ML20147A856
| ML20147A856 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/1978 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-43FR10370, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-70 NUDOCS 7812140380 | |
| Download: ML20147A856 (178) | |
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l 1 CR9113 ; UNITED STATES OF AMEX 1CA T110RPE/blt All 2 NUCLEAR REGULATORY COMMISSION 3 ! t 4 5 PUBLIC MEETING FOR REVIEW OF NRC DECOMMISSIONING 6 POLICY 7 f 8 ! I i 9 .' i !. 10 l l Wednesday, 18 Octooer 1978 l l 11 10:00 a.m. 12 GSA Auditorium l I r 13 l L:-- 18th and F Streets, N.W. i 14 j l Washington, D.C. l 15 l I l I6 I l l 17 l ! l i 18 l' f m 19 I l ! 20 I I I 21 ! 22 i , - 1
. 23 l- .
l 24 1 Am4xws Remners, tec j 25 l I : f ) l . l
2 I j CONTENTS P#98 j 2 ! 3 Overview / Policy Issue Presentation (Robert 3
- Bernero,. Assistant Director for Material j 1
4 Safety Standards, Office of Standards i Development, U.S. Nuclear Regulatory Commission) l 5 Technical Presentation I l 6 R. 1. Smith, Battelle Pacific Northwest Laboratory 64 l l 7 124 Dr. E. Smith Murphy, Eattelle Pacific Nortnwest Laboratories 8 9 l 10 ! l 11 , STATEMENT OF MR. REYNOLDS ON BEHALF OF SEVERAL POWER 68 l l 12 ' REACTOR LICENSEES !
!j 1 13
(- STATEMENT OF DUKE. POWER COMPANY 172 l )
- I 14 l
l ! 15 ! j 16 i 17
! l 18 ,
l
)9 i,
20 ! 21 22 I i-23 . 24
'econm nne.
25 i l i
., 3
' PROCEEDINGS I }.,i ,
i MR. BE RNERO : Gooc morning. On behalf of the j 2 I l
~
'h Nuclear Regulatory Commission Staff, I would like to welcome !
r I , 4 yor all to this public meeting. j 5 This meeting is associated with the Nuclear , 6 Regulatory Commission's re-evaluation of its policy on de- c commissioning. l 8 We will have a fairly extensive meeting here today. r oa An agenda is available outside on the table, and it was pub-
'u a 39 1 ished in the Federal Register.
ij The agenda for today is at 10:00 o' clock, after 12 the introductory remarks, I will give a somewhat lengthy pre- ' j3 sentation on the background of our concern about decommission-i.. j. 1., g il in g . I will discuss decommissioning itself --the act, the na l' 15 { termin 1 gy, what's involved with decommissioning-- and explain I g [ the program that the NRC is following to re-evaluate its policy i . g on decommissioning. I will go quite extensively into inter- ! t
,6 s
a relationships with the states. ' l. i r- { As you will learn from the course of action we're 20 f 11 wing when it is explained to you, we are working very a 1closel"v with the states on this matter because of the mixed 4 21 I i g ' jurisdiction we have with them. . I At the end of-ry talk, I would be happy to have 1 i i 23 h i
. P 2, i;.some questions and answers.of a general nature. We are plan-n Ae,.Feo.m memnm. inc. q ning to recess f or lunch about 25 b, 12:00 o' clock and return at ,
a.
- l i
N .
4 , r! I o a b1:30. p At 1: 30 there will be two technical presentations: one i il n J by Dick Smith of Battelle Northwest, who is right down here 26n - t'
,j!
in tne front row, and the other by Dr. Smith Murphy. I l i h l
,f apologize -- his last name was omitted in the agenda here.
l t They will give you summary presentations on the specific re-5 ' l I f i I 6 i sults of decommissioning studies that Eattelle has performed s < for us. 7 g And then at 3:00 o' clock we will have a question i 9 , and answer session. 10llp . All attendees here, all members of the public, are 15
); invited to make public statements. There are two .Ticrophones, 12 ne in each aisle. I would ask that, in order to ask cuestions l t
I 13 ; or to make a public statement, unless you have a rather booming i i i Id i
- voice, please use the microphones and identify yourself so i
15 !that the Reporter can properly credit vour remark or comment. I I I g The entire meeting is being transcribed by a i 1/ 4jReporter here, and the transcript itself will, of course, be ! L Foart of the oublic record. 18 n { U If you have a prepared statement, I would prefer to g j h ! e0 i have prepared statements read into the record or spoken into I n' 21 lthe record after the afternoon session. I would like to set a
,2 l\Fnominal a quota of 5 minutes on any one statement, although we i i
will be tolerant, depending on the pressures. i
,3
. g !
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p ( You will see in the theory presentation f ourteen u,.sec.i nemmn. in g i 15 questi ons relating to decommissioning, and I wila, go over them. o li h 1: ' l d
5 I 3 ii 0
.) These are. questions which we discussed with the states, and 2
it was my intention that, after explaining these questions, > h' 4 3 we would put them back on the screen this afternoon and use 7 i I 4 them as a basis for dialogue or discussion to complete the day 5 so that we may get your views on the same matters as the states ; 6
! have discussed.
7 With the record of your names, you will all receive I E [I a copy of the outcome of what happened at the State Workshops, f e ;, as well as this, this meeting here. Basically, the NRC is using t 39 [ State Workshops and this public meeting for early advice in the c 3)[ development of new rules as appropriate. i We feel that those l n ., i who have taken the trouble to give us the advice deserve to i b.Ii know whether we heard it or whether we acted upon it, so we s c y [ will have a report of some sort to explain what's happening as i 15 , the result of this advice and we will distribute this report, i i 16 J Right now our tentative date is the end of November to have it n,, completed. <
. \
IE So let me begin now with a presentation on what is 39 ,;cecommissioning and what we're doing about it. , i 20 I have a basic problem in that this presentation i g [is geared particularly for the state representatives with whom h g y we met, and those state representatives are not nuclear people- ,
,.,b f uy ot all of them. Certainly some are. In the state radiation gycontrolprogramsthereareexpert people, but we were meeting e
- Ap.Fmpd FIPMffPfl, 0fC g pI with state people who were legislators, from governors' offices, 1 l n ) b i
- d- ..
t
6 u{ f i d
)[ state energy offices, from a whole variety of disciplines.
1 2! Much of wha' I say in this presentation may be l I i 3l familiar to you. I notice a lot of people from industry here. ; O 4 Many of you people already know what I'm saying; many others 5 may not. Bear with me if I'm boring you. If I'm skipping 6 ver something or seem to be presuming knowledge of something, 7 feel free to interrupt or call on me and I'll try to explain E a little better. 9 But-as I-said, we're in the state of a re-evaluation
)gf!andrevisionofourpolicyoncecommissioning. It is an q 0 agency-wide policy; that is, . the whole NRC is involved with 12 it. We're trying to sort out this affair and get a logical,
)3 ; comprehensive policy.
Is [ (Slide.) ' { This presentation that I'm going over with you is t
)3 to discuss what the facilities of interest are, and I will ex- '
t! g jphin n what it means in our mind to decommission them. We can h 37 get some terminology straight so that when one of us says v .
)gl"emtombment," for instance, we all understand what is meant or l
m-
);qwhat is .ntended.
1 20 I'll give y u a brief review of some of the de-3.1 ll commissioning history of public reactor f acilities.
,, By "public" i
I mean demonstration reactors. 22 j yjEneravfacilities. I don't go into Department of .
..g There is a great lore of technology there J l"as well.
. Ac .p.omi newners, ine'y 25 h. l I will review the present requirements. NRC does p d Ie I d- .
3 7-
- ,1;
')
b Iu have a policy on decommissioning. I've said many times I m w anted to change it. I want to improve it; I want to make it i I
\
fi '
.h more specific. We do have requirements now, and I'll review '
e i 3 those for you. , 5 And then, lastly, I'll go over what we're doing l 6
- about it: what is this plan? How are we going about getting 1
) i
,;. a better or more clear policy? 1
'f l Eh (Slide.) i f
! First of all, I'd like to clarify some terminology. l 9
\
jo ll When we speak of decommissioning, we 're speaking of the ultimate i i q;[ act of removal of a facility from active service,, and along is with that the disposal of'the radioactive residue. i I 13 Any nuclear operation is going to involve some form i f (. . .. li I y of radioactive residue, and we're looking for " decommissioning" " n
)', ll!! to be the term to cover.the final solution, whether that raclo-L i i
active residue is left there in some stabilized fashion or is y 8 l [ g : taken away and removed. This gives us of necessity the need l E. to consider both temporary decommissioning and final decom-
); p missioning.
li ' 20 This has been a long-standing problem, not so little ! 21 h elped by the lack of clarity in NRC regulations and standards, t 23 . "I 4
- Many people speak of a mothballed reactor as a decommissioned r
.3 a' reactor, and it really isn't decommissioned; it's only par- '
24 h tially so. It's in some form of safe storage. It has some i A n.Ra m i ne m n m inc f 3.c,g! barriers, guards or padlocks on the door or electric fences or
.y n
b . .
8 y < s o
, / sometning to r.eep people from straying in there and being con- . I i
e, ! it requires continuing care. It's 7p taminated or exposed, but 4 not finished. a 1
,h Final decommissioning really has two conceptual 0
,l! options. You can take the thing apart, remove all the residue, ,
"d, i a nd have unrestricted release of the site. There are some 6
a
. l l criteria or standards by which you can say the site is now I
Efleanenughtobeleftandusedforwhateverpurpose, and that ) a ejl would be what we would usually call a dismantling or a total
-n r dismantling of a faciiity.
a u
,1 An alternative is an entombment, an entombment of e
a permanent nature. That is where the intent is that whatever i 12 33 radioactivity is not hauled away or is not of a lo.w enough , O g y level to be trivial or negligible, that that radioactivity is ; h g ] fixed - having concrete poured over it or' fixed in some way, g sealed up -- with the intent that that's forever, th s long lt o nb
,, enough for that radioactivity to decay away to negligib.a
.lE [ values. That entombment is the other conceptual alternative.
p n. S 19 s I It involves sealing the resicue. i And notice I didn't say anything about unrestricted i II
, I release. Tne requirements that go with that are still so un-el
'l certain. Presumably the thing would be entombed. People usually 22 !
i visualize it as being entombed with sufficient integrity to 23 L
, permit unrestricted release.
ep 3CP 590F91 AfDortME, inC. 2f " ' u U S 0 0
9 il , 3g Now, the scope of our decommissioninc procram, I l 7 ( decommissioning policy program, covers the whole range of i 1 L licenses that NRC is concerned with. 3 Depending on people's i
, interest, we have people'who focus entirely on reactor licenses; a
lotherpeople, especially in the states, will attempt to focus o 1 6 far m re heavily on material licenses, the small nuclear l
-'I1, material operations, because they are so great in number and l h I gjthe state's role is so much larger in that. !
~
i 9p We are looking at decommissioning alternatives for g uhe whole range. The policy may not be the same for a reactor
;)p as for a small i ource manufacturer, but we'll cross that bridge p' ,
khen we get to it. We're trying to get a coherent policy for l gj the whole range, and we're playing what amounts to a juris-L .i l 3 p dictional trick here. L , L gg This is very convenient for me, and it asks a lot li y of anyone looking at this prograr and commenting on it. We're p/ phs aying this program does not cover waste management, waste dis-glpsal , either high-level waste or low-level waste. As you know, there are many groups all over the 39 , s ; 20 l) country. i There is a Federal Interagency Review Group conven- - 9 gjtionrightnowtolookatwastemanagement, the national waste D 2e. . i , management program. That is such a sensitive and difficult l g jand important problem that it is very easy for a decommission-o ing discussion to become just another quorum for discussing Aes4gcyrO3 I'itD0"ff 8, 8%
.u. g; waste management, and I don't think we would contribute that U
h I
y 10 > , i l.
; much to the solution of the waste management problem. At the 2 y same time, we would not be confronting the unique questions '
b i 3}g of decommissioning, and as a result we would not be doing any- ; J 3
!l thing fruitful. ,
i 1 3 What I have asked everyone involved in this program , I. l 6 and everyone commenting on it, please, for the sake of effec-i . tiveness, presume a solution to the waste management; presume l i H 4
,( that there will-be a repository of some sort when needed and
~ Il 9l;alow-levelburialgroundwhenneeded.
g ,; I recognize the softness or the difficulty, the un-
;) certainty that comes with that , because we're going to make i
1,. i{ estimates of waste form requirements, packaging, how far it ,
, )..Jn has to be shipped, what it will cost to bury it or dispose of y [ it there. Tnat's going te be, therefore, a tenuous estimate t n
g k]l in every instance because we don't have the certainty that yes , indeed, that's what it will cost to bury something 3,000 feet g h g in the ground or in a. shallow land burial site. n g Somewhat related to waste management is the standards n
);[forresidualactivity: how clean is clean? What sort of level I '
20 ei of radioactive contamination is acceptable for unrestricted n I g '!r elease ? That question is vital to decommissioning; and that 0 g ; question is tira up wit'h waste management to a great degree, f ' a,iiso ve will have a significant uncertainty there, too. io 2.; n.. - (Slide.) w.s ece newrm, inc 'li
. 25Fa Now, the facilities in question -- you've all seen l!
d et
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+ + ~ . . e m - - - , e- . r ----y w . ,a w = v.-,,e e , ,wn-, ,q r~ y- n
11 1 t i u l Y . s ' H 1l! this map, I'm sure. This thing.is updated periodically by the , 2 h Department of Energy. 4 It's a map of the reactor facilities in i Il 2L the United. States. t i 4 I might just inject here that the State Workshops ,
?
5 that we had were broken up into regions. We held three of 6 them: one in Philadelphia, one in Atlanta, and one in L 7 Albuquerque, New Mexico. l i 8 ,} The dots on this map give you a fairly good impres- j ll o !i sion of the range of discussion. At the Philadelphia and the 10 Atlanta meetings, very, very great emphasis on reactors. At
'i uhe Albuquerque meeting, a much greater emphasis on fuel cycle 12 f acilities , because there is a paucity of reactors out here 12ti I: but there are an awful. lot of uranium mills out here.
(- 0 14 h (Slide.) 15 We've got now 67 reactors operating and some greater 16 ! number comine on the line. h These are NRC licenses and state licenses of major 17 [4 IE magnitude. There are about 2,000 uranium mills. Half of
~
19 h those are licensed by states and half by the NRC. l l 20 In'the category of fuel fabrication and conversion--i l i l 21 : these are factories that make, for instance, light-water reactor d 22 f , oxide fuel or converts yellowcake into UF, for the enrichment i b O h 2[ plant* facilities of that type, there are about 15 in the 24 ; United States right now. Ac.4.cmi nanm, inc. ' 25 a Low-level burial grounds, low-level waste burial C p. n 1 C i
,-w=c- -y - ~ - '
w , c - _ m , -,-m +==-r 4 -,,,ew vw , w g tw ' -
- 12 -
6 I i f grounds, we have six, but only three are operating. i n. All but 2e one of those are state-licensed burial grounds. 4 3- Here is a category that we consider very important. 1 3[It'sveryeasyforpeopletoforget it when they speak of re- , I 3g actors and all the dramatic questions that go with reactors. 3
.li 6 h Material licenses -- these amount to more than 20,000.
0 7g Right now slightly less than 9,.000 of those are NRC ; 4 U licenses, and the balance are state licenses. Thev rance over !, e u. - - E e/ a very broad spectrum: There is a radiologist that has radio-3g pharmaceuticals for diagnosis or treatment of ill people; L
;; li! people who make industrial X-ray sources; a whole variety of l
yhlicenseeslikethat. Some of them are very small, and some are 1 j~L verv large. { r ! There are big companies, and some that are just j l y one-person operations.
)3 It is across.this broad spectrum that the states g are especially involved, and there, although you don't deal o
g [ with multibillion dollar decommissioning questions -- you know, I g; for reactors the decommissioning costs are in the tens of u
- h billions there the sheer numbers involver. and the difficulty -
1, ,i h 20 f keeping track of them, and the fact that cleaning up the t i, i
.1gresidue could happen if the owner does or moves away and nobody '
,,irealized it, or somethine like that.
"g So.this is an area of l' i i
- Jsome concern to us, a
24 In that group of 20,000 cr more, about 60 percent insnmt nnesm. un. b 3 i of those are' industrial uses of one sort or anotner, and about f it
'N 6 , .- , e- ----e
13 , l} t j l40 percent are medical or acacemic. 1 I i (Slide.) l F r those of you who don't know the jcrisdiction 3 l 4 l l
, split between the NRC and the states, basically for reactors 1
5 and fuel reprocessing plants, if we were ever to have them, ; 6 these are very large facilities, very high radioactivity
/
inventory facilities. We have a Federal licensing procedure i d B for the facility itself, and there is a state certification 9 or water permit, depending on the state -- it varies -- but 10 0 basically the state is not licensing the faciligy; they're more . i jj licensing the site for it. 12 in the fuel cycle facilities, getting int'o uranium i u t
.g 13 l mills and fuel f abrication, there are Federal licenses, or a !
y-l i jg program we have where about half the states have agreements ; I 15 i with us and have undertaken the licensing responsibility for 16 facilities like that. These are the so-called agreement states.i i j7 In the state of New Mexico, for instance, any j i l jg uranium mill in New Mexico would be licensec by the State o# i { 19'New Mexico in consistency with an agreement they have with us ~~ t i I 20
.t license facilities of that type in their state. !
21 The smaller source material, byproduce material ( 22 : SNMs, Special Nuclear Material Licenses, are also done by i l i agreement states. i 23 a I 24 l For those of you who aren't familiar with the '
- Ac.4.oce.i nenornri, Inc. ,l 25h i terminology, source material.is material like uranium or
}l
, 1 ! i . . _ - ~
g' 14 -i ,
?l l l
) thorium-from.which one can start a nuclear fuel cycle. By- i I
2 li_ product material is material which has been made radioactive-E I 3{ by a nuclear process. i t
" For instance, natural cobalt 59 is not radioactive; 'l 4
5 if y u put it in a reactor, it is irradiated and becomes ! 6 cobalt 16 0 , which is widely used in teletherapy or industrial y X-ray use. That cobalt 60 is a byproduct material. 8 SNM, Special Nuclear. Material, is the fissile 1 9 material, the uranium 235, uranium 233, plutonium 239 -- i g, things that can actually fission to make bombs or reactors, '
- 3) I and they are treated according to their relative hazard.
1 i I n There is another class of material that is frequentlyj l 1_, j3 called MARM, Naturally-Occurring and Accelerator-Produced l' j i ja Radioactivity. Radium is a good example. Radium is not ; i 15 regulated by the NRC at all; we have no jurisdiction over that, f, 16 It is regulated by tne states in varying degrees, depending , 17 lon thear own-statutes. ! l 16 l Accelerator-produced materials -- you know, these 6 19p particle accelerators can produce many byproduct materials ; 20 tnat are just like byproduct materials you would get out of a l r 21 - reactor, except they came out of an accelerator. We have no i 22 jurisdiction over'them. They are used in nuclear medicine and i 23 j in industry, again under state regulation where they have it.
~ i 74 Lastly, tnings like X-ray machines. We have no w.Feocrat Reporters, Inc. I!
73 jurisdiction. The states alone have that. , i! ~ n e.
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i i i 1 (Slide.) 1 , I DR. JOHNSRUD: Mr. Be rn ero , a question, please. l , 2q . . 1 I
,?
s MR. BERNERO : Yes. !
~
l ' DR. JOHNSRUD: How many agreement states are there?
.MR . BERNERO: Approximately half of the states. I l 5 i think it's twenty-four or twenty-five. I l
There is a question here. Please identify yourself. l MR. BAUM: I'm Ashby Baum, Virginia Electric Power, t l 8 l i How about the reactors on military developments -- ! I sabmarines , aircraft carriers? NRC does not have jurisdiction i 10 h j l there, but the decommissioning of those units, is that coine - ' 11 ; 1 to be handled as part of this program, also? i l 12 i
! i MR. BERNERO: No, that wouldn't be. The Department I . 13 l
( 14
- of Energy has a whole pile of f acilities. They have, o#
i course, Admiral Rickover's reactors, they have a whole bunch of reactors at Hanford and Savannah River, at the National i l 16 ; f Reactor Test Station in Idaho. They have many fuel fabricationj 17 or conversion facilities, enrichment plants. I 18 - i __ i The philosophy of decommissioning, the criteria for I 19 l decommissioning, many of the things which we are doing here ' 20 I will be applicable to DOE to a certain extent. They are follow-21 i ing this program with interest, but their approach to decom- ! 22 ' l missioning is quite different becausa of their needs, f I j They, the Department of Energy, right now really , 24 ]l Ae.4.oc. n.mnm. inc.d has a three-part program going on . Their fi.rst priority is for i ; 25 y,, li . s. Il ,
-- - -- ,. - ,,,-w --+ y gg > m , ey, y n y + . . , - -r-
n e 16' , i i
;}remedialactionwithold facilities, left over from World War l i
2 II and that era. There are uranium mills here and there, ! 3- material handling stations or fuel plants that were used in 4 the Manhattan Engineering' District. Their first order of i 5 business is covered by a piece of lecislation, which I think 6 passed in this Session of Congress. There is a bill which 7 gives both the authorization anc the funds for DOE, in con-8 unction with the affected states, to clean up some of these 9 old programs, these old sites. They are going at that at the i i 10 i higher priority. 11 Their lower priority is tc catalogue everything they i i 12 h ave, all of their facilities all over the country, and sort I 33 them out on sort of a 5-year plan basis: sort them out to I 3, say what needs to be taken up first and how to oc it. The l 15 general pattern of the whole thing is to follow the criteria { 16 for commercial facilities or licensed facilties to the maximum j i l 37 e xtent possible. This is a very strong trend in the DOE. j i 1E Even in their safety manuals, they have words like, ~ 39 "If you build a new facility, build it as if it will be licensedp" i 20 S the DOE program is not explicitly covered in l i 21 lthisprogram, but it is affected by it a great deal. Obviously,l l 22 iit doesn't have some of the financial ramification 5 that the i
~
22 commercial ones do. h j 24 i In order to understanc decommissioning as an act, ' w.s.woi wwmn, inc. p 25[l'and especially with a reactor, wnich is a very extensive 11 ll .
,, 17 h
t< decommissioning, and a very contreversial one, I have oeen '
\
l 2 u sing an explanation based on an actual type of plant, which
- n. t i l 1 is a fairly common one.
I ll 4 fl This is the Three Mile Islanc Nuclear Station in ! 5 Harrisburg, Pennsylvania, just outside of Harrisburg. It con-i sists of two pressurized water reactors: Unit 1 1s here and 7 l Unit 2 is here (indicating), and each one of them is supported l i i by a natural draft cooling tower for the heat reiection, the E }lt I 9 ;! river being too small for once-through cooling. e 1 10 h In order to understand what it would mean to de-
))
L commission a facility like this, I'd like to take you down g inside the reactor building. Let's take apart a reactor sta-i l a,, l tion and see what we have. l (Slide.) 1., , f g If we go down into the reactor building, the core j ll 16 o- or the heart of the whole thing is the reactor vessel itself. 14 1,/ ;, Incidentally, I neglected to say at the beginning j e, , of tnis thing that co.cies of all these viewc.ra.chs are on the 1-,' table. I .cresume ever.vbod.y picked un. a set. There is a copv .. i Y l 20 [: of mv viewcraphs and a copy of Dick Smith's and Dr. Murphy's t I :
,1 viewgraphs, and there are a number cf other materials, like ,
_, P[ summaries of the reports and so forth, that are available to __j you out there. za i i l This is a pressurized water reactor. It is the ' l om.s e r o n. m n m .inc., 25 more common of the two c,asic light-water reactors which are
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18 1 1-h 1 } more or less' standard in the United States. 1 i! , 2l This is the reactor core, perhaps 12 feet tall and i
. habout 12 feet across.
3 ' i 3 Thres Mile Island is slightly smaller than 1,000 l
\
5 megawatt electric. The current generation of plants going on i 6 the line is a little over 1,000 megawatts electric, but they're
/
not all that different. ! l i The water in the reactor comes in in one of those 8 i l t
\
9 l big nozzles, comes down a sleeve on the outside of the core, j i
);hgetsintothisplenum, goes up through the core.
i 11 1 That nuclear core has fuel assemblies. They are , 1 I i 12 zircaloy rods, about as big around as a finger, and they are i j3 ; filled with uranium oxide pellets, pellets that are undergoing jg lnu'elearreaction, generating all these neutrons and a lot of 15 l heat. l 16 i The heat, of course, is picked up by the water. l
)- The water goes out here; it's pressurized so it won't boil.
33 That's why we call this a pressurized water reactor. It's 39 hcle under pressure, and that hot water goes out to be the 20 . heat source for a boiler to generate some steam so we can turn i 21 0the' turbine, i I There are several phenomena associated with this
^2 i l !
.ea pereactor core that are of interest.
n It is very radioactive . 24 itself, because as it fissions, as each uranium 235 atom in m m - .-,.,..,q[there'brear.s'up, 23 it breaks into wnat are called fission ii
't m
h '
- v , w e.-, -,--4n,- , , - e,
19 it
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fi !
/ i 1 !! fragments or fission products : things like strontium 90 and i i !
2 h strontium 89 and cesium 137. Many, many radioactive materials l gl 3* are in those fuel pins. And the fuel pins aren't always intact. t
)
i 4 They leak, so you get some fission product leakage into the ' 5 reactor water. It gets out, and there are systems to clean it j 6 up. l 7 In addition, all of the neutrons from the nuclear E oreaction are banging around in there, and they actually make 1 l l 4 9 l the structure radioactive. The stainless steel around here, i
- l 10 t these pieces that are holding the core in are exposed to this l
;l radiation flux day after day, and some of them become very j i
12 radioactive. By that I mean that the metals in them are con- { i 13 l verted by the nuclear proc'ess into a. radioisotope. It's not i t 14 i surface contamination; it's right in the matrix of the metal, i 15 lthe metal itself. I i i 16 l In addition, even though this is virtually all 17 i stainless steel and materials like that which don't corrode i IEl fast, there is corrosion.~ The corrosion products, the very 1 i-19 [ small particles of metal, circulate around. They have a j i i 20 tendency to stay in the core when they can. When they're in t ! i 21 ]thecore, the neutrons irradiate them and they form what is I 1 22 j typically called crud. Tne crud is really a bunch of black ' t 23 .;I metal oxides. It's just a thin black film or crust. It is
. U 24 0 quite radioactive because it 's irradiated in the reactor.
we, care nnerms. ine y 25 [ The nuclices u: it are metal: 9 manganese 55 and chrome 51 and h 0. tr
.e ., ~ ,, , , ,, ,,-w+ -
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20 i
)p cobalt 60.and cobalt 58.
u l-2 {j The predominant one, the one that really is notice- I U l 3 ~a ble in the radiation flux,-is cobalt 60 ; 4 Tne corrosion products, this crud, will deposit f 1 3 on the surfaces here. It will also go into the pipes and out . 6 into'the cooling system and deposit in fairly extensive i
' quantities, so that-one can develop fairly hign radiation. i t i l
g ' Tnat is material that is not in the matrix of tne metal; it's i l . c., on the surface. It's a crust or film on the surface, and ! l g the right kind of an acid or scrubbing treatment can remove it. 11 ] So we have a couple of types of radioactivity to I i 12 note. One is an activation product that's actually in the i !
! 1 33 ! metal, so the chunk of metal has to be removed. The other are I
( ' y activation products or fission products that are deposited on 1 15 ; metals or other surfaces and micht be scrubbed out, unless ; i 1 16 ,;i it's just not effective. Concrete is so porous, and it might i i
! get into the pores.
t
)7 i If you spilled it on the floor on some j i
33 l bare concrete, you might take up the whole concrete as waste. t I-
)9 So keep in mind that in tne reactor you're dealing i l
20 e lwiththepiecesthat are inherently radioactive -- and later 73 on you will hear how radioactive. 22 (Slid **) 1 33 -ll If you loor. at that reactor core and reactor 1 24 g pressure vessel in scale with a nuclear steam supply system -- w.t.o,,.r 9,noners. inc. y 3 yhere's a.numan being for scale. It's a very large system. d it i; N
, . , . - , , , - - -,--,c . .m, . , . . , . , -,--,.,,,w,m s...,,,. ,-,,.,,,%..,, - . , , . ~oy,..,
21 i G ,- . 1 i O i ) 1g This is a reactor vessel. This housing up at the top holds it ! f 2 the control rods. The hot water cc:aes out of that reactor, i h { l 3! l goes in this tall, straight pipe that goes up there. That l
^
4 ' tall thing is the boiler. I i 5 . This plant configuration shown here happens to have . 6 two boilers. It's a two-loop plant. 7 The hot water just passes through the boiler and i e }. acts as the heat source to generate steam. The steam pipes ! I' , 9 laren't shown he:e. The steam goes out anc turns the turbine, iI 10 'i and tnat 's wnere the electricity comes from. F 11 The cooled after, after the water has given up this , 12 I heat, these big pumps bring it right back into the reactor to i i 13 {co it all over.again. \ i la l i 1 This system, which operates at fairly high pressure, 15
;more than 2,000 psi, is the system I meant when I said the i
16 I corrosion products circulate around it and build up in places. i 17 jWe 9et some fairly high radiation. le { j- So when you are decommissioning, you say, "Well, i 19 I'm just going to have to take the fuel out of the reactor. I 20 ilwill also have to take those irradiated pieces, consider them, I' ll 21 vhat to do with them. i And I've got a lot of this surface con- t
\
22 t tamination or crud on all these pipes and boilers and pumps and l 23 such' so the reactor coolant system is a candidate for de-24 commissioning." It 's basically a big matrix of stainless steel. w.5 0,ro: seconces, im d 25 Sow does it fit in the building? Let's see the next slide. t < i 4
l' 22 l'
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i i t I (Slide.) ' ( 2 l All ofLthat goes into the safety containment build-
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. 2 l
ing. That's what you saw in that picture when we started out. 4 It's a big, cylindrical structure. It's heavily reinforced 5 concrete. The purpose of the building is so that if the 6 reactor coolant s stem ruptures or bursts in some way, the 7 steam system bursts, the whole mess is contained to protect g the public. 9 Now, there is an intricate concrete matrix inside l l
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l
)0 ' that building. Here is the reactor vessel way down here, in '
h, t' 11 a cell all by itself. Next to it you can see a cutaway here. I l 12 There is a separate cell for the boiler and the pumps; another ! 13'l y one on tne other side for the other boiler and its pumps. If ; 14 you have a four-loop plant, there are four such cells. Those ! t 15 lcellsaredesignedsoth'at if one of the pipes bursts and 16 jwhips around, it's going to hit concrete and not another pipe; 1
'7 1
li i i't won ' t propagate the failure. I i IS }l This inner shell' surrounding the reactor', in theory i j 19 even this can become slightly radioactive from the reactor , I 20 flux. A few of the elements in the concrete, the rare earth I i 21 . metals, might convert. , I 22 j i There is a major transfer of radioactivity about 23 !;once a year in a reactor. You have to refuel it, on this h 1: 24 'i sort of reactor, you flood it. A..pmc.i n wonm, inc. ! You just flood this whole thing; i 25 dtake the top off the reactor, and there's a passaae to co out I
. li
; i I
i 0- l
a 23 q
! l into the next building. Tnere is what amounts to a big swim-
)
2 ming p 1 ut there . I I I
,, (Slide.)
