ML20040E358
| ML20040E358 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/03/1979 |
| From: | S.M. STOLLER CORP. (SUBS. OF ARTHUR D. LITTLE, INC.) |
| To: | |
| Shared Package | |
| ML20040E356 | List: |
| References | |
| NUDOCS 8202040224 | |
| Download: ML20040E358 (52) | |
Text
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'i o, . , '. . NUCLEAR SERVICES LIBrtARY 1
cc 1 HE S. M. STO LLER CORPORAL ION A Subsidiary of Arthur D.Uttle,Inc. 1250 Broadway, New York, N.Y.10001 (212) 868-2800 i
UPDATE OF ESTIMATED COSTS FOR DEC0!1MISSIONING OilE OF THE PALO VERDE NUCLEAR GENERATING STATION 1
(PVilGS) UtlITS
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. Prepared for Arizona Nuclear Power Project by The S.M. Stoller Corporation October 3, 1979 This document is produced by The S. M. Stoller Corporation (SMSC) for Arizona Iluclear Power Project (AflPP). This report is based on studies by The S.M. Stoller Corporation, and it reflects the conclusions reached on the besis of these studies. Although SMSC has exercised due diligence in this work, it makes no representation as to the completeness and accuracy V of the information presented.
8202040224 820129 PDR ADOCK 05000528 G PDR Western office: suite 815. Colorado euilding. Boutder Corcrado (303) 449-mo
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%l I. Introduction A. General To date, decommissioning has been performed on 14 reactors with ratings .
greater than 10 megawatts thermal . Of these 14 plants,10 were power production units while 4 were principally test facilities. Table A sumarizes the decom-issioning experience at these units. About 50 res'earch reactors have also been I
decomissioned, typically by dismantlement.
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From Table A it can be ~seen that the amount of work done at each unit varied considerably. Presently two basic options for decomissioning exist. A l unit may either be immediately dismantled or it may be placed in some form of safe storage (custodial, passive, or hardened modes) and dismantled at some later date.* Thirteen of the fourteen units listed in Table A have opted for some form of safe storage. ' Only Elk River has performed imediate dismantlement.
At the time a unit is constructed, it is generally not possible to de-termine which approach to decomissioning would be chosen at the end of the unit's b' . life, The decision at the time of decommissioning will depend upon current eco- -
nomics, current regulation, the nature of the then current operations at the site, and intended future use of the site.
Expanding for a moment on that latter thought, there are several points ,
to be made. First, nuclear plants are not expected to suffer from conventional economic obsolescence. The heart of the system, in the context of where future
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technical development may occur, is in the reactor core, and core and fuel design changes can be accomodated (retrofitted) within the existing Palo Verde units as developments occur; i.e., current programs to enhance uranium utilization efficiency. Relatedly, we have no evidence to date which suggests what the limit l
on physical lifetime is. The oldest commercial plants in the U.S., San Onofre and Connecticut Yankee, are almost 12 years old, and their good performance over the last several years suggests no physical degradation due to " aging." The first point, therefore, is that there is no current basis to anticipate that the service life of such plants will be limited to their accounting lifetime.
. *(Detailed descriptions of these decommissioning modes are presented in fiUREG/CR-0130,6/78), referred to here as the P!1L report. as it was performed by Battelle Pacific florthwest Labs.
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TA$ LEA -
s Date .
Pl a n_t Type Power Decouaissioning Ccmpleted Cost llallam Sodium Graphite 75MW(e) Removed all fuel and sodium. Removed sane piping 1969 $4,207,06u and some components. Encased reactor in isolation ,
s truc ture. '
CVTR lleavy Water - 65MW(t) Removed fuel add heavy water. Decontaminated some 1968 $ 250,000 Pressure Tube areas. Scaled'up reactor area.
CONUS Coiling Water - 50MW(t) Removed fuel. ' Decontaminated plant. Removed some 1971 $1,613,000 componen ts. Encased reactor in isolation s truc ture.
Pa thfinder Boiling Water - 53.5 Removed fuel. Decontaminated plant. Removed some 1969 $3,700,000 Integral Superheat NH(e) piping and components. Scaled reactor in place.
,Re-used turbine with fossil boilers.
Elk River Boiling Water 22.5- Dismantled to below grade. All radioactive 1974 $6,075,000 TAl(e) compnnents shipped to burial site.
Piqua Organic Cooled 11.4 Removed fuel. Removed all piping external to 1967 $2,000,000
+ moderated HW(e) biological shield. Ship components off site.
Encased reactor in isolation structure.
Sanon Pressurized Water 23.5 Safe Storage (mothballed). Ror.oved fuel . 1973 $2,500,000 (test facility), HU( t) Helded security enclosure.
SEf0R Sodium Cooled 20 Safe Storage (mothbal_ led). Removed fuel. 1973 Unknown Fast reactor MW(t) Welded security enclosure.
(test facility) fermi 1 Sodium Cooled 200 Safe Storage (mothballed). Locked doors 1975 S6,950,000 fast reactor liU( t) and security fence.
OE EVESR Boiling Uater 17 Safe Storage (mothballed). Continuous --
Unkna.n (test facility) NN(t) security force and locked doors.
Peach Gar Cooled 115 Safe Storage (mothballed). Removed fuel. --
linkunun tuttom 1 Graphite I;oderated Inl(t) Continuous security force e
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P.lant Type Power Decomnissioning Comple ted Cost-3/lf,!R Coiling Hater 50 Safe storage with steam plant conversion. --
Unknown Coritinuous security force with locked doors.
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!!estinghouse Tank Reactor 60 Safe storage (mothballed). Continuous '
Unknoud lest Reactor (test facility) N'.l( t) security force with locked doors.
SRE Graphite moderated 30 Safe storage (mothballed) in 1967.
Unknown Sodium Cooled inl(t) Dismantling started in 1974. ,
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N The second, and more important point as regards cost of decommissioning, is that it would clearly be logical to defer dismantling of Unit 1, for ex-ample, until all of the units at the site had finished their useful operating li fe. At that time, one would develop a coherent plan for a total site de-commissioning program, and mobilize the necessary resources in the same way as planning for the multiple plant construction program. There is no question that that procedure would bring substantial savings in the total decomission-ing cost as compared to estimates for a single unit dismantlement.
A clear incentive for deferring dismantlement is that personnel and public exposures are reduced (NUREG/CR-130 estimates that total radiation dose is reduced 40% for a ten-year delay and 60% for a 30-year delay). The conse-quently reduced inventories of radioactive materials after allowing time for decay,will result in simplified disassembly of equipment and reduced waste disposal costs. To some extent, these savings are offset by factors such as restrictions on site usage, front-end costs to achieve safe storage, and annual g surveillance costs, but most studies, on balance, indicate that deferred dis- ,
mantlement results in lower costs a'nd lower exposures. For example, the Comp-troller General Report
- estimates that safe storage with delayed dismantlement can save from $3 million to $10 million over immediate dismantlement, exclusive of time-value-of-money considerations. The latter can make deferral much more attractive.
As conservative approach, this analysis considers only immediate dismantlement. This approach should always be the more expensive option as compared with safe storage and the discounted expenses of deferred dismantle-ment, and as well, does not consider the savings inherent in a planned multiple decommissioning as alluded to earlier.
B. Basic Cost Data The earlier analyses of decomissioning costs made by SMSC for ANPP
- Report to Congress, GA1.13: EMD-77-46, using information from the AIF Study-AIF/MESP-009.
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(1975) were developed from basic cost data derived from decommissioning of the Elk River reactor and from the BONUS reactor. Since 1975, many important studies have been done on decomissioning which has received increasing public and regulatory attention in the intervening years. As an illustration of this level of interest, FY1980 budget of DOE allows $33 million for D&D (decommiss-ioning and disposal) studies; this is also a reflection of the many (approxim-ately 500) government-owned facilities involving radioactivity which exist and which shall need decommissioning.
Thus, in this report we have had available the results of these many studies. The key source of cost data used herein is the Battelle Pacific North-west Labs (PNL) report (NUREG/CR-0130), a comprehensive cost estimate for de-comissioning a large commercial PWR, specifically taken to be the Trojan Reactor for PG&E. Where PNL cost estimates appear to be more valid than orig-inal Elk River - derived experience, those former estimates have been used herein.
Elk River is the only cor=ercial nuclear plant thus far to have been
(.i completely dismantled and therefore remains an important basis for cost estima- -
ting. The Elk River reactor was a boiling water reactor with a net electrical rating of about 22fG. It was completely dismantled in the period of 1971 through 1974. The total cost of dismantling was about $6 million with approx-imately $2 million dollars spent in each .of the three years; 1972, 1973, and 1974. On the average then, Elk River dismantling costs were in 1973 dollars.
Data is available for Elk River giving the costs of each task in the dismantling operation. Within each task, costs are broken down into labor, equipment, over-heads, etc. General overheads, such as planning, supervision, and radiation monitoring are lumped together and distributed among the tasks. As a result of this, the overhead costs for each task contains a portion of the general overheads.
In areas where a particular operation was not performed at Elk River, cost data is available from the deccmissioning of the BONUS reactor. B0!iUS was a 50 iM(t) boiling water reactor with integral superheat. Decommissioning was by entombment (hardened safe storage). Costs by tasks are available for g
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80flVS as they are for Elk River. Most of the B0tlUS work was done in Pue'rto -
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Rico in 1969, and it was therefore necessary to adjust these costs -to 19/3
(' 4 U.S. averages.
s Albeit data derived from real experience is very useful,- it is' recog-
- nized that b'oth. Elk River and B0ll S were much smaller than the PVitGS . units, so simple extrapolation of the costs incurred at these smaller units may in-troduce errors.
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s 's Also, the_ experiences at Elk River and Bonus were prototype decomm- g l issioning operations, and certain costs, i.e. , planning, engineering, super .g j vision, and tooling develooment are likely higher than they will be for rou . ,
tine future decommissionings. It is, in fact, likely such as for the PVNGS ~ 3 \
units, which will be decomissioned after much experience in these types of [~ 4 operations has been accrued and the methods are more routine. %
Therefore, we believe it is important to relate such cost extrapola- ,
tions from experience to more recent studies which examined costs explicitly. f The Pill study,done under contract to f1RC, provides an in-depth analysis of the b costs for each of the basic decommissioning tasks based upon detailed cost
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schedules for manpower, equipment, special services, removal, transportation, and waste burial requirements. As an example, demolition costs were estab- ~
lished by having a demolition contracting firm estimate the job. ,s ,
As it turns out, most of the PNL. estimates _for the individual decom- .
missioning tasks closely agree with those estimated by SMSC in 1975 by extrap-olation. This is not unexpected since, generally, the assumptions on decommiss- "
ioning technology are the same (i.e., remote cutting of the reactor vessel 1 s 4 internals was assumed), even though a different methodology was used in deriv-ing the cost. In some instances, PitL costs were lower than SitSC's original estimate due to economics of scale achievable in the larger plant.
