ML20045E146
| ML20045E146 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1993 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9307010176 | |
| Download: ML20045E146 (69) | |
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LUNITED STATES 10F AMERICAL NUC LE AR1RE GUL ATORY:"COMMI S S ION 4,
4 SbI.3l BRIEFING ON STATUS OF PACIFIC l NORTHWEST LABORATORIES' (PNL) STUDY OF DECOMMISSIONING COSTS
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9 9
LOC 3IlO.l' ROCKVILLE, MARYLAND h3I6l JUNE 24, 1993 23G63l 51 PAGES NEALR.GROSSANDC0.,INC.
CorRT. REPORTERS AND TRANSCRIBERS 1323 Rhode' Island Avenue, Northwest Washington, D.C.
20005 (202) 234-4433
.4'
DNSCLAIMER
~
This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on l
June 24, 1993, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was 1
open to public attendance and observation.
This transcript i
has not been reviewed, corrected or edited, and it may contain inaceutacies.
}
)
The transcript is intended solely for general j
informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the commission in any proceeding i ns the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorise.
e HEAL R. GROSS count neeontatt AND TRAN$CRillR$
1333 kHobt itLAM9 AYtHUt, N.W.
(202) 2344 433 WASHIH6toH. D.C. 2000$
' (202) 232-6600
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-r UNITED : CTATES: CF AMERICA :
' NUCLEAR RE3ULATORY COMMISSION:
l i
. BRIEFING ON STATUS OF PACIFIC--NORTHWEST LABORATORIES (PNL)' STUDY OF DECOMMISSIONING' COSTS-
-j PUBLIC MEETING
)
Nuclear' Regulatory Commission One White Flint North Rockville, Maryland
.e Thursday, June 24, 1993 I
,j The Commission met in open-session, pursuant to
- notice, at 8:30 a.m.,
'Ivan-Selin, Chairman, presiding.
i COMMISSIONERS PRESENT:
IVAN SELIN, Chairman of the Commission i
JAMES R. CURTISS, Commissioner FORREST J. REMICK, Commissioner:
E. GAIL de PLANQUE, Commissioner
'I M
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2 STAFF SEATED AT THE COMMISSION TABLE:
WILLIAM C.
PARLER, General Counsel JOHN HOYLE, Assistant Secretary JAMES TAYLOR, Executive Director for Operations THOMAS MURLEY, Director, NRR CLEMENS J. HELTEMES, Deputy Director, RES SEYMOUR
- WEISS, Chief, Nonpower Reactor and Decommissioning Troject Directorate, NRR DONALD COOL,
- Chief, Rad.
Prot.
& Health Effects Branch, RES NEAL R. GROSS COURT REPORTERS AND TRANSCR:BERS 1323 RHODE ISLAND AVENUE. N W.
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3~
1
'P-R-O-C-E-E-D-I-N-G-S 2
8:30 a.m.
3 CHAIRMAN SELIN:
Good morning, ladies and 4
gentlemen.
5 This morning-the commission is to receive 6
a briefing from the staff on the costs associated with 7
the decommissioning of nuclear power plants.
8 Five years ago, in July of
'88, which is 9
in fact five years ago, the Commission published 10 regulations concerning nuclear-power plant r
11 decommissioning, including standard decommissioning 12 funding requirements for both pressurized and boiling-13 water reactors.
These regulations include minimum 14 required. funding amounts and a formula for updating I
15 these minimums periodically.
16 Over the last five years, these minimum t
17 decommissioning funding amounts have been the subject 18 of repeated analysis, one might even say criticism 19 from a variety of sources for being too low and for 20 not reflecting the real costs that utilities face in 21 decommissioning large reactors.
Also, several power 22 reactors have ceased operations prematurely in the 23 last few years before they could run up the full 24 amount of decommissioning funds that was expected.
25 Furthermore, in each case the site-specific cost NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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estimate has been higher than would have been produced 2
from the NRC's generic formula.
3 There are now over 100 operating reactors, 4
many of which are funding for decommissioning on the 5
basis of the minimums required in our regulations and 6
therefore it is a matter not just of neatness and.
7 housekeeping, but real importance that the minimums we 8
do require be adequate for their parpose, which is.to.
9 assure that at least the bulk of the monies needed for 10 decommissioning will be available when needed.
This 11 is not easy given the dearth of actual decommissioning 12 experience and. also the fact that a
number of 13 assumptions such as the fuel ' being take off-site 14 promptly and a couple of other such assumptions have 15 not held up very well.
16 I understand the staff will address these 17 assumptions as well as how the original estimates have 18 held up, concentrating on both the high level and the 19 extreme variability and uncertainty of low-level waste -
20 disposal costs, as well as the regional variation of 21 labor
- costs, a
factor which affected the 22 decommissioning cost estimate for. Shoreham quite 23 significantly.
I 24 With all these points in
- mind, the l
25 Commission is quite interested in hearing from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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staff.on its efforts to rooxamino decommission ~ ing cost 2
and what you might have to say in terms of suggestions u-3 for our regulations in this area.
4 Would any of my fellow Commissioners care 5
to make any comment?
6 Mr. Taylor, would you proceed, please?
7 MR. TAYLOR: Good morning.
I'll open with 8
a few notes about the briefing which you'll receive.
9 First, the information is based on a draft-10 report prepared by Pacific Northwest Laboratories to 11 look at the subject of decommissioning costs, to give 12 another assessment and a potential update based beyond 13 the development of the decommissioning rule issued in 14 June 1988.
This evaluation will' cover a referenced 15 PWR, pressurized water reactor facility and boiling 16 water reactors will be a separate report.
17 With me at the table are Jack Heltemes and 18 Don Cool from the Office of Research, Tom Murley and 19 Sy Weiss from NRR.
The briefing will commence with 20 Don Cool.
21 DOCTOR COOL:
Thank you, Mr. Taylor.
22 Good morning, Commissioners.
23 (Slide)
If I can have the second slide, 24 we'll get right into the discussion.
25 I'm going to try and cover several things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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'this morning, a little bit of background on tha first 2
assessment to give us a baseline from which to look at 3
the reassessment, the results as we have them from the 4
draft report at this time, and then finally an outline 5
of where we see ourselves going from here in terms of 6
schedule.
7 (Slide)
If I can-have the next slide.
8 The assessments of the decommissioning 9
costs have been something which have been occurring 10 over a large number of years.
It goes way back to the 11 mid-1970s.
The first pair of assessments were done 12 for the staff by Pacific Northwest Laboratories, PWRs 13 coming out in 1978 and the BWRs coming out in 1980.
14 There were a whole set of assumptions built into that 15 at that time, including the fact that when those 16 assessments were originally done reprocessing was 17 still a viable option, waste disposal was very cheap 18 and no one was particularly worried about waste-19 volumes.
There were a lot of things that could 20 properly be assumed at that time which, of course, 21 have changed since then.
22 The studies were done assuming a reference 23 facility and a reference PWR and a reference BWR were 24 selected. They were both up in the Pacific. Northwest.
25.
They were Trojan for the PWR and WPPSS for the BWR.
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-7 1-Going along with the selection of a
particular 2
reference go those set of particular assumptions about 3
labor costs in that particular area, where the waste 4
would go, to Hanford in that case.
It was nearby.
r 5
And those sorts of things which are in some respects l
6 facility-specific and make it a little more difficult 7
to then extrapolate to what other facilities would 8
have. As we look at the reassessment, that's going to 9
play out very strongly in a couple of aspects that 10 we'11 get into.
11 The assessments were updated in 1986 in 12 preparation to support the decommissioning rule, 13 which, Mr. Chairman, you referred to which came out in 14' 1988.
So, they were done in 1986 dollars to support 15 that rule.
The staff initiated its reassessment with 16 a contract to PNL in late 1990 at the request. of 17 Office of Nuclear Material Safety and Safeguards, 18 recognizing that a lot of things had changed at that 19 point and we wanted a complete fresh relook trying to 20 take some of those into account.
