ML20077G056
| ML20077G056 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/24/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20077F967 | List: |
| References | |
| FOIA-90-568 NUDOCS 9106210295 | |
| Download: ML20077G056 (108) | |
Text
_ _ _ _
1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 NRC STAFF BRIEFING ON THE DECOMMISSIONING OF SHOREMAM 5
6 Commission's Hearing Room 7
11555 Rockville Pike 8
Rockville, Maryland 9
Thursday, May 24, 1990 10 The Committee met in open session, pursuant to 11 notice, at 10:00 o' clock, a.m.,
S.
BROWN presiding.
12 NRC STAFF MEMBERS PRESENT:
~
13 Tom Murley, Director of Nuclear Reactor 14 Regulations 15 Jim Partlow, NRR, Associate Director for Planning 16 Joe Scinto, NRC 17 Stewart Brown, NRC Project Manager 18 Mike Miraglia, Deputy Director, NRR 19 Steve Varga, NRC 20 ATTENDEES:
21 Richard Kessel, Chairman of LIPA 22 Jack Brons, Executive Vice President, NYPA 23 Stan Klumberg, General Counsel, LIPA 24 Less Hill, Director of Special Projects, NYPA 25 William Sieger, NYPA 9106210295 910523 il } [j(( ;? f(/ '_'tD PDR FOIA MCGRANE90-568 PDR
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5 1
PROCEEDI NG B 2
MR. BROWN:
Good morning.
Today's meeting is a 3
meeting open to the public.
The Long Island Lighting 4
Company and associates of the Long Island Power Authority 5
and the New York Power Authority are here to brief the 6
staff on matters related to decommissioning of Shoreham.
7 While public meeting participation is limited to 8
the licensees, its associates and staff, the members of 9
the public will be allowed to make statements at the 10 conclusion of this meeting.
This meeting is being 11 transcribed.
Thank you.
12 MR. MURLEY:
Thank you, Stew.
That was Stewart 13 Brown, who is the project manager for the NRC for the 14 Shoreham plant.
My name is-Tom Murley.
I'm the Director 15 of Nuclear Reactor Regulation.
I'll ask the NRC staff to 16 introduce themselves and then we'll turn.
it over to.
17 MR. PARTLOW:
I'm Jim Partlow, NRR Associate 18 Director for Products?
19 MR, SCINTO: NRC.
20 MR. BROWN: Stew Brown, project manager.
21-MR. MIRAGLIA: Deputy Director, NRR.
22 MR. VARGA:
NRC.
23 MR. MURLEY:
Perhaps James Taylor, our executive 24 director for operations may-perhaps stop down later.
25 I have a few openings comments to set the stages
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1 for this meeting.
Long Island Lighting Corpany has a 2
license from the NRC to operate a Shoreham Nuclear Power 3
Plant.
NRC has however issued an order which modifies 4
that license which prevents LILCO from moving fuel from 5
the fuel r>ool to the reactor vessel and therefore prevents 6
the plan; from being operated.
We were told by LILCO that 7
they are prevented by agreement with the State of New York 8
from caring out actual decommissioning activities.
9 We understand that intend to sell the plant to 10 the Long Island: Power Authority who will be responsible 11 t.
carrying out the actual decommissioning.
We're being 12 asked, nontheless, even today by LILCO, for relief of 13 certain licensing requirements in order to reduce 14 operating. expenses.
There is certain information we 15 believe that we need.
We hope we can get some of that 16 information today; and that is who is the Long Island 17 Pawer Authority; what is their technical capabilities for 15 caring-out the decommissioning; can they do it safely; 19_ what are their plans and schedules for specific 20 decommissioning actions; and what are the funding plans 21 among other questions.
22 With those he introductory comments I'l1~ turn it-L s
I 23 over to Bill Sieger.
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24 MR. SIEGER: Good morning.
I would like to I
25 introduce to you members who are here today and the Long l
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4 1
Island Power Authority and the New York Power Authority 2
will be answering questions which you just asked.
3 In the center table is Mr. Richard Kessel, 4
Chairman of the long Island Power Authority.
On his right 5
is Jack Brons, Executive Vice President of the New York 6
Power Authority.
To the left of Mr. Kessel is Stan 7
K11mberg, General Counsel for the Long Island Power 8
Authority, and at the far end on the right is Mr. Les 9
liill, Director of Special Projects for the New York Power 10 Authority.
11 With that, Mr. Kessel.
12 MR. KESSEL:
I want to first of all thank you, 13 Tom Murley, for the opportunity to address you today.
As 14 I mentioned previously, we do know each other.
The 15 Shoreham issue has been an issue that has, I guess, 16 brought us together in many different ways over the years 17 and this is yet another twist and turn in that process and 18 I want to thank you and the other members of your staff 19 for taking the time to meet with us today on an issue that 20 I think is of significant importance and that is our plans 21 regarding the Shoreham Nuclear Power Plant.
I'm going to 22 try answer some of the questions that you raise and I'm 23 certain also our other people here today, Stan Klimberg 24 who is our executive director of general counsel and 25 certainly Jack and less from the New York Power Authority
1 can answer a lot of technical points.
I also certainly 2
invite questions that any of you might have at any point, 3
interrupt me or any of the people that are talking today.
4 I'd like to make just a couple of opuning 5
remarks.
The fact of the matter is, as you probably know, 6
that the Shoreham issue has been a very contentious issue.
7 It has certainly been a political issue on Long Island now 8
for over two decades.
9 However, at this particular point, following 10 Governor Cuomo's settlement with the Long Island Lighting 11 Company and other parties to close and decommission 12 Shoreham, we don't view this as a political issue anymore.
13 We view it as a technical issue. ke're not here to discuss 14 the politics of Shoreham.
We're here to discuss the 15 technical aspects of closing the plant, transferring the 16 license to the Long Island Power Authority, and then 17 decommissioning the plant.
We see this as a technical 18 issue, but not a political issue.
I want to assure you 19 that it is our intention at the Long Island Power 20 Authority to follow all Nuclear Regulatory Commission 21 miles and regulations to accomplish the objectives of 22 Governor Cuomo' settlement to closing and decommissioning 23 the Shoreham Nuclear Power Plant.
I 24 That is our responsibility.
We recognize, 25 certainly, the Nuclear Regulatory Commission's 4
l
1 responsibility in terms of regulating nuclear power 2
plants, including Shoreham, and it is our stated intention 3
to work within the rules and laws of the Nuclear 4
Regulatory Commission to see that the Shoreham plant is 5
transferred to Long Island Power Authority and then 6
decommissioned as expeditiously as possible.
7 I would like to say that it is very important, 8
and I want to communicate this, not only from Governor 9
Cuomo, but also from the Long Island Power Authority to 10 the rate payers on Long Island, that we develop a 11 cooperative working relationship because in effect we will Ii 12 be your licensee, if, in fact, you approve the t.ransfer of I
i 13 Shoreham's license over to the Long Island Power 14 Authority.
And we intend to follow all the rules and y
15 regulations.
16 We recognize that there are many to follow; at 17 the same time, we also recognize that the quicker we move 18 through this process and complete it, the cheaper it will 19 be for the LILCO rate payers.
And so our goal is to do 20 this in a manner following all NRC regulations, but also 21 in a manner that is cost effective and as expeditious as 22 possible to save local rate payers as much money as 23 possible, and, as well, of course, to do it, meeting all 4
24 cafety and environmental issues which are of prime 25 importance to Long Island Power Authority.
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-1
.I want to say that at today's meeting, I felt it 2
was important for me as chairman of the Long Island Power-3 Authority.to come down and address you personally, and I 4
want=to be personally. involved in this.
The governor has 5
a very strong feeling, as de the other LIPA trustees, that
~
6-we do want to work wif.h you on as high a level as we can
-7 to accomplish this, again withi.n your rules, as quickly as 8
possible, because it does mean the saving of-tens of 9
millions of dollars for LILCO rate payers.
10 I want to assure you that as chairman of the-11 Long Island Power Authority, I intend to work with you 12 personally.
I am available at all times, either on the i
13 telephone or, if we come down here, to meet with you 14-because I think we need to handle this on as high a level 15 as possible, and while I have a tremendous amount of faith-16 in Stan Klimberg who is an incredibly experienced person 17 in his field, and I'm going to describe some of his 18; experiences in a few minutes -- I think it's-important,
- 19. and Stan and I talked about it, that I personally come 20 down here and try to work on this issue because of the 21 importance that we all ascribe to doing this and doing it 22 right.
23 I'd like to just identify quickly who else is 24 with me at this presentation:
As I mentioned, Stan 25 Klimberg is our executive director and general counsel.
I
W 1-worked with-Stan for a number of years.
Stan has been 2
withEthe Long Island Power Authority since its inception.
3 Also to my right is Jack Brons.
Jack is presently in 4-charge of the New York Power Authority's nuclear 5
operations and, as we will discuss in a few minutes, Jack 6
will soon become a LIPA employee and LIPA's executive vice 7
president for the Shoreham project, and he will report 8
directly to Stan, who, by the way, reports directly to 9
myself as the chairman and the other tru.stees of the Long 10 Island Power Authority.
11 Also to my right, next to Jack, is Les Hill.
12 Les is currently head of the New York Power Authority's 13 special projects.
He also will soon be an employee of the 14 Long Island Power Authority, and after the license 15 transfer, Les will be like the Shoreham resident manager.
16 We-also brought-with us Ed Abbot with ADZ, 17 Incorporated.
Ed is with ADZ, Incorporated. They are a
'8 nuclear consultant firm with very broad, technical 19 experience.
Ed was tec hnical assistant to Victor 20 Gilinsky when he was a commissioner of the Nuclear 21 Regulatory Commission and was a senior reactor operator L
22 with the New York Power Authority at Fitzpatrick, which, 23 of course, as you may know, is the sister plant to the 24 Shoreham plant.
And Ed is consulting with us on 25 decommissioning and other technical issues regarding the l
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1 Shoreham nuclear power plant.
2 We_also have our legal consultants here'with us j
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today:
Bill Coleman and Carl Shenker from for O'Melveny y
4 any Myers over on my left; and also from the New York 5
Power Authority, Nick Reynolds and Dave Radcliff from 6
Bishop, Cook, Purcell & Reynolds; and also just.one of my 7
staff attorneys, Richard Donafield, and also I would like 8.to-cite Vic Furey, general counsel for the Long Island 9
Lighting Company.
We worked together for many years.
10 What I would ?ike to do now is to explain to you-11 the Long Island Power Authority's plans for license 12 transfer and decommissioning of Shoreham and summarize 13 what we-have-done up to this date.
I'm going to do this 14 in such a way so that I give an overall presentation and 15 then hand it over to Stan and Jack and Les to give you the 16 specific details.
17 But before I begin that what I'd like to do is 18 !give a brief overview of how we got here, where we're 19 going.and who we are, who the Long Island Power Authority 20 is.
The-Long Island Power Authority was created be the 21 New York-State. legislature and the governor by state 22 legislation in-1986.
It was created primarily to seek-a 23 resolution to the entire Shoreham controversy.
24 A.
you know, Shoreham was a very controversial 9
25 issue'on Long Island for many, r'any years and there were 9
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1 problems in terms of cost overruns; the LILCO first began 2
to plan the construction of the plant in the late 1960s 3
and, I think, by the time 1986 had rolled around the 4
majority of Long Islanders felt very uncomfortable with 5
opening the plant.
6 There were questions that we certainly dealt 7
with relating to evacuation and emergency planning and 8
other safety considerations.
And LIPA was actually 9
created out of that by the legislature and the governor to 10 address those problems and try to resolve a problem which 11 was really paralyzing Long Island, not only in its 12 pocketbook, but also in its ability to plan for the future 13 and move forward to make sure that we had an adequate 14 supply of energy to satisfy all of the rate payers on Long 15 Island.
16 LIPA began operations, in fact, in January of 37 1987.
As you are probably aware, and if you haven't read 18 a copy of the LIPA statutes that have been supplied to 19 you, LIPA is authorized to acquire all or part of any of 20 LILCO securities or assets.
21 My own personal involvement in LIPA began in 22 1987.
I was appointed by the governor as one of the nine 23 trustees of the Long Island Power Authority.
We have nine
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24 trustees.
Five are appointed by the governor, two by the 25 speaker of the New State Assembly, and two by the i
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1 president or majority leader of the New-York State Senate.
2 I was a LIPA trustee from the inception of-the 3
Authority. However, I was not the original chairmar..
The 4
original chairman was William Mack, who resigned last 5
summer.
I replaced Mr. Mack as chairman of the Long 6
Island Power Authority.
7-It's important to note the depth and breadth of 8
experience that I think we show.
In addition to myself, 9
we have Frank Cipriani, who is the president of a state 10 university on Long Island.
We have Richard Gardino, an 11 attorney and town councilman, a government official in 12 Nassau County.
We have Sheldon Sackstein, a local 13 businessman and civic leader, who is managing a company on i
14 Long Island.
We have Irving Lyke, a long time lawyer and 15 activist on Long Island, who some of you may know; Tom
-16 Toomey, whose from the Law firm of Toomey, Lakeland,. Kelly 17 and Smith, again a prominent attorney from suffolk County 18-on Long Island; Steven Liss, who is a special assistant-19 and counsel to assemblyman Paul'Harinberg, who is the 20 creator of the Long Island Power Authority Act; Leon 21
- Campo, who is chairman of the suffolk County Water 22 Authority, a civic activist, and a finencial officer in 23 East Meadow School District on Long. Island.
We have Nora 24 Grettis, who is a former chairwoman of the Shoreham j-25 Opponents Coalition.
Nora is very active in environmental
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1 and civic affairs on Long Island.
The ninth person, of 2
course, is myself, the chairman.
3 The Long Island Power Authority, as you know, 4
initially was created to review the Shoreham controversy, 5
Last year in 1989, Governor Cuomo, I think, to a great and 6
significant step in creating and negotiating through 7
several state officials, including the Long Island Power 8
Authority itself, to close and decommission the Shoreham 9
nuclear power plant.
This settlement, I think, was 10
- crucial, ending years of contention and litigation and 11 controversy.
12 The Long Island Power Authorisy agreed through 13 the settlement to acquire Shoreham and to decommission the 14 plant, and I would point out that the Long Island Power 15 Authority took a great deal of time reviewing the 16 settlement, looking at the pros and cons of the 17 settlement, and deciding that it was certainly in the best 18 interest of Long Island, in fact, to adopt tha governor's 19 settlement and agreed to be the entity that would hold the 20 license and decommission the plant.
21 Now, obviously, as I said at the beginning of my 22 remarks, there were and are many differing views about the 23 wisdom of closing the Shoreham Nuclear Power Plant.
l 24 However, as I pointed out, we're not here on an argument 25 about nuclear power and we're certainly not here about
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1 arguing the pros and cons of Shoreham.
2 We're here to deal with the technical aspects of 3
the settlement that is fully effective legally; that 4
settlement agreement was approved not only by the Long 5
Island Power Authority, but the New York Power Authority 6
and the New York State Public Service Commission, as well 7
as LILCO, its board of directors, its management and, of 8
course, the governor of the State of New York.
