ML20028E153
| ML20028E153 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/17/1983 |
| From: | Coleman J BEVERIDGE, FAIRBANKS & DIAMOND, LOUISA COUNTY, VA |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20028E144 | List: |
| References | |
| ISSUANCES-OLA-1, NUDOCS 8301210032 | |
| Download: ML20028E153 (59) | |
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1/17/83 UNITED STATES OF AMERICA U@IiGJD NUCLEAR REGULATORY COMMISSION In the Matter of )
)
VIRGINIA ELECTRIC AND ) Docket Nos. 50-338/339-OLA-1 POWER COMPANY )
)
(North Anna Power Station, )
Units 1 and 2) )
(Proposed Amendment to Operating License to Allow Receipt and Storage of 500 Spent Fuel Assemblies from Surry Power Station, Units 1 and 2)
C CONTENTIONS OF INTERVENORS COUNTY OF LOUISA, VIRGINIA AND THE BOARD OF SUPERVISORS OF THE COUNTY OF LOUISA Intervenors County of Louisa, Virginia and the Board of Supervisors of the County of Louisa ("Louisa County" or "the County") make the following specific contentions with regard to a license amendment pr) posed by Virginia Electric and Power Company
("Vepco" or "the applicant") to permit the receipt and storage of 500 spent fuel assemblies from Surry Nuclear Power Station Units No. 1 and 2 for storage in the spent fuel pool at North Anna Nuclear Power Station Units No. 1 and 2. Because the application l
l to receive and store Surry fuel at North Anna necessarily involves the transshipment of spent fuel from Surry to North l Anna, the County's contentions regarding the transshipment ele-l ment of Vepco's plans will also be set forth herein.
l l 8301210032 830117 1
PDR G
ADOCK 05000338 pop
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I. Need for Proposed Action The applicant has not established a need for the proposed action.
The Council on Environmental Quality regulations require all federal agencies, in considering a proposed action, to determine whether there is a "need for the proposal." ! These regulations are binding on all agencies, including the Nuclear Regulatory Commission
("NRC" or "the Commission") . In response to this require-o ment, Vepco asserts that it needs to store Surry fuel at North Anna because otherwise the Surry station will lose full core discharge capability in 1984. Vepco also states that Surry will lose the ability to refuel in 1987, but ties its request for immediate action to its asserted loss-of-full-core-reserve date of 1984. The Nuclear Regulatory Commission does not require utilities to maintain a full core reserve, Duke Power Company, 12 NRC 459, 515 (1980);
nor does Vepco allege that full core reserve has any safety implications. Thus, loss of full core reserve does not establish a need for the proposed action. Moreover, other 1/ 40 C.F.R. $ 1508.9(b) (1982).
2/ Andrus v. Sierra Club, 442 U.S. 347, 358 (1979); 40 C.F.R.
T 1500.3 (1982).
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3 Vepec documents,-~/ :
as well as the Department of Energy-commissioned .Tohnson Report,' place Surry's loss of full _
core reserve in 1985, thu1 casting doubt on the asserted 1984 deadline.
Perhaps more important, Vepco's application does not state the assumptions used to calculate either the 1984 or the 1987 dates. Yet it is clear that variations in factors such as the demand for electrical power, the operating capacity at Surry, and the burnup period of the fuel used at Surry, could have a significant impact on the rate at which spent fuel is discharged from Surry and thus on the need for additional spent fuel storage.
Indeed, there is evidence "that supports the conclusion that Surry need not be operated at maximum capacity. Vepco is currently in the process of selling to the Old Dominion Electrical Cooperative ("ODEC") 25 percent of North Anna 2 and 12.5 percent of the North Anna Power Station's common facilities,-/5 a move that suggests that Vepco may have overbuilt its baseload capacity and may not need to continue to operate Surry at the game capacity level as has been the 3 Interim Storage of Spent Nuclear Fuel: Vepco's Solution, at (Virginia Electric and Power Company, Feb. 1982) [ hereinafter Interim Storage].
4/ A Preliminary Assessment of Alternative Dry Storage Methods For The Storage of Commercial Spent Nuclear Fuel, at 3-4, JAI-180 (DOE /ET/47929-1(UC-85)) Nov. 1981 [ hereinafter Johnson Report].
5/ 1981 Annual Report of Virginia Electric and Power Company at 2-3, 12-14.
case in the past. Operating at a reduced power level, of course, would reduce the rate at which fuel would be required to be discharged and thus extend, in terms of years, Surry's storage capacity.
Given the Commission's statutory obligations under NEPA and the AEC to minimize adverse environmental effects and to safeguard the public against radiation hazards to health and safety, the NRC should not embark on a proceeding that could result in substantially increased handling of spent c
fuel, and thus increased environmental and health and safety risks, unless the need for such a proceeding has been clearly shown. Vepco has not shown such a need here.
II. Consolidation l The proposed action is integrally related to the appli-cant's other proposed actions now before the Commission.
Therefore, the three elements of the applicant's plan --
namely, receipt and storage of Surry spent fuel at North i
6/ Public Service Company v. U.S. NRC, 582 F.2d 77, 81, 85-86 T1st Cir.), cert. denied, 439 U.S. 1046 (1978); Calvert Cliffs Coordinating Committee, Inc., v. U.S. AEC, 449 F.2d 1109, 1128 D.C. Cir. 1971),
1/ VePeo concede 8 the interdependence of the plans to receive and store Surry fuel at North Anna and to expand the Northa Anna l pool. " Storage of Surry spent fuel assemblies at North Anna
- would, of course, hasten the day when the North Anna pool would
! be filled. Thus, Vepco has also applied to NRC for a license amendment authorizing the installation of neutron-absorbing racks ,
at North Anna Units 1 and 2." (Applicant's Answer to Motion of Intervenor Louisa County to Stay Proceedings. Affidavit of Marvin L. Smith at 1 5 [ hereinafter Smith Affidavit]).
Anna, expansion of the North Anna spent fuel pool and trans-
- shipment. of Surry fuel to North Anna -- should be considered
, in consolidated proceedings to ensure that the cumulative environmental, health and safety, and common defense and security impacts are properly addressed.