4 That swimming pool is where they store the exhausted i' fuel. New fuel is brought in; the old fuel is brought out. 5 6 I have to apologize -- this is not a reactor spent 7 fuel pool. I don't have a good photograph of a reactor spent fuel pool, but this is the General Electric Company's Morris, 8 9 Illinois , facility, which is a large spent fuel pool for special 1 l 10 storage purposes. Functionally it 's the same thing . It is h j) a pool full of water with holders of some sort in which spent Ii 12 f uel assemblies are stored. 33 (slide.) ! l I 34 You have a close-up photograpn in the viewgraphs I p- I which will show you a closer view of the holders. l 1 16 The water serves two purposes. It actsasacoolingf I l
)7jmediumtoremovethedecayheat from the fission products in '
l; the spent fuel and acts as,a biological shield. I
)g Spent fuel l
-- 1 39 ' is very radioactive, and if you walkea up to it bare you would , I I i 20 get a very serious radiation exposure. The water acts as an 21 ex ellent shield to suppress that radiation exposure. l i I l 22 As far as contamination is concernec, the spen
- I
'3 l fuel, of course, is a major contaminant. It is itself very i
. l 7jj;e radioactive,butthepoolitselfisgenerallyaveryclean '
Am.fewel Remrftrs. lec. d . 1 25 h r relatively clean facility. The water has a purification , o lI ll . ! u -
v 24 1 h i
)
; system to keep it clean. 'The pool is lined with stainless ;
l 2 j . steel, which can be scrubbec down and decontaminated. i l
., (Slide.) :
l i ; So we go back to the reactor station and look at f I 'i 5 the whole thing again and see where is the radioactivity. 6 You'll find the reactor core, tne reactor coolant system in here. Tne spent fuel will be in this auxiliary building. In 7 9
- 7U "
B 9 go with cleanup systems. l
\
10 For the most,part, that great, big vista you see is , 11 a nonradioactive structure. It's transformers and wires and g cooling towers and warehouses and office buildings, a whole j 13 host of things that go with a major station. i f i i y This brings us to a serious question of jurisdiction.i i 15 l Under the National 1:nvironmental Policy Act, when we license a 16 .eactor we ao througn a process of talking about the entire !
. 1 37 impact of the facility. As'many of you know, we spend a great [
)g d eal of time talking about,how to cool it and proper sites,
; cooling towers, things that are not radioactive but which are 39 i
i g , associated with the impact of the facility. f g When we come to decommission a facility, should we l ! 22 { care whether the cooling tower stands or falls? Is it NRC's 23 resp nsibility, NRC's jurisdiction, to come up with a de-24 h e mmissioning plan for assurance, for requirements that speak l
'se s,oen neponm. nne. l .
# 3[fto the levelling of the site or not?
n p ! I
T 25-
'i .i-i l
~
1 ) Well, our estimates -- and they will be discussed i i
'in detail -- our estimates and studies are not only removing.
4 2 3 ! the radioactivity, but taking the whole site down to a level l 4 of what I call a parking lot configuration -- just level the t 3 shole site. l 6 You will see from that that there are significant 7 resources associated with such levelling, and we feel that, g naving laid out'the thoughts, then we can always say, "Do we 9 do it or not?" We can decide and know what we're excluding ! i jo or know what we're including, whichever way we decide. j) (Slide.) '
~
12 If you look at some of the history of decommissioning,
, 13 , there was a program that the old AEC funded for power demon- ;
ja j stration and test reactors. This was 20 years ago, 25 years l 13 ,ago. Everyone had a pet theory on how power reactors should l' i 16 be designed, and they came up with many, many designs, many i j j7 l sites. Small experimental reactors were built in a variety i i I 15 of places, and an arrangement might be that the Atomic Energy ' t 19 j Commission would of fer a utility or operator what amounts to i l i 20 'a favorable arrangement: "Here, try one. Let's go in together,l 21 Iand 'I'll pay for most of it. Let's try one and see if it works I 22 jout to be efficient as designed." . 23 , Many of these didn't work out. They were experi- e i 74 l mental devices that weren 't as good or weren't as efficient, w.s,oew uwornes, sne. .i.i ' niDor too small or whatever, anc so they were decommissioned.
+-
.\
,o T I
.1'i t
t 26 o 1 l t j These are the names of them and tneir locations. l l 2 Tnat is self-explanatory. Note that we're talking about very l l
,; small' facilities. The megawatt thermal, 256 is the largest
-l l 4 one. Current reactors are limited by NRC policy to 3,800 5 megawatts thermal, and all of the current applications are for i
6 numbers very close to that in size. 7 I'f you look at the decommissioning mode selected, E y u see one of the penalties we suffer ror a policy that's , 9 not too clear: we have a lot of mothballed reactors. They're jo not hurting anyone, but they're not fully decommissioned, a 13 [ There are a few that were sometning other than i i 12 mothballed. You will see a few entombments here, and you see
, 33 a dismantlement here and there,
)g This one has received a great deal of attention, l i
j3 the Elk River, Minnesota, reactor. This is a widely discussed I f i 16 lc ecommissioning as an example of how a power reactor might be ! l
- 17. l dbcommissioned . i t
jg Here is Elk River. It's 38.2 megawatts thermal, I I 39l which is, as I said, very small. It operated for only six years l 20 il which means it didn't get as radioactive as a long-life plant 21 will get. It was decommissioned from the period 1972 to 1974 4 l 1 22 fbydismantlingforunrestrictedrelease. I'll show you a i . . 23 l couple of photographs of it shortly. I 24 j I should qualify the " dismantling" label with.the i Am.Fewaf Aemm% tnc. d 25 fact that Elk River generated electricity along with coal. ! j n I I
? e 1
-1 4 27 <
I 4 I i 1
) ; Elk River ' was a boiling water reactor. It heated the steam up '
2 to.a certain point. Then the steam was passed through a i 3, superheater which.was heated by a coal fire. That superheated
) e a
. steam went through a turbine.
t S When the time came, the owner said, "It's a great l 6 little thing, but we don't want it." The dea? was the AEC had E 7 to take it away. That's why it was decommissioned, g But they wanted to keep the turbine generator, 9 l which was perfectly good, and just do all the heating with coal. jo l So you will see the reactor part, the nuclear or radioactive i l: 11 i part, was dismantled, but the turbine generator and the coal i 12 plant.wasn't. 33 l Before I go on to show you the pictures, at the _ i 14 beginning of their dismantling. activity they made a program l 15 estimate, which is available in a detailed report, a detailed breakdown of what they thought it would cost to decommission 16 I 17 the plant. They~came up with S5.1 million, and then a couple , l
)g lof years.later they totalled it up and it was S5.7 million, !
39 which was not too bad. 20 DR. JOHNSRUD: Judith Johnsrud, g What was the original cost of construction of the 22 plant? i 23 MR. BERNERO: I have no idea. 24 l I must interject, there are many people, in par- ; AuJmeep Retortert ine, , 2' d ticular one of the Congressional committees, who nave called s l l 1 - n : o i a-A
, . . , _ . ,~..,-,,.-,-w s - -
28 , 9 , N o i. U l 1['on the fact that Oyster Creek, I tnink it is, is carrying an i i F
;j estimated cost of-5100 million to dismantle and $65 million or l
; l F
3/0 556 million to build. One of those is 1962 dollars, and the ( i ,I 4 other is -- I don't know, 1982 dollars. I think comparisons l l 5 like that are unimportant. l 6 If you compare what you paid for a car in 1971 and j 7 what it cost you to put a gallon of gasoline in it today, ) E ! you have to normalize. i i i I 9 l I think if you spoke in terms of cercentace of re- -I e 10 l sources -- normalized to some year, put everything in terms i j ' 11 of the same year dollars -- you will generally find most l l I 12 people 's estimates say that decommissioning costs somewhere ' l 1 13 )between5and10percentasmuchasit costs to build a plant. l l 1 l'
; l 14 (Slide.) ; l
! l 15 ,
Wnen they dismantled Elk River--this is the reactor I l l l 16 I vessel head -- they developed for that a special plasma torch, . l I ' 17 lwhich is a torch to go under water, cut off those hot pieces, i t l 18 ltne parts of the reactor which have become quite radioactive. t 19 1 This is a photograph of the In_ =.llation of that. I I i 20 } Note that this is a f airly small reactor vessel . The men on 21 ltop give an indication of scale. A modern reactor is not only ; i I i 22 jgoingto-haveanotablythickerpressurevessel, it's going to 23 'jbe a much larger vessel in diameter. ! h ! 24 l;. (Slide.) w .o.ex a.m mes,inc.p;j 25 Af ter the internal parts of the reactor and the 0" h d f l 11 .
+
- 29 !
l f i ld i j inside shield were cut up, the reactor builcing was open. HereI a. l 2 { you see a jagged . hole in the top. The crane is now picking 3lat
! the pieces to haul them away for burial. ! l I
l 4 (Slide.) l t I 5 And then that wnole reactor building was torn apart t 6 or dismantled, down to -- this is a piece of steel coming out k 7 of the subgrade. g (Slide.) 9 : Lastly, you see the same area, where the reactor i D t
)ghbuildingisnowwhat amounts to a parking lot, and all the !
- i. t
- 3) structure behind is associated with the coal plant. i j 12 That type of decommissioning of levelling the 13 , site is the sort of process we will be using, and those details 34 lwill be gone into this afternoon. '
I i 15 j This extrapolation of experience we ought to take I with a grain of salt. This is just a summary of it. 16 There is )
! I p a big difference in. size. We did a study of the Trejan reactor,!
16 which is 3500 megawatts thermal, and looked at the difference ! l 39
;! in reactor vessel wall thickness , 3 inches versus 8 1/2 inches. l 20 You see it is substantially thicker, and, of course, it would l 21 i be much larcer in diameter and heicht. ,
i l 22 l The years of operation: 6 years for Elk River, ' i I 23 :and something probably in excess of 30 for a major commercial > I 74[ reactor. 4 6 4e .p.e o neoonn inc. ! 25 n The dismantling costs in here, you've really got to ; d i 1: 6 i 3
- ..- ,, -.,~- - , - 4 -y .-__,4ye , ,
n" 30' , l
.I 1 -
i
- I '
i
)
be careful how you compare them. The Elk River dismantling w ,
.y ,
costs are in '73 dollars, and that does not include the stean !. I i s p lant and the neat rejection system. Our cost estimates, I i h a which will be discussed for immed'- tismantling, which is S somewhat comparable, is 542 mill : incluces all the 3 station facilities and the last full core and was in 1978 6 1 7 dollars. 8 ~ 9 MR. BERNERO : 't e s . l i 10 MR. STOUKY: Jon Stouky with NUS. ' u i j) When you say "the last full core," would you i l 12 cescribe th9t? 13 i MR. EERNERO: Yes. This is just a nookkeeping ' i 1., .! thing that we've encountered a number of times. In tne cost 1 15 lestimatetnatDickSmithwill show you, he will show you a l l ', 16 {removalandtransportcostforthelast set of fuel assemblies. ! l 37 . It's been pointed out to us a number of times already I gg {that'thewaythebooksarekept for a power reactor, that is I e ,
-- i j9 an operating fuel cost, not a decommissioning cost; so you !
i l 20 will see that separable item. ; 4 i < 21 ! 7 f rget -- it's a couple of million dollars, 52- I a i or S3 million. 1 l 23 When we say the last full core, that 's in there , 24 depending on how you keep books. Most people say it's taken Ace 4eoerst Reporters, ar o int, } out and not counted .
.. p II i y eA+y y gr wt y -m-ea,ng J-n 'y y 3 w -gps-e--yg--ww',mwyw y -g y mg 4 r w-+y- p
31 o" i
)
j MR. STOUKY:- For tne period of time associated l j
' l 2
with the decay of that, last core, there are a lot of decon- f l l
~
l i missioning activities that could be taking place but can't be -
},
9 l l . because the fuel has not been used, and in essence a lot of 3 5 safeguard systems have to be maintained. Is the operating f cost for that period of time covered? 6 7 MR. BERNERO: Let me defer these cuestions to.what Dick Smith nas. He nas a time line of expenses that will 8 explain that, I think. 9 MR. BANCROFT: Micnael Bancrofu, Public Citizen l . 10 , 1 11 Litigation Group.
! 1 In tnis picture of the Elk River decommissioning, l 12 vou have a cable there; and I wanted to ask about the auto-
, 1.3 . i jj j mation for the uncerwater cutting in cecommissioning the l 15 Tr an Plant. Would you have people in there doing tnat? , t
. I 16 l MR. BERNERO: Well, I think you could, up to a j point, because you would have water in there as a shield.
37 l 18 Dick Smith can better answer this this afternoon, I think, when l l
~~ !
39 he goes into the technical dis'. Tion. 20 There is a high rad. ion field down in that 21 reactor vessel. We don't have people going up close to it cry, ; 22 but once you have the water there.the plasma arc torch would 4 perate.under water. I. suppose the people are within 15 feet l 23 1 24 of it or 20 feet of it, something of that sort. I AaFersRemmn.ine.h ! 23 1 MR. BANCROFT: They're still in the containment, 3 l i I j i
- . . - + .e , ,n. ,......e,.,-m._.a ,
32 r i F . i ! F 3 within the -- , o i 2y MR. SERNERO: Oh, inside the containment building. l 1. c 3 ,i' MR. BANCROFT: -- the concrete. l
- i j MR. BERNERO: .Wnen you refuel a reactor, you move a r und , too. It goes rignt down througn the water.
5 I
*1 6 It's just like the spent fuel pool. The water is
/
a shield. It's a very effective shield. Tne radiation doses g are not trivial doses, but they're manageable. 9 Let me talk a little bit about wnat our present . je j requirements on & commissioning are, our present policy.
- P 11 (. Slide . )
l 37 We have our regulations in a code. :- Title 10, l, ' i ! I j3 ' " Energy , " of the Code of Federal Regulations it's difided l i 1
), into Parts, according to what the subject .ie subject 1
1 i 15 matter for regulation. 16 I Part 50 is the Part for big things, for what Are I p ; called technicalled production and utilization facilities. 1 . i
)g Actually, that means nuclear power reactors, enrichment plants l' l t
19 .or fuel reprocessing plants. SinceasamatterofFederalpolicyf I
- i 20 i
!all of the enrichmen* plants are and remain Federal plants, 21 and fuel reprocessing is not one of the options we're pursuing I
22 i at this moment , to all intents'and purposes we are just l I l 23 l icensing only reactors under Part 50. 1 1 l 24( Part 50 has two sections of interest for decommission-Au FCDers' FitOJrters, Inc. .f' in g : and 50.82. 50.33 73 j, Part 50.33 is the one that is operative ; a ' C, , . H t
.p!
I m
,,_ --+-m.e &'"
33 , 4:- i E d .
; l at the beginning, before you license a plant. In essence, ;
, 2 what it says is that whenever one of these facilities is to l 3
h be licensed, there must be a careful evaluation and a finding
, that the proponent or applicant is financially competent to ,
i 1 5' Perate that plant. By financially competent, that means that I 6 that company or group of people, corporation or whatever it is, 7 has the resources to hire the right staff, do the right train-1 > g p ing, cope with emergencies, to obviously construct the plant, i d 9j pay the nills, and all of the things associated with the con-gg]struction, operation and shutdown, safe shutdown, of that plant,. 3), with the extrapolation being that safe shutdown, of course, 12 w uld include decommissioning. I t 33 j now, there is an Appeneix to part su to detail or , i; i I 1, ; 7 delineate exactly what financial information and reports are : 1 g needed to make that judgment; but as far as decommissioning
{.
I 16 ! plans are concerned, 50.82 is the operative one. And it says c i
)7ysomethingthat is very troubling to many people. i
-g It says in effect when you're ready to decommission, !
39 , come and snow us exactly what you intenc to co; you must get I . 20 [ ur appr val bef re y u can do it. l
'l l g : That's an end-of-life thing. It says after 30 or ;
i- ! the owner would come up and say, ' 22 l 4 0 years or whatever tnat
'3p b
"Here is what I would like to do with that plant." It's not [
r t
. , prospective; it's not settled at the front end with any great A=4=we ne=rms. inc. ,i j 25 , f rmality. ,
L t i t i! ' II .
t; 34 e u i 3 The only thing that sort of guides it is a. Regulatory i . I i 2 Gude, R. G. 1.86. Regulatory Guides are published documents i i l 3j! by the Commission. The NRC Staff explains to users or
'l i 3 l l icensees or applicants how we are applying or enforcing the l t i 5
regulations, in sufficient technical detail to be helpful but 6 without the force of a Regulation. A Regulatory Guide is a j l 7 {Staffopinion, and it basically offers -- I get some cynical j i l gqsmilesfromsomeofthepeopleintheaudience-- l 9 ql (Laughter.) 4 10 h A Regulatory Guide in ef fe et says to the reader, 1 l 11 :. "This is one acceptable way to do it. If you have another 12 acceptable way or a better way, show us and we may accept it." i i l ' 13 ;i And the skeptical smiles come from, the burden of If
)g[ proof and the lack of success many have had.
o 15 But Regulatory Guide 1.8b on decommissioning says 1 ' i some not too clear things in my mind. 16 It says decommissioning ]
!; i p f is a good thing to do, you ought to consider it, and all the l !
- i jg nice words; and then it says there are four ways to decommission.'
I:
~~
It says you can mothcall, you can entomo, you can dismantle, 1 39 j 20 i: or you can convert tu anc r facility. > 0 i , That's Kind of troubling, because those things are i 21 j k n I 22 ' n t an even set of options. Mothealling, which means removing i 23 j i only the readily removable racloactivity -- the spent fuel and ; ) 24 3 the~ liquid waste in the tanks -- tnat's not complete decom-i , Ac.4soore Reporms, 25 That's Inc. [ missioning. only partial decommissioning. , n F . D
' 1 O e j
\
, . . - , - , , . , e -~* ~
35 di-I' y-
)
Dismantling, of course, is complete decommissioning. l 2, Jntombment in the sense of Reg.' Guide 1.86 is complete de-l II 3q commissioning. Conversion to another facility is really not f y l . 4 decommissioning. It's a perturbation of a decommissioning i f choice. l 5 : 6 As you saw, you could say that Elk Riv.er was dis- 'l 7 mantled insofar as all radioactive material was taken away, I C or you could say it was converted insofar as tne turbine
, e I
9 generator was neated solely by coal afterward. l n '
)g d So it's a rather confusing set of options that's I
)) ;, covered in Reg. Guice 1.86, p' For fuel cycle facilities, with.the exception of i I
l 33 Appendix F to Part 50, which is a little bit better than what ! n i 33 we have for reactors, there is very little in the regulations l 15 s. f or fuel cycle f acilities. I j 4 16 , Part 50.33, the one on financial competence, applies i
)7 .to the fuel reprocessing pinnts, if we would ever license one.
t l
;g i' Tnere is a part in the other regulations for fuel cycle ~~
39 , facilities -- Part *0.23, for example -- wnich imposes more e i I i '
'y vague , perhaps , but similar requirements: that the owner l i
21lshouldbefinanciallyqualified. t i ' 22lh And we have a variety of sources, like Regulatory l i Guides, for criteria. This one here, Regulatory Guide 3.5, ' 23 ,
.y 4
b is criteria for the stabilization of mill tailings. g That's aw ew.; nemnrt inc. L 33 :. not the only - thing in there , but that sort of decommissioning 6'
! )
I li ,
d m f 36 e.
! l H 1 d 1 i I
jg criteria is in there. p i 2 And we have residue. limits guides. Reg. Guide 1.86, f i in tne back of it, 3 1 I hasatableofresiduelimitsforacceptablej l
,k cleanup of walls or floors.
5 But none of these are well tested residue limits. ! 6 ! They're good practice numbers, . good health pnysics numbers. [l 7 It's sort of a hooge-podge of Regulatory Guides and opinions C i t hat we have. l j t ' 9 (Slide.) ( 10 h Just to give you an idea of now decommissioning is U 11 h aandled in a typical reactor case, tne licensee or applicant i V; 3 identifies usually some tentative mode of cecommissioning and { u !
, 33 associates costs with it. That's part of his environmental !
F gg ; cost analysis, the bottom line being mills per kilowatt-hours l 13p to cuild a nuclear plant and so many mills per kilowatt-hour { d, '
' ! l y ; to build a coal plant or whatever. I l 9
H l 17f The'NRC Staff looks at the cost of decommissioning i 0 i IS[andthetimine in that financial assurance or financial comoe-1 ~~ O 19 , tence review, out when you look at let's say a typical i I b 20 j pressurized water reactor .today, it has a cost on the order ! .; d i 21 I f maybe 5800~million. If you're looking at that cost today '
, l I
22 against a S40 million decommissioning ccst 37 years from now, l ( 23 [ tne ' decommissioning c~ost disappears. It's trivial compared to ; t t 74 [t hel current cost, because the current cost is not only much l w.5,o.,e memnm, inc. , t 25 [ larger in magnitude and the resources recuired; it is nere and I; F i h- . O ! a >
i
,e' 37 J" l
.9 now. You can't throw some monev in the kitty and get some
" ' i . ,
': i e t '
2 interest on it or.whatever for leverage.
. So even chough de-si i 3 11 commissioning cost is consicered, it becomes a relatively 3 0
- I l
\
small element in that cost consideration. When the NRC Staff g !! c!$,considersthemillsperkilowatt-hourintheNEPAfind1nc, in i 1 6l the Environmental Statement, decommissioning is not a problem; l .i 7 t i it's not a'significant factor in the cost-benefit analysis. l' I ' g It treats it, but treats it only moderately. { F 9 We rely on tne financial reports in this 50.33 l ww r finding for the financial assurance. The funds for reactor
;) decommissioning.-- if someone is going to have a sinking fund ;
I
);
l ', an escrow account or something like that, we have traditionally l 4, i
,el(2 eft tnat to the states, usually a state regulatory commission l
I
),, or public utilities commission. Each state has a different i 15 0 name for it. This is the nody, state body, which regulates -
F 16 ' electrical rates for investor-ownec utilities , and we leave it 1 i y' to thac. l IE Many of the states have mechanisms for this. There l 39 1s a wnole mixture of opinions on what the right mechanism is, i h ; 20 . and I have just one example here. 4 : L This is one that is beinc - 21 [ used' in the state of New York but is under reconsiceration, e i I'm tole. e2b
- z. t. Basically, the philosophy is that the decommission- i 74,.ing cost is a cost of power generation, anc it's legitimate to
. w.rcens r,,wnen. inc. g pass that Cost on to the Customers of the plant, the people , I s.
. j:
e p n v , - +..n.n. e n ,.- ., ,, ,, , & .,,,,-e, e gm. -w-r-,v
38 I 1 i l using the electricity from the plant, to get a , crc rata share 3 3 t
' , i
" 1 2
passed on in an orderly' fashion. ; What they do is the utility commission has the
,'i' ;
i
.i F ,
,' utility set up a depreciation curve tnat doesn't nearly write i
off the investment in the facility but comes to a minus salvage l , 5i, i value, a negative' salvage value; it says the decommissioning 6 7 { cost, way on down here at the end of life, is a negative number
.: I' g
l in our depreciation bookkeeping, so collect for it in advance. j i 9j Obviously, wnen they're collecting tneir own invest-g l ment nack, tney use a different way. Tnis is collection in
,3 acvance for an expense. .
i What happens is tney nave to crecit. They collect 3 II l
..e
.J2 that money and credit some reserve fund, anc that reserve is
); not counted in tne utility's rate case. It's customer money; 1,
it's not utility money. It's money that hasn't been spent. 33 o Then the utility com=1ssion nas a choice. They can 16 37 say, "Snall we put that in a bank or in a credit union or n
)g escrow account or wnat?" .In this case, they said to put it je into tne snort-term cash flow of the company. In tne snort-F
,C -
term casn flow there is a rate of return of about 15 percent,
,, and it's like having a savings account tnat pays 15 percent i D i 44 r interest.
l' gI In this case tne utility commission says, " Keep ' o
, tnat reserve fund account and credit it as 15 percent interest, wrwe neno,ms. une
;3 just as if you_didn't get tnat money from a cusicmer cut had I
I E
, .. m --,---,y , .. m. . - ,.y., -~ >
39 a t borrowed it from a local bank. i 7; In tnat way, the customer paying that money gets j the maximur interest leverage. Complicating the issue is the
,i su il IRS comes in, the Internal Revenue Service, and say, "Tnis l
o should ne cash, or "That snould be cash," and it fouls the 59s i wnole thing up. ; 6 I I ' Where tnis mone'v coes, how it's treated, how it's li 7 l especially associated with E [ collected is full of complications , d y ! the tax treatment. h, I emphasize again that enis is wnat states are coing. Many states are dcIng this. Tnere is a perceived need 33 i r '
, ;! a coss the country to bring order to this procedure , to have uy e
,3 more standardized procedures.
For instance, in Massachusetts -- let me say it the
,t a
other way. The Millstone Plant in Connecticut, there is a
)3 similar arrangement for its customers in Connecticut; tnev -
16 are paying for decommissioning. But the same plant has cus-g g tomers in Massachusetts who are not paying for decommissioning,
~
);
so there is a lack of comparability between states and there is a perceived need to bring orcer to the process. ec ,
*y l, (Slide.)
I' i, a,. F So let me summarine. Wnat's wrong with tne present policy on decommissioning, NRC's at least? We don't have 23 , recocnized criteria for racicactive residue, s - ACDJCCef t' ReMriff t, lhC 73 If you go out and say, "Wnat's an acceptable f i
l l s, 40 ; n. 4 1 1
'l[ radioactive resicue for unrestricted release in a soll, on f I.
2i a surface, in a burial ground or whatever," we don't have I 3 well established by rulemaking criteria. We don't nave criteria t . 1 I 4
, we coalc point to and say, "These are tested. These are I
! I i
50 valic. These are sound." Tne whole thing ultimately is based l I 6 , i on EPA criteria or stancards for radioactivity in the environ-a\ i 7J ment, and those standards don't exist yet, either. i I L t t Ey Right now there is a real weakness in that there e is a lack of recognized criteria. What has happened in the 12 past is someone cleaned up a site to criteria believed to be Y' acceptable in that instance. Then 10 or 15 years later someone 1 H I 12U else comes along and says, "I don't like that," and there is l 13j;abigargumentandanothercleanup. You get remedial action programs. 15 , We don't have a clear policy on the moce or method M of cecommissioning. We con't say flat out, "You must not 17 entomb." We say, "You may entomb. You may leave it there." if we don't say anything about wnen. There is nothing in the
'S regulations tocay that says you have to decommission a reactor F i i
20 within 2 years or 20 years or 200 years. The regulations as 21 [,p resently written are such that as long as the owner is j U. 22 [ financially competent, you just have it sit there in mothballs. l 1, 23ij Or for that matter, it can sit there like Incian d Point 1, Amseerr Aeoornri. ix. n which still'has fuel in it -- not even mothballed. I k 2 d S 4 l k 8 ,
- . . .. . ~ - . - - - . . . . . . . - . - -. . . a.
41 o i 1 1 b environment. It's guarded by a competent owner, but there j 1 !
- 2 [; is no time restriction 'cn1 i
that. That plant could sit there l
,e i l 2[ indefinitely. '
I f I i i The financial assurance on cecommissioning. As 1 l l i 5 said, we ' ve got a big range of licensees. Some of these people 1 i i l l are very large, power companies, investor-owned utilities i 6 . 7 , The TVA, Tennessee Valley Authority., is one of our licensees. l j , I E[i They own a number of plants. These are very powerful, very li l l l 9 reliable companies, and they're in a protected position as
'c regulated public utilities. They're without direct competition r !
l 11 { and their position is modulated by the states in a variety of b i 12 j degrees' so that they have an almost assured presence. I 12 j' There are other licensees that don't have anything i 14 like that. They are small owners of radioactive facilities, if small companies . They can go bankrupt; they have much compe-16 tition. Their economic situation can cnange dramatically. , 17 So we don't nave a clear policy on distinguishing 1E between those. 19 Last but not least, little is ceing done to improve 20 plant design, any Kinc of plant design, to facilitate de-t- 21 [\: commissioning. 1-p 22[ Tnere are probably a lot of design features that L 22 can ne put in at relatively modest costs which wcule either 24 recuce raciation exposures or reduce the cost of decommissioning. ' A!lb Fecero4 Resoners. IN. 23 r (Slide.) I-4
, e --
t w r -v , -w , - , - % y- mt,- -w e .r ,ww-,*w,-v.m.,,,,eecem-e-- mwv-w*..- g ~ee .t
_ - - - - , g. : _s - - n 42 a jp So what we're doing aoout it is we've got this a i.
