favor of keeping potential ex-19 posure as low as reasonably achievable.
The group, T
however, felt that a maximum dose rate of 5 mrem /Yr.
21 generally tends to be--and for some types of facilities 5
appears definitely to be--unrealistically low.
23
~They went on to say, also--and this is an 24 addition, Shelly--that the NRC needs to reconsider,
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2 possibly, the technological capabilities of measuring
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21 dose rate increments which will be the subject of the sl7 1
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2 regulations.
s On Question 9, the Draft Environmental Impact 3
here again we somewhat reflected the Blue i
4 Statement, 1
5 Group.
Without having had an opportunity to review i
6 the Draft EIS in detail, the group felt that it could 7
It did feel, however, that the EIS 8
not comment fully.
4 if feasible--and possibly already does--
i 9
should include, information on dose rates from residual radioactivity 10 after decommissioning of various types of facilities.
4 4
11 Consideration should also be given to in-l 12 cluding necessary long term surveillance responsibility I
13 by,the states which, as yop recall, was one of the items 3
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that we wanted to add to the list earlier.
15
' g, On Question 10, are the regulatory changes 16 f;j suggested adequate to assure safe decommissioning, the
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19 43%
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on Question 11, areas of states proposing E50 N
Mr
%n changes, the group felt that, possibly, there are areas 21
'3'Nd L%
in which state regulatory programs should be revised in S
av -
w order to be consistent with the proposed federal regu-0 M
%c The Blue Group, of course, went into c
hh)q 24 latory changes.
k However, our group felt that this M
25 more detail on this.
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would be a major exercise beyond ti.; scope of this 2
workshop and we really shouldn't get into it at this 3
time.
4 Finally, Question 12, should the states pro-
/
5 vide certification.
The group felt that the states 6
should not necessarily be required to certify an ap-7 plicant's financial plan.
I think this is partly in 8
recognition.of the fact that a state and a state govern-9 ment is partly, at least, political as well as whatever 10 else it is.
When we look forty years down the road, you 11 have to take that into consideration.
12 Part B, should the revised regulations for 13 decommissioning apply to all facilities.
The group felt n(
14 that this question was already adequately addressed in 15 its response to Question 6.
16 So, again, I repeat and thank the NRC for the 17 opportunity to do this.
I again commend the Green people 18 for an outstanding job and, with that, Shelly, bid you 19
" adieu."
20 MODERATOR SCHWART2:
I thank you so much, 21 Bill, for an excellent report.
You said there were no
' '2t '
other comments from the Green group?
23 (No response.)
24 That's excellent.
Thank you'so much.
25 The Buff Group..Gerry Parker.
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COMMITTEE C REPORT 2
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MR. PARKER:
Before addressing the 4
questions that we were asked to answer, our group felt 5
that there are several issues we would like to raise.
6 We'have some concern about them.
Our first concern was, who has the authority 7
8 and the responsibility for paying for decommissioning if 9
the owner of the facility goes bankrupt.
This issue 10 should be clarified by the NRC forthwith.
Another item is the cost of disposing of fuel 11 12 in premature shutdown.
13 Our second concern was, there exists no 14 mechanism presently, short of Congressional act, for 15 resolving health and safety conflicts between state and 16 federal authorities.
Particular concern was voiced for 17 instances where the state authorities believed there 18 were health and safety problams at a facility licensed 19 by the NRC, and the state lacked the authority to correct 20 these problems.
We would hope the NRC would investigate 21 what mechanism could be worked out.
n Third, conversion of nuclear facilities to 23 similar or other-use was not adequately covered as an 24 adjunct to decommissioning.. A study should be conducted 25 to consider conversion of all or a portion of the W
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1 facility and the effect that this conversion would 2
have on decommissioning.
3 she fourth concern was that we did not have 4
all the reports--first of all, all the reports are not 5
yet available.
Ne think the NRC should convene another meeting when all the reports on decommissioning presently 6
7 being worked on are available.
8 We have several other concerns which are not 9
connected with decommissioning and would like to place 10 those on the record.
11 The absence of progress on the solution of 12 the problem of permanent disposal of high level radio-13 active waste is astonishing, astounding, mind-boggling,
(
14 to some of the state people.