21 (Slide)
If I can have the next slide.
22 As a starting point, recall the 1988 rule 23 defined decommissioning as being for unrestricted 24 release of the facility in terms of radiological 25 criteria in terminating the license.
More NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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.opacifically, and this is in a footnote to 50.75(c),
2
. decommissioning was defined to not include the. costs 3
associated with spent fuel and costs for other 4
activities at the site which were for things other 5
than radiological.
Any other demolition of the 6
buildings, any other activities were specifically 7
excluded by the regulation as being part of the 8
decommissioning cost.
That's part of the rule.
So, 9
that sets the framework for what was and was not 10 included within the reassessment.
11 CHAIRMAN SELIN:
Let me just stop you.
I 12 iust want to be a little more precise.
They're not 13 part of the decommissioning costs, but'they are not 14 costs against which we require assurance.
15 DOCTOR COOL: They are not costs for which 16 we require assurance as we've defined decommissioning.
17 As the Commission has defined decommissioning in that 18 definition, it's from a radiological standpoint to 19 meet our criteria for unrestricted use.
So, things 20 that you would do which aren't related to meeting the 21 radiological criteria might be things that you would 22 want to do for any number of reasons that are outside 23 our jurisdiction..
24 CHAIRMAN SELIN: The reason I'm nitpicking 25 about that is that it was never intended that these' NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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estimates bn full decommissioning costs.
These waro 2
intended to be requirements against which. escrow 3
accounts have to be built to meet our radiological 4
decommissioning requirements.
5 DOCTOR COOL:
That's correct.
6 CHAIRMAN SELIN:
So, we're ending up a 7
little bit comparing apples'and oranges.
8 DOCTOR COOL:
That's correct, yes.
And 9
you have the difference between the term of art,which.
10 we've defined as decommissioning with that narrow 11 definition.
The more wide general use of the term 12 which is all of the things that you would do at the 13 facilities.
So, there's a difference there in terms 14
'of whether we're using decommissioning in quotes, if 15 you will, and a more general use of the term.
16 COMMISSIONER REMICK:
Mr.' Chairman, might 17 I add, I'm sure you know that the public does not 18 understand it well at all and that's why it's believed -
19 that there's a deficiency in our regulation.
20 COMMISSIONER CURTISS:
- And, Don, the 21 rationale behind the decision not to treat spent fuel 22 management, I gather, was that the Department of 23 Energy had a program going forward at the time that by -
24 the time these plants would decommission, the spent 25 fuel would be moved off to the repository 'or NEAL R. GROSS i
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10 1-conceivably an MRS?
2 DOCTOR' COOL:-
That's correct.
And, in 3
fact, at the time the studies were originally done in 4
'78, one of the assumptions built in was that it would 5
be there for 120 days or so and would go to a 6
reprocessing plant. At that time, the GESMO operation 7
was still in play and a lot of things in the-late 9
8
'70s.
So, there were a number of assumptions there.
9 It was assumed that fuel would be gone relatively 10 quickly, that there was in place the process with DOE 11 for waste disposal, and even with the decommissioning 12 rule in the mid '80s, the waste confidence, it was 13 assumed that DOE would have the facilities that that 14 plan would be in place that the high-level waste would' 15 be taken care of.
That's correct.
16 (Slide)
Slide 5.
17 The three alternatives from the original 1R report, the first being DECON, which was the prompt 19 decontamination following shutdown to the point'where 20 you could release it for unrestricted use.
There are 21 several facilities that have, in fact, done this or 22 are doing it.
Fort St. Vrain, for example,-is in the 23 process of DECONing, Shoreham.
The Shipping Port 24 reactor has been DECONed.
So, there are several 25 examples where folks have moved forward in that kind NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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of mode of operation.
)
2 Alternatively, an alternative would be the 3
SAFSTOR approach-where you would do certain things to 4
place the facility in a stable situation and then you 5
would hold onto it for a period of time to allow
~
6 relatively short lived materials to decay
- away, 7
followed by going ahead and doing whatever else was.
8 necessary to decontaminate for unrestricted uso.
A-9 good example there is Pathfinder, where they put it 10 into a SAFSTOR period for a number of years and came 11 out of that just a couple years ago and finished the-12 activities just earlier this year.
13 The third alternative that was looked at 14 in the study was an ENTOMB study where you would 15 remove the radiological contamination from around the 16 facility, but leave the containment itself either with 17 or without some of the internals such as the lower.
18 shroud and things in place, seal it up and leave it 19 there for decay, no matter whatever period of time 20 that was.
It could be a very long period of time.
21 There are a couple of the older small facilities, such 22 as the Bonus facility in Puerto Rico, Piqua up in Ohio 23
- where, in fact, that was done.
Those have been
~
24 ENTOMBED and are continuing to be watched under 25 various programs.
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So, those were the three alternatives.
2 COMMISSIONER CURTISS:
Don, is the Agency 1
3 officially neutral on which of these-alternatives a 4
licensee pursues or do we-have a preference between-5 and among these options?
6 DOCTOR COOL:
With the 1988 rule, the 7
Commission has expressed a negative preference in'a 8
sense that ENTOMB would not fit the definition of 9
decommissioning where you take it 'down for release for-10 unrestricted use.
ENTOMB assumes that you've got some 11 sort of guardianship continuing.
The rule does not 12 specify a preference between DECON and SAFSTOR.
It 13 allows a period of up to.60
- years, which would' 14 certainly encompass a SAFSTOR sort of proposal.
So, 15 either one of those are certainly viable under the 16 regulation.
Per se, DECON would not be'within the 17 regulatory structure, but the structure also provides 18 that a licensee could apply and could be granted on a site specific basis to do that sort of approach.
19 20 So, we haven't ' expressed a
positive 21 preference, a slight negative preference away from the 22 long-term controls.
23 (Slide)
Slide 6.
The results of the original study for PWRs 24 25 and BWRs, these are in constant 1986 dollars as they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1F23 RHODE ISLAND AVENUE, N,W.
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camn out of-the report and were updated in '86.
'DECON 2
of $103.5 million for PWRS, several numbers-- for 3
SAFSTOR, depending on how long you assume.d you watched 4
it before you went back in and took cara of it, and in 4
5 ENTOMB where the INC means " included," the internals
~
6 included.
They were still in the area, or that the 7
internals were removed.
8 (Slide)
If I can go ahead and have.the 9
next slide.
10 That resulted in the requirements which 11 are in 50.75 for PWRs of $105 million.
We rounded it 12 up slightly and placed that as the minimum 13 requirement.
$135 for BWRS.
We selected the DECON 14 option in placing those financial assurance 15 requirements on.
That was the most expensive option 16 in the study at that time.
Place an inflation factor I
17 into the regulation which is based, once again, on the 18 1986 dollars.
So, those ratios only hold assuming 19 labor costs, energy costs and burial costs in 1986, 65-20 percent, 13 percent and 22 percent.
Each of those 21 were adjusted each year for what happens in each of 22 those three areas and they may not be consistent.
We 23 know burial has gone up significantly and that's why 24 you have a formula.for escalating them.
25 COMMISSIONER REMICK:
Don, in arriving at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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thoso estimates, what was used as a definition of
'2 unrestricted use, Part 20?
3 DOCTOR COOL:
The assumption used.for the 4
unrestricted use was the guidance in place, Reg. Guide t
5 1.86, the Branch Technical Positions, those' criteria-6 that were in place then.
I-should note that the 7
reassessment uses those same criteria as the 8
Commission reaffirmed last year with its SDMP action 9
plan.
Those criteria presently in place were the 10 criteria assumed.
11 COMMISSIONER REMICK:
Later on when you 12 come to the current estimates, if you'd know how 13 sensitive the estimates are to what is defined as 14 the -- what one assumes for the decommissioning 15 criteria in a-qualitative sense, I would appreciate 16 knowing.
17 DOCTOR COOL:
I think I can go ahead and 18 answer that real quickly.
I don't have a good answer 19 for you today.
I already have PNL working under a 20 separate contract to give me that exact breakout.