, , . program to completely re-evaluate the policy. We're trying to
*LU .
,;; look at all our activities and set up a wnole basis of technicali \
~
l!, i
, studiessotnatwehaveacommongroundofcostsorraciologicall l
sc ;1 impacts, a kind of basis of fact on which to do the deliberation.l 11 i V 6l And we're going to do this by rulemaking. We 7 put out a Federal Register notice on March-13th, I think it i -' ! i 8;was, saying we're going to do rulemaking for policy and imple-i l l h~ ! l 9jment rules on decommissioning, i g] We are particularly interestec in coordinating with i
;; e the states because of the mutual interests. Also, wnat we do ,
it on NRC-regulated or co-regulated materials would aisc be useful i
);]0 '
l g, to them for the radioactive materials they regulate alene.
\;
34 g Some of the factors that influence us in doing this ; 15 fthing are that we recognize, and hope that you do, that the 3 responsibilities associated with decommissioning are the urgent j- factors. It's not the act of decommissionine. There is no i lE Jgreat rush to get out there and take apart a nuclear facility.
~~
3; Most of the power reactors, of course, are very valuable in-p 20 % estments, and most people want to operate them and generate i t' d _7)lelec'tricity to make them pay for~themselves; but the responsi-i! 22 , nility to make certain that it will be done, that it will be P f
- 3. . cone by the right partie s and paid for by the right parties, i
;; that's urgent, getting that straight. ,
Am.s ces newms, inc. , 25 , So in our policy and rulemaking we want to emphasize i l' kh 4 4
, 7n,.,-,,.,,e-te ~-v--,- w s-'*,,r%
n- .43 i
~
F D
) ( allowable or permissible methocs of decommissioning, residue i .
S \ 2hlimits, timing and financial or surety arrangements. I
, ! We recognize in this program'that we've got to sort j s .
Il f k out residue limits tnat we use for purposes of calculation l
' i 5 u t
r p licy development with the Environmental Protection Agency j i 6
'I and with the host states that are nosts to these facilities. i I
~
I 7 On financial surety arrangements, we are also in-volved with the states and with the Federal Energy Regulatory E Iil l eh Commi.ssion, which regulates wholesale-for-renail electrical gn power in this country and has a significant role in the ac-
- 3) counting methods usec. So we nave a deep involvement with h
I-1 g others in these two areas, and that does cistinctly af fect the c 13
> s enedule.
I 1 ~, , (Slide.) j3 So wnat we started out to do is to develop a body ; i 16 of technical reports. First of all, let me digress for :. moment..
)- u We published a plan, and there are copies of th1s l jg outside if you haven't alrgady read it, NUREG 0436, in March
); c: this year. We published the plan for re-evaluating this 20 p licy. It's got a lot of background information: Reg. Guide 1 73 1. E 6' , the Federal Register, anc all sorts of things like that.
l 1 i I e ,. a We have this plan on the street, and this plan ; l' : 3l explains that we're doing these technical studies. Each one
. of tnese is a major study.
DJ ecQfD) NtPOf ttri, l%
-c. Here is one richt here for a pressurized water D
l k
.f e
- m. ,-.+y- f.,a w y c. , -,-w=
44 1 i h I 1h reactor. It's a two-volume work which was published earlier ! n 2 t his year. e 34 What we're doing for each one of these facilities-- ; I 4 the pressurized water rea'ctor, the boiling water reactor, the i - l l 5 fuel reprocessing plant, a mixed oxide fabrication plant, low- ! tj ! 1 6 level burial, uranium mill, fuel fabrication of UF ~~ 6 1 7 the plan we laid out for. each one of those f acilities. We e !' Bg analyzed what are the different ways, what are the alternatives 9 il of decommissioning, what are the costs , what are the environ-1 10 4 mental impacts , radiation exposures, and so forth. 1 1 ', we felt that that broad range of technical studies t i
\
d ! 121 would cover all the potential problems. We also thought, as ; e.1 13 ' lonc as we have technical experts clecine into the "how," we s l l 14 . will ask them to study how to make it better, how to facilitate
!! the reactor decommissioning, how to facilitate fuel cycle ,
i 16 facility decommissioning.
'7 so this is the basic flow of information that we're 16 working with, these reports, all of which go into the public m
19 it record anc are circulated for comment. j 20 4 o We've already done the fuel reprocessing plant. f 21 ['i A summary of it is on the table outside. We've done the U . o . . 22 gpressurized water reactor study. A summary of that is outside, ; t 23 , also . The mixed oxide plant is here. We have been adding D to the facility as we go along, just tnis week. We have an w .cco n u nm.inc.n 25 , annotated bibliography for decommissioning of nuclear f acilities; o r ,,,,..n,, , , . . . , , - . . . , ,
1 45 J i
,e
' NUREG CR-U131. We have just published that and will be b
l. 2 0 circulating it. Thisgoesintoallthececommissioninghistory,f L n
" the source material, 3
i
,l Now, what do we do with that information? As I l 1
5 s aid, we had a Federal Register notice early this year and P 6 started a process whereby we would go on three critical areas 7 and start looking into financial assurance, radioactive residues 1 E: [ and ceneric applicability: are we getting enough facts to j 11 l ! gjil extrapolate from individual cases to ceneral oolicv? , l I g J We have started that work, and we recocnize that )
,, this whole thing, in order to come up with a policy statement g and a proposed rule, has to develop those two in a proper 33,. Environmental Impact Statement.
ja So we're going to have a product: a Draft Environ-33,, mental Impact Statement, a proposed policy and a proposed rule. p u ' We will go to our Commission with tnat and say, "
Dear Commission,
p; here is the rationale. Here is the policy here is the rule. ,
-g i Please adopt them."
(Slice.) ~
); In order to get tnere, we first got a bocy of F
20 State Workshops. These are the workshops we just held, and i n 21 this public meeting is an adjunct to those State Workshops. o' i e,, [i We are going to hold another set of State Workshops i g out nere. Wnat we're going to do in that one is, as soca as ! a our thoughts on the matter are jelling, that is, the NRC Staff L 64ews' Beporters, Inc, u is close enouch to the thine to say, "Here's how it looks to m e
~
46 l
'4 4 1
be coming out," we're going to come out with some Staff docu- ; i l 2 [ ments, just Staff explanations of how it appears to come out l
)
, I! for us; and we'll discuss those with the states again in order !
. l l
,dthat their advice can be f actored into this program. I 1
N 5j Our real objective is, when we get to this Environ- l H i 6 (I mental Impact Statement, we still have the public rulemaking 1
, process -- no question.
t The public forum is open, as it.always l
- l gg,is. But I'd like to insure that there is a much greater chance t U '
9 of consensus policy at that time, rather than have NRC hide i g in the closet somewhere , think in private, and then come out,
; "Here it is. We just came down from tne mountain. There are
,, ! five commandments on this tablet and five on tne other."
4- , This 33 ' w crksnop cycle is intended to do that. i 34 c In the State Workshops, we went through with them - ; j3 and again, I'm not trying to demean the public, but I just l 9 y repeat that I'm trying to do the same thing with you -- to get ,
;- views on jurisdiction; on residues, how clean is clean; on the t 16 nature of the data base, what we're doing, what kind of reports,'
1; snould we be doing better ones? I a. 20i; 'What we set up as the agenda is based on what's i 21 available at the time. For the first set of workshops in '
!i 22 L this meeting, we saii, "Look, there is the whole approach of D .
1 23 ' this plan," and we explainec what we 're doing and now we 're
;;,doing it. There are a set of questions that I will go over '
w.w.i ar.cnm. inc. 73 with you shortly, and there are the first major reports, the
, _ . . . _ , _ , _ . , -,-.--w- - ' -
k 47 , , l l 1 1 i; things we've already published. And we asxed, "Do you think ; j q t i I" we're doine the right thing?" t
?.
In the next round of workshops we will have a much 3l l t l l 4 j. greater body of technical reports, and we will .Tave the Staff i l l .
! l We wil] have a much more 5 , thoughts on the individual issues. !
I 6 ' p olarized discussion, I would expect, because at that time we ; 1 1
. 7 . will then be saying, "We think it should be done this way," i j 1
8}I and some other party may take an opposite view.
,1 l
1 9b (Slide.) 1 9 1C " So the states, anc you, can participate by taking 11 an active role in the meeting or in the worksnops and talking i 4 12habout the issues, u R ! 13 You can critique the technical reports. We have a ; i 14 v ery wide mailing list for these reports, anF all we ask is ! 15 g that any individual who wants to be on the mailing list to 16 , specifically request what you want. We're talking about such t 17c " an enormous printing cost that I'm a little bit cautious about ' IE over.doing it. We are printing thousands as it is. 19 o Those technical reports go out into the public li 20 d domain as soon as they're published, and we have a little fore-n it 21 [ word in the front of every one saying, "Please, if you will, p i I l J ' 22 ) comment on it. " i We give you an acdress for someone to send ; 23 the comments to. . 24 , 1 And anyone can participate in the process as we're
- o.2m2.' a mem,. inc. :. 1 I
25 !id oing it now without loss of perogative for participating in '
48
, i, 4
," the rulemaking itself, when the time comes.
1 2 I mignt add, the individual states then have a ! F I
,e separate consideration:
shoulo they change their statutes-- _r. L z expand them, contract them, in order to be compatible with
- l 3j whatever Federal policy on this matter comes out, j i 6 ! (Slide . )
1 7l So we get down to the questions. I'll try to explain [ E the, questions to you, and after I explain the questions and li ! 9 ,i later on this afternoon, I thought I would put them back up i g again and perhaps give you my personal impression of wnat the il , state people told us. I'll do that te whatever extent I can, : l g h:t let me caution you: We just held the State Workshops in i b l g the last two weeks of September. I was at every one of the j 3., ;. w o r k s h o p s . I floated from group to group, and I have a per- ,
,e
'c sonal perception of what I heard. I have Staff members who ! '
I g were in the groups that moved from group to group, also. We g I have written draft reports from each small group of state I 15' people, and we're trying to collate them all together, analyze ! g_ them anc share our' perceptions in order to have as objective an h e 20 analysis as we can. We will do the same thing with respect I g - to the puolic meeting today, and then we expect to come up with ; a > 22p h a revisi n or supplement to the plan document that says, "Here l i p r i
.p.gis the story so far; here is what happened at the. State Work-I I
74 ; shops; here.is what happened in the public meeting; here is r l h ,e.,s n ,w ne m inc. how the program has changed." But we want to do that with the ' 25 g I j t I j[ .
49 i! d
; views. of many of the Staff members invclved, so what I say
.' should be taken as my personal view because we haven't yet i I',
3 finished the Staff analysis.
, The first three questions, the first set of three, 3
are associated with this plan that I call the Plan, with a j ' 6 capital P, the approach for evaluating the policy. The ques- !
-q tion that basically goes'with the set is, is it a good plan? -
i L , Ik g Do tne states have a proper role? And I could rephrase that l 0 9 ;i question to say doer the public have a proper role in this? 10 ', Are tne technical reports adequate? Do tney cover the right sort of facilities, the right alternatives? Should we change j7l! the Plan? If so, how? b 73 [ The second set of three questions--and tnese things-c 1, cover issues that were covered in the cricinal Federal Recister c 13 l{ Notice-- should cetailed decommissioning plans be required ; u; prior to the issuance of a license? That's " plan" with a lower h
;- [ c ase "p." That's the plan to decommission Indian Point 1 or P
b
); some of these fuel cycle facilities. Is delay in cecommission-
~~
;r 19[ ing justified to save money or to recuce radiation exposure? ,
i 20 jWhen you get to the end of reactor life, certainly just letting ' h
;) eCthe plant sit there.in safe storage, the radioactivity is 0
22 h decaying quite dramatically in many respects. I One can save 23(a great deal of radiation exposure by waiting 10, 20, 30 years. 2 Typically, if cne is careful with the funds, waiting makes the A ..s .ee,. a m r*,s.inc. 1 25 ( thing cheaper if you handle your money intelligently. Is that L n 51 i
,--,v.. , ~ + , - , , , , , ,,.,w, , , . , ,,-n.-, - . . , . . . -
50 4
,<, justified?
t Is it appropriate to wait? And if so, how long? 2 Here's one that is a very difficult question for i
'i
,c us: is entombment, permanent entombment, an acceptable form t i.I J
," of decommissioning?
- And I don't refer nere to mill tailings .
s '
} l c d or low-level waste, to burial. Chose are by their very nature .
* :I 6
entombment. I'm referring here to taking reactor residues ) 1 7g or fuel cycle facility residues and, instead of removing the l i.: g[. radioactivity, just pouring the building full of concrete in l' f.:. 9q some way to make a tomb out of it. Is that an acceptable method g ' of decommissioning? 1
; ) ;. how, there are three questions here, 7, 8 and 9, J l 3x I that are associated with residues.
I have to admit I'm the I d p ,n autnor of these questions. Someone said to me that these ' i: l y , questions are either very gooc or very bad, and he wasn't sure o i g d which they were. l They are rather cryptic, anc for that I E a g apologize. g This one, should decommissioning criteria extend to y buildings, structures and components which are not contaminated, j; tnat is, snould we care amout the cooling tower or the reactor Y 20 0 building? The reactor' building is an absolutely enormous ! yl structure. It's typically steel lined. You could decontaninate b
..- !; one of those things, dig out a couple of the centaminated pipes, I
.a and then have a non-radioactive structure. And a wrecking ;
~
a- call could stand there for a century beating on that structure (3.;,e,,r n.mnen. inc.
-c i without knockinc it down. It's a formidable task to demclish p
I b h
.f
'i .
p 31 , bI 1i one.of tnose things. But snould I care about it? Should NRC d r 2 l Worry about it? Should NRC do something about it? That's I 3". what that question is addressing. ! 4 This is a tough one for us, cleanup criteria. Tnis l i 5 is radioactive or radiological cleanup criteria. Can the : I 6 Federal Government develop them with state advice so that 7 everyone can agree on them? l, B The Clean Air Act gets us in a position where at a l . 9 l nuclear facility there is a pipe, say, that has radioactive i 10 ll emissions . The. Federal Government sets a standard that says F 11 two filters have to go on that pipe. The state is clearly 12 authorized to come in with a more restrictive standard that i 13 says, "In our view, three filters should be on the pipe"; '
' f 14 }. therefore, the facility has to have a third filter. There is 1
i 15 {nopre-emptionthere. 16 i
! Now, adding a third filter as against only a first ,
I 4
- t. l l and a second isn 't going to change the whole thing that much.
17 '
, I I
16 l It's an incremental effect. But if you look at decommission-19 l ing in.an argument that might ensue about how clean is a soil l 20 or how clean must a soil be for unrestricted release, or a 21 concrete surface, you can make a dramatic change in your de-k 22 l commissioning policy. i , e 1 23 , If the residue on a concrete floor is good enough 243 h.secocai beorters Int n .. for the -Federal Government for unrestricted release but net 25 ' good enough for the state government, o the Federal Government. , o I u e
,--,y., - 5
- - - - .-w-- ,t , ---e,1- W t t v ' '- t
I
,, = ;
e 6" d; - 1
)(wouldlet you leave the building; the state government would j 4
i! 1 2 1l,l( make you dig it all up, so there is a great censitivity here f 1 R l i 1
,f to the states' richts cuestion of havine freedom to set more '
< t a , restrictive standards. This is particularly directed at states e
I for their opinion on can they, so to speak, join with the ) 1 1 6 Federal Government to-come up with a consensus standard, i
- l 7 This question speaks to a way to define an accept-j l ,
l How can you define how clean is clean? What e lableresidue. 9"4 we've suggested in these reports -- and you wi]1 see them l iti in there, and in the summaries, I believe, too -- a reasonable i e il1 way to do it is to say that when a facility has been cleaned : 1 i 12 l up enough for unrestricted release, you can say with some con- l !
, t 33 fidence that anyone who works there or lives there, or grows !
je 'his rutabagas there, or whatever, is exposed to a radiation
\ i le u i
risk no greater than some level which vou sav is arcuab1v i pt ut acceptable. i 17 In these reports we said somewhere in the range , i 1E i iof 1 millirem per year and 25 millirer per year whole body " L 19 lll radiation exposure is a dose rate that one could say is accept-I ; i : 20 i able under those circumstances, and that that could be a basis it f 7)Nforunrestrictedreleaseandthereforecleanupcriteriaifyou I 22 calculate carefully how many microcuries per square meter of I i 73jsurface or per gram of soil that that means. .
- a When I presented this question to the states, and w.rcoore noorwn, inc. a 2cjas I present it to you, I'..
asking about 1 millirem per year, d c g. 4
y- 53 t O
- o. .6 and I'm saying we think that's as low as it would ever go as i I
. ), a limit. We think it would be somewhere in the rance of 1 to
.i I ,
p , d 2P 25 millirem per year, and the only. exception to that we would t i ; 4 make is when you're discussing things like mill tailings, radium i I 5 and thorium residues in soils, this whole philosophy chances 6 and that's a totally different question. You're talking about 7 6 iffused background radioactivity and so forth, not what you g might call spot contamination -- buildings, structures, that 9 sort of thing. ; 10 (Slide.) 33 For those people who aren't familiar with radiation ; I 12 terminology of what 1 millirem per year is, if you take a scale i i, )3 of millirem per year with a typical population on the East ', 3 Coast, it's 100 or a little bit less than 100 dillirem per year pjjust from the natural sources, cosmic rays and things like that.; 1 i I g lIf you live out in the Colorado mountains, you get about twice t 1 l 37 lthat much. Depending on how much of a hypochondriac you are i i i
)g jor how sick you really are, medical exposures can easilv cet i l
W jg }jinto the hundreds of millirem oer vear. Some of us cet up in { 20 years and start getting more' serious medical problems and l i l ' I 21 iexaminations for them, and you-can go up into the thousands 2 ', lever nce in a while for very serious X-ray, things like that. l , 1 y gw i b.ir travel gives you -- well, on one flight you might get a ,i i'
- i, s.ir.illirem or so, and.if vou're a frecuent air traveller vou're 9
~ u.rme am,m. inc. y [orobablv in that range.
~q[
4 l: p h'I . i g m - n-es # , ..y.,....~i-m. ,,,s. -
54 i d i li i L 1 ,; This cives a sense of scale which gives you a per-f 2 d spective- for judging 1 millirem per year or 25 millirem 1 il e lI per vear as a' cleanup criteria would be added out to this sort i F { 4 4 of exposure. That's the basis of our saying we think that a i i s c r esidue risk in that range would be acceptable. l 6 (slide.) 7 The last batch of questions here, these are all E o financial questions: who should pay for decommissioning? 9 It's almost a truism. We think, and have actively said, it's t 1 10 ll' a cost of a nuclear facility; and however a cost for a nuclear 1 1 33 facility should be handled, this should be handled in an orderlyj 12 WEY-l 1 j3 l Should financial responsibility requi.rements -- i i i
,4
. lthis would be escrow bonds or sinkinc funds or anything like i 1
15 l'tha should that be imposed by state authorities or Federal i u .'authoriuies? And when? Tront end, later, halfway through? I 17 What sort of requirements? What t imin c, ? 3g This question here, bhould the whole price be set ~
); tEaside in advance, or is it reasonable to sav look at the person l 1
20 l or the agent or company; I'll use financial assurance to begin ! i 21 with, but I'll make them collect the money as they go along on )
! I 77 a time scale, so that I have a transfer of reliance fror financial l i
23hevaluation to the bonding or sinking fund or something like that.i t 2 >, l , If you do accumulate funds, who holds them?- The u.5,eorg n ecateri. is . [ 3 jl company? a The state? The Tederal Government? A third party? , lI b e s . P
55 t j
, And how can one deal with uncertainties in cost? l
.g .
1: 7[ There are several ways. In our estimates you will l i ! ,
,"[ see that they got finished with the estimate and said, "There's t I
,l l l
,i 25 percent contingency an'd 25 percent allowance for a lousy l l t
i 5, guess or what we didn't calculate." That's one way to'do it. l 6 Y u can make a 25 percent contingency on every cost estimate, l 1 7 , or mak~e'it 50 percent or whetever. Or you can take your~ j
} ._ .
gq collected money for individual decommissioning cases and go I e ll;j into some kind of pool arrangement or general fund, a Federal
'n af g fund or state fund, something like that: start setting aside j) money so that that general fund is there to take care of the
[
\
12 decommissioning job that costs too much or doesn't work out e L, ,because the company went bankrupt, or whatever. t. I i ! ja ; Of course, that again raises the question that if ; I
)
L,. F, you engage in something like that, would that be a state fund, l 1
, I g{aFederalfund,orwhocontrolsthat? i i I 17 i i
Well, with that I have completed what I have to say , I jg to you. I will take these questions down until later this c
.n i
)94I afternoon.
-l 20 ,
The floor is open for the next thirty minutes before ! a 1
.)0werecessferlunchifanyofyouwant to raise some general i
22 jguestionsnoworhaveanystatementsyouwishtomake. i i i : g lj Bob Newman. A
<a p
9 MR. NElfMAN : Bob Newman, Allied Chemical. w.Fpore, Reporters, Inc.19 y ', ' You indicate, and I think a. lot of people would
-o I
e , o N . f
h? g 56 i a l! i
- i
- (
' ' {
;[ agree, that one good question is, is enrombment acceptable?
e O I note that Battelle did not include this as an d. o
,U alternative in reprocessing plants.
Scanning the report on 4 : the power plants, which I am not familiar with -- I was looking ;I
' {
5 at the handouts, and it appears it was excluded there. 6 Does NRC plan on having a comparative study with l ,
/
the bases, assumptions, methodology and so forth to weigh all g i the~ economic and environmental costs of entomhment versus'the I l I
- c. n,l o thers?
t
;g['y MR. BE RNERO : Let me answer your question with an Io l
l 1 I
;) ' a mission tnat tnere is one, we think, prejudia; in our pro-12 cram here that we have admitted to oublicly. {
t i 13 j Coming into this thing, the people deeply involved ! i j i i j i __ i
;gi] in this, coth at Battelle and at NRC, formed an internal I
I 159 e pinion early on that entombment wasn't an intelligent way to - 3 si u I go, for a variety of reasons. i i 17 l We have been challenged by many parties; many of 16 ! the state people raised this point. Even before the state 1; i people did, we are reviewing this program periodically with' I 20 the NRC's Advisory Committee on Reacter Safeguards, and that , was an outstanding remark of theirs, that entombment'has to t 21 l l ee ! be considered. i , l I 23 ll Under NEPA it is an alternative. It is a viable --
. l' 24 n lI shouldn't say'" viable." It's an alternative that must be Am.Fecero! Elecorter s, In'_
25 considered, and it must be considered in the proper light. fi - a i; i
-( .
._. ., ,.., .-.- -~- - - ~ - - - ~ - - - --
57 i 0~ . Yes, we are, in cur modifications or additional l
) }l i l!
,, studies, we are adding to this program based on the advice we're
.y d
- , getting. We are covering entombment in a far more comprehen- ,'
i
~
.I sive way that we covered': e before.
t l I I 5 Si#' I 6 MR. MORGAN: .Rufus Morgan, Southern Company Services, 7 Atlanta. I g } This entombment I think some of us would be very l i, y !l 1 nterested in , those of us who have large reservations, 2,000 l i
)g ij acres or something like that. It mignt be highly different '
c l i) i f or some people in other utilities, which have plants in con- l s 1 gested metropolitan areas. 1 12 < l t
, 13 i.
. The other thing, I think you made the statement !
i l g ,'there were four alternatives and vou took exception to the last l 15 lone. That is mothballing, entombment, dismantling or conversion l i ;
.16 i to an electrical or non-nuclear plant. ;
i i j7 j In this 0436 I believe there is a different state- !
\
)3 ment that says the fourth option is a combination, and the !
i .. a studies wnich I've seen stress this. 19 It was discussed cuite a i i 20 b it in the State Workshops. ! l 21 t I was wondering if that reallv is what you might i 22 lconsicerthefourthalternative. 23 MR. BERNERO : Well, really the fourth alternative ' gayis a' complication about the alternative of what to do with
. w .o.,.is.wcwn. x.a 25 ii radioactive resicues .
ell 4 i e il .
SE n .f . L 0 :
) ,i You can, for instance, take an existing' nuclear ,
i:
~ .
i 2 g plant and convert it without decontamination. I think of the -l i i 3 [ Hanf ord N-reactor. It's an old reactor operating a very large l I i i I 4 steam plant, and at one time the Washington Public Power l {
! , t 5 Supply System was going to go right next-door to it and build .
i l . 6 a new' reactor.to provide heat for that big turbine system and ] 7 bhase out the old N-reactor. 1 1 g It's a complication of the issues. It's very real. 9 It's a very real alternative. The point I tried to make is
)gq when you're looking at decommissioning of nuclear f acilities , !
;;hultimatedeccmmissioningwouldcomplicatetheissue; it's not {
l 12 a solution in itself. It's a complication of the solution. l i 73j 1 All of the radioactive residues is either left there y or taken away, and that's why I tend to think that it is not
'l i 15 ' app: priate to rank four alternatives if one of them is moth- l g , balling temporarily; one is entombment, leaving the radio-o i
i I jactivi ;ere; one is dismantling and taking it away; and the
;7 1
;g ]four- .ersion, a very real physical situation but an O i
)g,ad" ive perplexity rather than a true decommissioninc ~
i 30 i i
,altt .
, i g i A. MORGAN: With. entombment you might have that I
,2 1 very thing.
i l' MR. BERNERO: Yes, indeed. uy i, You could entor.b the
. b ,
~
.t e 9 reactor and convert the turbine generator, which is an extremelv r
- A,.5.eco Repoems, enc :' y, valuable piece of equipment, depending on the life of it, the r . b t
..~y., , .E '
59 [ t e l 4 ! i e
; maintenance history and so ferth.
2 'l Any other questions? Yes, sir. l , j i i
.' MR. WOLKENHAUER: My name isL3ill Wolkenhauer, ,
*} l 4 Washington Public Power Supply System. ( '
l 3 Two related points , the sinking funds and conversion.l 6 We've been taking a look at decommissioning, trying to back 1 7 off and take a larger view of it. The preliminary view we're g tending towards is, because of other NRC regulations which 9 require us to build a plant a certain way, we're looking at j 4 jo ij f acilities , with the nuclear island , that have lifetimes which 1: l D 11 i are probably approaching large hydro units . It looks very l l 12 much to us that these units would be in actuality converted. l 1 j3 If you set uside a sinking fund to decommission I
},
y the plant, has the NRC thought through what to do with the l l' 15 l sinking fund in the situation where the plant is converted? ! i
, I s
16 l MR. BERKERO: We're wrestline with.that very issue, i 37 recause we have to consider a couple of questions in that one: l jg Would we set aside a sinking fund that in some way would dis- ! I r ,
); ipose of the turbine generator and its associated structures? t l
I i 20 We might or might not. If we ignore the turbine cenerator I i 21 l structure and say, "Look, that's a non-nuclear job, and it's l l l' "r l not our jurisdiction," we could confine ourselves then to the l 1
' nuclear island.
i l 74 We cre considering whether to treat the financial . . ca.non.' s,.ponm. ine ;; 2'Econtrol or financial collecticn for the nuclear island alene
..e l
O n '. H
.u
- , , , , . _ - , . ..r, - - - , , y
l 60 m b as one of the tactics. j , , i i 2 ll ' As far as extending that time, you have a third l , y I n 3 question that says it is questionable whether, if you're , V , 1 e going to collect money, a sinking fund, whether you should l achieve the full fund on the day you expect to decommission l 5 , c
\
6 l or substantially in advance of that day and therefore have , 7 lanassurancethatthemoneywillbeavailable. , i I j I g j. We're wrestling with all of this. We don't have , i 4 9 I any answer now. I i 10h I might, add, I didn't mention the names of the J i i
- 1) { facilities, but in order to do a decommissioning study of a I i
, i 12 facility we have a need to get into the facility and get all i i 4 i
13 i of the details. There are two reactors we studied. One of 1 j J l u ; them is the Washington Public power Supply's Hanford 2 reactor, ! j 1 1 15o j a large SWR, and the pressurized water reactor is the Trojan l f ' 16 Nuclear Plant that belongs to Portland General Electric. t i i 17 l MR. SCEENDEL: K. R. Schendel with Wyoming Mineral i, , 13 Corporation. e o ^ 19 I'm intrigued by the question of semantics. A:
)
20 what point does surrendering an NRC license or a state license l i
;j ! become decommissioning, and vice versa?
b, n . 22 l I'm particularly intrigued on this question of l
! i I
23 y conversion, because if you reach a point where you have rencved; o
. your radioactive items, surrendered your license and the Aa mer. pe:ene .inc.p
;5 ' facility goes into a conventional power operation, why is the 9
!i >
N,, i
,s .
. .- - . , . - . - . - . . . - . . =.
i I 61 L a I
. N?,C'even involved? '
.L a
l MR. BERNERO: The answer, Karl, I think, is we 4! u 3
-I j probably wouldn't be. !