. Thus, this analysis draws heavily from the Ptil work, making reasonable adjustments for design differences between PVilGS and Trojan. We estimate that I
costs for immediate dismantlement of a PVI!GS unit are 556.7 million in 1979 ,
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_, , N. i N Y p \ 'doilers, aNalae which includes substantial contingency allowances as discussed a( ', tsi klaterinthisrecort We believe the "real world" costs, wherein. dismantlement would'ah:ost cerk:afnly be deferred until ultimate disposition of tne site were t 3 known! would be expected to be substantially less'on a per unit basis.
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4 ' II. Cost EYtimate for Innediate Dismantlement '
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s a j This section details the esticated cost of dismantlkng one PVNGS unit.
, Since only peripheral itss ,
are shared among units, demolition of a single unit
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n g i could'be essenti Ally independent of othe? units on site. The folicwing ground
'D rules cere used it making the esti)nate:
e Plant data [was ,
taken primarily from CESSAR, from the PVNGS PSAR
, and from ddta prov,ided by ANPP. In a few caces wheie sufficiently detailshdata Nailnot ~
readi'ly available, an estimate was made based on data from similar units. ,'s '
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orgn data from the Ptil study. Wherq tI.ese numbers resulted in .
, 5 s. , different costs for a task, the more re.. al is' tite value was used.
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.,,; appropriate. Most dismantling operations such as cutting a pipe,
' removing concrete, or shipping drummed waste are repetitive in
~~F nature such that the' unit costs would be independent of the number
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, o Costs were estimated from the PflLytudy by using the methodology 5 s ,
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- 3 t_' of that report and the plant data for the PVaGS units. n - '
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, w The dismantling operaticn was divided into si;f easid , tasks.These tasks gene /aMy_ conform to the task definitic'ns 'forJQ'O River '
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Y study. The tasks were as follows:
., 1. ' Site and Facility; Preparation -- This task consists of opening I access hatches in buildings, bringing in temporary power, licens-in'g.and nuclear insurance requirements, and environmental sur-veil. lance.
f , - -2. - Rehocal;of spent fuel
- 3. Decontamination of piping and equipment -- It was assumed that all nuclear plant systems would be decontaminated, cut up, and shipped to an approved burial ground. This task includes the decontamination of the n'uclear plant systems.
- 4. Removal of nuclear and containment systems components -- This task consists of the cutting up and removal of the reactor
.' vessel and internals, nuclear system piping and equipment, and
- - the biological shield.
- 5. Shipment and burial of radioactive wastes -- This task consists
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of preparation, T.hipment, and burial of all the wastes generated in Task 4.
f 6. Demolition -- Upon completion of Tasks 1 through 5, all remaining structures and equipment would be non-radioactive. Remaining equipment would consist of p'Iping and mechanical equipment in the turbine building and control building, as well as electrical cables and equipment throughout the unit. All structures would remain and would require demolition. These structures would be mostly reinforced concrete, with some structural steel (primarily the turbine building super-structure).
B. Inventory of Comconents in a pVriCS Unit For purposes of this estinate, it was assumed that the following com-ponents would be contaminated to the extent that it would be necessary to bury them at an approved site:
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. . _ . - . _ _ _ _ _ _ _ _ _ _ _ ... _ 1 1 .. _ _1 J e All mechanical equipment in the nuclear portion of the unit (i.e.,
the containment, auxiliary building, radwaste building, and fuel storage building) e The biological shield The actual quantities of material to be buried would be somewhat less than the preceding for the following reasons:
e Much of the mechanical equipment in the nuclear unit, such as ser-vice and instrument air, fresh water, and auxiliary cooling systems, never carry radioactive fluids and should not be contaminated.
e Much of the biological shield would not be activated above allowable concentrations.
Table B provides an inventory of the mechanical equipment and biologi-cal shield in the nuclear unit. For each item the weight and/or volume of the
- p. Item is given. ,
It is assumed that after the radioactive components have been removed from the unit, the remainder of the unit could be removed conventionally. This would include the power conversion building and the control building, all elec-trical equipment, and the portions of the, nuclear structures remaining after the radioactive components have been removed. The reinforced concrete structures would presumably be demolished and used for land fill.
C. Cost Estimate for Each of Six Dismantlement Tasks
- 1. Site and Facility Precaration It is assumed that adequate security, office, shop. contamination control, water supply systems, fire protection system, and laundry facilities will be present at the site. Preparation for dismantling would consist of pro-viding:
e Electrical service e Access hatches for equipment removal e Licensing activities
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gj TABLE B Inventory of potentially radioactive ccaponents in containment, auxiliary building, raduaste building, and fuel building of a PViiGS unit.
VESSEL AfiD INTERIMLS flo.
- flame Weight each (tons) 1 Reactor vessel and head 510
. 1 Vessel internals 239.5 ,
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- 0THER f4AJOR E0VIPi4EilT 3 tio. flame Weight (tons) Volume (Ft )
2 Steam generators 714.5 17,000
. 1 Pressurizer '
115 ' 2,000
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4 Reactor coolant pumps 55 740 2 Shutdown cooling heat exchangers 10 200
, 2 Spent fuel heat exchangers ,,
4 100 1 Regenerative heat exchanger 2.5 -50 '
i 1 Letdown heat exchanger 2 50 2 Essential ccoling water heat ' *'
18 300 exchangers 2
fluclear cooling water heat exchangers 13 200 l Liquid waste evaporator 10 3,000 1 Boric acid conecntrator 10 3,003 1 Gas stripper 4 10]
TOTAL OTHER AJ03 EQUIP.'1Ei;T 1037 46.760
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.' page 2 TABLE B (continued)
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LARGE TA.'lXS -
f:o. flame Weicht (tons) 1 Refueling water , 36
. 1 Makeup -
33 m
i Holdup 50 TOTAL 119 SPEr!T FUEL RACKS AfID TOOLS At!D POOL lit!ERS i llo . ?!ame 3 Weicht (tons) Volu- e (Ft )
Racks 60 24,000 Tools 10 200 Pool Liners 90 *
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l PU."PS ilo . t: ace 7
Weicht (tons) Volume (Ft )
41 Small pumpt .
, ,,. .15 - 2 15 Large pumps 1 8 f
2 Ccapressors 1 8 TOTAL 23 213 FILTER & demit:EP.ALIZER VESSELS tto . ilame _
Heicht (tens) Volume (Ft )
11 Fil ter: .1 1 8 Danineralizers .8 30 g TOTiL 7.5 251
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Page 3 TABLE B (continued)
O TAMx5-tio. flame Weicht (tons) Volume (Ft i 1 Equipment drain 12 1,300
. 4 Accumulators -
63 2,400 1 Spray 12 1,100 3 LRS holdup 5 2,600 2 Spent resin 2 300 1 Reactor drain 3 2 400 1 Chemical drain 1 200 1 Gas surge 8 750 3 Gas decay 8 750 1 Volume control 1.5 400 ,
i 2 LRS recycle 5 2,600 2 LRS concentrate . 3 850 2 Refueling shutdown ,, 6 2,300 _ . _
2 ECUS surge 1 250 1 ECUS surge 1
250 TOTAL TANKS 384 36,650 Pl?II:3
!!o. flame Heinht (tons) Volo.me (Ft )
Reacter ccolant syste.n 143 1,763 All other piping 740 22,230 BIOLCa*C?,L SH!ELC 25' 10 37' CD 43' H IC.*0 cr.d of c ca a
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Total RCS Volum? 13,443 ft3 (381m3 )
Total fluclear Systems Volume 107,875 ft3 (3055m3 ) .
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- h e Insurance o Environmental surveillance
- a. Electrical Service During the dismantling operations certain of the unit support systems will be required to remain operational. At Elk River, temporary elec-trical service was installed for $7,500 to facilitate continued use of these systems. Costs of the electricity used during dismantling of Elk River was not aggregated separately, but was included in the total cost for the various operations. PNL, however, conservatively estimated that these requirements would incur costs of about $3.5 million. Trojan and PVNGS should have very similar electrical requirements during dismantling operations and costs of
$3.85 million were assumed for the purposes of this study.
- b. Access Hatches and Ecutoment Removal Removal of piping, equipment, and concrete from the contain-g~ ment, auxiliary building, and fuel building may require a number of access openings through floors. The PNL analysis assumes that existing accesses are sufficient for the dismantling of equipment in these buildings. At Elk River, however, one floor opening and one opening in the containment wall were required. Though it appears that equipment hatches will te adequate for re-moving equipment from the containment, it was conservatively estimated that one hatch would be required in the containment floor and one in the fuel building floor. In addition, several hatches may be required in the auxiliary building floors and roof.
At Elk River the two hatches were each aboet 12' x 15' and cost approximately $10,000 each. It is assumed that a PVNGS unit will require seven hatches which are about. 20' x 15' on the average. Using the Elk River costs and escalating to 1979 dollars, the estimated cost is about $200,000.
- c. Licensino Activities It is probable that there will be a number of licensing actions required by the decomissioning effort. Althouch it is not clear what these Q/
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i (; requirements will be in about 40 years, actions toterminate the operating
! license and apply for a possession only license will probably be needed.
Preparation of an environmental impact assessment and a detailed decomiss-ioning plan are,also likely.
For the purposes of this study it is estimated that these ,
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licensing activities will cost about $1.0 million.
- d. Insurance l
i Based upon PNL estimates these costs during the immediate dismantling operations would be about $0.9 million.
- e. Environmental Surveillance
, PNL study develops an environmental surveillance program lasting four years after reactor shutdown (the duration of the dismantle-
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i mentprogram). For PVNGS, this would cost about $170,000.
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, ( The total cost of these site and facility preparations are ex- -
pected to be about $6.1 million.
- 2. Removal of Soent Fuel <
During unit operation approximately one-third of a core is re-moved each year. Filter and demineralizer resins are also changed about l once a year. At the time of decommissioning, removal of all r? sins and fil-
[ teris and removal of one-third of the core can properly be regaroed as operat-ing 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 dismantling. Two-thirds of a I
core contain approximately 68.5 metric tons of uranium. Shipping costs in 1975 were about $13,000 per metric ton of uranium in spent fuel for a 1,000 mile shipment. Using this data, the current cost for transporting two-l thirds of a core would be about $1.2 million. This number compares closely with the estimate based on numbers from the PNL study.
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(,j 3. Decontamination of Pioing and Eouioment PNL performed a detailed analysis of decontamination and assumed use of a relatively expensive decontaminant: EDTA /0xalic/ Citric Acid in a 1:1:1 mixture by weight and in a solution of 5% by weight. Because the piping and equipment will no longer be used to support the operation of the nuclear unit, a harsher and cheaper acid wash could be chosen, although we have used the PNL costs. We have assumed use of a volume of solution equal to the entire nuclear system of a PVNGS unit (including support systems, tanks, the spent fuel pool, and the secondary side of the steam generators), to derive the total cost of
- the PNL chemicals of $1.3 million. PNL also assumes that additional costs (adjusted for escalation) of $70,456 and $115,500 are incurred for staff labor costs and power requirements to circulate the solution and rinses. The cost of decontaminating the nuclear systems at a PVNGS unit is therefore estimated t
at $1.5 million.
