ML20040E357
| ML20040E357 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/28/1982 |
| From: | Weinstein A JOINT APPLICANTS - PALO VERDE, S.M. STOLLER CORP. (SUBS. OF ARTHUR D. LITTLE, INC.) |
| To: | |
| Shared Package | |
| ML20040E356 | List: |
| References | |
| NUDOCS 8202040223 | |
| Download: ML20040E357 (16) | |
Text
m O
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
ARIZONA PUBLIC SERVICE
)
COMPANY, et al.
)
Docket Nos. STN 50-528
)
STN 50-529 (Palo Verde Nuclear
)
STN 50-530 Generating Station,
)
Units 1, 2 and 3)
)
)
AFFIDAVIT OF ALBERT A. WEINSTEIN ON CONTENTION NO. 7 STATE OF ARIZONA
)) ss.
County of Maricopa
)
I, Alburt A.
Weinstein, being duly sworn, upon my I
cath state as follows:
1.
I am employed by The S. M.
Stoller Corpora-tion as Manager of Engineering.
My business address is 1250 Broadway, New York, New York 10001.
2.
In such capacity I am responsible for con-sulting activities relating to nuclear reactor servicing, nuclear power plant decommissioning and nuclear power plant-arrangement and system design, and for projects in real-time system applications.
I have had direct experience in de-commissioning, having served as the resident engineer at the BONUS nuclear plant in Puerto Rico responsible for the de-
. commissioning program definition, planning and scheduling.
8202040223 820129 PDR ADOCK 05000528 G
o Decommissioning of the BONUS plant was completed in 1970.
My resume is set forth in Attachment AAW-1 (attached).
3.
This affidavit is made with reference to Intervenor Patricia Lee Hourihan's Contention No. 7.
4.
The term " decommissioning" may be defined for a nuclear facility as "the measures taken at the end of the facility's operating life to assure the continued protection of the public from any residual radioactivity or other po-tential hazards present in the facility."
R.
I.
- Smith, G.
J.
- Konzek, W.
E.
Kennedy, ~Jr., Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reac-tor Power. Station, NUREG/CR-0130, Vol.
1, at 1-1 (June 1978)
(hereinafter cited as the "PNL Study").
5.
Through 1981 at least fourteen (14) reactors with power ratings greater than 10 MW(t) have been decommis-sioned.
6.
The most commonly recognized dacommissioning alternatives are immediate dismantlement, safe storage and i
i entombment.
Immediate dismantlement refers to the disman-tlement of the facility at the end of its operating life resulting in unrestricted access to the site.
Safe storage refers to the mothballing of the facility for a period of time by putting it in protective storage after all fuel and radioactive fluids and waste have been removed from the i
l l
site.
Entombment refers to the sealing off of the facility in a manner which provides structural integrity for such I
1 l !
(
t period as significant quantities of radioactivity remain with the material in the entombment.
7.
I have been advised by Arizona Public Service Company, the Project Manager for the Palo Verde Nuclear Gen-erating Station ("PVNGS"), that Joint Applicants have not yet decided on a particular mode of decommissioning for PVNGS.
8.
For purposes of developing a cost estimate for decommissioning, Joint Applicants assumed that the method of immediate dismantlement would be used.
9.
The decommissioning cost estimate for PVNGS was prepared by The S. M.
Stoller Corporation in 1979.
The 1979 estimate was a comprehensive update of an earlier esti-mate prepared in 1975.
10.
The following ground rules governed prepara-tion of the estimate in 1979:
(a)
Plant data was taken primarily from the Combustion Engineering Standard Safety Analysis Report, from the PVNGS Preliminary Safety Analysis Report, and from data provided by Arizona Public Service Company.
In a few cases where detailed data was not readily available, an estimate was made based on data from similar units.
(b)
Essentially all costs were based either on data from the decommissioning of the Elk River and BONUS reactors or on data from the PNL Study performed by Batelle Pacific Northwest Labs ("PNL).
, i
Where the data resulted in different costs for a task, the more realistic value was used.*
(c)
Costs were estimated from the Elk River experience by extrapolating the Elk River costs based on a ratio of weights or volumes as appro-priate.
(d)
Costs were estimated from the PNL study by using the methodology of that report and the plant data for the PVNGS units.
11.
The decommissioning method for Elk River was
~
immediate dismantlement.
Decommissioning of the BONUS reac-tor was by entombment.
The PNL Study provided estimates fer both immediate dismantlement and safe storage.
An addendum to the PNL Study which considered decommissioning by entomb-met was published in August 1979.
12.
The PNL Study was performed for the Trojan Nuclear Plant, an 1175 MW(e) pressurized water reactor, as a reference reactor power plant.