9 I think it's important to note that while we 10 recognize the right of people to take differing points of 11 view on Shoreham, that under the settlement, which is 12 fully effective, Shoreham will not be ope.ated as a 13 nuclear power plant by Long Island Lighting Company or the 14 Long Island Power Authority or anyone else at any time now 15 or ever in the future.
I would point out to you, by the 16 way, that LIPA is statutorily prohibited from operating 17 any nuclear power plant on Long Island.
18 The settlement itself was initially signed last 19 February in 1989.
It was approved subsequently by LIPA in 20 April and, of course, by the New York State Public Service 21 Commission also in April of last year, and finally by 22 LILCO's board of directors at the end of June of last 23 year.
i 24 I will tell you that since that time a lot of 25 work has been done by the Long Is1..nd Power Authority, the
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New York Power Authority and LILCO in working 2
cooperatively together to execute the settlement.
3 First, let me talk about the license transfer 4
issue.
As you know, the settlement requires that the Long 5
Island Lighting Company transfer the Shoreham plant and 6
its license to the Long Island Power Authority for one 7
dollar.
That, obviously, is a crucial issue before the 8
Nuclear Regulatory Commission.
The necessary implementing 9
agreements that set up the framework for that have been 10 signed off on and approved by the Long Island Power 11 Authority, the Long Island Lighting Company and the New 12 York Power Authority.
13 ke have entered into two agreements, one with 14 LILCO, which is primarily a financial agreement dealing 15 with reimbursing the losses, and Stan is going to go into 16 that in a few minutes; and one agreement with the New 17 York Power Authority because we are fottunate to have the 18 New York Power Authority, as the entity that will do the 19 actual decommissioning work for the Long Island Power 20 Authority.
21 Those two agreements were approved -- they've 22 been approved by the board of the Long Island Power 23 Authority, by the board of the New York Power Authority, f
24 and yesterday the New York State Public Service Commission 25 approved the agreement between LILCO and the Long Island
. _, _ _ _. ~ - _
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fower-Authority, and so they are in full force and effect.
2.
They, in effect, establish the framework for the process 3-of----license-transfer and decommissioning.
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4 MR. MURLEY:
May I ask a question?
Are all the 5-agreements now in place and approved-that are necessary to-6 move ahead with requesting a license transfer?
7 MR.-KESSEL:
Yes.
And again I would' point out 8-to you, obviously -- and I'm going to deal with the plans 9
on license transfer -- now that the final agreement was 10 approved yesterday by the Public Service Commission; we 11 now feel all the agreements are in place and~we're ready 12 to move' forward.
13.
~I would point out to you that we have been 14 working vigorously with the New York. Power Authority and 15 LILCO to develop and prepare a license _ transfer
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16 application, and, as I'm sure you're aware, Mr. Murley, it 17 is quite a complicated and intensive process.
We intend
-18 to meet all the NRC requirements.
Of course, this is such 19-a new area for all of us, I-think both us and you.
We are 20 especially paying attention to what we think the Nuclear 21 Regulatory Commission requires of us in preparing this l-
-2 2 - document.
l 23 I would report to you today that we are very 1
12 4 close to finishing that document and I'm hopeful that we 25 will be filing formally a license transfer application
16 1
hopefully within the next 60 days.
And, as you know, the 2
Long Island Lighting Company has asked for a license 3
amendment in effect seeking a defueled license from this 4
commission. In our license transfer application, we will 5
be seeking the transfer of a defueled license rather than
'6 the operating license from Long Island Lighting Company to 7
the Long Island Power Authority.
Stan and some of the
~
8 others, Jack and Les, will give you more. details about the 9
anticipated transfer application, and I would tell you 10 that obviously we're trying to do this in a manner that 11 meets your requirements and also that allows us to move as 12 expeditiously as possible to save rate payers' money.
13 I will also ask not only Stan, but also Jack and 14 Les, to describe further the management and technical 15 resources that LIPA will have.
Let me just briefly touch 16 on them.
Stan Klimberg certainly is included in the 17 technical expertise that the Long Island Power Authority 18 has.
We will be using many qualified New York Power 19 Authority personnel; ABZ, consultants, LILCO personnel, 20 who are out at the new plant, as well as management 21 people, and other contractors.
22 I think most importantly, though, is that at a 23 meeting last week Long Island Power Authority trustees
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24 discussed and asked me to communicate to you our intention 25 to retain as LIPA employees key New York Power Authority
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employees, including both Jack and Les Hill.
It is our 2
feeling that the New York Power Authority's experience and 3
expertise -- they operate several nuclear power plants in 4
the state. I don't think there is anyone more respected in 5
this field than Jack Brons.
He has the utmost confidence 6
and respect of the governor, the state, Chairman Flynn of 7
the Power Authority, the Long Island Power Authority, the B
trustees and myself.
9 MR. MURLEY:
We have high regard for Mr. Brons.
10 MR. KESSEL:
I'm glad to hear that.
11 In effect, what we're talking about is that Jack 12 and Les and other LIPA employees will, in effect, become 13 LIPA employees for this process because that expertise we 14 recognize is crucial to fulfilling our obligation in terne 15 of decommissioning the plant.
16 We will also, however, include in LIPA's 17 organization an independent nuclear review panel of 18 outnide experts who report directly to our executive 19 management and, of course, to our trustees.
20 In short, I think what I'm saying is that LIPA 21 is developing a strong staff of capable personnel to 22 manage this defueled license once you transfer it over to 23 us.
t 24 Now, obviously, another issue is funding.
We 25 mentioned that before, and the agreements that I mentioned 4
1 before, and that Stan Klimberg will describe later.
We 2
have established a very strong financial plan to pay for 3
all of Shoreham's costs.
LILCO has agreed to pay all 4
Shoreham costs, including those of LIPA and NYPA.
This 5
mechanism is part of the agreement that was approved by 6
the Public Service Commission yesterday in Albany.
This 7
mechanism works well.
We're confident that it's working 8
well. In fact, it's working right now.
I would tell you 9
that despite the fact and this is important to note --
10 that we have such a strong technical staff, Stan and Jack, 11 LIPA trustees and myself are very involved in the 12 day-to-day decisions of what is going on.
This is not 4
13 some kind of an absentee situation where we don't pay 14 attention to details.
We review the details maybe too 15 much to some people's liking.
16 We reviewed very carefully, for inste.nce, the 17 Shoreham budget that LILCO has submitted; there is a 18 budget that involves LIPA, LILCO and the New York Power 19 Authority.
I must tell you that I and a number of l
20 trustees went over that line by line.
We are hands-on 21 trustees.
We've got hands-on management and hands-on 22 trustees.
We feel that's very important.
23 Obviously, the stated goal here following the 24 license transfer, of course, is to decommiseion the 25 Shoreham Nuclear Power Plant, and, as you know, we have r
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19 1
1 issued and submitted to you a decommissioning report which 2-describes the current status the Long Island Power 3
Authority's work.
4 MR. MURLEY:
Were you going to talk a little 5
more about the funding arrangement?
6 MR. KESSEL:
Yes. We are going to talk about 7
that, yes.
8
-MR.
MURLEY:
One of the things I think we'd like 9
to hear about is the stability of that funding arrangment.
10 If you were-to run into problems, how would you get the' 11 money to get out of the problems, that sort of thing?
12 MR. KESSEL:
Okay.
Let me respond quickly to 13 that.
Stan will cp3 into it in great detail, but just to 14 assure you that based upon the agreement that we have with 15 the Long Island Lighting Company, they are responsible for 16 all the costs relating to.the decommissioning of Shoreham.
17 And,-as you may or may not know, as part of the-governor's 18--agreement, there is a financial aspect to it that has i
19 given LILCO rate increases of --- I don' t know if you know 20
.the specifics, but just to go over it very briefly, _they 21 have three years that are guaranteed.
They have seven~
22 years of target rate increases.
I point out that while no 23 one likes rate increases, these rate increases, I think,
(
24 ar.d the governor feels, had the plant operated, I think 25-they're reasonable.
We want to even try make them lower,
1 if possible.
As part of these rate increases -- and it 2
was approved by the Public Service Commission last 3
April -- the funding is there to decommission the plant.
4 And while we're hopeful that actually the funding will 5
come in a lot less than what is included in the settlement 6
rate plan, the fact is the money is there and the Public 7
Service Commission has already approved the principles of 8
rate increase that will enable LILCO to, in effect, 9
transfer the money to us to pay for decommissioning.
10 MR. MURLEY:
Even if there is some completely 11 unexpected problem that causes very, very large unexpected 12 costs, they most reimburse LIPA and they are to be 13 included in the rate?
14 MR. STAFFIERI:
We could recover them from the 15 rate payers.
36 MR. KESSEL:
Let me just say to you that we 17 certainly don't anticipate that.
I understand your need 18 to know that and we certainly assure you of that, but I 19 think with the experience we have and the people that we 20 have, certainly with the way we're planning this, that we 21 anticipate doing decommissioning, once we get your 2L approval to do so, in a very cost effective manner.
I'm 23 confident of that based on what I've seen so far, that we 24 can come in well under the target numbers that were used 4
25 in the settlement. And I think that's good news for LILCO i
1
52
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1 and its rate payers because, again, while this is a 2
technical issue, it's an eennomic issue to Long Island.
3 I'm sure you can understand that; we do want to keep the 4
costs down as much as possible.
5 By the way, that is why the Long Island Power 6
Authority is involved in monitoring the decommissioning.
7 We have experience in monitoring things like this.
Many 8
of us come from other walks of life.
9 I should add, and I apologize for not mentioning 10 in the beginning, that in addition to the fact that I am 11 the chairman of the Long Island Power Authority, I'm also 12 the executive and chairman of the New York State Consumer 13 Protection Board, and I have had broad experience in 14 monitoring expenditures, sometimes wasteful expenditures 15 of public utilities, throughout the State of New York.
16 I also have experience in working with utilities 17 in drafting rate agreements.
We've drafted 17 or 18 rate 18 agreements, so I have that experieace in addition to being 19 chairman of the Long Island Power Authority.
As I said, 20 we did issue and send to you, I think a month or so ago, a 21 deconmissioning report, which describes the current status 22 of LIPA's work.
We expect to file a decommissioning plan 23 as early as possible; while our target date is next year, f
21 we are going to work as hard as we can with the New York 25 Power Authority to try and get a decommissioning plan in
1_
to you as early as possible.
2
'We do not' foresee, and I point this out, that 3
we're not doing'this in piecemeal fashion. You know, first 4
we do the license transfer and then we do the 5
decommissioning.
We're trying to work on both at the same 6
time.
In that report which we have been putting together 7-a license transfer application for submission to you, we 8
have also issued a request for proposals for an 9
architect-engineer to assist us in preparing the final 10 decommissioning plan and performing related services.
11 We hope to get responses back on that RFP some 12 time next month, and the Long Island Power Authority is 13 prepared to move as quickly as possible after consulting
_ ith NYPA and LILCO to select that independent 14 w
15 architect-engineer for us in the very, very near 'uture so 16 that we can-begin to move forward and prepare the.inal 17 decommissioning plan for Shoreham.
18 I would tell you_that the trustees have asked me
- 19 to indicate to you our desire to pick a firm that has 20 expertise. We certainly would welcome your input,-if that 21 is appropriate, in terms of doing this and obviously
'22 working with them from the get-go to try to get this: plan 23 put together, meeting _all your specifications and 24 requirements, but as quickly as possible; the earlier we 4
25 can submit this decommissioning plan, the quicker this
-. ~. - - -.
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process will move.
2 MR. MURLEY:
To respond to that, we generally do-3 not get involved in contract mattera between licensees and 4
subcontractors.
If there are problems, we'll let you 5
know..
i 6
MR. KESSEb:
I do want to say, in areas where we 7
_can_ draw on your expertise, we would certainly be willing 8
to do so.
That would be welcome because, again, this is a 9
new area for all of us and, as I said to you before the 10
- meeting, I think it's fact that this is a laboratory of 11 experience here at Shoreham and several other plants that 12 are going through decommissioning, and I think that the 13 lessons that we learn here may be very applicable in the 14 future to other facilities.
15 In' fact, we certainly think it would be 16 appropriate'for other utilites and possibly even the 17 federal government and yourself to participate in 18 monitoring this project, not only the project itself of 19 the actual decommissioning, but the process we go through 20 here as a kind of map'that can be used by others to follow 21 in the future as nuclear plants are retired to again -- to 22 establish a system and possibly to save rate payers all 23 over the' country a lot of money, and we're certainly going
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24 to participate.
25 I would also point out to you that while we are k
^^
~ 24 1
working to prepare this final decommissioning plan, we are 2
also now analyzing which of the Nuclear Regulatory 3
Commission decommissioning alternatives to select for 4
Shoreham.
5 As you know, we have looked carefully at, and I 6
think our preliminary report indicates three methods of 7
decommissioning, safe shore embombment.
Right now we're 8
looking at all three of them, although the one thatowe're 9
looking at most closely, which we seem to be leaning 10 towards at this point, is the decom alternative.
11 One of the reasons we've actually sent out an 12 RFP is to get an opinion on this. Again, we want to do the 13 method that is in the best interest of Long Island, that 14 again follows all NRC requirements, but the one that is 15 most effective.
I must tell you that several months ago I 16 personally went out to the Shoreham plant. I have been out 17 tb<re, as you know probably, many times in the past on 18 several sides of the issue, but I went out there with Tony 19 Early, the president of LILCO, and went through the plant 20 to get a better sense of what we were dealing with.
21 Several of our other LIPA trustees uill be going out to l
22 Shoreham to view that as well because I think to see the l
l 23 physical aspect of the plant gives you a better sense of 24 what needs to be done in decommissioning.
i I
25 I think this is part of the hands-on approach I
I that we're trying to show.
I'd like to add we have an 2
office out at Shoreham.
Our consultants are out there and 3
I know LIPA is also out there.
I've been out there on 4
many different occasions.
5 I would like to say to you also that we are 6
pursuing a number of other things at the same time.
One 7
that I think is of particular interest to you is a 8
question that we are currently studying, a gas fired 9
facility.
We have hired a team of consultants that are 10 busily working right now to put together a report that 11 looks into the potential conversion of the plants.
It 12 certainly is an alternative that has a lot of exciting 13 possibilities.
14 We've established several criteria for moving 15 ahead and looking at that.
Obviously, we recognize again 16 our obligation is to you while we are decommissioning the 17 plant as a nuclear licensee, but the potential for 18 conversion is something we don't want to ignore, if, in 19 fact, it can be done, if it's feasible to do from an 20 engineering standpoint, if it's practical from a legal 21 standpoint, if it's environmentally sound and, most 22 importantly, if it's cost effective and saves rate payers 23 money.
It's something we want to take a serious look at.
24 We have hired a team of consultants to look at g
25 that now. I would expect that they'll be reporting back to
ca9 1
us sometime next month.
We will be glad to share their 2
report with you; although again it doesn't relate directly 3
to the decommissioning of the plant, it does relate to the 4
future of the plant, and we'd like you to see the study 5
and we'll certainly keep you apprised of our deliberations 6
as we proceed along that way.
7 We are also, by the way, working on long range 8
energy' plans.
In general, you may know the LIPA statute 9
empowers us to do a great deal.
One of those obligations 10 is to develop and work with LILCO on developing a 11 least-cost energy plan that includes energy conservation, 12 that looks at demand-side management and some of the other 13 important issues that we think can fit into providing Long 14 Island with an adequate supply of electricity at a 15 reasonable cost.