4 There is a complexity in reactor licensing that i 5i many people aren't aware of or are familiar with, and that is l i 6 a Part 50, 10 CFR 50, license for a reactor is a very grave 7 and complex thing, and it is full of requirements that are t g- appropriate to the operation of a reactor: how many people are 9i on the staf f, how many guards, and all sorts of thine,s like je4 that.
- 3) When a reactor is partially decommissioned -- that is , you remove its ability to be a reactor, to generate power--
i 12 I a , I j3l it doesn't have a core anymore; it doesn't have a lot of thines i ' ll , ja [ that go with a reactor. There is a frecuent licensing procedure , H i
)
\
j3 1i used to change it to a possession only license, so the owner ; 1 I 16 i is not authorized to operate a reactor anymore anc we aren't !
.i i
( 17 p' looking at all the operational aspects. The company is ! i
, authorized only to own the radioactive residue and hold it in jg t i
w 19 , safe storage. i t I a 1 20 l It's very similar to a material license. A Part 70, I 21 l10 CFR 70, or 10 CFR 30'or 10 CFR 40 license is really a . F 3el license to possess and use-radioactive material. a c When one coes 40,i !. t> a reactor possession only license, it's still licensed and 74 , it's. licensed because there is a.potentially harmful residue ' w.5.ec.;nwonvi,b.L 73 i there. As long as that residue is there, some sort of license i l i b I h . .
t '. 62 1 e I: i i 1
; is required, even if you convert to a state license, 1
i I
- (!
.i-;) The C4 reactor at Fayetteville, Arkansas, which ii i I
N 3 was an experimental reactor, was decommissioned properly and t- l l 1 4 . went from a reactor license to a state material license. The ; 1 5 State of Arkansas now holds the license because there is t 1 6 still residue there. Once the residue would be removed, then l 1 1 7 there is no need for a radioactive material license of any ; i B ikind. -l i rI I 9 Indeed, if you have a turbine generator that was 10 !j good for 200 years and the reactor was long gone and all of e
.,. its residue cleaned up, there certainly wouldn ' t be an NRC l
12 license on that turbine generator. I I l a-i MR. BANCROFT: My name is Michael Lancroft, for 1 i ; I 3g ; Public Citizen. I have two questions. I l .e I i I'd like to know what the state of development of - i i 16 this underwater cutting technology is for the larger power I 37jreactors that you're talking about, how firm this technology i . 15 l2xists to estimate the cost that you made in the report. 19 The second one is, in estimating the costs and the {. ; 20 loccupationalexposures, have you taken account of the possi-
- 7) ,
bility of reducing the occupational exposure to perhaps a half I 22 of a rem per year?. 23 MR. EERNERO: Dick, could you please answer the >
\
- } questions? '
* = .smer.r amenm. inc. ij '
;g j.
n These questions, of course, go right to the PWx , i !. ~ !: 0 d 4 '
i 3 63 4
! 1 1
$ estimate.
-Dick Smith from Eattelle Northwest Lab. .
2 MR. SMITH: The technique we assumed for the dis- l e - of PWRs assumed cutting the pressure vessel in air, l 3-l l m act? ement 4 using conventional oxyacetylene techniques. The highly j
, 1 I
5 activated stainless internal components were assumed with the j 1 6 p lasma torch underwater. The techniques are presently avail-
, able for that for the thicknesses involved.
7 i g We did not treat your last question at all, the I i 9 i impact of reducing ti.e annual exposure. l t 4 39 ] MR. STOUKY: Jon Stouky. n 11 i A couple of things. I'c like to havet. summarized the : 1 12 results of the state meeting, what you felt came out of it.
. 13 The second thing is with regard to refurbishment. Unless I'm !
;g != 1ssing a point, the possibility of refurbishing a plant as i
)c a PWR, or perhaps as a BWR, is a realistic possibility. j 16 l If y u look at a power plant today, you look at it i, t 17 lattheendofitslife.
A nuclear power plant is theoretically 1 i i
)g 'so well maintained that it ought to have some active, ongoing f* ~
g life with some plant refurbishment program. 20 MR. BERNERO: Let me deal with the first question -- i i
- 7) .1the second question first.
42 i This did come up in State Workshops. Perhaps the 2 l i ,
,,obest example of the refurbishment question is a fairly recent
~F !
74jannouncement by the Commonwealth Edison Company of Chicago
- sw.s,en neemn. sne. h
,e
.. recardine Dresden 1.
$1 4
e li 1, .
64 l c i y 1 0 1 I! Dresden 1 was licensed in 1959 or~1960, I think, so , j l . .1
, e 4 3 hit',salmost 20 years old.
It's one of the earlier large }
~y (
,! reactors. It's only 200 megawatts electric. It's not even ,
.l ,
4 the same des.ign type as the cur:ent generation or recent 6 i 5 generation of BWRs. ' 6 But Commonwealth Edison announced perhaps 6 months 7 ago, or 4 months ago, that considering all the factors -- B cost to overhaul, cost to upgrade it to meet ratcheting safety l l l 9 j Isquirements of the NRC, and cecontamination necause it was it jehoneoftheplantswithalotofcrudbuilt up and radiation s ij exposure difficulties -- that addinc it all up, it's cheaper 1 l
- I 12 to refurbish it than it is to go out and buy 200 megawatts i
i 1 13 e lectric because any kind of power generation today is so ' jg expensive. ' I s 15 Well, refurbishment of a plant is a very real ; 16 option, but it really is not directly related to decommission- l
! i I 17 ling, i
g f For instance, if the plant gets to the end of the I j9 nominal 4 0-year life -- for those of you who don 't know, the , I i 20 I 40 years is a nominal' licensing period which NRC uses to ' i o . 21 H license the. reactor for 40 years from the date of construction i 22 l permit , not .4 0 years of operation. It 's 4 0 years minus the j l t I
, 23 number of years it took 'them to build the plant, so let's say 1
24 [ it 's 35 years of operation. If you reach the end of 35 years ' e.smo n.oonn inc. b 73,;or so and have a plant with a license about to expire, the L ll e
'U. .
65 1 .
- ! 1 0
1 . j merits of the case are such that the owners may conclude it's , 9,- < not worth refurbishing or it is worth refurbishing. Part of ; 2 h 1 J 3 3 that consideration is the safety aspect: would it be extended ,
, .i i 1 4
in license for 10 years or 20 years or something? j ! It is of significance to decommissioning insofar as 5 t i ! 6 l we must be conscious of any change in decommissioning tech- l _ nology that might be associated with a 52-year old reactor as <
/ !
g
.against a 32-year old reactor as to greater radioactivation
- 1 e il of the core barrel or ureater deoosits someplace or another.
e! l
)g lj Refurbishing as such, of course, is an operational l factor.
,' I i!' .
l i y If I could speak to the State Workshops, this ! ) glafternoonIwillputthosequestionsbackupandtrytogive ; s y 1 you a highlight of what I thought the advice we got was. , , b' t 15 ] In general, the state workshops were extremely use-I 161 ful f r us and for the state people involved. i We had about I l g,j fifty participants in each workshop, state officials of one o 4 g[ sort or another who actively participated. h g i I've heard from many of them, both there and since, 7g and they all, it seems to me, emphasized great satisfaction f u
, O to have the opportunity to get in early and start this thing
.1 3 l
, off together. We have found it very constructive to have those >
.e I i >
I
. 6 views . It enables us to go into a more efficient process. i
. >h 4 i
,L a, g Open development of Environmental Impact State.ents '
w eimiamom. inc. ;.
.e .'is what we're doing here..
We're also doing it in other areas, H .
7 66 i h . 1 i 1
)nL where instead of KRC Staff and some contractors doinc-it in .
s I 1 i 2 - private, so to speak, and then publishing it, we go through a n j 4 i 3 more structured involvement of the public or the states, j i i g It's a good thing. It's a difficult thing. It's j 2 5 expensive; it drags schedules out, but it's a very good thing. l l I I l 6 I In general, I'd say the state people said that we are doing 7 the right thing, and they gave us specific advice about do i B L this different and do that different, but not the whole thing. i 9 There was a question over here. ; 10y MR. NEIL: I'm Bob Neil from Virginia Electric
;) p a nd Power Company. j l
l 12 We have done some preoperational radiological ;
)
l j3 monitoring at our North Anna Power Station, and we have found 1 j { { I l,, that-a detector next to ordinary concrete receives a radiation j l I ' j3 1 dose which amounts to about 20 millirem per year greater than ( 16 l the average background adiation.
- i l
17 l With '.his in mind , how can a utility be reasonably l 18 i l required to get this dose down to 1 millirem per year, or even jp ' 25? l 20 i MR. BERNERO: We're certainly aware of the radio-t l 21 l activity f concrete, brick, wallboard and everything else 32 1 r in our werld where we live.
! i 23?jll In selecting a c.riterion, we, of course, are tr.vinc.
i 24 g to get an assigned risk, that is, 1 millirem per year er 25 'w.ew. numms. ene. !! 3 jmillirem per year, is that exposure ascribable to the e f! e u , u 4 f
I
, 67 i l j ,it radioactive residue from the facility, not the total exposure. [
-j Given that we do know that you've got the concrete l
t i 2 there already giving you that amount of radioactivity, we have ; i : 4 to be conscious of the technology necessary to even measure 5, whether you're that clean. I 1 1 6 Y u really don't measure these things with a meter, 7 walking around reading micro-R per hour. You're dealing'with g a technique of using filter paper to pick up radioactivity, 9 and you identify the key radioactivity that came from a yg facility. 11 l Yes incacd, it is a very real problem to get it ( l 17 down to background level so you're dealing with radiation ' 13 exposures that are very close to or below the level of the i i! i gg[ natural background. It's very difficult to detect. .l 1 l ~ 33 But the very reason we want to be there is to be 16 lable to say that what is left is trivial, is negligible. We i 37 l can release that and make a tomato patch out of it or whatever, i e i jg 'That's the whole point. You have to get down low enouc,h to '
- o. i 39ybe negligible and yet have a high enough number that you can li 20 ,l prove or measure. i o
- 7) d i One could argue that at .00001 millirem per year 22 lit would be a foolish endeavor; you'd never be able to prove it.;
O 73 d So that's a very gooc point. It's a difficult thine, t! o 24 h and we 're aware of it.
%.r., rs.conm inc..:
73 .'R. FZYNOLDS: I have a statement that I'd like to
'l
'l f
d.
i 66 3 I 4 read, either now cr later tocay. 2 MR. BERNERO: We have about ten minutes cefore we j 0 i o i 7 i , b reak for lunch, so vou could do it richt now, it you wish. l 1 I b 8 xxx 4y STATEMENT OF NICHOLAS S. REYNOLDS, ESO., DEBEVOISE ! u
'P AND LIBERMAN, WASHINGTON, D. C., ON BEHALF OF 5d 15 -
u SEVERAL POWER REACTOR LICENSEES. 6' 7 MR. REYNOLDS: My name is Nicholas Reynolds. I'm i g ,an attorney in Washington with the law firm of Debevoise and I i 9 Liberman. I'm here today representing several power reactor i g; licensees. , 11 p For the Reporter's benefit, I have copies of this I 12 state ment which I will present, i 73 I will elimintte the introductory comment and just I ;
;gd ao to the comments which are directec to the cuestions, or i 4
h i
! least some of the questions , that you presented.
13 >! a t8 i i i p- With respect to the question related to whether i I l 37 i cetailed cecommissioning plans should be required prior to { t i
)g ' licensing ur position is as follows:
;; j Detailed technical decommissioning plans should not l'i !
20llbe required prior to the issuing of licenses to construct and j i 4 21
- operate nuclear power reactors. It would serve no useful
.2 i purpose to propose to require an applicant to commit to a specific l i
'Li technical decommissioning method 30 or 40 years prior to actual j y
. - t ga[ decommissioning.
ac .c.ec.' n eoonm. inc. L 3.e ,. Reactor and decommissioning technology continues to , 1-e tf 4
- - - . - =
i 69 i j
. i,
; develop today and will~ most certainly continue to evcive for
~
many years to come. Any requirement that an applicant select k 9
' 1 3 a detailed method of decommissioning prior to licensing, or j i
- 4 I
even after licensing, would be premature and would introduce !j 5 unnecessary and unwarranted rigidity to the process. 6 This is not intended to suggest, however, that some 7 description of a general decommissioning approach prior to
! i 3j.licensingisnot appropriate. As a practical matter, present 0
i 9 L; NRC reculations and cuides require applicants to describe their , o t jo financial qualifications to decommission and plans and policies ; 4
.l[
i regarding decommissioning activities. S.oeakin c. verv soecificallv, e
;7 , 10 CFR 50.33 (f) and Appendix C of Part 50, and Regulatory Guide ;l '
! i 4
I h 4.2,H Revision 2, Section 5.8. I I 1 h
- i jg l Information is presently required on long-term land I I l 15 uses, irretrievable commitments of land, environmental conse-l li 4 l 16 h quences of decommissioning and an estimate of decommissioning j I 17 costs. However, the NRC'does recognize in Regulatory Guide 4.2 t I
I g jthat these decommissioning " plans and intentions of applicants l
-~ 1
- 19 ilfor construction permits may not be fully developed at the I !
20 l time of filing." f u a i i s i 0 l The information orovicec bv anolicants in their i I 22 lenvironmentalreportspursuanttoSection5.8ofReculatorv
' i I
23 j Guide 4.2 is suf ficient to permit the NRC to evaluate the r 2; ; general environmental consequences of power reactor decc=missioni w 5mem neoonm. w. ! 25 ing. Likewise, this information, together with the information I I i
. ),
4 i
'O h ,
i
)
i____1_____________ _ __
70 t, b 50 relating to financial qualifications, is l 1pl required by Part i n l a also adequate to permit the NRC to evaluate the financial quali i i 1 yf 'fications of an applicant to decommission a power reactor. ; I A general cost estimate of decommissioning can be ; l d derived from the information so provided, which can then be l l 8 5 J -. evaluated against the financial qualifications information. 6 Thus, the existing regulatory treatment of decommissioning at ;
/ ,
6
!.theinitiallicensingstageis,webelieve, adequate.
i l
- With respect to whether NRC decommissioning criteria 9
t
! should extend to uncontaminated structures , we have the follow-10l:
33 Lng comments . g Upon cessation of power operation, buildings, struc-g tures and components which were not part of a nuclear facility im chief or which are not significantly contaminated cease to , g j g have a bearing on, and hence cease to have a nexus to, the ! l ; g; NRC's licensing responsibility, inclucing its environmental I l I i g l responsibility under NEPA. I i This view is consistent with the increasingly recog I g l' 1
"~
nized need (and Administration policyi to avoid unnecessary 39 l I 40
! duplication between state or local and Federal requirements.
i I 1 i Accordingly, where state or local authorities exercise control g lI g lovernon-nuclearoruncontaminatedportionsofpowerreactor i j facilities, the NRC should not intrude and overlav its re-- 23 h l
!I local 3 q quirements on local plans and local decisions te meet Ace.Seocroi Reporters, Inc. a ,
30 h
' neecs. .
i L i h U .
m is a i L i 1 I On the question of the 1 milliren per year dose rate, l I : 1 i t we have the following comments. I
' t !
3 As noted in NUREG-0436, the preferred approach to l l , 4 establishing acceptance criteria for release of a site for i ( I 3 unrestricted use may be to reach decisions as to the extent. I of. decontamination necessary on a site-specific basis. A l l 7 balancing of the radiological impact of residual contamination in light of background radiation against the commitment of ' 9 ,i resources and environmental impact associated with removing g that contamination may be tne pre:errec approach. h
)) However, if the NRC determines that uniform, rigid '
acceptance criteria for all decommissioned facilities are 13 ,necessary, then such criteria should be both verifiable and i i l ' g - o reasonable. t g To be verifiable, the criteria selected should ob- l i t g viously-be capable of' measurement within the statistical range ! r I g jof accuracy of detection equipment. It is highly improbable i 1E ! that a dose rate of 1 millirem per year above background is i 19 serifiable. l I i t 20 l To be reasonable, the benefits of contamination 1 21 removal to meet the criteria should not be sienificantiv out-
~ ~
tw 22 l eighed by the resources expended. Since it is virtually in- I l l 23 yfpossible to verify a reading of 1 millirem per year above ' b 24 1 'backcrocnd within the statistical accu ra cy of even the mest i w.omi nemnm. I sensitive field detection equipment, it appears that the proposed: b n I!
- 11 . .
g 72 .
, I r
1 criterion is unreasonacle. - t
,0 Nho should pay for the cost of decommissioning?
6 l We. attended the State Worksnops, anc we cerived the sense of j
; i ,
a those workshops to be that, for power reactor facilities at i 5 least, the cost of decommissioning should be borne by the l I i 6 consumers of the energy produced by the nuclear facilities. 7 We agree in general with this conclusion, with the i g j. clarification that whether power reacter licensees market i c }dl nuclear generated energy at retail or at wholesale, the pur-
'. t chasers of the energy should pay the allocated costs of de-m jj commissioning.
i I 12 In any event, the task of approving the means of I I g i d ecommissioninc cost recovery resides in the appropriate state j I, r jj l utility rate commissions or the Federal Energy Regulatory l i : 15i, { Commission.
! Regulation of decommissioning cost recovery by
'l y the individual states or FER. in rate proceedings for a spe- j j7 cific facility permits this evaluation to be conducted on a i
15 case-by-case basis, i n- ,
>_ D .
jg Addressing now the question of whether or not ;
!! l 20 h advance funding should be required: l 21 With respect to regulated power reactor licensees, l 22 ldecommissioningfundinggenerallyshouldbeaccumulatedover i
3jjthelifeofthefacilitiesandnot be required in advance. i 1 We submit that the NRC lacks the authority to require its AwJerot Rnorwet. 24 )i iN; h ' 73 ] licensees to comply with an advance funding or suretv arrangement I 1~ t; 1 n , i 9 1
-73 n .
1 l , y u > 1 ( to finance decommissioning costs. l ( q i
'As to such' licensees, whether decommissioning funds ;
i I
,g
-o should be accumulated in advance or over the life of the 4
facility is an issue properly addressed by the state utility ' 5 rate commissions or the FERC. This state and FERC jurisdictioni is specifically preserved in the Atomic Energy Act, 42 U.S.C. 3 Sections 201E and 2019. In fact, several states and FERC have 8
} issued or are in the process of issuing decisions on the I
,j guestion of decommissioning f anding. We cite, for example,
'h 1m a 3 there the state proceedinos in Arkansas on Arkansas Nuclear One ,:
9
)) in Pennsylvania on Three Mile Island One, and in New Jersey ,
i g on Oyster Creek. We also cite the Carolina Power and Light case at the FERC , and I believe either last week or early this l i
), j week FERC issued a decision in the Connecticut Light and l l i.
l, j Power case for Millstone and in that decision addressed the l i . I g necative net salvace cuestion of decommissioning cost 1 17 I- recovery. i g ; Finally, we have a comment to make on the scope 39 of the NRC evaluation of decommissioning specifically relating { l to the tax implications of decommissioning cost recovery, j 20 i ! g The tax implications of decommissioning cost re- 1 l ! g covery in advance of incurring the expense should be evaluated in the NRC overall decommissioning policy re-evaluation. Power, 23 , 24 4 reactor licensees which'are now recovering decommissioning ' e- ' Au FCoe<a1 Reconerst inc.d
.25 ;i costs in their rates either as a cost of removal compcnent of
' il i '
1 a W p yr 9 -'Wv -%evy4 F'--m4 Ty W-y T" - = -Due p pS-w- f
.~ . . .. . _
n 74 i ,
- 1 ;
W : 11
,b
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the net salvage or-as a separate decommissioning expense gene- i ! F 2 d rally are taking 'the position that decommissioning is a de- l' 3 b I 3 P ductible expense for tax purposes. Whether decommissioning i i i 3 costs are accrued as negative net salvage or as a separate l 5 expense, it would seem logical that these accruals be tax-i 6 deductible, recognizing that the taxpayer is on the accrual 7 system and provision is being made for a known liability, even g though the costs of decommissioning must be estimated, i 9 However, technical considerations of tax law may c jg]leadtoadifferent result. In Revenue Ruling 75-150, the , 11 Internal Revenue Service has taken the position that estimated 12 removal costs in excess of estimated salvage value may not be j3 deducted as depreciation. l ' i
)g So.far as we are aware, the IRS has not yet dealt l; explicitly 15 with the tax consequences of decommissioning cost I i 16 l' r ecovery, whet her accrued under net salvage or as a separate '
i i : 17 l expense. In view of the uncertainties, we believe the tax l jg implications of decommissioning cost recovery should be ex- ;
~~
19 plored by the NRC. l i 20 I would appreciate if this document would be in- j. I 21 corporated into the transcript, because there is a lot more f ! t i 1 22 than I have read. l i 23l MR. BERNERO: Yes, we'd be happy to do that. l'
~
24 g MR. REYNOLDS: Thank you. , AnFxe*oi newnm, Inc. ll y 3 j: (The complete statement follows.) ! 6 1
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.A* OPPIC ES OF j D EB EVOISE & LIB ERMAN 1 1
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1 l October 18, 1978 l l Decommissioning Criteria for Nuclear Facilities 1 1 l l The Nuclear Regulatory Commission has requested public participation on the important matter of nuclear reactor decommissioning, and is conducting this public meeting on October 18, 1978, "to ensure-that adequate channels for public participation are available at an early time in the NRC decisionmaking process regarding deco:mnissioning policy." 43 Fed. Reg. 38025 (August 25, 1978). We appreciate the oppo.-tunity to provide a summary of the views of several nuclear power reactor licensees * / on _ certain aspects of decommissioning. i T. h.Mn<OUND The NRC conducted three regional workshops in late l September 1978 to obtain the views of the States on several
. aspects of decommissioning. Those workshops, and this public meeting, are part of a larger effort by the NRC to reevaluate its policy regarding a regulatory approach to de' commissioning.
The NRC has formulated a detailed plan to conduct its reevaluation which calls for the preparation of comprehensive reports on the technical and cos aspects i
/ Arkansas Power & Light Company, Dallas Power & Light Company, Jersey Central Power & Light Company, )
Metropolitan Edison Company, Pacific Gas & Electric i Company, Pennsylvania Electric Company, Southern ; California Edison Company, Texas Electric Service ! Company, Texas Power & Light Company, Texas Utilities I Generating Company, Virginia Electric & Power Company and Yankee Atomic Electric Company. . 1 l 1 l 1 1 1 1
~.-. . ,+ . ,- . - -
of light water power reactor (PWR and BWR) deccmmission-ing and on design improvements to facilitate economic decommissioning. The three principle issues being addressed by the NRC in this reevaluation are the levels of accepta-bility of radioactive residues, financial assurance, and the generic applicability of decommissioning analysis considering the various facility designs and possible circumstances. These issues are the subject of ongoing NRC review, and interim reports are scheduled to be issued by the NRC on these issues in May of 1979. The State workshops scheduled for the summer of 1979 will focus on 'the preliminary ~ evaluation and tentative conclu-sions in these interim reports. The subjects of discussion at the state workshops last month and at this public meeting are the NRC overall decommissioning plan (NUREG-0436) and NRC decommissioning reports on a reference pressurized water reacter (NUREG/ CR-0130) and a reference nuclear fuel reprocessing plant (NUREG-0 2 7 8 ) . In addition, the NRC requestep the views of the States on other issues, including jurisdictional matters and the related question of financial assurance. We understand that the format of this public meeting also contemplates consideration of these other issues by interested members of the public. Accordingly, we address below several of the more significant questions addressed by the States in the September workshops. In addition, we have attached hereto as Attachment A and incorporate herein the comments we filed with the NRC on July 15, 1978, in response to an earlier NRC solicitation of comments on decommissioning. II. SPECIFIC COMMENTS A. Adequa f nf PWR Report (NIJREG/CR- 013 0 ) . The decc=missioning report on a reference pressurized water reactor (NUREG/CR-0130) is deficient in that it does not evalu:+c permanent entombment as a viable decc=missioning alternative. The NRC Advisory Committee on Reactor Safe-guards has noted this deficiency, and has requested that the NRC Staff supplement the PWR report with an analysis of permanent entombment. We understand that the NRC Staff has acted to supplement the PWR report in this regard, and to assure that the forthecming report on a reference boiling water reactor iso includes an analysis of permanent
J entombment. The supplement to the PWR report (and the forthcoming BWR report) should evaluate all aspects of permanent entombment, including removal of certain long-lived radionuclides to an approved high-level waste storage facility and the subsequent permanent entombment of rela-tively short-lived radionuclides on site. B. Detailed Decommissioninc Plans Not Necessarv. Detailed tecnnical decommissioning plans shoulc not be required prior to issuances of' licenses to construct and operate nuclear power reactors. It would serve no aseful purpose to require an applicant to commit to.a specific technical decommissioning method 30 or 40 years prior to actual decommissioning. Reactor and decommissioning technology continues to evolve today, and will most certainly continue to evolve for many years to come. Any requirement that an applicant select a detailed method of decommissioning _ prior to licensing (or even af ter licensing) would be-premature and would introduce unnecessary and unwarranted rigidity into the process. This is not intended to suggest, however, that some description of a general decommissioning approach prior to licensing is not appropriate. As a practical matter, present NRC regulations and guides (10 CFR 550. 33 (f) and Part 50, Appendix C; Regulatory Guide 4.2 (Revision 2), 55.8) require applicants to describe their financial qualifications to deccmmission and plans and policies regarding decu~aissioning activities. Infommation is required on long-term land uses, irretrievable commitments of land, environmenta] consequences of decommissioning and an estimate of decommissioning costs. However, the NRC recognices in Regulatory Guide 4.2 that these decommission-ing " plans and intentions of applicants for construction permits may net be fullv develcoed at the time o# 'd'd nc."
)
The information provided.by applicants in their environmental reports pursuant to Section 5.8 of Regulatory Guide 4.2 is sufficient to permit the NRC to evaluate the general environmental consequences of power reactor decom-missioning. Likewise, this information (together with the information required by Part 50 relating to financial qualifications) is also adequate to permit the NRC to , evaluate the financial qualifications of an applicant to I decommission a power reactor. A general cost estimate of decommissioning can be derived from the information so provided, which can then be evaluated against the financial qualifications information. Thus, existing regulatory l treatment of decommissioning at the initial licensing stage is adecuate. I I l l i i
4_ l 1 1 C. NRC Decommissioning' Criteria Should Not Extend l To Uncontaminated Structures. Upon cessation of power i opera:1on, ouildings, structures and components which were not part of a nuclear facility in chief or which are not significantly contaminated cease to have a
, bearing on, and hence-cease to have a nexus to, the NRC's licensing responsibility, including its environmental responsibility under NEPA. This view is consistent with the increasingly recognized need (and Administration i policy) to avoid unnecessary duplication between State l (or local) and Federal requirements. Accordingly, at least where State (or local) authorities exercise control over non-nuclear or uncontaminated portions of power reactor facilities, the NRC should not intrude and overlay i its requirements on local plans and local decisions to meet local needs.
D. One Mrem /vr Dose. Rate Is Unreasonably Low. As , noted in NURIG-04f6, the preferrec approacn to establish- ' ing acceptance criteria for release of a site for unrestricted use may be to reach decisions as to the extent cf decon-tamination necessary on a site-specific basis. A balancing of the radiological impact of residual contamination in light of background radiation against the commitment of resources and environmental impact associated with ramoving that contamination may be the preferr.ed approach. l nowever, if it is determined that uniform, rigid acceptance criteria for all decommissioned facilities are necessary, then such criteria should be both verifiable and reasonable. To be verifiable, the criteria selected should obviously be capable of measurement within the 1 statistical range of accuracy of detection equipment. It is highly i= probable that a dose rate of 1 mrem /yr above l l background is verifiable. To be reasonable, the benefits I of contamination removal to meet the criteria should not ! be significantly outweighed b? the resources expended. Since it is virtuall.y im.possible to verifv. a reading of , 1 mrem /yr above background within the statistical accuracy of even the most sensitive field detection equipment, it appears that the proposed criterion is unreasonable. Comparing the proposed standard (1 mrem /yr) to the unrestricted area criteria for operating nuclear power plants (500 mrem /yr (10 CFR $20.105 (a) ) and 25 mrem /yr from discharges (40 CFR 519 0.10 (a) ) also appears to confirm the unreasonableness of the proposed standard. While we do not suggest that 4 -w m m, w w
cperating plant criteria should be imposed for decommis-sioned' plants, the wide variation between them and the proposedLstandard dictates the need for a close appraisal of the proposed standard, and suggests that a higher standard is appropriate. E. Consumers Should Fay For Decommissioning. The sense of the State workshops conducted by the NRC in September was that for power reactor facilities, the costs of decommissioning should be borne.by the consumers ; of the' energy produced by the~ nuclear-facilities. We t agree in general with this conclusion, with the clarifica . tion that whether power reactor licensees market nuclear generated energy at retail and at wholesale , the purchasers , of.that energy should pay the allocated costs of decom-missioning. In any event, the task of approving the means of decommissioning cost recovery resides in the appropriate State utility rate commissions or uhe Federal Energy Regulatory Commission. Regulation-of decc= mission-ing cost recovery by the individual States or FIRC in rate proceedings for a specific facility permits this evaluation to be conducted on a case-by-case basis. F. Advance Funding Is Not Appropriate. With respect
- regulated power reactor licensees, decommissioning funding generally should be accumulated over the life of the facilities, and not be required in advance. We submit '
i that the NRC lacks the authority to require its licensees to comply with an advance funding or surety arrangement to finance decommissioning costs (see Attachment A). As to such licensces, whether decommissioning funds should be accumulated in advance or over the life of the facility is an issue properly addressed by the State utility rate commissions or the FERC. This State and FERC jurisdiction is preserved in the Atomic Energy Act, 42 U.S.C. 552018, 2019. In fact, several states and FERC have issued o'r are in the process od issui.ng decisions on the question of deco =missioning funding. E.g., Arkansas Power & Light , Co. (Arkansas Nuclear One); Pennsylvania Electric Company ' 1 (Three Mile-Island One); Jersey Central Power & Lign: Co. (Oyster Creek); Carolina Power & Light Co.; FERC Docket No. ER 76-495; (see Attachment A). G. Tax Imo. lications Of De_cc.nmissioninc. Cost Recoverv.- The tax implications of decommissioning cost recovery in ' l advance of incurring the expense should be evaluated in ; 1 l' t
, n. 3 m e .,
the.NRC overall cecommission2.ng policy reevaluation. Power reactor licensees whi'ch are now recovering decommissioning costs in their rates either as a cost of removal component of net salvage or as a' separate decommissioning expense generally are taking the~ position that decommissioning is a deductible expense for tax purposes. Whether decommis-i sioning costs are accrued as negative net salvage or as a separate expense , it would seem logical that these accruals be tax-deductible, recognizing that the taxpayer is on the accrual system and provision is being made for a known liability (even though the costs of decommissioning must be estimated). However, technical considerations of tax law may lead'to a diiferent result. In Revenue Ruling 75-150, the Internal Revenue Service has taken the position that estimated removal costs in excess of estimated salvage value may not be deducted as depreciation. So far as we are aware, the IRS has not yet dealt explicitly with the tax consequences of decommissioning cos: recovery, whether accrued under net salvage or as a separate-expense. In view of the uncertainties, the tax implications of decom-missioning cost recovery should be explored by the KRC.
