ML20056H170

Forwards Documentation Re Downs Syndrome & Chromosomally Damaged Nonhereditory Children Concieved in Deerfield River Valley During 1980s-1990s

ML20056H170
Person / Time
Site:	Yankee Rowe
Issue date:	08/12/1993
From:	Katz F CITIZENS AWARENESS NETWORK
To:	Fairtile M Office of Nuclear Reactor Regulation
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ML20056H171	List: ML20056H170 ML20056H174
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NUDOCS 9309080326
Download: ML20056H170 (43)

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August 12,1993 Mr. Morton 8 Fairtile Senior Project Manager d

9 Non-power Reactors & Decommissio ni ng Project Directorate Division of Operating Support Office of Nuclear Reactor NUCLEAR REGULATORY COMMISSION Nashington, D.C.

20555-0001

Dear Mr. Fairtile,

Enclosed are the documents that we agreed to send you.

I want to make clear that the birth defects documentation has been compiled by CAN and local citizens. Dr. Cobb's analysis does not contain the up to date data on Down's Syndrome and chromosomally damaged non hereditory children concieved in the Deerfield River Vallry in the 1980's-1990's.

3 There are 9 children born with Down's Syndrom in the Deerfield River Valley between 1980- 1990's.There have been S-6 chromosomally damaged non hereditory children concieved during this samle period.

One of these children is alive today. This child has features similar to the Down's syndrome

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children. The others were medically aborted.

There are poseiblely 6-7 children with Downs Syndrome born during the 1970-1980 in the Deerfield Valley.

Dr. Robert Knorr, the Deputy Director of the Environmental Health Assessment unit.is in an investigatory process concerning thses children.

The children bor n in the 1980's have all been confirmed.Dr.

Knorr is also investigating the increases in cancer, heart disease, and infectious disease in the Valley. As I stated there have been approximately 2.000 l

live births in the DPV in the last 20 years. Down's Syndrome occurs at a rate of 1/700 to 1/1000 live births. As you can see something is terribly wrong.

There has never been a competent environment report to satisfy the requirments' of operating or decommissioning or to access funds for decommissioning.

l There are also possible increases in Down's Syndrome in Greenfield. Since the state of MA has no birth defects

.i r egistr y we have begun a. citizens registry.

l The Shearson Lehman document domonstrate a joint effort by the NRC and utilities to quell the apprhenhension i n the

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investment community over the problems encountereed by the early retirement of a significant number of reactors and the unpredictability of costs.It also shows that the NRC, l

utilities and the investiment community are aware of the

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economics of the SAFSTOR option.

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We are comfounded by your. silence at the ultility's claim that this early componet. removal would save money for the rato payers or anyone else.

We can only wonder that we have again entered a peridd of experimentation in which our-

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community

• 1.1 function as nuclear guinea Pigs in the cost i

analysis Rowe Atomic. We therefore want to with' draw our concent from this untried, unreviewed unsafe', and illegal j

process.

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We would appreciate confirmation that all our documentrtion j

will be placed in the PDR.

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l We have not recieved the letter in regards to the POR in the l

Greenfield library.

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i S'ncerely, fj j

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Fre ericK Ka'LI Citizens Awareness Ntework i

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Govemor Charl9s D. Baker Secretary David H. Mulligan Commissioar August 9, 1993 Citizen's Awareness Network ATTH:

Debbie Katz P.O.

Box 242 Charlemont, MA 01339 o

Dear Ms. Katz:

At your request, I am writing to present the current status of the Department of Public Health's (DPH) activities with respect to the Deerfield river valley and the Rowe nuclear facility.

The DPH, in an attempt to address citizen concerns, have undertaken a review of cancer data for the area.

This review includes the geographic mapping of cancer cases and the calculations of area-specific cancer rates.

This work is continuing and should be completed by late summer.

This effort will be helpful in establishing whether a cancer problem exists in the Deerfield river valley.

In addition, the DPH is receiving reports of Down Syndrome among residents of the Deerfield river valley.

Because the number of Down Syndrome cases reported by residents is greater than those recorded in DPH records and because the number of cases, though unconfirmed, may be greater than the number expected, the DPH is attempting to determine if the number and-geographic distribut' ions of cases are indicative of a health problem.

This activity entails the confirmation of reported cases, the characterization of the cases, and the geographic relationship of the cases.

The DPH plans to complete this activity also by late summer.

One major limitation of the DPH efforts is that the target populations is small and, therefore, the number of observed health outcomes (i.e., cancer and Down Syndrome cases) is j

expected to be very small.

As a result, it may be difficult to l

establish whether the occurrence of these health outcomes is significantly greater than expected or not.

When carrying out environmental investigations, it is valuable to not only examine i

Page 2 Debbie Xatz i

health outcomes but also environmental data.

This is especially true when faced with a situation such as this one where the number of observed outcomes is small.

If it is not possible to establish whether a health problem exists, but the potential for exposure can be established, then the plausibility of an association between the environment and health can be determined, which is the real gosi of an i

environmental investigation.

However, the DPH does not have the capacity to properly assess historical exposure potential without i

additional resources and expertise.

I hope this status report is helpful.

If you have any questions, please do not hesitate to call me at (617) 727-7170.

Si cerely,

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&]QTQ Robert S.

Knorr, Ph.D.

Deputy Director Bureau of Environmental Health Assessment RSK/tp l

I GaHFARSON MHMAX BROTHERS Eleetric Utilities Commentary January 6.1991 Paul C. Parshlev aShould Investors Be Concerned

. n::9s a

%%[jp" About Rising Nuclear Plant Decommissioning Costs?"

om. nouw

. n::9s:m Vol.3, NO.I EXECUT1VE

SUMMARY

attention to matters related tc' nuclear plant De future econome viaodity of er:stiry nuclear p;wer cecommissoning for several reasons.

First, an increasing number of companies are facinq plants is an issue which has received :ncreasing decommissioning questions sooner than previcusly attenten in the finarc:al communrty in the past year.

had been expected as they contemplate ear:y Beginning in the late 1980s, several reactors nave been shut down prematurety because they cannot shutdowns of uneconorne nuclear plants. Secord, the compete on the basts of cost with aftematrve means of projected costs of decommissioning appear to be meeting ebetre uttity C1tstomer needs In the next few nsing sgnficartty. Third, earty menear plant closings may create a shontatt between accrued years. we expect econome pressure to continue to grew on marginal nuclear urvts due to enactment of decommissoning trust funds and the actual costs incurred for defueling, statull2ing, and maintaining me Energy Pelicy Act of 1992 whch is intended to these units in a lorg-term safe shutcbwn cordition.

promote development of an independent power inoustry and competitbn in the wholesale electre These issues were discussed at a Lehman Brothers market. Also, nuclear plants must continue to pass research conference on November 19,1992 by a econorTyc rmster as more states irrplement integrated panel et experts with unsaue perspectrves ard diverse resource plannerg processes which will put utdities with views on the subject-The is the transcnpt of that high operatirg costs at a corrpetithre desactvantage.

session, together wrth our corctusens.

These facters have ied us to the corcusion that, of the KEY LESSONS LEARNED 110 commert al nuclear plants now cperating in the U.S. as many as 25 of them could f ace premature snutoown in the next several to 10 years. And. this innvestors should be concerned about rising inuclear plant decommissioning costs and should races some interestfrg issues for their utility owners

{ become knowledgeable about the issues related to the timng, cost and financial impact of

,lmpacting the decommissioning of nuclear power cecommissioning esse units and storage and 1ptants in the U.S..

eventual d:sDCsal cf therr low level waste and spent tuel.

The decommissioning issue has been something ct Artcng investors. a commonly-ned view has been a 's!aeper.* but now. a nurroer of elecinc utilities are that, wnde decomm:ssoning costs could grow well Hkety to conf ront it soor,er than nad been expected.

above current estimates, they are not hkely to be ncurteo 'Or '"any years and. Inerefore. are not Since NRC regulations assume eacn plant s canculany 'elevant to today s.nvestment cec:siens.

decommiss;oning fund wiil accrue over the hfe cf.ts

nvesters shcud begin paying c;oser

oerating acense, premature!y closec un:ts prcea:::y

n cur :cirwn

l Effective utility management can make a big]

Fixed.coce decommissoning. contracts, d

'dttierence in the financial Impact on a company {

obtainatie are desirable because they generally i resulting from nuclear plant decommissioning,;

should reduce financial nsk for utilities.

particularly for prematurely shut down facilities i

'To the benefit of their investors, we expect somei '-

Utilities should be ConservatNe in their estimates,

companies will do a better job than others ofI and collection of funcs for nuc! ear plant retirement anc meeting the technical, regulatory and politicall decommissioning costs. SCEcorp for example, has challences of nuclear decommiss6oning.

made the following clean-up funding assumpt Ons for 4

its three San Onotre reactors. complete dismanthng i Beth Pubfc Servce of Cciorado at Fort St. Vrain, and full site restoration; $330 per cubic foot allowance '

and SCEcoro at San Onofre 1. have mace tougn for low level waste disposal. '5% contingency l decisons in a trnely manner and devised sound allowance; seven percent est tion rates: 5.25% '

strategies for hanchng the cnallenges that accompany decommissioning fund growth: and, a 30-year ;

their respectNe cec:saons to c:ose trcse facilities.

operating hfe for units 2 and 3. artnougn their operating t Icenses are for 40 years.

In particular, much can be teamed from the Fort St.

Vrain expenence that is applicable to the industry as a In addition to technolog and financmg I wrcle. For example, the two years that Puble Service consideratons, labor issues should be addressed in i of Coloraoo scent in discussen wrth the NRC staff and company plans. An irnportant objectwo should be i the NRC commissoners has provided an opportunity managing the workforce reduction that naturally {

for the industry and r's regulators to leam a lot aDout accompanies plant closings so, for example, a utthty !

the deccmmissoning effort that many Other companies oces not prematurety lose the very work force wri;ch is '

are hkely to f ace in the next few years essential for maintaining NRC licenses. Pubhc Service i of Colorado spent about two years putting together a j The transition from an operating s;te mto a human resource plan to mar age the downst 1ecommissioning site should be planned and actwity at Fort St, Vrain.

managed since there are some signifcant costs dunng that perod wnch shou 6d be carefutty cons >dered.

Utilities can choose from three basic: ;

decommissioning methods provided under NRC: '

Also important to the success of a utility's ongoing rules (SAFSTOR, DECON and ENTOMB), We i Operations as the managing of the oownsizing of the expect that most utilities, wtUt wme exceptions for, ;

' abor icree as a nuclear plan is shut down, spects! cases, wlit prefer to close their nuclear; !

plants and then postpone actual decommissioningi l Expenence shows us that different utilities respond for up to 60 years, which is allowed under current; ;

to NRC requirements czfferentty. So, for example, the NRC rules.

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statfing levels and O&M expenses tend to vary from plant to plant for essentially the same set of regulatcry RECOMMENDATtONS reoutrements, i

NRC should increase its cu. Tent decommissioning Because of the great uncertainty now surrouncing cost estimates, art! also reflect low level waste and i the Department of Energy's effort to s:19 and butid a spent fuel storage and disposal costs.

repository for commercial reactor fuel and high level raccac*tve waste. utilities should be planning now for

+ NRC should clanfy its pohey on clean-up steps which i sng term onsrie storage of spent fuel.

can be taken by a utihty poor to Commisson approval l cf a decommissoning plan for the f acdity.

l Some characteristics of good utility management g State regulators (perhaps through the National' i practices for nuclear plant shut down and decommissioning, Association of Regulatory Utility Commissioners), in :

collaboration wrth NRC and others, should seek to Centingency plans are imocriant.

One of Public assure utdaties do not have an unintended incentive to Servce of Ccioraco's key stratege moves at Fort St.

keep uneconomic nuclear unrts in operation because Vrain was the dec: son earty in the process to never they are too expensive to shut down.

cperata with a s:rygle plan Every plan the company developed for detuehng and deccmmissioning also

• Congress should establish a clear national policy 9ad a backup plan and minimum standards for nuclear plant decommisscning and srte restoration.

2 Executive Summarv

LEHMAN BROTHERS ELECTRIC UTILITIES in the industry or among ts regulators share at this CONFERENCE point in time "Shound investors Be Concerned About Rising Meeting Format Nuclear Plant Decommissioning Costs?"

We are going to tercw a tomat that is famshar to many November 19,1992 of you who nave attendec conferences and panel discussons that we've put en in the past. We will stan INTRODUCTION with presentatens by eacn of the four panelists. Then we'll give each of them an ecponunity to fdl in PAUL PARSHLEY. Good afternoon i want to thank something that they may want to add to their initial you all for joining us here today My name is Paul comments or a reaction that they might have to Parshley, and !!'s my pleasure on beha:f cf Lenman something they've heard ' rom one of the other Erothers to weiceme you.

panelists.

This afternoon *e will be looking into the cuestion And then we move into an area of cuestions and

'should investors be concemed about the nsing costs answers, where we strongly encourage very active cf nuclear plant decommissoning?* Let me take a partccaten from all of yc,u We will be done with that moment to lay out the tramework for what we intend to around (30. And at that po:nt. we have a reception accomplish and how we're going to get there tccay.

just outside. And the purpose of that is to give you a more informal environment in which you can ask As we look at '.ne industry, we see about 75 invester-questions and talk to the various panelists more wned elecinc utilities that are of interest to us. Two informally. And. hopefulty, gather any information that mirds of these companies are involved, to some the more formal presentatens hasn't given you.

oegree, en owning ancor operating nuclear plants.

Finally, wrthin the next several weeks, we intend to One of the trends we have been watching in recent prepare a transcnct of this sessen. And that should years. is the growing need for electnc utilities to be grve you a permanent record of what goes on here.

ready to operate in a more competrtive business and rate making envircnment. As a matter of national Background Materials porcy, a more competrtive business environment is becoming increasingly important. The new national We have prepared a background booklet. Let me just energy policy legislaten probably is going to move tell you wnat's in that package. It includes an overview things a little tanher along in that d:recten. And, as rt of what we're attempting to accomp!!sh here. It also L

turns out, nuclear, and the quahty of nuclear provdes you w:th the beogrr cal sketches of each cf l

operations. :s an important contobutor to the ability of the panelists. It includes.

.b 11, a report that was

.ncividual comoanies to perform well financially for prepared for this confererc. cy A8Z, Inc., whose

nvestors and to provide economic power for president, Ed Abbott who is nere with us today. Ed.

customers.

will you please stand up? Ed is a former nuclear plant operator. He was a technical assistant to Victor One factor which has recorved increasing attenton in Gilinsky when Victor was a Commissener of the NRC.

s the financial community this year, is the future And he now is a consuttant operating out of the econormc viabilrty of existing units. We held a Washington. DC, area.

confererce back in March - I think a number o.f you have seen the transcnpt which also has been included We asked him to prepare a primer on in the matenals that we gave you today - that fed us to decommissioning issues whch tries to take some very i

the concluson that, of the 110 or so operating plants complex concepts and terms and put them into plain tut are out thera rght new, as many as 25 of them will English that we can all understand and weigh the

' ace premature shut down over the course of the next sign:ficance of. I think ne's cane a very good job of :t.

several to 10 years. And this raises some interesting ssues related to the timing, cost and financial impact We also have included in the background book a of decommissioning these units and storage and memo that was prepared for the NRC Commissoners eventual disposal of their spent fuel earlier this year that explains the rationale behind a new rule that they have promu!qated that deals with We've got a group of panelists here who can address decommissioning of prematt rely shut down plants.

some of these issues from some very interesting something that we think is a very timely subject nght perspecir,es and wrth a degree of experience that few now I

Another entry in the cacKground bock is a detailed and I worked together as congressional staffers in

nronoogy of tne Fort St. Vrain facmty And Ralph Sargent, who ni ntroduce in a moment is here and Wasnington, D C, along wrth Jim Assefstine, anoiner tells a very mteresting story cf the issues that nave one et my cotteagues at Lehman Bromers who :s in me aud.ence.

been confronted by Pubic Servee of Colorado. In many cases. Ralph and his coneagues nave confronted unprecederned issues and addressed tnem Jim Curtiss is going to be acie to g:ve some msights curte effectrvery in the past several years mto tne current status of the regu:atery environment surrounding deccmmissioning decisens. He wdl talk about the Snancial imchcations ter mdividual

mally, m the occk we nave the slices that Joe ccmcanies Wambold will be using in his cresentaten so that you And then. he well discuss some of the can use them to take notes on and to follow wnat Joe emerging issues that have nct yet really been has to say.

addressed in a tinal way in the regu!atory environment.