We have hired consultants who are 16 beginning to put together for us a long term energy plan 17 for Long Island and that is another document that we would 18 certainly be willing to share with you.
19 Let me conclude my part at this time -- I'm 20 going to come back later, and then there is like 30 21 seconds left for Stan.
I just recently orally argued for 22 ten minutes an and I was supposed to do four and my 23 attorney was supposed to do six. After nine and a half
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24 minutes he gave me a bump in the rear.
25 Let me conclude my part by assuring you on the
ev i -Long Island Power Authority's behalf-that we are in this 2
to stay.
We are prepared to work.
I want to give'my
'3 personal commitment as chairman of LIPA and communicate 4
the commitment of other trustees that we want to do things 5
safely, efficiently, and, as I've said all along, totally 6
according to the NRC requirements as we proceed with the 7
license transfer, first, and, of course, thereafter with 8
with the decommissioning.
And I think tnat you will see 9
as we go through this meeting this morning that in the 10 future -- we have given, will give, and do give a great 11-deal of thought to these matters.
12-Now, what I'm going to do is --
how are we 8
13 -going to work this?
Stan Klimberg'will describe LIPA a 14 little bit here.
I guess I described it probably more 15 than I should have, including some of our past activities 16 and the next steps that we will take.
Jack Brons, from 17 the New York Power Authority, will discuss NYPA's-18 assistance.
Lea, from the New York Power Authority, Les 19 Hill, will talk about license transfer plans and 20 decommissioning plans.
And I will come back to provide 21 some concluding comments.
22
- I'd like to introduce Stan.
Actually, I ion't 23 have to read this introduction, Stan. I've known Stan for
(
24 many years. Stan is currently the executive director and 25 general counsel to the Long Island Power Authority, and,
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as I said earlier on, Stan has a wealth of experience in 2
the energy field.
A person who is excellent in his field.
3 As I said, he's had nearly 20 years of experience in 4
energy matters with the New York Power Authority.
He 5
worked for the New York State Energy Office for over eight 6
years.
He was general counsel, and he knows, because many 7
times as a consumer activist on Long Islanc, I sued Stan 8
when he was general counsel and I was quiJe an opponent of 9
his.
He was one person that we went to with a great deal 10 of understanding of energy issues, and frankly, I must 11 tell you that he is an incredibly brilliant person with 12 incredible experience.
I'm sometimes amazed, and I will 13 say this publicly because he shows this in each and every 14 issue he deals with at LIPA on a daily basis.
15 He was staff counsel to the Public Service 16 Commission.
He was also an assistant general counsel to 17 the Public Service Commission.
Stan is going to describe, 18 as I said, a little bit of what the Long Island Power 19 Authority is and give you some of the more specific things 20 that I haven't touch 9d on.
Stan.
21 MR. KLISBURG:
I'd like to begin my portion of 22 LIPA's presentation by describing LIPA's creation and 23 statutory authority.
There is a slide that describes 24 generally that subject.
LIPA was created by state f
25 legislation and enacted in 1986 to describe the serious
e, 1 ~ energy p'roblems facing Long Island which have been 2
discussed generally by Richard Kessel this morning.
-3 LIPA began operations as in January of 1987.
In 4
the LIPA Act, LIPA was given the authority, among other 5
things, to acquire and decommission Shoreham.
- Indeed, 6
LIPA was mandated in-the statute to close and decommission 7
Shoreham, and to investigate and develop alternative uses 4
8 for Shoreham, if any, and we are currently doing that.
9 LIPA was also given the authority to promote energy 10 conservation, co-generation and the use of renewable 11 energy resources on Long Island, and to construct new 12 generation and transmission facilities, among other i
13 -things.
14 LIPA is a nonprofit, publicly owned authority.
.15 It is comprised of a nine-member appointed board of 16 trustees.
The chairman is-appointed by the governor.
As 17 has'been mentioned, the trustees come from all walks of 18 life.
As executive director, I am responsible for the 19 day-to-day direction and administration of LIPA and report-20 to the chairman and to the board of trustees.
21 I would like to briefly describe LIPA's Shoreham 22 organication. In addition to the chairman, the board of 23 trustees and myself, LIPA's Shoreham organization will
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24 include key NYPA employees, including Jack Brons and Les 25 Hill, who will become LIPA employees.
Other NYPA k
30 1
personnel will become LIPA employees.
Then the New York 2
Power Authority will also be assisting LIPA through the 3
management services agreement, which I will describe.
In 4
addition, we have retained the services of ABZ.
ABZ is 5
headed by personnel who are expert in nuclear matters; Ed 6
Abbot was assistant to Commissioner Gilinsky at the 7
Nuclear Regulatory Commission.
I'm sure you're familiar 8
with Ed.
Ed was also operations manager at the 9
Fitzpatrick plant, the sister plant to the Shoreham plant.
10 In addition, we will be selecting an independent 11 review panel of outside experts who will be assisting LIPA 12 and reporting directly to the executive management.
13 Finally, we will be retaining other outside 14 consultants who wall be providing advice to LIPA on 15 nuclear matters, including the consultant we will hire to 16 provide decommissioning related advice shortly in 17 connection with the issuance of the RFP.
We also have the 18 servicca of various law firms, O'Melveny & Myers and 19 Bishop, Cook, Purcell & Reynolds, who will be representing 20 us before the NRC.
21 MR. PARTLOW:
I take it you have not yet decided 22 exact 3y to whom the independent board is going to report.
23 MR. KLIMBURG:
The independent board will be j
24 reporting to the chairman.
I 25 MR. PARTLOW:
Has that been ironed out yet?
l l
l l
-~
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1 MR. KLIMBURG:
We will discuss that shortly.
2 Jack Brons will be going into that matter further in 3
detail.
4 I'd like to describe the 1989 Shoreham 5
settlement and related agreements.
These agreements form 6
the framework for LIPA's Shoreham activities.
The 7
settlement agreement, the basic agreement between Governor 0
Cuomo, on behalf of the state of New iork, and the Long 9
Island Lighting Company, was entered into on February 28, 10 1989.
11 The agreement provides the broad framework for 12 settling the years of controversy over Shoreham and for i
13 transferring ownership of Shoreham to the Long Island 14 Power Authority.
The key provisions of that are that 15 LILCO will not operate Shoreham under any circumstances, 16 that LIPA will acquire the plant and decommission it, that 17 LILCO will cooperate with LIPA in obtaining NRC approval 18 for the transfer of Shoreham to LIPA, and wd l assist LIPA 19 in maintaining and decommissioning of the plant.
20 LIPA and LILCO also agreed in that agreement to 21 enter into a more detailed asset transfer agreement which 22 I would like to discuss at this point.
The asset transfer 23 agreement between LIPA and LILCO was entered into on April 24 14, 1989.
That agreement is the basic agreement under
(
25 which Shoreham will be transferred to the Long Island-
1 I
1 Power Authority.
Under the asset transfer agreement, once 2
the settlement became effective on June 28, 1989 when 3
LILCO's shareholders approved the settlement agreement.
4 LILCO was obligated not to operate Shoreham under any 5
circumstances.
6 The asset transfer agreement also committed 7
LILCO to make its best efforts to make available those of 8
its employees previously assigned to Shoreham to the 9
maintenance and decommissioning of Shoreham.
10 In addition, the asset transfer agreement 11 describes the specific assets to be transferred to LIPA 12 and, significantly, it commits LILCO to pay for all costs 13 attributable to Shoreham, including LIPA's and NYPA's 14 costs, and I will describe the mechanism for that 15 arrangement when I turn to the site agreement.
16 The asset transfer agreement contemplates 17 further agreements which were executed on January 24, 18 1990.
Those agreesients are a site cooperation and 19 reimbursement agreement between LILCO and LIPA and a 20 management services agreement between LIPA and NYPA.
21 The Public Service Commission approved the asset 22 transfer agreement and the settlement agreement on April 23 13, 1989 and that PSC approval had the effect of ensuring 24 that LILCO will have the financial resources to pay for j
25 Shoreham's maintenance and decommission.
33 1
I'd like tc first turn to the management 2
services agreement between the Long Island Power Authority 3
and the New York Power Authority.
The management services 4
agreement provides the terms and conditions under which 5
the New York Power Authority will provide technical and 6
management services to the Long Island Power Authority in 7
connection with the transfer of Shoreham to LIPA for the 8
maintenance and the decommissioning of Shoreham, and I 9
might add the disposition of Shoreham's spent fuel.
10 LIPA has chosen NYPA to serve as its prime 11 contractor in connection with this project, to assist 12 because of NYPA's considerable expertise in nuclear 13 matters, as a result of its operation of its two nuclear 14 power plants, including the Fitzpatrick power plant, which 15 is the sister plant of Shoreham Nuclear Power Plant.
16 NYPA has agreed to and is devoting significant 17 manpower to this effort.
18 I'd like to now turn to the site cooperation and 19 reimbursement agreement or site agreement between the Long 20 Island Power Authority and the Long Island Lighting 21 Company.
22 MR. PARTLOW:
Could I ask about provision of 23 LILCO cmployees?
Who will they work for, those employees,
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24 after the license has been transferred?
25 MR. KLIMBURG:
The Long Island Power Authority
n 2
and the New York Power Authority manage on a day-to-day 2
basis the operation of the plant, specifically maintenance 3
and decommissioning.
The New York Power Authority will 4
identify specific Long Island Lighting Company personnel 5
who are now involved at the Shoreham project to become 6
part of the overall LIPA-NYPA organization of Shoreham.
7 And LILCO has agreed, to the extent feasible, consistent 8
with its other needs, to make those personnel available as 9
part of the team, and Jack Brons will discuss this in 10 further detail.
11 The site cooperation and reimbursement agreement 12 provides for, among other things, the terms and conditions 13 on which LIPA will be provided access to Shoreham's 14 facilities, property and records.
It provides the terms 15 and conditions on which LILCO employees assigned to 16 Shoreham will be made available to LIPA and NYPA and the 17 site agreement also contains specific provisions for 18 accounting, billing and auditing of Shoreham's costs.
19 I would like now to describe briefly the funding 20 mechanism provided in the siting agresment in which LILCO 21 has agreed to end is currently paying for all the Shoreham 22 costs.
Undet the site agreement, LILCO will provide on a 23 monthly basis to LIPA funds to pay for the Shoreham costs.
(
24 The funds to be provided to LIPA will be based 25 on a cash flow projection prepared by LIPA and NYPA.
2 LILCO funding will include at all times a three-month 2
cushion of furds to ensure that there is always on hand 3
sufficient funds to pay for the Shoreham costs, 4
LIPA, I might emphasize, will have control of 5
all of the funds to pay for the Shoreham costs, and under 6
the site agreement two specific funds have been 7
established, a LIPA reimbursement fund and a cost 8
reimbursement fund for this purpose.
This funding 9
mechanism ensures that LIPA has a very secure source of 10 funds for payment of all costs attributable to Shoreham, 11 including LIPA's costs and NYPA's costs.
12 The site agreement, as I've indicated, is 13 currently being implemented and is working very well.
14 I'd like to now discuss briefly the ongoing 15 cooperative arrangments between LIPA, NYPA and LILCO, 16 which I've alluded to, as has Richard Kessel in our 17 remarks.
LIPA, NYPA and LILCO have established good 6,1d 18 regular working relationships.
For example, LILCO is 19 currently sharing with LIPA and NYPA its site 20 characterization data and has provided data to LIPA in 21 connection with the preparation of the decommissioning 22 report which we submitted through LILCO to the NRC in 23
- April, 24 In addition, has been mentioned, LIPA has 25 established a site office which is being manned on a daily
36 1
basis by personnel from ABZ, who, as I've indicated, are 2
consultants to LIPA.
ABZ is monitoring LILCO's site 3
characterization program and is familiarizing themselves 4
with the Shoreham facilities.
That effort will assist us 5
as will, of course, the New York Power Authority's i
6 exanination of the facility in the preparation for the 7
assumption of the license and its maintenance and 8
decommissioning of the Shoreham Nuclear Power Plant.
9 I'd like now to discuss briefly LIPA's next 10 steps, particularly its license transfer application and 11 its decommissioning planning.
Jack and Les will describe 12 those activities in further detail.
13 In accordance with the settlement agreement, 14 LIPA and LILCO will be filing a joint license transfer 15 application.
LIPA and.'.ILCO will submit an application to 16 transfer the defueled license for which LILCO has applied 17 to the NRC, which is currently pending, I might note.
The 18 license transfer application will be predicated on NRC's 19 approval of LILCO's defueled license amendment application 20 prior to or at the same time as NRC's approval of LIPA's 21 license transfer application.
22 In the license transfer application, LIPA will 23 demonstrate that it has the financial and technical
/
24 capability to assume the license, that there are no 25 significant hazards considerations and no environmental
l 1
issues.
The license transfer application is currently 2
being drafted, and we expect to be able to file it next 3
month.
4 I will now, in my closing remarks, discuss 5
briefly the status of LIPA's planning and NYPA's planning 6
for Shoreham's decommissioning.
As has been mentioned, a 7
decommissioning report, prepared by LIPA with the 8
considerable assistance of the New York Power Authority, 9
was submitted to the NRC in April.
The decommissioning 30 report described LIPA's overall approach to planning the 11 decommissioning.
12 In addition, also in April, LIPA issued an RFP 4
13 to hire an architect-engineer to prepare the Shorehas 14 decommissioning plan and provide related engineering and 15 license services.
16 The due date for response to that RFP is June 11 17 of this year, and we expect to be able to hire a 18 consultant in July.
We are also evaluating three NRC 19 approved decommissioning alternatives and hope to choose a 20 method this summer.
21 Finally, we will submit the final 22 decommissioning plan and supplemental and environmental 23 report next year.
As will be discussed by Les Hill, LIPA 24 and NYPA, as well as LILCO, are currently evaluating
{
25 options for the disposition of spent fuel, and Les Hill
sla 1
will describe that evaluation in a further detail.
That 2
concludes my portion of the presentation.
3 MR. MURLEY:
One question:
I don't mean to harp 4
on this funding thing, but it's something that I know 5
we're going to want to look at.
We all recall Hurrican 6
Gary.
I guess it swept over Long Island.
If something 7
like that were to happen and cause some serious damage and 8
caused some funding that needed to be done for safety 9
reasons, would that be forthcoming under this agreement?
10 MR. KLIMBURG:
The agreement provides ironclad 11 guarantees to LIPA that LILCO will pay for all costo 12 related to Shoreham, and those categories, of course, are 13 clearly laid out in the settlen.snt agreement.
But they 14 will cover all of LIPA's and NYPA's costP associated With 15 the asset transfer, the license trans'.er and the 16 maintenance and decommissioning of Jhoreham, the 17 disposition of fuel and any otner related costs.
18 MR. SCINTO:
I just want to interject.
You've 19 repeated that concept of the funding related to the 20 decommissioning cost.
I think our concern is does the 21 funding clearly apply to your costs for-maintaining the 22 plant in a safe condition as it proceeds?
23 MR. KLIMBERG:
The agreement is very clear on 24 that nubject.
It makan clear that the maintanance of 4
25 Shoreham pending decommissioning is a cost attributable to
~
~
JW 1
Shoreham and will be paid for by LILCO.