We 21 have asked them to look at a range of dose values 22 right through the range on down to a very small number 23 that would match the EPA's 104 in support of the GEIS 24 for the criteria rule because that's one of the things i
t 25 we know we'll need and we're developing that over the -
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next couple months.
2 COMMISSIONER REMICK:
That's fine.
Thank 3
you.
4 DOCTOR COOL:
(Slide)
Slide'8.
5 Looked at a number of things, or had PNL 6
look at a number of things in the reassessment.
Some 7
of the things related to technology, such as what you 8
would actually do in terms of decommissioning.
The 9
original study assumes you would go in and you'd take 10 off two inches of concrete.
Waste disposal was very.
11 cheap.
Go in and get it, a very conservative 12 approach.
The reality is you don't go in and you rip 13 off two inches of concrete.
You go in and you take 14 off a quarter inch or a half inch and you check to see 15 if you've done the job to try and minimize the amount 16 of waste.
So, that factor has been taken into 17 account.
High density packaging, cutting'up pieces 18
'and packaging them in a high density manner, once i
19 again to reduce waste volumes, another assumption 20 that's now built into the reassessment that wasn't 21 there before. Things related to safety, both in terms I
22 of regulatory requirements, the ALARA regoirement, the 23 dose limit requirement.
i 24 The original study assumed that you had 25 the old Part 23 rem per quarter.
Now we're assuming NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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it's five rem par year.- You'vo,got the revised Part 2
20.
So, that makes a difference in how you-would 3
utilize workers.
How a utility would actually go 4
about supervising, managing, planning the activities. -
5 There's an increased level of planning, increased 6
level of oversight, increased health physics coverage-7 that now takes place as a result of a variety of 8
factors, post-TMI and a variety of things in the 9
regulatory regime.
10 S o,- the control mechanisms, oversight, 11 supervision and planning, trying to take into account 12 the reality of how this work is actually done this 13 time, costs, both including what we've learned in the 14 last 15 years or so about decommissioning, things like 15 Shipping Port and some of the activities where there 16 have been activities that have taken place, costs 17 associated with low-level waste disposal..That's one 18 of the really volatile ones and we'll see that in a 19 couple of minutes.
20 And timing and some of the assumptions 21 about that.
The original study assumed the fuel was 22 going to be gone very quickly.
Now the assumption is 23 that you have the fuel sitting around for awhile.
DOE.
24 has a requirement that it has to have cooled off at 25 least five years.
That's the same time period that we NEAL R. GROSS i
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17-1 have before you could put it in an MRS.. It has'to do-1 2-with heat generation.
So, you're going to have the 3
fuel-around for a considerably long period of time 4
than originally assumed, even longer than that likely 5
given the current DOE acceptance schedules, some of 6
those sorts of things, influences, timing associated 7
with the particular options.
8 (Slide)
If I can have the next slide, 9
slide 9.
10 There are a couple of things that are not 11 factored into the reassessment by virtue of the way 12 the regulations are. constructed.
Restoration of'the 13 site to " green field. " That term of art, if you will, 14 for all of the things you would do, once again not t
15 related to radiological cleanup, further demolition of 16 the building, other things that you would do there, as 17 we discussed before, and the management of spent fuel' 18 because spent fuel is handled separately as an 19 operational cost, this time under 50.54 (bb).
20 Now, we did ask PNL to take a very cursory 21 look, this is one of the things that we did just in 22 the last couple months, at what spent fuel management 23 costs might look like, although they are not included 24 in the numbers that are on the next slide.
We can 25 come back and address those, if you like, but those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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oro not included in the numbers becauso'they'ro not 2-included in the decommissioning financial assurance 3
under the regulation.-
4-COMMISSIONER REMICK:
Don, do we have any 5
requirements, guidance or is there any industry 6
general practice on how long to store in a pool before 7
going to dry storage?
8 DOCTOR COOL:
There is a requirement that 9
it be' cooled a minimum of five years before you can go 10 to a
dry storage facility because of the heat 11 generation considerations.
12 (Slide)
Slide 10.
Sort of like, "And now 13 the envelope, please."
14 From the draft report as.we have it at 15 this time, their estimates of' numbers, these are once i
16
-.again constant dollars in 1983 dollars.
1993, excuse-17 me.
.I just suddenly lost ten years.
DECON at $124.6 18
- million, SAFSTOR, a range of. values. depending on 19 whether you assume that' the-facility has had a 20 relatively clean life without any fuel breakdowns, 21 fuel failures.
So, it's whether you have relatively 22 short-lived activation products, like cobalt-60, which 23 after 55 years.or so you've gone through ten half 24 lives and significantly reduced the activity you have 25 to deal with.
But whether you've got some-of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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'19 1
cosiums and other things that even after.you'va gone 2
55 years you're still going to have to~ deal with them.
3 And ENTOMB, which we continue to consider 4
because a licensee could apply for it as an option.
5 Here, the only thing considered in the assumption was 6
that the internals would have been removed as part of 7
the initial activities, at $162.7 million.
8 SAFSTOR and ENTOMB that period of time 9
particularly are increased now.
A couple of things 10 that go into that, added costs of monitoring and 11 surveillance, the ongoing activities associated with 12 the whole variety of the way operational business is 13 conducted, surveys and those' increased costs of 14 insurance.- Post-TMI we've had a significant increase 15 in what insurance would be.
Now, the effects of what 16 might be reduced because you no longer actually have 17 fuel in the core, you're no longer operating the 18 facility.
Very difficult to estimate.
So, it was a 19 very conservative assumption that the insurance was 20 still a relatively high quantity continuing over those 21 periods of time.
22 COMMISSIONER de PLANQUE:
Don, what's the 23 reason for the higher dose on the ENTOMBMENT?
24 DOCTOR COOL:
The higher dose on -the 25 ENTOMBMENT is the result that you go in and you do all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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20-
'I of the activitics outside of the containment and you 2
remove the internals.
You're doing most of the work 3
right on the front end, early on, and then once you've 4
ENTOMBED it, you've got virtually no dose.
You've 5
already incurred all your dose and you're just 6
watching it.
It's sitting there all sealed up.
So, 7
early activities.
8 In the SAFSTOR mode, you've done a lot of 9
the work out between 55 and 60 years.
You take 10 advantage of the fact that a lot of the activation 11 products have decayed significantly and thereby you 12 have reduced dose.
You have some reduced waste 13 disposal volume, that being dependent on whether I
14 you've had fuel failures or not.
So, you're.still 15 dealing with the cesiums.
If you've had that sort of 16 situation, you haven't really gained anything in terms 17 of volumes because you've still got to_ deal with that 18 other material, even though it'may not be as hot as 19 it's decayed.
20 COMMISSIONER REMICK:
Don -- oh, excuse 21 me.
Go ahead.
22 CHAIRMAN SELIN:
No, please go ahead.
23 COMMISSIONER REMICK: What's the rationale 24 that.DECON went from being the most expensive in the 25 previous estimate to now being the least expensive?
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DOCTOR COOL: There are probably a raft of 2
f actors that influence that. The cost of watching it, 3
as I said, the costs of insurance.
. Costs of-that I
4 uncertainty out there in the course of time is the biggest factors as we've been able to determine it at 5
6 this point. The staff has had this draft in its hands 4
7 for one week.
We had seen an earlier draft in December after we had talked with Commissioner Curtiss 8
9 about that at that time.
That one was done in 1991
]
There were a number of things that we asked 10 dollars.
PNL to do before we believed it would be ready to be 11 12
- coked at for public comment, moving it to. '93 13 dollars, looking at waste disposal sensitivities and 14 some of those things.
But as we've been able to determine it thus far, the watching it over the course 15 of time, as you can see in the ENTOMB, the assumption 16 is tnat it's about $1.03 million per year to continue 17 18 to watch it.
If you multiply that by 55 or 60 years, you'll see that there's the majority of the difference 19 20 between the activities.