- 4. Removal of Nuclear and Containment System Comoonents In the 1975 SMSC analysis performed for ANPP, the cost of dismantling the biological shield and the reactor coolant system, including the reactor
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vessel and internals and other contaminated piping and components, was estimated by extrapolating data from the Elk River decomissioning, recognizing that such extrapolation may result in unrealistically large costs for these tasks. The Elk River decommissioning, because of its' nature, incurred large tool develop-ment and engineering and supervision costs, these two tasks representing more than 87% of the total costs for removing the Elk River reactor vessel and in-ternals.
The actual expenses at a PVNGS unit should be much smaller for l these two parts of the dismantling jot,, and in addition, extrapolation of Elk
) River data for removal of contaminated equipment does not take credit for any economies of scale.
We now have available what we believe to be a more realistic estimate of the cost of these decommissioning tasks. In the PNL analysis a detailed schedule for all job tasks was developed and listings of manpower requirements (v -
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b for the individual jobs and salary data was then used to derive total manpower costs. In addition, a complete listing of costs for specialty contractors and for special equipment and miscellaneous supplies was developed. i The total costs for these manpower requirements, equipment and supplies derived by PHL and escalated to 1979 dollars is $12.9 million. Two
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major contingencies have been allowed for in the total estimated cost of $19.4 million for dismantling contaminated structures and equipment for the PVNGS units. PNL assumas that the biological shield will be dismantled by use of '
explosives. Because this concrete structure will be somewhat contaminated, we have assumed use of explosives may not be acceptable. Also, PNL has assumed a'n optimum that there is good utilization of decomissioning personnel, with people hired and fired as they are needed. While this is probably reasonable if the job is well planned, we have elected to increase the PNL estimates. i
- 5. Shipment and Burial of Radioactive llaste i
Based on the Elk River experience and the data from the PNL analy-y sis, the following assumptions were made concerning radioactive waste shipments -
and burial:
e Highly activated components like the reactor vessel and internals will be cut up and shipped in shielded casks.
.. i e Contaminated materials like the reactor coolant pumps will be '
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cut up'as necessary and shipped in unshielded, disposable con-tainers or will be capped and sealed with welded closure plates and shipped as their own containers, i
It is assumed that the shipping distance to radioactive waste sites is 1000 miles. Transportation costs were calculated based on weight of the radioactive waste shipments, while burial costs were determined by rates per 1 volume of waste.
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k (a) Activated Materials (1) Reactor Pressure Vessel-The cost for shipping and burying the Elk River reactor vessel was about $1,263/ ton. The reactor vessel of a PVNGS unit weighs about 510 tons. Escalating these numbers to 1979, the cost of shipping and burying a PVNGS unit reactor vessel will be about $!.0 million. This agrees quite closely with the PNL estimate of $1.3 million (1979 dollars and scaled for the difference in weight of the PVNGS and the Trojan reactor vessels). The larger
- $1.3 million estimate will be used.
(2) Reactor Vessel Internals The estimated costs for shipping and burying the reactor vessel internals from a PVNGS unit differ between extrapolated Elk River ex -
perience and when the PNL analysis is'used. Both analyses agree that the in-ternals will be more expensive to dispose of than the reactor vessel. The
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reactor interna 1's'ha've a' higher surface to vo1Ume ratio than does the reactor vessel and therefore will have more surface contamination. The internals U will also have higher levels of radioactivity from activation products. PNL
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estimates that the internals will be 250 times more radioactive than the reac-
- tor vessel. This problem together with the odd shapes of the internals will result in less of the internals transported per shipment and higher costs for the shipment and burial. At Elk River, disposal of the internals was about 10.6 times as expensive per unit of weight than disposal of the reactor vessel.
PNL estimates this factor at about 3.0. This study assumes the more costly Elk River experience, yielding a total estimated cost of $5.1 million for transporting and burying the reactor vessel internals.
(3) Biolonical Shield It is conservatively assumed that the entire 28,000 ft 3 of biological shield must be buried. Shipping and burial costs for a PVNGS unit's biological shield, using the PNL cost basis, is about $300,000.
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(b) Contaminated Materials Nearly all piping and equipment in the containment building, the auxiliary building, and the fuel building are considered to be contamin-ated during the operational life of the unit. It is assumed that these materials must be interred at a low level waste burial site.
~
PNL performed a detailed analysis of the cost of removal and burial of those materials. Based on the PNL methodology and using weights and volumes of equipment at the PVNGS unit as listed in Table B, a total cost of
$2.4 million was obtained. In addition to the equipment listed in Table B, this cost includes the transportation and burial of the turbine-generator, concrete from the pressurizer and steam generator enclosures, the missile shield, and the base slab.
(c) Other Radioactive Wastes
- (1) Solid Wastes ,
(. Solid wastes are assumed to be generated during decomm- .
issioning in the form of spent resins, spent filter cartridges, and miscell-aneous materials like rags and plastic sheeting. It is estimated, based on the PNL study, that these wastes will require about 1,412 disposable containers, j 86 shipments by truck, and a total burial volume of 12,440 cubic feet. The resultant cost for transportation and burial of these solid wastes is estimated at about $0.4 million, t
(2) Linuid Wastes Liquid wastes will be evaporated, and the concentrate will be solidified and shipped for burial. The total liquid holding capacity of all nuclear systems in a PVNGS unit is about 80% cf the total volume of these systems or about 86,300 cubic feet (the other 20% is metal). Completely full, these systems could contain about 690,000 gallons of water.
At the conclusion of unit operation, these systems are assumed to be about half full. It is assumed that each system is then flushed three times for decontamination, and each flush uses 1.25 times the system
%+'
(/
volume. The total waste water inventory to be processed is therefore about 4.25 times the volume of the nuclear systems, or about 2.933 million gallons.
Additionally, one would expect that about 1 million gallons of contaminated water is in the holdup and refueling tanks and in the spent fuel pool. Using the PNL assumption that this liquid waste can be concentrated by a factor of 100, a total of about 150 cubic meters of solid waste is ultimately generated.
In addition to the liquid wastes from residual system fluids and from flushing, one reactor coolant system volume (381 cubic meters) of liquid waste is assumed to be generated by the decontamination operations.
These wastes are then concentrated to about 58 cubic meters.
A total of about 208 cubic meters of solidified liquid wastes is therefore generated. Using PNL numbers, a conservative estimate of the cost of transportation and disposal of these wastes is $0.6 million.
- 6. Demolition
(j PNL performed a detailed analysis of demolition costs of the non- .
radioactive reinforced concrete structures by engaging a wrecking contractor to develop a typical bid for such a job. The contractor's estimate takes into account economies of scale associated with tearing down and removing these large structures and salvage profits from.the retrieval of some materials (only structural materials are assumed to have scrap value - no salvage of equipment is considered).
The projected cost for demolition and removal of all structures on the Trojan site was $7 million. This estimate included the demolition of the large hyberbolic natural draft cooling tower at Trojan. The wrecking contractor estimated this part of the demolition job at $2.7 million. The PVNGS units, however, will utilize much smaller mechanical draft cooling towers which accord-ing to the estimates made by extrapolating the Elk River numbers should cost less than $1 million to remove. Adjusting the PNL estimate for demolition of l the non-radioactive structures results in a total cost of $5.1 million.
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- 1. Concrete Floors Concrete floors in the containment, auxiliary building, rad-waste building, and the fuel building will probably contain small amounts of contamination from spills which have penetrated a small distance into the concrete. -
The quantities of activity would be very small, but the limits on amounts of radioactivity, below which material may be considered non-radioactive, are so low that removal of floor concrete as radioactive wastes has herein been considered.
The area of concrete floor in the nuclear portion of the plant consists of about 105,0002 ft in the auxiliary building, 49,000 ft2 in the containment, 19,2002ft in the fuel building, and 38,000 ft2 in the :idwaste building. If it is assumed that this floor is contaminated to a depth of three inches, which we believe to be very pessimistic, 53,000 ft3 of concrete
, .: would have to be removed.
v , .< ,
At Elk River, removal of 840 cubic yards of concrete from the biological shield and concrete flooring cost approximately $1 million. Taking a cost of about $490 per cubic yard as the appropriate value for floor removal, which may well be high, and correcting for escalation, the cost of removing contaminated concrete floor surfaces from various nuclear unit buildings at PVriGS would be $1.5 million. The cost of transporting and burying this con-crete based on PNL numbers is $0.5 million. The total cost for removal, trans-portation, and burial of contaminated concrete floor surface is therefore about
$2 million.
- 2. Decontamination of the Secondary Plant Some portions of the secondary plant might require decontamination in order to meet the stringent limits necessary to be treated as non-radioactive waste. It has been assumed, and this, too, we believe to be pessimistic, that one-half of the secondary plant requires decontamination. The secondary plant V
. O . .
d contains a total of about 154,000 feet of piping. Extrapolating the costs that were incurred at the BONUS decontamination, the esticate for this oper-
~~
ation is $2.6 million.
- 3. Contincency Above and beyond the specific contingency allowances noted herein, an additional overall contingency of 20% of the total cost or about $8.7 million has been added as suggested by good general engineering practice.
E. Total Cost Estimate for Immediate Dismantlement The costs of the six dismantlement tasks described in the previous section are as follows:
Task Cost ($ x 106 )
1 Site and Facility Preparation 6.0 2 Removal of Spent Fuel 1.2
\sif 3 Decentamination 1.5 -
4 Removal of Nuclear and Containment System Components 19.4 5 Shipment and Burial of Radioactive Wastes 10.2 6 Demolition '
5.1 TOTAL (excluding contihgencies) 43.4 CONTINGENCIES 13.3 TOTAL (including contingencies) 56.7 F. Cost Sensitivities Estimates for this report were_made in 1979 dollars and were based on decommissioning regulations and technology that is current in 1979. These regulations and the technologies are subject to change. Anticipating the effects of these changes on costs forty years in the future is difficult, if not impossible. However, some understanding of cost sensitivities to evolving technology and regulations may be derived fran examining percentages of total
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for additional transportation costs, it is unlikely that deep geologic burial
\ .
of the highly activated wastes would increase the total cost for immediate dis-mantling by more than 2%.
NRC and DOT are in the process of upgrading requirements for trans-portation of low-level radioactive waste. It is unlikely that these changes would impact heavily on the decommissioning cost attributable to waste trans-portation, as changes are likely to emphasize administrative rather than phys-ical changes.
Personnel costs, which are a significant component (34.1%) may be influenced by changes in occupational radiation exposure limits. NRC is in the process of tightening these limits, though drastic changes are not now contemplated,
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o' UNITED STATES OF AMERICA NUCLEAR REGULATORY CO!G1ISSION
, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
ARIZONA PUBLIC SERVICE DOCKET NOS. STN S COMPANY, et al., SO-S 9
)
S0-530
)
(Palo Verde Nuclear Gener- )
ating Station, Units 1, 2 )
and 3 )
)
)
INTERVENORS ANSWERS TO APPLICANT'S FIRST SET OF INTERROGATORIES GENERAL Answer to Interrogatory No. 1.
