ML20059P045
| ML20059P045 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 10/15/1990 |
| From: | Kriesberg J, Nogee A MASSACHUSETTS CITIZENS FOR SAFE ENERGY, MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00075, 55FR29043-75, AD04-2-128, AD4-2, AD4-2-128, NUDOCS 9010250038 | |
| Download: ML20059P045 (5) | |
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L MASPIRG'39193)
MASSACHUSETTS PUBLIC INTEREST RESEARCH OROUP "U
october 15, 1990
'90 DCT 16 P2:06 Docketing and Service Branch U.S. Nuclear Regulatory Commission'
[ ACE 0: 5FCPI W Y' Washington, DC 20555 "W %gf"WJ
- Re Comments on Proposed Rule on Nuclear Power Plant License Renewal The following comments are submitted on behalf of the - -
MassachuseM:s Public Interest Research Group-("MASSPIRG") and Massachusetts Citizens for Safe Energy ("MCSE").
MASSPIRQ is the.
state's largest environmental and:censumer advocacy organisation, with over 170,000 members.. MCSE is the largest citisans group in l
Massachusetts dedicated solely to promoting safe energy policies, with over 10,000 members.
MASSPIRG and MCSE object to the proposed' rule that would allow'for the' renewal of a nuclear plant operating license for up to 20 years, with the opportunity for an additional 20 year extension upon expiration of the renewed.iicense,'for the reasons stated below.
i The Need for License Renewal-Rules Has Not'Been Established We do not believe any clear need for such a rule has=been-established.
The oldest operating nuclear Plant, Yankee Rowe,.
still has 10 years to go on its current _ operating. license.- It is quite possible, if.not likely, that there will be no economio-rationale for nuclear plant life extension beyond 40.yeare.,
A 1988 analysis by the Energy Information. Administration:of the'U.S. Department of' Energy concluded, for example, that
"(c]ontinued escalation in operating costs could erode-any cost advantage that operating nuclear ~ power plants now have....If
. operating costs continue to escalate, it.-may become economical to-close some of the older plants, and thus the assumption of a~40-year operating life may be optimistic.":(An Analvain of Nuelaar power Diant oneratina costa,-DOE /EIA-0511, March 1988 at vii)
A 1989 analysis by the Boston Edison Company of the cost-i effectiveness of its 1986-198s' Pilgrim capital' additions showed that continuing _to operate Pilgrim through the-remainder of its-proposed 40-year. operating life would not be cost-effective,'even l
if the plant achieves a 68-percent capacity factor. (Response-to Department of Public Utilities:Information Request'RR-DPU-RSH=lo',;
DPU 69-100, Excerpt, Attachment-1).
This study compared only the-incremental costs.of operating and maintaining Pilgrim with the full replacement costs of new capacity c.nd energy.
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29 Temple Place, Boston, MA 02111-1305 (617) 292-4800 O
'OCT-15-90 MON 16353 MASSPIRG p,e3 A 1988 MASSPIRG analysis of the costs and benefits of continued: operation of the Yankee Rowe plant through the end of its original license period foundsthat operating the plant was likely to be more expensive than retiring it. The MASSPIRG analysis used virtually the same methodology as a previous /Rowe MASSPIRG/ Pilgrim analysis, which was largely confirmed by.the o
' Boston Edison analysis excerpted in Attachment-l'.
We would be l
happy to provide a copy of: the Yankee Rowe study on request.
With the cost-effectiveness of' continued operation through o
the end of the original license period in question for some nuclear plants, the current need for rules to evaluate license extension beyond.the original 40 year period is doubtful, particularly when such life extension decisions are still years
't away from being ripe.
The Pronosal to Accent __the_Oriainal Licensina Basia-for Renewgl' is Not Anprooriate- ~
~
As we understand it, the proposed rule would allow a-reactor-
.with a licensing basis considered adequate to meet = safety standards when first reviewed to continue to operate for 80 years
~
L unfar the original licensing basis (or longer, since original-operating license expirations are being revised to 40 years from.
L commercial operation, which may: be 10 or more -years: from the plant's construction permit application.)
At the-time of, license renewal review, the licensing basis may bo 60 years out of date.
i The proposal to renew the license of a nuclear power plant on the basis of ability to meet 60 year old safety standards,.
rather than the standards in effect at the time of review is unconscionable, particularly in view of the fact that no commercial reactor has yet achieved even'30 years of' operating 1
experience.
It is inconsistent with the conservative safety
. philosophy espoused by the comm!ssion,'and-inconsistent with
" rising standards e,f excel' we" the NRC. claims to require of I
licensees.
To the extend; the commission considers 111 cense-renewals, the agency should regaire conformance to the licensing basis in effect at the tioe of the renewal application.
