ML20035B096
| ML20035B096 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1993 |
| From: | Weiss S Office of Nuclear Reactor Regulation |
| To: | Roy R CONGRESS (JOINT & ROTATING COMMITTEES, ETC.) |
| References | |
| NUDOCS 9303310116 | |
| Download: ML20035B096 (9) | |
Text
,
-l February 19, 1993 Mr. Robin Roy, Project Director l
Congress of the United States Offica of Technology Assessment Washington, D.C.
20510-8025
Dear Mr. Roy:
I am responding to your letter of December 22, 1992, in which you requested comments on a draft Office of Technology Assessment report, Aoina Nuclear JLower Plants. The enclosed comments are the result of Office of Nuclear Reactor Regulation and Office of Nuclear Materials Safety & Safeguards reviews 4
in response to letters you sent to individual NRC staff members. We have restricted our comments to factual information and clarity of presentation.
Lack of comments does not indicate agreement with the recommendations contained in the report.
I hope these comments will be of help to you.
If I can be of any further assistance to you or members of your staff, please i
do not hesitate to call me at (301) 504-2170.
Sincerely, Original signed by:
Seymour H. Weiss, Director Non-Power Reactors and Decommissioning i
Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulations
Enclosure:
As stated DISTRIBUTION:
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February 19, 1993~
Mr. Robin Roy, Project Director-Congress of the United States Office of Technology Assessment Washington, D.C.
20510-8025
Dear Mr. Roy:
g I am responding to your letter of December 22, 1992,-in which you requested i
comments on a draft Office of Technology Assessment report, Aoino Nuclear l
Power Plants. The enclosed comments are the result of Office:of Nuclear.
Reactor Regulation and Office of Nuclear Materials Safety & Safeguards reviews-in response to letters you sent to individual-NRC staff members. We have restricted our comments to factual information and clarity of presentation.
^!
Lack of comments.does not indicate agreement with the recommendations I
contained in'the report.
I hope these comments will be of help to you. -
l If I' can be of any further assistance to you or members of.your staff, please--
do not he.sitate to call me at (301) 504-2170.
j Sincerely, l
l t
' 'Seymour H. Weiss, Director.
Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor' Support Office of Nuclear Reactor Regulations l
i
Enclosure:
As stated l
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COMMENTS ON OFFICE Of TECHNOLOGY ASSESSMENT DRAFT REPORT
" AGING NUCLEAR POWER PLANTS" Chaoter 1 (1)
Page 3, paragraph 2, line 4 - Comment, Haddam Neck is currently not the i
oldest operating plant. The oldest operating plant is Big Rock Point, located near Charlevoix, Michigan, CP issued May 31, 1960 and OL issued May 1, 1964.
(2)
Page 4, paragraph 1, line 4 - Suggestion, verify that the percent values of 40 percent for the NE and 10 percent for central are consistent with the data presented in Figure 1-2.
(3)
Page 10, paragraph 4, line 3 - Comment, the same comment as Chapter 1 comment (1), above.
In addition, the Big Rock Point license expires May 31, 2000.
(4)
Page 11, paragraph 1, line 2 - Edit, more than 60 other plants, over one half of those now in operation.
(5)
Page 18, paragraph 2, lines 7 and 8 - Edit, operating licenses expiring in 2013 and 2014, although current storage capacity is sufficient only through 1990.
i (6)
Page 19, paragraph 2, line 7 - Edit, few years or extended over several decades to a maximum of 60 years, unless further delay is required to protect public health and safety.
(7)
Page 20, paragraph 2, line 5 - Comment, although the planned participatory rulemaking has not yet codified NRC site radiological release criteria, interim criteria have been established by the NRC and are contained in the Site Decommissioning Management Plan Action Plan, SECY 91-342A and its related Staff Requirements Memorandum dated April 6, 1992.
(8)
Page 20, paragraph 2, line 8 - Comment, this statement appears to be ambiguous.
It is more accurate to state that the choice of financial assurance mechanisms allowed by the NRC can affect cost. These mechanisms were established by the NRC in 1988, so the level of requirements is no longer uncertain.
Further, since essentially all NRC power reactor licensees are using an external trust, the only major cost variable is the amount that each trust fund earns.
(9)
Page 21, paragraph 3, line 9 - Edit, under 10 CFR 50.75 are not.
Comment, also, the point should be made here, as it is elsewhere in the report, that the NRC decommissioning cost formulas do not include such costs as spent fuel storage and disposal and demolition of non-radioactive structures and components.
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t (10)
Page 22, paragraph 1 - Comment, NRC regulation 10 CFR 50.54(bb) does l
include financial assurance requirements for maintenance of spent fuel until it is accepted by the Department of Energy. These costs are i
considered operational costs and thus are not included as 1
decommissioning costs.
(11) Page 22, paragraph 3, line 5 - Comment, the number of other plants (46) is not consistent with the 40 plants cited on page 11. Also, see Chapter 1, comment 4.
(12)
Page 27, paragraph 1 - Comment, TVA also has 4 units (Watts Bar I and 2 and Bellefonte 1 and 2) under construction.