As support for this contention, Louisa County notes that a license to store Surry fuel at North Anna is insig-nificant without an accompanying Commission approval to transship the spent fuel. Similarly, storage of Surry fuel at North Anna, absent expansion of the North Anna pool, -
would merely shift the locus of the storage capacity insuf-ficiency from Surry to North Anna. The current capacity of the North Anna pool is 966 fuel assemblies; with 237 assemblies already stored there as of August 1982, the addition of 500 Surry fuel assemblies would leave little space for fuel discharged from North Anna's reactors, thus causing North Anna to lose full core reserve before the currently projected date of 1989 and possibly foreshortening North Anna's operating life.
Moreover, the courts have consistently held that, even apart from any agency responsibility to prepare an environ-mental impact statement, "NEPA mandates comprehensive consideration of the effects of all federal actions. 42 U.S.C. I 4332(a). To permit noncomprehensive consideration of a project divisible into smaller parts . . . would
- provide a clear loophole in NEPA." City of Rochester v.
- . . . , - ,,. , . - . - ~ , , , - - . . , -
. s .
United States-Postal Service, 541 F.2d 967 (2d Cir. 1976).
Thus, in compliance with NEPA, the proceedings must be ,
consolidated.
III. Scope of Environmental Inquiry Required A. 'The proposed action, viewed either alone or in conjunction with the other integral elements of Vepco's plan (i.e., transshipment and expansion of the North Anna pool), is "a major Federal action significantly
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affecting the quality of the human environment," and therefore the Commission must prepare an environmental impact statement in accordance with the provisions of 42 U.S.C. { 4332(C).
As the Council on Environmental Quality (CEQ) regulations make clear, "[s]ignificance cannot be avoided by terming an action temporary or breaking it down into small component parts." 40 C.F.R. $ 1508.27 (1982). Rather the question of significance turns on, inter alia, "whether the action is related to other
( actions with individually insignificant but cumula-
, tively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant
-F impact on the environment.
- Id. Thase regulations are binding on the NRC.
B. Since Vepco's application does not discuss the transshipment component of the overall plan, it is insufficient to form the basis for Commission compliance with NEPA because it fails to consider the environmental impacts of the proposed shipments.
C. Vepco's environmental analysis is insufficient to form the basis for NRC compliance with NEPA (42 U.S.C.
$ 4332(A)) because it fails to consider how the security measures necessary to ensure that transship-ment is carried out safely will affect the lives of citizens living along the transshipment routes -- i.e.,
8/ See also the CEO regulations on " connected actions," which state that "[a]ctions are connected if they:"
(i) Automatically trigger oth( actions which may require environmental impact statements.
(ii) Cannot or will not proceed unless other actons are taken previously or simul-taneously.
(iii) Are interdependent parts of a larger action and depend on the larger action r'or their jurisdiction.
i 40 C.F.R. $ 1508.25(a)(1).
j9 See Andrus v. Sierra Club, 442 U.S. 347, 358 (1979) ("CEQ's interpretation of NEPA is entitled to substantial deference").
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whether the need for security, and indeed the trans-
- shipment itself, may cause restrictions in human activities. Additionally, there is no discussion of the environmental consequences that will flow to such citizens should an emergency arise during the course of transshipment.
D. Vepco's environmental analysis is insufficient to form the basis for Commission compliance with NEPA (42 U.S.C. 4332(A)) or 10 C.F.R. $ 51.7(b) (1982), which requires consideration of the " probable impacts of the proposed action on the environment" because Ve~pco has failed to consider the environmental consequences for Louisa County if (1) no other storage facility is available when North Anna loses full core reserve or when the North Anna pool is filled to capacity or (2) no permanent solution is on-line for handling the spent fuel' stored at North Anna at the end of North Anna's operating life.
The dates at which North Anna will lose full core reserve and refueling ability depend on whether the i
10/ See also 40 C.F.R. $ 1508.9(b) (1982) which states that an
" environmental assessment . . . shall include brief discussions of the need for the proposal, of alternatives as required by Sec. 102(2)(E) [42 U.S.C. $ 4332(2)(E)], of the environmental impacts of the proposed action and alternatives, and a listing of agencies and persons consulted." (Emphasis added). The CEO regulations are now binding on all Federal agencies. Andrus v.
Sierra Club, 442 U.S. 347, 358 (1979); 40 C.F.R. $ 1500.3 (1982).
proposed action is viewed in isolation or in conjunc-tion with expansion of the North Anna pool. The ,
applicant's submittals assert, without supplying any data, that if the pool is expanded and Surry fuel is stored at North Anna, North Anna will lose full core 11/ 12 reserve in 199u and refueling ability in 1993.- /
Presumably, if the fuel is shipped but the pool is not expanded these dates would be advanced significantly, but Vepco makes no assertions based on this scenario, n
Even under the most optimistic projections, the permanent federal repository provided for in the recently-enacted Nuclear Waste Policy Act of 1982 will 13 not be operating until well after 1993.- / And now that North Anna 3, along with its storage capacity, has been cancelled, Vepco has no intrasystem back-up to take up the slack in 1993. Thus, NEPA requires the Commission to consider the environmental consequences if additional storage facilities are not available when 11/ Smith Affidavit at 1 5.
i 12/ Summary of Information In Support of the Storage of Surry Spent Fuel At North Anna Power Station Unit Nos. 1 and 2 at 2 (July 1982) [ hereinafter Storage of Surry Fuel Summary].
13/ Vepco estimates that a permanent federal repository will not be in place prior to the mid- to late-1990's. Storage of Surry Fuel Summary at 21.
North Anna loses full core reserve and, later, refuel-
- ing ability. 42 U.S.C. $ 4332(A).
Similarly, given the uncertainties that have characterized past Federal action on the spent fuel permanent storage question and the current Commission uncertainty whether permanent storage facilities will be in existence at the end of North Anna's operating life, NEPA also requires the Commission to consider the environmental impact that will obtain if no permanent facility is operational when North Anna reaches the end of its life. Potomac Alliance v. U.S. Nuclear Regula-tory Commission, 682 F.2d 1030 (D.C. Cir. 1982).
E. Vepco's analysis is insufficient to form the basis for a Commission finding that the proposed action is not a
" major federal action significantly affecting the human environment," 42 U.S.C. { 4332(C), because Vepco imper- ,
missibly segments the total plan, treating receipt and storage of Surry fuel at North Anna as separate and discrete from the transshipment and North Anna pool expansion elements of the overall plan. "In ascertain-ing the significance of a major federal action, the project must be assessed with a view to the overall, 14/ Possible consequences include premature shutdown of the North Anna station and a consequent loss of jobs for County residents and tax revenues to the County.
cumulative impact of the action proposed, related :
tederal action and projects in the area and further actions contemplated." Sierra Club v. Bergland, 451 F.