Law creiers or i D ES EVolS E 62 LI B E R M AN - PCC SMCQChow DVILDING 8 0 6 e s t= S T a c rt, N . w, WAS HI N GTC N, C. C. 2 0C C S TELt *"C N C l2C2) 3 9 3 2 0 0 0 July 15, 1978 i l Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory - Commission Washington, D.C. 20555 Attention: Docketing and Service Branch ! 1 Re: Decommissioning Criteria f or Nuclear Facilities Advance Notice of Proposed Rulemaking (43 Fed. Reg. 10370 (March 13, 1978))
Dear Mr. Chilk:
I. BACKGROUND On March 13, 1978, the Nuclear Regulacory Commmission published in the Federal Register an advance notice that it is considering the initiation of a rulemaking proceeding to establish decommissioning cr.iteria f or nuclear f acilities (43 Fed. Reg. 10370). In thar notice, the NRC solicited advice and recommendations on the matter of overall decom- l missioning policy development, and requested responses to six 1 specific questions. Subsequently, the NRC extended the deadline f or the submission of advice and recommendations to July is, ' 1976 (43 Fed. Reg. 19053 (May 3, 1978)). l On behalf of Arkansas Power & Ligh t Company , Dallas Power I
& Light Company, Jersey Central Power & Light Company, '
Metropolitan' Edison Company, Pacific Gas & Electr ic Company , Pennsylvania Electric Company, Southern Calif ornia Edison Company, Texas Electric Service Company, Texas Power & Light Company, Texas Utilities Generating Company, Virginia Electric & Power Company and Yankee Atomic Electric Company, we respectfully submit the f ollowing responses to the six specific questions in the notice and comments on overall decommissioning policy development. All members of this Utility
. Decommissioning Group are NRC licensees which are constructing and/or operating nuclear power reactors. Accordingly, this Grcup is interested in, and its comments ar e directed toward, matters of power reactor decommissioning.
ATTACEMENT A
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II. DISCUSSION A. Responses to NRC Questions In the Advance Notice of Proposed Rulemaking, the NRC requested responses to six questions relating to decommis-sioning policy development. Responses to those questions are set forth seriatim below.
- 01. Is it desirable to develop more definitive decommissioning criteria for production and utilization f acility licensees and byproduct, source, and special nuclear material licensees? If so, should the criteria be in the form I of: (A) Potential exposures to individuals; (3) Numerical contamination limits; (C)
Other? (Specify) l l Cur res=onse to this cuestion decends on the inter-
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pretation of the phrase more defini ive decommissioning criteria." We do not believe that it is desirable at this time to develo.c production andmore s.oec decommissioning requirements f or utilizatioific n f acilities, such as an inflexible timetable for decommissioning, specific site restoration i requirements, and rigid exposure or contamination limits. l . Eowever, we believe that it is desirable from a regulatory l policy standpoint to develop general ocjectives and cost ' estimates f or decommissioning which may be utilized in develop-ing generic case assessments. These gener ic assessments in turn would permit the NRC to dispense with a detailed evaluation-en a case-by-case basis at the time of initial licensing or license i l renewal, and would provide valuable genert: information for near- l term license termination. It is a premise of such general objectives and generic assessments that there are three methods of decommissioning (mothballing, entombment, and dismantlement) and combinations thereof which are acceptable. It is a further premise that other acceptable methods er variations may be developed as technology evolves. Such general ebjectives should include, to the extent technically and economically practicable, the minimiration of health eff ects, minimization of indefinite preclusion of further productive use of the site, and the taking of no irrevocable action prior to decommiss ion ing which might preclude alternative courses. These objectives must, of course, be fulfilled on a basis which accounts f or botn costs and a rational assignment of pricrities. ,
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There has been no decommissioning of large power reactors representative of current f acilities. Var ious decommissioning experiences (such as at Elk River, BONUS, Fermi I, Piqua, Ballam, Pathfinder and Peach Bottom I) have served to demonstrate basic approaches and technologies which might ; be applicaole in the decommissioning of larce power reactors. In addition, ongoing decontamination and other activities on steam generators at Dresden I, Surry, Turkey Point, and Indian Point I will provide additional information on decontamina-tien and steam generator removal technology. However, decom-missioning experience to date does not form a basis for the development of more definitive decommissioning recuirements. Further, the NRC. has been developing a data base and reevaluating its criter-ia, standards and guidelines f or the decommissioning of current ref erence light water reactors as a par: c ., -its decommissioninc study procram initiated in 19 7 5. Major technical studies on decommissioning have been and are being conducted at Battelle Pacific Northwest Lacoratcry which are designed to provide further informa-len en :ne engineering methodology, radiation risks , and estimated costs cf deccmmissioning light water reactors. The report cy Battelle en pressurized water reactor decommissioning was issued in June 1978.1/ In addition, the Atomic Industrial Ferum issued a report in 1976 on the ecs s, occupational radiation exposures, and environmental effects of decommissioninc.2/ Several presentations en :ne costs - cf decommissioning have been made by various NRC licensees before State utility rate commissions in the E.g., Arkansas-Power & Licht context Cc. of rateNuclear (Arkansas proceedings.. One); Pennsylvania Electric Co./
. Metrepelitan Edison Co. (Three Mile Islanc One); Jersey Cen:ral Power & Light Co. (Oyster Creek); Alabama Power CO.
(Farle,y Unl: 1). These studies on the technical and economic aspects of power reactor decommissioning necessarily involve estimates and extrapelations because a very substantial majority of the ~ of :ne large power reactors will not be decommissioned for a number cf years. While it may be appropriate a: this time to develop general objectives to aid in the development cf general cost parameters and technical data for use by State 1/ NDREG/CR-0130, " Technology, Safety and Costs of Decommissioning a Ref erence Pressurized Water Reac:cr Power Station" (June 19'/2). _2/ "An Engineering Evaluation Of Nuclear Power Reac:c: Decom-missioning Alternatives, Atomic Industrial .:crum (Nevemcer 1976').
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i utility rate commissions in rate proceedings (see Q3, infra), l and : assess the rangt of environmental effects, i would ! be premature to establish more definitive requirements for ! decommissioning. Development of such requirements would I require imprudent and unnecessary predictions of the ! technologies f or decommissioning which certainly will evolve as studies are completed and experience is gained in the next decade and be~vond. , l The Supreme Court recognized in Power Reactor Development l Co. v. Electricians, 367 U.S. 396, 405 (1961), that nuclear I reactor technoloa..v is fast-developinc and fast-chancinc., and that -[w] hat is up to date now may not, probably will not , be as acceptable tomorrow." The Court's rationale in 1961 obtains with equal weight today, and mandates that the NRC defer the establishment of definitive requirements at ! this time. As a corollary to this rationale, it should also ! be noted that timely administrative decisionmaking does not compel the development of definitive requirements As noted, no no large power reactors are scheduled fer deccamissioning for manv vears. Accordinc1v, the NRC mav reascnac1v defer estab-
,'e-'.-ng cedinitive cecisional criteria un '2 more cecommissioning experience on smaller r eactor s is gained, and should retain flexi-bility to adapt its requirements as deccmmissioning technology evolves. , In anv. event, there is no need at this time te develop more definitive criteria for potential expcseres to individuals.
Present NRC r egula-icns and guidelines adequately saf eguard against excessive exposures to individuals during or fellowing decommissioning activities. Pursuant to Section 50.52 of the Commission's regulations, 10 CFR 550.52, :ne Commission may require that applicants for termination of licenses provice cetalas as to cecommissioning plans, inciucing plans for disposal of radioactive material and decentamination of the site. For example, a relevant fae:Cr in chocsing ce: ween modes cf decommissioning, as well as in makinc decisiens within a given mode, woulc. .ce tne occupa:1cna2 deses associated with each alternative. Such applicants must satisfy the NRC that decommissioning ef f orts will be performed in accordance with NRC regulations and will not be inimical to the common defense and security or :c the health and safety of the public. Additional guidance relating to potential exposures te individuals is already provided in NRC Regulatory C-uide 1.56, which describes the methods and procedures considered accepta:1e for the termination of operating licenses for nuclear rea::crs. Radicactive materials remaining onsite af ter decctmissicning must be isclated trem the public :c prevent exposure te
hazadous levels of radiation. Surveillance is necessary to assure that exposures are prevented, and the extent of
. surveillance depends upon the potential hazard to the health and safety of the public from the onsite radicactive materials.
Before areas may be released for unrestricted use, they must
-have been decontaminated or the radioactivity must have decayed to less than the levels prescribed in Regulatcry Guide 1.86, Table I. Prior to release of the premises for unrestricted use, -
the applicant must make a comprehensive radiation survey establishing that contamination is within the levels specified in that table. Against this f ramework of regulations and guidelines, we .- submit that there is no neeo to establish more definitive criteria ,or potential exposures to incivicua_,s, or to alter - the numerical contat ination levels in Regula: cry Guide 1.86.
- 11. any event, if the LMC should develop criteria for potential realistic exposures to individuals (taking into account actual and expected occupancy) in unrestricted areas, such post-decem-
-issioning exposure 1evals shocid nc: be mere restrictive than nc mal var iations in natural background r adiation.
1
- may se desiranle to develop generic environmental )
assessments for decommissioninc to sumolement the numerical l contamination limits and other'saf ety'iecuirements in Regulatory l Guide 1. 8 6 and 10 CFR 550.82. Factors which might be evaluated l . include the environmental effects cf decommissioning and any i subsecuent surveillance on land, air and water uses, and on other environmental censiderations and alterna::ves. For ; example, :ne removal of land from other probable uses and the commitment cf resources 'f er surveillance are f actor s which ' will affect cost-benefit analvses for decommissioninc. For
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purposes of an initial generic environmental impact statement on decommissioning, such environmental assessments shculd cover a range of parameters (from realistic to conservative) enveloped by an aggregate " upper bound case for we er three re'ference decommissioning methods as applied to typical power reac:crs (i.e., 1000-1300 MWe). The assessments should reflect a generic nalancing of fac:crs such as ne minimum dedication of land over time and of active barriers to entry relative to the economic and other costs of minimizing such factors. Of course, any subsecuent plant-specific nega::ve declaration or environmental impact statement (if necessary) could account for any unicue circumstances leading to a decision to decommission, and possible unicue er site-specific factors which micht serve to alter the ceneric balancinc
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(such as, for example, the dedication cf the site as a nuclear energy park).
C2. Should detailed decencissioning plans be required prior to issuance of licenses? The Utility Decommissioning Group submits that detailed decommissioning plans should not be required prior to issuance of licenses. It would serve no useful purpose to require an a p p .3 . cant to commit to a decommissioning metn.oc thirty or . forty years prior to actual oecommissioning. As noted herein, supra, reactor and decommissioning technology continues to evolve today, and will most certainly continue to evolve for manv .- vears to come. Anv recuirement that an applicant select One cetallec methoa. of c.ecommissicning prior to l..icensing (or even after licensing) would be premature and would intro-duce unnecessary an a unwarranted rigidity into the process. Moreover, we seriously. doubt that the NRC would now irrevocably approve a method c, o.ecem=1ssionine to be em:3ovec. cecaces hence. Acccrdingly, no regulatory purpose would se served by altering :ne existing regulations (10 CFR 550.52) which provide :nat a licensee will submi: a decommissioning plan upon filing an application f or termination of a license. This approach allows a licensee to select from state-cf-the-art options which it is r easonable to assume will r eflect and incorporate procedural and technical approaches which were . unavailable or unknown when the f ac ili:v.e w a s initia11v
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e licensed. As a t r a c t i c a l ma t t k..t. ,?,bman NRC licensees ase.requir.ed to cesignate a aecommissioning mennoc curing :ne Qperating lif e of a f acilit.y in the context of rate .troceedine.s before .
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in certain States to permit the recovery cf decommissioning costs .frc: current customers, and should not be interpreted as a firm commitment to a rpecific technical deccmmissioning metnod. . While decommissioninc. cost recoverv mav be termitted
. n certain cases casec upon an assumec me:noc, licensees should not be deemed to have abandoned the ortion cf modifv-ing :ne assumec met.s.oc in view or souno alterna ves wnich may arise or oecome more attractive in the future for technical and/or economic reasons.
- 03. Should funding or other surety arrangments be required before the issuance of licenses for all cases?
The Utility Decommissioning Group submits that funding or surety arrangements should not ( ind eed , may not) be required bef:re issuance of licenses fer power reac: ors. NRC reguia-tions a3reac.v. require consicera:1on c_g c e c o m= : s s i o n. in e. as 4
1 l part of financial qualifications and envizcamental reviews ) in licensing cases. The regulations recuire an applicant f or a license to operate a power reactc: te provide information to show that an applicant possesses or has reasonable assurance of-obtaining the funds necessary to cover, inter alia, i.h e estimated costs of eaermanentiv. shutting down the facilitv . and maintaining it in a safe condition._3/ The regulations con-template that, in most cases, an applicant 's annual financial statements contained in published annual reports will enable the NRC to evaluate the applicant's financial capability to satisfy this requirement. 10 CFR Part 50, 550.33 (f) and Appendix C. . In addition, the regulations require NRC licensees and .oermitees to file annual reports with the NRC each year (10 CFR 550.71(b)). The regulations also reserve :o the NRC the right to require additional financial information during operation of a f acility, "particularly in cases in which the proposed power generating f acility will be ccmmenly owned oy tvc or more- existing companies or in which financing depends upon lcng-terr, arrangements fc: :ne sharing of the power f:cm the facility by :vo or more electrical generating companies." . 10 CFR Part 50, Appendix C. The demonstration c:. ,inancia_, qua_3.fications 1 . anc t.x.e c on t in u ing surveillance by the NRC of a licensee's financial condition provides a saf eguard that necessary decommissioning f unds will se available when necessarv.4/ - - . NRC regulations requiring applicants te demonstrate financial qualifications are rooted in Secticn 152 of the Atomic e .nergy nc: o, _3.c0%, .as amended, we D. .s.C. Sezz..a, w n i c h a _3 _, ow s the NRC to determine what inf ormation an applicant must provide 3/ In the contex: of a licensee's financial qualifica ions to decctmission, NRC Licensing Boards have received evi-dence on costs of decommiss'ioning, and cne has concluded that the incremental decommissiening costs wculd nct imv al: an c:herwise financiall.y c.ualif ied applicant 's ability to decommission. Matter of Nortnern Indiana Public Service Co. (Bailly Genera: Inc Station, Nuclear-1) ~ i AEC 557, 613 (1974). See Fansas Gas and Electric Co. (Welf Creek Generating Station, Onl: No. 1) 5 NRC 101 (.,c// . _4/ The NRC recenti_v initiated a rulemakinc. croceeding to con- . side the factual, legal and policy aspects Of the require-
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tiens to. receive 10'CFR Part 50 licenses for power reac: cts (43 Fed. Reg. 22373 (May 25, 1978)). Thus, the adequacy
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B S - _a_ to demonstrate technical and financial qualifica icns. The
" reasonable assurance" standard utilized y the NRC in 10 CFR Part 50, 550.33(f) and Appendix C to implement section 182 of the Act was affirmed in Power Reactor Development Co.
- v. Electricians, supra, 367 U.S. at 407-05. See Nor n Anna ,
Environmental Coalition v. NRC, 533 F.2d 655, 659 (D.C. Cir. 1976); Nader v. NRC, 513 F.2d 1045, 1052 'D.C. Cir. 1975). The NRC authority to require an applicant to demonstrate on a " reasonable assurance" basis its financial ability to cesien, construct' operate and decommission a power reactor is, as noted, derived from the Atomic Enerev as Act of 1954, and is beyond valid dispute. However, any NRC authority to require its power reactor licensees to post bonds or to otnerwise impose suret.v requirements on those licensees is clearly lacking. Such a scheme would require NRC censideration of matters of economic regulation such as funding mechanisms for decommissioning. costs. Neither the Atomic Energy Act of 1954 nor the National Environment Policy Act of 1969 ves; jurisdiction or authority .in the NRC over matters of economic regclation and utility financing. As to NRC licensees, such matters are properly addressed either by State agencies or by the Federal Energy Regulatory C OT.m is s ion ("FERC") in the Deparment of Energy. chis S tate and FERC jurisdiction is specifically preserved in the A:omic
, Enere_v Act.
Section 271 of the Act, as amended, 42. U.S.C. 52015, provides that nothing in the Act affects "the authority or regulations of any Federal, State, or local acencv with respect to tne generation, saae, or transmission or. ,e_ectric power produced through the use of nuclear facilities" licensed ty the NRC. Section 272 of the Act, as amended, 42 U.S.C. 52019, subjects NRC licensees which either transmit er sell at wholesale in interstate commerce electric energy generated by nuclear power reactors to "the regulatory provisions of the Federal Powe r Act. " The Commission itself has recognired that the NRC "has no authority to regulate certain economit aspects of nuclear power plant's, such as ra:es." Ma::er of Ecusten Lighting & Power Co. (South Texas Project, Onl:s Nos. 1 and 2) 5 NRC 1303, 1312, n. E (1977). The lack of NRC authority to require its licensees to comply with a funding or sure:v arrancement to finance decommissioning costs was demonstratec in 23e; when the then Atomic Energy Com=ission (NRC's predecessor) propcsed to tne Jcint Committee on Atomic Enere.v that the Atomic Energy Act be amended to authorire the Commission to require
_9_ licensees to pos t bonds.5/ The AEC proposed this amendmen; since in its view "the Atomic Enere.v. Act does not now provide to the Commission the requisite authority tc regire such a per formance bond. "6/ we are aware o., anc. unpersuac.ec by (especia_3_,y as to its applicability here) the summary opinion expressed by the NRC's Executive Legal Director to the House Committee on Science and Technology by letter dated August 3, 1977, tha t while the matter is not " entirely free from doubt," NRC " statutory authority is sufficiently b cad to enable the NRC to require licensees to post bonds to assure performance of regulatory requirements." This opinion is not based upon specific statutory authority to require licensees to post bonds (which the Executive Legal Director expressly recognizes is lacking), but rathe~r merely on the Commission's general rulemaking authority (Section 161b t of the Atomic Energy Act, as amended) and the Commission's ~ financial qualifications authority (Senion 192 of the Act).7/ Eowever, this view is not consistent with the more -traditional view expressed earlier at the same hearings by the ERC Acting Director of Fuel Cycle and Material Safety that "we do not have this authority in our legislation."8/ We view this opinion of the Executive Legal Director to be cu: one expression on a question which v.ust be evaluatec against the rationale and history discussed above. Against )
-5/ The amendment was proposed by the AEC in view of the cankrur.:cv of two small nuclear waste disposal firmsf a
and would have authorized the Commiss_on to require the posting of conds to assure its reimbursement for expenses incurred in the event of licensee bankruptcy or license r evoca t' ion . _C,
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and 2nc sess. (July 17, 1963 anc May 19, 1964), Appendix 3, at 3. Commissioner Ramey cf the AEC noted similarly tha:"[n)either the Atomic Energy Act of 1954, as amended, nor other Federal statutes, provide the Commission with the necessary authority to require that licensees furnish to the Commission bonds of the type contemplated in this sect en.. ac., at <. 7/ Eearings on Decommissioning and Decontamination Before
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4 this background, the only' reasonable cenclusion to be drawn is
- ha: there is great doubt that the NRC has authority to impose funding or surety arrangements on these licensees in the event it determines that such a policy is necessary and justified.
In any event, if the NRC believes it may have some (perhaps - secondary) jurisdiction to conside r matter s o < . economic regu_3 a-tion such as funding or suretv. arrangements, the better regula-torv. oolicy. . ac.oroach would be for the NRC tc forec.o involvement in these matters. Where, as here, various State commissiens ! and the FERC are considering and resolving such matters as decommissioning financinc, -- the NRC should defer to the , primary jurisdiction anc obvious expertise o., such commis-siens and the FERC. Several NRC licensees have sought successfully to recover future decommissioning costs in current rates in proceedings before various State public utility com-missions. Other NEC licensees have cases pending before State commissions. For example, concepts of nec.ative salvac.e have been employed ec recover decommissioning costs through depreciation (e.c., Arkansas Power &'Lich: Co. (Arkansas Nuclear One)), anc :ne FERC 5taff nas endersed such concepts. See Yankee Atomic Electric Co. (Yankee-Rowe) TERC Docke: Nos. E-9410, E-9421; Tr. 351 (July 20, 1977). x L.,ewise, another approac.w. to recover decommissioning costs which has been approved is an annual expense allowance (.co be placed in an interest-bearing escrow fund) designed to accumulate the necessary funds over the lif e of the nuclear facility. PennsylvanianElectric-Co. (Three Mile Island One) Pennsylvania Purlic U:111:y Commission Order, entered June 22, 1972. The Pennsylvania PUC recognired that estimates of decommissioninc. costs may chanc.e over the life of the facility, and noted that such changes "may be dealt with through periodic. review and adjustment of the ctal estimate (and its annual provision) within each rate case, or at any time upon the initiative of the [PUC) when it feels that such review is necessary." This is one example'of how regulation of deccamis-siening f unding by the States in acccrdance with criteria and
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_ actors wnicn mav. .ce mociriec to account . aspects or matters unique to the licensee assures a desirable i flexibility and accountability in the regulatory process. Anothe r' ' example o f how State rec.ulation adds. flexibilitv. to
- he process is found in the letter cated December 30, 1977, to the NRC from the California public Utilities Commission in Docket No. P RM 5 0- 2 2 , in which the State noted that it employs the negative salvage concept to assure that decommissioning costs are recovered from current cus:cmers. The State further noted that estima:es of future negative salvage are centinuously ,
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.c e r m i t s recovery of decommissioning costs cased on :ne most current data, and provides a high degree of assurance that decommissioning funds will be available when required.
While we submit that the NRC lacks the lecal authcritv to require its power reactor licensees to post bonds er to"
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otherwise impose surety requirements on those licensees, we believe that the NRC has a large and important advisory role to play. For example, the NRC should provide to the State commissions and tne FERC the detailed generic cos: and ~ technical inf ormation on the various methods of deccmmissioning wnich will be developed in this proceeding. In addition, the NRC could provide the States and the FERC with guidelines as to what the NRC perceives to be a range of acceptable methods of recovering decommissioning costs, such as by negative salvage depreciation, annual expense allowances, or some other appropriate method. Thereafter, if the States and the FERC authorize decommissioninc cost r e c c v e r v. - consisten with the range of the NRC-appreved methods, anv . financial qualifications review by tne NRC would be sim-lified.
- 04. What are acceptable criteria for residual levels of radioactivity on materials which can be released _xor unrestricted use?
One cf the principal *iss.ucs :'c'be " addressed ir reevalua:ing NRC decommissioning poli'cv f is levels of accer:ahde radio- *
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given f acility, yet may be eco stringent for ano her facility. In any event, there should be no requirement to reduce exposures below the levels associated with normal variations in natural background, The merits of site-specific considerations were endorsed by the NRC in NUREG-0436. While the NRC stated that it "will activel.v seek to prevent a proliferation of sites where the remains of nuclear f acility operations stand guarded or entombed," it also noted that some sites "are uniquely suited to that purpose for the foseeable future, and it may not be reasonable for our society to expend great resources and increased doses to the workers to decommission an old nuclear f acility site to a pristine condition . . . . NCREG-0436, at 31. We agree that the costs of reducing levels of radioactivity may exceed the benefits, and urge the NRC in ceve2cping criteria for acceptacle residual levels o_, radioactivity to consider fully and give due regard to the cost aspect of decommissioning. We believe that selection cf a decommissioning method must include site-specific con-sidera icns such as land use and demography, and agree tha: scme sites are uniquely suited for permanen encomnment or some other alternative to complete dismantlement. C5. Proposals have been made to maintain reactors, which have been closed, in protective storace for lencthv .-ceriods of time to allow for rac..icactive cecav .crior to dismantlement. From the standpoint of determining the impact to future generations, what is an acceptable length cf time, if any, af ter a f acility operation ceases bef ore the facility should be decommissioned? It appears that, the Staff in question 05 may have Inacvertently usec :ne werc " c.ecccmissionec' wnere the con-text of the question indicates the word "dismantlec- should have been used. He will frame our response to this question as if this change were made. In addition, we assume that the wording of this question does not indicate that the permanent entocoment mode f or decommissioning has been precluded from Staff censidera-tion. Permanent entombment is a viable alternative to dismantle-ment, and may be . referable in some cases. For example, where a f a c il i }* is located in an enere..v .cark, c.ermanent entombment may be a clearly preferable alternative. Further, where regiona2 aanc. use anc cemograpnic consicerations nc;cate tna tnere is no need to restore the site, permanen: ent: moment again may oe preferable. Thus, our response to this question assumes tnat while there are alternatives to dismantlement, tne
tme dismantlement option has been selected der purpcses of discussion ;7 the cuestion. The acceptable period of . delay between cessation of ... cperation anc cismantlement wl.,1 depend to a signiricant degree upon the mode of decommissioning selected. It is d if f icul t based upon the data available to determine on a generic basis an acceptabic period of delay. The reports completed and beine. e repared b.v Battelle (en pressurized and boiling water . reactor decommissioning, respectively) . will provice acci:1cnal c. ata to assist in tnis cetermination, particularly with res'pect to the potential impacts of each mode or. ceco ==1ssioning in terms o, occupational exposure anc. overall public safety. Althouch oresent thinking seems to be that the immediate dismantlement -mode woulc. result in occupational doses (primarily attr icutable to cobalt-60 ) sienificanti.v larc.er than those due
- mo thhalling er entombment (see AIF Study, Chapter 4, supra,
_), eacn moce o, cecc=missioning will resu;,; in radiation n. exposures c ne decommissioning work force. One factor for consideratien is tha: those engaged in activities ,cursuant
- NRC licenses are recuired to make reasonarle eff erts to maintain r adiation exposures as low as is reasonably achievable.
The phrase "as low as is reasonably achievable" means as low ae 'e -aasenacly achievarle taking into account the state of technelogy, and the economics c., Improvements in relation to benedits to the public health and saf ety, and o ther societal anc socioeconomic consicerations, and in relation c the utilizatien of atomic energy in the public interest. See 10 CFR 520.1(c), , 300.26(a), and rar o0, Appenc..lx :. . . *".us,
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cf as low as is reasonably achievable to take actions to miticate coces cue to cecommissioninc activ :les, p a r t i c u _3 ar:y
. .u . e's o e c t to occucationa_, doses, cut ccasistent with a cos:-cenefit evaluation of total doses over time. Wnile a relatively shor: delay in dismantling activities could effect c e<.._<_e.<...
_. . a. d u c . _4 o r, .' u- ^. c' d o s e _' _-m- .. ~ . .k. e .. .. " ... c .- v c .. . .- 4 cutor, ccbalt-60 (which has a half-life of apprcximately f;ve years), other factors such as land use and cos: v.ay d ictate e arlier or later fismantlement. While it nav be sucerficiallv accealinc to place a n.eavy empnasis on occupa:1onal exposures in the selection of a decommissioning method (and thus tend te disfavor early dismantlement), one mus: also consider une long-term exposure to employees and the public at large associated with delayed dismantlement and the other decc=missioning options, as well as the desirabill:y cf crenine the site to other creductive uses a: a relativelv ear., er ca:e.
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. s e-i.e....a u- .. a....e.. . - A a n. n~ - ..<. e c i~n n .:..n: . . . . . -.nc selected for a particular facility, the scnecule for activities
r must reflect a. balance struck cetween allowing maximum decay Oc take its cearse by de., erring disman:, ement and the impacts associated with the dismantlement deferral. notec, :ne generic assessment o., cecommissioning (incaucing e.r inter in mcchballing f ollowed by dismantlement ) should await the completion of the studies being performed at the instance of the.NRC. However, a decision as to a waiting period (if any) must be made in the context of a plant-specific and site-specific evaluation. The c.eneric assessment should recoc.nize that economic and other considerations will have to be analyzed in a given case to determine if dismantlement is cost-effective, and if so, at what point in time f ollowing cessation of operation.