Using this nuclear steam supply configuration in conjunction with a generic site and
- For example, for the PNL Study, the projected cost for dem-olition and removal of all structures at the reference nu-
. clear power plant site was $7 million.
This estimate in-cluded the demolition of a large hyperbolic natural draft cooling tower.
The wrecking contractor estimated this part of the demolition job at S2.7 million.
The PVNGS units, houever, will utilize much smaller mechanical draft cooling towers which, according to the estimates made by extrapolat-ing the Elk River numbers, should cost less than $1 million to remove.
Adjusting the PNL estimate to allow for this de-sign difference between PVNGS and the reference nuclear power plant, the estimate for PVNGS for demolition of the non-radioactive structures is $5.1 million.
_4_
structures, systems and components typical of the current generation of large pressurized water reactor power sta-tions, PNL developed a set of work plans for the decommis-sioning by immediate dismantleient of this station.
The choices of plans and techniques made in the study were pre-dicated on the utilization of demonstrated methods for de-contamination and dismantlement and on the provision of an appropriate level of safety to the public and the decommis-sioning workers.
Because the realistic bases and the level of detail applied in the PNL Study make it a definitive evaluation of decommissioning costs, I would rely on it as a primary reference for comparison.
13.
The basic methodology used in the cost esti-mate for PVNGS was to divide' the dismantlement operation into six discrete tasks and to develop a cost estimate for each task.
The tasks used in the PVNGS study generally con-form to the task definitions for the Elk River decommission-ing and the PNL Study.
14.
The six discrete tasks analyzed for PVNGS, and their respective estimates in 1979 dollars for each unit, are as follows:
I TASK S(MILLIONS)
(a)
Site and facility preparation.
6.1
- This task consists of cutting additional access hatches in buildings for equipment removal, t
9
~
TASK
$(MILLIONS) bringing in temporary power, licensing and nuclear insur-ance requirements, and environ-mental surveillance.
( b )'
Removal and shipment of spent 1.2 fuel. - During unit operation, approximately one-third of a core is removed each year.
Fil-ter and demineralizer resins are also changed about once a year.
.At the time of decommissioning, removal of all resins and filters and removal of one-third of the o
core can properly be regarded as operating expense for the previous year, and only the added cost of removal of the other two-thirds of the core, as well as removal of all sources and control rods, have been taken as part of the cost of i
dismantling.
(c)
Decontamination. - It is assumed 1.5 that all nuclear plant systems will be decontaminated, cut up, a
9 TASK
$(MILLIONS) and shipped to an approved burial ground.
This task is concerned with the decontamination of the nuclear plant systems.
(d)
Removal of nuclear and contain-19.4 ment system components. - This task consists of cutting up and removing the reactor vessel and internals, nuclear system piping and equipment, and the biological shield.
(e)
Shipment and burial of radio-10.1 active wastes. - This task con-t sists of preparation, shipment, and burial of all the wastes generated in Task (d), as well as other solid wastes (e.g.,
l spent resins, spent filter car-tridges and liquid wastes).
A shipment distance of 1000 miles is assumed.
l (f)
Demolition. - Upon completion of 5.1 l
l Tasks (a) through (e), all remain-ing structures and equipment would t
be non-radioactive.
Remaining l i
TASK S(MILLIONS) equipment would consist of piping and mechanical equipment in the turbine building and control building, as well as electrical
' cables and equipment throughout the unit.
All structures wobld require demolition.
These struc-tures would be mostly reinforced concrete with some structural steel (primarily the turbine building super-structure).
Subtotal 43.4 CONTINGENCIES 13.3 TOTAL 56.7 15.
The nominal net power output of each Palo Verde unit is 1270 MW(e).
16.
The 22.5 MW(e) Elk River reactor was decom-missioned in 1974 at a cost of $6,075,000.
17.
As noted previously herein, the PNL Study was performed for an 1175 MW(e) pressurized water reactor.
The PNL Study resulted in an estimated cost for immediate dis-mantlement, including a contingency allowance of 25%, of $42 million in 1978 dollars.
0 18.
In preparing this affidavit, I have reviewed the following reports for the purpose of determining the extent to which such reports affect the decommissioning es-timate for PVNGS:
(a)
Accountants for the Public Interest, An Analysis of Decommissioning and Premature Shutdown Costs of Nuclear Power Plants (August 1, 1980)
(the " API Report"); and (b)
Richard Hubbard, Nuclear Power Plant Decommissioning, Draft (August 31, 1979)
(the "Hubbard Report").
19.
The API Report focuses on two issues related to decommissioning of a nuclear power plant.
These issues are the possible effects of decommissioning costs and earlier-than-expected retirement of nuclear plants on rate-payers, taxpayers and utility companies.