Indeed, all the 2
costs attributable to Shoreham from the point of work on 3
the license transfer, the asset transfer, through the 4
completion of this project, and any continuing LIPA 5
ownership of the facility will be paid for by LILCO.
6 MR. STAFFIERI:
Let me add to that, that indeed 7
LILCO will be paying all costs associated with LIPA's 8
efforts at Shoreham keeping it in a safe condition.
Wo 9
have done so on the basis that the Public Service 10 Commission in turn has agreed all of those costs will be 11 passed on to the rate payers.
12 MR. PARTLOW:
In terms of our regulations that 13 say, I think, on July 26, all utilities need to certify to 14 us that they have a method of funding available.
Will 15 that certification be made by LILCO will and it reference 16 to the PUC's decision, is that what represents your 17 certainty of funds?
18 MR. STAFFIERI:
LILCO will be making the 19 certification to you and like it will include --
20 MR. KLIMBURG:
I might add that our agreement 21 with LILCO is not conditioned upon any particular rate 22 increase or rate approval.
It is an irorOldd assurance 23 that LILCO will provide LIPA with the funds involved in
(
24 the acquisition and transfer and maintenance and 25 decommissioning of the facility, fully consistent with all
w 1
the regulatory requirements.
2 MR. KESSEL:
Before I introduce Jack, let me 3
just mention on that issue that the general counsel 4
I'll point out the Public Service Commission is with us 5
today, Bill Cowin, who I neglected to mention before --
6 Bill and I go back a long time as well and even on some 7
Shoreham cases, I think, and Bill has been working with 8
us.
I point-out to you that we do have a working group.
9 I ought to point this out, that every month or so the 10 chairman of the_New York Power Authority, Richard Flynn, il myself, my staff, Stan, Vic and the president of LILCO, 12 Tony Early and Bill Cowen, the general counsel of the New 13 York Public Service Commission, and also some other staff 14 people from the governor's office and counsel ueet to 15 discuss issues on a top level basis.
While staffs meet 16 all of time, the fact is we personally meet on a regular 17 basis
.o discuss many of the issues we bring forward to 18 you here today.
19.
I'think that the funding mechanism is no 20 different for the Long Island Power Authority than it 21 would be for any of your other licensees, that obviously 22 have to eventually get funding approved by the State l
23 Public Service Commission.
That funding has been l-1.
24 guaranteed to LIPA through LILc0 no differently than any j --
25 other licensee, which obviously is passed subject to
~
- ~
l 1
regulations.
2 With that, I'd like to introduce Jack Brons.
I 3
already gave him a big warm-up before.
So I just wanted 4
to say that Jack is the person who will be in charge and 5
is in charge of LIPA's nuclear operations, and with that 6
I'll turn it over to Jack.
7 MR. BRONS:
Thank you.
We wanted to present to 8
you our proposed organization, at least the large 9
framework of the organization that we have, and 7 hope to 10 demonstrate to you that it has clear lines of 11 responsibility and communication delineated.
12 I would also like to point out that LIPA has 13 been very good, as Richard has described, in involving us 14 with the LIPA board.
Les and I met over at the LIPA board 15 last week to discuss these issues.
I've appeared before 16 tne board before and I would expect in the role that I'll 1,
have in co-employment to have direct access to the LIPA 18 board.
I found them to be very thoughtful and truly 19 concerned about doing this job right.
20 As LIPA's senior corporate nuclear officer, I 21 w i'1 1, as Rich indicated, be co-employed LIPA.
So I will 22 have my responsibilities to the New York Power Authority 23 but separately be employed by the Long Island Power 24 Authority and acting in that role.
25 Reporting to me, there will be several current k
1 NYPA employees who will also become co-employees of LIPA, 2
but they will be working exclusively on the Shoreham 3
project.
So except for myself, other co-employed 4
employees will be exclusively devoted to the Shoreham 5
project.
6 MR. MURLEY:
Including Mr. Hill?
7 MR. BRONS:
Yes.
As a co-employee who will be 8
exclusively on that project.
9 It was mentioned earlier, and I think Jim raised 10 the question, about the independent review panel.
We have 11 prepared and will be submitting to you in the license 12 transfer application a charter that we expect for that 13 group.
Our current planning and what we expect to present 14 to you is that it will be comprised of five individuals.
15 They will be selected by the LIPA board of trustees.
It 16 is very important to us, speaking as a New York Power 17 Authority employee in this case, but also as a subsequent 18 co-employee of LIPA, that they be independent of the 19 operating organization, so that selection, we will not 20 play a role in that selection.
We may play u role in 21 identifying potential candidates, but the charter calls 22 for people from industry and from academia and perhaps 23 from the national laboratories, who have the necessary
/
24 experience to have an independent quality oversight and 25 have the judgment and the wherewithal to look at what we
{
I do.
2 We envision that we will -- the charter provides 3
that they'll be provided with all of the materials that 4
are involved with the project, certainly quality assurance 5
reports, our operating reports, any event reports that may 6
be generated.
We expect that, and the charter calls for 7
them to visit the plant on a periodic basis and then to 8
meet probably with us, the LIPA staff, and then 9
independently brief the board on their oversight 10 activities.
11 The site staff, when the license is transferred, 12 will be under the day-to-day direction of Les Hill, who is 13 currently our director of special projects, and will 14 become the LIPA resident manager for the Shoreham station.
15 We are involved today on a fairly substantial basis at the 16 station.
We have one employee in residence there 17 full-time now.
We would expect to become resident before 18 the license is transferred.
19 My point is I want to assure you that is not 20 going to be an operation that is run by some people 21 remotely from headquarters.
These co-employee people will 22 be stationed at the tacility and actually involved in day 23 to day management of the operation, 24 We're also going to fill out the site staff with g
25 some NYPA people who will not be co-employed but will be
44 1
l 1
out there.
so many LIPA people and LILCO people -- and, 2
Jim, I believe you raised a question about the direction 3
of LILCO people.
The agreement provides specifically that 4
those LILCO employees who are selected to remain at the 5 'Shoreham station will be accepting direct managerial
+
6 direction from the Power Authority.
7 It also provides that the labor relations 1
8 aspects will remain with LILCO because we do expect that 9
there will be a large number of people eventually at 10 Shoreham who will remain at Shoreham, and to the extent 11 that it involves bargaining in the relationship, Long 12 Island Lighting will retain that responsibility, and, as I
13-you know, we will have people at the organization who are 14 _LILCO employees to deal with those issues.
15 But as far as the provision of direction or 16 management, that is included in the agreement.
The main 17 idea behind these provisions is to make the actual l
18 transfer of the license relatively unimportant to the i
19 operation of the station.
We want it to flow very l
20 smoothly.
r 21 Going to the organization chart which is on the 22-next page before you, we show the key features we've 23 talked-about here, the independent review-panel reporting
{
24 to the chairman and a board, probably going to show two.
l 25 lines there, and then the LIPA executive vice president u-.
1 reporting directly through the chain to Stan.
2 And, as I advised you before, we also have had 3
frequent access to the b1PA board and would certainly 4
expect that to continue.
5 We have retained -- you'll see dotted linen 6
coming out of the executive vice president box.
That 7
really should be a solid line.
We've retained a quality B
assurance department head who will have direct access to 9
me but will be physically present at the site and by 10 taking day-to-day dotted line access an'd direction from 11 the Shoreham resident manager.
12 We have highlighted on the one that is the 13 organization chart that is being projected, those 14 positions which we expect to be co-employed. For those of 15 you that are looking at the graph, that is the executive 16 vice president position, the resident manager position, 17 the quality assurance department head, the department head 18 for operations and maintenance, and the decommissioning 19 department head.
20 There will be co-employees as well as the 21 director of radiological controls and licensing and 22 regulatory compliance department head.
23 The notion behind the scope of those positions 24 who will be co-employed, it's not the full scope of the
(
25 New York Power Authority employees that will be working on I
1 this project, but these are the ones that will be 2
employees of LIPA and working exclusively on the Shoreham 3
project.
4 Our intent is to assure you that in any dealings 5
that we have between the Nuclear Regulatory Commission and 6
LIPA, you will be dealing with employees of LIPA.
7 MR. PARTLOW:
No Shoreham employees will be in 8
the department head or director position?
9 MR. BRONS:
Not in those positions, that is 10 correct.
There will be shoreham employees certainly 11 working -- LILCO-Shoreham employees, I understand your 12 question, wo: king very closely with these people but wo 13 felt that as a licensee it was important that the 14 leadership of those departments be LIPA employees since 15 LIPA is the licensee.
16 I do not mean to imply at all that thera is twy 17 discontinuation being made about the quality of the L1 18 employees at Shoreham.
Indeed, we find them to be very 19 talented people and we expect to have them there for 20 continuity and continued good performance at the station.
21 MR. VARGA:
Am I going to have to worry more 22 about Fitzpatrick and Indian 3 than I usually do?
23 MR. BRONS:
No, Steve, I don't think you will.
24 It's a good question and I'm glad you raised it.
I don't 25 want you to have to worry about those anymore.
Recognize,
QV 1
first of all, the only person that will have a dual role 2
in this is me.
3 In addition, we have had the very fortunate 4
circumstance of the core group here of people that will be 5
co-employees of LIPA who worked for Les in the special 6
projects group, which is a group of people that did the 7
generator replacements at Indian Point.
The organization, 8
the New York Power Authroity organization was not 9
dependent upon that group of people for the day-to-day 10 operations of these two plants.
So, as a core group, 11 we're able to move that without disrupting our operation 12 and hopefully raising concern.
13 secondly, there cre other people being drawn 14 from the organization, but they are being taken out, one 15 person from one group and another from another.
We are 16 not disrupting any other function in any significant way.
17 MR. VARGA:
And you feel from your personal 18 involvement, the percentage of 19 MR. BRONS:
At this particular point, because of 20 presentations such as this and because we are setting up 21 the initial stages and fairly heavily involved with the 22 LIPA issues, as time goes on I expect to remain involved, 23 but I expect relative to the day-to-day operations that 24 Les wd11 take much of that responsibility and I will l
25 fulfill the kind of oversight role, that I think will not k
OG 1
1 dilute the quality of our operations.
2 MR. MIRAGLIA:
Can you comment on the relative 3
size of organization?
4 MR. BRONS:
Well, it's not too premature.
If I 5
understand your question correctly, relative to the size 6
of the New York Power Authority involvement, including r
7 those people who will be co-employed, we're talking about 8
a team of people that is in the range of 30 individuals 9
that will mix in with the present Shoreham management to 10 cversee this.
11 I'm not prepared to give you a number of what 12 the size of the total Shoreham count is.
Les can perhaps 13 addrass that for you.
14 The current activities that we have underway:
15 We're working on the licenae transfer and plant 16 acquisition work.
We are developing corporate and site
(
17 staff organizational materials, such as the charts of 18 organization, departmental charter position description; 19 all that material is a necessary piece of the license 20 transfer request and that will be put on the docket 21 shortly.
22 We're also reviewing LILCO's programs and 23 procedures for use by LIPA, and the intent there is that 24 we maintain stability of the progrras With a large
{
25 contingent of LILCO people working on this.
We don't
y, 1
intend to come in and impose unfamiliar programs on them.
2 High quality programs exist at the station that are being 3
modified to the extent that it makes sense to fit the 4
conditions of the defueled license, but other than that 5
the baseline LILCO programs, we certainly expect that once 6
that license gets on the docket, through the normal 7
inspection process and interaction between us and the NRC, 8
that you will look very carefully at all of those things 9
and we expect that to be a part of the process.
10 We're also doing a very thorough review, which 11 was initiated by the asset transfer agreement, of those 12 licenses, and we are working on what is necessary to 13 transfer those licenses and permits as they exist to LIPA.
14 In some cases, they will just simply have to be 15 assigned; in other cases, they will require some agency 16 approval.
But we will be maintaining the infrastructure 17 that exists there.
18 We are also working at tracking the LILCO work 19 review and I would like to stress that is e cooperative 20 effort when LILCO makes license submittals or submittals.
21 We have been involved as we have prepared things for you.
22 LILCO has been involved, and it's working quite well.
),
23 We also are participating with LILCO people and 24 representing LIFA in the NUMARC group that is dealing with g
25 decommissioning issues, so that hopefully we don't present
50 l
1 anything to you that is in conflict with anything.
We're 2
reevaluating all decommissioning alternatives, pursuing 3
some options to remove the fuel from the site.
4 There is only one point that I would like to 5
make about that particular set of issues and that is we're 6
going -- we intend to do this decommissioning with a 7
completed set of engineering.
There is no intention to 8
jump the gun on anything.
We expect to do a full 9
decommissioning report and then present it to you when 10 it's fully engineered.
Then we'll start working.
11 MR. MURLEY:
Jack, I have a few questions about 12 the site in itself.
Is this as good a time as any to 13 talk?
Mr. Kessel talked about the option of possibly 14 converting the Shoreham site to a gas fired plant, and we 15 know that has been done at some places, so it can be done.
16 On the other hand, it brings up questions of 17 access to the parts of the site and who controls it.
Then 18 there is the separate question of security at the site and 19 where does LILCO's security end and where would LIPA's 20 begin.
21 Also, I know that in the past, at least you used 22 diesel generatore to supply power to the grid, and that 23 has aspects of who controls the switch yard and that part
{
24 of the site.
25 Could you talk about this in general?
l
l l
1 MR. BRONS:
First of all, generally speaking, 2
relative to the conversion project, LIPA is well aware 3
that the primary task is to decommission the plant and 4
conversion is being looked r,t in that.
5 To the extent that there is something mutually 6
exclusive or required access to a security place, for 7
example, after decommissioning, comes first, but we do 8
have a charter under the statute to look at alternative 9
uses and they are beginning to do that, but it is not 10 envisioned as something we're going to present for some 11 remarkable or unusual solution in order to accommodate the 12 conversion while decommissioning is going on.
13 MR. MURLEY:
So it's fear to say, is it, that if 14 that option were chosen, we would deal with access and 15 security on that thing as a license amendment at that 16 time?
17 MR. BRONS:
Absolutely.
Relative to the 18 security issue, we are developing a security plan which 19 will be consistent with the boundaries defined in the 20 asset transfer agreement for what will be transferred, and 21 we expect that security plan will be presented to you for 22 your approval and it will meet all of the security 23 requirer.ents.
24 As we proceed on down the line if, for example, 25 we're successful in transferring fuel off-site at an early I
4 1
date, then we would present an amendment to the security 2
plan that would account for that, and we certainly see 3
that as being a continuing process as decommissioning --
4 once the decommissioning plan is approved, it will 5
probably have several stop points in it.
i 6
We will further retrench the security boundary 7
to be consistent with the state of the plant as it i s 8
being decommissioned, but I think that the plan is that 9
that be done completely through the license and properly 10 submitted security plans and approved by you in advance--of 11 taking any action to modify the security program.
12 MR. HURLEY:
Perhaps LILc0 can -- I don't know e
13 about-the question to use the diesel generators to supply 14 power to the grid.
15 MR. BRONS:
I could talk about it.
The site 16-agreement is very detailed in the control of electrical 17 supplies, taking into account which controls are inside 18 and outside the boundaries, and it deals with more than 19 just electrical lines.