We urge that the federal goverbentgetonwiththisjob.
This is a very critical 15 16 issue and the solution of this issue may be the thing 17 that the decision whether we will have nuclear power 18 in the states or not.
We would hope that, Shelly, you will bring the work back to your colleagues that we would 19 20 like this done.immediately.
21 I must say, Shelly, that I wrote my first paper on this back in the early '60s and I think we are 22 23 at the same spot we were in the early '60s.
We have 24 made very little-progress.
25 Another concern was that guidelines, 9
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definitions and classifications should be developed by 2
A'C to clarify what is meant by low and high level 3
waste.
4 Now to the questions.
On Question number 1, 5
the technical and staff reports.
We believe that these 6
technical and staff reports should be subjected to an in-depth peer review by a selected group of professionals 7
8 including state officials.
9 We would hope, also, that t'he NRC would widen 10 the number of organizations that it goes to to prepare 11 these reports.
We think it is time for a fresh and new 12 view on some of these subjects, and not to be subject to 13 the same kind of approaches that we have been in the past.
14 Two.
The NRC should conduct sensitivity
~
15 studies concerning residual radioactivity.
We would 16 like to see more information on the cost of decom-17 missioning with respect to exposure at the 25, the 5, 18 and the 1 mrem.
19 Three.
This is still under Question 1.
The 20 state representatives would like-an NRC position on i
21 state jurisdiction.
We would hope that the staff of the 22 NRC would go back to last year's report, page F-1, and 23 take. a look what we asked them to do last year and hope,
if we get together next year, they wi$.1 do that kind of 24 25 review that we requested last year.
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Four.
Detailed data should be obtained 2
from the decommissioning of large scale reactors such 3
as shipping port in Indian Point.
Also, since there has 4
been some decommissioning, we would hope that the NRC 5
would prepare a report on what has already been dons 6
and distribute them to the members of this group.
7 Five.
A sensitivity study should be conducted 8
to determine the effects of lowering the limits on worker 9
exposure during decommissioning.
Some of the members of 10 our group felt that it wc3 unacceptable to plan to allow 11 these workers to get 2.7 mrem /Yr.
12 Six.
A system should be developed to track 13 the level of radiation exposure to temporary workers.
7,
\\
14 Here, I would like to digress from the report and give
~
15 you a personal remark.
I think the NRC should investi-16 gate and study deeply the idea of allowing spongers to 17 go into these places that have to be cleaned up, and for 18 these people to get 3 mrem and get them out of there.
19 I find that morally unacceptable.
20 Seven.
The question was raised as to what 21 state of decommissinghwill the states have the. opti'on.
22 of assuming the licensing responsibility.
We would hope M
that the NRC would investigate and study at what point 24 they would be willing to turn over this responsibility
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25 to the states.
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Eight.
More financial data needs to be 2
developed on the cost to the state for environmental 3
surveillance and emergency response for operating and 4
decommissioning facilities.
A mechanism should be de '
5 vised to compensate the states for these activities 6
which are very high.
7 Question number 2, is the major goal of 8
early rulemaking viable.
9 The general concensus is that early rule-10 making is beneficial and necessary.
However, early rule-11 making should be flexible, and authority should be left 12 to the licensee to select the type of decommissioning 13 with state and federal approval.
..m
[i 14 An additional comment was that we should get 15 these* rules very quickly but there should be a sunset 16 provision.
In other words, there should be continuous 17 review.
No gap should.be between the termination of the 18 interim rules and-the permanent rules.
The comment was 19 also made that rate setting can influence the type of N
decommissioning.
21 The next question had to do with modes, 5
timing, planning, and there was general agreement that 2
these five major issues were the correct ones.
No 24 other issues were proposed.
("s 25 The nextJquestion has to do with timing L
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classification.
It was agreed that the suggested 2
timing classifications were useful and adequate.
3 Concern was expressed for the step differences 4
in radiation doses, and the group favored immediate 5
action as opposed to short or long term safe storage.
6 NRC should study the potential problems associated with 7
short and long term storage.
8 Concern was expressed that additional delays 9
may be taken following a specified storage period.