COMMISSIONER REMICK:
In counting that, I 21 would think that with decay you'd end up with less 22 volume going to the waste disposal and with a large 23 waste disposal cost -- I'm not arguing with you, it's 24 25 just I find it interesting that there was a switch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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from being the most expansive to least expensivo.
f 2
CHAIRMAN SELIN:
Just following up on 3
Commissioner Remick's comments, a fair summary seems 4
to be that DECON costs are within the same ball park 5
as the original costs. You probably could account for 6
all of those that -- for instance, disposal cost for 7
low-level waste, whereas SAFSTOR and ENTOMB are l
8 I'll go back.
On an apples to apples basis, not 9
looking at real costs, which include green field costs 10 and high-level waste costs, but on an apples to apples 11 basis, the original estimates of DECON have held up 12 extremely well, and the others have held up very 13 badly.
14 DOCTOR COOL:
That's correct.
In fact, 15 just so the record is clear, if you simply inflated 16 the old 1986 numbers to 1993 dollars, that number 17 would be $153 million.
So, in fact, the estimate is 18 a little bit less for DECON than strictly counting for 19 inflation.
That has to do with reductions.in waste h
20 volume.
The assumptions you make about the use of 21 technology and not taking large quantities of 22 material, waste volume comes down by over a factor of
'i 23 two, which tends to offset disposal costri under -the i
24 assumption, and we'll get there in a minute, about 25 where you dispose of it.
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(Slide)
Go to the next slide.
2 The original study and the numbers I just 3
gave.you are all in constant dollars.
The reality, of -
4 course, is there's inflation, there's interest being 5
accrued on the money.
So, in addition to the constant 6
- dollars, the draft. report contains present value 7
dollars in 1993.
These assumes an interest rate or a 8
net rate of three percent interest minus inflation, a 9
discount rate.
You can see that when you do that'you 10 end up with all the numbers.
You can cover them with 11 a very small dime, everything from
'91 under the 12 lowest of the SAFSTOR options to $103.
So, they all i
13 come very close together because your SAFSTOR 14 activities and ENTOMB activities which run out for a 15 long period of time because of your three percent 16 discount rate get discounted back significantly.
17 CHAIRMAN SELIN: The previous one was just 18 adding up the --
19 DOCTOR CC OL:
The previous one 'just 20 assumed --
21 CHAIRMAN SELIN:
-- value plus over the 22 lifetime of the --
23 DOCTOR COOL:
Over the lifetime-without 14 any --
25 CHAIRMAN SELIN:- Without any discounting.
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DOCTOR COOL:
Without any discounting, 2-that's right.
3 CHAIRMAN SELIN:
So, this has the benefit 4
that the huge uncertainties in out year. costs are 5
offset by very large amounts of discounting by the 6
time you bring them back?
7 DOCTOR COOL:
That's' correct.
8 CHAIRMAN SELIN:
So, even.if you're way 9
off on burial costs for SAFSTOR and ENTOMB, in other 9
10 words when you finally get around to getting rid of 11 the stuff, you've got a very high discount rate to go 12 through.
13 DOCTOR COOL: That helps to some extent at 14 least, yes.
15 COMMISSIONER REMICK: Don, on the discount 16 rate and I'm not arguing with the three percent..
I 17 think history, that's kind of been what it has been.
18 And I'm not sure about. this, but I
think the 19 Commission has on its desk right now regulatory 20 analysis guidelines' that uses a different~ discount 21 rate.
22 MR. HELTEMES:
I can answer'that.
That's 23 correct, Commissioner Remick.
The OMB recommended 24 discount rate is seven percent.
So, we reflected that 25 in'the revised regulatory analysis guidelines --
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1 CHAIRMAN SELIN:-
Seven percent real 2
discount rate?
3 MR.
HELTEMES:
Seven percent is the 4
recommended OMB guidance.
The staff in the past has 5
used five percent and in the past OMB guidance was ten 6
percent.
We thought the difference between the five 7
percent and th, '
percent was too large.
But when 8
OMB revised '
. i; guidance last year to seven percent, 9
we went ahead and adopted-it.
10 COMMISSIONER REMICK:
The only reason I 11 raise it, I'm one who likes consistency.
Why we have 12 two things before us, one three percent and seven 13 percent.
14 MR. HELTEMES:
Well, the other thing I 15 should mention is that in the regulatory analysis 16 guidelines we say for very long activities.
Part of 17 that was low-level waste disposal type activities. But 18 we took that'to be 100 years or so.
Then you use a
[
19 lower discount rate than the seven percent, 20 DOCTOR COOL:
And that three percent 21 matches about what you've got here, if I remember what '
22 you've got on your desk in terms of the reg. analysis 23 requirements.
So, it's not that far off.
The other 24 thing that the reg. analysis requirements say --
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follow that, Don.
Why three and seven percent are 2
close?
3 DOCTOR COOL:
No, no.
The seven 4
percent
-- let's try one more time.
Let's see if I 5
can dig myself in a hole here.
Reg.
analysis 6
guidelines assumed seven percent. But for a long-term 7
activity, as Mr. Heltemes said, it suggests use of a 8
smaller number, which would be on the order of three 9
percent, three, four percent.
The three. percent is
.i 10 relatively consistent with that.
The other thing, it 11 says that you also ought to look at what the actual 12 constant dollar would be to see what influence you're 13 having way out there in the future by discounting 14 those down.
So, in that sense --
15 CHAIRMAN SELIN:
These are very different 16 figures.
The OMB figure is supposed to be a figure 17 that you use when figuring out whether federal r
investment is worthwhile or not and it's not just real 18 19 interest, it's the cost of' capital.
In other words, 20 even the federal government can't borrow infinitely as 21 each dollar.
22 DOCTOR COOL:
Right.
'23 CHAIRMAN SELIN: And before you make long-24 term investments that aren't going to pay off for ten 25 or 20 years, you need to charge yourself a proper NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISU.ND AVENUE, N W.
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amount of capital, not the three percent that.th@
2 government charges itself for-water projects, which 3
makes investments that don't pay off for 30 years look 4
attractive. -This is the other way around.
This says 5
that when you're looking at costs to people that are
~'
6 being delayed for awhile, if you use too high a 7
discount rate, you're effectively saying that anything 8
that doesn't get incurred for another five or-six 9
years is free.
10 In an industry like ours where you have 11 long-term capital decisions being made, it would be 12 ridiculous to use a seven percent figure.
I wasn't 13 aware of the fact we had this figure ahead of us, but 14 I think we really need to take a hard look at that 15 because that says that-any investment where you don't 16 really have to start paying off for fi' 9, six or seven i
17 years is essentially free.
In an industry where you 18 don't get any power out of a new plant for five,'six 19 or seven years, that's clearly a very poor way of 20 doing things.
But.this is sort of cost oriented and 21 the other one is an investment oriented' figure, very 22 different purposes.
For investment oriented you want 23 large figures so that you don't treat capital as free, 24 and for cost you want relatively low discount rates so 25 that you don't ignore it long-term, long-term effects.
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28-1 DOCTOR COOL:
Correct.
2 (Slide)
Go ahead and go to the next 3
slide, slide 12.
4 The draft report contains a
revised 5
formula inatching the '93 dollars.
If you flip back to 6
the previous slide, you can note that there are some 7
changes.
Labor is up a little bit, waste disposal 8
actually down just a little bit, labor and energy down 9
just a little bit.
These relating to the relative-10 proportions that labor, energy and the waste disposal 11 contribute to this reference waste disposal cost.
12 Now, one of the things that we recognized as being 13 relatively important was the assumptions you make 14 about waste disposal, where you're going to take it 15 and thereby how much it costs.
16 (Slide)
So, one of the things that we 17 asked PNL to take a look at, if I can have the next 18 slide, was the sensitivity of these. estimates to the 19 waste disposal assumptions.
The assumption of a 20 reference facility being Trojan up in the Northwest, 21 direct access to Hanford, which will continue in that l
22 compact.