As I mentioned. in the folder we've also included the That wdl then set the stage for Ra!ch Sargent. Ralph is transcnot from the Conference we had entrtled, Are the Treasurer et Puble Servce of Coterado. rm really Ober Nuclear P! ants Still Viable?* And that was what ihntled that he traveled here for this. He has been wrin Pubhc Servce cf Cobrado since 1977 He's a native led us to believe that there are a number of plants out Coloradan.

there that are Skery to f ace earty shutdowns in the next few years. We have included some recent press I had an unusual opportunrty about a year and a na:f -

clippings that aodress the suoject of decommissioning ago to meet wrth Ralph in his vtfice, where i neard kmd of plants, and some of the costs that are emerging or cf a spellbinding tale of some of the things that PS are still urw.newn about that issue Colcrado has been through in accressmg the need to Uthmatety, we hcce to grve you some answers to the shut down their Fort St. Vrain plant ear 1y. He, as w:th questcn, shoud you be concemed about the nsing Jim and Victor. does a tremerdous Jcb of taking very Cost of decommissionmg? We dd a little mformal compiicated issues and making them understandable.

polhng of the panelists at lunch just a few moments ago. The answer is 'yes and no " Sc. we'll pursue Some of the things that have come up unexpectedly inat in a irttle more detail here for PS Colorado in the last few years, and have been managed qurte effectively, I think set a very good

~3 Introduction of Panelists standard by whch to measure the performance of some other companies that we think will be Let tr*3 take a rrement to lust tell you a httle bit about encountering some of these issues in the next few each of the speakers, because i think we're very years. So, I think you'll agree wrth me, after you've tortunate to have such an unusual group gathered heard, that Ralph does a wonderful job of going here to address the subrect.

through this ard actualty making :t sound fun.

First of all. Vctor Gdinsky :s a pnysc:st by training. He Finally, we have Joe Wambold wno is here from has a Ph D. from Cal Tech At one point, he was head Southem Califomia Edison, a subsidiary of SCEcorp.

of the Physical Sciences Department at the Rand Joe is the Manager of Projects there He's been with Corporation.

He was one of the ongmal NRC the ccmcany for 18 years and has been very cicsely Commissoners, appointed by Gerad Ford back when involved with the decision that his company reached m the NRC was formed in the md 1970's. He served a the past year to shut down the San Onofre-1 before its Scense expires. He has been invotved in the dealings second term, after being reappointed to the NRC by wrth the Cairfomia Public Utiffry Commission. which we Jimmy Carter. He has been very helpful to us over the think has led to a constructive rate making settlement years. Many of you have heard Victor at other that will enable the company to recover its discussions that we've had on related nuclear sub ects. And, I think you will fird, as we have, that unamortized balance in San Onofre-1. wrth some f

there is nobocy be!!er at takirg very comolex issues, retum on it. Ard, also, to accrue a decommissioning big picture issues, ard turning them into easy to fund over a pened of time that is more palatable to urderstard concepts that place the proper signifcance both fis regulators and its customers on the vanous issues that are raised So Vctor will be the hrst of our speakers today.

So, Joe will be presenting the perspective of a company that is confronting these issues currently.

He wdl be folbwed by Jim Curt:ss wro curently is an And, thars slightty different from the vantage point that NRC Commissener. Jim is a lawyer by training He Ralph Sargent and PS Colorado have, out is ahead of has a law degree f em the Univers:ty of Nebraska Jim tne rest of the industry. The industry. I think is goin g 2

j.

to nave to confror t some et these issues a utt!e soor er NRC 1s. for some years - they may stdl be. and we than some of us may nave thougnt may

ar about rt from Jim -- enthusiastic aoout hcense extenson for another 20 years. And,50. that That is the introduction. I don't think you need to hear takes it weil into the 21st Century.

50. the *nole much more from me at this point So. with great subject seemed some distance away.

lP easure. let me tum things over to Vctor Gdinsky Then a bunch of thmgs happenec For one thing. a OPENING REMARKS OF DR. VICTCR GILINSKY number of plants shut down in the fate '80s One was the Fort St. Vrain Diant you hearc about. Patch VICTOR GILINSKY. Thank you Paul. The cuestion Sargent represents Pubhc Service of Colorado Pere before us is whether we need to worry aDout nuc: ear today. The Shoreham Plant shut down tot ochtical plan! decommissioning, in pa*tcular, deccmmisscning reasons, almost before rt started And the Rancho costs. !'m going to try to be very careful in *nat i say.

Seco plant shut cown after a murc0al vote.

Decause I understano some of you are takmg care of my money. [ LAUGHTER]

Each of these could be said to have shut down for some sort of a unicue reason that 00esn1 carry over, The base safety prcDiem that bnngs us to this subject it's not a trend. But then some other things also is. ct course, that when a plant operates. t becomes happened. The Yankee Nuclear Power Plant, whch contaminated ^*tth radioactivity. Ard this matenal and had intended to extend its l Cense, found that that equipment has to be dismantled and removed and wasn't so easy to oo. They couldn't convince the NRC carted away rf the plant srte is to be safe from a point that their pressure vessel was okay. And they opted to of raccacturty and available fOr other uses shut down instead And 4 tumed cut that they saved money thereby.

Overview of the Decommissioning Process The San Onotre-1 plant of Southem Cantomia Edisen The p'ocess is expenstve. It invoNes some irradiaton

-- a representatNe is here today w!!h us - also decaded on tt'e part of the wmers. Ard. cf course, :t needs a to shut down their older Unrt One, a small plant. The placf,, for ah ;his wasa to go and to get the site to the owners of the Trojan plant decced to snut that plant in point where it can br availab!e for unrestrcted use.

1996. And a number of other plants are looking nard You also have to renove the accumu!&ted tow level at their economcs and are consdenng shut down.

waste from the operaton of the plant, rf that had no place to go dunng that penod. And that's the case for So, there is a common thread. And that is the some of the plants, and may be the case more so in economes of operaton. Nuclear power plants as a the futurt And you wouk$ also have to take away the whole are now more expensive than conventional spent fue, wnch is accumulated from the decades of plants, and some of them are cutte a bit rnere coeraton of the plant, again, to be able to re 3se the expenstve. So, a fair nurnber of outf tts are locking stte for unrestncted use hard at their srtuation. Ard I would say, overall, maybe a dozen or maybe even two deren plants are at nsk in Now, tnat is wnat cecommissioning means to the this category and are going to get a substanttal NRC. It coesn1 just mean wha! happens aber the plant scrutiny.

snuts down. It means cleaning the site up to the point

• nere rt can be released for unrestncted use ard the in arty case, the important thing is that all of a suten kcense terminated, tt's a term of att.

decommissoning is important. And the NRC rules on that are also very important to those who are The Decommissioning issue Has Been a " Sleeper" considenng what their options are.

Now, the :ssue, as a whole, has been something of a NRC's Decommissioning Rules 5:eeper. !! never got the attenton that say, spent fuel disposal has gotten, for a wnole bunch of reasons.

Well, the NRC put out a set of rules in 1988 covenng But, arguably, rt's eo; atty important. Ard, in any case, the subject, covenng the options for decommissoning, the issues are intertwined.

and also the provision of adequate furds to make sure that they'll be there so the process can be camed out.

It didn't atways seem that way. For a long time rt The options are basically decommissioning promptly.

seemed like something you could put off. The nuclear And, as a practical matter. that means something hke hcenses run for 40 years. The first sizab: plants wrthin frve years. starting wrthin five years after a plant came along around 1970. so, those woulc not be shuts down. Or delaying that by some number of terminating their 'ecenses to the year 2010. Even row.

y ears.

that seems Amd of a icog way crf Beyond that the 3

CECON

{

Where Will the Waste Go?

i Prompt decommissioning is called, by the NRC i

DECON, in capnals As a cractical matter, they may have no otner ch D4C-O-N. It invotves cleaning up, dismanthng ecutoment. and taking rt off to suitableBecause the urcettainties of the situa I

waste sites.

You're generating thousands of Cubic they may have no cptons but to delay. For one yards of low level waste. and some small amount of there may not De any place for the waste to go I

waste that es above that category that would have totevel waste betere you can clea

. It i

go to a hgn level reposnory 1

and release it for unrestrcled use And the NRC's Current Decommissioning Cost Estimate tnere is simply up in the air.

It's not clear that enner low or hign level sites will be ava.lable in the c The cost the NRC estimates is scr ething like $100 i

decades, or commg decace for that matter.

mmen. $150 mmon. And tt's important. incdentalty, m taiking about costs, that tne NRC only thinks *in terms DecommlSSloning Costs Are Uncertain - And of decontaminating a s:te from a raccactivity point of Probably Going Up They're not talking about cleaning it up or view.

ennging :t back to its onginal ecndition. Often when The cther problem is cost. The costs are uncertain you see crtferent estimates, tne reason is that there And probably hgher than those estimated by the NR are c:tterent assumptions aDout the c!eanup.

The NRC is coming out with new estimates, I be before the end of this year. Those, i expect, will be But, in any case. 5100 mmon to $150 mdhon was the somewhat higher. But I think that other sources. cthe NRC's cost estimate up to now And the process consuttants, and einer contractors, seem to be c might take several years. And would involve a up with substantially higher costs.

And the Ccsts et radcactivity dose to the werkers roughly ccmoarable toreign entities seem also to be sucstantially higner to what rt would be rt tne ptant contmuec to operate inose estimated. expect that the true costs will be cuce i

cver tnal pered.

i There Could Be Shortfalls in Decommissioning SAFSTOR l

Trusts The cther opton, er range of optons, is to postpone i

this process. And this has the name SAFSTOR in Beycod that, if you shut down eariy -- the NRC exp caprtals again Again, t 00n't krow exactly why, but you to accumulate these costs over the life of a plant i

tnat is what they cailit. !! means putting the plant into say through a sinking fund.

a sort of a safe storage mode, and makirn sure that down earty, you're going to be short.Now, if you're sh the radioactivity does not escape m the environment.know, even it you're pretty close to the end with aA The NRC rules atlow the utility to postpone the actual signricant furd, you can be substantially low. becaus i

decommissioning for up to 60 years, and even 6cnger it sort of accumulates rapidly at the end.

tnan that rf there is no waste site avastable. So that's a very long time you can wart.

So, plants that are shutting oown prematurely are simply not going to have even the amount that is now The advantages are that, first of all, the cost is estimated that they need to have. So. they're likety t substantra!?y lower. The radioactivrty dose is far tower be short.

And, as a consequence, rt sesms to me.

to the workers.

And the amount of waste that you taking these two things together, the direction plants eventually have to cart ott is down by something like awill go will be very much toward delaying factor of 10.

decommissioning.

Whnch Decommissioning Option is Best?

New NRC Rules For Decommissioning Prematu Shutdown Nuclear Plants Now. the NRC clearty favors the DECON mode.

because it cleans the srte up once and for all and itNow, the NRC has put out some rules this year or a seems to sotve the proclems and leave no loose ends.of premature closings. amendment to the rule My own view is that utilrties, wrtn some exceptions It's interesting that even as possibly for special cases are gcing to find tnat, even recently as 1988 when the base rule came out, no on under the best of cond: tens. it's attractive to, delay was thinking about plants closing down for econom c i

cecommtssoning.

reasons. The only thought was that plants might shut r --

oown in the case of an accident.

course. considered to be cuite unlikety.And that was. of e

4 i

New *nen you re talking about snutcc*ns fcr uely to De needed. because cecommiss cruno *di econorrac reascrs, the 5:tuaton is cune oderent. and hkely te celayed in most cases Tne ining 10 wory we may actualty see a fair number of snutcowns in aoovt. n seems to me. is that the NRC's trancial ruies any case, there wdl be a fair number of ;lants tnat m3

• di push some ut.inies in a cirecton et uneconnmic de reviewing their estcns cn inat sccre strateg;es. wnich wd! leave ther9 *itn r:gn coerating Now. NRC put OL1 a draft Tule wniCn was Ourte specifc and Included Cena!n 00renions and bond rat;ngs arc PAUL PARSHLEY: Ckay, thank vcu We re going to so on, what you nac to cc in c;tterent cases Aner move now to Jim Cun:ss And rm sure inat he wul receiving ccmcrents iney Oacxed away ano ended up nave some thir'gs to say, in respense tc a ceuo;e et saying that they wdl ceal with these snuatons on a Victor's comments. in charactenz:ng *nat has teen case Dy case casis. Eut taken togetner with the going on at the NRC. and the recent n;1e change. and comments that went a:cng wnh the rule. the sense of it some of the thougnts that went mte that, paniculart s that if someone snuts down. and rt they re in pretty f

ood financ

al shape they can centinue to' cel!ect with respect to the financ:al souncness of mdivcual companies

'non.es at least to the end of ineir eng:nai ocense penod. If a utd:ty.:s not in good f.nancial shape, they OPENING REMARKS OF COMMISSIONER JAMES are expected te ccme up **in the money pretty fast CURTISS, U.S. NUCLEAR REGULATORY Eecause it isn't cenain wnether they11 have :t !ater COMMISSION Now, et ccurse, the sense cf rt is to prctect ine pubhc.

maAe sure the mcney s goirq to be inere JAMES CURTISS. Thank you. Paul These Of you m the Oack of the room wdl have to forgrve me. rve had

! inmA the real e"ect of t is going to be C:*terent

.rc a sore Inroat over the last couple of weeks. ;n f act.

Inat c will. in f act. mn;tri economc cecisens :t wdl s:nce the electico fve had scmewhat of a scratcay cause utdmes to nang On to piants, rather inan to shut throat. And a couple of days ago I woke up and could cown. even wnere those plants are uneccnomic.

barely talk. And it tums out I was coing my Dest to simply because tre citty doesn1 want !c f ace tne sound Lke a Eill Ciinton Democrat.

uncertaint es. What nappens rf they oc shut cown?

So, we're ge ng to enc up in a srtuaten wnere plants.

Then this rroming. I woke up *nh a ennk in my neck.

j i

or at least r Ome pl ants are too expens:ve to n;n but And, fortunately, they're all on the left sde of the room, i

also too en en5Ne to snut down.

because i can hardly tum my head to the rght. So, The Pubhc Servce Ccmpany of Coloraoo had a there's nothing against the speaxers on the ryht nere.

but tnese rnaladies that have atticted me including the comment : ^ this m *rtng to the NRC. whch i

• ant to abile only to bok to the left now --[ LAUGHTER]-- are read you, u nich I think ts pretty much to the point.

They werE commerting on the onginal rule. wnsch was pros 7 to be helpful at this ttme in Washington

{LAL 3HTER]

a htile mcre spec:f.c. Out I thinx the comment still apolies Here's *nat they said.

Victor has cone, as he normally dces. a superD job r i

laying the backdrop for the issues that are before you A situation may eccur where a utinty nas not nere at this, wnat I think is a most timely conference.

ccmpletely recovered decommissoning costs but And, in fact. has touched on many of the questions

• outo be f acec *:th accumulatify decommissioning tunds within five years or less if the plant that I think are central to the consderatens that we as regulators. you as representatives et the financial is prematurely shut oown Faced wrth this possibMty, the communrty, utdtties ard others that are now beginning u1dity may be influenced to make an unsourd business to think in more detail about these cecisons, neec to cecrsion to contmue to cmrate the piant. Such a be focusing on.

decision is irresponsible to both the PUC and the utdtty's rate payem

• tt seerns to me that puts rt pretty What I thought rd oc here in just the few onef minutes

• ed that I have is to try to pick up raally wrere Vctor left ott. Tak about what I see as three imp rtant areas or Conclusion issues from a regulatory standpoint. First fli Say a muple of addnionalwords about regulatory framework.

Let me just say r conclusion and to sum up. shoud because i thank Paul ard Victor are both correct. that we worry? Shoud we rct worrf? WeH let me Say the the regulatory framework that was established in 1988 bad news is that cecommisso nng fu is are hkely to rs. sn f act. going to be central to mucn et the be cw. And the estimates for decommrssonirg costs Oeli0eration and consideration that goes on in this are Wely to be ngter. The good news from a franc:al 3rea. And 50. I thought rd say a tritle brt about wnM point of vtew is trat the *ull amo;n' ci the funds is ret

'nat framework is.

5

\\

l For tnose of you wnc are eterested. you can go to the Federal Reg: ster or ine Code of Feoeral Regulatons The genenc mintmum value set fortn m the rule ter a and read rt in more cetail any night you're havmg PWR ts $100 mmen. Ard the minimum genenc value troubie getting to sleep.

set forth in the rate for a BWR. Dcihng water reactor. is

$135 milhon. Now inese numcers are imocriant.

Secondty. I thought I d ta!k a h*tle bri about the fmancial Decause they are the base against wncn utilates then

ssues, wnat we re seeing from the stancocint et tne nave to begin accumutat:ng tunas plants that have now emta+ec uccn the cain inat. of course, is represented nere ey two cf :2,r sceaners.