The parties have agreed that the Intervenor may have an additional period of time within which to respond to the Request f'or Admissions. The date for said Response will be se't by agreement of the parties.
Answer to Interrogatory No. 2.
See Answer to Interrogatory No. 1. above.
CONTENTION NO. 1.
Answer to_ Interrogatory No. 3.
The term " transfer factors" as used in Paragraph 1.a of the Explanation to Contention No. 1 means that fraction s
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the number of control rods, the greater the potential for deformation under peak-ATWS pressures (3800 psi to 4100 psi in larger reactors) during vessel-head lifting.
Answer to Interrogatory No. 41.
No. See Answer to Interrogatory No. 39 above; plus ACRS Advice and Comments Report on ATWS proposals of NUREG-0460, Vol. 4, submitted to NRC, April 16, 1980.
i CONTENTION NO. 7.
Answer to Interrogatory No. 42.
Contention No. 7 is based upon Joint Applicant's in-adequate treatment of decommissioning costs in their ER-OL.
Cost estimates provided in the ER-OL are inadequately cal-culated due to a lack of operational experience in decommissioning a plant of this size. In addition, the dismantling operations outlined in Section 5.8.1 of the ER-OL are overly simplified
- (
and lack specificity.
Answer to Interrogatory No. 43.
.Intervenor maintains that the Joint Applicants have
" inadequately figured decommissioning costs" based on their calculation of 557 million as the entire cost of decommissioning i PVNGS. See Answer to Interrogatory No. 45.
Answer to interrogatory No. 44 Yes.
i .
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Answer to Interrogatory No. 45.
NRC Reg. Guide 1.86 describes four alternatives for retirement of nuclear reactor facilities which are considered acceptable by the NRC. The Joint Applicants in Section 5.8.1 of the ER-OL discuss dismantling as the method they will use to decommission the plant. The Joint Applicants then state an estimated cost of 557 million per reactor unit. A detailed engineering cost estimate for decommissioning a commercial power reactor was presented in 1975 testimony before the Pennsylvania Public Utility Commission concerning TMI Unit 1. At that hearing, a witness on behalf of General Public Utilities Services Corp., estimated the capital costs of dismantling to be on the order of S118 million.
k A study prepared by Northeast Utilities on decommissioning f costs for the Millstone 3 Nuclear Power Plant in Connecticut es-i timated a total cost of $264 million for decommissioning.
In addition to capital costs of decommissioning, a l Pacific Gas and Electric study in 1976 estimated an additional cost of surveillance and light maintenance of between 560,000 l and $330,000 annually.
I Answer to Interrogatory No. 46.
f ,
Yes.
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6 Answer to Interrogatory No. 47.
The methodology used by the Joint Applicants in Section 5.8.1 of the ER-Ol is inadequate in its entirety.
Numerous questions remain concerning the specifics of dismantl'ing procedures.
Answer to Interrogatory No. 48.
See Answer to Interrogatory No. 45.
Answer to Interrogatory No. 49.
See Answer to Interrogatory No. 45.
Answer to Interrogatory No. 50.
Presumably the Joint Ap'plicants will recover these costs through rates.
Answer to' Interrogatory No. 51.
See Answer to Interrogatory No. 53.
2 Answer to Interrogatory No. 52.
See Answer to Interrogatory No. 53.
Answer to Interrogatory No. 53.
. It is the Intervenor's position that the utility commissions of the various states involved in PVNGS could i
conclude that the decommissioning expenses were imprudently incurred and prohibit the Joint Applicants from recovering such expenses in rates.
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Answer to Interrogatory No. 54 See Answer to Interrogatory No. 53.
Answer to Interrogatory No. 55. ,
No.
Answer to Interrogatory No. 56.
Not applicable.
l CONTENTION NO. 8.
Answer to Interrogatory No. 57.
I A concrete slump test is an indicator of water / cement i
ratio, ambient air temperature, air content, cement temperature, and consistency of cement prior to pouring.
l Answer to Interrogatory No. 58.
The information obtained from a concrete slump test Il j includes the water / cement ratio, the ambient air temperature, the cement temperature and the consistency of the cement.
I Answer to Interrogatory No. 59.
A concrete slump test measures the amount of water and air in the premixed cement.
Answer to Interrogatory No. 60.
When performing a concrete slump test, the premixed cement is poured into a 12" high by 6" wide metal cone or tube.
The cone is then removed from the cement and the slump is measured.
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Answer to Interrogatory No. 61.
If the slump is not of correct proportions, the cement will not meet its designed strength specifications.
Answer to Interrogatory No. 62.
The lab numbers, date of reports, placement numbers, ticket numbers, and any other means of identification will have to be supplied by Engineering Testing Laboratories, the Bechtel Corporation, or the Joint Applicants.
Answer to Interrogatory Nos. 63 through 65.
Object on the ground that the interrogatory calls -
for information which is irrelevant, immaterial, and not designed to lead to the discovery of admissible evidence.
Answer to Interrogatory No. 66. ,
( The concrete slump test is an important indicator -
of the strength, integrity, and job specification proportions of the concrete which will support a system essential to reactor operation.
WITNESSES Answer to Interrogatory No. 67.
Intervenor has not determined at this time who will be called as witnesses.
Answer to Interrogatory No. 68.
See Answer to Interrogatory No. 67 above.
- 20 _
_____.__i. . _ _ _ _ _ . _
e
'e Answer to Interrogatory No. 69.
See' list of documents attached.
Answer to Interrogatory No. 70.
Intervenor has not determined at this time.which I . exhibits will be used.
Answer to Interrogatory No. 71.
t l
See Answer to terrogat N . 70 above.
DATED this V!dayof u ef, f 1981.
l ,; , llj s Bruby MeyWrbd5 Arizona Center for Law l in the'Public Interest -
- 112 North Fifth Avenue
, Phoenix, Arizona 85003 (602) 252-4904 Attorney for Intervenor i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) -
ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY, et al. ) 50-529
) 50-530 Palo Verde Nuclear Generating )
Station, Units 1, 2 and 3 )
)
JOINT APPLIC NTS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO INTERVENOR Pursuant to 10 CFR 55 2.740b-2.741, and the Stipu-q lation of Parties Regarding Contentions and Discovery ("Stip-~
ulation"), dated December 12, 1980, Joint Applicants hereby propound the following Interrogatories and Requests for Pro-duction of Documents to Intervenor.
I INSTRUCTIONS
- 1. Each Interrogatory must be answered separ-ately and fully in writing under oath or affirmation by the person or persons making them no later than June 22, 1981, and each document requested must be produced no later than 30 days after service of these Interrogatories and Requests for Production.
a 0
Advisory Committee on Reactor Safeguards reportedly has ac-cepted ' Alternative 3A', with modifications, while the Com-mission minutes referenced above also have advanced the same recommendation, with other features, including limited peak pressures and improving scram systems."
CONTENTION NO. 7
- 42. Explain in detail the basis for Contention No. 7.
- 43. Explain in detail what is meant by the con-tention that Joint Applicants "have inadequately figured decommissioning costs."
( 44. Is it your position that the estimated cost s of decommissioning provided in Section 5.8 of the Palo Verde Nuclear Generating Sta'; ion Units 1, 2 and 3 Environ-mental Report - Operating License Stage is too low?
- 45. If the answer to Interrogatory 44 is yes, ex-plain in detail the basis for your answer. ,
- 46. Is it your position that the methodology used by Joint Applicants in estimating decommissioning costs for PVNGS is inadequate?
- 47. If the answer to Interrogatory 46 is yes, explain in detail what aspect or aspects of the methodology used by Joint Applicants are inadequate.
o.
0
- 48. State what you consider to be a reasonable estimate of the decommissioning costs for PVNGS. Explain in detail the basis for such estimate.
- 49. Is the answer to Interrogatory 48 based upon any type of study, calculation, or analysis? If so:
(a) Describe the nature of the study, cal-culation, or analysis and identify any documents which dis-cuss the study, calculation, or analysis.
(b) Who performed the study, calculation, or i
analysis?
(c) Describe in detail the information that was studied, calculated or analyzed.
(d) What were the results of each study,
( calculation, or analysis. _.
- 50. What is your understanding as to the source of funds to cover the costs of decommissioning of PVNGS?
- 51. Is it your position that one or more of the federal, state and local agencies which regulate the rates charged by Joint Applicants will not approve the rates nec-essary for the Joint Applicants to receive an adequate re-turn on their investment in PVNGS?
- 52. If the answer to Interrogatory 51 is yes, identify the agencies and explain in detail the basis for your answer.
a e
- 33. Is it your position that the ratemaking stat-i utes applicable to one or more of Joint Applicants prohibit ,
the recovery of decommissioning costs?
- 54. If the answer to Interrogatory 53 yes, ex-plain in detail the basis for your answer.
- 55. Is it your position that the costs of decom-missioning a nuclear power plant the size of PVNGS are un-known and incapable of determination?
- 56. If the answer to Interrogatory 55 is yes, ex-plain in detail the basis for your answer. g CONTENTION NO. 8 s s
' 57. Explain in detail your understanding of the s purpose of concrete slump tests for the concrete used in the containment base mats.
- 58. What information is obtained from a concrete >
slump test?
- 59. What measurements are made as part of a con-crete slump test?
- 60. Explain in detail your understanding of the procedure followed in the performance of a concrete slump test.
- 61. Explain in detail how, if at all, the infor-mation obtained from the concrete slump test is related to the strength or integrity of the containment base mats.
1
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- 70. Identify, with specificity, esen anh every ,
exhibit you intend to use in this matter. As to each such exhibit, state which facts, opinions, or contentions the , ,
exhibit supports, if any. ,,
- 71. With reference to the exhibits listed in the, ,
answer to Interrogatory 70, state the source and nature of
- the exhibit, i.e., whether said exhibit is documentary, a[
picture, or whatever; who prepared each exhibit; its data of preparation; and, who has custody of each exhibit. ,
b
.t III
- REQUESTS FOR PRODUCTION OF DOCUMENTS
- 1. Produce all documents identified in response to Interrogatory 69. _.
- 2. Produce all exhibits identified in response s to Interrogat.ory 70.
- 3. Produce all studies, calculati ns_or analyses
.s identified in response ;to' Interrogatories x 16, 24, 29 and 49.
- 4. Produce 'all ' documents upon which your expert
?
r, .
witnesses will rely in formulating; opinion' testimony.
RESPECTFULLY SUBMITTED this 22nd day of May,
- 1981.
. , l l ;
By M ARTHUR C. GEI V l'
CHARLES A. BISCHOFF 3100 Valley Bank Center
((/
Phoenix, Arizona 85073 Attorneys for Joint Applicants l
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.4 UNITED STATES Cr A.E ICA-l-
,- NUCLEA: EGULATOiY CC.9'ISSION EFO .E THE ATCPIC SAFETY AND LICENSING ECA'D .