Al-10 though it may be decided to store things for thirty years 11 af ter the thirty year period, they may decide to store 12
.1,t another thirty years and we would like to have some 13 time limit.
(
14 Assurance, liability, accountability and 15 respon'sibility is needed over time periods of thirty to 16 one hundred years when safe storage is used.
17 The timing classifications.
We believe that 18 the timing classifications are satisfactory however, 19 NRC should be conscious of technological and social 20 changes over a hundred-year period.
We suggest that 21 long term storage in the decommissioning process be 22 taken only when there is clear justification.
23 The next question, having to do with 24 planning requirement.
Detailed studies should be con-25 ducted of the decommissioning of the initial major 9
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facilities that terminate operation.
A distinction 2
should be made between government and privately owned 3
facilities.
4 As far as question number 7 on financial 5
assurance, we have a great deal to say about that.
6 NRC should conduct a study to look at the 7
financial implications of decommissioning facilities 8
that are taken out of service prior to the end of their 9
expected useful life.
10 Two.
The so-called unfunded reserve, i.e.,
11 nonsegregated funds, should not be ruled out as a method 12 of funding.
13 Three.
NRC should not mandate the type of
(
14 funding.
General concensus was that the licensee should 15 have the flexibility of selecting the type of funding 16 with state approvaV.
17 Four.
There should be.some type of surveil-18 lance on the financial status of the utilities required 19 to generate decommissioning capital.
20 The next one is, consideration should be given 21 for pooling and self-insurance by utilities for premature 22 2ecommissioning.
23 And finally, under question 7, we believe 24 that an independert, knowledgeable committee should be 25 convened to addres thec6 Jery difficult and technical L
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1 questions of financing.
2 Radioactive residues.
Satisfaction with the 3
maximum dose exposure to an individual could not be 4
determined.
NRC and/or EPA should conduct detailed 5
studies on the cost effectiveness and the biological 6
dose response of radiation levels.
7 As far as the EIS is concerned, we agree with 8
the other two groups.
We believe we should have had the 9
complete report rather than just review the summary re-10 pcrt.
11 The regulatory changes.
The regulatory 12 changes do not appear developed sufficiently to determine 13 whether they are accurrte or not.
14 Suggestions, comments and reservations are 15 reflec'ted in rasponse to the earlier questions.
The work 16 shop attendees would like the right to comment on pro-17 posed regulations when they are drafted.
We don't want 18 to have to wait until we see them in the Federal 19 Register.
20 The attendees also felt that a state meeting 21 similar to this one should be convened to consider these 22 regulations after they have been drafted.
~
2
As far as the states are concerned, the states 24 should propose changes to their own regulatory program.
25 A state meeting similar to this should be convened to
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the model legislation and regulations.
2 We believe a number of groupe should be 3
invited to this meeting.
NERU, the Conference of 4
Radiation Control Program Directors, the Legislative 5
Association, the Association of AttorneyJ General.
6 As far as certification, yes, we believe 7
the states should provide certification as part of the 8
NRC licensing process.
These regulations should apply 9
to all operating facilities.
10 We would like to thank the NRC and Shelly 11 for inviting us and giving us the opportunity.
- However, 12 we would hope that they would pay more attention to our 13 comments this year than they did last year.
CD 14 We w;uld like to thank Larry Pelham, our s
15 rappartour, who provided valuable assistance tc us and 16 to the two resource people from NRC, Peter Erickson and 17 Jane Mapes.
Thank you.
IS MODERATOR SCHWARTZ:
Thanks so much, Gerry, 19 for a very detailed report.
I don't know how I can 20 respond yet to all the suggestions and I don't know if 21 we are going to get around~to it today.
Let's hear 22 from the last group and then maybe we can discuss it a 23 little bl.t.
Are there any other comments from Gerry's 24 group?
25 (No response.)
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Okay.
The last group, the Lime group.
2 Unfortunately, David Levine had to head back home.
3 I don't know if Frederick chased him or what, but he 4
left last night.
We are very fortunate to have Delegate 5
Steve Sklar from the Maryland Legislature to present 6
this group's report.
7 MR. SKLAR:
I would subscribe to 8
the first part of Shelly's statement when he said that 9
it was un5ortunate that David Levine is not.with us, 10 and not necessarily to the second part when he said that 11 we are fortunate to have Delegate Steve Sklar in his 12 place.