In analyzing such effects, the authors make no attempt to estimate the decom-missioning costs of a nuclear power plant.
Rather, they simply refer to and use several estimates prepared by others, ranging from $24 million to over $100 million.
As stated by the authors:
"Our purpose is not to predict which of these estimates is the most reasonable, but rather to demonstrate the possible effects of decommissioning costs on ratepayers based on a range of both costs and estimated use-ful lives of the plant. "
API Report, at 11 (emphasis in original).
In summary, the effects analyzed in the API Report have no bearing on either the methodology or the re-sult of the decommissioning cost estimate for PVNGS.
20.
At page 35 of the API Report the authors refer to the testimony of W.
A.
Verrochi before the Penn-sylvania Utility commission stating that the estimate for immediate dismantlement of TMI Unit 1 in 1974. dollars was
$117.5 million.
No further information respecting this es-timate is presented in the API Report.
21.
In discussing the earlier-than-expected re-tirement of nuclear plants, the authors of the API Report mention several factors which could affect the useful life of a nuclear facility.
These factors are aging, radiation buildup, more stringent radiation exposure levels, the stor-age and disposal of spent fuel and radioactive wastes, and more stringent safety standards.
Consideration of these factors would not increase or decrease the decommissioning cost estimate for PVNGS.
At most, such factors might affect the time when decommissioning costs would be incurred.
The authors of the API Report distinguish "early" retirement from a " premature" retirement caused by the occurrence of an unforeseen event such as a serious accident.
It should be recognized, as the accident at TMI Unit 2 has shown, that in the event of an accident requiring premature decommission-ing, the combined costs of decontamination and decommission-ing would likely far exceed the costs of decommissioning alone.
22.
The Hubbard Report presents a brief descrip-tion of decommissioning alternatives and decommissioning procedures and then reviews four decommissioning cost stud-ies.
Mr. Hubbard makes no attempt to estimate the decommis-sioning costs of a nuclear power plant.
The decommissioning studies reviewed by Mr. Hubbard were prepared by (a) the Atomic Industrial Forum for both boiling water reactor and pressurized water reactor types (the "AIF Study"), (b) Gen-eral Public Utilities ("GPU") for TMI Unit 1 (the "GPU Study"), (c) Pacific Gas and Electric Company for the Diablo Canyon Nuclear Power Plant (the "PG&E Study") and (d) the Nuclear Regulatory Commission (the PNL Study).
As to the AIF Study, Mr. Hubbard makes certain adjustments to the es-timates presented therein to ~ llow for escalation, contin-a gencies and site specific features.
The decommissioning cost estimates for immediate dismantlement resulting from these studies, as presented by Mr. Hubbard, are $49 million to $67 million in 1978 dollars for the AIF Study, as modi-fied by Mr. Hubbard, $117.5 million in 1974 dollars for the GPU Study, S39 million to $100 million in 1978 dollars for the PG&E Study, and $42 million in 1978 dollars for the PNL Study.
23.
With respect to the GPU Study, Mr. Hubbard lists as his source of information the testimony of W. A.
i Verrochi of GPU presented before the Pennsylvanli Public Utility Commission in 1975.
Mr. Hubbard includes in his re-l 1
. l
port a breakdown of the estimated costs for dismantling, mothballing and in-place entombment of TMI Unit 1.
24.
Examination of the decommissioning tasks and cost estimates from the GPU Study as set forth at page 14 of the Hubbard Report discloses that of the estimated cost for immediate dismantlement, $117.5 million (1974 dollars), $89 million is ascribed to Direct Costs, and $28.5 million to Indirect Costs.
The Direct costs can be separated into radioactive type ($39 million).and non-radioactive type ($50 million) work.
Radioactive type work covers (i) the removal and shipment of fuel, control rods, etc., (ii) the decon-tamination of fluid systems, (iii) the dismantlement, pack-aging and shipment of low-level and high-level radioactive components (including the reactor vessel), and (iv) the pro-cessing, packaging, shipment and burial of radioactive waste.
Non-radioactive type work covers the dismantling of buildings, cooling towers, structures, tanks, and site res-I toration.
The Indirect Costs cover engineering and owner's costs ($11.5 million) and contingencies ($17 million).
The estimate for the non-radioactive work is substantially higher than that generally associated with decommissioning
. non-radioactive structures.
In the PNL Study, which is the most detailed estimate of decommissioning costs yet done for a pressurized water reactor, non-radioactive facility dem-olition is estimated at about S7 million and represents ap-l proximately 19% of the total cost.
Other studies generally t.
indicate that facility demolition costs do not exceed about 25% of the total decommissioning cost.
In the GPU Study, the non-radioactive dismantling is estimated at $50 million which represents about 50% of the total cost (exclusive of contingencies) and is much greater than the usual allocation for facility demolition.