In the Fatter of ) -
. ) DOCKET NOS. STN 50:528 i ,
t Ac'IZCNA PUBLIC SE'.VICE ) 50-529 50-330
[I.
COMPANY. et al.. ) ' '
) .
) s . .!- 4 (Falo Verde Nuclear Gener- ..
.c . ,W .~ -
ating Station. Units 1. 2 ) ,
And 5
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APPLICANT'S SECOND SET OF INTHiROGATQtIES J, fyt ;
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l The term capacity facto'r refers to the ratio of aversge" 2 ' -i,af,1, c )? -
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Answer to Interroratory No. 25
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- q This information is culrently unavailable and vi be; .
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The answer to No. 53 reads: It is the Intervenor's position l
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I that the utility commissions of the various, states involved in PVNGS
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L could conclude that the decommissioning egenses were imprudently i
f incurred and prohibit the Joint Applicants /
from recovern ,..>
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incurred and prohibit the Joint Applicant from recovering such expenses in rates.
Ansve- to 7.nterrogatory No. 29 Yes. e Answer to Interrocatory No. 30.
The methodology used by Joint Applicants in estimating 7- ..
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- . decommissioning is inadequate according to the following studiess., " . '/ .. .
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' .l An Analysis of.Dec-1==4onine and Ammatt. e_Shutd srn.fosts'of
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'l s Nuclear Iower. Plants. Accountants for the Public Interest. .8/1/80.. ~ /'
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, ' estimate for decommissioning costs. ,
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Answer'to Interro;ratory No. 33 #; -'.
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I The cost , estimate presented before the.Fennsylvania':Publici
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- ~" Analysis- ." . @w W;
- Utility. Commission concerning TMI Unit ~1 can be ..; found in'.t .
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. of Decommissioning and Precature Shutdown Costs of Nue1Sar Power. . .m ! -
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in " Nuclear Power Plant Decommissioning *' by Richard Hubbard of MEB 'e f *
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- Technical Associated, San Jose, CA. 8/31/79, p. 20. / ,
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Answer to Interrogatory No. 3b. .s f.
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6 UNIT 5D STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
ARIZONA PUBLIC SERVICE ) Dockets Nos. STN 50-528 COMPANY, et al. ) STN 50-529
) STN 50-530 Palo Verde Nuclear Generating )
Station, Units 1, 2 cnd 3 )
)
JOINT APPLICANTS' SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO INTERVENOR Pursuant to 10 CFR 55 2.740b-2.741, and the under-standing between Joint Applicants and Intervenor, Joint Applicants hereby propound the following Interrogatories and
( ' ,
J Requests for Production of Documents to Intervenor.
I l
INSTRUCTIONS
- 1. Each Interrogatory must be answered sepa-rately and fully in writing under oath or affirmation by the person or persons making them no later than August 20, 1981, and each document requested must be produced no later than l
l 30 days after service of these Interrogatories and Requests l for P:nduction.
- 2. All information is to be divulged which is in the possession of Intervenor, her attorney, investigators,
1 u l l
4 (c) Describe in detail the information that was studied, calculated, or analyzed.
(d) What were the results of each study, calculation, or analysis?
P CONTENTION NO. 6B AS
- 24. Define the term " capacity factor" as used in Intervenor's Answer to Interrogatory No. 40.
- 25. With reference to Intervenor's Answer to Interrogatory No. 40, describe the " evidence" of a "degrada-tion of CE capacity factors due to steam generator tube denting and leaks," and explain how such evidence contrib-u.tes to establishing that large reactors manufactured by ;
=,
Combustion Engineering will experience a greater frequency of transients that require " scram" initiation. Provide '
specific references for such evidence.
- 26. With reference to Intervenor's Answer to Interrogatory No. 4C, identify those factors which Inter-venor believes will contribute to a greater frequency of transients that require " scram" initiation or response for large reactors.
. 27. For each factor identified in the answer to Interrogatory No. 26, explain the basis for your answer.
.J -
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W b CONTENTION NO. 7 C#
- 28. With reference to Intervenor's Answer to In-terrogatory No. 53, identify each situation currently known s,
s to Intervenor in which a state regulatory commission con-cluded that the expenses associated with decommissioning a nuclear power reactor were imprudently incurred.
- 29. Is it your position that the methodology used by Joint Applicants in estimating decommissioning costs as described in the reports by S. M. Stoller Corporation en-titled " Estimated Costs for Decommissioning One of the Palo Verde Nuclear Generating Plants" and " Update of Estimated Costs for Decommissioning One of the Palo Verde Nuclear Generating Station (PVNGS) Units," dated 1975 and October 3, 1979, respectively (copies of these reports have been pro-vided to Intervenor), is inadequate?
- 30. If the answer to Interrogatory No. 29 is yes, explain in detail what aspect or aspects of the methodology used by Joint Applicants are inadequate. Explain the basis' for your answer.
- 31. State what you consider to be a reasonable estimate of the decommissioning costs for PVNGS. Explain in detail the basis for such estimate.
- 32. Is the answer to Interrogatory No. 31 based upon any type of study, calculation, or analysis? If so:
(a) Describe the nature of the study, calcu-lation, or analysis and identify any documents which discuss the study, calculation, or analysis.
(b) Who performed the study, calculation, or analysis?
, v-1 (c) Describe in detail the information that was studied, calculated or analyzed.
(d) What were the results of each study, calculation, or analysis.
33.
With reference to Intervenor's Answer to In-terrogatory No. 45, provide specific references, including page numbers as appropriate, for the cost estimate presented before the Pennsylvania Public Utility Commission concerning TMI Unit 1 and for the study prepared by Northeast Utilities on decommissioning costs for Millstone Unit 3.
34.
With reference to Intervenor's Answer to In-terrogatory No. 45, is it Intervenor's position that costs associated with " surveillance and light maintenance" will be incurred where the method of decommissioning used is imme-
'('
diate dismantlement? .
]
l
- 35. If your answer to Interrogatory No. 34 is yes, explain the basis for your answer.
CONTENTION NO. 8
- 36. With reference to Intervenor's* Answer to In-terrogatory No. 58, explain in detail how the ambient air
, temperature and the cement temperature are obtained from the slump measured in a concrete slump test.
- 37. With reference to Intervenor's Answer to In-terrogatory No. 59, explain in detail how the " amount of l
water and air in the premixed cement" are obtained from the l slump measured in a concrete slunp test.
. c. * -
2 IV y
I REQUESTS FOR PRODUCTION OF DOCUMENTS 1.
Produce all documents identified in response to Interrogatory No. 41,
- 2. Produce all exhibits identified in response to Interrogatory No. 42.
3.
Produce all studies, calculations or analyses identified in response to Interrogatory Nos. 23 and 32.
- 4. Produce all documents upon which your expert witnesses will rely in formulating opinion testimony.
- 5. The documents produced pursuant to paragraphs 1-4 above should be made available for inspection and cc?ying as follows:
l DATE: f August 20, 1981 S_ TIME: 10:00 A.M. '
LOCATION: Snell & Wilmer I 3100 Valley Bank Center Phoenix, Arizona 85073 RESPECTFULLY SUBMITTED this ((aAf day of July, 1981.
t SNELL & WILMER By J. //
ARTHUR C M EHR g -
CHARLES A. BIS @0FF 3100 Valley Bank Center Phoenix, Arizona 85073 Attorneys for Joint Applicants 7
f %
'* 41786 L
r d- ' "*" i Propose'd Rules Vol. 46. No.159 j Tuesday. August 1B 1981 1 qualifications review and findings b Tnts sectaon of the rEDERAL. REGISTER At. DRESSES: Interested persons are I, contams notices to the pubhc of the invited to submit written comments and required by 10 CFR 50.33(f) and other .
proposed issuance of rules and suggestions on the proposal and/or the sections of10 CFR Part 50 as to electric reputations. The purpose of these notaces supporting value/ impact analysis to the utility applicants for construction is to gwe interested persons an Secretary of the Commi.sion, U.S. permits and operating licenses for opportunity to part>cipate in the rute Nuclear Regulatory Commission, nuclear power plants, which are i.
m ng pnor to tne adoption of the finai. Washington. D.C. 20555 Attention: utilization facilities licensed pursuant io [
Docketing and Service Branch. Single 10 CFR 50.21[b) and 50.22, or for copies of the value/ impact analysis may production facilities licensed pursuant ,
be obtained on request from Jim C. to 10 CFR Part 50.The one possible ;,
Petersen. Office of State Programs, U.S. exception to this proposal ma3 be that NUCLEAR REGULATORY Nuclear Regulatory Commission, the Commission. in the alternative, will COMMISSION Washington. D.C. 20555 (telephone: 301- decide to retain at the operating license l 10 CFR Part 50 492-9883). Copies of the value/ impact stage that portion of the financial
. analysis and of comments received by qualifications review and findings that Financial Qualifications; Domestic the Commission may be examined in the relate to the costs for permanent Licensmg of Production and Utilization Commission's Public Document Room at shutdown and maintenance of the Facilities 1717 H Street, NW. Washington D.C. facility in a safe condition (i.e.
AGENCY: Nuclear Regulatory FOR FURTHER INFORMATION CONTACT: decommissioning costs). If the
~
Commission. Jim C. Petersen. Office of State Commission decides to retain the Programs. U.S. Nuclear Regulatory financial qualifications requirements ACTION: Proposed rule. Commission. Washington, D.C. 20555 relating to decommissioning costs, the
SUMMARY
- The Nuclear Regulatory (telephone 301-492-9883). rule will serve es an interim rule until Commission is considering amending its SUPPLEMENTARY INFORM ATION: completion of a future rulemaking on regulations conceming requirements for decommissioning that will coneider the
- 1. Background costs of decommissioning and the financial qualifications review and fmdings for electric utility applicants A. The Statute and the ProposedRule. necessary financial assurances. At that that are applying for permits or licenses Section182a of the Atcmic Energy Act time, the Commission will,if necessary, for production or utihzation facilities: of 1954, as amended. 42 U.S.C. 2232a again amend the financial qualifications (1) To eliminate entirely these . (the "Act"), provides in pertment part: regulations to make them consistent requirements for construction permit Each application for a license hereunder with the final decommissioning applicants; and either shall be in writing and shall specifically state regulations adopted. The proposed rule (2){i) To also eliminate entirely these such information as the Commission by rul' also makes certain editorial requirements for operating license Ch0 ' m difications to i 50.33(f) to improve its applicants; or
{f ,, SOY et " "" Qlc f clarity, makes conformmg changes to qualifications of the applicant, the character i 50.40(b) and { 50.57(a)(4), and (2)(ii) To reta.m these requirements for of the applicant. the citizenship of the operating license applicants to the applicant. or any other qualifications of the eliminates Appendix C to to CFR Part extent they require submission of applicant as the Commission may deem 50. In addition, a new provision information conceming the costs of appropriate for the license. . . . The discussed in III., D., below, would pe manently shutting down the facility Commission may at any time after the filing require power reactor licensees to and maintaining it in a safe condition of the ongmal appbcation. and before the maintain the maximum amount of "piration of the hcense, requireferther commercially available on-site property (i.e. decommissioning costs). # ' b th-The Commission is also considering ,[#','$,I", j,".'heth r damage instrance, or an equivalent amending its regulations to require amount of protection (e.g. letter of application shall be granted or denied or credit, bond, or self insurance), from the power reactorlicensees to maintain the whether a license should be modified or maximum amount of commercially revoked. , point in time that the Commission first available on. site property damage Permits ownership. possession and (emphasis added). In New England insurance, or an equivalent amount of Co lition on Nuclear Pollution v. NRC, 5! rage of special nuclear matenal at the protection (e.g. letter of credit, bond. or 582 F.2d 87 (1st Cir.1978), off*g sub vom. site of the nuclear reactor.
salf insurance), from the time that the Public Service Co. ofNew Hampshire The Commissicn believes that its Commission first permits ownership. (Seabrook Station. Units 1 and 2), CLI- existing fmancia! qualifications review possession, and storage of special 75 -1. 7 NRC 1 (1978), the U.S. Court of has done little to identify substantial nuclear material at tFe site of the Appeals for the First Circuit stated that health and safety concerns at nuclear nuclear reactor. the Act "gives the NRC complete power plants. flowever. there are DATES: Comment period expires October discretion to decide what fmancial matters important to safety which may 19.1981: Comments received after qualifications are appropriate." 582 F.2d be affected by financial considerations.