13 This is really a work product, in a way, of ks 14 the Chairmen as well as the people on the workshop.
I 15 do not take credit for anything here, I am merely re-16 porting what the reporter says happened.
If you want to 17 send plaudits or appreciation, please do it to David is Levine.
19 I might tell you a story.
David was inter-20 viewed by a gaggle of reporters here when he first came 21 in.
One of the reporters said, " David, what do you think 22 of NRC's decommissioning plan?"
%I Dav#
ch3ngnt for a minute, paused, and 24 finally-ar.
1, really haven't made up my mind about it Ti yet, but wuen I do, I'm going to be damn bitter about it.
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Now, being last has certain advantages 2
and, of course, the obvious disadvantages of saying, 3
"Well, we said that, too."
What I will try to do is 4
just give you a little bit of some of the things that 5
our group emphasized.
6 I understand everyone has a copy here.
This 7
copy has been improved upon in a good, lively session 8
this morning so it is not the last word, at all.
9 The questions.
Now, we did combine a few.
10 We did take objections to a few of the questions.
11 The first question of the adequacy of the 12 staff reports and the additional issues, if any, that 13 need evaluation.
Like everyone else, we wanted more than m
I 14 just a summary of the Generic EIS.
We thought we could 15 not ma'ke decisions or give comments that were informed 16 unless we had the information before us.
17 What we did think, however, that was missing 18 in the staff reports, was really an analysis of options 19 laying out the interface between the states and their 20 constituent agencies within the states with the NRC and 21 other federal agencies that may be required to come into 22 play for d2 commissioning.
23 We also thought that concurrence, particularly 24 was a state option that should have been delineated some-2 where along the line in the various planning and. actual
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operation procedures.
2 One state in particular thought that the low 3
level waste disposal and other facilities should be 4
covered in other problem areas in other rulemaking 5
procedures, as well, not particularly here.
6 The question of the viability of early rule-7 making.
We sort of defined the question of whether it 8
is viable to be early, whether it is doable as a rule-9 making process in the mere term.
I think we added the 10 necessity of going about it--not whether it was possible 11 but it had to be possible.
It had to be done and it had 12 to be done expeditiously.
13 Many of us, particularly in the political (G
14 scene, are concerned about the opponents to the nuclear
~
15 option who happen to be very sincere or otherwise moti-16 vated, being able to cling to the very uncertainties 17 and indecisions that still remain in the nuclear cycle.
18 and say that the option itself is not viable unless 19 these areas can be resolved.
20 That is why many of us feel that rulemaking 21 is a necessity and earliest rulemaking a necessity, in 22 order to do away with some of the political problems 23 attenuate to nuclear and decommissioniag, as well.
24 In response to the five major issues and
(*
25 whether these are the correct ones, we said that a sixth
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one should be added.
2 Again, we reiterated the mechanism that ought 3
to be laid down for state involvement in this and, also, 4
a specific articulation of state authorities and re-5 sponsibilities between the states on the one hand, and 6
FERC, EPA and..NRC on the other.
We thought that kind of 7
interface, again, must be spelled out as a specific issue 8
and approached as such with the various alternatives to 9
select.
10 The question of timing classifications and 11 modes, we took together as one.
One of the problems, we 12 thought, that ought to be addressed,.is the stated NRC 13 objective which was stated as a primary goal of complete (9
14 dismantlement and return of the facility and site to un-15 restricted public use.
16 Many of us at the state level thought that 17 almost arrogant for NRC to say.
If we look at the site 18 from a decommissioned facility, we are looking at a land 19 use problem.
Land use is something that ought to be 20 specific and resolved at the local level, if possible.
21 This should not be a federal decision in Washington, 22 dismantlement and return to public unrestricted use..
23 This ought to be a state decis. a, and we thought this 24 aught to be something the states should be able to decide
{
S on their own.
The primary objective as stated by NRC N
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should not be one that in any way permeates the rule-2 making objective or conclusion.
3 Someone pointed out, I believe from Pennsyl-4 vania, that in the future, thirty years down the road, 5
sites where nuclear facilities now are would be very 6
precious and very scarce because of the difficulty in 7
getting new sites approved and through the political 8
process.