The rule secenc!y recuires utd, ties to ac;ust tne and others as well To try to s*eten - a:Incugn we re cecommission ng fundmg level accoremg to a not directly in the busmess of worrymg accut what scec:fied formula that's set fortn :n the rule :tsett, over knancial costs are, Or Deing concemec ancut these the hfe cf the fac*ty. Ard. basca!!y that f0rmula sets inat are direct, we do have a very cens deraDie role in forth an inflation adjustment. together witn wnat's the conter1 cf the cecomm:ssenmg ule in terms of called in the rule. an escatation tactor ter waste estabhshing a tramework for insunng 'nat sutincient funcs *di be available when neeced cisposat And. so. the ad;ustments that you may hear about, read about in the trade press ard so fortn that are going on now, are a function in part -- and I Arc then, thire. I thougnt rd conciude etn iust a onet emphasize just in part -- of the built in mecnanism cuerview et wnat the s:gnitcant regulaton, issues are, wrlhin the rule itself that recuires an aciustment en a some of which we've addressed as a resutt of the util!!y spectf c basis.

excenerce et Fort St Vram and others And some of when, frankly, are still now pending before the Third and fina!!y. the rute recutres utihties to suOm;t five Ccmmisson or yet to Deccme oefore the Commisson, years before the projectec end cf operation. a

?

Dut ina need to De accressed by the Agercy So, wrth prehminary decommissioning plan and a site spec:fic your todulgence, rtl go back anc say a cOuc e cf worcs cost estimate. That's the third rna!cr point. As Victor EDout the regulatcry framework pointed out, that rule was drafted at a time when we ddn't antc:pate that some utihties wouldn't have the NRC's Regulatory Framework For Nuclear Plant complete five years notice that that provision Decommlsskoning centemplated And, of course. we've had to deal with e

what we have come to refer to as the prematurely shut As Vetor indicated. rt was estachshed in 1968. I can t cown pfants.

claim any credit for rt, because rt was established cercre I came to the Commtsson. So. wny they call But the rule riself, for your typical utility --one that thtngs SAFSTOR or wnat have you t con't even know operates a nuclear plant to the end cf its Irfe and then

• nat the acronym stands for. but he s cescribed the shuts itdown-- recurres them five years ahead of cotons fairty clearty.

shutting down to suomit a

preliminary decommissioning plan and give us a site spec:iic

' cd want to say scec:ically about *nat the rule estimate as to what iney think rt will Cest.

Peovires. because although 't's pretty cetaned. I think you can summanze the rule. cr its central points for NRC's Decommissioning Cost Estimates purposes of this discussion, with tnree maior recuirements that eacn hcensee under the rule must I do want to come back to the cost cuestion, and meet.

menten a coup 6e of points First, the cost figures that I have crted are genenc values that, as I mentened. are First, the icensees must estabbsh a decommissenmg based upon the worx that Pac:fe Northwest Laos cd in

'urding mecnanism to prowde assurance that spec:fc' the mad 1980's.

minimum levels of funding will be available for cecommiss.oning. And the rule itsett -- and this is a Secondly, and til pck up on a point here that Victor point I want to ccme back to -- the rule riself sets emphastzed. because rt's extremely smoortant in terms minimum genere values that the Commisson at the cf trying to urderstand what these numoers mean that time, based upon some work that was cane by Pacrfic you see discussed here ard in the trade press and Northwest Labs. Concluded - represented here in elsewhere.

1 about the md 1980's, cur cest estimate of what cecommissioning would cost. The numbers are The NRC minimum estimates contained in the rule 0;tterent for pressunzec water reactcrs than for ooihng assume certain things, but they don 1 assume other water reacters. Decause the boihng water reactors terd things that may De ncorporated in estimates Inat to take a httle trt rncre - they're a uti:e brt more you're seemg. They do not assume demohtien of comam nated structures and a retum of the reactor site to as engmal 6

ui 3

j L

f F, tate Deyond what is neeced for oecontamination of But what I wouic Ise to ao ~ and fl! }ust simDly

[

the reactor for racobgcal purposes summan2e wnat you can looA at m more cetail on these three sheets -- rd like to talk a little bit about As a consecuence, what are refer e.: to. anc you may Anat we've seen happening with the cost estimates as I

hear cf.Md.

• green field

• estimates, returning the the plants have snut down prematurely and have reactor to a

• green field" concitior.. Those dollar gotten into the Dusiness of evaiuaimg what <t really figures assoc:ated with that are not asst d in the takes to decommisson a plant.

i NRC estimates.

The Yankee Rowe Case

{

in addr.cn. many of the estimates that were seen from the licensees. including Yankee Rowe and others that Ive lotted Down some notes here to try to give you a are emerging now, also melude costs for storage of

!!avor of what's happening. A general overview at this spent nuclear fuel. That fgure is not assumed. has not point. Let's take Yankee Rowe as an example. Their

~

i been in the past. and at least to date will not be.jn the cost estimate has gone up $130 mdlion from their future, in the estimates that the NRC uses.

onginal estimate. And these are all 1992 dollars tnroughout all of these figures And, so we've Ceviously with the s:tuatien en the hign level waste isposal program sini being TABLE 1:

NRC DECOMMISSIONING ESTIMATES FOR neghly uncertain. utdrties are YANKEE ROWE neecmg to plan. and 1 inmk we'll hear more about this YANKEE ROWE DECOMMISSIONING COSTS I

neectng to plan for Spent fuel i

provlous decommlssioning cost estimate

$ 116.6 m m storage on site until that

NRC fctmwa value. ad:ustec ?cr future LLW cisocsai cesis - in 1 %

program becomes available ss)

~

to take that fuel. Anc.so, l

those estimates do not New decommissioning cost estimate

$ 14 4. 9 m m inCluOe tf cse numbers.

Reams W mmase nw Tw wage costs am Nw G csoosal costs - in 1992 $s)

Let me Just shtft here at inis Additional costs. not included in NRC estimate:

point to talk about some of

. condition

$ 13.0 m m i

se e

e erge n

t ecn s oeyond NRC reoverements tnat racciogeal hazare sna;! de t

individual uses. You should scuced se mat me Me can M msased for unmsmeted use - m nave in frc1 of you a copy of 1992 $s) a two page sheet that was

2. Site maintenance costs to 2000

$ 3 2.7 m m

+

passed around, I think.

(Altnough NRC SAFSTOR costs incluos a component for storage

~

earlier which lays out the over 30 years, this storage cost s countered Dy lower dismantement decommissioning cost costs resurting from decay of radioac vrfy. An 8-year oslay wouic not estimates for four of 1he provide tne same level of benefits. In 1992 Ss) n**,'ul""k** "i l 'fe "

3g;gfmstoms.ossp.ntm.i e

sss.smm (The informaton is contained in Tab;es 1-4)

Total current decommissioning cost estimate 5 2 4 7.1 m m rm going to skip over Fort Unexplained increase

$ 0.0 m m 5.t. Vrain, because Ralph. rm sure, will speak about that in SOURCE OF FUNDS trtore detail. In addrtion. Fort Retopayer savings reallocated to decommissioning costs $116.0mm i

St. Vrain is somewhat (From eneaper a:tematve power anc ciner avoced Yankee Rowe urucue.

They're a high expenses mat must be collected from owners - in 1992 $s) temperature gas reactor and.

External trust fund balance

$ 63.0 m m

.or that reason may involve Expected future tax refunds

$ 9. 0 m ra Additional funds needed from owners

$s9.

n 1 a we don t e

DWR's and the CWR's.

• • **M Total 5247.

E f

n

ac;usted. You may near different numoers out this is ine way we've coked at r!

And then a big amount of money. $a2.9 mdion. or rougnty haff of the irrtease, frarNy. We at the Agency Their estimate nas gene up 5130 mdhon trom the

n evaluating 11 haven't been able to exDiain where inat comes from.

I con't know crgmal estimate ci $116 6 tc $2471 mdion. The wnether that's trom imoccant thing here is too loca at wny tnat is and contractor work or consuttant work or wnat have you.

what s contributing to these :rcreases And I'll ust but there's a sgrufcant amour't cf money there that at creak them down for you Here vou can iock at them least we haven 1 been able to tracx to a specifc issue l

I,ke green held concr!cn or scent fuel stcrage in more cetad Firs 1. $28 malicn cf that mcrease er rcugniy 20%, is ant:DutaDie to bqner wage anc t'gf er !C* ievel waste The Shoreham Case ciscosal costs. And rm go!rg to come cack to tne low level '*aste disocsal cuesten later in my remarks.

Shotenam we have less etcrmation on. I wid simply Rcugnty 43%. $56 5 mdhon is anneutatie.here to say that their estimate has gone to $22.3 mmon. from toent fuel storage costs The green tietc :ssue. *ncn 1 about $163.7 to $186 mdhon ~ hat's abcut a 14%

mentioned before, that is to say to tal e tne reactor increase. And, again all measu'ec in 1992 do3ars down to a cleaner level than we as an Agency recuire, That wal p e you a flavor, togetner writ "

• Vrain.

they nave estimated $13 mobon addctenM. Thars And they have acdttenal maintenance whch rm su'e Ralph can accress :n more c -

about 10%.

.s to costs which, frannly. I m nct as f amir,ar with.

where the numbers are gcing.

sgnstcant amount. 532 mWcn a rcugnty a cuaner of increasing for what purposes.

And why iney'fe A

their mcrease.

So. you get a feel fcr *nat rt TABLE 2:

NRC DECOMMISSIONING ESTIMATES FOR

s thars causing inose increases as the utdities RANCHO SECO tegin to estimate what DANCHO SECO DECOMMISSIONfNG COSTS spec:fcally decommissioning will Ognal Heensee Nn&g ce@cadon coM Mmsk recurre.

And there are

~.1992 ss'i tM3mm Scme ccmmon trends here Additional costs not Included in NRC estlmste:

as we take a lock a! Ine 1.

OUNIS Spent fuel storage and handling

-Construction of dry storage modules The Rancho Seco Ose

-lSFSI Support (scrosa Phases 1 through 6)

$ 16.5 m m

-Weintenance staff & securtty forces

$7.omm Lefs shr'! to Rancn Seco 548.omm 3 71. 5 m m for a minute. That estimate 2 Green fleid (Non-radiolog! cal demolition) cur!O surpnsingsy, 3Clually,'

ase 6 f costs incurred cunng ac:La! DECON)

D has gere up a total of $166

$ 7.1 m m millon from their nriginal

3. Other conte not attributable to decommissioning

$4.9 m m estimate ci $126 5. rcw to Total 3 210.0 m m 5292, a:most $300 mdhon.

Total current decommissioning cost art! mate 3292.9 m m (A)

And the numoers there. as unexp Wned increase you look at them, again, s a2.9 m m a715 rni; ion, again, almost 50UntE OF ruNDS identcal to the percentage Erternst trust fund balance

>ncrease that we saw at A nnual contributions 5 9 0.0 m m Yankee Rowe 43% has r$4mm c si3mm Th ough 2005 (~d))

$12Bmm to Deen set aside kit aent s 208. 3m m Total (excluding earnings) fuel storage

% veen

~

3218m rI to field issue. 'l % L.

's, 5 29 8.0 m m 4% of their orginal estimate y aam m me Emm mess oq m mate Mmec 'o W h

-- 4% of the increase, or narono Sc. the's is a:so a sacara o pnase 7 cost asemate of s46.7mm for

$7.1 milhon, is added on to non-tadoeogscal cemccon to be performed afw DECON to enng the facxy anc sne to cnng the reactor to green green fier concroons. for a total cost of $327.5 mm ($3416mm in 1992 ss).

f;gg (3) Annua l cowens have nct yet been ce:er nmed by Rancho seco s itensee Tre above est aws n'a sta" esema:es basec on me range c' cos s owcac.

S

TABLE 3:

lK NRC DECOMMISSIONING ESTIMATES FOR I

NRC Expects SF'REHAM Decommissioning Costs To Rise St EwAM OECOMMISSIONING COSTS Funcing contfication amount as calculated by staff

$ 16 3 J m m' i

'If you remember two things

Ong:na; Nncing :e tf.caten ::st estm. ate not crewoec ceca se r

~

. about - the f ramework..

ocensee s.nemot on recuest as :: acconmirty of recuireme-ts -

-i rememoer,12rst. tne numbers

2 sse in the NRC rule are genenc c trent estimate Secondly, they're minimum 5186 cmm values. We expected. and i u ne s plaine d increase (A)

I

$ 22.3 m m t hine, we'll Continue to see j

thc3e numbers go up over time as the valuations get External trust fund balance

$ 10.o m m

[

unc ertaken. There may be Line of credit (B) 5 3co.o m m i

some things that surpnse us-Total 1,ke the cost of fuel storage.

3 310.o m m l

But we expect, and one of the w some na=cn ts cue to toca; enien wem rates.

ma,c conclusions. I guess S The eensee nas commmeo to reserve a porton et tNs v.e of : eca as -

l that 3 reacn is. that those

<er tne outrano:ng calance of cecommiss:en:ng msts.

t nurroers are probably going to continue to go up until we

+

TABLE 4:

settle out some of tne NRC DECOMMISSIONING ESTIMATES FOR

uestions about now much FORT ST. VRAIN -

decommissioning costs with RANCHO SECO DECOMMISSIONING COSTS these early cases Original licensee funding certification cost estimste 5 93.6 m m Rising Low L Nel Waste ucrusted i 19921s. A sne-soec6c es: mate was prec.aroc ey tne j

D@ sal Cost'. May Affect "censee owcause $50.75(c)icrmulas 00 ret cover HTGRs.)

j Utility Decorn ;isslcning

/ djustments since 1990 certification:

[

DeclSlcnS 1.

Increate in LLW disposal 512.sm m k

I do want to ccrre back to low

2. Adjustment for current year dollars

$ 2 6.5 m m

, Costs ow+ to delay in start of decommisaloning

$ 5.7 m m level waste c:sposal cost i[

Letter of credit fees not assumed in original estimate 5 2.0 m m because, trankty, frorn what S v. 7 m m I've heard, that tencs to be a significant factor. Actually, i jc:c Totsi 1

$1R3mm think it may cut in a cirection

..rrent decommissioning cost estimate

$ 157.5 m m

.[

opposite from the conc:Uson

' Om 23*d pnce contract with Wesengnouse. $s in year expenoed that Victor reacnes.

'You

• ;ugn 1995) j

}

know, I may have a shghtly Unexplained increase (A)

$ 17.2m m different view here.

SOURCE OF FUNDS Expended to date -

The estimates that people

$ 10,sm m l

External trust fund balance have used, in terms of 528.0mm TilCulating what it Costs to irrevocable letter of credit (B)

$ 125.0 m m -

l i

take the low level waste that is Total 5163.smm

.g e n e r a t e d in (A) inc:vdes inflaten ter delayed expenocates inru 1995.

I decomrnissioning and dispose

'i of it, and, in particular, as we O *" "D I

see the operating sites erther shuttiry down or increase in the cost of disposal, and 1m going to actually tread on Ralph's furt here and-I the projections for the increased cost of low level give you some numbers that, wnen I was out at Fort i

waste disposal over time. Some have estimated $500 St. Vrain in 1990, stuck in my mind and that I think are i

a cubic foot and on up.

significant in terms of whether bw lavet

-t r---

encourages earty dismantiement or SAF ' TOR.

t 9

i L

i 4

At we time that I was inere. anc rm sure ne'll have taking a iook at Inat cuestien to see casea uoon row i

upcateo intornaten. Iney were estimating tne cost of some real concrete experience whetner inere's

[

ceccmmissioning at rougnty $100 milion. SAFSTCR.

,ustrhcaton or need for upcatirG me Ocst fqures that unicn rs the opicn et cefemng cecommissoning. in we nave in the rule, or provcirg for a mecnanism tnat 1990 collars. was estirnatec to be aDout 5383 millon

^ouic ensure that the necessary %ncs to reflect tnese increased expenses are, in f act. mace avaitaole Now. if you assume a 5% annual escalaten figure in l

!cw eevel waste disposal. Anch is not signitcant. and We nave the same lab. Pacrf c Nonhwest Lab. worung may, in fact, be exceecec. !cta: SAFSTCR cost for that on this issue. The cate's actually a hitle ort later We j

utihty in the year 2043 ran accu

• T2 3 bilien So. you ncoe to have a craft repon out for public comment can see the significant imcact of d ef e rring around March a next year that will typically go final

{

cecommissioning when you calculate the cost of inen. But that will be an opportun:ty to take a look at 1sposing of that low level waste, if you assume that upCaling those figures anc coming up wdh a current Mat cost is going to centinue to increase estimate.