October 19.1981, will be considered if it at 93. Consequently, the Commission requests is practical to do so, but assurances of As will be discussed below,it is the comment regardmg the type of NRC consideration cannot be given except as NRC's present proposal,in exercising review that would focus effectively on to comments received on or bcfore this the discretion conferred by Section 182a, financial considerations that might base date. to elimmate current fmancial an adverse impact on safety.
I .
3 F;d:r;! Regist;r / Vol. 46. No.159 /. Tursday. August 18, 1981 / Proposed Rules 41787 i B. Ti)e Commission's SeabrooA study of the financial qualifications of nuclear facilities is centingent upon Decision. In Pcb//c Service Company of issue (43 FR 22373. May 25,1978). The the fmancial qualifications of the New /kmpshire, et c/. (Seabrook notice requested interested members of applicant. It stated that insufficient S:ation. Units 1 and 2). CLI-78-1. 7 NRC the public to submit comments on the financing during construction could lead 1 (1978) (hereinafter "Seabrook"1. the issue and to propose specific changes to to the use of substandard materials and Commission directed the stuff "to the rules by July 24.1978. Seven sets of to costly delays in construction. NCLC
, initiate a rulenaking proceedmg in comments were received. Six of the further suggested that NRC shuuld l
! which the factuallegal. and pohey submittals were from electric utilities. promulgate a regulation requiring that c '
aspects of the fmancial qualifications the Edison Electric Institute (EEI) and nuclear facilities constructed with a i issue may be reexamined." 7 NRC at 20. law firms representing electric utilities. reasonable cost of financing and that I
Specifically, the staff was to examine The seventh set of comments was from failing to do so may financially burden the relationship between the financial '
to l quahfications of part 50 applicants and th'e Nttional Consumer Law Center. Inc.
The fcllowmg is a summa y of the the applicant and ihe applicant's owners and customers.
hcensees and their ability to safely relevant points made in these comments.
t ccnstruct and operate production and The utilities, the eel. and the law II. Separate Treatment of utilization facilities. Further. the staff firms recommended that the regulations Decommissioning Costs 1 was to prepare a proposed rule to serve be revised to substantially reduce the 41 as the basis for mitiating the rulemaking scope of NiiC's fmancial qualifications Generic study of the costs und w described by the Commission in financial arrangements for review especial!y as it applied t decommissioning nuclear power plants.
Secorook. applicants whose rates for service are a in its Seabrook decision. the as well as for other nuclear facilities, either self determined or are determined Commission first reviewed the statutory has been and will continue to be treated by cate and/or federal regulatory as a subject area separate from the more l and regulatory basis leading up to the _ agencies. These co'r.menters generally i present fmancial qualifications routine financial qualifications issues maintained that a history of successful reqturements set forth m 10 CFR 50.33(f). plant consuuction and operation that were discussed b} the Commission
~lhe Commission cbserved that "Illhis coupled with the legal requirements in Seobrook. With regard to j history suggests that for established placed on economic regulators together rnmissi sg cous, b E i utilities with substantial operating #ecently published two documt.nts:
constitute " reasonable assurance" that i records, close scrutiny of financial adequate financing can be obtained (the , Assuring the Ava,i lability of Funds for qualifications was not viewed as presently-existing standard set forth in Decomnussiomng quclear Facmties g~
necessary to assure that financial 150.33(f)).This group of commenters (NUREG-0584. Revision 2. October 1980) cunsiderations did not compromise further argued that ** cutting-corners"in and " Draft Genenc Environmental
, i safety." /d. at u.The Commission went construction or operatinn is not in the Impact Statement on Decommissioning on to express its belief that financial self-interest of the utility, as it is d d'"# MU b E **
ns l qualifications of a regulated public imperative that a plant provide long- January %. he generic study of utility have less bearing on assurin2
' term operation reliably and safely in decommissionmg. mcludmg un safety in construction and operation accordance with NRC regulations. The applicant's financial ability to bear the
,', than for other applicants, even though commenters said that the financial costs thereof, and the publication of a
! the Commission noted,in the context of proposed rule for comment are expected savings that could be achieved through g" the present " reasonable assurance" " corner-cutting" would be smalj t be completed by March 1982.The requirement of i 50.33(f). that merely compared to the sums required to Commission's treatment of being a regulated public utility would complete the project.The risk of decommissioning and its costs as a not automatically satisfy i 50.33(f) as detection by NRC inspectors and separate matter is thus expected to lead applied to a construction permit possible resulting legal action against to a final rule on this subi ect. It is also application. The Commission stated: the utility were cited as additional expected that when the final policies While unexceptionalin the abstract, this disincentives to violation of NRC's and regulations are developed. they will propos: tion is less compelling in the case of a safety regulations. be imposed on all Part 50 licensees, regulated pul lic utility engaged in a including the electric utility applicants
- yJ I), construction project which is itself subject t One of the above commenters expressed a preference for complete and licensees affected by these hich safety standards and ongomg proposed financial qualifications elimination of the financial qualification
~
fmdings as now required by the amendments, the th absence of any dernonstrated d: rect gg runnecnon between financial qualifications regulations. That commenter maintained As stated above, the Commission is -
ond safe:3i n the utahiy-cithe generally or that a causal relationship between proposing a possible alternative to the F g g. m this case in particular-we are left with the financial qualifications anc ,afety had 3
elimination of the entire financial r mennal!> specu!.tne daans of s pauca. not been demonstrated. qualifications review presently required hl. at 1E Fmally. after characterizing the The National Consumer Law Center. by i 50.33(f) for electric utilities applymg ?
link between safety and fmancial Inc. (NCLC) commented that the existing for operating licenses for nuclear power ~
(" qualifications as " seemingly tenunus.*
the Commission emphasized direct regulation is inadequate in that it does not require the filmg of sufficient plants. This alternative would retain the present financial qualifications review
[(' approaches for assurmg safety:"[tlhe fmancial information to demonstrate and findings at the operating license
}' resulting hmited usefulness of the fmancial qualifications for a stage as to the issue of decommissioning ;
(""# S' f nancial qualifications inquiry construction permit or an operating costs. Upon completion of the separate
( sts underscores the importance of ongoing license. NCLC provided a detailed list of rulemaking on the decommissioning ms cctions of reactor construction types of fmancialinformation that issue, the Commission will re-examine protects." /d. at 19. Shou ld be required of applicants.NCLC the financial qualifications regulations C. Ecr/ict Pubhc Comments: based its suggestion for NRC requiring and will,if necessary further amend
" l'olionmc the SeabronA decision, the such information on the premise that them to conform to the final rule on NRC notified the public of its generic safe. reliable construction and operation decommissioning.
- {
1 1
7 41788 Fed:ral R: gist:r / Vol. 46 No.159 / Tuesday. August 18. 1981 / Propos:d Rul:s !
!!!. Other Basic Considerations and operating license review related to for operating power reactors to maintain A r ,.ts of the Proposed Rule financing the permanent shutdown and the maximum amount of commercially A. Electric Utihty ond Other ' maintenance of the facility in a safe available on-site property damage Applicants. With regard to the financial condition. insurance, or an equivalent amount of qualifications issues as raised in The Commission proposes to reta,m its protection.The proposed rule is Seabrook the Co.nmission continues to current review under i 50.33(f) of mtended to serve as an interim believe that technical reviews and applicants for any production or requirement until the Commission has inspection efforts are effective, direct utilization facility license, if such an opportunity to conduct a rulemaking methods of discovering deficiencies that apphcants are not electnc utilities to determme what level of protection is could affect the public health and safety. having either a regulated status or the necessary to cope with the on site While analysis of financial authority to set their own rates for radiological hazards resulting from an qualifications has bun viewed in the electric service. The 150.33(f) financial accident. While the vast majority of past as possibly an additional method of qualifications review is also unchanged licensees for operating power reactors determining an applicant's ability to as to production or utilization facilities currently maintain the maximum satisfy safety requirements. experience n t covered by i 50.21b or i 50.22.I.e. available amount of such insurance, the
~
has failed to show a clear relationship medical utilization facilities, research Commission understands that some between the NRC's review of an and development facilities, and testing utilitia do not buy the maximum applicant's financial qualifications and facilities. amount and one utility (TVA) s(f-the applicant's ability to safely construct BJMmUnformuon & Ca insums for property losses. In 5 ew of and operate a nuc' car power plant. Be Required. By this proposed rule, the the substantial ircportance to th public As discussed above, such utilities are ***
usually regulated by state and/or _
rehngm.ssion does sh its resid not intend to walve or health and safety of adequately c reqmre such additm,ual authority to up nuclear accidents, the Commission is alinfonnanon in federa'l economic regulatory agencies' proposing that such maximum : nsurance and generally recover the costs of individual cases. as may be necessary coverage be mandatory (1) for a constructing generating facilities through r the Comission to detennine construction permit holder from the w er an apphcau n s a be the ratemaking process, subject to the point in time that the Commission first e cies As a sult reasonable co ud e o e o d e r [to ge of peci l nuclear a eria at the P
necessary to meet a utility's obligations $2a of t ** *
(including NRC-imposed safety tom c Fne 8y Ac o 1954-holders of nuclear power plant operating t s ra e ' th o i r e . e g to h a a o
[d e m ndato iy clear e p., FPC v. Hope Natum/ Cas Co. 320 "" " " * * " * " " "
U.S. 591 (1944); Bluefield Water Works review of non-utility applicants for part earber construction stages. Within 90 andimprovement Co. v. Public Service pt o n to or7a e fr
- Y' * ** ** * "*
th ei
- Commission of the State of West promulgated in final form, would be H ensen wu e em nstrate to Virginia, 269 U.S. 679 (1923). These the Commission a satisfaction that they possible to require the submission of landmark court decisions established possess the maximum amount of the principle that public utility financial information from a particular electric utility applicant if special c mmercially available on-site property commissions are to establish a utility's circumstances are shown pursuant to 10 damage insurance damey possess rates such that all reasonable costs of CFR 2.758 in an individuallicensing an eq*a ent amun pmtection.
serving the public may be recovered hearing. .