- 06. Should decommissioning criteria extend to buildings, structures, and components which have ne: been con- :
taminated with radioactive mater als? The authority and related functions of the NEC should . . .. . . a_, ways be exercised in re_, ation to tne tasxs wrien it has been assic.ned b.v the Conc.ress. The .crimar.v function which the NEC must perform in connection with decommissioning is to assure that the possession and/or use of regulated radioactive
. materials and of (functional) producticn er utilization facilities will not be inimical to the ecmmen def ense and
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..s authority under NEPA is coextensive with its authority under the Atomic Energy Act, i.e., the'NRC nas environmental respon-sibilities with resoect to those matters which it is en owered to regulate under the Atomic Enerc..v Act.
There is a material dif f erence in the sweep of the Com-mission
's NEPA responsibilities between those activities wnten ar e c. enera_, _, v licensed or ex em : frca licensinc., anc major activities requiring a specific license. ~
Such differences
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reasoning, where the Commission's safety and common defense
.iurisdiction comes to an end (because a f acilit.y is no lonc.er functional or ca. cable o' beinc. made functional, or the materials are no leger present in significant quantities) its NEPA responsibilities'lixewise come to an end. This reasoning cotains even though the Commission might during the construction or operation of nuclear facilities have
.murisciction over non-nuc, ear .acrtions of :ne ,ac12itv cecause .
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significantly contaminated cease to have a bearing on, and hence cease to have a nexus to, the Commission's licensing . . . . responsibility, including its environmental responsibili:y under NEPA. , Declining to extend decommissioning criteria to . non-nuclear and. uncontaminated portions or. a ,acialty is con- ,1 sistent with the Commission's duties, responsibilities and authority under applicable law. This view is consistent with the increasingly recognized need (and Ac.m:nistrat4on poliev. ) to avoid nnecessarv. duplication between state (or local) and federal. requirements. Accordingly, at least where state (or local; authorities exercise control over non-nuclear po tions of the facilities, the NRC should not intrude and overlav. its rec.uirements on local c.lans and local decisions to meet local needs.
=ence, not on1v. sho ulc. the NRC avoic establisninc. cecom-missioning criteria for uncontaminated buildings, structures and components of a facility, but it also should declare that it will not do so except perhaps in special circumstances wnere :s specia., competence anc. expertise can be :.:cugnt to bear either to fill a regulatory void or at the invitation of state or local authorities having jurisdiction. Eence, in the c:dinary case, an order authorizing decommissioning snouac release for unrestricted use any builc..ings, . structures, anc components which are not contaminatec anc w,.len are not . . . .
so proximate to or so intertwined with contaminated ones as
.to require appropriate restrictions or c:her conditions on access, occupancy, use or the like.
- 3. Comments on Overall Decommissioning
-Policv-Development In addition to the foregoing respenses to the six specific questions, the NRC also sclicited comments with respect to the matter of overall'cecommissioning policy .
ceve_,opment. .. . . . . . . we have severa, .casic points wnien we ce_,: eve require discussion or reiteration, as presented below.
- 1. Specific Decommissioning Plans We believe it is necessary to emphasize a point which is discussed in response to question 2, sopra. With respect
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plans should ce required at the initial licensing s: ace, we perceive of ne polie.v or other reason to >d ustifv such a requirement. Since reactor decommissioning tech.1 ology will
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p g, . . cesi:Eule to CoCD.el 3 Comm_4tment t o s D. e C 1.g 1 C C e C ort.i s s i o n inc. plans a a premature stage. Neve 'ha' ass, we assume that the NRC will continue to develop and refine regulatory guides and will cooperat'e with industry standard-setting groups. The product of these efforts should provide NRC power reactor licensees with additional guidance as technologies further develop. Moreover., such guides will serve (together with the general objectives discussed below) as a basis for estimates of health and environmental impacts associated with future decommissioning.
- 2. Gene r al - Decommis s ioning - Ob j ec t ive s We believe that the NRC should proceed with ongoing studies leadinc to the development of ceneral objectives for Basec. -in part upon sucn power reactor cecommissioning.
objectives, the NRC could develop a generic impact assessment i vn en may be incorporatec by re,erence and considered in the NEPA review during initial licensing. Such general objectives should include acceptable occupational and public exposures
- c: g;ven cecommissioning methoc.s. The ceneric intact assessment should include a range of ef fects associated with various modes of decommissioning from dismantling to mothballing for a range of categories of sites. The range of effects should span from reintroduction of the status cuo prior to the power reactor construction to indefinite dedica-tion of the' site to the decommissioned power reactor or to i n c u s :.:: a a, uses, incluc..i n c. . cower c.eneration using nuclear and other energy sources.
As noted, supra, the criter;a for radiation exposure to the general punlic in areas released fc: unrestricted use.should not be more stringent than levels which are within normal variations in natural background radiation. However, those levels might be hi.gher taking into account site-specific factors such as expected actual occupancy and . use anc :ne costs c:. recuction to _3 eve _,s comparable to background. We presently foresee that the criteria for structures in areas released for unrestricted use would be along the lines of those set forth in Table I of Regulatory Guide 1.86.
, 3. Financial Ocalifications We believe that the presen: NRC regulations recuiring that applicants demonstrate financial cualifications during initial licensing and recuiring licensees and permitees tn submit annual reports each year are adecuate to p cvide reasonable assurance that sufficien: funds-will be available 1
i l l
Oc ccver the ecsts o., cecommissioning anc any associatec. 3ong-term surveillance. Tne specific method c be employed by NRC licensees to provide for or recover the costs of deccarissioning are matters which are singularly within the ex.cer:ise and jurisdiction of appropriate state agencies and, in some cases, ' the FERC. Ac c o r d inc.1.v , it is neither necessary n o r a.cc. r o.cr i a t e for the NRC to require the posting of bonds or other security by power reactor licensees for decommissioning. In any event,- it is questionable at best that the NRC even possesses the statutory authorit.y to impose such rec.uiremet. We have discussed this matter at greater lenc.th in res.conse to , question 3, supra.
- 4. Physical Security ;
Physical security regulations directed to such threats ; as terror ism and saccr ac.e a.colv to c.re ra tinc. reac:crs. 2 These regulations do not apply te facilities where special nuclear material is no longer located, such as a .oower reactor , ed - - .. -.... ". a. . .e d.on'..-. - an o.ce.a.4
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-s .= r-^a w = o . .c .c i n 1 only licsnse or materials license, or, cf course, where no )
license at all is required. Whatever may be required to ; maintain post-operating license surveillance f rem the stand- 1 point of protection of puclic health and controlling access to anv area remaininc restrictec, no envsica, securitv recuire- . . ments neec ce incosec once the f acilit.y ceases te contain ; significant quantities of special nuclear material. Therefore, I i no extension of the present applicability of the physical i securi:y requirements in 10 CFR 573.55 need ce considered in j connection with a review of NRC .oclicy on decommissioning. . l
- 5. Uncontaminated Buildings, Structures and Compenents e.s ciscussed in response te question 6, suora, ne specific criteria or provision for NRC approval of the .
disposition o., uncontaminatec cul.,cings, structures anc i components at a power reacter site is either necessary or appropriate. The general objectives-referred to in subsection S.2'aseve will permit assessment a- :ne initial licensing stac.e of the ranc.e of environmental im.rac s, includinc the disposition of the site as a whole. Snecific rec 5irements at tne time of c. ecommiss ioning w ith r espect to uncentaminated portions of the facility should be left c state and local regulation.
- 6. Results of Decommissioning-Reevaluation-A fundamental point for this decommissioning procee' ding is that reevaluation does not necessarily imply that major changes ar e required, or tha t the policy embodied in existing regulatorv. treatment is unsound. Existinc. NRC rec.ulations alreadv rec.uir e ac.cro.criate consideration o f decommissioning prior to issuance of operating licenses, and are adequate to protect environmental values and the health and safety of the public. While the reevaluation may reconsider acceptable contamination levels and exposure criteria, there is no compelling requirement on the basis of available information that the NRC revise its general approach to decommissioning regulation. As noted, inherent in existing regulations is a flexibiltty which permits NRC licensees to formulate specific decommissioning plans based on state-of-the-art technology uc. on the termination o f nuclear oower oo. eration. Further, active rec.ulation cf and o. rovision for decommissioninc. f un c. .i n c.
by the States, and FERC in some cases, provide a high degree-of assurance that necessary funds will be available when required. In short, a modification to existing decommissioning regulaticns fo: th e sake of change alone is not desirable or consisten: with cbi.ective rec.ulatorv oclicv. . . .
- 7. Regional Decommissioninc-Workshcos The NRC Staff has developed plans to conduct regional wc kshops to r revide the States with opportunities to review and cotment on the NRC's proposed plans for developing an overa;.3 decommissioning pc3. icy.
The wc kshops are scheduz,ec-for the third and fourth weeks in September of 1975. We under-stand that participation in the workshops will be by invitation only. Sosever, we assume that power reactor applicants and licensees will be permitted to participate fully in such workshops. These applicants and licensees have an obvious and significant stake in the outcome cf this decommissioning proceedine, and can contribute materiall,y to the develcoment or. in:craec anc. reasonec input on c.ecommissioning issues, as well as provide assistance and information to the States. Accc dinglv, it would be accrocriate to cermit such acclicants
~ ~~
and licensees to participate in these woikshops. At t.Ve least. the NRC should assure that individuals from industry with technical / management backgrounds , and who have had act a1 experience with decommissioning analyses or activities, mav.'carticio. ate in the workshoe.s.
. There are several such individuals who are e= ployed by members of this Utility Oecommissioning Group. In this regard, the undersigned would welcome the opportunity to assist the NRC in securing such individuals from among the members of this Group, or elsewhere.
III. CONCLUSION
'de appreciate the opportunity to provide the NRC with our cccments en the vital issue of decommissioning , and will appreciate a further opportunity to participate in the decommissioning rulemaking proceeding as it develops.
Respectfully submitted, DEBEVO!9E - LI3 E R.u_AN l a'-+v Nichola S Revnolds e - t 8
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75'
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, MR. 3E RNERO : Mr. Newman.
l, .
- MR. NEWMAN: I'd like to comment about a couple 2
l' o One is re-2l cf the things we've heard you say this morning. i i l i lated to the need for a contractor to get into the facilities l a i l 5 serving as examples. 6 I I w uld strongly urge that in doing so they give , 1 more heed to realistic cost estimates than some of those that 7 appeared in the reprocessing study. .This becomes especially B l i e' l important on a comparative study with entombment . t . jo j: For instance, one thing that se think is grossly H I 11 underestimated in both cost and radiation exposure is the 12
. dismantling and removal of high-level waste tanks. If that !
I ' g , is understated and entombed is compared with it, we don't have -
- . i l
34 i a fair comparison. i ic
! The other was your statement related to DOE findings.1 ;
16 , You said that you were certain they would wherever possible ,
! ! i j7 ;*It's hard to conceive of something that could not be done by i
i i 15 DOE with their resources t. hat could be done by commercial j 39 fpeople. Let's hope that all your regulations are doable by j e i I 20 h both, i H. 21 l MR. BERNERO : If I said "wherever possible," I 4 2 , should have said "wherever reasonable." . yp; MR. BAUM: Ashy Baum, Virginia Electric and Power. ! l' One thing that would appear to me is that, as far 24{ An4.wed Recami. inc. h 25c [ as the addition te background radiation, that we should be t v w -
-a>r e es- *4 7+ r
76 F 1 1 talking in the realm of 500 millirem per year, the same as - i i!: ' 2 Appendix I has if.we had a man at the fencepost. I think i l 3l that's a reasonable amount for a decommissioned facility. I
, Along that line, if we have a multiple-unit site, l i n
5 more than one reactor operating there, we will have Appendix I 6 guidelines, I presume, at that time to cover the other units 7 that are still operating. 8 It would seem to me that would be good logic for 9 g m aintaining the site boundary dose the same as we would have i 0 n . . . . . 10 y :or cecommissioning. u 11 I don't know of any utility or any organization i 12 that would be willing, and I don't think it would be practical, ' I 13 ' to give up a site where a nuclear power f acility is located, I ja ,certainly not with the all the regulations and recuirements to i 15 l get approval for a site now, much less what it will be 30 years ! r
- I 16 ;fcm now or beyond that. No company would want to sacrifice .
l 37 lthat site. I'm almost certain it would be used for some advanced i jg systems or maybe some other type of reactor in the future. l 19 , I think it's totally unreasonable to even talk in ; l i l
} ;
20 ftermsof1to25milliremperyearadditionaltobackground 'l l 7; radi'ation for decommissioning of a plant. I think you should i 22 fbemindfulofwhatAppendixIcallsforasthesiteboundary ; I 23 [ dose to the population. i. l 74[ Thank you. Av.ceroi nemnm. inc. j! 25 [ MR. BERNERO: The gentleman raises a good point that H F
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i l]
n, 77 i, - ll ! k l
)y we're conscious of and want to treat-properly, i 2lli A power plant site'is a notable piece of real l
1 3 hestateinthatitbelongstoapublicutilityofsomesort, or 4 a company. It is a nexus of many high-voltage power lines l 5 and therefore is a logical place to generate power. It has l 1 6 some assured form of cooling water available to it. As a 7 result, it becomes a unique and very valuable pi,ce of real g estate, and many would argue that these things 'l never be 9g anything but a power site. If they are so hard to find and l 4 10 i so hard to qualify, they will remain that, i! ij Getting back to Mr . Reynolds' statement, there is 12 something I would like to add for your information. We do l 33 have a docket file on this proceeding, and one of the issues - 1 I 34 lhe touched on was tax treatment. , 33 'Just for your general information, a few days ago ;
' I 16 !I received a letter from a Mr. Preston Collint, at Gilbert -
i i l i j7 lCommonwealthAssociatesinReading, Pennsylvania. Mr. Collins , I I jg ;did a parametric analysis of decommissioning fund accrual with l 19 ifferent tax treatments. It was a very extensive thing, full l i 20 l of leogers and 'so forth. ! > r y For those of you whose bent is looking at numbers, t a i
.it will be in the docket file shortly. I've sent it back in i ,
i J 23 order-to get it stamped and put in the PDR. 24 It is a very complex thing: the tax treatment that
- sa.r we newned. x .i 23jis possinle and the tax treatment that is probable. It's an b
4 0
17 8 i
- , i
'; I 1n !
F extremely complicated thing. The states have badgered us on i 1on 2 this point of discussion. l 4 3p Mr. Reynolds. 3 MR. REYNOLDS: I have another question not related 5 to the tax treatment. 6 With respect to the supplement that you're having
+
7 done on the PWR study, will the analysis of permanent entombment g 1 nelude degrees of permanent entombment, such as removal of 9 long-lived radionuclides from the reactor and permanent
)gjentombment of the short-lived radionuclides?
l l l
;) MR. BERNERO: Well, one of the points of concern l l
i 12 we had about entombment ever since the beginning -- and there i 13g are words to that effect right in the PWR study -- is that d ja ; given the probability that the reactor core barrel contains. f 15 l a substantial quantity of Nb 94, one of tne nuclides, these I 16 nuclides would have a half-life of 20,000 years and the cuantity: i 1 17 { calculated to be present is such that the core barrel would have ; i i 1E l a surface or near-surface dose of 2 R per hour after all the -l r9 i conalt 60 is gone. You would still have that kind of a dose, i, , 1 20 . We concluded -- I think rightly -- that isn't the l ) n l l sort'of thing you would entomb, that King Tut's tomb didn't l ' 21 . l I 22 ,last anywhere near that long and to protect for a 20,000-year 33 d half-life it makes no sense. l 0 ! 24 g one of the gentlemen from the states put it to me rw ner swormw w. l e j l 3 very succinctly. He said, "Look, you're perfectly willing to l'~
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79 l 0 i s < jl! speak of pulling the spent fuel out, and getting the plasma arc i I 2 f torch in there and cutting out that core barrel is not all j u 11
,p that much more complicated."
f I ! a You should separate your entombment considerations { l' to treat those materials, the core barrel, as something like 3 6 spent fuel. It's clearly high-activity waste, clearly some-l thing that should be removed. And then you ccnfront the issue 7 l g of entombment for wnat's left, which is principally cobalt ; i I' 9j 60, cesium 137 and materials like that. a jg Yes indeed , we are consicering that. It gets into l 73 i, cuestions of snould you leave it all in tne individual build-f l 12 ings and entomb an auxiliary building or entomb the spent fuel l D h po 1 or entomb a refueling water storage tank or entomb a ; I L , i, 34h reactor building, of should you shove it all in the reactor 15 , building and entomb the reactor building? l t i MR. REYNOLDS: You told us earlier that the Staff 16 [ I: j7 was predisposed against permanent entombment. Was that to j
~
)g l s uggest that you were predisposec acainst this type of per- i i
19 manent entombment, that is, removal of'long-lived radioisotopes l l I 40l or radionuclides and entombment of the remainder? l i 21 MR. BERNERO: You're asking me if I'm still biased. !
.i
; i i (Laughter.) l 2e i t.
23 We're trying to be as objective, as unbiased, as li 74 " we can in the consideration of the alternatives. I think we Ac..r.o i a n en m inc.0 e..c 6 will have an unbiased treatment. I can only leave it to your 5' 1 h II i
80 i I 9
;O j ;j comment when you see it. '
( I 3
, Ms. Johnsrud. I I
~lg !
s DR. JOHNSRUD: Mr. Bernero, I'd just like to make i 3 a comment for the record since there will be a transcript or 3 p ublication of this record in some form. 6 i I understood that this was to have been a public 7 meeting, an opportunity for public participation. I would like B the record to reflect that the sign-up sheet at the beginning 9 of the program indicated only three or four representatives . 9 10 Il of the public interest organizations of the -- what? Seventy- t l
.) ' five to a hundred people here. ,
I i < 12 Therefore, I don't feel it is representative of I 13 l the public's interest in nuclear power. It would be a mis- j 1 i 14
! r epresentation of the comments received frc . this audience !
33 ,for those to be publicized as the record of a public partici- , 1l ! 16 ] pation meeting. i i j7 MR. BERNERO: Well, we are sensitive to that. l
)g By the way, my count was about sixty people. There f t :
j9 ]ere a number of NRC Staf f people nere, anc I don't count them. l I . I 20 h, They were just padding the audience. I , 21 l But I do recognize many of the individuals here are f l ! 22 ; industry representatives. I've dealt with them professionally j 2 ,.
!for some years. -
Il 2ah Our view of the public role in the decommissioning , C Ac,4eoW Rmorms, thc. d ,
,edooliev development is such that I-looked primarily to tne
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l) u i r f c- ---.e
n. p 01 j. h i
; f involvement of the' state representatives as the way to do it.
W 2 ! We 're getting the state people.
! We're just not going to the b
3 0 radiation control program directors, who are technical people ' like we are. We're going to the state political structure: 4 l l 3 the governors, the legislators. I personally have spoken to l 6 l all sorts of state organizations on this very subject and 7 will continue to do so. v I really think in this context the best representa-i 9 tion of the true public interest is through them; therefore, - ig l.ij we have structured our program very heavily on the state role. L ji 'l And we constantly kept those as State Workshops and not State ' i 12 Public Worksnops, because if we had State-Public Workshops we j i
. ;3 , would end up with state people competing for the floor with l
34 l aentlemen from the industrv, many of whom are experienced and l 15
. Knowledgeable and difficult to talk down.
i 16 (Laughter.) l 37 j So I think the public is primarily represented j l
'15 {tnroughthestates,butIthinkyourcaveatiswelllaid, !
19 ' that of perhaps sixty people here the predominance is industrial; a ! 20 representation. 21 Jon. I I 22 i MR. STOUKY: liaybe I can put the last comment to 23 this 'before lunch = I'd like the record to show also that this 24 fmeeting was very well publicized, and anybody could have been , e ' AM E MFDl N *CMMFfl. IOC. I 23 Fhere. L O i
E2 i' l D. . il
, MR. BERNERO: Yes, we always have enat proclem. ,
i g One more, please. j 2 l VOICE FROM THE AUDIENCE: Tne lady cidn't identify ! 3 [' 4 herself who made the comment. I MR. BERNERO: Ms. Johnsrud, Judith Johnsrud, 5 6 l Environmental Coalition on Nuclear Power. Bef re we break for lunch, let me just point out 7 , E t y u that outside there is a stack of little maps of the 9
, a rea that show the restaurants. - t 3g Thank you. We will reconvene at 1: 30.
i t. j)' (Whereupon, at 12:15 p.m., the meeting was recessed, to reconvene at 1:30 p.m., this same day.) 12 13 l i r l. I4 1 15 l i 16 17 i I I 18 l 19 l . 20 l 21 ! 22 l, 6 s
. Ace f ece+s' Reconm. lec. ;j 6.t 6 ;t -
.:t
(
I 83 I i l'
. AFTERNOON SESSION 1 l-I, (1 : 40p.m.)l
, i e
MR. BERNERO: We're acout 5 minutes after the time n . I i for reconvening, so I'd like to get started agdin. ;
# f As I said before this morning, we will hear the !
S technical presentations: Dick Smith on the general subject of the decommissioning study and the reactor decommissioning 7 l l study in particular, and then Dr. Smith Murphy on the fuel 6 j
! reprocessing plant decommissioning study, which was the first 9ii 1
ene that Battelle did for us. 10 :s: i; 3 ) lj After the reports on the decommissicning studies, g there is an opportunity for independent public statements if l any are desir ed . It is my intent to then go into ,a session g \
! i I
g I where I will put those questions back en the board , the four- i ee.n ques 1 ns that we resdewed with ine state people at the ] 15 I i
; )
g 1 State Workshops and which are equally applicable in the context l 1 a l here. I'll put them up and tell you in general what the
! states said and have the floor open for discussion or comment, ! !
1 18 4 i i r I 1,7
! w hatever you care to do. I think that would be a constructive ' i
)
i ! , i '
)
I wa'v to go through the whole issue. 20 At the end of the fourteen questions there could i 21 I be any summary or additional remarr.s or additional questions ; 22 j ; that any of you micht succest, and then I tnink.we'll have a l
.y )k '
n e day of it. l
,d e .
1 e i A=J e-e n ewner.. ine. it
,, !' So right now I would like to introduce Dick Smith ;
I en ,s I b w ' ii r fh'
. -- ,. . , , , c-,.- -- - . , - -
84 .; IL li from Battelle Northwest Laos to give his presentation..
)
l
*s 1 xxxx l PRESENTATION BY R. I. SMITH ON STUDY ON 4
. l 2 ,
!, l
,h DECOMMISSIONING A PRESSURIZED WATER REACTOR. -
I 4 MR. SMITH: Thank you, Bob. l 1 1 5 ISlid**) I l 6 You should have in your possession a little booklet that nas this title on it. This contains basically the slides 7 1 i l g that I'm going to be discussing this afternoon. l I think what I'd like to have you do is hold the , y 9 jo; questions on the reactor study until I've finished presenting i I 11
'i it , and then we will break for a few minutes and talk about 12 that before proceeding with the discussion on the fuel re- l i
13 pr cessing plant study. l 4 .
;g l (Siide.)
! I 15 At Battelle we're conducting a whole series of l !
i 16 i studies in the area of decommissioning for the Nuclear Regula- , 17 tory Commission. The ones we're reporting on this afternoon j U jglbasicallyarethefirst two that we've completed. I-1; (Slide.) . I i 20 Let's look for a minute at what we 're talking about. 21 We're preparing a facility for retirement from active service f 22 and putting that facility in such a condition that any risk from i l I 73 l that thing to the public safety is within acceptable bounds. 24 There are a range of conditions. We're really talking about [ c AaJeoecot Accorrers, int ' 25 ij some of the ones that we determined were probably the most 4 I i n, p 4 r
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h! ! s 1 (Slide.) i 6 2l The studies in particular have the following objec-
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t ives: 5 We wanted to see whether or not the technology was 6 really available to accomplish some of tnese joes. Admittedly 7 a certain amount of decommissioning has been cone in facilities in l
- g fyearspast, but nothing quite as large as a full-scale re-i 9 processing plant or a large nuclear electric power plant. !
io ! We're looking at systems hardware anc techniques. 11 We had to estimate the radiation dose to the occupational , i 12 workers who were doing the job, try to estimate the total ! I l 33 1 manpower costs as well as raciation cose for doing these kinds l 1 I ' ja ; of ef forts to decommission the various facilities via several i 15 ,possible routes. l (Slide.) 16 Dismantlement is the obvious first one we considered.i i 17 Safe storage was looked into, or possibly entombment. j 3 l
.js Basically the studies went something like this.
I' i l 39 iWe looked over all existing regulations, some of wnich Bob l i l l ' 20 talked about this morning, to see what they tell you you have 21 to do and developed our work plans accordingly. ! i 22 We looked at what experience has been had in this l l c untry and abroad to see what we could learn from that.
~
23 Then 24 : e went into what we call a facility characterization, wnich - Ac.4w.+ nemmn. inc. f l 25 I is a fairly extensive effort to develop a description of the-I L
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ii l C 1 i' j . l l-k' facility hardware and also the racioactive nuclide inventory , l! 2 in the facility at the' end of life. 3d Tnen we proceeded to develop work plans and methods , I . 4 and are trying to develop a schedule for accomplishing these j l . I 5 jobs resulting from the work plans. , l 6 We~then began to estimate costs anc safety in par-7 ticular . When we talk about safety in these studies today, we B will be principally talking about radiation safety, radiation o exposure. , l l What is the allowable residual radioactivity that K) l o 11 you can leave in a place and waix away from it? Bob talked l 12 about that some this morning, and we did some work in that 1 13 ! area to develop a technique for translating from allowable , l l i l 4 14 dose limit to major residuel radioactivity. i i 15 Finally, we looked very briefly at some of the 16 j financial alternatives there might be, in a verv restrictive ! i l 17 ) sense. We cidn't try to get into things as complicated as l 1 l taxation intarfaces and all that, 18 i i { i
' l
. l 19 i (Slide.) l l l
20 These are the bases for the studies in general. i 21 , We toox in each. case a real facility, because to do the jo'r, l l 22 j to.get down to the nitty-gritty details of manpower estimates, 23 exposure estimates and so on, you have to have a real place
' I i,
24 to;1ook at. In each case we had a real facility. As Bob Ace.Feoors' Reporters, int ;; n 25 mentioned, it was the Barnwell Plant for the reprocessing h t
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_ , _. - . ,4-
87 I f i
' plant and the Trojan Nuclear Plant for the PWR. .
.I 2
We made certain assumptions about what contamina- I l 3 tion levels were in these facilities. We assumed that the ! a operators had lived there and worked there and would make a 5 reasonable effort to keep the place clean enough to work in. 6 We used always a generic site, because this par-7
.ticular problem does not influence or impact very much on g the emission problem, and we wanted to be able'to relate ,
9 potential releases from the various activities, different kinds ' 10 of emission activities for different facilities. We picked
- 1) , a generic site which was reasonably typical of micwestern er i
12 middle southeastern facilities. ! i 13 We looked at a number of decommissioning modes. ! 14 lWe'll talk about those in some depth. We tried te strike a I I 15 l reasonable balance in the work plan between sa:ety anc cost. ' t ! y lI say " safety": we're really talking about radiation exposure. , f 17 ! We tried to keep in mind the principles of as low jg Ias reasonably achievable in these work plans. And, as I men- !' t
); tioned earlier, one of our ground rules was to try to limit i 1 r
1 i 20 ourselves to current technology, not to rely on somebody in- ! , i 21 venting some great, wonderous device but to do it with things < i
)
t 22 that you have available today. { i !
-23 , We assumed that the decommissioning performance was. ! :
1 24 reasonably efficient. What may be efficient to one person -
-A o.a.o n s a. w n m inc.
.25 !C3Y. dot be to another. We assumed that you could get perhaps P
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- 3. i six working hours out of an incivicual per day for an 8-hour I i it i ,
2 shift considering the suiting-up and unsuiting, break times ) 1 3 and all that sort of thing. - 1 3 A very important assumption in these studies was ,
! l 5 the reference facility is alone on the site. This makes a i
6 big difference in.what you have to do in the support facilities, 7 security guards and all kinds of support activities. If.the 8 facility is alone, you have to supply it during all times; it 9 it's on a multiple site, then they are-already there. This ; 10lisacost consideration in our studies. P h 11 We also assumed that the transuranic wastes in the + i 12 case of the reprocessing plant and the high-activity wastes l l 13 l from that plant had to go to a deep geologic disposal. No i such facility ex!.sts today. 14 We don't really know what the costs l: i 15 are. We based our estimates on some previous studies that have !
! 4 16 Ibeen done for DOE to arrive at some reasonable estimates of l 17 inat these costs would be like.
i
~18 All the other radioactive wastes we assumed would l 1
1 19 go to a low-level burial ground. Even here we used the exist- i i 20 ing pricing structure from several burial grounds to develop 21 these costs. 22 (Slide.) 23 l-These are the modes that we were dealing with. ! i 24 i l Dismantlement is the first and most obvious consideration, wherei. i AeFedwW Rrsorwrt 4% l , ! 25jyou completely decontaminate the place of all the radioactivity , l h-P
.-. N
89 I i
; above some allowable residual level, whatever that may be. ,
2 Then you can terminate the license and walk away if that suits 3 you. You don't have any problems about continuing care. 4 Safe storage, on the other hand, is one in which 5 you do a certain amount of decontamination and remove things 6 like radioactive fluids and combustible wastes and that ' sort , 7 of thing and confine the rest of the radioactive materials in 8 a reasonable inshion. You have to maintain a certain mmount 9 of surveillance on these facilities for as long as they remain 10 in this state. j l l 11 We 've essentially coined new words in this area be-i l 12 cause we didn't like the old ones. We say custodial safe
. 13 storage. This applies if you have an active protective system ,
=-
14 operating, ventilation system and that sort of thing. l i l 15 Passive storage means that all the active systems j 16 are shut down and you don't have to have any operating equip- 'l I 17 ment running, other than perhaps electronic security surveillance, 18 f ire alarms and that sort of thing. I 19 And what we call hardened safe storage, which is I 20 essentiwlly the temporary entombment where they come in later j 21 and dismantle. , 1 22 All of these cases, all the saf e storage cases , 23 is an incomplete mode. You can't leave it there forever. The 24 License is still in force. You can't walk away from any of ' A.#e-wamoms w. j 25 these safe storage conditions, l , l
-v
90 l l. 1 Permanent entombment, on the other hand, conceivably, l 2 if you've done the job properly and the regulations permit, 3 you can walk away from such a thing. I'm not sure how that's 4 g oing to come out in the . regulations in the end in the sense j 1 3 you still have a large inventory of radioactive material there l l 1 6 that you have to do a certain amount of surveillance on over J 7 some reasonable period of time to assure'it's not escaping. ) il I 8 These are the modes that we were concerned with. 9 As was mentioned this morning, for the most part we tended to to seite off en*.ombment,- for a number of reasons which we'll talk j 11 about in some detail in the individual study results. We i i 12 basically dealt with dismantlement and safe storage. 13 In the case of safe storage, we dealt principally i,
. ja with custodial or passive conditions.