• *:ii also say, altrcugh I con't have a lot of cetails on

!!'s focusing on the PWR. the pressurizec water this yet at th s point. Yankee Atomic. wrth the Yankee reactor estimate first. And trying to take into account Rowe Plant, is currentry taong a lock - arc I m going the expenence that we'll get wrth the Trojan facedy, to come back to th:s issue in terms et 'ts regulatory

• ncn is a PWR. I will say there are three issues nere rnchcations ~ at trying !c take out the steam that we have asked them to take a 6ook at in paricular gererators and the cressurreni so they can get those and to run some sensrtivity anafyses. Because rt tums major components cown to Bam* ell the regional cut that these decommiss;oning costs are highly tacilty in the Southeast for ?c* ievel waste. Defere that sensstrve to these three facicts. ermer inc:vidually or as f acil.ty cioses And, 50. there 5 a great intcntive to a group.

move forward *dh cispc s al cf some Of these components. While the 00sts are relatively moderate.

First, the low level waste disposal cost, we need a and unile the f acihties are cDen sensrtivity analysis on that issue. Secondly, the amount of concrete to be removed for a reactor is an important Conssderation. And the third issue, that i NRC's New Rules For Decommissioning mentened before, the spent fuel management costs.

Prematurely Shutcown Nuclear Plants those have not been reflected in our current estimates.

Let me tum here Cuckfy now and corclude wrth just an

!t's obvious if you take a look at some of these overview of what some of the maler regulatory issues estimates that I passed out that upwards of 40% or are As Victor indicated. *e have. after promulgating 50% of the increase in cost is now oeirg attnbuted to the rule in 1988, setting tcrin the decommissioning spent fuel management costs on site. As I indicated.

i framework, we have since seen a situation that not inat report should be out in draft form around March of l

many antcipated -- in fact, rm not sure any anticroated next year for those of you wno are interested.

f

- wrin the premature shutcown plants. And, in some respects. that has caused us, as an Agency, in responcirg to earry snutdowns, to make mid course "How Clean is Clean Enough?"

corrections in tre decommissoning framework, to aodress issues tnat were not addressed scuarely in Secondly, over the coming year, I expect to see the cecommissioning ruie 'iseff, because we didn't centinuing focus and discussion of the issue, now antc:cate eany shut co*n.

clean is clean enougn. How clean do we need to get inese reactor sites? Victor cescnbec correctly the And im going tc go tnrougn some of the cuestcns that recuirement in the current rule and inat is the objective

[

weve taken a look at and inat you may see Deing the of achieving a level that would permit unrestricted tcus of our cenberation in this area over ine next access to tne site. This is an issue. in fact that has memns ano. Scoetuuy. net too mar'y vears come up in the context of some of the other sites around the country that we are decommissioning, the matenal sites, and we have established some NRC ls Considering increasing its workshops to take a nook at the issue in that contert so Decommissioning Cost Estimates that we can evaluate the cuestion of exactly how clean inese srtes need to be. That will get some continuing The mest cbvcus cueston '/ictor a!!uced to it as well.

attenton as welt.

4s wnat are tne costs going to ce with ceccmmissicrung' Anc,n f act *e as an Agency are i

10

NRC's New Decommissioning Funding Requirements For Prematurely Shutdown Plants the rule itsett recuires the agency to approve a decommissoning plan submeted cy tne uttlity before

}

Third, tet me tum to the issues tnat have ansen in the the utility can proceed with cecommissioning. The question has arisen:

how do you define context of prematurely shut cown plants, because in some respects those plants have promoted issues that cecommtssen? What can ano can1 a utility do bdfore

t gets its decommissioning plan acoroved? Could it we've had to deal with. The SECY paper that you nave, take out a steam generator, as Yankee is thinkin in your notecook talks about the agency's approacn to the early accrual of funds ano m f act lays cut tne aDout doing, and send it down to Bamwell. get it ott-l srte, even though that's a radioactrve component and

[

approach that the Commission will take (the SECY even though that might constrtute dismantlement of a paper is included in the appendix). Victor descnbed it major component?

That's an issue that the correctly; it's a case-by-case evaluation. I have a c:tierent view on wnat the impact will be.

Commission is currently thinking about. and the statt is in the process of trying to formulate some guidance on

{

Thers was a concem, trankly, with 'ne proposec rule, that cuestion. But as you look at plants that shut down prema"urety, it may well be that it a plant wiches to sell whch proposed that if a plant snut cown earty all of the t

funds necessary to decommissen the plant had to be off components or dismantle them or not have to put accumulated in five years. There was a concem that temponents in lay-up and so forth, that the question ot what they can do in this regard, how you define that rule wouid, in f act because of the onerous dec0mmissioning is going to be a cntical f actor in colgation that a utility would have, mgnt in fact force a utilrty to keep operating the plant because they couldn't terms of what they can do before a decommissicning i

plan is approved.

accrue those funds in that five-year genod. That's wnat I understood Public Service of Colorado to be Cost Savings From Labor Force Reductions Prior saying in their comment. It was because of that To NRC Approval Of A Decommissioning Plan

}

concem that the Commisson in Ine fmal rule adopted the approach that's reflected in the paper that you Fourth, I would say that the Commission in the past

?

have and now allcrws accrual over a longer penod of time so that we don't have a srtuaten wnere that Irve-has been wilMg, and here I'm shttting to issues that we've addreised, the Comm:ssion has been willing in year artificial penod forces util: ties to say. 'we simply the cases t date to allow the utaies even prior to the' ~

can't accrue those funds in that penod -- iet's keep the reactor operating."

decommisi..cning plan to reduce staffing and resources to things that are really unnecessary for a plant that's shut down.. And the figures there may be NRC Will Accept a Iltllity's Shutdown Decision s'enrficant. In fact, I've brought along with me just a Secondly, an issue that came up in the context cf c:.uple of notes on the figures that we saw at Rancho Seco and Shoreham. The savings that Shoreham Shoreham and. curte frankly, i think. is unique to estimated it could achieve by not, for example, having i

Shoreham - I thought I'd mention rt - we debated at emergency planning in place and att the statting that the time whether the agency ougnt to require a utility to goes along with it, were on the order of $17.5 milton.

keep its plant ready for full-power operation even so there are some significant numoers here. These i

though it had made a decision to shut !! down before are things that they wished to do before they got their l

we approved the decommissioning plan. The decommissioning plan approved. and so they stopped l

Commissen has settled that issue, we're not in the paying for emergency planning people, they stopped -

business of saying whetner a plant should or shouldn't

- they bnng their secunty bouncary in, and so fortn.

1 coerate. if a decison is taken to shut it down. well get Likewise, the figures in the case of Rancho Seco came j

j cn to the decommissioning questen and not insist that out to about $10 million.

the plant until then be kept ready for full-power coeraton So there are a sgnificant number of things that utilities may be seeking permission to do before approval of What Plant Clean-up Steps Can Be Taken Prior To decommismonirg, after they shut the plant down, so NRC Approval Of A Decommissioning Plan?

that they can reduce tne expenses and that's going to be an important financial consideration as well.1 Third an important issue. The cuestens arising in mentened the issue of when coes cecommessoning Yankee Rowe. I mentened the steam generators, and begin. I talked about the cost issue.

will anse,1 inink in fact has ansen. in Fort St. Vrain, and I think Rancho Seco as well. !ne cueston of wnat When Wi!! Spent Fuel Be Moved Offstte?

a utility can co crict to having an approved decommiss;cn:ng pian. What scr of d:smantlement There is an imoonant issue atthougn we con 1 have 1 can they under*ake at the stant? I snouc nenten tnat d: rect role in :t, that nas to ao witn spent fuel stora-1 l

==

11

.= _

6 t s ccming up in the context of Yankee Atomic. They d append:x to this report). the paper crecared for mis ise to get their spent nuclear fuel ctt-sne as soon as conf erence called

" Nuclear Power Plant possible and have approached other utshties and DOE Cecommissioning Regulation. P ocesses and Costs?

r about getting to the iront of the ime 11 and wner. the reocsnory opens. So that they can dispose of their fuel you will find some fairty short cefirations of some et first and get it ott srte. Sort of uncer the rationate that these terms that are Deirq used here in acdnion. rt you oo.ake a look at tne SECY paper (also inciucea in we were the first ones to snut down, we ougnt to te in tne acpendix), I think you wd1 thd some pretty the iront of the kne. That issue ts somethmg tnat we intelbgtble discussen of the comments that were mace con't have a direct role in Out :t will attect now iong the to the NRC and how the NRC cealt with tnose spent fuel neecs to be kept On sne comments wnh respect to what's going to happen to Summary And Conclusions comDanies that plan to shut down their nuclear plants e arty. There's discussion that may be of interest to some of you about credt! ratings and how that may Um gomg to conclude here, let me make four affect the kinds of information the kinds of tests inat i

ccservations in inis area inat are notable. First, I agree wnh what I thinx V.ctor nas sa.d and that is that have to be met in getting NRC approval to move

.orward. So at your leisure. I commend both ct incse we're likely to see the cost estimates increase nere in things to your attention. With that. I think we should the future. We in fact may see them increase in our rnove from it'e realm of regulation to the realm et tormal analysis i think you're hkely to see some reahty here and let Raion talk a httle bc about what PS stabdization of that as we get a better feel of how to undertake decommissioning, wnat it costs and the Colorado has confronted in recent years and now efficiencies that can De achieved.

they've managed some of those issues.

Secondly, i do believe that low-ievel waste disposal OPENING REMARKS OF MR RALPH SARGENT, costs are going to be a sgnificant component in the TREASURER, PUBLIC SERVICE COMPANY CF COLORADO decommissioning area. Tnat leads to my third conctusen.

RALPH SARGENT: Thanks. Paul. fd like to start cut 1 frankry think tr'at at least at inis point because of the by saying that Fort St. Vram has been desenbed a number of different ways. Most commonly we are low level waste issue and based upon rat we have ret tred to as a unque nuclear power plant. Tocay seen at the plants that have shut dow* crematurely, that there's actually some preference :aitt into the Jim referred to us affectionately as a

• prematurely shu:

system fcr early dismantlement, as oppcsed to long-down" nuclear plant. We prefer to think of ourselves te m SAFSTOR. The financial numbers. the anatyses as pioneers in the decommissoning industry.

tnat have been undertaken. seem to suggest that it is The Decision To Close Fort St. Vrain cestrable to get the facility dismantled as soon as cossible. That may be something that's unique to utihties that have single unrt srtes. If you have muttiple At the Lehman Brothers conference earlier this year, discussmg the economic viability of nuclear sites, as Southern Cal Edison does, there may be a d!tterent caiculus inere, if you still have operating decommissoning, Paul made a etsing comment anc sad from the point of view of investors, that investers reactors.

eught to pay particularly close attention to those Fourth, and finalty, i think as we at the agency take a companies that had hgh O&M costs associated with tneir nuclear plants and low capacrty factors. And :t Icck at implementation of the decommissioning rule wouldn't have taken much investigation to find the you're likely to see continumg mid-course corrections bottom of that list. And unfortunalely, Fon S _ Vrain as we bok at the specific issues. The Yankee Atomic was at the bottom of that list. We expenenced C&M cuestion - can you serd oti the steam generators? - -

costs as high as $100 million a year and we had a i

s a good example. And I think the adjustments that have been made to cate are hkety going to presage lifetime capacrty factor at the plant of less than 20 continuing flexibility as we implement the rule to percent. That made the economic viability issue cune simple for us: rt was not economically feasible for us accommocate from a technical stancpoint wnat we need to do from a nearth and safety perspectrve but to continue operating Fort St. Vrain. Its unqueness m abo to allow dec:sions to go forward in the most that area did cause the premature shutdown of the effcent way from a f tnanctal stancoomt.

plant and one of the reasons that rt's so imponant m today's discassion is because the plant is closed. In t

PAUL PARSHLEY Okay. Thank you, Jim. I would addition to that we have completed the defueling of point out two thmgs real Qualy and then tum :: over to that plant, we have our spent fuel stored on-site. and rll ta!k more about that in a moment, and we se Raich Sargent. m the background book Iand n tne oegun the process of cecommissoning. So we are l

12 i

f i

l actrvely invorved an the suoject that we're ta! king about Fort St. Vrain Provides Some Lessons today. One tning that rm happy to note is that we nave been mucn more successful in managing tne True. Fort St. Vrain was unique. 't is also true that my defueling and decommissioning of the plant than we comments today are specific 10 cur Fort St. Vrain were in managing the operaten of the plant.

expenence, but I think that we've teamed a lot in the Fort St. Vrain expenence that is applicable to !ne Fort St. Vrain's Removal From Rate Base

.ndustry as a whole. I would also celieve that the two years that we have sDent in discussion with the NRC l

!.et ms give you a couple cf cntcal dates because !

staff and the NRC commissioners has provded an i

thinx they're important. Fort St. Vrain was a 330 cpportunrty for not only Pubic Serv.ce of Colorado but

{

megawatt, high temperature gas-cooled reactor. and it also the industry and the Commission to ??am a lot

• ent into commercial operaton in 1979 11 had a very about the decommissioning effor1 that tne industry now I

unstable operating life and by 1986 we had a faces.

tremendous amount of pending trtigation against. Pubic Service Company claiming tnat in fact the plant was Fort St. Vrstn's Defueling and Decommissioning not used and usetut and shoud be removed from rate Cost Estimates base. In 1986, under an ac eement wrth the Pubic Utitty Commesion and t-Ottice of Consumer From your perspective, one of the things that you Counsel, whicr is the cons er advocacy group in should be concerned about is the adecuacy of the Colorado, we cc decce to re eve Fort St. Vrain from defueling and decommissioning cost estimates i

rate base ano at that time tock a $200 million pretax Unfortunately, we fell outside the guidelines wreedown on that facility. Ninety-five msIIcn [oollars]

established by the NRC because we were a high of that was set aside to cover the eventual cost of temperature gas-cooled reactor But estimates are still cefueling and decommiss ening.

tmoortant.

~ t Now once again we find Fort St Vrain to De a uncue My numbers will drtfer a irttle from those that Jim story The future costs associated with Fort St. Vrain.

Cumss gave you, because the numoers that t want to as a resutt of removing !! from rate base were put on give you are in net present value terms. When you the backs of our investors as opposed to being costs look at estimates, you know, obviously if they're that would be covered by our customers.

Current year estimates or future value estimates or net present value estimates, you will get slightly different The Early Stages Of Decommissioning Planning

r. umbers. But the estimate that we had for defueling and decommissioning Fort St. Vrain in 1991 was $209 i

We knew at the time that the 595 million for the millen. That was a net present value; Recognizing cetueiing and decommissoning was not going to be that the work was going to be pertoimed in the year adequate, so Derween 1986 and 1988 we aggressrvely 2043, we escalated our costs at SA percent and we pursued the planning that would be necessary for the discounted those costs back to 1991.

eventual defueling ard decomrnssioning of that plant.

Clearly we were earty in the game, this was poor to the Now the reason for that, I would ask you to remember NRC rules and we knew that we had an awful lot of that we were not in rate base and we had to take a work ahead of us. Paul earlier disOJssed the fact that I liability provision to pay for the cost of defueling and once told him this story and made it sound fun. In decommissioning. As was mentioned by Jim, the some ways it was fun, it was like putting together a future value on that decommissioning was $2.6 billion, huge jigsaw puzzle trying to figure out the necessary that's more of a writedown than we were able to take.

components that would allow us to do this activity We dd recerve some accounting permission to do the successfully.

wntedown on a net present value basis. Now the way we established that liability provision was, in 1986 we By 1988 wo had erough information to augment the took the first $95 million, in 1988 we took the additional liabiitty provison for detueling and decommissioning

$64 million, which rve talked about, and then between and we took an addrtional wntedown of 564 million.

the years of 1986 and 1991 we took net present value Then on August 29. 1989, we made the decision to adjustments on a quarterly basis, as we moved permanently cease coeratens at Fort St. Vrain.

forward in time approaching the date that we would do November S.