Waste disposal contributed about 25 million 23 to the total, which was 17 percent as we saw a minute 24
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29-1 had to go out of compact, in this casa the only way wa 2
could try to estimate that was to say what if they had 3
to ship all this for disposal at Barnwell, the other 4
operating facility, it makes a significant difference.
5 To be precise, a factor of almost five, so that waste 6
disposal, instead of being $25 million would be about 7
$106 million.
Instead of being roughly 17 percent of 8
the total cost., almost 50 percent, roughly 47 percent.
9 of the total.
10 CHAIRMAN SELIN:
That's basically the 11 difference between obviously transportation is 12 trivial compared to the burial cost.
Is that the 13 difference between decommissioning a
plant in a 14 compact that has a site versus decommissioning a plant 15 in a compact that doesn't have a site where you have 16 to pay out of compact costs?
17 DOCTOR COOL:
It's roughly reflective of 18 that because what you have is you have the Hanford r
19 facility which does not have surcharges.
So, you're 20 looking at a per cubic foot on the order of $50.00 per 21 cubic foot versus disposal at Barnwell where although 22 the basic charge is in that same vicinity, you've got 23 a $200.00 surcharge, roughly comparable perhaps-to 24 what you might expect with an out of compact.
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to $300.00 or moro dollars par cubic foot.
So, that 2
gives you some indication of what the disposal cost 3
might be in that environment. And here we're starting 4
to get very speculative in terms of. where those 5
numbers may end up.
6 CHAIRMAN SELIN:
They're also.
Very:
7 significant.
8 DOCTOR COOL:
But very, very significant.
9 COMMISSIONER CURTISS:. Does the analysis-10 use a set amount that you assume for purposes of 11 disposal costs?
12 DOCTOR COOL:
The cost comparison assumed 13 the disposal costs from the beginning of 1993 for 14 Hanford and Barnwell, including the surcharges,.and 15 assumed the disposal of the volume which the study had 16 projected, which was roughly 7,000 cubic meters to 17 either one of those locations.
18 COMMISSIONER CURTISS:
You don't project
.{
19 out though what you think disposal costs will be?
20 DOCTOR COOL:
Have not attempted to 21 project it out. The sensitivity was based on the hard 22 numbers we had for actual disposal at either Hanford 23 or Barnwell right now.
To go beyond that, you're 24 going to then start speculating and you_give me a set 25 of assumptions and you could rig a set of numbers.
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DOCTOR MURLEY:
May I make a point here?
2 Clearly most of the plants that are going through 1
3 decommissioning now or that will be in the near future 4
are going to not be able to go to Hanford.
So, it's 5-more likely that the Barnwell figures are more 6
typical.
Clearly, when you look at the plants that 7
are going through decommissioning now and you see the 8
large_ costs, Shoreham and Yankee and so forth, it's 9
due largely to this $80 million difference that you 10 see in low-level waste costs.-
11 COMMISSIONER CURTISS:
let me pick up on 12 that point.
If you take a-look at the option of 13 SAFSTOR from the standpoint of what the projected low-14 level waste cost will be, and if you assume just as an 15 operating assumption that the costs are going to be 16 more expensive tomorrow than they are today and 4
17 perhaps much more expensive ten years from now than.
18 they are five years from now, is there any benefit 19 from the standpoint of the. volume that a licensee 20 would have to dispose of? Assuming-here, for the sake 21 of discussion, that the standards stay the same, the 22 cleanup standards, to seeing the high cost of disposal 23 to simply SAFSTORing for the purpose of decay or.does.
24 the 60 year outer limit that we've got on that option 25 limit the time frame within which decay would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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required to achievo any significant reduction in the 2
volume?
3 DOCTOR COOL:
It really depends on the 4
kind of contamination you've got.
If you've got 5
activation products and simply cobalt-60, then going 6
out to 60 years will have an impact because you'll be 7
down ten half lives on that.
That could reduce your 8
volume significantly.
If you've got fission product 9
contamination, cesium and otherwise, 60 years gets you s
10 a half life or two, but isn't going to have a major 11 impact on the total volume because you're going to-12 have to remove that material one way or another.
So, 13 it really depends on the assumptions you make about 14 the kind of contamination you've got and that's why 15 you saw in the SAFSTOR numbers a range depending on 16 whether or not you had assumptions that you did in 17 fact have decay working.for you well or whether decay 18 was buying you something in terms of dose, but not in S
19 terms of volumes.
20 DOCTOR MURLEY:
Could I also make a point 21 on this?
As Don said, we've just gotten the draft 22 report, so we want to take a look at it as well in.
23 NRR.
But we now have about a half a' dozen plants that 24 have prematurely shut down and we have some experience 25 on what requirements, operating cost requirements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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would ba/
For
' example,. security requirements.
2 There's some fitness for duty requirements and those 3
sorts of things.
So, we'll get, I think, a better 4
experience judgment on what SAFSTOR costs would be 5-than we had in the original report.
6 My sense is that those costs are going to t
7 be higher, those costs of just maintaining the 8
facility than was originally assumed,.but I don't have 9
firm numbers on that.
10 COMMISSIONER CURTISS: The important point 11 I'd emphasize here is that the situation with respect' 12 to low-level waste today is a much more significant~
13 influence on the decommissionirig process.than it was 14 back in 1988 or than was expected to be.
15
. DOCTOR COOL:
That's absolutely correct.
16 COMMISSIONER CURTISS:- Take just a coup? <>
17 of recent examples.
We see _ situations. where the-18 potential for denial of access is driving a utility, 19 in this case Yankee-Rowe, with respect to its steam 20 generators and pressurizer, to move forward as 21 expeditiously as possible to try to get those major 22
' components to a facility before the facility closes 23 down.
Similarly, it's conceivable that the cost 24
-figure,-and particularly that starts going up in the.
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have been some that have spaculated to go that high, 2
may in turn also have an influence on decommissioning.
3 This consideration, together with the spent fuel 4
consideration, is I think the two most significant 5
developments since the rule has been promulgated and 6
the ones that make it much more proslematic trying to 7
predict what the minimum values ought to be and what 8
the future is going to look like, what the options 9
are, what the relative merits of DECON versus SAFSTOR 10 are going to be.
11 DOCTOR COOL:
Agree with you completely.
12 (Slide) Go ahead and have the next slide.
13 Just to wrap up what we had wanted to 14 present today, as I said a few minutes ago we've had 15 this version of the PWR draft report for a tad over a 16 week.
It's currently under review in the Office of 17 Research, NMSS and NRR.
When we complete that and 18 have a draft that has been reviewed, it's still 19 undergoing PNL internal review as well, they have not 20.
completed their own QA process on it, our plan would 21 be to publish it for comment, recognizing that there 22 are an awful lot of things out there that are subject i
j 23 to_ controversy that people have a lot of opinions on, 24 to obtain that public comment prior to going and 25 trying to finalize that report.
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Similarly with the BWR reevaluation where 2
we tentatively expect a draft in the December time 3
frame, a review, also a public comment period, and.to 4
take advantage of the public comments, the things that 5
have come in on that prior to the time of making some 6
recommendations with regard to-how the funding 7
requirements should be changed, what factors are in, 8
how some of those things interplay in terms of trying 9
to reset the numbers.
10 COMMISSIONER de PLANQUE:
Don, when would 11 you expect the PWR one to be ready for public comment?
12 Have any idea?
13 DOCTOR COOL:
I would like to think that' 14 it would be within a month or two.
It will really 15 depend on how comfortable we are at this point with 16 the draft' report.
As I had said, we had seen a draft 17 in the December / January type time frame and - we 18 requested the contractor to do a number of things.
19 That report had been in '91 dollars.
We asked them to 20 update it to '93.
We asked them to take a look at the 21 sensitivity of waste disposal, so we haven't had a 22 chance to look at that portion of it.
So, I can only 23 speculate in terms of whether or not we'd be ready to 24 have this out later in July or in August.
It will g
25 really depend on what we
- see, how quickly PNL NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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comfortable with their product.