Supp. 120 (D.Miss. 1978).
IV. Alternatives Vepco's analysis of the available alternatives is insuf-ficient to serve as the basis for NRC compliance with its NEPA obligation "to study, develop, and describe appropriate alter-natives to recommended courses of action in any proposal which -
involves unresolved conflicts concerning alternative uses of available resources. 42 U.S.C. { 4332(2)(E).
The obligation to consider alternatives arises regardless of whether a proposed action is significant enough to warrant a full-scale environmental impact statement. Rather, it is an independent NEPA requirement that comes into play whenever "the objective of a major federal [ action] can be achieved in one of two or more ways that will have differing impacts on the environment." Trinity Episcopal School Corp. v. Romney, 523 F.2d 88, 93 (2d Cir. 1975). Moreover, even if Vepco's analysis of alternatives were exhaustive, the obligation imposed by % 2(E) is the agency's, not the applicant's; it is therefore improper for an agency to rely solely on the evidence submitted by an i
j 15/ Accord, Township of Lower Alloways Creek v. Public Service Electric & Gas Co., No. 81-2335, slip op. at 13 n. 14 (3d Cir.
Aug. 27, 1982); Aertsen v. Landrieu, 637 F.2d 12, 20 (1st Cir.
1980).
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. i applicant as to the feasibility of other alternatives. City of :
i New Haven v. Chandler, 446 F. Supp. 925, 934 (D. Conn. 1978).
As support for its alternatives contention, Louisa County i
notes the following:
A. Vepco rejects the option of increasing Surry's storage l capacity because it asserts, without support, that "no additional weight can be allowed in the Surry spent 16 fuel pool . '*- / Vepco, however, fails to address the possibility of installing aluminum racks at Surry, and thereby increasing the total storage capacity at Surry ,
l by about 10 percent without exceeding the pool's l claimed load capacity. Nor does Vepco consider the 1 temporary installation of spent fuel racks in Surry's cask laydown area, to be used only in the event a full 18 core discharge is required.--/ I B. Vepco rejects the option of constructing a new pool at Surry, even though such a pool would meet Surry's storage needs until a federal repository is available, ,
because, it asserts, a new pool would cost $100-125 million and take eight years to design, license and 16/ Storage of Surry Fuel Summary at 16. l lj See Attachment A.
18/ See Attachment B.
construct. No data, however, are supplied to :
support these assertions. The Johnson Report estimates that a new pool could be operating at Surry within seven years, and other internal Vepco documents estimate that a new pool could be available at Surry within six years of project start-up at a cost of $70-98 million in 1982 dollars.
C. Vepco rejects the dry cask option because, it asserts,
" design, licensing, and construction of this type of -
facility would take approximately 3-5 years . . . and because it is less certain to avoid the loss of full core discharge capability at Surry in the fall of 22 / 23 /
1984.' As mentioned earlier, Louisa County questions whether loss of full core reserve, even if Vepco's unsupported assertions about the 1984 date turn out to be accurate, should set the target date for Commission action. Moreover, the Johnson Report 19/ Id. at 19.
2g Johnson Report at 7-3.
21/ Current Cost Estimates, Independent Fuel Storage Installa-tTon, Surry Power Station - Units 1 and 2 (Vepco Memorandum, Oct. 6, 1982), Attachment 2 [hereinaf ter Current Cost Esti-mates]. This document is appended to Louisa County's Contentions as Attachment C.
22/ Storage of Surry Fuel Summary at 18.
23/ See page 2, supra.
I estimates that design, licensing, construction and pre- :
operational procedures associated with dry-cask would be completed within 42 months. Since Vepco has already filed for the necessary Commission approvals for dry-cask (October 8, 1982), this means dry-cask storage could be available at Surry beginning in 1986, well before the Surry pool will be full.
Vepco's " analysis" also fails to note that dry-cask is an onsite solution and thus eliminates the fuel handling and attendant environmental and health and -
safety risks associated with transshipment. Nor does it consider the cost advantages of dry cask. The Johnson Report, however, concluded that "[s3torage of spent fuel by modular methods (such as casks . . .)
where storage capacity need be added only as required, results in the lowest unit costs for storage inasmuch as a minimum initial investment is required; in addi-tion, the risk of installing more capacity than ultimately needed is eliminated.'
24/ Vepco filed its initial NRC application for dry-cask on October 8, 1982. (NRC Docket No. 72-2).
25/ Vepco's internal documents also project a 1986 startup date for a dry-cask facility at Surry. Current Cost Estimates, Attachment 1. See Attachment C.
26/ Johnson Report at 3 of Executive Summary.
D. Vepco rejects the alternative of reprocessing because, 8 it asserts -- again, without foundation -- that "under current administration policies" shipment to a foreign reprocessing center "would almost definitely be con-sidered inimical [to the common defense and security]
of the United States.- Yet, at least one admini-stration spokesperson, John Marcum of the White House Office of Science and Technology Policy, has indicated that there are "no impediments to U.S. utilities contracting to have spent fuel reprocessed in foreign plants .
E. Vepco presents no data to support its assertion that an
" extended burnup" program would have only " negligible impact" on Surry's near-term fuel storage require-ments. Even if it is true, as Vepco asserts, that Surry will lose full core discharge capability in 1984, only a small increment of additional capacity, if any, is required to meet Surry's storage needs until dry-cask could be available. During the first year that Surry discharges more assemblies than it can store while maintaining full core reserve, the excess number 27/ Storage of Surry Fuel Summary at 19.
28/ " Bring Back Buy-Back," Nuclear News at 61-62 (October 1982).
29/ Storage of Surry Fuel Summary at 21.
of assemblies will be only 61-65. It is possible c that extended burnup, used alone or in conjunction with one of the other rejected alternatives (e.g.,
contingent transshipment, operating Surry at a reduced power level), could provide the needed increment.
F. Vepco's assertion that it cannot operate Surry at a reduced power level (and thereby extend the life of the fuel) because to do so would involve "significant economic penalties" is again totally unsupported. As o mentioned earlier, Louisa County has significant doubts about the need for Surry to operate at maximum capacity.