1990 we filed a proposed the work, which totaled $50 million. And that brought

'1 oecommissioning plan with the NRC. and we our liabilrty provision to the $209 million. And we had a anticipate the approval of that decommissioning plan match, defueling estimate of $209 me!! ion and a liabiltty from the NRC sometime th:s rrentn.

provision of 5209 mittion.

i l

13 i

t FS Cc6eraco's Strategy sgn:tcant advantages to decommissoning eany We Cne et me very impenant plann ng aspects that we were able to convince them to Ine point that tney approved the recovery of the $124 milhon cost i

uncerwent with Fon St Vrain is mat we cecicec eany ddferenhal anc that, tottunately, has allowed us to on that we woud never coerate w:th a single af an trove forward Startng in 1993 we wdl recover 513 9 Every pian mat we nac for cefuenng cecommissoning maicn a year from our customers also nad a tackup pian And tne cacxup plan ter the SAFSTOR cotier ancn was our er g:nal intent was the early DECCN o!an SAFSTOR vs. DECON in 1988 we contracted with the Becntei ongancaten to Let me talk a httie brt aoout the acvantages anc ccme in ano do an estimate for us. trying to cecce disadvantages of SAFSTOR versus DECON, trcm cur j

whether or not the technology was avadable to oc the very specife perspective. First ct all. the advantages decommissoning of Fon St. Vrain in the 1990s. We of SAFSTOR. this was our anginal thought. the were concemed with two inings, tecnnecgy avadabutty acvantage seemed to be future tecnnoegy. Given the and whether er not there wouid be an ecorcmc impact SAFSTOR opton, you have saty years for the ircustry i

to develop new technology for plant decommissoning to us rf we did the work eany The mictmat en we received from Bechtel gave a s the encouragement to This seemed to us to be an advantage that we sort of i

then send out RFPs to mact organcatens wort rwice wanted to hold onto. From a saiety perspective. we were actually safety neutral between the two optons l

tor a fixec-once contract bid to cc ine Safety is a entical issue in the defuehng, cecommissioning work on Fon St Vrain us:ng the deccmmissioning of a nuclear power plant and even l

t DECON approach After receiving trese bids we

• ere very enceuragec to find two very imocriant thougn the sixty years provices some radiation cecay pered. from our point of mew. saf ety was going to be a l

mings. One, it was clear to us tnat tre technobgy was pnmary issue a' e

, we neutral between the l

avadable today to do early decommisscning and. two, irroortance of safe.,

se r*o cotons.

we had tremendous economic comfort estabhshed from tne fact that tnere was a very narrow scread Disadvantages of SAFSTOR, and I beheve that tnis between the five bids that were actually subm:tted to was the more important issue from our point of view, i

i oc the decomm:ssoning work, again. on a fixed ptce first of att, SAFSTOR requires the continued i

casis. In 1991, we signed a contract mth possession of the part 50 license. which recurres a Westinghouse to ao me f!xec-prce ceccmmisscning plant that is in that SAFSTOR pered to maintau all i

fcr me Fort St. Vrain ctant.

monttonng, surveillance and fire-prevention equipment.

1 ard to keep a certain number of licensed staff on site Now, one of me imoedant consceratons on this was for that sixty year perod. Another disadvantage to

(

remembenng that we had a habd:ty provison set asde SAFSTOR was the unknown changes in the regutatory l

at $209 mdFon, whch. again, was the SAFSTOR environment, and here we were assessing this from a cotion on a net present value casts. The 1991 business nsk. ooint of view. Not knowing what estimate for coing tne DECON option. early regulation on eriher the state or the federal level would decommissoning, was $333 mdlion. This provded an be in sixty years was a business nsk that we were ecoremic ddemma for us. The d:tterence between the urtwithng to bok forward to. Another change has to a

(

5209 mdhon that we nad as a liabihty provison and with the increased cost of low-level waste. You've mat current donar estmate of $333 mdion was $124 million. Now that $124 million coud not be covered heard from both Victor ard Jim that the escalating trom a fund that had oeen set asde because we shut costs of now-level waste is a cntical factor in deccing l

cown prcr to having a furd that woud navo been set unether or not to decommission early or go into a SAFSTOR pered. This was certainty on our mirds as l

asce tc cover mose costs. Our enry choce, if we were we looked at what we anticipated !ne escalaten rates i

going to proceed wrm the early decommissiomng on low-l? vel waste stcrage mght be in the future. The coton. was to go Oack to tne Pubi'c Utihty Commisson last disadvantage of SAFSTOR has to do with labor and ask for recovery ct that $124 mdlion from me customers that we promised in 1986 would never force. It was not an unimportant issue for us thinking again have to pay for future ccsts of Fon St. Vrain.

about having a labor force working on the defuehog and decommissioning of our plant that had no actuat C earty we were faced with a very citiicutt cresce. We plant expenence.

And remembering that the wanted to go wrth eany ceccmmissioning, Out we had SAFSTOR option would have allowed us to

$124 mdtion cest prcbiem that we neeced to nave decommissien mat plant in the year 2043. rt's safe to ecovered 1

say that we have no current workers at the plant who i

woud stdl be with us in the year 2943 actively invoNec l

Long story sncrt Ae were acie to convince the Puche in tnat process.

ahty Commissicn et Octoracc nat inere were j

14

4 Now, adva3tages et earry Ceccmmissch:ng, From a tnat wcLc nave rc future value Weil as tne ster <

1eCnnobgy point -

tew *e Da0 received assurance cl3yeC oui. *e were not acie tc resoWe our iss;,,es w;;n from the bcs that

Deen submntec Cact to us on

!cano. we were adle to Ccmptete anc license me that plan tnat the :cnnology was m fact avadable storage ta: day on-s:te. and wnen n came time to ce:uei today and we were comfoned in tne worx scope that Fon St. Vtan the fuel went cire: tty trom the rea tor was defined by the ecs that we recerved Again. we core to our on-s:te tacdriy. All ct ine scent tuelis row were safety-neutra! Derween the r*o clans From an stored at our on-sne f acdrty Now in tne future n is stdl economic perspective the Dig acvantage of the our plan to move that fuel to icano. From there it *di DECON coton was that a recuced tne Dusiness nsk of enner De reprocessec or stay in Ine tCano tacdny As a an urwnown tuture ! recuted the fear of deahng w:th Oacxup pian to Inat. we wdl keep the fuel on-sne ur.t.i :t ang-term bwdevel waste costs. We could defuel and can be stored in a federal reposrtory And the cate of cecommissen wrth an expenenced worktorce anc. as a completec federal reposticry is stdl anyone's guess stated by tne Pubhc Utd:ty Commisson in Coloraco.

We currentty anticipate that tnat repository wout te we were not pusning tne preciem off to a future generation of worxers avadable in 2010, assuming that we get in hne ngnt now, we think that we'd be able to make sn:cments to tnat reposnory by the year 2020.

Fort St. Vrain's Spent Fuel Storage Plans Fort St. Vrain's Low Level Waste Plc.s And Costs Let me talk specif.cally r.Dout spent fuel storage

,d low level waste When all was said and cene. id Let me tak a Irdle bit about low-level waste because i taking into considerat.on the fact that we dic hav e a tn:nk that that remains the crrtical issue. We are j

.. fry sign.ticant economic issue relative to gening currently shipping our bw-level waste to the storage r:covery on the $124 mdhon f rom the Utihty sne in Beatty. Nevada, and the cost on that 's between Commiss:on. I inmk mat the crn cal issue ter us was

$36 and $40 a cuoic foot. Stamng the first of 1993 tne std! the handhng of spent fuel are also the low ievel Beany, Nevada, facihty wdl be closed down, tertunately a aste. And let rne tell you a fritte brt about that story the Rocky Mountain Compact has,cined forces witn a s a ptayac out the Northwest Compact and we have a contractual arrangement whch albws us to sh:p our waste to the When F:' St. Vrain was enginally buitt and put into Nonhwest Compact at Richland, Washington. It is our operator we had an agreement wrtn the Department understanding today that the costs for stonng fuel in of Energy to store our spent fuel in a fac4y buitt in Rc' hland, Washington, will be, again, between $36 and Idaho. Now we were under a centrac:ual agreement

$40 a cubc foot. Contrast that with the costs at the with DOE tor the storage of that fuel. And that faciltty Barnwell f acihty, which we understand range trom $66 was built :pecifically to house the Fort St. Vrain fuel.

to $286 a cubc foot. Now $220 of that $286 is a So as we approached defueling we fett comfortable surcharge for utilities who are outside that compact that we had that problem solved Shortly after t- ' plant area that need to use that facihty as a storage ta:Aty.

was shut down, we recerved a letter from the G. amor Let me put this in context with our estimate. We of Idaho, Cecil Andrus, who notrfied us that -

ear currently estimate the cost of stonng low-level waste a' fuel would no longer be wek: cme across the tc der

$140 per cubc foot. So we have plenty of room in ou-into Idaho. We immediately entered into ong.ng current estimate for the escalation et fuel or et low.

htigation wrth the State of Idaho trying to resolve :ne level waste, again, wnhin the narrow time frame given issue of whether or not we would be able to move fuel the fact that we are decommissioning the plant by into Idaho.

1996 The volume of waste for Fon St. Vrain is estim:ted to be at 140,000 cubic feet, so wrth that kind Now, at the time our O&M ccsts at Fod St. Vrain were of volume, obviously, an escalation in those ::sts in the neighborhood of $3 8 tc $4 mdnon a month 11 would be significant we would have found ourselves in prolonged delay perods in being atVe to ship our fuel as a result of the Summary Of Key Points defuehng activrties, we would have found ourselves paying that $3.8 mdlion a month for some indefinrte Certainly there is the economic decision of an eany penod of time. Our backup plan was to build on-site shutdown. Fort St. Vrain led the way on that decision an independent spent fuel storage facdtry. The cost of Another point of corcem from the investor communny that, whch we included in our defuehng estimate, was ought to be the accuracy and adequacy of cefuehng

$20 milien. And many looking from the outside in and decommissoning expenses. The good news trem figured that that was a $20 mdlion debacle. They the Fon St. Vrain perspectrve is we were able to do cur figured that we would be able to resolve our idaho defuehng on oudget and ahead of schedule. We are issue and what we would end up with was a $20 currently decommissioning and, as Commissioner mdicn concrete monoisth On the sne et Fod St. Vrain Cumss indcated, there are certain actrvnies wncn an 15

l 4

De done in agreement w*m the NRO pror to tne actual imponant to Ancw whether me> are mings to, be receipt of me NRC cecommissioning c:an We are concemed about er not.

wormng wrtn those issues. We are anead ct cur i

onginal scnedule and. aga:n. we anticipate me Witn that as a istile diverson. 'et me inove on to Jee approved plan fater this montn We are en schecute Wamoond to tell us about the cace of SCEcorp So for completing our decomm ssoning by 1995 Tnereis tne cecison wnich m!! be a site-soecit.c cec:sicn as Cat. Ed and the San Onctre-1 snuaten to whetner or net to go DECON *nich is the eany OPENING REMARKS OF MR. JOSEPH J.

cecommissioning route. or ic go SAPSTOR There 's WAMBOLD, MANAGER OF PROJECTS, an issue of spent Ne< s:cra;e anc me avadaDMy ct a SOUTHERN CALIFORNIA EDISON COMPANY i

federal repository and mere is the issue wr'cn we nave all tourned on wnich nas to do min me escalaten of JOSEPH J.

WAMBOLD: 1 na: lust a couple of cw-level waste ovemeads I'll be putting up. Out first just to get some context to San Onofre site. As Paul has mentioned.

in answenng me cuest On snouid msestcts ce we ao have San Onofre Un t 1 SONGS-1). whch he's corcemec about the nsing costs of cecommisscning emphasized, we 11 be closing that clant at the enc of nuclear power plants. my answer would te this' I

this month, but we con't plan to do active t.eheve that the investment ccmmunrty shoutc be sery concernea. And stay very knowledgeable about the cecommissioning on n unt:1 in concert with the two

<ssues impacting the cecommissioning of nuclear other units that are on that site. San Onofre-2 and San Onotre-3. Edison also nas a 15 8 percent share in the power plants in the U S.

However. rt nas been cur Palo Verde nuclear site in Anzona. At this point. some ex::enence in the cetvenng anc cecommtssanmg et of this, rm sure will be a recap or a restatemert of Fort St Vrain mat mese issues can ce successtuuy some et the things you've neard. mayDe with a slignt!y mana;ec in a way that prov ces an ecuitable scrution def erent percpecove for bom customers anc msesters.

First, just some definitional issues regarding P AUL P ARSHLE'r ~ hank you verv much Ra'ph decommissioning, it would be imponant, i woud tninx Betere movmg en to ;ce Wamocc rd Me to read to tor the nvestment communrty to carefuity consicer in

=

you cuckly trem a recent ecmon et Nuc'ecr'c Week.

each case what is the planned snutdown date for any given plant or plant site and how that relates to the Decause we've heard a Ocuote et different 1:mes aDout decommissioning collections that are taking place.

the escalating costs of low-level waste. and :: mignt be neipful for you to understanc what me impact of that There is some conservatism, or tack of conservatism.

can De. The article is aDout a public power entny but n that can come into play on those assumptions and, as rti srow you later and talk about a little further, for our applies equally well to some investor-owneds tnat San Onotre 2 and-3 tacility, we're making were also narned. "The scanng costs et !cw ievel cecommissioning collections over a 30-year pened radioactive waste disposal coupled with uncenainty ard have a planned shutdown date of only 30 years of about DOE's ability to take Dossession of commercial spent tuer -- smeming else we've heard aDout here operation. So, because the collections are advanced in that way, that's a more conservative posture and tocay has prometed the Omaha Public Power tends to counteract any potential of premature District to nearly treble the cost estimates for shutdown to sorne extent.

cecommissoning their Fon Calhoun plant." What th:s means in pracical terms, as the ancle goes on to say The Transition From Plant Operations To is that NRC's genenc recuirement, which Jim Cuniss mentioned earlier. which in 1992 dollars for Fort Shutdown And Decommissioning Calhoun was something hke $116-$117 mdhon has now gone to about $312 mdhon. That's in a pretty shon Also, the scope el decommisscning is a key aspect, and that's been touched on by some of the other penoc of time. Inrtial estimates were estachshed.

panelists. One riem we've identified is to look carefuuy prcDanly, in 1989 and so rt's a pretty steep sicpe. It

• di be interesting to know where rt goes from here at the transition from an operating site into a The same is true Mth Yankee Rowe, where the $100 decommissioning srte. We foure that in some cases the estimates are done by different groups. As you million estimate that is now $240-5250 mdhon. also, can imagine, and as we're facing now for SONGS 1 has been escalated rather quickly. I think Jce Wamoold may be going to say something about wnat you dorrt just one day drop from full cperaton ano the i

next day be into just the decommissioning mode or just mey see going on at SCEccrp that will grve you some the SAFSTOR mode. There are some significant costs more evidence alcog the way nere So we're ta: king dunng that transrtien penod that nave to ve carefully 3

aoout some race!y.ncreas.ng ances and so :rs conscered.

i 16 1

1

"How Chan is Ckan?"

The level of rescual contaminaten is an :ssue that Figure 1 was toucned on earlier ey Commissener Curtss This KEY INPUT VAR 1 ABLES is 'now clean is clean?" What will be recuired by the atterent regulatory bodies to know wnen a srte has Deen property decontaminated The current rue that LLW Disposal Costs apphes is a regulatory guide trom t!m NRC. Reg.

Guide 1.P6, that goes back as far at 373 and an DOE Receipt Of Spent Fuel issue to point out there is that at st time the recuirements in that reg. guce generalty were rougnty ecurvalent to wnat was the lowest level of detecten Contingency Allowance capacihty at that time. We are now in an environment where the bwer ievel of detection is a couple of orders Escalation Forecast of magnitude below that regulaton So you can detect contamination to a mucn lower level. And that raises Fund Growth Forecast the cueston, then. of how truch is going to be recuired by regulators to be cleaned up. Finally, also touched on was the noncentaminated faciltties. Beyord wnat is to any partcular need. The escalation forecast. How recurred by the NRC. wnat assumotions nas any utihty truch real growth is albwed for in eacn of the drtferent made regarding the dismantlement of the site includin9 decommissoning cost parameters: that is beyond lust background inflation. have there been allowances returning to green field kinds of concit: ens i mentcned?

That this is a technology area that may grow in terms of its cost laster than just intiation. And the las; Utilities May Have To Store Spent Fuel Onsite important assumption would be what kind of fund Longer Than Expected growth projections have been made wnere the cecommissioning funds are being collected? How Key vanables or assumptions that come into play conservative or aggressive have those assumptions been made. And that can also give an dea to how (Figure 1 outlines Soutnem Ca!rfomia Edison's key variables for decommissioning). Again, these have conservatrve the utihty has been.

also been touched on. Low-level waste disoosal cost, certainly tnat's Deen touched on, and I'll grve some SoCal Ed's Cost Estimates And Decommissioning examples particularty relevant to San Onofre on the Funding Plans For SONGS-1 next ovemead. The C esartment of Energy's receipt of spent tuel, we've talh.d a irtile brt about, the earliest Looking at the San Onofre srte, specrfically, in this that there would be a receipt in terms of a montlored case trying to grve you an idea of how at least our retnevaole storage, t'. is an intenm type of tacihty.

intent, ard we believe we are being successful so far, wouk! be 1998, wit a permanent repository not is to be conservative in our allowances, for the expected until 2010. : ;t pemaos trore importantty for cecommissioning needs. We are collecting our funas for the complete dismantlement and full-site many snes will be tna. the current projectens of how rapdly the DOE will take spent fuel once they start-restoration. So we are well beyond just collecting just ano of what will be the rate, leads to a lot of utilnies ior the NRC-bounded scope and are collecting funds row recogntzing that they will have spent fuelin their that are intended to tulty decommission the srte, which possession for many years. In the case of San of course wouid be a conservative assumption of wnat Onotte, even using row the most aggressive estimates the needs will be.

from the Department of Energy, we would have spent fuel on sne until the earty 2030s, about 20 years after Regarding our allowance for lowdeve! waste disposal.

we would have shut down on our current plant hcer.se in 1992 collars we're collecting in our turd for a pnce cases. And possibty as long as 2050. that we would of $330 a cubic foot, even though we know in 1992 nave to take care of spent fuel at the site rtsett netore dollars we were actually paying in the range of $70 a DOE would take receof cubic foot. But we were able to anticipate that tnat would not be a long-term stable pnce, that there were parameters in play that would force tnat cost to With these sorts of uncertainties. planning for increase. And so we've been collecting in our fund for cecommissioning should include the idea of a a 1992-dollar figure of $330 a cubic toot whicn.

contingency albwance. knowing in each of the utthty s although there's still some poss,cihty it could be sightly estimates how much pure contingency nas been ngher than that, that's certainty in a more conservative adowed, That :s money allowed that isn1 yet a'bcated range than some of the other assumptons tnat einer ut& ties have mace.