The impact of this proposed new assuming prudent management of the requirem6 on construcuon pennit C. Pmetica/ Impacts. The proposed utility.Therefore, one presumption that holders and on licensees for operating
- underlies this proposed rule is that rule wili. in normal circumstances.
reduce the time and effort which the power rcactors is expected to be regulated electric utilities (or those able applicants. licensees, the NRC staff and relatively smallin comparison to total to set their own rates) will be able to NRC adjudicatory boards devote to utility resources and the large consumer meet the costs for safe construction and reviewing the applicant's orlicensee's base for a nuclear power plant.The operation of a nuclear production or financial qualifications. The proposed current property damage insurance utilization facility.The other rule aims at either reducing or premium for a two-unit site is presumption is that the more direct eliminating staff review in cases where approximately si million per year for i
methods of ensuring safety-inspection the applicant is an electric utility, maximum coverage with the premium and enforcement-will be reasonably presumed to be able to finance activities for a one-unit site being proportionately effective in deterring any " corner- to be authorized under tite permit or les. For regulated utilities, insurance I
cutting" and in remedying safety license. costs and the costs of complying with problems.
D. Interim Rule RequiringProperty NRC regulations are normally passed The Commission has tentatively Damcge Insurance. At present, the through to consumers. All other utilities concluded that the present fmancial Commission does not require licensees set their own rates and can pass such qualifications review can appropriately to maintain property damage insurance. costs through to consumers at their own be eliminated for electric utility or its equivalent. Under its discretion.
applicants, which can be presumed to be responsibilities to protect the public able to meet the financial demands of health and safety the Canission is IV. Proposed Application of the Final constructing and operating nuclear Rule concerned about the ability of a nuclear power plants. As an alternative to power plant licensee to finance the In summary, the Commission has entirely eliminating the present financial clean.up costs resulting from a nuclear. tentatively concluded that adoption of quahfication review, the Commission is related accident. The Commission is the proposed rule will substantially considering retaining. at least as an considering the adoption of an interim reduce the effort of demonstrating interim rule. that portion of the current rub which would require alllicensees financial qualifications without reducing
rm I;
' ~
Fidircl R: gist r / Vol. 4S. No.159 / Tu2sday. August 18, 1981 / Propostd Rules 41789 j
~
b 8 the protection of the public health and small busin1ss found in Section 3 of the on financial qualifications discribid in l in safety. If the proposed rule is Small Business Act.15 U.S.C.1632. or paragraphs (f)(1)(i) and lii) of this f
/ promulgated as a final rule. it is the within the Small Business Size section shall be required, nor shall any
. Commission's present intention to make Standards set forth in 13 CFR Part 121. financial review be conducted,if the f l it effective immediately upon applicant is an electric utility applicant publication. pursuant to 5 U.S.C. Paperwork Reduction Act Statement i for a license to construct or operate a i 1553fdl[1) since the rule is expected to Pursuant to the provisions of the p'roduction or utilization facility of the s significantiv relieve the obligation of Paperwork Reduction Act of1980 (pub. type described in i 50.21(b) or 5 50.22.
M i certain appiicants with respect to L 96-511), the NRC has made a (i)If the application is for a is ! information required for construction preliminary determination that this construction permit. the applicant shall
! permits and operatirg licenses. and also proposed rule does not impose new submit information that demonstrates
! to reduce the amount of unnecessary, information collection requirements. the applicant possesses or has I time-conse;nmg staff review and This proposed rule has nevertheless reasonable assurance of obtaining the 3
adjudicatory proceedings. In that regard, been submitted to the Office of funds necessary to cover estimated the Commission notes that the final rule. Management and Budget for its construction costs and related fuel cycle ge when effective, will be app lied to consideration of any potential or new costs.The applicant shall submit i ongoing licensing proceedings now information collection requirements estimates of the total construction cost pending and to issues or contentions pursuant to Pub. L 96-511. of the-facility and related fuel cycle therein. Union of ConcernedScientists Pursuant to the Atomic Energy Act of costs, and shallindicate the source (s) of
!! v. AEC. 499 F.2d 1069 (D.C. Cir.1974). 1954, as amended, the Energy funds to cover these costs.
.lic In addition, the NRC neither intends Reorganization Act of1974, as amended. (ii)If the application is for an ng nor expects that the proposed rule,if and Section 553 of Title 5 of the United operating license, the applicant shall is and when fmally e!!ective, would affect States Code, notice is hereby given that the scope of any issues or contentions submit information that demonstrates gce adoption of one of the two followin8 the applicant possesses or has i related to a cost / ben 1 fit analysis alternative amendments to 10 CFR Part performed pursuant to the National reasonable assurance of obtaining the
! so is contemplated. funds necessary to cover esti nated St Environmental Policy Act of 1968. either operation costs for the period of the in pending or future licensing PART 50-DOMESTIC LICENSING OF license, plus the estimated costs of the proceedings for nuclear power plants PRODUCTION AND UTILIZATION FACILITIES permanently shutting the facility down all (utilization facilities under il 50.21(b) and maintaining it in a safe condition.
ling , and 50.22). Under NEPA. the issue is not The authority citation for Part 50 The applicant shall submit estimates for j whether the applicant can demonstrate reads as follows: total annual operating costs for euch of pr i reasonable, assurance of covering Authority: Sees.103.104.161.182.163.189. the first five years of operation of the l certain rarojected costs-the Atomic Energy Act issue dealt with in the 68 Stat. 936. 937. 948. 953. 954. 955. 956. as facility and estimates of the costs to p
proposed fmancial qualifications rule- amended (42 U.S.C. 2133. 2134. 2201. 2232. permanently shut down the facility and E33. 2239): secs. 201. 202. 206. 88 Stat.1243. maintain it in a safe condition.The hto but rather is merely what costs to the 1244.1246 [42 U.S.C. 5841. 5642,5646) unless applicant of construction and operatmg applicant shall also indicate the py otherwise noted. Section 50.78 also issued i the plant are to be put into the cost- under sec.122. 68 stat. 939 (42 U.S.C. 21521 sources (s) of funds to cover these costs.
l benefit balance. As is now the case, the Sections 50.80-50.81 also issued under sec. An application to renew or extend the rule of reason will continue to govern 184. 68 Stat. 954. as amended (42 U.S.C. 2234). !erm of an operatm, g license must ,
the scope of what costs are to be Sn tions 50ano-50.102 issued under sec.186, mclude the same financial information i included in the balance, and the 68 Stat. 935 (42 U.S.C. 2236). For the purposes as requi:td in an application for an i
resulting determmations nay stillbe the of sec. 223. 68 Stat. 958. as amended (42 anitiallicense.
U.S C. =73), i 50.41(i) issued under sec.1611. (2) Except for electric utility subject of litigation. Thus, financial 68 Stat. 949 (42 U.S.C. 2201(1)); 1150.70. 50.71 qualifications would not be expected to applicants for construction permits and and 5038 issued under see teto.68 Stat. 950 q become an issue or contention in an as amended (42 U.S.C.2201(o), and the laws ' operating licenses, each application for
('p Cc P ing nsofar as referred toin Appendices. a construction permit or an operatin'g Mr mi8 e {ns01 '
license submitted by a newly formed Alternative 1 Fhrninate Entirely the entity organized for the primary purpose Regulatory Flexibility Certification Financial Qualifications Review And of constructing or operating a facility In accordance with the Regulatory Findings As To Electric Utilities That must also include information showing:
7 Are Applying For Construction Permits Flexibility Act of 1980. 5 U.S.C. I 60'5(b). (i) The legal and financial klely the Comnussion hereby certifies that And Operating 1icenses For Production relatienships it has or proposes to have this rule will not,if promolpated. have a Or Utilization Facilities with its stockholders or owners; significant economic impnct on a 1. Paragraph (f) in $ 50.33 is revised to (ii) Their financial ability to meet any b.
$ substantial number of small entities. The read as follows: contractual obligation to such entity propo' sed rule reduces certain minor which they have incurred or propose to pils information collection requirements on i 50.33 Contents of apptications; general incur; and the owners and operators of nuclear informaten. (iii) Any other information considered h"U power plants licensed pursuant to Each application shall state: necessary by the Commission to enable f
- i Section 103 and 104b of the Atomic - * *
- it to determine the applicant's financial p Energy Act of 1954. as amended. 42 (i)(1)Information sufficient to quahficutions.
U.S.C.112133. 21345. These electric demonstrate to the Commission the (3) Except for electric utility
( utility companies are dominant in their financial qualifications of the applicant apphcants for construction permits and j service areas. Accordin;;ly. there is no to carry out, in accordance with operating licenses. the Commission may l@f significant economic impact. nor are regulations in this chapter. the activities request an established entity or newly-l such owners and operators of nuclear for which the permit or license is sought, formed entity to submit add:tional or I power plants witbin the definition of a pwided. however. that no information more detailed information respecting its
}cing
e~
41790 Fed:ral R:gister / Vol. 40. No.159 / Tuesdcy. August 18. 1981 / Proposed Rults
'B fmancial arrangements and status of possesses an equivalent amount af estimates of the total constructirm cost lands if the Commission considers such protection covering such facility. of the facility and related fuel cycle information appropriate. This may 5. Paragraph (a)(4) in i 50.57 is revised include information rt>garding : costs. and sha!! indicate the seurce[s) of to read as fo!!ows: funds to cover these costs.
licensee's ability to continue the conduct (ii)If the application is for an of the activitics authorized by the 1 50.57 issuance of operaung licenses.
- * * *
- operating license. the applicant shall license and to permanently shut <!own submit information that demonstrates the facility and maintain it in a safe tal * *
- the applicant possesses or has condition. (4J The applicant is technically and reasonable assurance of obtaining the
. . . . . financially qualified to engage in the funds necessary to cos er estimated
- 2. Paragraph (b) in 150.40 is reviwd to activities authorized by the operatin8 opera' ion costs for the period of the read as follows: liwnse in acc rdance with tne license, plus the estimated costs of regulations in this chapter.provided-permanently shut'ing the facility down f 50.40 common standards. however, that no fmding of financial ' and maintaining it in a safe condition.
qualifications shall be necessary for an The applicant shall submit estimates of (b) The applicant is technically and electric utility applicant for an operatinS total annual operating costs for each of financially quahfied to engage m the license for a production or utilization the first five years of operation of the proposed activities in accordance with facility of the type described m facility and estimates of the costs to the regulation in this chapter.pmv!ded. 1 Sa21(b) or ! 53.22: permanently shut down the facility and however, that no co isideration of * *
- maintain it in a safe condition. The Imancial qualifications shall be 6. Part 50 is amended by removing applicant shall also indicate the necessary for an electric utility Appendix C. source (s) of funds to cover thcsc costs.
applicant for a license for a production Appendix C-[Removedj An application to renew or extend the or utilization facility of the type- term of an operating license must desc'ribed in i 50.21(b) or i 50.22. Alternative 2-Eliminate The Present include the same fmancialinformation Financial Qualifications Review And as required in an application for an
- 3. A new paragraph (vlis added to Findings A initial license.