G. Vepco's assertion that it cannot close Surry when the pool is full because replacement power would cost approximately $350 million a year is also unsupported by any data.
l H. Vepco has failed to consider installing flotation spent fuel cannisters at Surry and thereby extending Surry's storage capacity by twelve to eighteen years without
[
30/ Johnson Report at 3-4; Spent Fuel Disposition Alternatives Study for Vepco (Ebasco, Mar. 1980) at A4-3 Lhereinafter Ebasco Report].
31/ See page 3, supra.
I having to increase the structural strength of the e pool. This Dyna-Canister system, designed by the U.S.
Tool and Die Company of Secaucus, New Jersey, was 32/
reported in a recent issue of Nuclear News.---
I. " Buy-Time" Alternatives: Although Vepco appears to be committed to a dry-cask installation at Surry, and, as discussed above, current projections indicate that such a facility could be available in 1986, Vepco has c
not considered any combination of alternatives to " buy time" for Surry until dry-cask would be on line, such as the following:
- 1. Give up full core reserve for a limited time, as have other utilities;
- 2. If Vepco's primary goal is to preserve full core reserve at Surry, install, temporarily, fuel racks in the cask handling area to be used only in the event full core discharge is required. Once the Surry dry-cask facility were operational, the racks could be removed. This option is addressed in a May 1982 Vepco memorandum, which reports that 4
32/ " Fuel Pin Consolidation," Nuclear News at 112 (October 1982).
33/ See pages 13-14, supra.
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such a temporary installation would provide space :
for 108 fuel assemblies and extend the time to loss of full core discharge by at least two years; additionally, the memo reports that once before, when high density racks were being installed at Surry, a rack was placed temporarily in the cask handling area;
- 3. Install aluminum racks at Surry, and thus provide space for approximately 100 more fuel assemblies without exceeding Surry's claimed weight limits, thus also extending the time until loss of full core discharge capability by at least two years.
Assuming for the moment that Vepco's 1984 date for loss of full core reserve is correct, aluminum racks would extend pool capacity to 1986, and by then dry-cask would be operational; and
- 4. Operate Surry at a reduced capacity for a limited period of time.
34/ Alternatives for Loss of Full Core Discharge, Surry Power Station Unit Nos. 1 and 2 (Vepco Memorandum, May 5, 1982).
(Attachment B).
J. Long-Term Alternatives: Vepco has failed adequately to 8 consider alternatives that would permanently resolve its long-term interim storage problems.
" National environmental policy requires a detailed analysis of the long-range environmental costs of proposed action and a thorough study of the available alternatives before any action is taken. Planning and building . . . in a piecemeal fashion threatens to frustrate this policy by allowing a gradual, day-to-day growth without providing an adequate opportunity to assess the overall, long-term environmental effects of that growth." Patterson v. Exon, 415 F. Supp. 1276, 1282 (D. Neb. 1976). Thus, proposed actions must be viewed comprehensively and, further, consideration of environmental factors must begin "at the earliest possible point." Sierra club v. Bergland, 451 F. Supp.
120 (N.D.Miss. 1978).
Even under the proposed scheme, Vepco will run out j of storage space for both Surry and North Anna in 1993, and it is highly unlikely that any permanent federal repository developed under the recently enacted Nuclear Waste Policy Act of 1982 will be on line at that time. In fact, it appears that using the most opti-mistic assumptions, the repository could not be ready l
until the mid to late 1990's. Thus, it is clear e even now that Vepco's plan to store Surry fuel at North Anna is only a stopgap measure postponing the inevi-table, and that, even if Vepco's current scheme is approved, Vepco must still develop additional interim storage capacity to bridge the gap between exhaustion of the North Anna pool's capacity and the availability of a federal repository to receive spent fuel. Yet, Vepco attempts to focus only on near-term problems, ignoring or. rejecting out of hand alternatives that o would provide a comprehensive solution to its interim atorage needs.
K. Comprehensive Alternatives: Vepco, by treating the -
discussed alternatives as mutually exclusive does not consider the advantages of a comprehensive, multi-faceted approach. For example, Vepco cceld solve both its near- and long-term interim storage needs and continue to operate both Surry and North Anna by:
- 1. Temporarily installing fuel racks in Surry's cask handling area to bridge the loss-of-full-core-reserve gap (asserted by Vepco to begin in the 35/ Vepco agrees with this projected timetable. See Storage of Surry Fuel Summary at 21.
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8 fall of 1984) until dry-cask could be available at Surry in 1986, or .
- 2. Temporarily abandoning full core reserve, or
- 3. Temporarily reducing Surry's capacity, and
- 4. Vigorously pursuing the dry-cask option at Surry which, by Vepco's own reckoning, could be on line in 1986 and meet all of Surry's storage needs for its entire operating life.
Faced with a proposal such as the instant one, where it is clear that the currently presented solution leaves a gaping hole in the applicant's long-term spent fuel storage needs (i.e., the time between 1993 when the Surry and North Anna pools are completely filled l
l and the late 1990's when the planned federal repository may be operational), and inadequately addresses the short-term picture, it is incumbent upon the Commission to evaluate Vepco's interim storage needs comprehen-sively. This obligation springs not only from NEPA but l also from the Atomic Energy Act, which requires the 4
Commission to take steps to minimize the health and safety risks associated with the commercial use of nuclear power. Thus, the Commission should, at this
i early point, attempt to develop an overall plan that -
minimizes fuel handling (and the attendant environ-mental and health and safety risks for workers and the public at large) over the entire lifespan of Vepco's nuclear plants.
North Anna 3 was once thought, at least by Vepco, to be the answer to its post-1993 storage needs.
Vepco, however, recently decided to cancel the North Anna 3 project, a decision 4hich clouds the longer-term storage picture. Louisa County urges the Commission to take steps now -- for example, by using its authority to impose conditions on the licenses it grants, Public Service Company v. U.S. NRC, 582 F.2d 77, 81, 85-86 (1st Cir.) cert. denied, 439 U.S. 1046 (1978), -- to require Vepco now to develop a comprehensive solution to its interim storage needs. The aim would be to develop an environmentally-acceptable overall plan to (1) reduce the need for fuel handling and thus minimize the risks of accidents or sabotage and reduce occupa-tional exposure, and (2) ensure that NRC licensing and supervision of commercial nuclear plants is consistent and rational -- in particular, to ensure that a Commission licensing action does not effectively bail out one plant at the expense of another.
36/ Interim Storage at 10-11.
V. Transportation Hazards A. Vepco's application is insufficient to support a Commission finding that receipt and storage of Surry fuel at North Anna, which necessarily entails trans-shipment of Surry spent fuel to North Anna, is not inimical to the public health and safety.