The high estimate for dismantling of non-radioactive structures at TMI Unit 1 may be due to plant or site features unique to TMI.
Information presented by Mr. Hubbard does not permit verification of this possi-bility, however.
25.
With regard to the PG&E Study as discussed at pages 17-19 of the Hubbard Report, Mr. Hubbard states that i
PG&E had reviewed several decommissioning estimates, four of which are listed by Mr. Hubbard.
Mr. Hubbard adds that the results of these four estimates, when adjusted to 1978 dollars and scaled to a 1050 MW(e) pressurized water re-actor, range from $39 million to $100 million for the cost of immediate dismantlement.
Because Mr. Hubbard does not provide further information respecting the four estimates, there is no basis for a detailed examination or comparison of such estimates to PVNGS.
26.
The Hubbard Report at page 20 also refers to a decommissioning study by Northeast Utilities which con-sidered local property tax costs which would be incurred during the period from the end of the facility's operating life to the return of the site to its original state.
Mr.
Hubbard indicates that estimated property tax costs for 50
o
~
i years in 1978 dollars ranged from $24.8 million for the par-tial dismantlement and delayed removal of Millstone Unit 1 to a high of $264 million for the mothballing and delayed removal of Millstone Unit 3.
Neither of these figures has any application to the decommissioning cost estimate for PVNGS because the method of decommissioning assumed for immediate dismantlement and not mothballing with PVNGS was delayed removal.
With immediate dismantlement, the facilty is dismantled at the end of its operating life resulting in unrestricted access to the site.
N f-f' / /fd, t t.
Albert A. Weinstein Subscribed and sworn to before me this M.P day of._\\Ad)(/A N Y
, 1982.
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' Notary Public My commission expires:
piy Committica Exp?res Jan. 23, las i _
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ATTACHMENT AAW-1 RESUME ALBERT A.
WEINSTEIN Mr. Weinstein is Manager of Engineering at the S.M.
Stoller Corporation ("SMSC") responsible for the areas of reactor servicing and operations, mechanical systems design, and real-time system applications.
As Manager of Engineering he provides. consulting services to nuclear utilities on refueling systems analysis, plant operational and maintenance support, design review and quality assurance, and plant arrangement and system design.
In this context, he is responsible for safety analysis and licensing support in special areas, such as cask drop, and fuel handling accidents, and leads SMSC efforts.in support of facilities design review, including fuel storage pool arrangements and fuel inspection and reconstitution facili-ties.
Mr. Weinstein also leads activities at SMSC re-lated to nuclear power plant decommissioning.
He served on the AIF task force assigned to monitor and review the prep-aration of AIF/NESP-009SR, "An Engineering Evaluation of Nuclear Power Reactor Decommissioning Alternatives".
He has reviewed LWR plant designs for ease of decommissioning, and has participated in the actual decommissioning of the BONUS nuclear plant in Puerto Rico, where he served as the resi-dent engineer, responsible for program definition, planning and scheduling.
Mr. Weinstein has directed the preparation of decommissioning cost estimates for both PWR and BWR nuclear power plants.
He is presently also Project Manager for the D.C.
Cook NPP combined RE&M/ Security System and as such, is re-sponsible for system development and installation, client and subcontractor interface and other project related activ-ities.
Mr. Weinstein has been extensively involved in the
- design and application of the RE&M System since its begin-nings and continues in this capacity.
He is also responsible for service administration after installations are complete.
Mr. Weinstein entered the nuclear business in 1957 at Combustion Engineering Company, where he participated in the mechanical design and analysis of the SIC reactor core
. ith responsibility for startup and testing procedures re-w
e e
lating to mechanical safety of the core.
He assisted in subsequent reactor disassembly and inspection of radioactive core components.
In 1960 he joined the United Nuclear Cor-poration ("UNC"),
and, in 1967, Mr. Weinstein was named d
Manager of the Engineering Section of the Mechanical Design Department.
Mr. Weinstein has directed the design of fuel inspection equipment and supervised the on-site inspection of commercial irradiated fuel, utilizing underwater video equipment and measuring devices.
While at UNC Mr. Weinstein served on the Technical Support Team under contract to the AEC to provide technical assistance for the Elk River, BONUS, and Lacrosse nuclear reactor plants.
He was assigned.
lead responsibility for the technical support for the BONUS nuclear reactor in Puerto Rico.
Mr. Weinstein received a B.S.
in Civil Engineering from the University of Southern California in 1954, and an M.S. in Applied Mechanics from the University of Connecticut in 1969.
He has performed additional graduate work in Engi-neering Mechanics and is a Licensed Professional Engineer in the State of Connecticut.
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