That deals with telephone lines, 20 and so on, because there is very detailed presentation of 21 that l'n the site cooperation agreement.
It does envision 22 that LILCO will be able to use some of the diesels out 23 there.
24 As you know, there are several sets of diesels
[
25 on the Shoreham site.
The cold diesels, if I'm direct in
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the designation, they are actually outside the asset 2
transfer area and they are the ones that will be used.
3 The site cooperation agreement deals that with that very 4
explicitly.
-5 MR. SIEGERT The GM diesels, ten megawatts of 6
power.
Those we have supplied to the grid and we would 7
intend to run those as long as we had them and they will 8
stay with us after the transfer to the Long Island Power-9 Authority.
The TDI engines we have not run in the past.
10 MR. BRONS:
The next page in the handout-is an 11 organization chart which I will only comment on briefly.
12 One is to give you a notion of the scope of the Power 13 Authority people, the New York Power Authority people that 14 are assisting LIPA in this effort at the present time.
15 I would make the point that because we are 16 taking a person here and a person there -- Les has been 17 given the charter and because of the representation that 18 his group has developed in the past, he has access to some 19 of this.
An example is that the department head for 20 quality assurance, because we didn't have a quality 21 as'surance person in the steam generator replacement 22 -project, we used people from the quality assurance 23 department, but we now have a need for a quality assurance 24 person.
The individual needed was the quality assurance 25 manager at the Fitzpatrick plant for seven years, so he 4
I has a lot of experience in this specific line of work.
2 With that, I would like to turn it over to Les 3
Hill.
4 MR. PARTLOW:
Back on the overall organization 5
chart, the independent review panel, that is part-timers, 6
isn't it?
7 MR. BRONS:
Yes.
8 MR. PARTLOWs I guess the question is sort of 9
the executive director and the president -- in there going 10 to be anybody at LIPA headquarters that gives you advice 11 on a daily basis about radiological control factors?
12 Where are you going to get that from?
Are you going to 13 rely on part-timers to a degree?
The answer, as this is 14 configured, is that they are going to be relying on their 15 employee, me.
You're not going to be a daily employee at 16 LIPA headquarters.
17 MR. BRONS:
Les will be a daily employee at the 18 site.
19 MR. PARTLOW:
Where is headquarters?
20 MR. KESSEL:
Garden City, New York.
It's on 21 Long Island.
It's about 30 or 40 miles from the plant 22 itself.
23 MR. PARTLOW:
I just offer that for your 24 consideration, to have somebody around when you need 25 advice.
[-
1 MR. KESSELt Just to answer that in terms of our 2
capabilities, I think we've established again regular l-3 communications with NYPA, Jack and Les Hill, through Stan l
4 and my conception is -- and others at LIPA
-- and I think 5
I certainly understand your requirement there, and I think l
6 that is very, very simple to fulfill.
I don't see any 7
problems with that whatsoever.
l 8
MR. MIRAGLIA:
Is there a number projected for 9
selecting LIPA employees within the context of the 10 organization, other than a LIPA NYPA co-employee?
11 MR. KLIMBURG:
One, we have not made a decision l
12 on precisely what our requirements will be in that matter.
13 MR. KESSEL:
Let me just assure.you that we will 14 have-enough staffing to satisfy all of your requirements 15 and enable us to monitor and do our job, but as few people
-16 as possible to be cost-efficient-and to try to keep rates 17 down.
We recognize that we need to have certain= expertise 16 'on our own staff, and I think Jack and stan have outlined 19 to you that as.well.
At this point in time, we don't want 20 to create a bureaucracy for the sake of creating a 21 bureaucracy, and I:think these arrangements work very-22 well, not only in the sense of having'NYPA's experience, 23 but also in being able to monitor and maintain a low cost
(
24 position.
25 MR. KLIMBURG:
We have been giving some thought
l l
1 to hiring NYPA employees who would report to me to assist 2
se in my activities, in addition to our hiring Jack and 3
Les and other NYPA employees as LIPA emloyees.
4 MR. SCINTO:
The chart that you just provided, 5
the Long Island Power Authority that has approximately 25 6
boxes in it as people identified as directors, but only 7
seven of those are doubles.
So aren't the rest of those 8
people going to be LIPA employees?
9 MR. BRONS:
They will be New York Power 10 Authority employees working full-time under the management 11 services agreement for LIPA, and, in addition, some of 12 them may be actually LILCO employees.
13 MR. SCINTO:
So we're basically talking about 14 the darker looking boxes are LIPA and the lighter looking 15 boxes on that are essentially under the management 16 services organization; is that correct?
17 MR. BRONS:
No, that is not correct.
18 MR. SCINTO:
Please explain it to me.
19 MR. DRONS:
There is a footnote that shows --
20 MR. SCINTO:
For seven people.
21 MR. BRONS:
Yes.
But that is not the lighter 22 and darker box.
For example, towards the bottom of the 23 chart, right underneath where it says site review 24 committee, there is an operations and maintenance 25 department head which will be a co-employee of LIPA and
l 1
immediately below that is the radiological controls 2. director who will be a co-employee of LIPA.
?
3 MR. SCINTO:
How about the maintenance director, 4
is he going to be a LIPA employee or is he going to be 5
someone provided by NYPA under the service agreement.
6 MR. BRONS:
He will be provided under the 7
management services agreement?
8 MR. SCINTO:
The question I was getting at on 9
this organization chart, which identifies the Long Island 10 Power Authority organizational chart, there are 25 boxes, 11 but only seven of them are as co-employees.
I inferred 12 that those boxes that were not marked as co-employees 13 would be LIPA employees.
I understand now that I'm wrong.
14 MR. BRONS:
Yes.
15 MR. HILL:
The first subject that I'm going to 16 touch upon is the license transfer process and the 17 transfer of the plant over to LIPA.
18 Mr. Kessel has mentioned we are in the process 19 of assembling a license transfer submittal that will 20 request your approval of the transfer of the license from 21-LILCO to LIPA.
I'd like to mention at this time that the 22 basic foundation for the entire process and the entire 23 package is the defueled license, the DSAR package that was 24 submitted by LILCO in January of this year.
That forms 25 the basis for all of our plans and all of our actions to i.,.n.',
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date and in the future.
2 MR. MURLEY:
Could I ask a question, because I 3
think it's going to color at least my understanding of the 4
rest of the discussion.
5 Mr. Kessel, you mentioned in your introductory P
6 remarks that LIPA is seeking the transfer of the defueled 7
license and not the current operating license that exists.
8 Is that an absolute requirement or condition?
Have you 9
thought about that?
There are some questions we have with 10-this license condition; there are some policy questions, 11 and what I was getting at is, it might take some time 12 before we can actually get to the defueled license action 13 on our part.
14 MR. BRONS:
That is not a statutory requirement t
15 of LIPA; rather, it is the basis on which we are preparing 16 the license transfer request.
The organization that we 17 intend te present to you is based on the assumption that 18 -the plant is in that condition.
19 To the extent that the license transfer request 9
20 requires us to identify technical specifications and other 21 technical matters, it is based on the assumption that the 22 plant is defueled, not going to operate, as opposed to 23-something else.
We certainly are prepared, and in the
[.
24- ' interest of moving as quickly as we can, to not present 25 you with something that artificially imposes difficulty
. ~. _, -. -
g. _ _..
1 for the commission.
2 If there is some other set of circumstances, we 3
can adjust to that, but,a want to transfer a stable 4
license, a stable condition plant.
5 MR. MURLEY:
This is a hypothetical question, 6
but suppose this -- what is it called -- a defueled 7
license amendment that is in front of us.
Suppose that 8
for whatever reason it looks like it was going to be 9
substantielly delayed before we could act on it, would you 10 consider moving ahead with the transfer anyhow?
11 MR. BRONS:
Yes, we could and we would if we 12 were knowledgeable of that, but I'll stress that the legal I
13 considerations, we are only authorized to acquire the 14 plant for the purpose of decommissioning, so we would find 15 that we have problems for accepting an operating license.
16 MR. KLIMBURG:
I'd like to interject for a 17 moment.
LIPA is authorized to acquire the-plant in its 18 current condition.
We are simply not authorized to 19 operate it.
We have proposed and are planning to present 20 the license transfer application to transfer LILCO's 21 proposed defueled license because we believe that that 22 would be the most expeditious way, consistent with our 23 long term objectives of transferring the plant to LIPA, 24 maintaining it, and then ultimately to decommission it.
I
[
25 must stress we have the legal authority to accept the 0
du^
1 current license if that appears to be the most effective 2
way of proceeding.
3 MR. KESSEL:
Let me just also say, you used the 4
word absolute.
It is certainly not absolute.
I think our 5
policy considerations -- and I think that there has maybe 6
been a misnomer out there in terms of what is going on, 7
what LILCO is doing.
And I think that working 8
cooperatively and talking with LILCO, it was felt with the
)
9 company that in the best long-term interests of safety 10 requirements, as well as the best long-term interests of 11 LILCO rate payers, that a defueled license was and is the 12 way to go.
And, in fact, we would certainly encourage you 13 and are supportive of LILCC's license.
14 Obviously, we feel that granting that license 15 amendment as quickly as possible, meeting all of your 16 specifications and requirements, not only would meet all 17 safety requirements that are established here at the 18 Nuclear Regulatory Commission, but again -- and I must 19 emphasize -- this in the long run will save Long Island 20 Lighting Company rate payers a great deal of money.
We 21 don't see this as what we are er_ aging in now is 22 decommissioning the plant.
We are not engaging in 23 decommissioning the plant right now.
We're certainly 24 making plans in those directions.
25 We would hope that -- and I think Jack pointed
1 out -- that we intend to file the license transfer 2
application, again based upon that defueled license.
3 We're going ahead to do that because we want to move the 4
process along, and again as expeditiously as we can move 5
on the license amendment as well and on a license trancier 6
application, understanding the objectives and where we're 7
going, I think as long as we meet the requirements, I 8
think it is in the best interests of all concerned 9
parties, but it is not an absolute issue.
10 MR. MURLEY:
As you know, there are some 11 questions that are pending that are not before us, and 12 it's not at all clear how soon these questions -- some of 13 them involve policy questions from the Commission.
How 14 soon we will be able to act on that?
For our thinking on 15 the subsequent discussion here, I kind of needed to know 16 whether there was an absolute requirement.
17 MR. STAFFIERI:
Insofar as the company is 18 concerned, and we have made some recommendations to the 19 Long Island Power Authority, but if we suspected we should 20 transform the situation because of delays with the 21 consideration of safety analysis report and subsequently 22 the defueled operating license, we would certainly change 23 our recommendations.
(
24 MR. KESSEL:
Just as an afterthought, our 25 working group has certainly discussed this on a regular
I 1
basis,'and I don't know that one is mutually exclusive of 1
2 the other in terms of ciming.- Again, while I recognize-3 that it's not a decision tha' O.t may make tomorrow, 4
hopefully the day after tomorrow, maybe, but as quickly as 5
you can.
6 We also recognize that, for instance, it may not 7
be finalized by the time we're ready to prepare to submit 8
our license transfer application.
We don't see any 9
matters concurrently.
In other words, as I think I 10. mentioned, it's not a process that goes one, two, three, 11 but rather we're trying to do as much as possible, again 12 in a way to be cost efficient for the rate payer.
13 MR. PARTLOW:
It is, I guess, the case, as Jack 14 ' mentioned; that is perhaps that you have-not built into 15 your organizational plans maintaining the operating 16 qualifications of 1$ censed operators under the current 17 organization; is that_.an example?
18 MR. BRONS:
That is a consideration that would 19 be in our license transfer request, but it is not a
-20 significant barrier because of the arrangements that we 21 have with LILCO, who is maintaining-those people, and they 22 would. work under our supervision.
'23 MR. PARTLOW:
But you would have to factor that 24 in.
j 25 MR. BRONS:
But we have to take some baseline on
I which to prepare the license transfer request.
2 MR. KESSEL:
I think Jack makes a point, just in 3
the interim time period that is involved.
4 MR. HILL:
Again, along those same lines, I 5
wanted to specifically mention, we would specify as 6
license change the fuel is not to be reloaded into the 7
reactor for any purpose.
Again, it's consistert with the 8
previous discussion we had on the type st license that 9
we're looking -- the nature of th( i lcor.m wa're looking 10 to transfer over.
We're looking to devalcp taat based on 11 the LILCO programs.
It's going to b5 cons 12 tent with the 12 requirements and the actions necocaary to carry out our 13 job out there in a responsible fasnJem, 14 Your question earlier about the specific numbers 15 of personnel, I'm going to get into some specific details 16 about the O and M programs.
17 With regard to the operating plant, we're going 18 to try to distill that which is necessary to maintain the 19 plant in its defueled condition, and out of that we'll 20 define.
I think we'll be able to make some real good 21 assessments as to the number of personnel that will be 22 requisite to perform those functions.
23 The technical specifications, the station l
24 procedures will make provisions as appropriate.
I will 25 note that as far as tech spec revisions are concerned.
64 1
based upon the LILCO submittal, the only changes that I 2
would envision would be those related administrative 3
details for section six, which fleshes out, specifies all 4
of LILCO's administrative functions in tne tech specs.
5 And I'd like to add that the entire package will be 6
focused primarily on plant operations and maintenance in 7
this stable condition, and it's going to tend to not delve 8
into the functions and issues surrounding plant 9
decommissioning.
That will also be addressed in 10 subsequent submittals as we develop them and get to the 11 point where we can get them in to you.
12 As far as the overall infrastructure, the 13 program review and event that we are conducting, what we 14 want to do is to identify what it is, what we're supposed 15 to be managing out at the station.
We want to establish 16 programs and procedures that will be necessary to conduct 17 our business in a responsible manner.
18 Ao Jack indicated earlier, the overall objective 19 is to facilitate an orderly and smooth transfer of the 20 ownership of the license to LIPA.
We're hopeful that if 21 we do things right, basically that there won't be any loss 22 in function.
There will be no compromise in safety.
The 23 overall game plan is to conduct this process the day
/
24 before license transfer the same as the day after license 25 trensfer.
I
1 Again, as I touched upon earlier, there are a 2
whole series of additional permits and state and local 3
requirements in addition to those under which you'll be 4
licensed by NRC and we're looking at the transfer of those 5
responsibilities and permits as well.
6 Again, lastly, the objective is to provide for 7
an effective and efficient organization out there at the 8
Shoreham site and a lot of our efforts are not 9
programmatic. It is going to really start to give us a 10 better handle on what the staff needs to look at in a lot 11 of detail.
The scope of all these activities is to review 12 the existing programs and procedures out at the atareham 13 station and to identify their applicability to sawntaining
.4 the plant in a defueled status.
We cerr.ainly recognize 15 that because of the change of ownership of the facility, 16 because of some certainly organizational changes, we're 17 going to have to make some changes to existing procedures 18 and programs that are out there.
19 We intend to minimize that to the extent 20 feasible, recognizing again we're going to need to follow 21 up on local licenses and permits and contractual matters 22 between LILCO and outside entities.
23 Just to give you an overview of the scope of the 24 programs, our efforts are going to touch basically all
{
25 walks of life out there at the Shoreham station.
At this N.
i 1
point in time we're going to review programmatic 2
infrastructure procedures.