13 (Slide.) 16 One of the things that we were trying to do in de-17 veloping criteria.for-release of these facilities -- we were is trying to develop this criteria, and these were the objectives 19 that we were working with:
' 20 To develop an acceptable contamination level for un-1 1 J 21 restricted use. We wanted to base that on what the recommended '
i l 22 dose limits for such a thing would be for members of the public ! l l 23 and those that lived on the site and raised vegetahles there '
' i 24 tand so cn. It considers all the potential. pathways to exposure, j .
Am.se-w anomm. w. { l r. 25 such as ingestion, inhalation, direct irradiation, whatever. ! l l 1
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91 - We wanted to have a method that could be applied i 1 y to any kind of a nuclear facility, not just a reactor or a , 3 r eprocessing plant or some specific f acility, but all kinds of a f acilities containing radioactive material;. and hopefully we 5 w uld c me up with something that was reasonably consistent
')
6 with the reasonable criteria. I think we were reasonably successful, and we will 7 B take a look at that in the next slide. 9 (Slide.) g This is the technique that we evolved. First of 11 all, you look at the inventcries that are present in the , i 12 f acility and evaluate certain kinds of release scenarios : how 13 does this stuff get out to the public? g l l You also compute the doses, the annual dose to the I 34 l 15 l public , the maximum exposed individual, from this kind of 16 inventory and then look at that dose compared with the accept- , i able annual dose. If it turns out to be larger, this tells ] 17 t jg you that you've got to reduce the residual inventory some amount l. i 19 You can also then compute the contamination levels 20 associated: first the level that you had to begin with, and 21 secondly the level that you're trying to achieve. The end 22 product is the contaminations levels that will result in the 23 cose to the maximum exposed individual that is less than or ! - 24 .ecual to the allowable annual dose, whatever that limit may be,g Ac.-F.o.r.i neoort.ri, inc. 25 For: purposes of example, in our calculations and studies we use i
! - I
'92 g ,
I 1 1 millirem per year. We don't necessarily espouse that number, ; ; 2 but it was a basis ' for calculation. 3 (Slide-) 4 We look at financing, as I said, in a very simple 5 way. There were basically three ways to do it: pay for it 6 at the time you do_the decommissioning; develop a prepaid I y sinking fund in which you put the money when you start the g facility up; or you can collect the money on an annual basis j 9 during the operation and develop a sinking fund for that, we ; 10 looked at these in a fairly simple way. 11 (Slide.) i m One way to compare these kinds of alternatives is ! 13 t o look at the present value at the time of reactor startup, t
~" !
14 facility startup, the present value cost associated with each ! i l l 15 of these. You compute that present value at the time the i 16 facility is started up.
.17 On,the' pay when incurred-case, we assumed for this particular example a decommissioning cost of 44 million in l 18 i i
i 19 dollars at be time of startup. If one assumes certain things, 20 like an interest rate available at 8 percent, an annual infla-21 tion rate of 6 percent and a discount rate of 10 percent, we 22 arrive at-a present value of that $44 million, if you pay it 23 40 years later, it's about 10 million. If you put in enough l 24 money into this prepaid fund to arrive at the proper amount l AmFewW Amomn. W. , 25 after 40 years, and the proper amount is S44 million, if you !
)
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I .
93 l t The 1 l escalate it for 40 years it turns out_to be 452 million. 2 proper amount that you essentially would have to have into this { . 3 fund would be --initially it's 44 million. That gets adjusted a as time goes on by refunds and so on, excess growth in the , 5 fund, so the final present value, taking into account all e 6 refund payments and so forth is $27 million. 7 Similarly, if you accumulate a certain amount.each e year on an annual basis, the present value of all those 9 accumulated payments is about 15.3. ! 10 This just gives a very crude feel for the comparison : 1 11 you make this way. It doesn't take into account any of the 12 very difficult problems, like whether these payments are taxablel 13 or not. . I ! 14 l (Slide.) , i i is Bob talked a little bit about negative salvage l 16 i value and depreciation. This sort of illustrates what he was t 17 talking about. I I l 18 j The upper line here represents a straight line de- ! l 19 .preciation of the capital cost of about 5440 million initially, , i 20 plus the 44 million decommissioning cost, depreciated over the 21 40-year life. 22 The only trouble with that upper curve is in the j i 23 time fr sre to here (indicating) this 44 million is inflated 24 down to . ion, so one really has to arrive at this point l Aasexe Anorms. inc. i ! 25 ;to collect . . Jer amount of money so the depreciation curve ; I - 1 l- ! 8 4 e
!- 94 I
[ t would be a straight line. Depreciation would be this lower 2 c urve, but that's not quite reasonable, either, because people j , 3 who maxe the payments up here are paying them in less inflated i 4 dollars than the ones down in here. It would be more equitable 5 for them to follow this kind of a constantly adjusted curve 6 to arrive at a reasonable value.
\
7 That's about all I have on general ideas. I want 8 to go into the specific details of the PWR study at this point. 9 (Slide.) i , 10 This is the Trojan Plant , located near Portland, 11 l Oregon. It's 1130 megawatts electrical net, Westinghouse , 1 12 four-loop PWR. The parts that'we're particularly interested
/
13 b, of course, are the containment building, the fuel building, ! t 1 14 the auxiliary building-- you can't really see that here -- and ' 15 the associated tanks, storage tanks and so forth, around the
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16 area. By and large, the rest of the plant is clean and doesn't. F 17 n.eed any particular decontamination. So our principal efforts l 3 ja in this analysis were devoted to these three buildings. " -- 19 The cooling tower, of course, dominates the whole j t 20 place. This is a single natural draft type cooling tower. 21 If you've ever driven by that place on Highway I-5, it's a very i 22 impressive sight. l 23 (Slide.) j 24 In the case of the PWR study, we really looked in - Ac..p .o.r3: n.porieri, inc. l 25 ldepthatimmediatedismantlementandpassivesafestoragewith I
- i. I.
i l
95 . l '! 1 deferred dismantlement. We looked very briefly at the custodiali I ; 2 safe storage and concluded for this situation you really didn't 3 gain enough-- the cost here of maintaining the staff that you l 1 4 had to have for custodial safe storage was significantly worse 5 than the slight additional cost of deactivating the system 6 and putting it in the passive mode, so we essentially skipped 7 this one and went on with the detailed analysis on this one. 8 (Slide.) i 9 This curve is one of several I will show you. We ; I 10 b ased our conclusion that entombment is not a viable approach 1 11 for these situations. i 12 This shows the growth rates of a number of radio- l 13 isotopes on the stainless steel components inside the reactor i f i la vessel. These are fairly long-lived isotopes: nickel 63, I l l l 15 nickel 59 and so on. These have half-lives that are quite l
} I l
16 long, ranging from about 2 to 80,000 years for nickel 59. ) k 17 These data are normalized to unity at 30 years in ;
)
'is same drawing so you can see f lIorder to get all the curves on the I 19 lthemtogether. '
l l 20 The relative activities from one to another are quite, i 21 different, but you can see that as years go by -- the longer I 22 you operate the plant, the hotter this stuff gets. It really 23 stays there for a long time. 24 To give you a sort of perspective in terms of effee- > Ace J edret Reporters, Inc, 25 ,tive full power years, the Elk River Plant only rar for about I i l I
o
^!
p 96 -l 1 , I l- , 1 -2 1/2 full power years so the level of radioactivity that was ; 2 ! associated with i.t was something in the order' of ' O percent. l f l l 3 As you get into the large plants, they run for 30 years. E 4 (Slide.) l 5 We've covered more here than you want to know about 6 the subject. These are the principal isotopes that are present 7 in the stainless stee2, neglecting those that had half-lives g of less than a' year. ' 9 The thing to note, the half-lives are in increasing , 10 lcrder. These are the types of radiation they emit. These l 11 are the radioactivities in curies per cunic meter. We went i 12 through and calculated from these the surf ace dose rates. l i 13 The principal problem as far as radiation dose is !
~
l . 14 ' concerned is associated witn external radiation, principally I i 15 gamma, from these highly activated components and from activated! 16 corrosion products in the system. These numbers were generated ' , I 17 I for the hottest part of tne reactor. I This is the core shroud. I l 18 l These numbers were on that, plane, which is a deflux area , so i 19 lthese are the worst numbers you will have. Here we're talking I-t 20 about a million curies of iron 55 and almost a million curies j 21 'of cobalt 60. If you do the calculation to get the surface 22 ' dose rate, you 're talking about 560,000 R per hour, which is l' 23 almost incredible to consider. ! 24 We go over here to niobium 94, and there's a couple l Ace-Fooersi Reporters, Inc. 25 , of R per hour. For the nickel 59, it's about 90 ME per hour. i ! i i 1 l U
7 97 i i i
; ; The principal problem arises because this stuff has a~5.3 year ~
j 2 h al f-li f e , this is.'there for 20,000 years with a half-life of 3 80,000 years. In 100 years this is about gone,- and this stuff . a is there for a long time. l i 5 (Slice.) I ' 6 This one presents the curves for those things I 1 7 showec you on the last slide. The yellow curve is the total l I l g l curies. We took all the data on the previous slide, summed l 9 them and decayed them by appropriate isotope to get the yellow j 10 l curve. These again were all normalized to unity to get them 1 11 all on the same curve. 12 This is the cobalt 60 on the pink line, and you see ; i 13 about 80 curies or so. It ceases to be the dominant item, ! I 14 and the niobium 94 takes over and stays here for all practical t i 15 purposes forever; so we didn't feel it was reasonable to con-r l 16 sider an entombment structure tnat we could put together that ! 1 17 would De sufficient to assure -- to protect against this thing 18 for essentially forever. Ne said entombment is not a viable ! 19 approach. I I 20 I've heard people say, "Well, vny don't you take l 21 this stuff out and take it somewhere else and put it away 22 where it's safe, wherever that is, and then entomb the rest 23 of the thing?" Well, you can certainly do that, but again it 24 'doesn't seem like a very reasonable thing to consider. You i u row,, neponm. anc. 25 'might as well take the whole thing out. This part nere is the ; I l !
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t: 98 l p >
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;( hottest and the nastiest part of the whole place. If vou're I
il - t i 2 j going to take tha.t out anyway, you might as well finish the { 3 Joc_and be able to release it. I guess that's all I want to 4 say about that one. I 5 (Slide.) j i 6 Here is a typical sequence of activities for cis-
- 1 7 mantlement that we went through in our exercise. There is about a 2-year preparation period to be taken care of curing I e .
i 9 the final two years of the facility operation. Wearedevelop-j 1 ii , u) { i ng detailed plans for doing the Joo, cettine the necessary i 11 equipment and materials on board and so on, training the staff l
)
i 1 12 that will be used. l i i i 13 } The second step is after the plant is shut down. We ! I 14 a ssumed that we did a very thorough chemical decontamination ' e I ! 15 l of all the primary systems in the PWR. These are the systems , t , 16 ! that have the activated corrosion products deposited through- !
]
17 out, certain fission products perhaps. These are the ones that ! 1g contribute to the high personnel exposure of those working ; We assume we used chemical oecontamination 19 I around these parts. I 20 to reduce the dose rate levels by possibly a factor of 20. l 6 1 21 We then went through a removal of all contaminated - i iequipment. I 22 This is everything that was potentially contaminatedj I ' I 23 )Ii ncluding all the pumps, piping, everything that had potential 24 for having contaminated water, this sort of thing.
- u..v. owe newnen, enc.
25 j The next step down the road was to do the mechanical i ; i > l
- l. ,
l! !
1 a 99 ; g 1 ! cecontamination of these buildings, after you've taken out all , p 2 I the equipment and. hardware. In many cases there will be areas 3 that have radioactivity, that have spilled fluids soaked in the 4 concrete in various areas and so on; so we assumed it was l , l
\
5 physical removal of this kind of material that was required. I I I 6 We made a. number df assumptions about what those 7 areas were and how much concrete had to be taken out and.so on. ' 3 We went through a fairly detailed calculation to see wnat 9l volumes of material were involved here and what was the cost ' l 10 i of putting it into packages and shipping it to the burial grounci n 11 i to dispose of them. l 12 i We went through a final radiation survey to assure ! i l l 13 ,that tnere was no radioactivity above tne requirec levels so - 14 ,the license could be terminated. l l I h 15 ! Finally, tne last thing was an optional condition, I . l ! 16 'that is, do you want to tear tne structure down and restore the t 17 site to pre-facility conditions, !,
?
18 i In our studies we examined this problem. It's broken: i 19 'out by line item so you can evaluate it for what it was worth. . i 20 ,It's not a requirement of NRC. l l l i 21 l (Slide-} I i I i 22 Here is a summary of the costs generated for a
.I 23 ! pressurized water reactor.
As you can see, staff labor is a l I i 24 i f airly major item, something like S11.2 million. I should : ( Acyhoces' Reponert 8% b 25 ] mention that all the numbers I'm going to show you are in 19.78 l li i: , if il . l 2 we cranked in af ter the analysis was done; so these are the 3 upper limit numbers that we generated. i a I should also ~ mention that the staf f labor here 5 is for the decommissioning staff. It does not include people j 6 who were involved..in demolition. It does not' involve people - 7 who were involved is the transport of radioactive material to g the burial ground.
"I 9 Another' thing that is important to reme nber in the 10 staff. labor area is that we made certain assumptions about the i 11 makeup of these crews. The people were weren't locked into the 12 compartmentalized craft structure or construction job. We were , 13 able to use people who were reasonably ec= mon at reactor sites, .
14 reactor mechanics or maintenance mechanics. These guys were 15 gualified over a whole range of crafts. If we went to a com- ; l i 16 partmentalized staff structure, these labor costs would be sig- l l 17 nificantly higher, I'm sure.
]
is For radioactive material disposal here, we have 19 basically three kinds of things. We have activated materials, i 20 contaminated materials, and the small Dox on the end'is what ) 21 we call radwaste. These are combustible wastes: evaporator 22 bottoms, filters, that sort of thing. i The total for the radio- >j 23 active material disposal was 10.8 million. This included the ! 21 case. cf the highly radioactive materials and the cost of the I A.#e-w nummn. inc. l shipping containers for all this material as well as the disposal 25 l' .
l 101 1 i
; cost at-the disposal site in the case of shallow land burial. i 2 We said.we didn't make estimates on tne demolition l l
3 job. We didn't co that one ourselves. We hired a professional l ; 4 demolition contractor to'make -- to essentially evolve a bid 5 for us as the basis for that one. 6 Trojan is.a plant that uses an electric boiler for 7 its auxiliary steam supply system, so we have a fairly sizable B electricity bill for the period of this decommissioning effort. , 9 Part of this goes into providing neat for the evaporators for l I 10 l all the water we have to evaporate. Some of it went into the l l 11 operation of the primary pumps for tne decontamination water. , i I 12 We broke out the shipment of the last whole core
\ l 13 of spent fuel as.a separate item. In the bookkeeping system '
1 14 that may be part of decommissioning, but it's nevertheless a ;
! i 15 cost that has to be taken care of at this point in time.
16 And this general equipment and supplies item was 17 about 3 mi11 ion. Here we're talking about things like some l 18 fairly interesting things like electric polishing systems and , 1
~
19 a whole assortment of miscellaneous tools. 20 Nuclear insurance is going to cost you something , 21 during this period. We don't have a very good handle on that. 22 This was based on an estimate made by people at the liability 23 insurance offices. i 24 Anc we had some special contractors in this area. l Am. rent amomn. tac. ' 25 This was auxiliary racwaste equipment that we trought in fairly i I t
102 i lo !
) late in'the game because we were tearing out the existing ;
.l
.2 ! racwaste equipment. l 3 All of this added up to S41.2 million. If you want
. . . -' ,r 4 to subtract out the spent fuel shipments and the demolition 5- cast, you'd have about S31 million.
6 I might mention at this point that after we completed 7 this study I was asked to make a fairly quick estimate of what 8 the comparative cost would be if we decided to entomb this 9 thing, so I did that on sort of a difference type basis. We ; 10 made the assumption that if we entombed, we would entom the j 11 reactor containment building, the reactor vessel, all. its , i 12 components and the structures like steam generators and so
- 13 forth, and would proceed to dismantle the rest of the plant.
~~
i 14 The bottom line was that the cost to do the job, including ! l 15 the reactor containment building and dismantling the rest of ' I 16 the plant, was about 35 million. And then you're left with l
-17 that thing to-contend'with..
l 18 (Slide.) i I l-19 This is the breakdown for the cost of the radioactive' 20 material disposal, the activated components. This is the cost 21 for the pressure vessel and all the rest of the paraphernalia . 22 inside the reactor containment. 23 In the lower portion here is the cost of the con-24 ' tainers. This section is the actual transport cost of shipping ! A..reme nnwan. W. 25 it from the reactor site to the disposal site. In these cases ; I
, 103 I
l !
)
{ we were assuming shipment by truck at a distance of 500 miles
- one way. l x l 3, In this next section is the charges for the burial I
, : ground , shallow land burial ground, for disp,ral of this 5
material. In the case.of the activated components, we also 6 did a short look at what.it.might cost to take this same 7 material and put it in the deep geologic disposal site. 'That j g added about 2.25 million to the bill. It was done on the i 9 g assumption that we didn't ship all this stuff, but just about o lI g ij three-quarters of it, the highly radioactive stuff, shipped
)) it by rail at a cistance of about 1500 miles. And there were ,
i i g certain assumptions about the cost at the disposal site, too. i I g These were broken down ny buildings. This was the I
), a ctive stuf f. This is the contaminated equipment in the con-15 tainment building, and this is the material that was in the l t
- I I 16 l fuel and auxiliary buildings. '
I 37 This fraction of the disposal volume that you see i I
)g ;is the contaminated material that you nave from that very high
~
i t 39 iracloactivity, and then these are the radwaste and evaporator I i 20 bottoms, combustible wastes, filters and so on. The whole g jcomponent added up to just under 18,000 cubic meters of material. i 22 ! (Slide.) I l 23 1 This is the expenditure pattern. I should point i ey ,t out that these numbers are for the first year before shutdown,
\ ;
sa.rmno nowrwn. enc. l'an . 25 j this is the second year before shutdown and so on. Over ; i l' f il
104 i l j here we're simply hiring people and getting equipment on hand. 2 > The first year we have a fairly large electric bill
,, for cecontamination and evaporation work. Here is the staff
+- ~l 3
labor. A fair amount of radioactive material disposal cost. 5 In this first year we were disposing of highly activated struc-tures. 7 Fuel shipment',was on the top, We put in demolition g to complete the picture. This little yellow strip down here 9 is the insurance cost. It diminishes once you get rid of the g, i fuel . And then your special contractor cost.
- 1) As you can see, based on our work plans and schedule !
12 and so on, it took two years to get ready and about four years
! to conclude the job after we shut down.
13
)g l (Slide.) i
-15 One of the things that keeps coming up all the time i
16 is a comparison of the different size reactors that have been 17 dismantled. It's a little difficult because- of the dif ference- ;
)g linthemagnitudeofthedollars, 5.7 million as opposed to 42.
j9 . We looked to see how we might look at these things j l 20 and decided that the percent of total cost for the various 21 functions might be a reasonable way of looking at it, so that's 22 what we do dov tre. 23 , Here we have staff labor. For our study it was t l 24 29 percent of the total cost. Elk River looked like 43 percent. ! A=4 mar n e=rms. inc. . l 25 l 1 For material disposal, we're estimatinc about 28 i - i i s
, , _ . _ . . ~,e
i
'l 105 g l .
I 1 percent of the total cost, and thev actually had about 21 per-l 4 cent, 7 3 The demolition of the structures, our estimate was A i i a 20 percent of the total;'their actual value was about 17 per- ; i 5 cent, ); 6 Our power costs were much higher. For one reason, at this point they ha'd been down for two or three or four 7 3 years. The fuel was all gone and the fluid systems were all l 9 drained dry, and we had no large volumes of radioactive water 10 to dispose of. i 11 The special equipment costs were quite a bit higher 12 than our estimate because they were developing specialized ' 13 egalpment. I i, ! i ', ja The miscellaneous is not too different, I don't ! ! 15 think our estimates are all that +ar off. 16 (Slide.) 1 i 37 If we can look for a minute at safe storage, or jg ! preparations for it, anyway . i I.t's very similar in many respects!, , i 39 ito the dismantlement approach. You still have to plan for it, i I 20 get ready for it. ! i g When you shut a plant down like that, you may think 22 y u know what you're going to do 5, 10 or 50 years away, but i 23 y u're never quite sure. If you decided to put the plant in 24 safe . storage with the . plan to take it apart 50 years frc= now Ac>4.o.m nemn.n. inc. , { ., 25 and didn't chemically decontaminate it, and for some reason you
' . ! I
; 106 l,
) changed your mind and about 5 or 10 years later you decided 2 1 to go in and do it, you're going to pay a very severe penalty 3 ia terms' of exposure because you did not do this decontamination.
a It's extremely unlikely that you would be able to do it in a 5 reasonable time or cost after the plant had set there for 5 6 or 10 years. You have to essentially reactivate the whole plant , 7 It's fairly cost-effective to do it initially. g Again, you do a certain amount of mechanical de- i 9 contamination and fixing of contamination: deactivate all the i 10 lequipment, isolate certain areas, contain all radioactive 11 material. You might even pour concrete, but not very much -- 12 quite.a lot of padlocks and this sort of thing, and then I
, 13 prepare the facility for surveillance and maintenance..
I 14 In our study we assumed that the security surveillance!
! l 13 we operated was performed by having electronic surveillance l I
16 devices all over the plant which were monitored by the offsite { 17 sampling station -somewhere . You still have to go in and I l je jperiodically check things out and fix up what is going wrong. lThat'spart of the interim care after the plant is put away. 19 l l. I 20 h As I mentioned earlier, this is not a terminal state ! 21 at all. You finally have to do something to terminate the 22 license. Depending on the facility and the nature of the 23 activities contained in it, that could be as simple as a very 24 detailed survey that shows the levels are sufficiently low to j w.p.omi n. con.n. inc.
.25 ; walk away from them. More likely in the c.ase of a reactor plant,!
i f
. 4 i I
q 107:
' l 1
i you're going to have to do a fairly significant amount of l l 2 dismantlement. I 3 MR. OLSON: Fay I ask a question? l i 4 MR. BERNERO: Please identify yourself and speak 5 very loudly. l 6 MR. OLSON: . My name is Rich Olson, Baltimore Gas I 7 and Electric. 8 On the previous slide, not the one just before 9 this but the one before that, where you compared Elk River , 10 with your estimates, you were using the comparison between i 11 the Elk River costs and your estimated costs as sort of an j i 12 absolute comparison to see how well you had done compared to 13 something that actually happened.
- j s i
ja In so doing, I guess you assumed that the two were i 1 really independent, like the Elk River cost occurred and that i 15 i 16 occurred independently of your trying to sit down and estimate , I j7 what the cost might be. In that way you can compare the two 18 and say, "Yes, we came pretty close to what it really was." l I pp l But in fact don't you think that when your people { l 20 l were doing the study they probably said, "How much is it going l l 21 to cost to dismantle this building? If it costs Elk River ' 22 X bucks and this is three times as big, it's probably going to 23 ,co s t us this much." l l 24 l Don't you think your figures were influenced by theirl Aasemi smomn. ix. : i 25 jactual costs in some way? l l
108
!i i i
} ll MR. SMITH: Only.to the extent that we had available j ,
to us certain estimates on manpower to do the kinds of jobs l 2f , l 3 that had to be done. You couldn't really say, "Oxay, that I a building is like this one'and it cost that much," because the buildings were much larger, much different; but we did have I ' 5 6 certain ideas based on the operator work about some of the 7 more complicated things, such as tidying un the structures. i 1 8 We had estimates on how difficult, how much it cost time-wise i l
}'
9 to do some of these operations. 10 These were intended to be scaled, I guess. But it $ 11 I wasn't nearly as simple, I don't think, as you indicate. i 12 MR. OLSON: I don't mean it's simple.. I was just 1 j
, 13 trying to show there was.some interdependence.
14 IGL. SMITH: Oh, yes, you always have that. You ; 15 l always base your estimates on your experience and knowledge i l 1 16 1
- hat you have from whatever source. You do the best job you .
I 1 I 17 iknow how. They aren't totally independent. i i i is
}. My point in making up that slide was simply to show ,
1 the things that are reasonably comparable. 19 We've had people j 20 comment that our demolition costs are way too high or way too 21 low, depending on their point of view. ! f 22 (Slide.) 23 As for cumulative costs, there is the immeciate j 24 dismantlement line. If we went into safe storage, there are ' u.4ewei nnenm. irc ' 23 certain costs associated with getting there. We took the cost . i i 5
~h
" 109 3't I U
l j of interim care to keep it that way and then added the dis- i i 2 mantlement cost to dismantle the structures at some point in
,j time. In these cases we looked at dismantlement after 10,
~ll 4 30, 50 and 100 years of safe storage.
5 Y u will note that the cost decreases here.from 30 6 to 50 years. That results from a somewhat arbitrary choice 7 by us that a lot of the contaminated material, which contains g largely cobalt 60, will have decayed sufficiently that we o
'J I won't have to dispose of a lot of it in a burial site.
i je il So what's happened here is the volume of contaminated! jj material has diminished from here to here, and likewise out l 12 to the 100-year mark . We did it essentially step-wise. For 3 3 i all practical purposes, it's a continuous slope of decay. i ja l i 1 That gives you a total look at the total costs of 4 i j3 {theseoptionsintermsofthecostofdollars. i
- {
16 l IbliO**) I ! j7 Immediate dismantlement is still sizable here, as I p~ jis common in present value analysis. Deferred payment reduces 39 'Ilthe present value until eventually you get out here to where I i 20 the cost of placing it in safe storage is nearly the whole thing,'I' 21 l1lf you wait long enough in terms of the present value at the
\
point in time. 22 This is taking into account the change in dis-23 pount rate and che inflation rate. I don't think anyone deal-
\ ,
24 png in financiaa bucaness is coine ' Aoameo numrwn. iac ii
., to nav much attention to ;
3 . umbers out here oeyond 20 years, anyway, because the parameters II i-d l o 4 V f Il i
110 , y i ,
;' I i
, !. are too unstable to rely on.
ip i 1 2 (Slide.) ) Let's look at radiation dose for a while. This , 3l l l 4 summarizes the doses that we estimate will be received by 3 occupational workers at the plant for immediate dismantlement 6 or for placing the facility in safe storage. 7 It's broken out here by the various functions. l B The reactor building, the containment building, is far and 9 away the chief material here. This first segment is the exposure il 10 !!, to the workers due to cutting out and disposing of the activated'
!i 33 jstructures. 3 i,
12 This portion here is for the steam generators, and 13 the rest of the har is associated with all the rest of the I ! 341 contaminated material in the containment building. I 15 Similarly for dismantlement of the auxiliary build-P 16 iin g . We estimate something on the order of 200 manrem for that ! I i 1
)7 jone, I i 16 The fuel building is somewhat less, around 130. !
The spent fuel handling is the same in both cases because you -~
),
20 still have the same full core to dispose of. 21 There were some differences in the miscellaneous i 22 l cost here. There is a fairly sizable change in the exposure l t the truck drivers who are hauling the stuff away. This is l 23 lJ : 24 jli again simply the dif ference in volume of the material you 're , . w.o.o
- n. mom.25ice. h;d ealing with. Here we're hauling 18,000 cubic meters of stuff, l 1
i o i II i
. ., ._ ~
U ll ' i b , 19 a and here we 're talking about a few hundred probably, 500 or i 2h600, I guess. j it I < ti : J
, i' I should point out that these kinds of exposures, i i .
