ML20095H561

Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan

ML20095H561
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/28/1992
From:	Leslie Hill LONG ISLAND POWER AUTHORITY
To:
Shared Package
ML20095H559	List: ML20095H556 ML20095H561
References
DCOM, NUDOCS 9204300012
Download: ML20095H561 (5)

Text

. c.fR-29 '92 14:37 ID:L ! PCUER WTHORITY TEL to:1-516-742-2084 #2T PD1 ,

UNITED STATES NUCLEAR REGULATORY COMMISSTON BEFORE Ti!E COMMISSION -

In the Matter of Docket No. 50-322 LONG ISLAND POWER AUTHORITY (Decommissioning (Shoreham Nuclear Power Station, Authorization)

Unit 1) w AFFIDAVIT Of LESLIP M. HTLL Leslie M. Hill, Resident Manager, Shoreham Nuclear Power Station, being first duly sworn, statos as follows:

INTRODUCTION 1.(a). I am cha una i riane Manacar of the choroham uunicar Power Station (Shoreham), employed by the Long Island Power Authority (LIPA). In this capacity I have overall onsite responsibility for the safe and officient decommissioning of Shoreham. I have the authority to implement all administrative controls in conformance with applicable regulatory requirements regarding the facility and havA the racponsibility for the coordination of all decommissioning functions through key personnel. I am also responsible for the selection and training of .

personnel, administrative implementation of plant security, and relations with regulatory authorities, including the Nuclear Regulatory Commission (NRC). I am familiar with and can attest to the significant implications of a delay in NRC approval of LIPA's decommissioning plan beyond May 15, 1992 at Shoreham.

1.(b). The purpoco of this affidavit is to eupport the position of LIPA that circumstances exist warranting prompt commission action on the NRC Staff's recommendation (in a memorandum of April 17, 1992) that an immediately offoctive order approving the decommissioning plan for Shoreham be issued as %on as practicable, but in any event, no lator than May 15, 1692.

Specifically, this affidavit explains how a delay in issuance of such an order beyond May 15, 1992 translatas into problems potentially resulting in unnecescary onsite low-level waste f

storage, decommissioning delays, and avoidable costs that will be borne by the ratepayers of Long Island.

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- DACKGROUND 2.(a). On February 26, 1992, the NRC authorized the transfer of ownership of the Shoreham plant from the Long Island Lighting Company to LIPA, en entity of New York State. Lona Island Lichtina

.Qo. (Shoreham Nuclear Power Station, Unit 1), CLI-92-04, slip op.

(Feb. 26, 1992).

2.(b). In anticipation of the transfer of ownernhip to LIPA, by letter dated December 29, 1990, pursuant to 10 C.F.R. Section 50.82, LIPA submitted to the NRC a Decommissioning Plan for Shoreham and a Supplement to the Environmental Report for Shorcham cacommicaioning. The shoreham Decommisaloning Plan providos technical background for the effort to decommission Shorcham, including information concernina selection of tha immndiata (11 ema nr i nment- sianommiccioning option (DDoOH), radioloerisul _

protection programs, residual radioactivn contamination release

,-vitoria, d o c'omm i c c i o n in g ooot optimate.o, t o shniora l oud environmental specifications, quality assurance provisions, security program, and a schedulo for completion of decommissioning.

The Supplament to the Environmo n t..a 1 Rwport. provideo information which demonstrates that tne environmental impacts of decommissioning Shoroham are bounded by the NRC's analysis (NUREG-OSS6) of the impacts of decommissioning the end-of-life refere:nce BWR.

l 2.(c). One year later, on December 23, 1991, the NRC Staff noticed in the Fodnral nanincor a "canaidoratinn of Issunneo of an orcer Autnorizing uecommissioning [of) a Facility and Opportunity for Hearing." S6 Fed. Reg. 66,459. The notice provided a thirty '

day comment period with respect to issuance of an order approving the Shoreham Decommissioning Plan and authorizing Shoreham decommissioning. Two petitions to intervone were filed in responsc l co thin notico.

I 2.(d). On April 3, 1992, the Commission denied the NRC Staf f's motion to dismiss the petitions to intervena, and forwarded the petitions- to an Atomic Safety and Licensing Board "for i processing in accordance Vith the NRC's Rules of Practice." Order, at 3.

2.(e). On April 17, 1992, the NRC Staff recommended that the commisalon approve by May 1, 1992 issuance by the Start of an ordor approving LIPA's Decommissioning Plan including a no significant hazards consideration determination. The Commission has thc.

Staff's recommendation before it at this time.

mpuczmous oP Druy _Ud_AtzrnQnIcTNo OnongIag_orcomissLqrtINo l 3.(a). Continued delay in obtaining authorization for l Chorcham decotumissioning will have s igni f icant. Impacts on the I

complexity and duration of the chorenam Dcoommiauluning Project.

and, consequently, on the cost of the project. The magnitude of the additional costa could ranch An high n W A,ono pwr day.

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- 3.(b). Shoreham decommissioning costs are driven primarily by personnel costs. Thus, to the extent that the project duration is extended for any reason, additional costo are incurred because of the need to retain personnel at Shoreham for longer periods of time.

3.(c). The Shoreham Reactor Pressuro Vsssel (RPV) and internals contain approxinatoly 600 curies of re.dioactivo material.