While we understan'd' the proposed rule to require; a review of equipment -
aging issues, such engineering. evaluations; inherently include-i uncertainty, particularly given tha. limited: industry operation experience in comparison to the time frames contemplated by'the proposed rules. As plants age, it'becomes even more important that they-be required to meet current licensing standards in l
order to ensure overall, plant safety.'
I The Dronomad Rule Allowa Dramature License Renewal Applicatiana t
The proposed rule would allow licensees to apply for license extensions up to 20 years before the current license expires.
Such applications would clearly-be made far in advance of when-necessary, and:could only lead to exclusion of potentially.
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ocT-is-ce4 McH 16:51 MAOCPIRG P.e4-I significant information gained from operating experience between
.the; time the renewal application is made and the time of original g v license expiration.
Such an approach would.not be prudent.
Tha Droposed Rula beam Not Ennura Licennan camelianca with the Licensing Basis submissionofdocuments'whickroposedruledoes'notevenrequire We~ understand-that the 1
I comprise a plant's licensing basis, but only. submission of a list of such documents.
This approach j
will not~ ensure that the plant meets even the original licensing basis, let alone a current-licensing basis.
-l 1
To the extent that the commission allows license renewal, it j
should. require,Jat a minimum, that-all1 relevant documents be i'
-provided, that the licensee de"onstrate that it is in compliance with the appropriate licensing basis, that ths licensee has complied.with all commitments made under the origina1111 cense; and that all resolutions of previously Unresolved safety-Issues-and Generic SafetyfIssues have:been implemented.
I conclusion
.The economic analyses discussed above indicata that, even if-l
' licensees choose to continue.to operate reactots, tney are likely l
to be under' intense economic pressure to remain competitive with alternative power sources.. Under such' circumstances, it-is even more imperative.that-the NRC apply the-strictest possible safety a
-standards to license-renewal or extension applications, should such applications be considered at all.
j The NRC should reject the proposed rulesas. unnecessary.
If j
the Commission does approve.the rule, it should make at=least 1
such modifications as.necessary to meet the ebove concerns.
Thank you for your consideration.
sincerely,
[4 h
hkph rieshp Alan Nogee d
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/ Director, NC Energy Program P. rector, MASSPIRG 3
4 i
OCT-15-90' MON 16354'MAGOPIRG P. Ei3 5
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ECCNCMIC USEFULNEES ANAL'vili
'W Ah*atNINei A A
j' 74 27% ENTITLEMENT'IN FIL3 RIM l'
L es% FIL3 RIM Cr.FACITY FACICR...
(CNFV 0F PAOJECTED ANNUAL CCST$ 1490-0010)
,ALL FIGURE 3 IN >lILLICNG OF 1?E91 UNLEGE NC7ED)
SECO SYSTEM OPERA?ING COSTO I*CM W/C FIL3RI-W/ PILGRiti D I F A't.t c..v 6 2
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- REL C0iYS -(d'4;~.IU5tVF 0F PILGRIM).
47,250.3 Itai 15.f:4.4 <!):
6i.221.E NON-FUEL COSTM EXCLUSIVE OF PILGRIM) 1
'l tax 65. CtM. RETURN, DEPR 5997.8 (0),
s510,? is).
4454.Y -
FURCH SJWER CAFACITY CCETS 3345. 5.- ( ~ ) l-9144.0.tP)P 1001.7 FREMATURE DECOMMIESIONING 5040.7 (4) l'
- 30A0.'
==
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l ammamanu TOTA: JO5T5 iEXCLUSIVE OF PILGRIM) 54.654.0 1
56,s55.4 l
s2.195.4 l l
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IL5MIM FUEL COSTS I
2180.5-(8)l FILGJIM NON-FUEL COSTE I
i T4XES. C&M.. RETURN. DE*R I
si,944.s-(9)l' i
DECOMMIS5:0NING l.
1976.2 (9)1
- summewns i
-TOTAL PILGRIM COSTS l-50,200.5 (s.203.5) 4 l'
esummmmm' smessame mesammaa TCTA; gvgrEn COSTS
$8,254.0 1
25,859.4 I
(45.1/
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-5AVINGS DUE ?O FILGRIM
( 45. l i 40."231 ATTACHMENT C
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FACS MILE TRANSMISSION
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f To:
Docketing and service Branch, US NRC-(.
202-634-3343 fax
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FROM:
Alan'Nogee_
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Fax: 617-292-8057 or ask recoptionist to f,ax directly to Alan i
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PAGE #1 0F 5'
TOTAL PAGE!:
Please deliver to Docketing and Service Branch.
Thank you very much.'
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