We not only want to become 3
completely familiar with the way of doing business on the 4
refueling basis for the Shoreham to make it applicable to 5
the plant in its current status.
6 I guess some other aspects and guidelines th6t 7
I'll mention in the conduct of doing business and 8
conducting this program review and program development, 9
we're going to rely extensively on a DSAR for conducting 10 our reviews.
I want to emphasize and maximize the use of 11 existing resources that are out there, both people and 12 software and programs and procedures.
They seem to be 13 working quite well. We want to maximize our utilization of 14 what is out there.
Certainly, it would be foolhardy to 15 impose a whole new set of procedures and programs and the 16 people out there who are hopefully going to be retained to 17 work for us on Shoreham maintenance.
18 Lastly, I'd like to emphasize that we intend to 19 be out at the Shoreham station, lock, stock and barrel as 20 project organization, well in advance of the actual 21 transfer in the license.
And, in fact, I presently have a 22 staff engineer who is working for LILCO.
He's physically 23 working for LILCO right now and conducting business as a l
24 LILCO employee and I think it's going to yield benefits 25 for everybody that it inve'ved.
I 1
1 We'll get a bit of insight as to how LILCO 2
functions as a utility. Certainly, LILCO has an able 3
e: gineer working for them as well, so it's going to yield 4
some benefits for us, but yet again, on-site well in 5
advance of the license transfer and also there on-site for 6
establishing a project office out in Shoreham station is 7
being mapped by the engineering staff.
8 Based upon our discussions thus far, there 9
would be approximately 30 NYPA employees plus some mission 10 of LILCO's and others that we'll have better time at the 11 time of the transfer application.
We're in the process as 12 time has gone on since -- at this stage of the game all of 13 us, all my project team members are becoming more and more 14 NYPA staff and we've initiated discussions with LILCO 15 management about specific individuals who may be 16 interested in staying onboard, under whct circumstances, 17 and we're starting to work through all the details 18 associated with assembling this group, and we're doing 19 that kind of in parallel with assessing what our needs are 20 as well, and I think we'll have a better handle on it.
We 21 are today, as f ar as our knowledge of LILC O's personal and 22 staffing, and we are today versus where we were three 23 months ago.
(
24 I think we've got a pretty good handle on what 25 we need to do to establish an effective staff out there.
_..~ -.-.._ _.
68 1
As'-far as decommissioning approaches are-concerned, we 2
have-initiated an overall study of th'e various options 3
available-to us to decommission the facility as defined in 4
the decommissioning rule.
We'have learned an awful lot 5
from it.
We're conducting an evaluation of the three 6
alternatives that we view as viable for Shoreham.
7~
-Our current thinking right now is that the 8-decommissioning alternative is going to be the most
-9 appropriate, given the conditions out at Shoreham.
The 10 by-product is an extremely limited operation of the 11 station.
There are extremely low levels of radioactivity-12 out there, very limited period of core operation and the l
13 contamination-levela are also significantly quite minimal.
- 14 So we feel that given the current radiological conditions
. 15.out there, that some benefits offered by safe store and a -
lo tomb are minimized to some degree.
= 17 We also see-a very large benefit in the 18 assumption that the immediate decom alternative, that-we 19 have access to a lot of-station staff personnel who know 20 the facility inside and out and will be available to work u
-21 with us inside;the Shoreham project.
22 Just from a staff availability standpoint, we t3 see the decom alternative being -- those available staff f
24 members, as far as the options are concerned, the
,-r l
25 immediate decon option does allow for some other purpose L
l
.s,
-,,..-,m.
1 by LIPA or LILCO or some immediate basis,.certainly some 2
assets out there that represent some value that-are used 3
for other purposes.
4 The overall decommissioning approach, we're 5
right now contemplating an immediate decom technique-that 6
would result in minimal dismantling or disassembly of the 7
facility, only that which is necessary to remove the 8-radioactive material from the site-and thus remove the 9-licenses.
10 I believe that is going to happen just as a 11-by-product of removing the material, the radioactive 12 material from the station.
b 13 As far as the engineering process itself, that 14 was previously touched upon.
The engineering phase of 15 plant decommissioning, to give an overview, we're going to 16 foster, I guess, for lack of a better term, due
-17 engineering process for Shoreham decommissioning.
We want 18 a carefully evaluated and engineer-effective
-19 decommissioning.
20 Some of our initial activities will-be v
21 conceptual in' nature.
We're going to start and look at 22 the big picture and when we understand the big picture, 23 we're going to get into the details.
Some of the initial 24 study activities will be just flatly to identify the scope
(_
25 of decommissioning. We're going to look at the
1 characterization data.
We're going to balance that 2
against the plant description.
We're going to identify 3
for our purpose what is it we're decommissioning.
We're 4
going to define what decommissioning is.
We're going to 5
evaluate various techniques and processes that are 6
available to us to achieve those objectives.
I think 7
there are a lot of group techniques and capabilities out 8
there.
We'll be developing a conceptual schedule, 9
basically take a broad look at those actions necessary to 10 decommission the facility, subsquently through our 11 conceptualization of the project and developments of 12 consultant studies -- and we're looking at that process to 13 be conducted over a period of two, three, or four months.
14 We're going to identify the scope of detailed engineering 15 that is going to be necessary to carry out the work.
Our 16 basic would be --
17 MR. MIRAGLIA:
Sorry for interrupting, Les, but 18 could you discuss at this point what the relationship is 19 with the architect-engineering firm?
Are you going to 20 develop the concepts and then an A-E will be the actual 21 firm that implements it?
22 MR. HILL:
The A-E would perform the conceptual 23 study.
I will be involved with his activities throughout i
24 the course of his business, as we will be also during 25 detailed engineering. Historically within NYPA -- and I
1 intend ;o carry forth the same notions as the LIPA 2
employees -- we intend to get very involved with the work 3
that is done by our contractor.
So certainly we're going 4
to be working together.
5 MR. MIRAGLIA:
That A-E would be nominally under 6
an engineering director of decommissioning?
7 MR. HILL:
Yes, sir.
8 MR. BRONS:
Maybe I'm interpreting something 9
that is not there, but the A-E that we're talking about 10 here is doing the engineering only.
We're not talking 11 about a layered approach, but really a person that is 12 going to be doing decommissioning, an A-E.
He's just i
13 doing the engineering at our direction to a very detailed 14 specification.
The project is broken up into a couple of 15 phases. The first one is to do what we're calling 16 conceptual engineering.
We will then approve that or 17 disagree with it and get it to our liking.
18 By then he will be chartered to do the detailed 19 work, packaging the actuc) detailed plans that you all 20 will want to review and approve., but that then at the 21 completion of it, that guy doesn't then come out ano do 22 the work.
23 MR. HILL: That is going to form the basis, using 24 LILCO and NYPA resources and LIPA resources.
We'll make a
(
25 determination when we have identified and defined what 1
l
l 1
decommissioning means to us.
We'll determine at that 2
point how best to package the work and how to procure and 3
bring on board the resources to truly carry out the work, 4
the detailed engineering public safety steps, the actual 5
decommissioning. We're going to basically take a 6
conceptual finding, expand the engineering work package 7
for detailed implementation, while conducting safety 8
reviews of the related activities.
9 Basically, it,'s going to form the basis for 10 procurement specs for subsequent bidding or assignments 11 for LILCO staff; depending upon what falls out of this, it 12 will form the basis for actual work activities.
It's our 13 experience that in a project of this nature, a very 14 careful and well planned job will go a long way out in the 15 field as far as its implementation, and we intend to carry 16 those same concepts with us along in the decommissioning 17 arena.
18 I'd like to emphasize that through conceptual 19 engineering and detailed engineering it will involve 20 radiological protection, both in our efforts to minimize 21 exposures and in our efforts to minimize waste.
It's 22 impossible to involve this type of expertise when have you 23 a complete engineering package. We're going to involve 24 such personnel, right at the initial stages of project j
25 development. You've got OI relying on extensively LILCO's i
l
g 1
personnel to assist us in this area.
2 Basically, we're going to take conceptual 3
estimates for ways for personnel exposure cost schedule.
4 We're going to expand upon those estimates.
We're going 5
to come up with definitive estimates for radiation 6
exposure cost, come up with a level two schedule, 7
something offering a little more detail, define what 8
decommissioning is all about.
We're going to take 9
basically the engineering, detailed engineering processes, 10 going to culminate in decommissioning the plant, to the 11 NRC for their review and approval, 12 It's going to be representative of an cnergy 13 project.
It's not going to be conceptual in nature.
14 We've fleshed out the details.
We'll have engineered a 15 job when we are done so that when we present the plan to 16 you, you're going to see what is going to be our accurate 17 reflection of what the Shoreham plant decommissioning is 18 all about.
19 Again, as I indicated, it's going to provide a 20 very comprehensive, detailed basis.
We're going to use 21 those packages and determine how best to package the work 22 and take the next step and get the resource needed for the 23 actual decommissioning.
[
24 MR. PARTLOW:
Do you see this plan this year or 1
25 next year?
1 MR. HILL: In terms of times, we're looking to i
2 initiate our efforts at that architect-engineering ia 3
about mid-July, and I anticipate that will be well into --
4 we will be concluding our efforts as far as writing a 5
decommissioning plan some time during the first quarter of 6
next year.
I think some time next year is -- we're 7
targeting some time in the first or second quarter to be 8
approaching the NRC with the decommissioning plan.
We're 9
learning an awful lot as time goes on, on some of my early 10 feeling about what the Shoreham plant decommissioning will 11 entail.
We're learning an awful lot through site 12 characterizations.
So I think, if anything, we're 13 continuing nowadays to think that we'll be able to do 14 things sooner than later.
I think it's going to be a 15 little simpler task to engineer the project than I would 16 have thought earlier on.
17 As far as the fuel is concerned, I certainly 18 think the decommissioning rule addresses fuel.
The rule 19 will certainly be covering something that we view as one 20 of the most critical elements that we have to deal with 21 out at the Shoreham plant.
We collectively, and when I 22 say we, the Shoreham community, including LILCO and LIPA 23 and NYPA, we are directly evaluating three options for the 24 ultimate disposition of the core.
g 25 The first option that we are evaluating and 1
l
g
'I working with-a couple vendors on is the1 sale of this 2
material to another licensee for use in another reactor-3 and_ pursuing that as an option.
4 Secondly, we're looking'at the shipment of 5
material to a commercial reprocessor.
We've got bids out 6
on-the street.
We're looking to receive competitive bids
'7
.I believe there in on July 11 and we're going te certainly 8
evaluate the reprocessing alternative as an option for the 9
disposal of material.
10 MR. MURLEY:
Does the fuel have net value after 11 you've reprocessed it?
It has its urandum --
12 MR. HILL: The material itself does have -- the 13 core does have some considerable value, so that would 14 certainly be factored.
15 MR. MURLEY:
After shipping overseas, after 16 reprocessing of all those costs?
17 MR. BRONS:
Not net positive value.
18 MR. MURLEY:
That was my question.
19 MR. BRONS:
We would be required to make a 20 statement to a facility to do this and-to reprocess the
.21 fuel --
22 MR.-HILL: We'll reinspect bids on July 11 to 23 tell us what that is.
We are also considering the on-site
( -.
24 interim storage of the material of a dry cast nature, 25 something that has some considering that is being
1 evaluated.
2 I'd like to stress that our objective is to 3
remove the material from the site, so certainly any option 4
which achieves that objective, either a sale of material 5
to another utility or the transfer of this material to a 6
reprocessor, both those are alternatives we're pursuing 7
vigorously.
8 MR. MURLEY:
This option of on-site storage, do 9
I understand that to be that you would decontaminate all 10 the rest of the facility but that which is still foreign 11 restrictive access, but there would be still be a storage 12 area that would be projected for some time?
13 MR. BRONS:
We would like to discontinue the 14 Part 50 license and have a Part 72 license for storage of 15 fuel.
16 MR. MIRAGLIA:
Would that be pursued by LIPA?
17 MR. BRONS:
That could be pursued by either 18 entity at this time, depending upon the timing of it.
If 19 they were still the Part 50 licensee and they stored the 20 fuel, they could probably do that with an amendment to 21 their existing license.
It would probably be done by b1PA 22 if it came to that.
23 MR. MURLEY:
They would own the fuel, so they'd f
24 have to.
25 MR. BRONS:
It depends upon if the license
= - - _ _ _ _ - _ _ _
l 1
transfer fuel is still -- we're working very closely.
All 2
parties see this as an urgent issuc to deal with.
3 MR. HILL:
Just to summarize some of our future 4
actions.
Again,we have an architect-engineer on board to 5
work with us on detailed engineering and we're looking to 6
complete those efforts in the top priority and immediate 7
basis so that we can be getting back to NRC as soon as 8
possible on the decommissioning plan.
We're reevaluating 9
three fuel alternatives and we're prioritizing those which 10 offer off-site ultimate disposition of the material, and 11 again we're looking to get decommissir a planning and get 12 it going as fast as we can.
13 MR. MURLEY:
You spoke about getting some bids 14 on fuel reprocessing I think some time in July.
Do you 15 have a target for a decision on what you would choose, 16 what you're going to do with the fuel?
17 MR. HILL: There are three options being pursued 18 and we're going to have to wait until we have a definitive 19 idea on what the financial implications are for each.
So 20 I think we may have the bids in on July 11, but that is 21 one of three answers we need.
22 The other two answers, I think we're going to be 23 negotiating with a couple of vendors, a couple of
(
24 contractors and that answer may fall out beyond July 11 as 25 will the on-site storage.
I think some time by mid-summer 4
1 1
we're going to have a clear definition of what all three 2
options are going to be about.
You have to look at all 3
three.
We have definitive packages to see what it is all 4
about.
5 MR. BRONS:
I think in the big picture we're 6
hoping to have gotten all of the necessary inputs to make 7
that decision and to make it before the fall of this year.
8 MR. KESSEL: I'd point out also at the last 9
meeting of the Long Island Power Authority, the trustees 10 discussed this very issue.
We have been discussing it at 11 our executive level work group now for a number of months, 12 and obviously this is a main priority, again from many 13 points of view.
Obviously, there are many considerations.
14 Certainly there are safety considerations; most 15 importantly, I think also there are economic 16 considerations that again we want to factor in.
And it's 17 something that we all consider a top priority and we want 18 to move as quickly as possible.
19 With that, let me just briefly summarize and 20 conclude.
As I think we mentioned, we are well underway 21 towards moving forward and implementing the Shoreham 22 settlement agreement.
I hope that today we've dealt with 23 a lot of the issues and questions that you will hear.
24 I recognize that this is the first formal 25 meeting between the Long Island Power Authority and the
l 1
Nuclear Regulatory Commission. You heard what LIPA is, who 2
we are, and I hope that today we've given you an 3
indication of who we are and what our intentions are and 4
the depth and seriousness to which we approach the 5
subject.
6 As I said, we are approaching this 7
decommissioning of the plant and this license transfer as B
a very technical issue, and I think the plans that we've 9
laid out here to you today certainly show the amount of 10 work that we have put in and that we will continue to put 11 there to obtain our objective.
12 I think it's certainly essential that we have 13 regular lines of communication between Long Island Power 14 Authority and the Nuclear Regulatory Commission at all 15 levels, both on the executive level and as well as on the 16 working levels.