Disposal of these materials represents the primary radiological challenge of all Shoreham decommissioning activitiou that are constrained by issuanco of a Decommissioning Order. It is a

, priority objective of LIPA that those materials be disposed of in j a licensed burial facility before the end of 1992, in order to avoid the need for interim storage of theco materials at the '

Shoreham sito af ter tho burial facilities close to further disposal of low-level radioactive vaste originating outsido of their atates.

All licensed burlal facilitica ara scheduled to be closed to disposal from out-of-stato as of December 31, 1992.

3.(d). In order to moet this doadline, LIPA has ensured that it is prepared to commence the removal, segmentation and disposal of the RPV internals on May 15, 1992, to be followed immediately by removal, seg1tontation and disposal of the RpV itcoif. Such preparations include mobilization of specialty contractor personnal and specialty equipment. Failure to commence the aforomantionud activities on time will result in such personnel boing retained at Shoreham longer, thereby incurring additional staff coctc.

3.(o). With the addition of these personnel and other

d. Namissioning staf f personnel, the general site worker population at Shorehtm will reach approximately 1000 pe.ople . A significant fraction of this population is needed to moet the requironents of the Shoreham 10 C.F.R. 50 liconso. To tho oxtent that the project  ?

achedulo is extended, license termination would be delayed. Thuu, between any delay in decommissioning work and tho associated delay in liconae termination, mucn or all of the site worker population would need to romain at Shorcham longer. If all of these 1000 work;rs were retained an extra day, the additional cost incurred would be approximately $320,000. Should there be an oxtended delay, LIPA would have the alternative of reducing the nito worker population; however, as noted above, much of this populaticn in needed under the station 11conso, and there would still be a significant cost impact through the loss of tino and effort invested in personnel acquisition and training.

3.(f). Delays in commencing Shoreham decommissioning would also result in furthur achedulo delays in that certain essential equipment will be less available after the passage of timo. For example, the polar crano is to be used for a variety of decomminaioning activitios, including those noted above,. and use of the crane for docommissioning activition is thus on a critical path. Une of the polar crane is also essential for fuel disposition, which is currently anticipated to occur the latter i part of this year. This leavas a window for exclusivo use of tho l

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polar crano for other decommissioning activitios at this time. A delay in commencement of decommissioning would further extend the decommissioning schedule because those decommissioning activities requiring the use of the polar crane will becomo constr*lned when fuel disposition is taking place.

3.(g). Beyond the financial ramifications, there are additional logistical consequences of a delay in authorizing decommissioning. As noted earlier, such a dolay would have a significant impact on LIFA's ability to dispose of low-level radioactive waste (LLW) at the Barnwell, South Carolina and Hanford, Washington burial sites. The Barnwall and llanford sitos are scheduled to close to further LLW disposal from outside of their otates at the end of 1992. Thus, fallute to commence decommissioning activities according to schedule couAd require the indefinite onsite storage of the bulk of Shoreham decommissioning LLW at Shoreham due to Barnwall and Hanford closure. While contingency plans are being prepared to do so as a matter of prudency, it would bo in the best interests of LlPA, the Shoreham community, the ratapayers of Long Island, and the NRC not to be faced with this unnecessary burden.

3.(h). There would be savoral consequences resulting from indefinite onsite storage of larget quantities of LLW at the Shoroham plant. First, the potential occupational exposure due to ensite atorage of LLW will be increaeed if the LLW must continue to te storce on sito. This was a concern raised and emphasized by the NRC Staff in its technical review of the Decommissioning Plan.

Second, any futuro LLW disposal would come at increased costs. '

Ihese costs will be borne by the ratopayors of Long Island.

Finally, although LIPA would naturally ensure that onsite storage of additional amounts of LLW did not jeopardize the public health and safety, avoidance of the need for such storago would obviously remove any concerns that the Shoreham community might have -

regarding the storage of additional LLW.

3. (1) . Delay in authorizing Shoreham decommissioning may also result in a reduction in the availability of qualified personnel.

Highly specialized perse .a1 and equipment are requirod to perform many of the tasks associated with Shoreham decommissioning. Rather than having trainod personnsi and useful equipment romain idle at Shoreham awaiting initiation of decommissioning activities, contractors may elect to cond trained personnel and equipment to other projects, thus reducing the cubnnqunnt, immediate availability of those personnel and equipment and further delaying

'Shoreham decommissioning.

CONCLUSION i The foregoing demonstratos the consequencen of delaying issuance of an order authorizing decommissioning of the Shoreham Nuclear Power Station beyond May 15, 1992, In summary, those adverse consequences involve extension of the project schedule and associated cost increases, storage of additional LLW at the Shoreham site involving additional occupational radiation expecuro l

and costs, and potential loss of qualified epecialty contractor l personnel and equipment availability.

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All of these problems would . add up to significant and avoidable. cost- impacts. . Accordingly, circumstances exist warranting Commission action as coon-as practicable on the NRC-Staf f's recommendation for an immediately effective order approving LIPA's decommissioning plan, so that the ~ order may be issued no lator_than Mhy 15, 1992.

i I cvoar that the forogoing is true and accurato to the best of '

my knowledge.

Executed at/Vdt.7 /21wo , New York, this M th day of ,

An /2r / , 1992.

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IMslio M. Hill Subscribed and sworn to before me this APM day of April 1992.

BRU0E W. EAKEN, JR.

. No"iARY Neuc, stats et m yovn No. 314062830

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