(13)
Page 32, paragraph 2 - Comment, the NRC modified the process used to prepare generic communications after considering the merits of the GA0 report.
In order to ensure that the public has access to information on significant safety issues, the NRC no longer factors whether INPO issued a SEE-IN report into the decision to issue or not issue a generic communication. This change was transmitted to the staff formally through a memorandum from J. H. Sniezek to T. E. Murley and E. L. Jordan of July 8,1991. The memorandum stated that the staff could still review INPO SEE-IN reports for technical information.
The NRC staff continues to review operational events of its licensees using a combination of methods that includes daily observations by resident inspectors at the reactor sites, routine inspections, special inspections, and the review of information provided to the NRC by various sources (e.g., licensees, vendors and owners groups). The INP0 SEE-IN reports are utilized as one of these sources and allow the NRC to review the technical aspects of an event from an alternative perspective. Although the staff does not expect to find any significant information in these reports of which the NRC is not already aware, it is appropriate for the staff to take advantage of all available information resources.
Although the INPO SEE-IN reports are not available to the public, various sections of the 10 CFR, particularly Sections 50.72 and 50.73, require licensees to report safety significant events to the NRC.
These licensee reports to the NRC are available to the public. Therefore, the public does have access to the information on safety significant events.
(14)
Page 36, paragraph 3, line 2 - Edit, and other equipment lasts.
(15)
Page 41 discussion point 3 - Comment, the discussion of nuclear plant economics should include a recommendation on better identifying the reasons for variations in nuclear operating and maintenance (0&M) costs.
Although this seems to be subsumed in the third discussion point, it i
needs to be stated explicitly.
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With respect to-improving estimates of decomissioning costs', the NRC.
l specifically chose to require licensees to use generic decomissioning
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cost formulas rather than site-specific estimates. Site-specific.
estimates are burdensome to licensees early in reactor life when there
- i are large uncertainties concerning decomissioning costs that will be i
incurred relatively far in the future. For this reason,-the NRC chose to require power reactor licensees to submit site-specific-decomissioning plans five years before planned shutdown. Five years were chosen because it is close enough to shutdown to reduce uncertainties but far enough away to allow a utility to'makeLup any decomissioning funding shortfalls without being unduly financially.
stressed.
i Chapter 2 (1)
Page 4, paragraph 1, line 4 - Edit, Institute of Nuclear i
Power Operation.
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(2)
Page 6, paragraph 3, line 4 - Edit, Yankee Rowe had no direct l
means of measuring.
(3)
Page 8, Footnote 20, line 1 - Edit, delete the word generic before the word bulletins.
(4)
Page 15. paragraph 1, - Comment, only '10 plants participated in the SEP--
effort.
(5)
Page 16, paragraph 2, line 1 - Edit, NRC backfit' rule.-
(6)
Page 35, paragraph 2, line 3 - Edit, before and during.
(7)
Page 35, paragraph 2, line 6 - Edit, five PRAs necessarily.
i Chapter 3 e
(1)
Table 3 Comment, the information related to Trojan needs to be f
corrected to reflect the permanent shutdown of that facility. Year of-i permanent shutdown 1992 and age at shutdown 17.
i (2)
Page 10, paragraph 1, line 1 - Edit, the first statement is not a complete sentence.
i (3)
Page 11, paragraph 1, line 3 - Edit,1967, and was retired in 1992 under.
(4)
Page 12, paragraph 1, line 5 - Coment, for Fort St. Vrain, some additional decomissioning costs have been authorized to be ' recovered from rate payers. This paragraph should be supplemented to include the correct information as stated later in Chapter 4, page 29, paragraph 4.-
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(5)
Page 13, paragraph 1, line 5 - Edit, variety of major.
(6)
Page 13, paragraph 2, line 3, Edit, plant's pressure boundary to transfer.
(7)
Page 16, paragraph 1, line 2 - Edit, plant in 1992 was.
(8)
Page 19, paragraph 3 line 3 - Edit, 8 percent of the average unit.
(9)
Page 23, paragraph 3, line 5 - Edit, Indian Point Unit 2.
(10) Page 24, paragraph 2, line 1 - Comment, the first sentence in this paragraph is unclear. Nuclear reactors consume uranium-235. Uranium-235 is a small fraction of the total uranium in the core.
(11) Page 26, paragraph 1, lines 2 and 3 - Edit, expiring in 2013 and 2014 although...only through 1994.
Chapter 4 (1)
Page 1, paragraph 1, line 7 - Edit, same as Chapter 1, comment 6.
(2)
Page 1, paragraph 2 - Comment, same as Chapter 1, comment 9.
(3)
Page 2, paragraph 3, line 5 - Comment, waste storage uncertainties have not prevented "the development of definitive cost estimates." The costs of long-term waste storage have caused decommissioning cost estimates to vary over fairly wide ranges depending on the waste situations for
~
particular reactor sites.
(4)
Page 10, paragraph 2, line 3 - Edit, sources that regulation below a certain level will not yield benefits that are commensurate with the costs of such regulation. A formal.
(5)
Page 11, Box 4-X, Comment, the BRC issue affects all nuclear activities, not just activities related to commercial nuclear power plants.