17

r i

We've useo a 25 percent contingenc!

~

?

allowance, tnat is just an accitional 20 Figure 2 percent on our estimates fcr unallocated SONGS Site AsumDtions types of groMn or enanges that wd! cccur in the years ahead-We've anticicated i

Complete Olsmantling And Full Site Restoration

.i high escalation growth rates in our estimate m excess et 7 cercent-well aoove antic:patec rates et mf!ation for Allowance For LLW Disposal t

growth in this ty1pe et a tecnncicgcal area Our fund growin assumptons on tne etner 25% Contingency Allowance hand, have been very ConseNative, in the area of 5-114 percent.

So, f the High Escalation Rates Assumptions coportunity is there to see less growth in the cost and to improve as inere now may Fund Growth Assumptions ce a distinct opportunity witn tne new natcnal energy legislaton to :morove the fund growth ocssibihties. that would also SONGS 2 & 3 30-Year " Operating Life" Assumption then lead to the assumptions we have made being very conservative. And. as I touched on How Clean is Clean Enough?

eartier, we are cotiecting for SONGS 2 and 3 over an Operating life of just 30 years...hch again leacs to The residual contaminaten issue is a significant one ~

more aggressive collectens and a more conservatrve wnere. :t the reguiatory process leads to a much lower posture in the cecommissioning tunc.

tregure 2 level of contamination being neeced to be removed summarizes Southern Califorma Edison's SONGS-1 that will certainly affect the cov and the amount of s:te assumptons for cecommissoningl matenal that has to be removed as a iowdevel waste as opoosed to just ordinary waste going to an ordinary l

Are there signrfcant uncertainties even when you are ad trying to take a conservative posture and also gett ng some very specific cooperation from our state Low Level Waste Disposal Ccsts Are Uncertain regulatory commission? Yes, as we've heard today there cenainty are still many signrficant uncertainties.

The low-level waste disposal and timing cost is a very ihe premature snutdown, as we ve seen for SONGS volatile situation. I've mentionec that we think we've 1 that s the type of issue that has to be dealt wrth and been conservative in recent years of boking at a pnce i

was not in our assumptions for our cecommissioning in the area of $330 a cubic foot. Let me grve you some collectons. On the other hand, the analyses that we idea of how that can be a very volatile dd and coordinated wrth our state commission, that srtuaten. The pnce structure for the operators of the was done on tne casis that the cecision to shut down bw-level waste f acilities has a high fixed cost up front the plant fully recogntzed that that choice was one of that they then amortize like a utility investment over the arrremental optons compared to how much more rt time. such that in the early years you see a mucn cost to run a piant anc wnat the oenefrts are of running nigher cost being allocated than in the later years.

a plant. The imoonance of that is that in the wake of We've looked at some cost profiles and we see that it I

decding to shut the piant down. the costs to keep rt in can get as high as $500 in the eany days that one of ts snutdown conc'!cn are fulty being recerved in rates' those waste sites will be open, cropping to as bw as

.>c that althougn it s been prematurely snut down, rt

$250 tater in its hfe. as they amortize off their fixed was understood in our interface with our regulatory m m h a g @W nW W n's a Me ccmmission that that would be a ratepayer cost. to amount of fixed costs that are being wntten off over the seep the plant m :ts shutdown condrtion and rt was volume that would come to the waste facility each analyzed accoremgty. The Depanment of Energy year. Unless there's some price stabilization effons spent fuel reced scnecule I've touched on that, that that are put into place you'd find where some years even with the safer start dates, perhaps even more where there's a bt of volume, the pnce per cubic toot imponant is the slower rate that rt is now anticipated could be drrven lower than in years wnen there's not a that they wou6c even ce accepting fuel, will lead t large volume coming to that waste site. So the pnce building fuel stcrage fac2frties on-site. as Ra!ph Sargent streams in the years ahead for these new low level has men!ionec. Simi:ar to Anat *Ney had done at Fort g

ggjygggg gg volatile in our view.

(Figure 3 lists significant uncertainties which Mr. Wambold beheves face tne utihty industry with respect to nuclear Olant jl decomm:ssonina-)

18

.\\

toucnec on ean.er. anc Figure 3 smwn n w mucn nas:ne casts terinat:Tnen SIG NIFIC A NT UNCERTAINTIES inrougn Septemoer of 1992aneacy ceen conecter Anc. as you can see.

eveence e I

conservatism. *nere aireacy tne Premature Shutdown marxet value of our fund is nigner inan the NRC

+

mmum aM stamng to well ascr0acn m the case cf. say, SONGS-1, in 1992 collars wnat wouia ce DOE Spent Fuel Receipt Schedule eW ssa And M ine last column. the annual ceninouten. I think you11 f.nc Regulatory Residual Contamination issue the money that we are currently authereec e collect in rates is sgnificantly nigner than any ct Low Level Waste Olsposal timing And Costs the other fqures you woulc see from cther utilities:

and our financtal people tell me inat we're aDout i

four times hgner than the average. So, again m:s Timing, Cost And Funding Of SONGS-1 is a very conservative posture in temis et unat I

weNe been allowed to collect in rates in preparaton for i

Decommissaning cecommisscning. Thank you.

Last, I have some specific figures to give some inacation of the relative conservatism.n our accroacn PAUL PARSHLEY: Okay. Tharx you.-Joe. WeNe i

to collecting for cecommissioning costs (see Table 5).

been heanng here about DOE's reposacry date oeinj In the left-hand eclumn. youll notice tne cesenstion et very uncenam aM probaW sicping. AM weNe aisc the d:tterent nuclear units and snes that Southem Cal Edison is involved in At San Onctre, our ownersnipheard from a couple of drtterent perspectives about Ine j

environment for each company because(

share is 80 percent in Unit 1,75 percent m Units 2 and 3, and then we have 15 figures are snown as.8 percent in Paio Verde. these :nfluerce the company s aDility to maten up with *nat

• #11 Edison snare.

So, some we see as umenain costs that couc be enanging cute anthmetic woud be necessary to get the full share for rapc%

each sne if you were interested in seeing those type of calculations.

You can see our authenzed estimate r,ecently the Florida Pubfc Service Commission sent a both in 1992 collars are then escasatM out to year of letter to DOE, I think it was in the medie of Octcber expenditure and IVe snown down Dstow what those and it was unanimously supponed by the members cf plant shutdown dates would be.

But as I've the Commission. And what they asked DOE to co.

mentioned. SONGS 1 wouldn1 actually be activelyand I would be surpnsed it they're going to be very decommissoned until in concen wan SONGS Unns 2 In the middle column 1ve shown the NRCsuccessful in their request, but it coes reflect their and 3.

minimum calculation which Commissioner Cuniss* view -- theyve asked that the utilities, and this.

point wou ce Florida utilities, be compensatec tor TABLE 5:

(Dotters in milHons)SOUTWERN C AliFORNI A EDtSON'S NUCLE AR NUCLEA ING ESTIVATES Authortred Estimates NRC Winimum Calculation

(

Collected Annual Plant

$s infear 28 so anyear of thru 9/30/92 Contri-1992 sa Ernand:

.2

.1122 _11 Ereenditure Mkt Va tuedutle n 1

San Onofre unit 1 (1 @ 4so WW) 190 1100 90 s00

-60% SCE snare 17s 18 units 2&3 (@ 1100 W W eacnl 620 4600 210 1400 375 63

-7s% SCE share

~

Subtotal SONGS 810 s700 300 1900 _

Palo Verde 1,2,3 ss0 81 160 2400 60-1000

{

(fp 13o0 Mw esen)

-16.8% SCE share 97 1s e

Grand Total e70 a100 360 2900 647 96 Pla n ned S r*Utc own Dates SONGS 1:

1992 Palo Verde 1:

2024

(

SONGS 2:

2014 Psio Verde 2:

202s SONCS 3:

2014 Pelo Verde 3:

2027

)

]

i 19

auditonal spent 'uet storage costs tnat *dl be incurred VICTOR GILINSKY-Let me ;ust say tnat the NRC Dacause et the unavadaDdity ct a repository along the environmental report says aner 50 years you have knes cf wnat had been contemplated back when the one-tenth.10 percent.

Nuclear Wasle Policy Act was first passed and then later amended So !nere are some essues here that oo JAMES CURTISS: R g ht. R g nt bear ccse monitorirq as *e 90 forward VICTOR GILINSKY:

PANELISTS

• FOLLOW-UP COMMENTS And i just ta"ned with somebody trom PNL who was preparing NRC's statement your new ccsts. and he thought that rf you get out inat f ar i

We now move mto me second pnase of the you mght now nave any.

anemcon's presentaten i apprec: ate your patience We're going to get to your cuestions in just a couple of JAMES CURTISS: The thing that offsets that. it l

moments. But I wanted to give each of the panebsts an caportunity to aod some additonal comments and seems to me, is that rt the pressure - and this is an issue that we're looking at this point in time - if there is to pemaps respond to thmgs that tney mignt have great pressure to drrve down the cleanup standard at nearc from other panel memoers. I m going to ask that they do this rather bnefly so that we do have a chance the site to a green tield conditon, or it there is pressure ter cuestions and answers, But let's move on and do to keep the levels at unrestncted use. rt may well be it at Vctor. do you want to ;o brst?

that matenals that haven't cecayed entirely that are considered below the low waste now and can be incinerated or what nave you, may increase -- But you Longer Onstte Low Level Waste Storage Might raise a fair cuestion about whetner there's an effect Lower Waste Disposal Costs that ottsets the sharply increasing cost that is attnbutable to the decay in the crcouct over time. And VICTOR GILINSKY Ny i nad cne cuesten ter em I haven 1 personalty cone any evafuations. We should Curbss, I guess He ccmmented that the overa'l cw-take a look at that queston.

'evei waste disposal ccs; wou!C Oe going up sign:hcantry if you waited. And I wonderec whether RALPH SARGENT: Actually, maybe it would be a in:s taxes into account that the amount ct the waste good time to pck up on the questen that Jim Curtss ad! be coming down. In 1act. If you wait several was going to keep passing on down, and give you decades, it's down by a tactor of 10.

And the some basis of the 140,000. The 140.000 cubic feet of escalation is compensated by the discouchng c1 the waste that we are estimating is based on doing the money. So I wondered about that. One other decommissoning under the DECON opton or doing rt coservaton before you respond. I notice on this chart.

by 1995. In the radiation analysis that we did poor to I tnougnt rt was really interesting tnat the Shoreham establishing our estimates, what we concluded was cecommissionirg costs are up there with the rest of even though there is significant radiation decay that them and, in f act. exceed orginal eshmates or at least occurs within the first 60 years. the real decline that the prevous statt calcu!aticn When Shoreham was a plant that hardly was contaminated at all ! mean rt just you would achieve in terms of getting to the point

• nere you had no radiation left or enough radiation barely got started.

And that strikes me as an nteresting po et. You may nave some thoughts about decay so that it made economic sense to delay aidn1 inattoo happen until about year 100. So the interesting noten here is the 60-year period. True. there es radiation decay that takes place but there are stdl racioactive JAMES CURTISS Okay. Actually, the cueston tnat elements whose hatt irte takec them beyond that 60-you raised. the cesersation you made, which is that inere is some potential for decay of low-level waste, year period and Inose were the ones that were creatirq some d;tficulty for us. I think you would also pemaDs to the point where you mynt not have as hnd that the 140.000 cubic feet from the Fort St. Vrain mucn to dispose cf and hence the Cost r~ay be iower was one I was gorrq to tum to Ralch and ask. His estimate would be significantly lower than what you would see in other plants. One of the aavantages of estrmate of 140 000 cube feet. How did you treat that the high temperature gas-cooled reactor was that it cid

n your assumotcn abcut decay over years Because i resutt in a relatively cleaner plant than what you would have been assur mg tor purDoses cf the low-level hnd with other technoiogies. And so our cubic feet of waste issue that yout essentia!!y have. unless you raccactrve matenal wound be less.

extend rt out over 60 y':ars, you'd essenhally have the sarne amount of icw-ievel waste that you'd have to VICTOR GILINSKY: Let me just say a word about inat 1socse of 50 or 60 years. That basically was picked on the basis of the decay of elements like cocatt-60 wnich nave a haft 1:fe of about five years. And so if you ten har lives.

' hat's two to the tenth and anycne wno deals

• th M

T i

computers knows mat s 102

'c you re ccwn oy a

.n ra!es t;r 'ne clant m snLiccwr 2reOn e a.

Tactor et a thousanc. Anc ath at m rgs s:cw oown teast there s a case *nere tre e-xn:rcs aere.c.c ec i guess rm trore surpnsec aDc me r.urcrec years at m ac::rocrately calance: :asn.:n am. e Cor*%ss,Cn ! "'.mL gener% treatec s :a;ny /. c -

RALPH SARGENT: it wasni tne cca. %nt i was

cunte ratarcec any ciner ctmen re 6, m,g-Ine cesium Anc 9Cf Deing a nuc: ear en,s,cist *e are ia',e nac IO tr, to Ocnt.nce :0 :Derate w 3, ant wre -

ciearry out of my area But the stucies I"a! were c0ne me ecercmics Ocn't justfy :

gave us a feeling mat tne nuncrec year cenoc wouc be a significant reaAmg Ocmt ?:r me remaanmg PAUL PARSHLEY 3ay "w mai s a ta r :cr.

raccactmty that we ^ cc brc at Fc-St Vrarn Tnere s one area wrch we.e stare: w ng a: oren ts a 1ttle cit narcer to get f ur arms at:unc

.n me Shoreham Decommissioning Costs San Cnctre case, you nac a scec:nc event inat was tnggenng a PL!C review. d ter emeer ne s.tuaten JAMES CURTISS. Let me !ust say a word about tne

=rrec!ty question about the Shorenam esumates Two comments there. One, in the numbers tnat our stati JOSEPH WAMBOLD: We nac cr:ocsec 5125 mmen has taken a look at anc that are rettected here. we wcrtn et investrnents *) De "'e fmal LDgraces 10 cnng obvousry nave less detail m terms et the creakdown of mat f acility in ccnforman::

"th rnocein cay MC wny rt s costing wnat rt's costing there. You will see. in stancarcs fact. very trttle explanation in tnose numoer Seconcly.

artd this is more of a nunch than it is a conclusion.

PAUL PARSHLEY So. mere was a s.gmt cart :ac.:a-Decause of the criargement that's been reatned in tr'e

nvestment Inat was inggenrq the recew ?

case of the Snoreham f acility, wnere tne decommissenmg is going to be cone Dy a citierent JOSEPH WAMBOLD: Yes, Inat !s xrre-!.

entity rt's not at all c; ear to me in terms Of how the costs nave schec out up there yet, wno's paying for PAUL PARSHLEY: The more d:fficu:t srtuations ter what to be donc and now mucn they are paying. And secunties anatysts, I think. are the ones *nere you it may be tnat unen that's lookeo at in more careful have plants tnat don't realty have that incremental cost detail, trat well have a clearer sense of why those hurdie to clear, tha* triggers a review, but instead inere numbers are Ice tnat. But. Victor. I inink. makes a is more of an ongoing situation wnere pernaps the good point. Tne facilrty was not operated for any daity operating cost or a nuclear plant are now iorger significant lengtn of time. In f act, rt was onty operated. I as corroetrtive as they were perhaps or actually ngner think, for two ettectrve tull-power days. And hence inan some conventional fossil plants. And in tncse ought to be ws: ocntaminated arc therefore less of a cases. it's not as easy for utilities to get tne reviews ;

cost to oecc..tr.sson.

think rt depends on a state by state casis anc me aggressiveness of tne local puolic util:ty commisucn PAUL PARSH'.EY soe, you got to go last here Did Ralph?

you have anytnng mat you wantec to add?