- 1. Vepco has not demonstrated that its transshipment plan will meet the "as low as is reasonably achievable" (ALARA) standard set forth in 10 C.F.R. $ 20 (1982) or the other precautionary procedures mandated in 10 C.F.R. I 20 (1982) to protect workers and the public at large from impermissible radiation exposure.
- 2. Vepco has not demonstrated that it has established a physical protection syatem which meets the requirements of 10 C.F.R. I 73 (1982).
- 3. Vepco's application does not indicate that it has made the required arrangements with local law enforcement agencies to ensure that their emer-gency response capabilities, in the event of an accident and/or sabotage, are sufficient to
protect the public safety and health. 10 C.F.R. 8
{ 73.37(b)(6) (1982). .
- 4. Vepco has not demonstrated that the procedures governing shipments from Surry to North Anna will meet the requirements of 10 C.F.R. 71 (1982).
- a. Vepco does not specify the type of license being requested under 71.
o
- b. Vepco does not meet the minimum requirements of 10 C.F.R. I 71.51 (1982) to provide a description of a quality assurance program for the proposed transshipment, nor does Vepco discuss the procedures which will be utilized to meet the standards delineated in Appendix E of { 71.
- c. Vepco does not fulfill the requirement of 10 C.F.R. $ 71.21 (1982) that applications for licenses or license amendments "shall include, for each proposed packaging design and method of transport:"
(1) a package description as required by $ 71.22;
(2) a package evaluation as required e by { 71.23; (3) an identification of the -
proposed program of quality assurance as required by
{ 71.24; (4) in the case of fissile material, an identification of the proposed fissile class.
- d. There are no computations or computer simulations to indicate that criticality will not be reached during shipment (10 C.F.R. c 71.33 (1982)).
- e. Vepco fails to identify the type of package and mode of transport; therefore it is impossible to evaluate the effect of the transport environment on the nuclear safety of the packages (10 C.F.R. { 71.37 (1982)).
l f. Vepco fails to identify the type of package and mode of transport; therefore it is impossible to assess whether the spent fuel I
shipments will meet the standards for hypo-thetical accident conditions. (10 C.F.R.
l j 71.36 (1982)).
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8 B. Since Vepco's application contains no information about the environmental impacts of the proposed shipments, it is insufficient to form the basis for Commission com-pliance with its NEPA responsibilities or with Part 51 of the NRC regulations.
C. Transshipment of spent fuel from one plant owne'd by a
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utility to another plant owned by the same utility is a relatively unusual event. Most spent fuel shipments have been from one licensee to another licensee (utility to spent fuel processor) and therefore have had the advantage of reviews by separate operating and quality organizational components. The Surry to North Anna shipment will be totally under the jurisdiction of Vepco and therefore should be subjected to independent review to assure that appropriate procedures are in place.
VI. Louisa County Spent Fuel Ordinance The proposed action should not be approved because the proposed action would violate the Louisa County Spent Fuel ordinance, which provides that:
It shall be unlawful for any person, partner-ship, corporation or any other entity to store or maintain in Louisa County any spent nuclear fuel or any other waste radioactive
d materials of similar qualities, except such :
materials as may result from nuclear fuel being used in Louisa County.
Anyone violating or causing anyone to violate this ordinance shall be fined not more than
$1,000.00; and each day that any such viola-tion continues shall be a separate offense.
If any phrase, clause, sentence, part or portion of this ordinance shall be declared unconstitutional or invalid by any valid judgment or decree of a Court of competent jursdiction, such unconstitutionality or ,
invalidity shall not effect any of the remaining phrases, clauses, sentences, portions or parts of this ordinance.
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Respectfully submitted, :l January 17, 1983 / h'Y, -
/J. Marshall Coleman Christopher H. Buckley, Jr.
Cynthia A. Lewis Robert Brager Virginia S. Albrecht Beveridge & Diamond, P.C.
1333 New Hampshire Avenue, N.W.
Washington, D.C. 20036 (202) 828-0200 Attorneys for Intervenor _
Of Counsel:
Richard W. Arnold Jr.
County Attorney Courthouse Square Main Street Louisa, Virginia 23093 (703) 967-1650
r CERTIFICATE OF SERVICE COGEjf0 :
gc IherebycertifythatIhavethisdayservedtheforegoing Contentions of Ir.tervenors County of Louisa, VirgdhidSk d h Board of Supervisors of the County of Louisa upon,eachcofdtke3 lyi M IV ((C I personsnamedbelowbydepositingacopyintheUnited'$' States mail, properly stamped and addressed to him.at the address set out with his name:
Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and Service Section -
Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Pa.tel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George A. Ferguson School of Engineering Howard University 2300 5th Street, N.W.
Washington, D.C. 20059 Daniel T. Swanson, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James B. Dougherty, Esq.
3045 Porter Street, N.W.
Washington, D.C. 20008 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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Michael W. Maupin a Hunton & Williams P.O. Box 1535 Richmond, VA 23212 -
a January 17, 1983 \ [/ /
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.g g3 rdAT 1 0 2-06 Mr. Ronald H. Laasburg Vice President-Nuclear Operations Virginia Electric & Power Company P.O. Box 26666 Richmond, VA 23261 SU3 JECT: Spent Fuel Storage at Surry
Dear Mr. Leasburg:
I am sending this letter in response to our telephone conversation of last week. As I see it, VEPCO has' three reasonable alternatives for spent fuel storage: increase pool storage capacity, tranship to North Anna, and on-site non-pool storage.
I reali=e that Stone and Webster will not allow any increase in fuel pool loads. However, it may be possible to increase the storage cacacity without increasing the loads. I do not know the ' details of the Surry fuel rack design, but if the present racks are stainless steel
,,9, without nuetron_ absorber, it would be possible to replace
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'{~ them withe' racks with neutron absorber and sub-g s:ancially! C C ihe fuel rack weight. This change alone i should allow storage of about ten percent more fuel in the
! existing pool. A side benefit of this approach is that the new racks could be designed for a higher fuel enrichment, which may be advantageous when considering ex: ended fuel cycles. I assume that the fuel pool strue: ural analysis has taken advantage of the concrete aging strength increase,
- used bouyant weights of fuel and fuel racks, minimized hydrodynamic = ass effec
- s and similar means of maximizing strength and minimizing loads. However, there may still be some other means of increasing storage capability.