Instead of turning it over to unrestricted 9
public use, the state and the utilities together might 10 decide they want to convert that. site to another use in 11 the nuclear area.
12 So, again, the cuestion of modes and the 13 question of timing, we feel, should be more determined m
\\
14 by states and the generic requirements of each mode and
~
15 timing as suggestions and as requirements might be more 16 properly determined at the national level.
17 Someone also felt that it is possible that 18 it is also possible to partially decommission a site.
19 For instance, decommissioning the reactor and using the 20 on-site reactor pole as an AFR, or for a nuclear waste 21 facility of some type..
So, again, the partial decom-22 missioning of a site is an option that might be left 23 better to the states with the caveat that full funding 24 for full decommissioning ought to be included in the t'
25 planning and the requirements of decommissioning along
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the line.
2 As far as the planning requirement itself, 3
is it satisfactory, we, again, would stress the ability 4
of the state and the authority of the state to be able 1
5 to concur in the planning stages with NRC's decisions.
6 State involvement, again, is at the top of our list, and 7
a distinction that we thought should be explicitly made 8
for planning of new facilities and planning for existing 9
facilities.
^
10 One of our members thought that initial plans 11 for new facilities should be able to include designs 12 which would facilitate the actual mode of decommissioning 13 that is selected.
There wasn't too much disagreement to O
14 that.
15 Again, some thought that we have to begin even 16 sooner in the planning process to fund, in order to start 17 the-funds coming in as soon as possible.
18 On-the question of radioactive residues, on 19 the 5 mrem standard, we shared the response of most other 20 workshops that there is just not enough infornetion in 21 order to respond intelligently.
We did have the feeling 22 expressed that there is difficulty in determining and 23 enforcing even the recommended level of 5 mrem.
24 DOE and EPA representatives'both stated that 25 it was difficult to develop standards, in their opinion.
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There was also a total lack of agreement, which is not 2
new, between EPA and DOE and NRC on the proposed limit.
3 Seeing that kind of total lack of concensus, we were 4
unable to reach one ourselves, just being state experts 5
ou the matter.
6 It is interesting to see the EPA representa-7 tives coming into our non-smoking workshop with lit 8
cigarettes and telling us about safe health standards.
9 No' offense, but...
Life is full of inconsistencies.
10 On the Environmental Draft Statement, the 11 preliminary statement, we saw the cost benefit analysis 12 that apparently were in the full draft, completely 13 lacking in the summary.
We couldn't respond to those A
14 questions or implications.
15 We did suggest, and I think this is important 16 to us in the political area as well, that the Environ-17 mental Impact Statements which are more readily read by 18 members of the general public and concerned members of 19 groups and organizations, be couched in terms and ex-20 pressed in terms that are meaningful whe., we talk about 2L radiological impact, particularly.
22 It has got to be readable and understandabi.e 23 by laymen as well as by the technical people because, 24 if you say, "Oh, my gosh, do you know this facility is
{
25 going to generate.04 mrem. per year?" and they say, L J PRECISION REPORTING MAIN OFFICE. RALEIGH. 832-9C85 AND TRANSCRIBING, INC.
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"Oh, no.
That much?"
It's got to be put in some kind 2
of relative terms to background, particularly when this m
3 statement more than any other will be the one that is 4
read by more members of the general public who will ccme 5
forward to express their concerns and comments at public 6
hearings.
'Again, a plea for readable, understandable, 7
equivalents in health effects.
8 A
itleman from Connecticut was not satis-9 fied with the extrapolation of PWR data for the Boeing 10 Water Reactor impacts in that statement, as well.
11 I might just go down to a couple of other 12 areas.
The one on our own state regu'_atory program 13 changes, if any.
I think we were all more or less con-q 14 vinced nat the state ought to begin developing its own 15 involvement in decommissioning procedures, and ia funding 16 mechanisms.
17 The problem for that is that we have to have 18 starting points somewhere.
We have to know our relation-19 ship vis a vis the NRC's own process for interface with 20 the states.
In order for the states to make any changes 21 in decommissioning, we have to know what options, what 22 delegations, concurrent authority and responsibilities 23 we were going to be given by NRC's own regulations.