\\
3 CHAIRMAN SELIN: I have a couple of things 4
I'd like you at.least to consider before you publish 5
a document.
Actually, one set of things before you 6
publish it, one set of' things thinking ahead.
7 Before you-publish it, given the 8
centrality of both high-level and low-level waste 9
costs, you might consider putting out a couple of --
10 well, not parameters but different situations..
In 11 other words, you'll get from the contractor enough 12 information to say what would happen to the estimate 13 if you assumed Barnwell costs instead of --
14 DOCTOR COOL:
Correct, we will.
15 CHAIRMAN SELIN:
You should look at a few 16 cases rather than just publish the numbers.
It might 17 be Barnwell versus Hanford.
It might be an assumption 18 that delay for ten years would give everybody access 19 to a compact site.
I don't know exactly what cases 20 you'd want to look at, but given how central low-level 21 costs are, rather than just publishing an estimate you 22 might put in front of it some parameters, taking the-23 same factors but making some other assumptions about 24 low-level waste.
You should at least think about 25 whether you want to have the staff add that to the NEAL R. GROSS i
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contractor --
2 The second point, thinking far ahead, not 3
for the publication of the estimates, but any j
4 suggestions you might make, I was thinking about what 5
Doctor Murley said about the public doesn't understand 6
the difference.
The reason the public doesn't 7
understand the difference is we haven't explained the 8
difference.
What we have here is a
classical 9
insurance situation which says that if you project 10 costs, there are a bunch of costs, including green 11 field costs and high-level waste costs.
It doesn't 12 mean that one has to be insured against all these 13 costs.
They're really two separate amounts.
One is, 14 without trying to be too cute about it, what is it 15 going to cost _the utility to decommission a plant?
16 The public doesn't care whether it's for radiological 17 reasons, DOE wasn't able to live up to its commitment 18 or this or that.
That's a cost.
That quantity should 19 be a quantity that's estimated.
20 There's a second cost which is we as 21 radiological regulators, how much is it appropriate 22 for us to require be covered and that could exclude.
23 certain whole units, like decommissioning radiological 24 stuff, or it could be based on estimates that says, 25 there's not 100 percent chance that people are going NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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to run through their full 40 year period anyway, so wo 2
could conceivably require more rapid buildup of the 3
tund, but not up to 100 percent of the cost.
I mean 4
there are a lot of different ways of looking_at it.
5 If you separate out what are the total' decommissioning 6
costs and what is appropriate for a nuclear safety 7
regulatory agency to require in the way. of escrow 8
accounts to protect the public from being stuck with 9
these at least nuisances and probably unsafe.
10 situations.
That's the kind of thing that I think the 11 staff ought to be thinking about, not just what is the 12 amount and therefore how much do we need at a point in 13 time, namely exactly 40 years after the amount is 14 done.
Then I
think we'd have much better 15 communication with the public and I think it's also 16 much fairer.
So, we're not in a position of, "I'm 17 sorry, that's not our problem.
That's your problem."
18 It doesn't mean we have to cover the whole amount.
In 19 fact, I don't it.would be appropriate to cover the 20 whole amount.
But laying them out.as two separate 21 pieces when you think about policy recommendations, 22 not analytical views, might be useful.
23 That's the end of your --
24 DOCTOR COOL:'
That's the end of my.
25 presentation.
We'll try to answer any other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N.W.
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questions.
2 COMMISSIONER CURTISS:
I just have a 3
. couple of quick questions.
This was a good overview.
4 and it will be interesting to see as the report gets 5
scrubbed by the. contractor and then by us' what-6 actually makes it way out for public comment.
7 I have two really unrelated questions.
8 With regard to spent fuel, I understand that you're 9
not including the cost of spent fuel management in 10 this reevaluation, and perhaps appropriately so given 11 what the rule itself says today.
12 But as you look at the spent-fuel 13 situation, and in particular the assumptions that were 14 made when the decommissioning rule was promulgated in 15 1988 about what would happen with the spent fuel, 16 clearly we're talking here about a
radiological 17 consideration as opposed to a green field issue and in 18 my view they're distinguishable for that - reason.
19 Taking a plant to green field may be something that.'s 20 desired, but it's not essential from the standpoint of 21
. a radiological concern that we ought to be focused on.
22 Spent fuel, on the other hand, is clearly 23 a matter.that involves a radiological. consideration 24 that the licensee will need to account for as it 3
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i that decision.
And I guess, in looking at the 2
estimates that we've seen on Shoreham and Yankee Rowe, 3
the cost of spent fuel management is a 'significant 4
contributor to the estimates that those utilities are 5
coming up with for how to manage the radiological 6
component of their decommissioning.
7 I guess what I'd like to just ask and ~
8 invite you to comment on is, recognizing that the Rule 9
says what it says today, what is the staff's current 10 thinking given the developments that have occurred and 11 the potential that we may see plants shutdown with as 12 much as, I guess, currently 10 to 15 years before'a 13 repository would be available?
What-is the staff's 14 current thinking with regard to whether spent fuel 15 management costs ought to be encompassed ~ in the 16 financial considerations that ' we as an agency take 17 into account and perhaps require a utility to account 18 for in turn?
19 DOCTOR COOL:
Well, let me start and then 20 Mr. Murley or Sy may want to add to it.
21 Spent fuel cost currently covered as an 22 operational cost under
- 50. 54 (bb) requires that. a 23 utility submit their plan within five years of end_of 24 license and of course we have gotten ourselves into a 25 situation where because of a premature shutdown they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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41 i
l' wouldn't have to even submit that cost until a number
~
2 of years down the road.-
3 Staff is looking right now at considering
~
4 some requirements which would at least require the 5
utility to submit their plans and how they would fund 6
that at the same time they submit their 7
decommissioning plan.
That's an' interim step to at 8
least get the timing together on those.
We. have 9
talked about whether or not and how you would 10 incorporate that more directly into the 11 decommissioning costs recognizing that the structure 12 that we've got of setting up financial assurance 13 targets says you've got a rough estimate of the amount 14 out there.
15 If you're going to weave spent fuel costs 16 into that, you need to likewise have.a rough estimate 17 of what a typical plant would have in terms of spent-18 fuel management costs and we know that varies all over 19 the map depending on the DOE acceptance schedule which 20 each facility has. With Trojan you've got it accepted 21 at one time, but some facilities. on the currently b
22 published acceptance schedule go out 25 years or more.
23 So that's a high variable, but that is one of the 24 things that we've at least considered is how you might1 25 approach-that.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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Sy, did you want to add anything?
2 DOCTOR MURLEY:
Let me add a point and i
3 maybe Sy can add something.
My staff collects data 1
4 and information on what utilities are-actually 5
collecting versus what they're required to collect by 6
our regulation and it turns out at about 49 out of 76 7
sites they're actually collecting in excess of NRC's 8
formula and that's largely because their state PUCs 9
are asking them to do that for just these reasons, 10 fuel storage and green field costs.
It is a
11 significant cost. Of the three recent shutdowns where 12 they've had to build the ISFSIs, that is on-site 13 storage facilities for fuel, the cost estimates range 14 from $27 million to $56 million, so it's a fair cost.
15 And I'll add one other
- point, Mr.
16 Chairman.
The reason I mentioned the public's views 17 on this was I about a month ago was at a public 18 meeting in Vermont where I thought the focus was going 19 to be exclusively on the plant and safety.
It turns 20 out what exercised a
lot of the public was 21 decommissioning costs were not being, they.' felt, 22 collected enough to really decommission the plant the 23 way they understood it.
24 And it sounds very lame, quite frankly, to 25 have to explain, "Well, we only collect part of it for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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43' 1
radiological safety," and they don't understand why 2
fuel storage costs are not part of radiological safety 3
costs and in a way it makes us appear to be part of 4
some kind of conspiracy to reduce the apparent cost of 5
nuclear power and I think somehow we've got to do a 6
better job, as well as the industry, in explaining 7
just what we require and why.