Although the increase in pool storage capacity is so=ewhat limi:ed, it deserves all possible consideration because of 1:s benefits; reduced licensing proble=s, less fuel handling, no new structures or ::ansportation recuirements and so on.
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Mr. Ronald Lonsburg Page In relation to this approach, Mollerus Engineering could provide -;
a detailed evaluation of the potential storage capacity increase, work with S & W to ensure that the pool structural capacity is not exceeded and provide a report including recannended approaches, <
licensing concerns, cost and schedule estimates and recommended -
suppliers. This work would require about five weeks, and ME would perform the work on a time and materials basis for approx-imately $8,000.00, including one trip to Virginia.
Transhipment of Surry fuel to North Anna for storage would provide temporary relief of the Surry storage problem. However, licensing i
of this alternative could be a long and difficult process. Some of the areas in which ME could be of assistance to VEPCo are:
' evaluation of alternatives for the license request, determination of the availability of licensed equipma.nt (particularily shipping casks), review of the North Anna fuel handling equipment for comnatibility with Surry fuel, and review of North Anna storage racks for mechanical, structural and nuclear compatibility with Surry fuel.
_c If you are interested in ME providing services relafed to any or all of the above areas, I will provide cost and schedule esti=ates based on whatever scope of work you desire.
As we discussed on the telephone, the most reasonable ap on-site non-pool storage appears to be storage in casks.proachThereto are several companies interested in supplying these casks. To my knowledge the most advanced is Brooks & Perkins. B&P received l
a contract from DOE in January 1982 to supply one of these casks.
The cask to'be delivered to DOE will be for BWR fuel, but B&P i
will submit a topical report to the NRC to cover both BWR and PWR fuel storage. The proj ected schedule for this is :
Submit topical report to NRC July 1982 Complete cask manufacture December 1982 NRC review complete January 1983 The cask will be delivered either to Barnwell or TVA for testing.
Mollerus Engineering can provide assistance to VEPCo in relation to this type of storage as follows: preparation of bid specifications, technical and quality assurance qualification of vendors, evaluation of bids, deternination of requirenents for the cask storage facility, independent review of cask and/or facility design and analysis, licensing assistance and project management. As with the transhipment alternative, I will gladly prepare a cost and schedule estimate for a specific scope.
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Mr. Ronald Leasburg Pago . Both Fred Mollerus and I are experienced with design, analysis, fabrication and licensing of spent fuel storage modifications. -
Both Fred and I have testified at NRC hearings on spent fuel storage modifications.
As stated in our brochure on fuel storage which Bob Allen gave to you, ME is associated with Arne ?. Olson Corporation for nuclear and shielding analysis. Dr. Olson has extensive experience in fuel storage modifications and has also testified as an expert witness on this subj ect at NRC hearings.
In the area of structural analysis, Mr. Glenn 3rockmeier has over 35 years of experience, including spent fuel pool structual analysis. Mr. Brockneier would provide the structural analysis input to these proj ects.
I certainly believe that MI can be of assistance to VE?Co en this work. I will call you in about one week to discuss this further.
Sincerely, -
Mollerus Engineering m
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, James D. Gilerest JDG:j r -
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's MEMORANDUM , ;
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ro M. L. Smith Richmond, Virginia me. M. L. Bowling, Jr. May 5,1982
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ALTERNATIVES FOR LOSS OF FULL CORE DISCHARGE SURRY POWER STATION UNIT NOS. 1 AND 2
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j Loss of Full Core Discharge Capability is presently estimated to occur in the fourth quarter of 1984 at Surry Power Station Unit Nos.1 and 2. To postpone this loss of full core discharge there are options wnich may be available.
The one major option which could be utilized on a strictly " temporary basis" would be to utilize up to 3 spent fuel racks which are presently in the spent fuel pool at North Anna. The spent fuel racks could be ] laced ,
in the Surry spent fuel pool in the cask laydown area. This wouTd provide additional storage for 108 spent fuel assemolies and extend the time to loss of full core discharge at Surry by at least 2 years. In order te do this, a temporary stand for the fuel racks would have to be installed for the racks to be piaced on as there is a step in the floor of the spent fuel cask laydown area. The stand would simply consist of 2 or 3 I-beams and some stainless steel plate. The weight associated with the stand, the fuel racks, and fuel assemolies could be accomodated as the total weight would be less than a 125 ton spent fuel shipping cask and it would be spread out over a greater surface area of the floor (see attachment 1, calculation of
- weights).
From a licensing standpoint, Vepco would have to request the NRC to provide emergency permission to do this, however, from a technical stand-point there should be no problem. This was actually done with one spent fuel rack during the installation of the Surry High Density Spent Fuel Racks.
i From a seismic / structural standpoint there would be no problem as the
' North Anna fuel racks were designed to North Anna siesmic criteria which envelopes the Surry criteria. From a thennal-hydraulic and criticality stancpoint there would be no problem as the North Anna spent fuel racks were designed to accomodrte either Nortn Anna or Surry spent fuel.
I In order to temporarily relocate the 3 spent fuel racks from North Anna to Surry, should the need arise, the racks would be removed from the pool and decontaminated (hydrolased). They would then be wrapped in plastic and possibly be crated and then be shipped by truck to Surry. Once at Surry they could then be placec in the cask laydown.
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To: M. L. Smith May 5, 1982
.A.
Other alternatives include storage in dry casks (NPE is currently reviewing this alternative as part of the dry cask ISFSI project) and storage in transportation casks.
Please advise Mr. H. S. McKay if you require any further information on this matter.
M
- M. L. Bowling, Jr.
HSM:cbs cc: W. C. Spencer
_J. M. Davis E J*^1 Ligp_o.13 R. W. Calder L. H. Girvin C. P. Sanger G. H. Flowers
- H. S. McKay PSE&C Records Management NM-01, NP-51.2 l
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ATTACHMENT I
,..s,
-s-108 assemblies x 1700 = 186,300 lbs. or ~ 92 tons Weight of Fuel Racks = 15,000 lbs. each or 45,000 lbs. for 3 racks 22.5 tons Stand - < l5,000 lbs 1
Total Weight to Pool 122 tons
< 125 ton shipping cask i
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MEMORANDUM M fD M..
ro Mr. M. L. Smith Richmond, Virginia vnow M. L. Bowling, Jr. ,
October 6, 1982
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CURRENT COST ESTIMATES INDEPENDENT SPENT FUEL STORAGE INSTALLATION SURRY POWER STATION-UNITS 1 AND 2 Attached for your information are best-estimate lifetime total cost estimates for the Dry Cask and Wet Pool Storage facilities being considered for interim storage of the Surry spent fuel. The estimates provide projec-ted cash flows associated with each storage opt, ion ,as well as assumptions
'" forming the basis of the estimatei.' '
- . .C The attached information is the same as that which was reviewed with' .
you in the August. 23, 1982, meeting as preliminary. The-purpose of the.itrr..- -
formation is to provide a' basis for estimates of total lifetime cos'ts.