24 Again, that reinforces our plea for early determination
{
25 of,NRC rulemaking.
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On financial assurance, I think we reiterate 2
most of the concerns of the other groups.
First, that
,s 3
money will be available at the time of decommissioning, 4
mechanisms and pla'ns that will guarantee that.
5 We have to also make a distinction between 6
new facilities ani existing facilities.
How in the 7
world can we get plans.for funding existing facilities 8
that may be. ten yea rs already into their useful life, 9
and be ab_le to have equity as well as guarantee of to adequate funds within the next 25 years.
11 There was an interesting comment that NRC 12 should be the lead agency in bringing together IRS and 13 the other groups like FERC, and even maybe the Associa-b 14 tion of Public Utility Commissioners into getting the 15 tax ramifications and the tax treatment into some kind 16 of sympathetic light by IRS.
17 If possible, someone suggests, that NRC ought 18 to lean on Congress.
That would be cv
. the more 19 difficult recommendations from our group for NRC to 20 accomplish, but if they can do it, all the better.
21 Again, we reiterated our intention and pre-22 ference to be able to review the proceedings of work-23 shops again, and be able to make an intelligent reaction 24 and.,ccmment on what has developed both here and in Seattle,'and in uther meetings and proceedings around 25 7
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the country.
I would like to leave the group with just a
..)
This reminds me, first, couple observations, personally.
3 of a situation in Maryland where we were debating a very i
4 contentious bill dealing with the power utilities.
1 5
I One of our colleagues got up on the floor, 6
and he was very animated and very emotional and he said, 7
"Me fighting the Gas and Electric Company is like the 8
,1 classic case of Samson versus Goliath."
9 i
I leaned over to him and said, " Ray, you 10 l
11 mean David."
He goes, "What?"
I said, " David."
1 i
12 He says, "Oh, that's right.
The classic case 13 of David versus Samson."
.i I.see us approaching these h
14 Well, in a way, I think 15 behemoths, if you will.
The only difference is, we are talking about really the monster, if you will,
~
16
.. ;.,j being the complexity of the problems that we have,to 17 address in the decommissioning phase and also the
-wS 18
=
diversity of interests that have to be satisfied and 2
$3 19 NE the ones who offer their own recommendations for reso-20 g6 M
21 lution.
It's a tough job.
'It's not that easy to just say, "Well, the WJr 22
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23 NRC, it's their problem.
Get your act together."
All the time, ~han you come to a regional conference like
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it becomes very easy, open season on your host.
It's 2
the Feds, you know, the insensitivity of the Feds.
3 I didn't see that here.
I think it was a 4
very significant departure from the usual type of con-5 ference where there wasn't the scapegoating, there wasn't 6
the finger-pointing.
I think, for the first time, we 7
are beginning to.see, in the energy context, state people 8
being able to recognize the sincerity of the federal 9
agency to really resolve a very difficult problem.
10 I congratulate Shelly and the other member s 11 of his staff, and you people who have come here in 12 support services to bring that kind of flavor and means g
of cooperation to ts.
, s, 14 Again, to our technica1 <*iends in the
~
15 audience who are not politicians, don't be frustrated.
16 These will not be technical decisions decided with 17 technical information and technica. data.
Technical 18 people strive for certainty.
Politicians thrive on 19 ambiguity, and I think you will have to understand and 2
appreciate and recognize and ultimately swallow hard 21 that the technically right decisions will be moderated S
quite a bit by political considera ions and politicians like myself[ Thank you.
%3 24 MODERATOR SCHWARTZ:
Thank you so much, 5
Steve, 'for your comments and the group report.
Are
\\-
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there any other comments from the Lime group that 2
were not taken into consideration?
3 Yes, sir.
4 MR. BAKER:
I am Ken Baker from 5
the Department of Energy.
I was wondering whether you 6
would permit me tc clarify a statement that was at-7 tributed to me by representing the Department of Energy?
8 MODERATOR SCHWARTZ:
Absolutely.
9 MR. BAKER:
I refer to, I believe, 10 question number 8 regarding the residual 5 mrem /Yr. To 11 my knowledge, I did not indicate that it was difficult 12 to develop standards at this time.