Managing The Downsizing Of The Labor Force As The California PUC Has Treated So. Cal. Ed Fairly Plants Arc Shutdown With Respect To The SONGS-1 Shutdown RALPH SARGENT: I do want to make one acc:tional JOSEPH WAMBOLD. I wouk3 make one coservaten.

comment, which has to do with the lacor torce The comment earber that utiitties may be motrvated to Generally in these discussions a lot of attention is continue to operate a plant even when it may not be given to the technology and to the fmancmg c-economically appropnate, of course. there's a very decommissioriing one experience that we hac ar strong counterbalance in rnost cases, particulany in Fort St. Vrain, when we staned, or actually when we Cairtomia. I can say there is, that the public utilities made the announcement to shut down, we had a werK comm:sson offers a lot of scrutiny to see what is the force of 520. We row have a work force of 65. And so taasts for utiltty dec:sions And SONGS-1, I think, had it was very important for us to manage the downsong some of those features where even though the utility of that labor force. What we found was that nuclear was concerned both aDout rts unamortized capital employees, although they work for a utility, tend to investment ar3 the not yet fully funded want to remain nuclear worxers. They are welltramed.

decommissoning, nonetheless the process that to M they are specialized in that partcular area. And given place in that state got all the numbers out on tne ta:

the announcement of a shutdown of a nuclear facil:ty.

It was at least fairty anatyzed in terms of what were e many people working in that nuclear plant would want appropriate obr.gations of the ratepayer and. a-i to move to another nuclear plant as coposed n stay mentoned earter, we are a!nowed to continue to collect wrthin the utility inat iney're currently emocyec What c1

tnis recuires is partculany for a singte site nuclear facirty to pay very close attention to managing the the safety Questens And in some of these cases.

work torce and managing the cownsizing so that you including the steam generators at Trojan the tecnncal

'ecuirements at Southem Cal Eoison, the Yankee con 1 prematurety lose the very worx force which is Rowe issue, which got a lot et visibility, _the essential for mamtaining the hcenses that you have Commission was very active in taking a look at the estachshed with the NRC. Througn the downstzing tecnnical Questons and I expect as we see the plants e f f o rt, actually tnrough ine detuehng and aging, we will contmue to see an active Commission decommissioning at Fort St. Vra n we only expenenced a 5 percent attnten That comcared to a interest. It may in fact precct: ate discussion of these 10 percent attnton inat we had cunng the operaten of issues as utihties look at what tney need to do to the plant. So for us. :t cc not tum out to be problem.

comcly wrth the continumg tecnncal recurrements anc but I would hke to let you krow that we spent about the financialimoact therect i

two years putting together a human resource plan to Rate Treatment For Fort St. Vrain Dismantlement manage the downstzing actrvrty. And I thmk rt's a very important component Ct the wnole snutcown activity of QUESTION: With respect to the recovery from the nuclear power plants tnat will nct get the suthcient attenton that it may need.

Coioraoo Public Utility Commission of the $124 millen tot early dismantlement of Fort St. Vrain -- which PAUL PARSHLEY: Ckay.. thmk at ims comt we actually seems to be in contradiction to 1986 ougnt to go to your cuestens. Lers get staned ngnt settlement between PS Colorcoo and the PUC which removed the plant from the customers' responsibility --

over here.

what were the compelling reasons that were used in QUESTIONS AND ANSWERS reaching that negotiated settlement.

j RALPH S ARGENT: Two answers to that One. It dd Technical Decommissioning issues not turn out to be an economic decision, quite honestly. The Commission continued to take the QUESTION: The panel has talked a lot about the ecorome consideratens that lead to the snutoown of perspectrve that the investment enginaFy in Fort St.

these f acilities, aren113e techncal considerations Vram was a decision that the company made, the eaualif not more imcenant, and what is there -- what operating history of Fort St. Vrain spoke for itself. I believe that we were most effectrve in our argument is the consensus of the Nuclear Regulatory based on the discussion of advantages and Comrnsson, :s there a debate, is there disagreement over what the techncal controversies are?

disadvantages that I went through of SAFSTOR versus DECON. The difference for the two from an econome JAMES CURTISS: I guess in my judgment I see perspoctive was that we had sufficient liability provision to pay for the SAFSTOR. We needed 5124 these two issues going hand in hand. If you take a look at the plants around the country that have shut million to proceed with the DECON option, and for all down, they in some cases have done so at the time of the business nsk uncertainties that I talked about, that major technical questions have faced them. We the Commission agreed with us that it made good heard about the expenence with Southem Cal Edison, sense to approach the decommissioning as quickly as where for San Oncfre 1 they had major upcjades of a possible to avoid some number of business risks that caprtal nature that they had to meet to come into would be out there in the future that were too numerous to quantity. Now, we did have to give up comphance with the NRC reouirements. And that, I certain things to reach that settlement. It was a think, was a tactor in their decision. Trojan, for negotiated settlement and there were comportents m exar ele, was lookir9g at the possibility of r".afor steam generator replacement, which in tum is a financ.at that settlement that we agreed to which impact us in l

ouestion for them. There are others around the future rate cases. So it wasn't a giveaway, let me put rt that way.

country of that nature as well. Yankee Rowe, of course, had a mator techncal queston about the OUESTION:

So, the Colorado commission it!!egnty of the vessel. that in tum was f actored into their financial anafysis. So the observation I guess t'd determined rt was better to pay a little more up front, make on the first gi;eston is that in the cases that and avod the uncertainties of keeping the waste onsite for a longer penod of time?

w4ve seen to date, these plants have had technical issues that have ansen and in the context of the RALPH SARGENT Yes it was one risk opton that financial analysis have oeen important tactors m their overall assessment. The technical tssues w: thin the we coulan1 quantity versus a nsk opton that we could.

Commission. withm the Agency, of course that's the sum and substance et our responsibihty to focus on 22

Tne Cost Of NRC Regulaterts

_rcer 4 3, 2: *ne Agercy :

T, 2 a: east mare L e I

mat *e are <macsmg ccsts recessanly OUESTION:

~c anat ecent na,e NRC regwancns

mext :f emcec resources a:

ese p;ar:s ae m

c: aced too mu::n eccnomc Durcer, en eecirc utmt:es ecc;nce :9at rescurces cee::ec : cne issue are m c0mparson tc tre cenefns ic cuosic neaan anc taken awas *r:m anc:ner Pc :: Tsan c:ena~

Eatety ?

xncern l

JAMES CURT 1SS; <cu re cucn:rg :n an :ssue tnat's The in.rc acmt ! guess fc mare.s nat m ax.p;r ::

ready been at me nean of cscussion nere in tne cast inat the utWties are rcw sia : rq n.nx :o recogni:e couple of years as the utmties :ncustry is ccking at anc tocus en the tact inat ::.**erent at es resacre m the prospects ter Dr.nging on new case cao cacacity NRC recurrements chtf erent!y Anc in f act. ims s to meet cemanc. Tne tatler part ct this cecace arc exactly the sucject of a recem gainenng ct :n et eany mio tne nen cecaoe arc it s in pamcular an issue executme crticers anc tne arnual APO ccnteren e that s gciten a ct et attention Decause there s oeen a mat was concucted wnere 'ney te cegmnmg 1:

crossover in nuc: ear O&M excenses with coal O&M recx>gnce that new a uthty resacrcs to our regu:a::ry expenses in tne tast couple et years. with nuclear recuirements vanes wicely. Anc sc if you locw a: :ne exceeding coal. That together w:tn the tact that we've

l ants in terms of their stattirg,eseis or tne

r C&M seen cases in the last year to two wnere plants have expenses, cr wnat have you, for essentally the sarne snut oown prematurety acng witn tne pencing Icense set of regu atcry ucuireme ts. :nere is a great ceas et renewal consderaten that some cf these utilrties are vanaten w: thin cuegones et pertermance Arc ! thirk evaluating nave all orought togetner at this point in you'll see a great ceal of trcre aggressrve at'enten n ame a good deal ct ciscusson anc cecate et ust that

nat front. "How oo we as an incustry" if Wu *dt.

l ssue. Let me respenc to it maMng r*'c Demis.

responc to regulatory requirements ard are we ccing 1

t m the mcst eficient manner? Arc I wouc exce:t Frst. whars naccenmg cut there? i do teirese that inat a ccmomabon cf the effcrts at tne Agercy as wed you saw cunng tne 1980s an escalaten cf O&M costs as tne er' orts unoer way wrtnin Ine ircustry are gem; carte ocoous ngnt after tne Three Mile Istard acccent to contrue to lead to a flattening ci that curve.

with requ:rements Inat the NRC imposeo anc it conunued en into the mid-1980s. We nave seen some PAUL PARSHLEY: Anjoocy e:se on tnat one?

fia:tening of the curve. And pamcularly for the good performing plants, we see some sgnifcant reduction JOSEPH WAMBOLD: I wcuc just mayoe etaDorate et O&M exrenses. They manage to keep their O&M that INFO at the conference Ccmmtssioner Cumss expenses c ite low, first, and I thinK you're beginning mentioned, atthough not conclusive. tney dic shcw 1c see the C&M issue on the nuclear sde settle ou-cata that tended to indcate that atinough their m ssen Tne Utiltty Data instrtute. for example, does thet pomarily is excellence in coerations, that they've evaluations on a yearly dasis and there's som.

identified plants that have excellence in cperaticas nattening ci that ircrease.

also tere to have excellence in cost also. So it tencs to counter the impression that ene mgnt get that INPO Secordty, we co have procecures in p! ace. they may is just deriving lots of things to co without any not be as effective as some would like, to evaluate the balancing in the cost. That doesn't appear to De ~

imcact of aodrtonal requirements that we impose on case from some of the data they snowed last mom:

the utilrty incustry. They're called the backfit analysis, if as I understard it. Also, I think rrore recently the NRC.

you w.ll, that recuires us to assess the cost ard the nas more consistently asked for teecback trom tne Denefits of those anpacts But beycrd that the Agercy industry in areas where tneir regulations may not be e currently uncertaking wnat I think is a fairly cost-effective or cuplicatrve. and I think there's son ct agressive anarysis to bok at things tnat pernaps are been an open envitation at this point for tne incustry to niarginal to satety, rt you wdl Recuirements that we've provde input a' ng that hoe in responsible f asncn.

e posed over the years that have grown up and t xisted and perhaps at this point we need to go back Nuclear Costs Outside The U.S.

tod reexamine. And that's urder way at the Agency.

QUESTlON: Are the nuclear power programs in Eeyord that, the Agercy is taking a lock at whether Japan and France expenencing simdar growth m tw tr 're are atteman.e ways to look at the regulatory level waste cisposal and spent fuel storage anc o%ectives Inat we nave, emphascing less prescnotrve d:sposa! costs?

requirements anc mstead emphascing or codifying the cojectives or goais that we are seeking with greater VICTOR GILINSKY: I nave some thoughts on tnat Henbd.ty or tantuce ter the hcensees cn how to meet when you're ta: king aDout Jacan and France. France those Anc so :nere are a numDer et things that are of course :s mucn more heavdy nuc' ear inan Jacan i

2.3

i they are toth ccuntnes *nere cusiness anc govemment, pancu:any utdities anc gcvemment. rnore cr something hke that. anc make the r" cst cptimist:c assumptions, W hic h "' e n can ieac to a cr less merge. These are -- certainly in France -

nonconservatrve collecten stream.

tascally govemment programs. And you oon't have the same competitive winas that you co here in any case their octens are d:'terent too. h isn't nuc ear So. if I undersund your cuesten - and. I touched on power versus ccal or gas. !!'s versus cel the answer in my remarks - at So Cal Ed. I beneve we are on the very conservatrve enc ct that spectrum to a Bntain is an interesting case. Decause they pnvatiad large extent and our observatens of the ciner utilities and created twerve Dnvate c:stnbuten ccmcantes. a is that perhaps they're not m as conservative a posture transmission company, and two generating ccmcanies. Now, the enginal plan was to have a cig VICTOR GILINSKY: Let me say a word about tne generating company. a small generating company, the big one was suCDosed to take tne nuclear plants.

uncertamties in decommissicntng costs. There are Now what happened was that tre pnvate buyers just severat elements. cne that's teen mentioned. the ccst wouidni take the nuciear piants Essentady under any et the low level waste sites. anat they're gomg to conc: tons. I mean, they set up some cordttons. but charge and that goes all over the place. In cther

• nat rt amounted to is that they just woulcn't take words. just how much material, in fact. has to be removed.

And I think it was Jim Curtiss wno them. Which is interesting. And wnat happened was inat the government set up a nuclear generating mentioned about how mucn concrete has to De ccmpany anc each of the c:stnbuten comoanies just And as I understand :t. the estimates are removed.

coming way oown. They think they can get away with has to take a cenain traction of nuclear power So inars a market test, at least in one piace removmg a lot less concrete than they originally calcutated A compensating f ac cr is the labor cost Decommission!n;; Costs And Plant shutdown And this I found really interestmg, talking to the NRC Decisions contractors. The arguments cer*een the people who have high cost and low cost ts whether you get usetut Are any utihties contemctatinn early work out of an eight hour day or three hours useful CUESTION:

snuttwn ct nuclear plants because et rapidly nsing work in an eight-hour day from pecpie who are working ceccmmissenmg costs >

on decommissioning. Because there's suiting up and then getting into the radioactive area and all the VICTOR GILINSKY- ! wculcn't magine that the activities that go along with that are just very very decommissioning ccst would cause a plant to be complicated and it one can find a way to improve th 1, there's just a lot of room for imcrovement, let me put :t cicsed prematurety. I would think tnat would come inat way.

' rom cther consceratens.

s QUESTION:

-Do the Bntish have more JOSEPH WAMBOLD: I would agtee. I don't think decommissoning ezpenerce we can team from?

that wdl be the precipriator. And at least in many cases cenainly :n Caltfornia. the scrutiny is alreacy VICTOR GILINSKY: The UK's reactors in the main curte comDrehensive and intense. So rt's like this may are very ditterent from our reactors and their be a crecipitatmg issue. in my view it's sort of alreacy cecommissioning costs are sometning like ten times inere. for muttole reasons pemans ours. They are very large reactors using either natural uranium or low-enrchment. and so it's a special Managing Rising Nuclear Waste Storage and situation.

Disposal Costs OUESTION: With the escalaton in ow level waste Regulatory Recognition C'f Rising Costs disposal, spent fuel storage and cecommissoning OUESTION:

costs. how can a utility manage inese financial Do NRC and state regulators adecuately uncertainties?

recognize that nuclear plant shutdown costs have nsen substantially, and probabty wi!! continue to grow?

JOSEPH WAMBOLD: Well, as 1 touched on in my JAMES CURTISS:

opening remarks. at least cne approach the ut:ltty can For the regulator's part, I think it take is to go into a very conservatrve posture relatrve was antcipated at the time that Yne decommissioning to what they anticcate in the future. if there is a public rule was established that costs would likety nse. And..

utilities commiss on that snares that view. obviously and understand here that frankly the effort that was that's very he!pful. rather than having it De an all-out undertaken to establish a decommissioning funding adversanal pos: ten to only keep current Cay rates cw mecnanism was really cuite unicue. It was discussed earlier that it was not ant c: pated that we'd shut these M

w

mants oown. But tne ettort to estaDiisn a trameworx RALPH SARGENT: Let me at to inat ; tem cur and to provde for tne fundirg cf these expenses in ine perspective. I see absolutely no reason any ine commercial nut: ear industry is sometning ina! *e ratepayers wouldn't continue to pay. through crccably all wisn we nad, for examcle. tor Ctner autnoncaton from the state ccmmissons, for the costs

'ac@es that are contaminated arcunc the country of cefueling, cecommissionmg. assummg that the We're trying to go around and find cecC'e to clean utilfty can cemonstrate prudent management ct trcee trcse up inrougn Super Func ard ciner programs it activities. To picx up on wnat Ccmmissioner Cur" s i

was anticipated a' the time inat there woula De an nas Just said. the vast macrity cf the cetueling a O engcirg m.o-ccese correcten tnat wouta need to te cecommissioning work Inat *e nave ocne at Fort St.

taren as we gc! more excer.ence witn actual Vrain was nght on estimate We feel very comfonable ceccmmisscnirg We nad not nac rnucn et mat at tne with the scope cf work that was cefined dunng the

. e that the cecommiss.on rule was promulgated bidding process We feel very comtonable witn the

,am Asselstine is nere. he was a commissoner at the estimates that were developed. and Drobably 95 time. ard as I recall we had not had any mact large percent of the work scope detinec in Doth the cetuehng tacd't es decommissonec Humooc! Bay in Canfomia and the decommissioning activities, we feel was a small and pemaps uncue fac:hty Pathfinder C mfortable with. The unknowns relative to low-level was moving icrward.