Accordingly, the estimated cash flows for each year may be subject to ad-justment without significantly affecting total estimated . costs, as the ,
actual timing or scope of specific project activities changes from the estimate. ,
Tables 1.2 and 2.2 sumarize the estimated costs of the Dry Cask and Wet Pool facilities respectively. The estimated . cost of the Dry Cask facility in 1982- unescalated dollars is between 58 and 75 million. The estimated cost of the Wet Pool facility in 1982 unescalated dollars is between 70'and 98 million. These estimates are generally cons.istent with
- our earlier estimates and those provided in Mr. R. H. Leasburg's memorandum of March 24, 1982 (60-90 million dollars for Dry Cask and 100-125 million dollars fo'r Wet Pool). The diffeience reflects our contracting experience, vendor discussions, and more detailed scope definition. .
We intend to update the istimate after approval of the 1983 budget. -
9 p.
At that time, we will know authorized funding f.or 1.983.and can plan near-term .
. . .,' project activities accordingly. Please nots that the attachment assumes commencement of Wet Pool final engineering in 1983. Your current authoriza '
tion to PSELC, and our 1983 budget request, do not provide for final eng.inesr. . .
l ing. Other known changes, which will- be included in the update, pertain (1) to the timing and amounts of license fees and (2) to engineering services. ~
to be provided by cask vendors. Seither of these items will have a signis .
ficant effect ca the estimated lifetime costs.
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Mr. M. L. Smith October 6, 1982 Page Two We will advise you promptly of any significant deviations from these estimates.
If you should have any questions concerning these estimates, please feel free to contact me.
hW$
M. L. Bowling, Jr.
GHF/JRA/nh Attachment ec: Mr. S. C. Brown, Jr., w/ attachment Mr. W. C. Spencer , w/ attachment Mr. A. L. Parrish, III , w/ attachment
- Mr.. J. M. Davis , w/ attachment Mr. G. H. Flowers w/ attachment l Mr. J. R. Adams w/ attachment PSE&C Records Management NP-50 w/ attachment i
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166759 l
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J ATTACHMENT 1 l
SUMMARY
OF COSTS DRY CASK INDEPENDENT SPENT FUEL STORAGE INSTALLATION i SURRY F0WER STATION 1
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L ii PSE&CS l AUGUST, 1982 I~
a 166760 I
brh/2942/1 - - _ -
TABLE 1.1 SIMMARY OF AS5UMPTIONS FOR CO5T ESTIMATE DRY CASK INDEPENDENT SPENT FUEL STORAGE INSTALLATION SURRY POWER STATION - UNIT 5 1 AND 2
- 1. Total storage capacity provided - up to 2000 assemblies
- 2. All costs projected in 1982 dollars without escalation
- 3. Project Start Date - April, 1982
- 4. Projected Startup Date - 1986
- 5. Facility Life - through 2008
- 6. Other assumptions are included with the individual tables t
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166761 l 08/82 l brh/2942/2
TABLE 1.2 c65TTIERKRY DRY CASK 5IURAGE FACILITY l 1952 5 X 1000 l License Application Preparation , $ 328 ,
l Design Engineering (A/E) 265
- ! Licensing Support (A/E) 429 Vepco Costs Excluding Construction 1645 1
Construction 2350
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1 Storage Cask Purchases 51000 - 68000 Operation & Maintenance 1454 Decomissioning 153 TOTAL LIFE OF FACILITY COSTS 57624 (Less Contingency)
Contingency 6
j Contingency at 15% for Licensing 882 1
support, Vepco Engineering, ll Construction, 08M
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TOTAL RANGE $58506 - 75506 Notes:
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! 1. Life of facility is through the year 2008.
9 l 2. If conso11 dated fuel is stored in the casks the total costs l
would be at least 25% lower than those shown above.
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O TABLE 1.3 CASH FLOW (000)
DRY CASK LICENSE APPLICATION PREPARATION BECHTEL POWER CORPORATION 1982 April $ 12 May 32 June 72 July 100 August 75 September 37 TOTAL $328
> The above costs are for the preparation of all documents to be submitted for the application for dry cask storage. Expenditures through June are actual amounts. Expenditures for July through September are estimates based on inputs from Bechtel.
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TABLE 1.4 CASH FLOW (000)
DRY CASK FACILITY ENGINEERING BECHTEL 1982 April $ 23 May 50 June 66 July . 50 August 30 i
September 25 1983 21
) TOTAL $265 The above costs are based on a fim price contract with Bechtei (Task Item f4) for all work required for the "No Building Option".
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TABLE 1.5 CASH FLOW (000)
DRY CA5K LICEN5ING SUPPORT BECHTEL 1982 $ 33 1983 132 1984 132 1985 132
. TOTAL $429 The above costs are based on Bechtel providing licensing support throughout the licensing process depicted on the project schedule.
Licensing process is assumed to be in accordance with the P. L. Grey Report. Bechtel assistance is estimated to be 200 MH/manth for 1983-1985.
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TABLE 1.6 CASH FLOW (000)
VEPCO EXCLUDING CONSTRUCTION COSTS PSE&C OTHER (Veoco) LEGAL TOTAL 1982 $ 141 $370* $ 50 $ 561 1983 144 72 50 266 1984 144 72 50 266 1985 144 72 50 266
! 1986 72 .36 50 158 1993 36 18 10 64 2001 36 18 10 64 n
TOTAL $ 717 $658 $270 $1645 r The above costs are estimated based on moderate Yepco involvement in predominately Mode II operation. 1982 ccsts are 60% of the current ISFSI
. estimate which also includes engineering for the Wet Pool option, based on pursuing dry storage as the prime alternative. Costs for 1983 through 1986 assume only dry storage will be pursued. The costs are based on
, PSE&C expenditures of $12 k/mo ($6k NPE, $3k ES, $3k Overhead), other Yepco department expenditures of $6k/mo (1/2 of PSE&C) and $50k/yr paid to Hunton & Williams for legal support during licensing and construction.