I think it is a very 13 needed effort at this time.
A 14 I do feel that maybe it would be very diffi-15 cult at this time to demonstrate compliance with the 16 5 mrem /Yr. limit for all facilities, and that led me 17 into making the statement that 5 mrem /Yr. may be ap-18 propriate for one type of facility but may be non-19 achievable for another type.
20 So I suggested that we may have to look at a 21 limit for.each type of facility.
'22 f
MODERATOR SCHWARTZ':
I see everybody shaking
-,,,,their heads.
They are saying that' now they understand, 23
,a 24
,I think.
{
25 I am very happy to see the positive nature m
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of the comments.
It's easy to be negative without 2
giving a positive solution, and I really appreciate the 3
way the groups have dealt with each of the issues.
4 Let me hit a couple of highlights of notes I 5
took down and Don, maybe you want to say a couple of 6
word 5, also.
7 Yes, I realize that a number of reports were 8
not available for you to review here at the workshops, 9
and it is unfortunate.
10 I was asked if we would have another work-11 shop on a couple of~ issues.
On residual contamination, 12 I gave a bureaucratic answer.
I said, "It could be."
13 The reason why it could be is that it depends on when
'O 14 we get our act together and get the GEIS on the street, 15 and wh'en we have to get our rule on the street.
I am 16 now saying no, but I am not saying yes at this time.
17 We do commit to sending it out to all of you 18 and, after reviewing it, if you think it's necessary, 19 get back to us and we'll talk about it.
20 On the. discussion of another meeting on 21 potential legislation, I commit to work with the national 22 organizations that Gerry Parker mentioned and, if we can 23 Eget a. concensus to have a group meeting with particular 24 individuals to draft.some proposed legi'slation and also p
25 implementing regulations, we will do so.
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it out to everybody, and if there is a need to have 2
further discussion on it, we will do so.
,m 3
That generally covers some of the major 4
things for procedura.'. sense and regulatory sense.
I-5 didn't touch any of the technical comments.
Maybe Don 6
wants to reflect on those.
7 MR. CALKINS:
Just a couple of brief 8
comments, Shelly.
Firs ~t',
I want to repeat the ap-9 preciation that I have for the hard work that's been 10 done by the participants here at the workshop.
We found 11 those extremely valuable last year, and attempted to 12 react to most of those.
Maybe we failed to react to 13 all of them.
As I told you in my opening remarks, we O
t 14 intend to react to your deliberations here this year, 15 again."
16 It is unfortunate that the Draft Environmental 17 Impact Statement wasn't available for you to look at in 18 advance.
It never was scheduled to be completed at this 19 time.
It is on schedule, and the best we could do 7as 20 to put together a summary of that and to discuss it in 21 some det$ ail with you.
The status of that Impact State-22 ment is that. the workirig paper, preliminary draf t, is U
,in.. process.of ' review at the moment by NRC.
The schedule 24 is that the draft itself, hopefully in' polished form,
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public about December of this year.
That's the 2
schedule.
I hope that those of you that thought what 3
you saw on that copy inadequate as of this moment, will take advantage of the opportunity to look at that volume 4
5 in detail and to send your comments to us, even if a 6
meeting on the subject is not held.
I hope that there 7
would be time to react to that.
December is pretty 8
close at hand, though.
9 I feel personally that it is important that to we maintain the schedule on this program of re-evaluation 11 of decommissioning policy, and I intend to push toward that goal of having something ready to go to our Com-12 13 missioners about December of this year, in parellel
_)
l 14 with the draft EIS.
15 I want to thank you all again.
l t
16 MODERATOR SCHWARTZ:
Thanks, Don.
17 There was one other point that I want to 18 make.
One of the groups said that before we go final 4
19 with the document on the proceedings of these-meetings, 20-this one and the one in Seattle two weeks from now, 21 that it be reviewed by the ind_vidual state participants.
a
.i 22 I would like to propose an alternate, and that l
23 is that we send a draft to the individual chairmen of 24 the working groups.
If that is satisfactory, I would i
25 like to de it that way in the interest of getting the
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47 43' document out and on the street as soon as we can.