Are Applym,s g ForTo Electric Utilities Construction Permi That,ts.
, (iii)If the application is by an electric I 50.54 to read as ioilows~
And Also Eliminate The Finar.cial utility for a license to operate a t 50.54 Conditions of licenses. Qualifications Review And Findings At production or utilization facility of the The Operating License Stage'For Electric type described in i 50.21(b) or i 50.22.
(s) Each electric util ty licensee under Utilities. Except Retain The Portion Of information shall be submitted that this part for a production or utilization That Review And Findings That Relates demonstrates the 1pplicant possesses or farahty of the type destnbed in To Permanent Shutdown And has reasonable assurance of obtaining 150.2i[b) or i 50.22 sha!!. within 90 days hiaintenance Of The FacilityIn A Safe the funds necessary to cover the of the date this regulation becomes Condition estimated costs of permanently shutting effective, have and maintain the 1. Paragraph (f) in i 50.33 is revised to down the facility and maintaining it in a muimum available amount of read as follows: safe condition. The applicant shall commercial on-site property damage submit estimates of these costs, and msarance or demonstrate to the I 50 33 . contents of apptiations: general shall also indicate the source (s) of fundt satisfaction of the Commission that it information. to be used to cover these costs.
possesses an equivalent amount of Each appication shall state: (2) Except for electric utility protection covering such facility. * *
- applicants for construction permits and
- 4. A new paragraph (1. is add'ed to i f)(1)Information sufficient to operating licenses, each application for i 50.55 to read as follows: demonstrate to the Commission the a construction permit or an operating financial qualifications of the applicant license submitted by a newly-formed
} 50.55 Conditions of construction to carry out,in accordance with the entity organized for the primary purpost l Permits. regulations in this chapter, the activities of constructing or operating a facility for which the permit or license is sdught. shall also include information showing:
(f) Each electric utility that is a provided, however, no information on (i) *ne legal and financial construction permit holder under this fmancial qualifications described in relationships it has or proposes to have Past for a production or utdization paragraphs (f)(1) (i) and (ii) of this with its stockholders or owners:
l f cility of the type descnbed in section shal be required, nor shall any (ii) The financial ability of such l 150 21(bl or i 50.22 and who is also the fmancial review of the information stockholders or owners to meet any l hoicer of a license under Part 70 of this required by paragraphs (f)(1) (i) and (ii) contractual obligation to such entity I
chapter authorizing only ownership. he conducted if the applicant is an which they have incurred cr propose to pussession, and storage of special electric utdity applicant for a license to incur; and nuckar material at the site of the construct or operate a production or (ii.' Any otherinformation considered nuc! car reactor for use as fuel in utihzation facility of the type described necessary by the Commission to enable operation of the nuclear rcactor attei m i 50.21(b) or i 50.22. it to determine the applicant's financial issuance of an operating license under la If the application is for a quabfications.
Part 50 of this chapter. shall. within 90 construction permit. the applicant shall 91 The Commission may request an in s of the date this re;:ulat:on het omes submit information that de nenstiates established entity or newly-formed effective. hase and mam:om the the applicant possesses or has entity to submit additional or more masimum avadoble amm.r.t of reasonable assurance of obtaining the deladed information respecting its uanmercial cn site property dan., fund 3 necessary to cover estimated fmancial arrangoments and status of msurance or demonst. ate to the construction costs and related fuel cycle funds if the Commission considers sut.h sat sfaction cf the Comm.ssion tha o costs. The apphcant shall submit information appropriate. This may
~
, Fe'deral Regist:r' / Vol. 46, No.159 / Tuesday, August 18, 1981 / Proposed Rules 41791 Include information regarding a maximum available amount of and sales of securities. Proposed }
licensee *s ability to continue the conduct commercial on-site property damage Regulation D. if adopted. would replace ?
of the activities authorized by the insurance or demonstrate to the the existing limited offering exemptions k icense and to permane nly shut down satisfaction of the Commission that it contained in Commission Rules 146,240, (
the facility and maintain it in a safe possesses an equivalent amount of and 242. p protection covering such facility.
condition.
- 2. Paragraph (b) in i 50.40 is revised to .
The Commission is requesting
- 5. Paragraph (a)(4) in i 50.57 is revised comments on the specific provisions of {
g read as follows: to read as follows; the proposed rules and also whether the i I 50.57 issuance of operating licenses.
p pss ns 8 1 50.40 Common Standards. g d r limited offering transactions particularly -b (b) The applicant is technically and (a) * *
- as they relate to the capital formation i financially qualified to engage in the (4) The applicant is techm.cally and needs of small business. L proposed activities in accordance with financially qualified to engage in the y the regulations in this chapter.provided, activities authorized by the operating DATE: Comments must be received on or however, that consideration of the license in accordance with the before October 5,1981. g.
financial qualifications of an electric regulations in this chnpter,provided. ADDRESSES: All communications on this ?
. utility applicant shall be made only in however, that a finding of financial matter should be submitted in triplicate L the case cf an operating Lcense qualification shall be made only in the to George A.Fitzsimmons, Secretary, j application for a production or case of an application to operate a Securities and Exchange Commission, t utilization facility of the type described production or utilization facility of the 500 North Capitol Street, Washington,
- in { 50.21(b) or i 50.22, and shall be type described in i 50.21(b) or i 50.2 . D.C. 20549. Comments should refer to
' and shall be limited in such a case to the File No. S7-891 and will be available for limited in such a case to consideration of an applicant's ability to provide the applicant's ability to provide the funds, public inspection and copying in the i funds, or to show that it has reasonable or to show that it has reasonable Commission's Public Reference Room, assurance of obtaining the funds, assurance of obtaining the funds, 1100 L Street, N.W., Washington, D.C.
necessary to cover the estima'ed costs necessary to cover the estimated costs 20549.
of permanent shutdown and of permanent shutdown and FOR FURTHER INFORMATION CONTACT: p mainteriance of the facility in a safe maintenance of the facility in a safe
. condition, condition.
paula L Chester,(202)/272-2644 Office of Small Business Policy, Division of gg
(
Corporation Finance, Securities and C
- 3. A new paragraph (v)is added to G. Part 50 is amended by remaving Exchange Commission,500 North
! 50.54 to read as follows:- Appendix C. Capitol Street, Washington, D.C. 20549,
[ i 50.54 Conditions of licenses. Appendix C-[Removedj SUPPLEMENTARY INFORM ATION:The
. . . . . Commission is proposing for comment Dated at Washington, D.C. this 13th day of (v) Each electric utility licensee under August.1981.
Regulation D, a series of new rules this part for a production or utilization g verning the limited offer and sale of For the Nuclear Regulatory Commission.
facility of the type described in se urities pursuant to the Secunties Act John C. Hoy! '
i 50.21(b) or i 50.22 shall, within 90 days of 1933 (the " Securities Act") [15 U.S.C.
l of the date this regulation becomes AC'i"BSecre' 'F- 77c(b). 77d)2)]. Proposed Regulation D is effective, have and maintain the * "-" " " "5al intended to result in a more coherent 8 C " pauern of enmptive relief. particularly maximum available amount of commercial on. site property damage as it relates to the capital formation -7 insurance or demonstrate to the " * * *** ' ** "8* E SECURITIES AND EXCHANGE -
proposed Regulation D brings together
! satisfaction of the Commission that it COMMISSION q
possesses an equivalent amount of the current limited offering exemptions contained in Rules 146 [17 CFR 230.146],
y l protection covering such facility. 17 CFR Parts 230 and 239 3m
- 4. A new paragraph (f)is added to 240 [17 CFR 230.240], and 242 [17 CFR y; i 50.55 to read as follows: [ Release No. 33-6339; File No. S7-891] 230.242). Thus, certain common terms such as " accredited investor" and Q'
J<
f 50.55 Conditions of construction ptrmits.
Proposed Revision Of Certain Exemptions from the Registration "securitie. of the issuer" are defined as %
those terms are used throughout the a 1
Provisions of the Securities Act of 1933 for Transactions involving regulation, and a common rule sets forth -O (f) Each electric utility that is a the informational requirements, the W.
construction permit holder under this Limited Offers and Sales limitation on the manner of the offering, b l Part for a prot! action or utilization ACENCY: Securities and Exchange the limitations on reale, the safe harbor Z facility of the type described in A Commission provision with respect to integration, i 50.21(b) or i 50.22 and who is also the Action: Proposed rulemaking. and a uniform notice-of sales for the holder of a license under Part 70 of this three exemptions contained in the W{
chapter authorizing only ownership.
SUMMARY
- The Commission is publishing Regulation. In addition, proposed il possession, and storage of specia! for comment a new regulation governing Regulation D would result in a number 7 l
nuclear material at the site of the the offers ar.d sales of ceruin securities of significant subctantive changes from 5
! nuclear reactor for use as fuelin without registration under the Securities present Rules 146. 240. anu 242 as i..
operation of the nuclear reactor after Act of 1933. This action represents an explained below. ;
issuance of an operating license under Port 50 of this chapter. shall, mthin 90 effort by the Commission to coordinate the va:ious limited ofiermg exemptions
- 1. Background k@
u days of the date this re;ulatirn becomes and to streamline the existing The registration requirements of the 8 effective, have and maintam the requirements appbcable to pnvate offers Securities Act and the uemptive Z W
n y
W
I s
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-528 COMPANY, et al. ) STN 50-529
) STN 50-530 (Palo Verde Nuclear Generating )
Station, Units 1, 2 and 3) )
)
CERTIFICATE OF SERVICE I hereby certify tha't copies of " Joint Applicants' Motion for Summary Disposition of Intervenor's Contention No.
7" have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid, this 29th day of January,1982.
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman, Maricopa County Board of Supervisors 111 South Third Avenue Phoenix, Arizona 85004 Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
. Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Patricia Lee Hourihan 6413 S. 26th Street Phoenix, Arizona 85040
Robert M. Lazo, Esq.
Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Dixon Callahan Union Carbide Corporation P.O. Box Y Oak Ridge, Tennessee 37830 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stephen M. Schinki, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Edwin J. Reis, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Rand L. Greenfield, Esq.
Assistant Attorney General P.O. Drawer 1508 Santa Fe, New Mexico 87504 Charles A. Bipchoff ~
t