(6)
Page 11, paragraph 2, line 3 - Edit, warranted.
In 1986, NRC published criteria and procedures for expedited consideration of petitions to exempt BRC waste streams from stringent requirements for low-level waste management and disposal.
In 1990.
(7)
Page 12, paragraph 1, line 1 - Edit, decommissioning, and 3 the extent to which slightly contaminated material may be reused or recycled in
)
general _ commerce. Depending.
(8)
Page 12, paragraph 1, line 5 - Edit, use, and the extent of recycling allowed for slightly contaminated material and equipment.
9 a (9)
Page 13, paragraph 2, line 7 - Edit, enough, portions of the reactor internals may be classified as GTCC.
(10)
Page 16, paragraph 1, line 5 - Edit, located in or near the reactor.
(11)
Page 33, paragraph 1, item 2 - Comment, the purpose of the $10 million external fund is to ensure that there are funds available to place the facility into a safe configuration should LILCO be unable to continue funding the facility decommissioning.
(12)
Page 33, paragraph 2 - Comment, fuel disposition options also include use of fuel in another reactor or storage of the fuel either at the Shoreham site or another reactor site.
(13)
Page 34, paragraph 2, line 4 - Edit,10 CFR Part EO, but has applied to amend the license to reflect.
(14)
Page 34, paragraph 3, line 7 - Edit, Including assumed escalation factors to adjust for inflation, decommissioning costs.
(15)
Page 41, paragraph 2 - Comment, it may be misleading to state decommissioning cost estimates in terms of percentages of construction costs. This implies that there is a cause-effect relationship between construction and decommissioning costs.
Both construction and decommissioning costs are related to some extent to reactor size; but several other factors that affect construction cost or decommissioning cost, but not both, are important.
For example, the same size and type of reactor could have been built at different times with different financing costs. The plant whose capital and thus overall construction costs were greater may not be any more expensive to decommission.
Access to low-level waste disposal sites will also vary independent of initial construction cost.
(16)
Page 46, paragraph 2, line 11 - Edit, delete the words of radiation after the word millirems.
(17)
Page 51, paragraph 3 - Comment, this discussion does not take into account the NRC requirement of a site-specific decommissioning cost estimate five years before permanent shutdown. The five year period was designed to allow licensees sufficient time to accumulate any additional funds needed to decommission beyond those accumulated on the basis of the formula amounts.
(18)
Page 52, paragraph 2 - Comment, same as Chapter 1, comment 9.
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-e (19) Page 54, paragraph 2 - Comment, the discussion does not properly describe the provisions of the final funding rule for prematurely shutdown plants. An "A" bond rating serves as a screening criterion.
If a licensee maintained this bond rating it would automatically be eligible to fund decommissioning into the safe storage period.
Licensees whose bond ratings are below "A" or equivalent could still fund into the safe storage period if they are able to demonstrate reasonable assurance in some other way that they will remain solvent.
Also, the final rule does not prevent the funding accumulation period from exceeding the expiration date of the original operating license.
Chapter 5 (1)
Page 3, paragraph 1, line 3 - Edit, begin new paragraph with Hope Creek.
(2)
Page 3, paragraph 2, line 8 - Edit, begin new paragraph with SONGS.
(3)
Page 3, paragraph 3, line 9 - Edit, delete the word them after.the word between.
(4)
Page 4, paragraph 4, line 1 - Comment, the basis for this statement is unclear since 10 CFR 50.73 defines the method and procedures for all reactor licensees to submit LERs.
(5)
Page 12, paragraph 3, line 4 - Comment, reference 10 is indicated to be related to Hope Creek. However, the title of the document is related to Monticello.
(6)
Page 12, paragraph 3 - Comment, the 2007 date is based on being able to fully offload the core. The spent fuel pool will not actually be full until after the end of the 16th fuel cycle in 2010.
(7)
Page 13, paragraph 3, line 3 - Comment, the TLG report should be referenced.
(8)
Page 16, paragraph 2, line 2 - Edit, staff numbers about 350:
about 300 permanent employees.
(9)
Page 16, paragraph 2 - Comment, with the current fuel cycle lengths and anticipated fuel loadings, the Monticello spent fuel pool has the capacity to receive spent fuel to 2010. However, there will not be full core off-load capability after 2004.
(10) Page 21, paragraph 4, line 1 - Edit, the Salem operating licenses expire in August 2016 (Unit 1) and April 2021 (Unit 2).
(11)
Page 25, paragraph 4 - Comment, this paragraph should be revised to reflect permanent shutdown of SONGS I at the end of fuel cycle 11 on November 30, 1992.
e,
< (12) Page 26, paragraph 3, line 2 - Edit, delete the words (mode 6) after the word mode.
(13) Page 26, paragraph 5, line 1 - Edit, Despite earlier difficulties with Unit 1, recent operations continued for 377 days.
(14) Page 33, paragraph 2, line 7 - Edit, will be placed back.
(15)
Page 35, paragraph 2, line 5 - Edit, until a license.
(16) Page 36, paragraph 2, line 5 - Edit, will be pumped.
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