8 MR.
WEISS:
At Trojan, for
- example, 9
they've estimated that it will be about $220 million 10 in 1989 dollars to do a decommissioning, including 11 substantial removal of the power block on the site.
12 That's about $180 million in terms of just doing the 13 radiological portion.
This is about 1989 dollars, so 14 I
would guess that Trojen's just radiological 15 decommissioning would be about $216 million in today's 16 numbers.
That does not account for spent fuel, which 17 might vary from, I guess, a low of about $27 to $56 to 18
$72 million.
Those are the estimates.
19 COMMISSIONER CURTISS:
This. issue is 20 clearly evolving.
We're comparing what we thought in 21
'88 to what we think now in '93 and I ~ suspect there 22-will be further evolutions in this. The Department of 23 Energy, I gather, is taking a look at the option of
.24 perhaps funding some of this storage through universal 25 casks under the Waste Fund and it's conceivable that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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w-m m
44 1-there may be funding mechanisms that emerge separato 2
and apart from the minimum values that'we require in 3
the decommissioning rule.
4 The important point, it seems to me, is S
- that, for some of the reasons that Doctor Murley 6
mentions, that it's important.to be able to say with 7
respect to at least the radiological risk and explain 8
why we treat the green field differently that we.have 9
confidence that the funds will be 'available to 10 decommission the facility, including management of the 11 spent fuel if required for the licensees that we ~
12 regulate and that seems to me an important objective 13 here.
It's, as I say, something that we've got a 14 different view on now since we first promulgated the 15 decommissioning rule and a much more sharp perspective 16 on what's happening on the waste disposal front.
17 My second
- question, actually, wholly 18 unrelated to that, we obviously have the same list of 19 what individual utilities are doing, because I did t
20.
count them and there are in fact 49 that collect more 21 than we require in the minimum' values.
I guess the i
22 question here is more of a question that involves the 23 financial end of this.
Who is it.in the-process who
^
24 makes a determination as to how much can be invested 25 in qualified funds? It's obviously not us.
Is it'the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W, (202) 234-4433 WASHINGTON, D C. 20005 (202) 234-4433
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-.v.--
45 1
IRS or the'pUC or who makes that determination?
2 DOCTOR MURLEY:
I'll ask. Bob Wood from my 3
staff.
4 COMMISSIONER CURTISS:
Okay.
5 MR. WOOD:
Generally it's the utility in 6
cencert with their PUC that makes that decision.
As 7
you know, Commissioner, the IRS rules on that were 8
recently changed because of the Energy Policy Act of 9
'92 and the allowable investments were broadened and 10 the tax rate is being ratcheted down on the earnings 11 on the qualified fund.
But essentially all investor-12 owned utilities now are using the qualified fund 13 approach, at_least for_a significant portion of their 14 funds.
15 COMMISSIONER CURTISS:
Right.
The reason 16 I raise that question, if the estimates are going up 17 a little and if there are some additional costs 18 related to spent fuel storage that need to be 19 collected, if a utility is permitted to invest in 20 qualified funds, only the minimum value -- and I don't 21 know if that's what's going on with the utilities that
-i 22 have only invested, set aside the minimum value, but, 23 if they're only permitted by their state PUCs to 24 invest-the minimum estimates in the NRC Rule in 25 qualified funds and no more, obviously there's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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46 1
disincentivo for them - to go beyond that bscause-2 they're non-qualified funds.
3 And an i.1justment to the minimum value, in 4
- turn, for those PUCs that tie qualified fund 5
investments to our minimum value might in fact cause 6
those that are investing only what we require today 7
and no more to adjust those upwards and invest:the 8
amounts that we're seeing many of these utilities 9
invest beyond what we require, and-I don't know if 10 there's a way we can get a handle on that.
11 Actually, my thought as I read this is it 12 would be very useful I think for the Agency, and I 13 know this was discussed in.1988, it would be very 14 useful I
think for the Agency now to consider 15 collecting directly from the utilities the information 16 on how much they're setting aside in their funds, 17 whether they're in qualified or non-qualified funds 18 and what the instrument type is.
This list that we've 19 gotten from Prudential Securities I gataer is the i
20 working list that we use, and it's a pretty good list, 21 but there might be some merit-in considering, 22 reconsidering the question of whether we ought to 23 collect the information directly from the utilities 24 ourselves.
25 Other than that, I thought this was a. good -
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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47 1
briefing and I
appreciate you all putting this 2
together on the short notice that you had with the 3
report having just come in.
It was an excellent 4
briefing.
t 5
CHAIRMAN SELIN:
Commissioner Remick?
6 COMMISSIONER REMICK:
Just a comment.
I 7
certainly agree with several of the comments that have 8
been made about the fact that we probably lack some-9 credibility because we don't fully explain why we're 10 doing-things the way we are.
And I agree with the 11 comments made that there's nothing wrong and in fact 12 there's some advantage in estimating what going to 13 green field costs might be, but that does not say that 14 we necessarily have to provide assurance because there 15 is a complication.
There's more than one example.
16 Because of the value of existing sites, 17 these sites have been converted to other
- uses, 18 production of electricity or other industrial.uses, so 19 I don't think it's safe to assume that just because 20 any type of plant is decommissioning at a site where 21 you have a tremendous investment in cooling towers and -
22 intake structures and discharge structures and other 23 industrial buildings that those sites will go back to 24 green fields at least immediately.
Elk River is a 25 good example, which was converted to other forms, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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48 1
there are many exampics, but I think it is reasonable 2
to estimate what those costs might, be if they went 3
back to that so that we're not accused of overlooking 4
those type of things.
5 And the same thing is on the storage of 6
fuel.
It's not just the question of when is Yucca 7
Mountain available.
It's a question will DOE fulfill 8
what some people perceive to be their responsibility 9
to accept spent fuel for storage, possibly in an MRS 10 or elsewhere in 1998 or when.
So one could make 11 estimates, but one has to factor in those possible 12 considerations also in doing it.
But if we at.'least 13 do it, if we attempt to do it, lay the figures out, I 14 think then we won't be accused of hiding information 15 and so forth.
16 DOCTOR COOL:
I should note, in agreement 17 with you, Pathfinder is another example where in fact
'm;g "
18 the utility chose to continbe using the infrastructure 19 that it had available.
Although it has now 20 decommissioned the reactor itself, it continues to use 21 the same turbine with a materials license because 22 there's a small quantity of byproduct material there 23 and they now use it as a peaking plant.
24 One of the things that we heard in our
~
25 series of workshops which we talked about with you a NEAL R. GROSS COURT REPORTERS AND THANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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49 1
couple of weenks ago was there is a considerablo 2
sentiment out there about what you would do with these 3
facilities and whether or not it. is the right 4
assumption to assume you're going to go back and no 5
longer use it for any purposes such as this, people 6
coming at it not only from the standpoint of using the 7
existing infrastructure but some other industrial base 8
because of the infrastructure or locations that may be 9
there having to do with a whole variety of things 10 including wanting to keep industry locations and 11 otherwise for tax base purposes for local communities, 12 a variety of things like that.
13 COMMISSIONER REMICK.:
Thank you.
14 CHAIRMAN SELIN:
Commissioner de Planque?-
15 COMMISSIONER de PLANQUE:
My questions 16 have been covered, so thank you for the briefing.
17 CHAIRMAN SELIN:
Okay.
I'd like to thanx 18 you very much also.
I personally think, based on this 19 discussion, and this was an illuminating discussion, 20 clearly the centrality of the waste cost leads to a 21 somewhat different approach, more of a parametric 22 approach and less of a point estimate in what we're 23 going to do in the future.
f.
24 I would like to hear from Mr. Weiss or 25 somebody in the not too distant future how 'we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
(202) 234-4433 WASHINGTON, D C. 20005 (202) 2344 433
50:
1 reconcile the real estimates of the Trojan costs with 2
the parametric estimates of the Trojan costs.
Since 3
you're talking about the'same amount of waste and the 4
same compact, it's not a generic question.