We nacn't nad a lot of v aste, we decced to solve obvcusly oy dealing with expenenCO. And *nat we're seeng now is that we're

!'lat near term as opposed !D long term. But our gettmg some excenence w it n Ine actual experience would lead me to feel comfortable that ceccmmissen:ng ratepayers would continue to pick up those costs i

without much cuestion. I mean, without Cuestion The numbers are mcreasmg. atthough i ccn't inmk beyond whetner these activities are Deing prucently sign'fcantry from the starepCCt of the amCs of things fr.anaged.

mat the Commission innialty estimated :n uncenamrq ts anatysrs There are some things that are bemg VICTOR GILINSKY: I have test cre thought en this.

acced to the cost that were not irclucec nt.any, things

t's worth keeping in mind, n seems to me, that the We spent fuel storage, cecause et

• hat's napcening queston of the shortfallis deccmmisscning costs is cr tne DOE front wrth the lack of progress on that t.kety in most cases to be cwaned by the issue of wnat D cgram. There are some rcreases that are coming happens to the unamortced plant investment. Inat's cn the tw-level *aste front, from tne stancooint of probably the big issue in the San Onofre case rete what's happenm; n tnat program as wed. So the the settlement. as I understand it was. the comcany cngma! estimates mat were uncertaken, in my view, got back, essentially the entire unamonced are provirs to be not bad estimates. They ougnt to be investment. That's goirs to be tne entcal cuestion acated tc reflect tne work that's teing cone now. We And some of the state laws, I thtnr. pose problems for

• d aod eroenses to that n terms of spent fuel stcrage m at.

arc ine costs mat we re seeing accrue for low level w aste And I expect you'll see some Continuing PAUL PARSHLEY: Before I go over nere for a reewration cf that expenence. We've talked about cuestion, my colleague. Jim Asselstine, has teen some issuet nere that may cut ertner way depending sitting in the back. And every time he hears his name uccn now ycu bcx at n. Low tevel waste is one. Do mentioned I notced that his twitch gets a 11ttle brt more you see tne expense go up Decause the cost per cube

- So, Jim. do you want to defend yoursett here Or i

toct ts close to $500 or wdl it go oown because you let ctfer some comments?

'ne waste s:t inere and cecay?

j Ne investment communny, I thmk. :s nght to te The Adequacy Of NRC's Current Decommissioning l

Cast Estimates merested in this issue and to eva:uate wnere we're gcing wnh these expenses. But the mecnanisms are JIM ASSELSTINE. Yeah. The only comment I was l

n place. in my v ew, for upcalsrg these erDenses The going to add here, and maybe this is more a Cueston i

analysis that's being undertaken row 1 ocnt think is for Jim Curtiss. You're nght. I was on the Commissen going to cause the estimates to go through Ine roof -

at the time that the Commisson put out the proposed ter times 20 3' C 1;mes *nat we estimated AndI rJie and the one area where I really had a Concern

'n:rA trankly *nen we start seeing the expenence about the proposed rule was On the cost estimates

.n:c Dcrated trom Anat we've got in the exis: ng plants.

And I realize that the national labora1Cnes had Come we te going to get some ett:ciencies that result trom up with those estimates, but one of the things that nad me f act that we've Degun actually cecomrnss;cning troubled me is that the industry's cost estimates were

• • ese D' ants and mat.

'hmk. will De 'ac'cre c mio the hgher than the estimates that were actualty put in the acccunt proposed rule And in f act the incustry estimates. as !

recall. were around $250 milhon per plant. wncn 25 i

d

Seems to Oe prehy Ocse to the expeCied expenence for a number cf mese Diants that weNe been talking nigh degree of Con!!dence that at tne conclusiCn ci accut. Fon St vra.n seing und of on tre now sce. tut coeratcn or at least at ine cencluscn et a ncrmal also Deing a piant mal was d;tterent in tecnrcogy. and r ar pened. 'ne financiai *nere*tthal would exist to e

naving lower contaminaten teveh proceed alth CeCommissoning i think it's picc. ably goirq to De bome out that those numbers need to te i guess I accroach tne ccst cuesten in tne NRC's

ncreased in can because we're talking aDout irc:ucing estimates from two perspectives

~irst. 't does seem some things now that weren't prevously conscered :n to me from ine stancocint c1 u1Wty customers and the ine estimate, in part because the~ expenses of actuauy companies tnemsetves that everyone is better Qt ri you ocir.g the work are indcating Inat our numbers may te collect the money for decommissoning wnde the plant Whatever the reasons were tehind tow.

.s stdl running and provcing some usetul benefft And formutation of those numoers at that time, and I want the the utdtty inevrtably is going to be at somewnat ct a deeply invoNed in the aCiual numoers. ;t does seem to cisadvantage rf you're trying to collect signrficant me that the observaton that Jim Asselstine has ma decommission ng costs trem customers that are nere. which is the NRC ougnt to sinve to have reahst c getting no benefit at all from the plant Ard pancuiarly estimates that incorporate actual experience that where regulators are going to be making that decision we've seen to date so tnat the rate coHeClion wrc weren1 necessanly invoNed in the earty decisons mecnanism can be based upon inat and then provice financial wherewithal at the appropriate time to to budd the plant or to collect the earher deccmmissioning amounts And seccnd. my other uncenake decommisscnirg That, in my view wut perspective is, there seems to be a tremendcus provide 1he kind et stabikty, d you will, tne kind ct a cunt of vanaticn among tne ecmpan:es anc the assurance to the financial communtty and others that incmdual states in terms et current deccmmissenmg unen the plant finishes its cceration, completes cost estimates.

We neard from Joe Wamocid about coeration that it can be cleaned up for wnat we Calttemia and Southern CaMcm:a Edison That state rcugnty estimate it can be and the companies in Calttomia seem to be really on the forefront in terms of being very conservative in Future Nuclear Plant Orders estimating the costs of cecommissonirg and collectingOUESTION:

those amounts wellin advance.

rd be interested to near the panebsts' t

views on the future role nuclear pcwer might play :n I guess, my cuesten Jim. is do you think the NRC is the U S. Do any of you believe e trore nuclear plants will ever be ordered?

sencing the wrong signal to some companies and pernaps to some states by continuing with a fairly low RALPH SARGENT:

estimate ter decommtssoning costs? Mght it be more Let me jump way out on that helptut to the companies and to regulators in the states hmb. And i don't even know that I m speaking on to actually move closer to the kinds of estimates that behatt of the Pubfc Servce Company of Colorado as the industry itself has been using for. say, the past frve much as rm speaking on the issue from having been years of so, and now that seem to be coming true for

.n the utinty industry for a whde. I beheve that the some of these eany plants?

nuclear industry does have a future. ! beheve that :t has a very sgnifcant future, rf only for environmental JAMES CURTISS. I think the opportunity that we reasons. I think that we will find in this country - and have here. and I agree with much of what Jim mayoe this is true wortwde - that nuclear power win Asselstine has 24. the epoortuntty before us at this ce a power source that we will want to avail ourselves of in the comt with the expenence that's actualty coming in, wnh future. Certainry one of the things that's in the some consderabie expenence now on what spent fuel way ng.it now is this decommissioning queston. And storage costs are going to be. dry cask storage. the Decause the expense of decommissoning and the tack construction of the ISFSI at Fon St. Vrain, the ci availabmty of low 4evel waste storage site as we:I as estimates that Yankee Rowe. all those numbers, spent fuel storage sites seems to be in the v.

You together wrth just much more expenence under the do rot find any utihties rght now stepping J to the cett for wnat decommissoning is actuany ccsting is to table to budd the next nuclear power clant. Arc rve take advantage of that and incorporate reahstic heard utiirty executives say, I would never want to be estimates. rf we coni nave them. in the rule rtsett the first to buid the next nuclear power plant. but i sure i do agree that we ought to as an agency seek to come up wouldn1 mind being the second. I think that thars Arth me most reaksic - cemaps errmg on the sde of probably at the heart of the issue. I think as we f:nc conservatism, g ven the collection mechanism --

that nuclear power is an a!!ernative that we want to estimates of what we croject decommissenmg to cost consider for a future power supply. that many ot ne And then recognizmg tnat inat gets plugged in'o tt e issues that we're ta: king aDout today will get greater mecnanism for coeng these fees. and then have a nat:enat attention and we will fire resciuten to these 26

ssues :1 onry as one mecr:anism to pave tDe way 'cr a growth er a reemergence of the nuc; ear :rcustry integrated Resource Planning CUESTtON:

Do you thmk :ntegrated rescurce PAUL PARSHLEY

.M0' oc.Ou w ar to :Cr rvi' plannmg processes wol nec uta:! es and regulators make gocd ecencmic Cecisiers accui nuclear piants?

VICTOR GILINSKY: t deni rear the cuesten. out nt give an answer {Laugnier}

RALPH SARGENT: Yeah.

, imrx the -- t guess you were asking Paul -- out I thm* inal process is very PAUL PARSHLEY: 7e ;esten was coes nurear important because it w H rrane costs comDansons more explicit.

power have a tuture And there wiu Oe a focus on the Operating costs of these vancus plants to an even VICTOR GILINSKY i thmx is nard to see nght row greater extent than inere is now also tt ;nk there is 1

more nuclear plants getting omerec. cancutany 01 tne another factor, when is as transmisson avess opens ype we have now Anc ! thmk tnese dsues et up and you're going to have more comtatition just i

necommissening and the waste cisocsat wnicn wdl generaHy between generators all over the place, Iinink crcoably be more active ten years from now wdl be those with high operating costs are going to be at a commg just at a time wnen others mignt be thmkmg disadvamage. I think tnat's a wncie separate area accut starting up a new nuclear power plant. So you're gomg to have this tensron and rt ene isnt PAUL PARSHLEY:

I agree with my answer

!Laugnter) resolvec rt's gomg to be narc !: thmk about otner nuclear power plants. At tre same :me. I have to if you?e 'ocong at ;crg term. you Decommissioning Cost Estimates agree w th Ra!ch

%nc ct woncer are we g:mg to.eeo rerymg en ccal QUESTION:

What's the test way to weep

'cre.er" lt you've ever Deen oc*n e a oca! mine. ri s a pre ty grm way to power O! ants, I Inmk. sc :t s harc to cecommissoning cost estimates accurate?

see Sc. guess -- et's see Vogi Serra sac inat :t's JAMES CURTISS: On our can we ought to oo wnat very narc 10 predet. especz y the future we're comg nght now penod'caHy. as experience JOSEPH WAMBOLD A Ocmtrent Natural gas. of everves with the actual decommisson of plarts. I think course is new Demg usec as a baselcad fuel. in wnat we're doing nght now with PNL Update wdl be acccer o coal. as Victor mentened. n that case an extremely useful in terms at taking the first rnaler mpcnar. tacter in the future avadability and pocing of accounting of some actual expenorce and putting it natural gas. rf rt was to remain at $2.00 or $2.50 a into the ru e itselt. Also as a mecnanism for utilities to mdlon t:gu, thars very econcrnc. are then you have to keep their estimates current in terms of updating.

I conseoer the environmernal pena ties you would pay guess rd ercourage those of you wno nave an interest But if you see a drfterent Mure in this issue, including those of you who have for burning fossil fuel.

ior fossa tuels, at some ocint the less avadabiirty or partcpated in the actual cecommissioning of some ms rg pnces. then thars a piace wnere nuclear shows plants here n the past couple of years. when the

'ts mact acvarnage centractor report becomes avadaole, and I think it's schedulec tor March of 1993. Victor. you may have Let me Just aod a comment My more current informaton on that than i do Out VICTOR GILINSKY own feehng about nucear power s that to come Oack it sometime here in the next six months or so. hopefudy,

t wdl be out for public comment. And the C0mment sni a matter of Deing a cara or a traction of a cent per kdowa!! hour cheaper than some attematNe. I think in process on that should ensure, we hope, that this kind the end to come back or to have a new commitment to Of experience will be taken into account. And I guess nuclear power in this country, peopde have to see rt as the message that rm taking away here from this back proviaang some maior aWantages. And these woud to the Cornmission among others. is that we need to be environmernal advantages, as cof acared wfth other make sure that we reflect the most accurate, most It depends a 60t on thinking about giocal recent information available on what it's costing, sources.

warming anc ether :ssues. Peop'e wid get clearer on expand the categories that we're evaluating it we need 1

those issues. they're still controversial to a certain to, spent tuel storage, if that's one that ooesn1 look Uke extent. And air oc!!Uten ard so on. But I think that's

t's go6ng to be solved in the tasnion that was realty the base condrten. It can't be pusned on oeople antcpated when the rule was promulgated, expand that category for purposes of having estimates

't anymore. It has to be kind of demand-drrsen And rt mcluded. But the comment process on that and the may get there. but thal s what it wd! take.

mteracion that we've had first wrth tne contractor and then with e people wno have actually conducted cecommis:. ning is. I think the enry mechy ism that 1 27

t know of to rnaxe sure ;nat we get into our regulatory before we actuany let the cunain cewn here is mame process some infom aton or some recuirements tnat sure that you are aware et my canners wno are nere actually reflect whar; going on.

sitting in tne front row. Debbie Grosser. Dec you want to stand up? And Dana Roulett Jim Asselstine Das Wrap Up had a chance at the mike in the Oack. but rm sure many of you know him and those of you who don 1 ne PAUL PARSHLEY-What I want te do now. Rob.1 is our counterpan on tne fixec inccme see at Lenman know you've been real patient But is C30 and many Brothers, and as you may have mterred from the of you. Demaps. ROD, you yoursett. sat througe, f,rkla conversation here today, has nao a cistinguisneo and Ohio Edison anc now this, anc so

• hat I'd like to career before tnat as a commessener et the NRC.

do is give everyone a cnance to cont:nue to ask ouestons, but i suggest that we oo :: in :ne nert room So, inank you all for pining us here today -- espec' ally a here we can do it and nave a drink or eat some our four Danebsts *no nave ocre a superD Jcb - anc cnicken wings. And the tast thmg i *cuic Ge to do we lock forwarc 'ic ta: king with vou next cocr I

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i LOW' DOSE RADIALOGICAL RESEARCH ON CHILD AND ADULT HEALTH RISKS i

FROM a-EXPOSURE TO LOW-LEVEL RADIATION

- r P

I Compiled by:

I Citizens Awareness Network l

Box 83

[

Shelburne Falls,Ma 01370 i

Contact:

Deborah Kat:

I Health Coordinator (413)-339-4374/8768 h

- f 1

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l

CITIZENS AW ARENESs NETWORK PO Box 83 Shelbume Falls,}viA 01370 (413) 625-9881 Partial Bibliography on Childhood and Adult Health Risks in Exposure to Low-Level Radiation.

Commu ni t y. Stu. dies Sorahan.T. Phd, & Roberts, P.

Phd. Childhood Cancer and Paternal exposure to Ionizing Radiation: Preliminary Findings From the Oxford Survey of Childhood Cancers. Am Jrnl Incust.

Med. 23:343-354 (1993)

Roman, E.,

et al. Case-control study of leukemia and non-Hodgkin's lymphoma amoung cnildren aged 0-4 years living in West Berkshire and North Hampshire nealth districts. BMJ 1993 d.306615-21 Nuclea.r W o r_ke r studies Checkoway et al. Radiation. Work Experience, and Cause Specific Mortality Among Workers at an Energy Research Labor ator y( Ca k Ridge). Brit Jrnl Ind Med. 1985;42:525-533 Kendall,G.M. et al. Mortality and Occupational Exposure to Radiation: First analysis of the National Registry for Radiation Workers. BMJ 1992:304,220-5 Kneale, G.W..et al Reanalysis of Handford Data: 1944-1986 Deaths. Am. Jrnl Induct. Med. 23:371-389 (1993).

Wing. Steven et al Study of Nuclear Workers at the Oak Ridge Nat ional Laboratories, Tn Jama-March 1991,vol.265,#11 Findings Around Nuclear _ Facilities Forman.et al. Cancer Near Nuclear Installations. Nature,vol 329.8\\10\\1987 Gardner et al. Results of a Case control study of leukemia and lymphoma amoung young people near Shellafield nuclear reactor in West Cumbria. BMJ vol.300, 17\\2\\1990 Gardner (1987) Brit.Med.J.295 Leukemia Excess for SMR's of Children born Seascale Gardner (1967) Brit.Med.J.295 No excess disease for children moved to Seascale after birth.

Johnson.K 1991-Tritium Releases from the Pickering Nuclear Generating Station and Birth Defects and Infant Mortality in Nearby Communities 1971 Atomic Energy Control Board.

Lambert,8.E. June 1990, Report on the Pickering " Fatal Birth Defects Study" Greenpeace Canada.

.[

McArthur,D 1988. Fatal Birth Defects, Newborn Infant Fatalities and Tritium Emmissions in the Town of Pickering, Ontario: A Preliminary Examination. Toronto, Ontario.

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1 l

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l l

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{

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{

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