And, as I said at the opening of my 17 comments, I make myself available and I know Stan is 18 ovailable from LIPA to have those lines of communication.
19 We're available to come down here.
We're available out on 20 Long Island at the LIPA office in Garden City and Shoreham 21 Station on a regular basis and we recognize the need to 22 have those channels of communication on a regular and 23 routine basis.
(
24 Certainly we want to assure you again of our 1
25 desire to work with you cooperatively in the spirit of I
1 l
Gb 1
implementing the settlement in accordance with all NRC 2
requirements and, importantly, with the objective of 3
projecting the safety of the general public and plant 4
personnel and of course also with an absolute goal of 5
protecting the LILCO rate payers in keeping costs as low 6
as possible and we can worn with you on that.
We'd be 7
most delighted to do so.
Thank you.
8 MR. MURLEY:
Thank you for coming down and 9
presenting to the staff your plans.
We can see that there 10 has been a good deal of systematic thought given to the 11 process.
To some extent, as we've mentioned before, we 12 are in new territory for us in terms of licensing on a 13 regulatory approach.
I think we can work our way through 14 this.
I suspect we will have to have these kinds of 15 meetings from time to time.
I would say at least by this 16 fall, that is about the time when a number of decisions 17 are going to be made and you'll have some more working 18 experience.
I think we can tentatively plan on another 19 meeting like this.
Let me ask my colleagues if we have 20 any questions.
21 MR. SCINTO:
I want to get a couple of tiny 22 questions straight.
Somebody from LILCO is planning to 23 submit the decommissioning and funding information July 24 27?
25 MR. STAFFIERI:
Yes, we'll address that
g l
l 1
requirement.
2 MR, SCINTO:
It's not clear from what I've 3
understood so far that under the agreement you're talking 4
about facts that fit into one of three catagories to fuel?
5 And I'm sure you'll provide the necessary information for 6
us to work on determination of whether your plan is 7
acceptable?
i 8
Next, why is the transfer application -- the 9
timing, I lost track of it.
10 MR. KESSEL:
The outside is two months.
We're 11 hopeful, and I'm expecting, we will file that application 12 in June.
(
13 MR. SCINTO:
I can't tell, from what I 14 understand, whether LIPA would qualify as an electric 15 utility under our definition in Part 50, and if it 16 doesn't, we'd have to look at financial qualification one 17 of, and you discussed them briefly in the meeting here, 18 but if you're not an electric utility, we're going to have 19 to understand the financial qualification aagreement in 20 substantially more depth.
Obviously it's one that is 21 going to take a lot of work.
22 MR. KESSEL: We certainly will address that.
23 Mk. SCINTO:
One of the things, I guess there is 24 a lot of discussion of where LIPA will be in its 25 organizational structure.
What is the size of LIPA right
{
l 1
1 now?
How'many employees do you have?
I recognize now is 2
not a significant point.
3 MR. KESSEL:
Just directly with LIPA.
First of 4
all, there is, as I said, an organi stional structure.
5 There is the chairman of the board of trustees.
The board 6
of trustees is not compensated in any way.
They're not 7
full-time and I am the chairman. As chairman I am not 8
compensated, but because I have another job -- I'm 9
chairman of the Long Island Power Authority.
We have had 10 an administrative assistant.
We have Stan, who is our 11 general counsel and executive director.
We have an 12 associate general counsel who I introduced Mr. Donafield.
13 We have a vice president for operations who manages the 14 day-to-day store, so to speak, our headquarters, our 15 offices and works with us on other issues.
We have a 16 director of finance who is hired full-time to deal with a 17 lot of the financial work that has to be done at LIPA, 18 Sherry Feld.
We have a finaicial analyst who works with 19 Sherry and Stan.
20 And, as I pointed out before, there probably 21 will be other hirings at the Long Island Power Authority 22 and again based upon the organization that Jack explained 23 before.
While there may be other hirings, we really want 24 to try to maintain as small an organization as-possible to 25 be cost effective and efficient at the same time.
w i
1--
I'would-also, just_because-you_may ask-it-at 2
some point, in_ terms of my personal involvement at-LIPA, 3
I'm physically at Long Island Power Authority offices 4'
between one and two days a week during -- and probably 5.
spend a-great--deal of my time on LIPA work.
6 I might point out to you that a lot of the work
'7 that~I do'at_LIPA is very coincidental with the~ work that 8
I do at the Consumer Protection Board and that is' helpful.
9 MR. MURLEY:
I don't know, if you said, I didn't 10 understand it.
But-you are full-time?
11
!fr. KLIMBURG: Yes, I am.
12 EM R. MURLEY:
Thank you.
This concludes the t
'13 meeting between NRC and LILCO.
We mentioned in beginning 14 that we would take comments trom the public if there are 15 any comments or questions for the NRC.
16 MR. MC GRANERY: I'm Jim McGranery of the law 17 firm of-Dow, _Lohnes & Albe r t son. -
I'm representing the E
18 Shoreham-Wading River Central School District-and I
19
' scientists.and engineers for Security Energy.in various of L
20 items of litigation with the commission'and concerning l-21 various LILCO license applications.
I listened wi.th great l:
I
=22 interest-to the presentation by LIPA.
At one point I l
23 think the chairman said he hoped that now we-knew 'sho LIPA
-( -
24 was.
I think that_we do.
25 When it comes to technical elements, the 0
gg I
1 management services agreement says that LIPA has total 2
control.
We also learned that LILCO also has control of 3
various labor arrangements and also provides other 4
employees of a technical nature.
5 When it comes to finance, we also found out what 6
LIPA is.
It is LILCO.
LILCO bears all of the expenses.
7 I don't see how the staff can consider an application for 8
even a materials license for LIPA without having both 9
LILCO and NYPA as co-licensees; otherwise, the commission 10 would have nobody who would be responsible, really 11 responsible on that license.
12 I was very disappointed, and I'm sure that the i
13 staff did not miss this, to hear the chairman of LIPA 14 equate cost savings and consumer protection.
The chairman 15 of a would-be licensee of the NRC should understand that 16 the commission thinks that the protection of the public 17 health and safety is the first item, not cost savings.
I 18 have nefer heard anybody make such an argument to the 19 staff before.
20 One final point:
There was a question raised as 21 to various NYPA policy decisions which the commission has 22 to make.
I'm aware that in approving SECY paper 89-247, 23 the commissioners directed the staff to prepare an EIS on 24 this proposal.
That is over ten months ago, and the staff 25 has done nothing yet.
Thank you.
era 1
MR. MURLEY:
Thank you.
Your comments will be 2
considered and we will, of course, be reviewing this 3
application and the questions that were raised.
4 Any other questions?
5 (No response.)
6 (Whereupon, at 12:10 p.m.,
the meeting was 7
concluded.)
8 9
10 11 12
(
13 14 15 16 17 18 19 20 21 22 23 24 25
REPORTER'S CERTIFICATE This is to certify that the attached proceed-ings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
Decommissioning of Shoreham DOCKET NUMBER:
PLACE OF PROCEEDING: Rockville, Maryland were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Ccamission taken by me and thereafter reduced te typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foragoing proceedings.
N 't fli%
c cri s k
/
Rita Shepard Official Reporter Ann Riley & Associates, Ltd.
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'SHOREHAM NUCLEAR POWER STATION L-1 PRESENTATION TO THE US NUCLEAR REGULATORY COMMISSION AT WHITE FLINT, MD MAY 24,199 0
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ESTABLISHMENT OF THE LONG ISLAND POWER AUTHORITY (LIPA) o CREATED BY NEW YORK STATE LEGISLATION ENACTED IN 1986 AS A NON-PROFIT CORPORATE MUNICIPAL INSTRUMENTALITY AND POLITICAL SUBDIVISION OF THE STATE OF NEW YORK o ESTABLISHED AS A PUBLICLY OWNED POWER AUTHORITY WITH THE OVERALL OBJECTIVE OF ASSURING AN ADEQUATE SUPPLY OF ELECTRICITY AND GAS,IN A RELIABLE, EFFICIENT, AND ECONOMIC MANNER, TO THE AREA SERVED BY LILCO o LIPA IS AUTHORIZED TO ACQUIRE THE SHOREHAM NUCLEAR POWER STATlON (SNPS) o LIPA IS MANDATED TO CLOSE AND DECOMMISSION THE SUPS o LlPA IS AUTHORIZED TO PROMOTE AND IMPLEMENT ENERGY CONSERVATION, COGENERATION, AND USE OF RENEWABLE ENERGY RESOURCES ON LONG ISLAND o LIPA IS AUTHORIZED TO CONSTRUCT AND/OR OPERATE GENERATION AND TRANSMISSION FACILITIES AND PURCHASE ELECTRIC AND GAS SUPPLIES FOR LONG ISLAND
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LIPA CORPORATE STRUCTURE l
o THE LIPA BOARD IS COMPRISED OF 9 TRUSTEES, THE CHAIRMAN IS APPOINTED BY THE GOVERNOR o EFFECTIVE JANUARY 1,19 9 2, LIPA's BOARD WILL BE COMPRISED OF ELECTED TRUSTEES (CHAIRMAN WILL REMAIN AS GOVERNOR APPOINTEE) o LIPA's EXECUTIVE DIRECTOR IS RESPONSIBLE FOR THE DAY-TO-DAY DIRECTION AND ADMINISTRATION OF LIPA AND REPORTS DIRECTLY TO THE CHAIRMAN AND TO THE OTHER LIPA TRUSTEES I
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l 1989 SETTLEMENT AND AGREEMENTS o SETTLEMENT AGREEMENT OF FEBRUARY 28,1989:
- LILCO AGREES NOT TO OPERATE SNPS AND TO TRANSFER SNPS TO LIPA
- LILCO AGREES TO COOPERATE IN OBTAINING NRC APPROV AL FOR THE TRANSFER OF SHOREHAM TO LIPA AND TO ASSIST LIPA IN THE MAINTENANCE AND DECOMMISSIONING OF SHOREHAM o ASSET TRANSFER AGREEMENT, AMENDED AND RESTATED AS OF APRIL 14,1989:
- LILCO AND LIPA IDENTIFY THE SPECIFIC SNPS PROPERTY AND OTHER ASSETS TO BE TRANSFERRED TO LIPA
- LILCO AGREES TO PAY FOR ALL SHOREHAM COSTS o SITE COOPERATION AND REIMBURSEMENT AGREEMENT OF JANUARY 24,1990:
- SPECIFIC MECHANISMS ARE ESTABLISHED FOR LILCO TO PAY FOR ALL SHOREHAM COSTS
- LIPA AND LILCO AGREE ON COOPERATIVE EFFORTS AT SNPS, INCLUDING PROVISION OF LILCO EMPLOYEES TO THE EXTENT FEASIBLE TO SUPPORT LICENSE TRANSFER, MAINTENANCE, AND DECOMMISSIONING o MANAGEMENT SERVICES AGREEMENT OF JANUARY 24,1990:
- LIPA AND NYPA AGREE THAT NYPA WILL PROVIDE MANAGEMENT AND TECHNICAL SERVICES TO LIPA IN CONNECTION WITH THE LICENSE TRANSFER,
(
MAINTENANCE AND DECOMMISSIONING OF SNFS 1.
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LIPA FINANCIAL QUALIFICATlONS o THE ASSET TRANSFER AGREEMENT PROVIDES THAT LILCO WILL PAY ALL COSTS RELATED TO THE LICENSE TRANSFER, MAINTENANCE AND DECOMMISSIONING OF SNPS o THE SITE COOPERATION AND REIMBURSEMENT AGREEMENT CONTAINS THE DETAILED MECHANISM BY WHICH LILCO IS PAYING FOR ALL SNPS COSTS o THE SNPS FUNDING MECHANISM PROVIDED FOR IN THE ASSET TRANSFER AND SITE AGREEMENTS IS WORKING WELL i
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LIPA ORGANIZATION FOR ASSUMPTION OF SNPS DEFUELED LICENSE o PROPOSED ORGANIZATION WILL HAVE CLEAR LINES OF AUTHORITY, RESPONSIBILITY, AND COMMUNICATION FROM HIGHEST LIPA MANAGEMENT LEVELS TO ALL OPERATING ORGANIZATION POSITIONS o LIPA's SENIOR CORPORATE NUCLEAR OFFICER, THE SNPS RESIDENT MANAGER, AND SEVERAL OTHER KEY LIPA POSITIONS AT SNPS WILL BE FILLED THROUGH COEMPLOYMENT OF OUALIFIED NYPA PERSONNEL o AN INDEPENDENT REVIEW PANEL OF PROMINENT NUCLEAR EXPERTS WILL SERVE AS AN ADVISORY BODY REPORTING DIRECTLY TO LIPA EXECUTIVE MANAGEMENT o THE SNPS SITE STAFF WILL BE UNDER THE DAY-TO-DAY DIRECTION OF NYPA's DIRECTOR OF SPECIAL PROJECTS, ACTING AS LIPA's SNPS RESIDENT MANAGER o SITE STAFF TO BE COMPRISED OF QUALIFIED NYPA, LIPA, LILCO, AND CONTRACTOR EMPLOYEES
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CURRENT LIPA/NYPA ACTIVITIES i
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- DEVELOPMENT OF CORPORATE AND SITE STAFF-ORGANIZATIONAL MATERIALS (E.G. CHARTS, DEPARTMENT CHARTERS, POSITION DESCRIPTIONS)
- REVIEW OF LILCO PROGRAMS AND PROCEDURES FOR POTENTIAL USE BY LIPA DURING SNPS MAINTENANCE AND DECOMMISSIONING
- ACQUISITION AND REVIEW OF LILCO LICENSES, PERMITS-AND CONTRACTS FOR TRANSFER TO LIPA IN CONJUNCTION WITH THE OPERATING LICENSE
- ESTABLISHMENT OF OVERALL LIPA FRAMEWORK FOR QA, TRAINING, AND OTHER PROGRAMS
- SECURING ADDITIONAL SUPPORT PERSONNEL FROM WITHIN NYPA AND LILCO
- TRACKING OF LILCO REGULATORY DEVELOPMENTS
- TRACKING OF DECOMMISSIONING EXPERIENCE AND DEVELOPMENT THROUGHOUT NUCLEAR INDUSTRY o DECOMMISSIONING:
- EVALUATING DECOMMISSIONING ALTERNATIVES
- PROCURING SERVICES OF PRINCIPAL DECOMMISSIONING ARCHITECT / ENGINEER
- PURSUING FUEL DISPOSITION OPTIONS
~* REVIEWING LILCO SITE CHARACTERIZATION ACTIVITIES AND DATA
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PLANT CONFIGURATION AND CONDITIONS FOR LICENSE TRANSFER o LILCO "DEFUELED SAFETY ANALYSIS REPORT"(DSAR)
AND RELATED NRC SUBMITTALS TO SERVE AS THE LICENSE TRANSFER BASIS o ALL FUEL TO BE SAFELY STORED IN THE SPENT FUEL STORAGE POOL AS DESCRIBED IN THE DSAR OR OTHERWISE DISPOSITIONED. NO REACTOR REFUELING TO BE PERMITTED o LIPA ORGANIZATION AND STATION PROGRAMS TO BE COMMENSURATE WITH THE GREATLY REDUCED HAZARD ASSOCIATED WITH THE DEFUELED PLANT STATUS t
o TECHNICAL SPECIFICATIONS, SAFETY ANALYSIS REPORT, AND STATION PROCEDURES TO BE REVISED AS APPROPRIATE o INITIAL FOCUS ON PLANT OPERATION AND MAINTENANCE, EVOLVING TOWARD DECOMMISSIONING l
OPERATIONS AND MAINTENANCE PROGRAM DEVELOPMENT (OMPD)
FOR LICENSE TRANSFER o OMPD OBJECTIVE 0:
- DEVELOP PROGRAMS AND PROCEDURES NECESSARY FOR LIPA/NYPA MANAGEMENT OF SNPS IN THE DEFUELED CONDITION
- ENABLE SMOOTH TRANSFER OF NRC LICENSE AND RESPONSIBILITIES
- IDENTIFY AND ESTABLISH SCOPE AND MECHANISMS FOR TRANSFER OF LILCO LICENSES, PERMITS, AND CONTRACTS
- PROVIDE FOR THE DEVELOPMENT OF AN EFFECTIVE SNPS SITE ORGANIZATION I
o OMPD SCOPE:
- DETERMINE EXISTING SNPS PROGRAMS, PROCEDURES, LICENSES, PERMITS, CONTRACTS, ETC. REQUIRED TO MANAGE DEFUELED FACILITY
- MODIFY EXISTING PROGRAMS AND PROCEDURES TO COMPLY WITH NYPA CORPORATE REQUIREMENTS AND WITH LIPA/NYPA PLANT ORGANIZATION FOR SNPS
- DEVELOP NEW PROGRAMS AND PROCEDURES, AS REQUIRED
- DETERMINE WHICH REQUIRED SNPS LICENSES, PERMITS, AND CONTRACTS ARE TRANSFERABLE AND INITIATE ACQUISITION / REPLACEMENT OF THOSE WHICH ARE NOT TRANSFERABLE
(
OMPD FOR LICENSE TRANSFER (CONT.)