5 But more broadly, I hope.that we as a 6
Commission can find our way, more like what we do in 7
the
- SDMP, to arrive at an overall estimate of 8
decommissioning costs on a set of more comprehensive 9
assumptions and then back off and say, "For our 10 purposes, this is what we think should be covered,"
11 and then local public interest groups could look at 12 these figures and decide whether they want to return 13 to green fields or what-have-you'.
But I'd much rather 1
14 start with a gross estimate including most everything-l 15 and then take a look at the parts that are of interest 16 to us.
17 The first set are the ones that are in the 18 rule.
19 The
- second, as Commissioner Curtiss j.
20 suggested, is we can't walk away from high-level waste l
21 situations regardless of who's responsible.
22 And the third set says, "These are also 23 costs and they're part of our sort of magistrate job 24 to get them out on the table, even if we' don't feel 25 it's necessary or appropriate that they be used as-a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
(202) 234 4433 WASHINGTON. D.C. 20CX 5 (202) 2344433
_a
51; I
1 basis for setting qualified funds aside a'nd we'll sea 2
where we go."
3 It was very, very helpful. Thank you very 4
much.
5 (Whereupon, at 9:31 a.m.,
the above-6 entitled matter was adjourned.)
7 t
8 I
9 10 11 12 13 1
14 16 i
17
^
18 19 20 21 l
J 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE (SLAND AVENUE, N.W.
(202) 234-4433 WASHINGTON, D.C. 20005 (202) 234 4433
9 CERTIFICATE OF TRANSCRIBER.
This is-to certify that the attached events'of a meeting.
of the United States Nuclear Regula' tory Connaission entitled:
TITLE OF MEETING:
BRIEFING ON STATUS OF PACIFIC NORTHWEST LABORATORI ES:
(PNL) STUDY OF DECOMMISSIONING. COSTS PLACE OF MEETING:
ROCKVILLE, MARYLAND DATE OF MEETING:
JUNE 24, 1993 were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the-transcript is a true and accurate record of the foregoing events.
~
/7 I
Reporter's name:
Peter Lynch h
NEAL R. GROS $
. j count espontea$ AND TRANSCRtteR$
1333 RNODE ISLAND AVINUG. N;W.
. {
(sor) 334 4433 wASNete?ON.DA 2000$
(202) 232 4 000 J
~j
4 l
DECOMMISSIONING COSTS REASSESSMENT l'
b l
L BRIEFING FOR-THE COMMISSION JUNE 24, '1993 i
1 Dr. Donald A. Cool Radiation Protection and Health Effects Branch Office of Nuclear Regulatory Research l
u
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e OUTLINE
/.
BACKGROUND
/
RESUL TS 0F REASSESSMENT FOR PWR's' b
/
~ CURRENT STA TUS OF REEVALUA TION i
2 Jene241M$
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- e HISTORY
?
/
Assessments of decommissioning costs performed by Batelle Pacific Northwest Laboratories (PNL) n'
.PWR Assessment Trojan NUREG/CR-0130 1978 BWR Assessment-WNP-2 NUREG/CR-0672 1980
/
Reference facility represents assumptions which may not.
i be directly applicable to other sites
['
/
Dollar value updates in 1986 to support rulemaking
/
Decommissioning rule Jfinancial assurance requirements -
publishedin 1988_
- /.
Reassessment:initiatedin late 1990 i
3 June 24,1993 -
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i NRC Regulatory Requirements i
. /
Decommissioning is the process for safely removing a nuclear facility from service and reducing residual radioactivity to a level that permits release of the facility for unrestricted use and termination oflicense'
\\
-/
Decommissioning financial assurance requirements do not includ e treatment of costs related to spent fuelhandling or.
site remediation:for reasons other than meeting radiological criteria for unrestricted use
'. Paraphrased from 1988 Decommissioning Rule -
A'
~ June 24,1993 9 -
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' DECOMMISSIONING ALTERNATIVES - ORIGINAL REPORTS-
/
DECON --
t i
Prompt decontamination to unrestricted release levels.
/
SAFSTOR - Custodial storage for a predetermined period of time followed by decontamination to unrestricted release levels l
5
/
ENTOMB -
Prompt removal of hot internals and.
entombment followed by a period of
\\
surveillance and maintenance until unrestricted release levels are' achieved l
I
', r
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June 24,199.1 i
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SUMMARY
OF ESTIMATED COSTS - ORIGINAL REPORTS e
OPTION PWR - $ MILS 1986 BWR - $ MILS 1986_
i DECON 103.5 131.8 SAFSTOR 97.7 ( 10 YRS) 128.3 ( 10 YRS) 100.5 ( 30 YRS) 131.4 ( 30 YRS) 80.3~(100 YRS):
106.1. (100 YRS) 1 l
ENTOMB INTERNALS INC 60.2 (100 YRS) 104.3 (100 YRS) t l
lNTERNALS REM 70.5 (100 YRS) 120.2 (100 YRS) l June 24,1993 l --
~
s
FINANCIAL ASSURANCE REQUIREMENTS - 10 CFR 50.75
/
PWR (3400 MWT or greater)
$105 MILLION
/
BWR (3400 MWT or greater)
$135 MILLION
/
Annualinflation Factor:
0.65 L + 0.13 E + 0.22 B Where L, E, and B are escalation Factors for Labor &
materials, Electrical energy & transport, and Waste burial 2 1986 Dollars 7
jaa y, im
I i
ISSUES ADDRESSED IN-REASSESSMENT
/
TECHNOLOGY - Use-of Current technology as basis for estimates
~
/
SAFETY -
Projections based on current conditions and regulatory framework
/
COSTS -
Use: actual decommissioning costs as available i /
TIMING -
DOE requirement that Spent Fuel decay for a minimum of 5-years.
E '.
June N,IM3' w.-
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i FACTORS NOT INCLUDED IN REASSESSMENT
./
Restoration of site to " green field"
/
Spent FuelManagement Costs Operation and maintenance of spent fuelpool Cost of constructing, operating, and decommissioning an independent spent fuelstorage installation
-1 S'
_ June 24,1993 '
~,.
L REASSESSMENT RESULTS FOR REFERENCE PWR ALTERNATIVES EST. COST EST. DOSE DURATION
($ MILS - 1993)
(PERSON-REM)
(YEARS)
CONSTANT DOLLARS DECON 124.6 931 9 YRS
=
SAFSTOR 174.2 321
= 60 YRS 230.3 321
= 60 YRS ENTOMB 4 162.7 790
> 60 YRS 3 Range of costs based on potential of contamination from long-lived radionuclides 4
Additional annual cost of $ 1.03 MIL /YR after 60 YRS 10 June 24,1993
INFLUENCE OF PRESENT VALUE CALCULATION ALTERNATIVES EST. COST EST. COST
($ MILS - 1993)
($ MILS - 1993)
CONSTANT DOLLARS PV DOLLARS 5 DECON 124.6 102.7 SAFSTOR 174.2 91.8 230.3 101.1 ENTOMB 162.7 103.2 5 Discount. rate of 3%
11 s.
- u. nih
.m
{
a 4
REVISED INFLATION FACTOR FORMULA
=
(.0.75.L + 0.07 E + 0.18 8 ) + TAXES / INS.
Where: L = Labor & Materials 1,
~
E = Energy;& Transport B = Waste burial n
12
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COST-COMPARISON DIFFERENT DISPOSAL-SITES TRANSPORT DISPOSAL TOTAL.
$.. Mil
$ Mil
- $ Mil-f 1
HANFORD (WA) 4.1 21.2 25.3 i
BARNWELL (SC)
.9.6 96.6 106.2 o
13
' June N,IM3
4 i
1 9
CURRENT STATUS OF REEVALUATION j
/
PWR Draft Reevaluation Staff review of draft in June 1993 Publication forpublic comment a
/
-BWR Draft Reevaluation q
t Staff review of draft in December 1993 Publication forpublic comment-l 1
/
. Staff recommendation on changes to funding requirements following consideration ofpublic comments andpreparation ^
l of finalreports 14' June 24 EM3 6
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