1, I am sure everybody is 2
If we send it to everybody else, and maybe going to deal with the language a little bit 3
get a few more points in.
If you're like I am, every 4
5 time you get a document for comment, you feel like you So are not doing your job if you don't comment on it.
6 we'll get comments back and it may hold the process up.
7 If that's acceptable, we'll play it that way.
8 9
I said that I would entertain any comments from the floor from any observers at the closing session.
10 Do I have anybody that would like to be on the record 11 12 with a statement?
Rufus?
13 MR. MORGAN:
Qr name is Rufus Morgan from, Southern Company Service from Atlanta, Georgia.
L._
14 i
15 That, which you may know, is part of the Southern i
+
Holding Company which has four power companies in four 16 states, Alabama, Georgia, Florida and Mississippi.
17 j
18 Frederic.- has just torn us apart yesterday.
19
'In the first place, I want to thank you for A number of the men had 20 allowing us observers to come.
to leave because they are on their way to Sun Valley.
et 7
22
, r don' t-blame them.
They are meeting on decommissioning h
s.
in Sun Valley, Idaho September.6'h through the 20th, so c
s 23 E
That's the several of them are on the way out there.
n a4 J.-
Q5 reason why they left. early.
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MODERATOR SCHWARTZ:
Rufus, could you 2
explain a little more about that meeting, whose meeting
_s 3
it is and who is participating?
4 MR. MORGAN:
The American Nuclear 5
Society, I believe, is the sponsor.
One big item is I
6 going to be on this funding which has been discussed 7
here and which, I hope, we will have an opportunity for 8
specialists as the Buff Group said, a knowledgeable 9
group to go over.
10 Several of us who have worked on it for some 11 time including our consultants, Gilbert and Associates--
12 Preston Kahns who is here has worked on it--have de-13 veloped computer prograrse.
If we could get some para-n s
14 meters from you, we would be glad to work up revenue re-15 quirements and other things.
16 Fundingfis just one of the topics that is 17 going to be discussed out there.
There are going to be 18 engineers and many other people.
Radiation experts.
19 I think, whe_n you say that NRC should lean 20 on IRS about this funding, what really--and I have said 21 so in one-or two of the groups here--what really, the
?.
taxp 7ers,. the utilities probably, should lean on the
.23 House Ways and Means Committee and Senate Finance Com-24 mittee because they are the ones that sort of recommend
(
3 things to Congress.
Then Congress should change the m
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1 tax code.
Then the IRS can make rulings and regulation 2
on this.
I think t.nat is the procedure we will have to m
3 go to if we are going to get any meaningful tax rulings 4
on funding.
5 Our studies show that, even though some people 6
here don't prefer it, the unfunded reserve, does lower 7
the revenue requirements over the total life of one of 8
these facilities.
Now, some of you may have come to 9
some other conclusions.
10 The third-party fund, for instance, might be 11 more reasonable.
Now, some of us are using the unfunded 12 reserve, incidentally, but would like to go to a fund 13 particularly because of joint ownership.
m 14 In the case of Georgia Power Company, the 15 municipals and co-ops own 49.7 percent of Plant Hatch 16 Number One.
We made them responsible, frankly.
We 17 would like to all go into funding and a number of you 18 have expressed the same desire.
When you have several 19 participants, whether they are investor-owned utilities 20 or governmental bodies, co-ops, what have you.
21 Those are just a few thoughts I thought I 22 would throw out.
Thank you very much.
23 MODERATOR SCHWARTZ:
Thank you so much for 24 your comments, Rufus.
25 Are there any other comments from the 9
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observers?
2 (No response. )
3 Any comments from anybody else?
Anybody 4
want to be on the record?
5 (No response. )
6 I will keep the record of this meeting open 7
for two weeks.
If anybody on the plane has some ad-8 ditional thoughts, any papers or reports that they would 9
like to' include in the record, please send them to me 10 at the NRC.
11 With that, I give a hearty thanks to all of 12 the Chairmen.
I thank you for your work and I discharge 13 you from your duties.
And I thank all of you for coming.
rs i
14 Thank you so much.
15 (Procacdings closed at 2:30 p.m.)
16 17 18 19 20 21 23 04 r
25 9
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