o OMPD PROGRAM AND PROCEDURE REVIEW TO CONSIDER:
- ADMINISTRATION
- SECURITY
- OPERATIONS
- COMPUTER ENGINEERING
- MAINTENANCE
- RADWASTE
- lNSTRUMENTATION
- QUALITY ASSURANCE /
AND CONTROL QUALITY CONTROL
- REACTOR ENGINEERING
- FIRE / SAFETY
- HEALTH PHYSICS-
- SYSTEMS ENGINEERING.
- RADIOCHEMISTRY
- RECORDS MANAGEMENT
- TECHNICAL SUPPORT
- LICENSING
- EMERGENCY PLANNING
- TRAINING o OTHER KEY OMPD ASPECTS AND GUIDELINES:
- MAXIMlZE USE OF EXISTING SNPS PROGRAMS
- UTILIZE LILCO STAFF PERSONNEL TO THE EXTENT POSSIBLE AFTER LICENSE TRANSFER
- LIPA/NYPA~ ORGANIZATION WILL BE ONSITE PRIOR
-TO LICENSE TRANSFER
l DECOMMISSIONING APPROACH o ALTERNATIVES IDENTIFIED IN NRC's DECOMMISSIONING RULE ARE BEING EVALUATED TO DETERMINE MOST APPROPRIATE SELECTION FOR SHOREHAM
- DECON
- SAFSTOR
- ENTOMB o-DECON CURRENTLY APPEARS MOST APPROPRIATE FOR SHOREHAM BASED UPON:
- LIMITED OPERATING HISTORY (2 EFFECTIVE FULL POWER DAYS)
(
- LOW LEVELS OF RADIATION AND CONTAMINATION
- LACK OF A CLEAR ADVANTAGE FROM OTHER ALTERNATIVES
- SHORT TERM RETURN OF LAND FOR OTHER USES o MINIMAL DISMANTLEMENT / DISASSEMBLY - LIMITED TO THAT WHICH IS NECESSARY TO FACILITATE:
- REMOVAL OF SNPS IRREVOCABLY FROM SERVICE
- REMOVAL OF RADIOACTIVE MATERIAL TO ALLOW RELEASE OF THE SITE FOR UNRESTRICTED USE AND TERMINATION OF-THE NRC LICENSE
(
CONCEPTUAL STUDY PHASE SHOREHAM DECOMMISSIONING PROJECT o INITIAL ACTIVITIES TO BE CONCEPTUAL IN NATURE o COMPREHENSIVE STUDY WILL ENCOMPASS:
- EVALUATION OF EXISTING SNPS RADIOLOGICAL CONDITIONS VS. POSTULATED RESIDUAL RADIOACTIVITY CRITERIA (1.E., DECOMMISSIONING SCOPE DETERMINATION)
- EVALUATION OF TECHNIQUES, ACTIVITIES AND PROCESSES FOR PLANT DECOMMISSIONING
- DEVELOPMENT OF PRF'_IMINARY ESTIMATES OF RADIOACTIVE WASTE, PERCONNEL RADIATION EXPOSURE AND COST
- DEVELOPMENT OF CONCEPTUAL SCHEDULE
- EVALUATION OF PLANT SYSTEMS AND FACILITIES NECESSARY TO SUPPORT DECOMMISSIONING h
DETAILED ENGINEERING / PLANNING PHASE SHOREHAM DECOMMISSIONING PROJECT o BASED ON CONCEPTUAL FINDINGS, FULLY ENGINEER THE DECOMMISSIONING PROJECT:
- DEVELOPMENT OF DECOMMISSIONING PACKAGES AT THE SYSTEM AND MAJOR COMPONENT LEVEL
- DEVELOPMENT OF TECHNICAL SPECIFICATIONS FOR THE BIDDING AND FIELD IMPLEMENT ATION OF THE PROJECT o PERFORMANCE OF BOTH IN-PROCESS AND FINAL ALARA REVIEWS OF DECOMMISSIONING PACKAGES o DEVELOPMENT OF DEFINITIVE ESTIMATES OF RADIOACTIVE WASTE, PERSONNEL RADIATION EXPOSURE, AND PROJECT COST o DEVELOPMENT OF A " LEVEL ll" SCHEDULE BASED ON DETAILED ENGINEERING FINDINGS o DEVELOPMENT OF A RADIOACTIVE WASTE DISPOSAL PLAN o DEVELOPMENT OF A DECOMMISSIONING QA/QC PLAN I
i o
.. _ _, - _ -.., _... _ _. _. _. _ - - - -. ~. ~.., _ -
DETAILED ENGINEERING / PLANNING PHASE SHOREHAM DECOMMISSIONING PROJECT (CONT.)
o DETAILED ENGINEERING AND PLANNING EFFORTS WILL CULMINATE IN:
- A PROPOSED DECOMMISSIONING PLAN AND ENVIRONMENTAL REPORT SUPPLEMENT THAT WILL BE SUBMITTED FOR NRC REVIEW AND APPROVAL
- COMPREHENSIVE AND DETAILED TECHNICAL BASIS AND PLAN FOR FIELD IMPLEMENTATION OF THE DECOMMISSIONING PROJECT t
l f
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l l
lRRADIATED FUEL DISPOSITION THE FOLLOWING OPTIONS ARE UNDER EVALUATION AT THIS TIME:
o SALE TO ANOTHER UTILITY o SHIPMENT OF FUEL TO A REPROCESSING FACILITY:
- REQUEST FOR PROPOSALS ISSUED fUNYR LILCO E Abu Tf0N I
4
FUTURE DECOMMISSIONING ACTIONS o SELECT PRINCIPAL ARCHITECT / ENGINEER TO PROVIDE COMPREHENSIVE DECOMMISSIONING ENGINEERING AND PLANNING SERVICES o PERFORM CONCEPTUAL AND DETAILED ENGINEERING INCLUDING DEVEsOPMENT OF DETAILED DECOMMISSIONING PACKAGES AND SPECIFICATIONS OVER THE NEXT YEAR o EVALUATE ALL FUEL OPTIONS AND DETERMINE THE OPTIMUM OPTION ON A PRIORITY BASIS o SUBMIT DECOMMISSIONING PLAN TO NRC DURING 1991 l
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/
. ~. -.
,m.._.
SUMMARY
AND CONCLUSIONS o INITIAL ACTIVITIES RELATED TO LICENSE TRANSFER AND 4
DECOMMISSIONING PLANNING ARE NOW UNDERWAY o A LICENSE TRANSFER APPLICATION is UNDER PREPARATION AND WILL BE SUBMITTED TO NRC IN JUNE 19 90 l
o CHANNELS OF COMMUNICATION BETWEEN NRC AND LIPA/NYPA NEED TO BE ESTABLISHED AT THE EXECUTIVE AND WORKING LEVELS o LIPA AND NYPA INTEND TO WORK CLOSELY WITH NRC TO ASSURE THE SAFE MAINTENANCE AND DECOMMISSIONING OF SHOREHAM,IN ACCORDANCE WITH ALL APPLICABLE REQUIREMENTS, AND WITH THE MUTUAL OBJECTIVES OF PROTECTING THE ENVIRONMENT AND THE HEALTH AND I
SAFETY OF THE GENERAL PUBLIC AND PLANT PERSONNEL i
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2 183o.1916) 462 3211 SACRAMLNTO MUNICIPAL U11LITY DISTRICT C P. O. Bou 16830 Secremento CA AN ELECTRIC SYSTENfJy3R HE EART OF CALIFORNIA GH 90 407 July 13, 1990 Honorable Kenneth M. Carr, Chairman U.S. Nuclear Regulatory Comission Washington, DC 20555
Dear Chairman Carr:
SUBJECT:
RANCHO SECO NUCLEAR GEN BATING STATION DOCKET NO. 50-312 I have received a copy of the June 27, 1990, letter to you from Mr. A. David Rossin of the Environmental Conservation Organization (ECO), on the closure and proposed decomissioning of the District's Rancho Seco Nuclear Generating
)
Station.
Since it is my understanding that the Commission has under i
consideration a proposed policy on the application of the National Environmental policy Act (NEPA) to NRC review of nuclear plant closure and decommissioning proposals, I want to respond briefly to the pertinent points raised by ECO.
. ECO addresses the District's application of April 26, 1990, to convert the operating license for Rancho Seco to a " possession only' license.
(ECO erroneously reports that the application has been returned to the District. The NRC staff has simply requested additional information.)
ECO acknowledges that the closure and decommissioning of Rancho Seco "... can be conducted safely, without undue or even any significant risk to the health and safety of the public."
But ECO appears to contend that NEPA requires the NRC to prepare an environmental impact statement (EIS) on the District's proposals, which would consider as an alternative the resumed operation of Rancho Seco as a nuclear generating station.
ECO argues that until such an EIS is prepared (and considered in hearings), the NRC may not "... allow any actions by SMUD which might compromise in any way the potential future operability of Rancho Seco as a nuclear power plant again."
l Last year, the District provided the NRC with its analysis of the NEPA review I
standards which should apply to your consideration of the District's closure and decommissioning proposals, including " possession only' licensing.
(Letter, December 22, 1989. J.Schort(SHVD) tow.Parler(NRC).) For your convenience, a copy of that analysis is provided as Attachment I to this letter. Since 1 just became General Manager of the District on June 1,1990, I want to take this occasion to let you know that ! strongly endorse the District's position, and
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I trust you will consider our views fully.
Rancho Seco was closed by the District pursuant to a vote of our local electorate.
The District may not legally operate the plant again.
The NRC
}
l o:STaicT HEADOUARTERS O 6201 S Street. Sacramento CA 95817 1899 TDMMaz2D
1 o
1.
[4 Honorable Kenneth M. Carr, July 13, 1990 Chairman GM 90 407 4
should evaluate the District's closure activities and " possession only' license application without assessing the decision of the District's voters to cease plant operation.
Approval of a ' possession only' license application does not have an effect on the environment. In the NRC's own words, it merely " confirm (s) the nonoperating status of the plant and... reduce (s) some requirements which are important only for operation-....* 53 Fed. Reg, at 24,024 (1988).
As long as the NRC's actions, including review of the " possession only' license, do not foreclose consideration of various decommissioning alternatives, no NEPA issue arises which would compromise, the NRC's decomissioning review.
The decision not to operate Rancho Seco was made by the voters, and resumed operation by SMUD is not a legal option. We believe quite strongly that resumed operation is not an alternative cognizable in the NRC's Rancho Seco decomissioning review, since it is not an alternative means of accomplishing the objective of decomissioning the plant.
Neither is resumed operation the
'no action' alternative.
In your decomissioning review, the no action option is not decontaminating _a facility which has ceased operation.
The District needs relief from equipment maintenance, surveillance, staffing and other requirements which are not necessary to protect public health and safety at Rancho Seco in its defueled condition.
We appreciate your assistance and timely review of our requests.
Thank you for'this opportunity to express my views.
Sincerely, N
S. David Freeman General Manager Attachment cc:
Comissioner Kenneth C. Rogers Comissioner James R. Curtiss Comissioner Forrest J. Remick Mr. James Taylor Dr. Thomas E.- Murley Mr. Jack B. Martin William C. Parler, Esq.
Mr. A. David Rossin
ENVIRONMENTAL' CONSERVATION ORGAN!IATION Suite 320 101 First Street Los Altos, CA, 94022 27-Jun-89 Hon. Lando Zech, chairman United States Nuclear Regulatory Commission Washington, DC 20555
Dear Chairman Zech,
We the undersigned, have formed the Environmental Conservation Organ!zation (ECO).
To the extent that any or all of the members of ECO have appropriate standing, we hereby wish to notify you of our intent to oppose any actions by the holder of the Pancho Seco Nuclcar Power Plant license that might impact negatively pon the future opers,bility of the plant.
On June 6, 1989, the voters of the Sacramento Municipal Utility District (SMUD) passed an advisory initiative which calls for the shutdown or tne Rancho Seco plant.
The Board ordered the plant shut down, and it is now in a cold shutdown condition.
The initiative allows SMUD to sell the plant to another operator, and the Board is preparing to receive offers to that effect.
The operating license requires that the plant must be maintained according to its Technical Specifications.
If the licensee proposes any license amendment which would result in impairment of the operability of the plant, its maintenance, or any of the hardware and physical systems, we request prompt notification and leave to intervene.
Dr. A. David Rossin will act as coordinator for ECO in regard to this matter.
He can be reached by telephone at 415-948-7939.
His signature appears below on behalf of ECO.
Copies of this letter bearing personal signatures of the other signatories will be forwarded to you in the near future.
Professional affiliations are provided for identification only.
Correspondence should be sent to ECO at the address on this letterhe Thank you for your attention to our request.
Ran-Raymond Ashley - Resident of Fair Oaks, CA, in the SMUD Milton Levenson - (Former President. American Nuclear Society)
Alan Pasternak - Resident of Sacramento, CA, in the SMUD A. David Rossin - Coordinator, ECO (Former Asst. Secretary of Energy)
Ronald Stinson - (Former President American Nuclear Society) cc: Hon. Kenneth Carr, Chairman Designate i
Hon. James Curtis, Commissioner l
Hon. Thomas Roberts Commissioner Hon. Kenneth Rogers, Commissioner r
Chairman, Board of Directors, SMUD (Q
i L. Manning Muntzi'ig. Esq., Counsel to RCO Wh p wc
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