Costs for 1993 and 2001 are for engineering support of modular expansions.
- 1982 costs include $300,000 for license application fee.
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! TABLE 1.7 l CASH FLOW (000)
FACILITY CONSTRUCTION COSTS i
- 1985 $ 425 1986 425 t
1993 750 I 2001 750 1
TOTAL $2350 The above costs are based on constructing storage slabs as required.
Initial construction (1985 & 1986) will consist of clearing the i entire site, installing any security systems and constructing the i
first storage facility. Initial construction is scheduled (optimistically) to begin before the license is issued. Costs are based on estimate made by Bechtel dated March 2, 1982. 1985 costs include purchase of cask transport equipment.
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TABLE 1.8 DRY STORAGE CA5K PURCHASES Number of Casks Cost /5600k/ea Cost / Cash Flow (000)/$800k/ea 1985 4 $ 2400 $ 3200 86 3 1800 2400 87 5 3000 4000 88 2 1200 1600 89 3 1800 2400 .
1990 5 3000 4000 91 2 1200 1600 92 3 1800 2400 93 5 3000 4000 94 2 1200 1600 1995 3 1800 2400 96 5 3000 4000 97 2 1200 1600 98 3 1800 2400 99 5 3000 4000 l 2000 2 1200 1600 01 3 1800 2400 02 5 3000 4000 i 03 2 1200 1600 l 04 3 1800 2400 2005 5 3000 4000 06 2 1200 1600 07 5 3000 4000 08 6, 3600 4800 TOTAL 85 $51000 $68000 The above costs are for 24-element storage casks. The current cost estimates for casks range from $600k to $800k each. The required quantities are based on the fuel buildup schedule (a ttached) . Casks purchased on 1985 and 1986 would be used for early storage of spent fuel prior to construction of the facility, subject to NRC approval, and are considered initial capital costs.
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i L- TABLE 1.9 l CASH FLOW (DJ0)
DRY CASK FACILITY OPERATING & MAINTENANCE COSTS I 1986 $ 57 87 64
,; 88 57 i 89 60 l 1990 64
, 91 57
- 92 60 93 64 94 57 Pl 1995 60 96 64 97 57 98 60 99 64 2000 57 01 60 02 64 03 57 04 60 2005 64 06 57 07 60 08 64 09 66 TOTAL $1454 l
I These operating and maintenance costs are based on the Bechtel preliminary engineering study dated March 1982. The costs include rental of cask unloading crane and routine maintenance of amnitoring and lighting systems.
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l TABLE 1.10 CASH FLOW (000) i DRY CASK FACILITY DEC0MMISSIONING l 2008 $ 51 l
l 2009 51 2010 51 l
TOTAL $153 l
i The above costs include dismantling the monitoring and electrical systems and checking the slab and surrounding area for contamination.
Costs do not include disposal of fuel assemblies and casks.
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- ATTACHMENT 2
SUMMARY
OF COSTS 1
WET POG. INDEPENDENT SPENT FUEL STORAGE INSTALL 4 TION i: SURRY POWER STATION 1
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PSE&CS AUGUST, 1982 166771 6 iseoze n-
TABLE 2.1
SUMMARY
OF AS5UMPTIONS FOR CO5T ESTIMATE WET POOL INDEPENDENT SPENT FUEL diuRAGE INSTALLATION SURRY POWER STATION - UNIT 5 1 AND 2
- 1. Total storage capacity provided - 2100 assemblies
- 2. All costs projected -in 1982 dollars without escalation
- 3. Project Start Date - April,1982
- 4. Projected Startup Date - 1988
- 5. Facility Life - throug's 2008
- 6. Other assumptions are included with the individual tables l
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, TABLE 2.2 SUMMMARY OF COSTS WET POOL INDEPENDENT SPENT FUEL STORAGE INSTALLATION
. SURRY POWER STATION - UNIT 5 1 AND Z 1982 5 X 1000 i
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License Application and Conceptual Engineering $ 465 Final Engineering 934 l Construction Costs 27000 - 54000 Vepco Costs Excluding Constructio'n 3075 Modular Expansion Costs 3388 Operating and Maintenance Costs 16262 Decommissioning 11250 TOTAL LIFE OF FACILITY COSTS 63134 l (Less Contingency)
Contingency J,
[i Based on 15% of Final Engineering 7713 4 Field Engineering, Vepco Engineering,
[
Construction Modular Expansion Costs
- and 0 & M Costs L
! TOTAL RANGE 570847 - 97847
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! Note:
Life of facility is through the year 2008.
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r TABLE 2.9 CASH FLOW (000)
WET POOL OPEPATItC AND IMINTENANCE COSTS 1988 $ 680
, 89 .
742
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1990 742 91 742 92 742 -
93 742 These operating and maintenance costs a;e based on Table B of the Stone 34 742 & Webster cost estimate dated March 1982. Costs for 1988 are for 11 months 1995 742 of operation per schedule.
96 742 97 742 98 742 99 742 2000 742 w 01 742 02 742 e
i 03 742 i
1 04 742 2005 742 06 742 07 742 08 742 09 742 s TOTAL $16262 08/82 hrhi?tMJD 166780
e o TABLE 2.10 CASH FLOW (000)
DECOMMISSIONING COSTS 2009 4 3750 2010 3750 2011 3750 TOTAL $11250 Decommissioning costs are estimated to be approximately 40% of the total construction costs including modular expansions.
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TABLE 2.9 CASH FLOW (000)
WET POOL OPERATING AND MAlHTENANCE COSTS 1988 $ 680 89 742 i
1990 742 91 742 92 742 -
93 742 These operating and maintenance costs are based on Table B of the Stone 94 742 & Webster cost estimate dated flarch 1982. Costs for 1988 are for 11 months 1995 742 of operation per schedule.
96 742 97 742 98 742 99 742 2000 742
- 01 742
> 02 742 s
l 03 742 i
!l 04 742 li) .
2005 742 1
OS 742 07 742 l, 08 742
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09 742
- TOTAL $16262
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1 1 TABLE 2.10 -
CASH FLOW (000)
DECOMMISSIONING COSTS 2009 $ 3750 2010 3750 2011 3750 TOTAL $11250 Decommissioning costs are estimated to be approximately 40% of the total construction costs including modular expansions.
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