I l 4 particularly here to the transport workers, are upper limit i
)
I We said a shipment has a surface dose as large j e kind of things. 6 as logarithm relations. That means that the dose at the truck 7 diiver's cab was a 2 MR per hour kind of thing in all cases. I i That's a gross overestimate of the situation, obviously. l g 4 1 9i The dose to the general public for immediate dis- t j 1 a t 10 d rantlement was due almost entirely to the trantport of this P
); stuff. fro = the highways and so on. The public dose due to 12 releases during the decommissioning work is almost zilch. l l l
) *, '
(Slide.) -
-. I I y j Bere is a su= mary of these radiation doses. For i i
J 1 j~, I immediate dismantlement, it's something over 1200 manrem for i l 1 16 'i decommissioning activities, something over 100 for transport l t 17 l and the general public dose, adding up to nearly 1350 man-rem. l l 1 f
'gj
- If you wait 10 years -- put it in safe storage and i 39fwait 10 years for dismantlement -- this first se gment is the ;
I 4 i > 20 6se associated with placing it in safe storage. It's on the l i 21 l order of 4 00 manrem. Then the dism.ntlement work is this much, ! l 22 and there is a little bit associated with interim care during ( { 4 and the public gh(the10yearsandonehasagainthetransport ! i 1 l I 24 h dose. $wFwee h wonm, W. h l
\
3p If you wait 30 years, the decay of the activated I d i li : n i Jl ,
; l l
3 12 1 11 N 1y materials in the place results in the decommissioning work 3, H, , being a fairly small contribution. The majority of it is 2 [! i 3 associated with placing it in safe storage. l i i Out to 100 years, it's essentially all due to the 4
)
pr blem of putting it in safe storage. l 5 So it looks like there ; 6 l is a relatively small incentive in terms of cose reduction to - 1 7 lwaitmuchbeyond30 years, if you want to wait at all. I g (Slide.) I, 4 t c,iy This is sort of a summary of the whole bash fer j
;cd the various things that we looked at. The cost was 42 pillion >
j)$ and the exposure was 1348 manrem for immediate dismantlement. 12 If you put it in rafe storage for 10 years and then dismantle i
; p- i it, it costs you about 50 million and something like 800 manrem.!
i lIf you wait y 30 years, your cost is only slightly larger, 52 1 l' ; 15 imillion, and your exposure is not quite half what it was at 10 : I ! 16 j years. If you go out to 100 years, your cost is slightly 37 i smaller and the exposure is very slightly smaller. l l i l 33 VOICE FROM TEE AUDIENCE: There are some differences ! n l j9 in the charts in the handout, i l l 1 1 20 MR. SMITH: Right. The ones in the handout were l g based on some working numbers. These are based on more detailed i , 22 numbers, so there are some small differences. Particularly I 33 think you're referrine to the exoosure levels. That's because ! L ! 24 the transportation and so on has been included here.
- .-_.,.-....~
.S,c g
(Slide.) e , s
!l h , i
113 - i b h ii V; We tried to use our technique for developing the
; ;4 it 2!l acceptable contamination levels in these example cases. Here !
h t 2 we looked at the PWR and we assumed certain things: certain j t i 4 inventories in the plant, residual. We calculated the allowable ! t 5 values here which would produce an annual dose to the maximum
)
6 exposed individual of 1 millirem per year. 7 This changes a little bit with time, just because g the makeup of the inventory changes. Similarly for the site, 1 ep we looked to see what the soil contamination would me. This
'a jo is cicocuries per gram of soil.
11 In the first case, we assumed that the material was 12 really not mixed; it simply was deposited on the site and i 13 l with nortal weathering was mixed to a depth of about a few l u ' centimeters . il 15 In the second case, we said, "You've gone in and l 16 l plowed up the place. You've tilled the soil and mixed all the i i 17 l stuf f to a depth of about 15 centimeters, so this distributes l i , 18 j it more thinly throughout. " ,
- n. i
" i j; h He also looked at this last case, the site case for 20 two different source terms. One case was a calculated source l 21 term release from a generic power reactor accumulated over 40 i 22 ' years , about 30 years of operation. NUREG-0218 contains data l l 23 i from all the operating plants, so we went through and looked j i 24 j at all the PWRs and structured a composite source term for ,
- _.4._ ,, . . e 73 this data. We used that in the samt calculation. You see there
,N n
I
.I ,
i e
114 :: 1 c i b l 3 are some small differences. After 100 years they are somewhat e 1' 2 m re widely separated. This.is due to the ' difference in the l
*i - radionuclide inventory we assumed and considered in these two 4
s ource terms . I 1 5 Now, these aren't very big numbers. You aren't ! 6 going to go out and measure any of these things with a hand-7 held survey instrument. I don't think there is any doubt.about 8 that. What one has to do is take samples and take them into 9 the laboratory and count them on fairly high efficiency, high l jolresolutionequipment; but there is no doubt.that you can measure 11 quantities at this level using available techniques. You could i I 12 indeed arrive, and be convinced that you had arrived, at a j i
, j3 contamination level that would be appropriate to this 1 manrem !
i _34 ; per year number. It's not easy, but it's within the realm of I I i 15 current technology, j 16 One of the problems with it, of course, is you have i to take samples. And how many samples do you take? } j7 How many ; i I jg jsamples is enough? That can go on forever. ; i
~~ '
19j The main point of this is it's possible. It'e < l ' 20 lachievabletoday. That may not be the number you want to work l lto,butyoucouldifyouhadto. 4 21 [ t I ' 22 (S1i00-) l , 23 t This sort of sums up what we think we learned out I
. t of this operation. '
24 We concluded you really can do it with.the Ac.Feoeezi Reporters, Inc. 25 [ things that are available today. The technology is at hand to l ' hl ,
t ,, 115 ., l i ,
-r ;
i I Il I
)
get the job done. j H Costs are certainly not trivial, but they're not 2
]l
- ' excrbitant , either, compared to the costs of building a plant. l l i
1 It's something in the 5 to 10 percent rate on the capital 1 5 market. 6 Occupational. exposures are not insignificant, but
.. not really exorbitant, either. If you look at 1300 manrem,
/
l that is about equivalent to the exposure of the people we'll ' E 9j accumulate at an operating plant in the same time frame, three , l n 39yorfouryears; so it's not all that different from operation. H jj The dose to the public is very small and came , i i p almost entirely from the transport of this stuff to burial , i 1
,a. crounds.
i ja l There were some areas where a little attention to f I i
)",
i l some fairly simple design chances would have made cost reduc- I l! I f 16ltionsanddosereductionsavailable, things that you can do in ; I h 37 [ the design of the plant when' you build it. Obviously, they l 1 jglj have to be things which are very cost-effective because you're
? '
39 1 making an investment now for the benefit of a time a long way i I 20 1 down the road. i 21 l There are a number of things that one can look at l i 22 here that would make decommissioning somewhat easier. By and j i 23'i l'arge , things tnat would be put in to reduce dose for the !
'I 74 ' c ecommissioning. people will tend to also reduce dose to the I Ac..s.o.< r,emn n, inc. g 25 P8f^tiU9 staff during maintenance operations, so these are o
H I I .
" 116 i i
i I
'N
[ beneficial all the way down the line. j
.)g ,
2 That's the PWR study. I'll entertain questions at I II ! 3
/ this point if there are any.
I i g Bill, do you have one? { 5 MR. BERNERO : Please use the microphone and identify 6 yourself. 7 MR. WOLKENHAUER: Bill Wolkenhauer, Washington 8 Public Power Supply System. s l 9 First of all, a question on occupational exposure. ; u
)g Do you have the equivalent information on the occupational *
))p exposures on entombment?
12 MR. SMITH: Not in any detail at all. They were 33 estimated based on looking at differences . We said if we don't !
)
)g .have to take off the reactor pressure vessel and all its
- i 15 l, internals -- we made certain estimates associated with that l i
16 job , and there is a reduction of that amoun t . I didn't mention ! l 37 j 'the reduction in the exposure for entombment, but instead of , 1 I jg]1300.andsomethingitcameoutabout 1100 because of these ~ v . 19 li things you didn 't have to do. 20 MR. WOLKENHAUER: Okay. The next thin c, has to do ' f: 1 21 lwith entombment. In the results of your analysis, I find it 1 I i ll 22 l kind of interesting that you don 't like entombment but you're l 23 , perfectly willing to bury things in shallow land burial . I f 2j find it hard to see the dif ference. Entombment might be a. ' t Am4eoera! Aeoorters. Inc. 25jlittle. safer. e)
! I t
l' ' . 6
117 l
".1 -
ii i l 7p secondly, it seems to me that your entombment i
- i 2 i !' pyranid, if you will, is balanced on the presence or absence I l' '
,l' of niobium 94. If the' niobium 94 in fact is not there, your i i
~I ' l' 4 curve would drop down at least another order of magnitude to ;
5 the nickel isotopa. I 6 My understanding is the niobium is assumed to be ! 7 there based on one measurement that you have which was made g i. by Cornell.
\
j 9 MR. SMITE: They made a measurement. I had a l
. 1 g ll measurement made locally at Battelle on a representative sample t it]ofstainless. There are also other data made in previous y 12 years.
; 13 l MR. WOLKENHAUER: My point is I talked to some
'I
;g ;j people that are reasonably familiar with that measurement u l I
15 ' technique, and apparently the technique itself is a point of l g ; discussion. 37 But my real question is, does the NRC plan to have l I gg ;a measurement program to determine the actual condition or i l-i 19 l constituency of the isotopes might be? By your curves some i i 20 of the Elk ' River material ought' to have a signif' icant enough. t i 7;i , exposure so you could go in and see what's there. . i I l t 22 MR. BERNERO: Dick, I'd like to answer that.
;3 A couple of things: One, the presence or absence
. i 24 ] of niobium 94. is, of course, a significant thing in this, and '
w.% s.:enn. :r.. ,i 25 [ we have very vicorousiv solicitec comment on that. I must say i i
.r l A! !
ti l H . i
l 118 . I I
- ! i d ! l
; we've gotten none. l l
l 2h Tnere are a lot of nuclear steam suppliers out
? ,
3 there, people who know, who have in tneir archives or one ! h l 4]placeoranother, the actual assay on core barrel shrouds and j I l ' 5 l pieces like that. We would very much like to have that. l, 6 We also have under way the supporting program at 7 . NRC which will be done on this very issue. It's a little bit i g . broader than niobium 94 It's a research program to evaluate 9 things which can be activated and produce noxious products, likel a g d the niocium 94. ' i 11 For the rest of you present who may not understand 12 some of this dialogue, niobium 94 comes from a trace element
;3 loracontaminant in the stainless " steel of the core structure, l
;gy the core barrel or shroud. It 's not the steel itself; it's 15 }l a material that's in the steel, and there is some uncertainty ;
16 .i about the actual quantity, i I 17 [{ People frequently allude to Dr. Pohl, Pohl and l 18h /Stephens, Dr. Pohl from Cornell, They were the first ones to ! I i f 39i my knowledge who focused on niobium 54. They did look into b i 20 the background. It's not'a stable measurement. I p l, i MS. WILLOUGHBYs Nancy Willoughby, Bechtel Power j e i l! ! npCorporation. l H d i
;3 [ Could you tell me tell me the dismantiement option, i
!i ,
72 li the plan that you studied, within major structures below grade? I i
#s.oy : n.comn. anc. ; .
23 ] MR. SMITE: We cisrantlec everything tnat was I h i el , i
, 119 ,
.I il +
1 1
)g radioactive. This included equipment and piping and so on
]
2 e d that was below grade. li I t f MS. WILLOUGHBY: You took out the piping that was 3' underground? I MR. SMITH: Oh, yes. - 5 i MS. WILLOUGHBY: This was included in the cost of y dismantlement? When you do the PWR study and you have something 8
, ,1 ike a suppression pool- 50 or 60 feet below ground, do you
' n..
g,ll plan to dig that out, too? ; 33 MR. SMITH: Assuming it's ccntaminated, which it I g undoubtedly will be, there are certain parts of it at least that will have to be removed. How muen of it vou have to take + 13 ,: -
- , 1 1 l i out depends on the penetration of the contamination in the l i
),
t
, structure.
- 15 k 1 16 j MS. WILLOUGHBY: But you won't have the same l
,_'ll a
activation problem that you have in the core. Couldn't you i g just entomb that part of the structure that is contaminated,
); or would you dismantle it completely?
l i t 20 i
! MR. SMITH: If we can remove the material, that's l
! i g what we will do. Whether or not you dismantle the structure l after it's clean is up to the owner basically, but one has
.4 l
l to remove the material.. The ground rules are that you remove
*3
. I i, ,
., d the material down to the acceptable levels, whatever that is, sp l ms een n,xnm. #~,sne. ; b e fore it 's relea sable .
lj ! V < i;
.i i b
d .
a 120 ; i' h i l ' i['q MR. SERNERO: Let me interject, please. There is l a dif ference between what the analysis should do and what the j 7
,'l I 6
t 3 d tradeoff that leads to the solicy or the regulation snould be. I 1
- i. i 4l The analysis shoulc calculate the costs of the !
I I 5 various alternatives so that we 've got the infommation to work i l 6 with. The actual decision of whether it would be permissible 7 to leave the suppression pool or sometning entombed or whether i g t we would require dismantling of it is a separate thing. l l 9: Basically what Battelle is doing is trying to calculate all the j o 10 ;j information, get it on the table in a reasonable, comparable l l 0 I 11 hasis so we can :nen co this tnoucn: crocess anc come to with l. 12 an intelligent choice. l l 13 So the f act tnat they would calculate demolition of i 14 a cooling tower doesn't mean we woulc require it. I just want i
! 1 1c to distinguish that. I, l i .
i i 16 MS. WILLOUGE3Y: And apparently you haven't made j l t t 17 l a cnoice yet? ! 1 l jg l MR. BERNERO: No. As we explained the program,
- 0 3; the Environmental Impact statement would develop cased on this 1
20 il information a policy and an implementef rule. l' ( , 7; l, MR. WAGNER: George Wagner, Commonwealth Edison. ! 1 22f. My question relates to the assumptions involving , i 23 , chemical cleaning or decontamination of the piping. !
. I I
74 { Number 1., did you assume chemical cleaning at A..s.em:nemnm.inc.,i 3 all during the 40-year life of the f acility? And, if so, , 3 b e i 6 h li i
121 1 0 l i i e j i D ;
;fhowmanycuriescidyouassumewouldberemoved'withyour 1 1 2 i econtamination?
i
, , Based on what we see on Dresden 1, I think you've '
l t l I 3 understated the cost of cleaning and disposal by about a factor 5 f 10. 6 MR. SMITH: We did not assume that the plant is 7 being physically decontaminated prior to shutdown. Incidentally', E we don't know what these residual activity levels will be like 1 9 af ter 4 0 years of operation. Admittedly we only have available ; ) g [i to us data from plants of comparable size tnat have been running gj for 4 to 6 years. 12 We essentially said, "Okay, this is what we know 73 today," and based on those kinds of major data we calculated i i 33 surface deposition and so forth, dose rates and cl1 that. ; I i , a i 15 If I remember correctly, the Inventory of the deposited ! 16 fission products and so on was really not all that large. It j j l 17 j was something on the order of 6,000 curies, which isn't very I i gg big compared to the stuff we're talking about on the activated l t I - I ps structure. ; i, 20 MR. WAGNER: We expect on Eresden 1 we will remove j
.)
e l3,000 curies, and that's after 18 years of service. We cer-l
! i i
l 22 q tainly con't expect the kind of cleaning that you assume, where 1 23 we have hands-on contact at dismantlement. I tnink your { i 24 , ultimate disposal costs will be much higher, because the Acu Jooer$ Resorters, Inc. gl 3- yradiation levels will be higher tnan you anticipated. i ! l h , i
122 i l u - l t 1 1 MR. SMITH: That's verv oossible.
- - On the other '
2 nand , you plan to start Dresden 1 nack up. l 0 '
-i MR. WAGNER: I'm just talkinc about the efficiency n
il 4 of cleaning. 5 MR. SMITH: The two go hand in hand. ' 4 6 12. WAGNER: What do you use for the basis of your 7 efficiency? MR. SMITH: This was based largely on historical E !. i I' data 9 for similar syste'ms. 9 10 l MR. WAGIER: What systems specifically? 1 11
; MR. SMITH : We decontaminatec, for example, the l
12 olc plutonium recycle test reactor three types. It is a ! I l 13 smaller size, 75, megawatts. ! ja By and large, we were able to achieve an averace i . 13 'l ce contamination factor of 20.
, They rac e from 5 to 1U0, i
16 ' cepending on wnere you went. i 17 It was on this kind of basis that we said we should i' 13 be able to achieve a factor of 20 with a decontamination l! Ic. ,; _c r o c e s s . i 2D ll ,- MR. EERNERO: George, I'd like to add scroething on l r 21 l!' that subject. I just had rome conversation with a subcommittee h Il 22 j of the Advisory Committee en Reactor Saf eguards . l i The point h I 23 has made there, which I think was a good one , that when you are ' 1
;g h decontaminating an operating plant with_ the intent of re-w s o,.
wenm. 3m. p' operating it , a decontamination factor of 10 is a goof one and ro f L a
g 123 u
! i
)! you remove.90 percent of the radioactivity as far as curies '
.C
,hareconcerned. But the ACRS was suggesting to us the fact :
I t r . 2 that we should give a lot of thought to recearch or investiga- ; I 6 5 ! 4 tion into procedures that will get a DF of 10 or 10 , some-5 thing like that -- a bucket of very strong acid, so to speak. j i 6 At the end of life, when you're not dealing with 7 the regulating metallurgists and everyone else who doesn't 8 want to burn the pipes up, you're not going to pressurize the l 9 system anymore and you're quite willing to De a lot more ; il jo g d rastic in your efforts to remove the activity. a You're ; 11 nterested a the last few curies. 12 MR. WAGNER: Then I think your 6,000 curies is much 13 ;too low, and your cost to handle that quantity of waste and ! i 14 { p rocess that quantity of waste are much too low. p l l 15 j MR. BERNERO: That's a good comment. I still i , 16o j maintain, though, that if you decontaminate to a DF of 10, !
' }
37 you've got 90 percent of the curies and you can do 10 19 and i i i gg only get 10 percent raore. } 19 p Are t'nere any other questions on the PWR study? l . 20 (No response.) l
- 7) Before we go on with the next presentation, I'd
( 22 l ust .like to make a quick reminder for those of you who may I 23 n ot have been here this morning. There is a sign-in sheet on l j 24 Ithe table just by. the door. If you haven't already done so, ! I .w.s.oc.. rs.mnm. inc a i 25 I'would appreciate having your name and affiliation, or you can ' 0 I 4 i
- i b ,
p 124 , ifd t
; leave your business card in a pile by the table.
- f. '!
xxx .! PRESENTATION BY DR. SMITH MURPHY ON THE FUEL ; eb l I i i 3 REPROCESSING PLANT DECOMMISSIONING STUDY. ! d ! 4 DR. MURPHY: The fuel reprocessing plant decommission!- 5 ing study was the first study that we performed at Battelle. 6 Much of the methodology-for these studies was developed in 7 that study. Bl (Slide.) l 9 In the handout that you have, the fuel reprocessing ol 10 ;j plant material starts on page 17, I think. It's a little bit ! n i 11 out of order. I'll go through this as quickly as I can, and i 12 I'll eliminate and omit some of the material that's in your j3 bandout. 34 This slide shows the Barnwell facility that was the i i 15 reference facility for doing the reprocessing plant study. The i 16 lareasoftheplant that were decommissioned were, first of all, i I l j7 the fuel receiving and storage station. It's up here. This
)g (isthepoolwherethefuelisreceivedpriortobeingcutup 1 l
j9u and dissolved. lf 1 20 The main process bu:1.cding, where the fuel is chopped { 21 ju p and is dissolved, froi the cladding and the uranium and i l 92 l plutonium are then separated from the solution. The solution 1 e,
;that remains that contains the fission and activation products 3 !
24 I is stored in underground tanks in this area here. We assumed Ap.F ec e's: R eporte's, Inc. [
. Ji n our study that there were four of these tanks that needed
..o c I il 2 ^ * '
a 125 ; 3 o O i
)y to be decommissioned, as well as this building here, the waste i H
2 tank equipment gallery, that contains the equipment for j v 3 4 contro11ine these tanks. l
\
l 4 .The Barnwell Plant does not have a high-level waste l 5 {solidificationfacilityassociatedwithit, and to extend the 6 I applicability of our study we assumed a conceptual high-level 7 este solidification plant which for our purposes would be 8
,.1 cated here. We assumed that that plant would also have to 9 be decommissioned, and then we decommissioned some auxiliary {
l 10 !l f acilities such as the la) oratory f acilities in this building, n 31 the ventilation supply building that's located right here, ! 12 and the main stack that's located over here. j i 13 (Slide.) ! i 14 The next slide shows the decommissioning modes for ! 15 which detailed cost and' safety analyses were made in this study. 16 4 We considered entombment and decided not to make detailed cost ! 37 l and safety analyses of entombment because potentially a lot i ( jg of the areas of the fr.cility are contaminated with long-lived j
- h- i l D
19 transuranic contamination, and for this reason we felt that i ! l I 20 we probably would not entomb the plant. We considered then fi 21 ,immediate dismantlement, passive safe storage followed by 22 &ferred dismantlement, and custodial safe storage followed by 4 23 deferred dismantlement. I 24 l The difference between passive safe storace and ! sa.nnwesnews.n.f 25 j e ustodial safe storage is really a matter of degree. In il ' h O ! t i
]
126 q y r if i e 1 l! passive safe storage you cuild more barriers. You disconnect , 4 i 2 g some of your systems, such as your ventilation system, because i c . you're going to put the facility in a passive mode. In cus- I 3 ! V i i 4 todial safe storage it's.in nare of a standby condition, and S the ventilation system is left intact. i 6 i For both the passive safe storage and the custodial
.i 7
storage modes, you have a period of interim care-- and we g considered periods of interim care of 10, 30 and 100 years -- eI and then finally deferred dismantlement. t j j 10] Immediate dismantlement is postulated to recuire, H 11 f irst of all, a 2-year period for planning and preparation, i 12 and this planning and preparation could take place during the i i l 33
- time that the plant was still in operation; and then a 5-year !
~ i jg ' period for the actual dismantlement activities.
l l i 15 For the safe storage modes, the planning and 16 g preparation period was 1 1/2 years, followed by approximately I i 37 a 2 1/2-year period for the initial decommissioning associated j
'16 with placing the facility in safe storage.
jp 1 . (Slide.) ; i 20 a l The total cost of immediate dismantlement was i 2,i i calculated to De about 67 million dollars. This was in 1978 i n 22 i dollars and includes a 25 percent contingency,
- p. ., This slide shows the cost breakdown for immediate i
74 dismantlement of a fuel reprocessing plant, Labor costs were ' w.e,wo, nwonm, sne. N; 25.cclculatec e to be about 32 1/2 percent of the 67 million dollars., 1
.u
g 127 i f il '
- i. .
; .The labor cost line is broken up into three segments by these 2
vertical bars. Tne first segment represents the labor cost 3; associated with dismantlement of the main process building. I
, The second segment of that line represents the labor ccst Ji 5 associated with dismantlement of the liquid waste storage tanks,'
6 and the third segment of the line on the far right represents
/ the labor cost associated with immediate-dismantlement of all g of the other plant facilities.
9 The labor costs include both the cost of the support ! 10 , staff and the decommissioning staff and all labor costs 1 i i
)) associated with waste management, that is, packaging cost, '
12 except the transportation cost. The transportation costs are 33 not included in the labor costs.
)g l You will notice that waste management is a signifi- i 33 cant cost item for the fuel reprocessing plant; almost half l
16 , the cost is associated with waste management. This is the j
> 1 37 packaging of wastcs, the transportation to a disposal siteg l {
)g )'andthedisposalofthewaste. I'll come back to this item i I
~
)9 on the next slide, so let me leave that for now and we will 79 talk about why waste management costs are so high on the next i
slide. ' 21 , l i i ; 22l Before I leave this slide, though, let me say just i 23 a, word about subcontractor cost. A significant part of the l 24 l chbcontractor cost is associated with knocking the plant cown See.FeoW Reporters, IN. i ! 25 ,after the rac,ioactive material has been removed from the plant, , ll 1 y n ll i
.. 128 t l_
0 i l
) that'is, plant demolition and site restoration . This is, of I
2 [ course, an optional activity as far as NRC is concerned, and l
- l n l 3 rh it was calculated to cost about 54 million. I wantec to point i a that out with this optional activity of building demolition 5 and site restoration, if that were taken out tne total costs 6 w uld be about $63 million.
7 Now we will go to the next slide and talk about g !vaste management costs. I 9 (Slide.) ' 10 Much of the waste that is ganerated in the dis-i; . 33[l mantlement of a fuel reprocessing plant is waste that is con- i i t'
;j taminated or potentially contaminated with significant quantities li p-of transuranics and would require deep geologic disposal. We !
! l 1 4 33 ! calculated that about 60 percent by volume of the waste gene- i Y
15 ' rated in the dismantlement of the plant would require deep I l l l i 16 , geologic disposal, and about 40 percent by volume of the waste i i 17 could ne disposed of by the shallow land burial ground. l t i 1 33 ; The cost of radioactive material disposal includes i j F i g " the cost of cackacing -- that 's the red bar -- the cost of i 20 transportation -- that's the yellow segment of the bar -- and 1 21 bthe cost of waste disposal -- that's the green segment of the \ i
,2 I l Daf' i
23 ll If you are sending waste to a deep geologic disposal,il
. !i '
24 [the packaging requirements are a little more stringent than they AM 5@F91 b KCMMI. 0T -4 , 25 hare for shallow land burial. We postulated that the deep li' i
^
l
i 129 ; I
'I il
)
geologic site was 1500 miles away and the material'would be 1 2 l sent by rail . The, shallow land burial site was 500 miles away and the material would be sent by truck. And then you have 3,l 4 the difference'.in cost between disposing of material in a 5 shallow land burial. ground and disposing of it in the deep 6 ge logic site. . 7 We have a pretty good handle on what it would, cost l 8 lt dispose of the material in a shallow land burial ground. We 9 do not have a pretty good handle on what it would cost to dis-pose of the material at a deep geologic disposal site, be-10 l
;j cause no such site exists. We had access to two studies that :
12 had been done in which deep geologic disposal sites had been 13 '. estimated and a third study that was in process, and we simply l 34 j used the average numbers that we got out of these studies. l 15 Admittedly, these are pretty soft numbers. Ther e 16 l is considerable uncertainty.as to what it really would cost I
)7 to dispose of something in deep geologic disposal, but un-t
)g doubtedly it would cost more than it cost to dispose by shallow h 1 j91 land burial. !
l 20 In any event, I simply wanted to point out with.this glslidethereasonwhywastemanagementcostsaresignificant is g that about 60 percent of the waste was postulate.d to require disposal at a deep geologic site.
~
23 The cost associated with.the 74 deep geologic disposal site is a rather soft cost. , 4 w.r.omianenm.inc.l (Slide.) k 25 i l ! il , ll . i
130
.'[
h 11
)
This slide shows the cumulative radiation exposure I to decommissioning workers and to transportation workers and 2} 1 3 l t o the general public from immediate dismantlement of the 4 4 r eprocessing plant. I I 5 If you add up all of these numbers here, you get ! l 6 the total radiation exposure to decommissioning workers, and 7 that turns out to bel 512 manrem if I've done my arithmetic g right. 9 The dose to transport workers was based, as it was 10 in the reactor study, on the assumption that the surface dose l
" l
- 3) rates at the surfaces of the truck or rail car are the maximum 12 all wed by regulations.
13 The dose to the general public is about half and
-j 33 half: half from the release during dismantlement activities l 15 and half from transportation.
16 In order to put the dose to the general public in I i l 37 lsome sort of perspective, we might indicate that for the same !
~
I > 16 I p pulation for which we calculated dose to the general public, l 1 39 4 that same population would receive a dose from natural background l 20 of about 10,000 manrem in a period of one year. 21 I simply want to say with regard to the dose to 22 decommissioning workers.that this dose, of course, was based on 23 the estimation of the number of manyears that it took to per- , 24 ; form the various tasks ' associated with the dismantlement of the r oom,w n.mnen. 25 L ix.( facility and also estimates of the radiat cn levels within the i
. l l . .
i
y 131 l
.l
) plant.
2 We estimated that 142 man-years would be required 3i to do the work of dismantlement. If you divide the total 4 manrem, 512 manrem, bv 142 man-years and convert that in man-l l 5 quarters, first of all, the average dose to a decommissioning ' l 6 w rker is about. 9 of a manrem per quarter. 7 (Slide.) 8 Now we will look at the slide which' compares de-9 commissioning costs for immediate dismantlement, and that's t 10 d this bar here, S67'million, with decommissioning costs for n il d eferred dismantlement after passive safe storage and for de-12 ferred dismantlement after custodial safe storage. l 33 For the deferred dismantlement option, you see we jg ! have three cost estimates. First of all, there is the cost 15 I f the initial decommissioning to place the facility in safe 16 ; storage. That's the red portion of the bar. Then there is { 37 the cost of interim care for 10 or 30 or 10Q years. Finally, jg the cost of final deferred dismantlement at the time that j;jyou'veactuallygoneinandremovedalltheradioactivity. We I 20 ' assume that the chemical decontamination activities were per-21 f rmed with the initial decommissioning so that they were not 22 repeated for final dismantlement,
,t 23 If y u place the facility in passive safe storage, j 24 you do some things that you do not have to do if you are placing!
to. send semmm. lac. d j 2e the facility in custodial safe storage; so the initial costs of C i
'l .
.I I i
132 il 0 I i
)
the initial decommissioning for placing the facility in passive' 2 s fe storage are about S2 million' higher than they are for plac-
,jl ing a facility in custodial safe storage. I 1 i l l i -
g By the same token, if you place the facility in j I l 5 passive safe storage, you build some barriers which must be 6 torn down so that you can get at the facility. You've dis- l 7 connected some services that have to be reconnected. A good l l 8 example of this is your ventila tion system. So the final dis-9 l mantlement costs for passive safe storage or for final dismantle- I i 3g ll ment after passive safe storage is about a million dollars higher il 11 : han it is for final dismantlement after custodial safe storage.j 12 On the other hand, the interim care cost is much i 13 higher for this mode than.it is for this mode , because interim ! l 34 , care following or during custodial safe storage is a hands-on ; 15 i operation. You've kept the ventilation system going, and i 16 there are a number of costs associated with interim care during ! l i 17 lcustodialsafestoragethatdonot exist for passive safe storage. i i i 18 The result is that after about 10 years custodial safe storage ! 6-- 19 costs more than passive safe storage.
\
20 l (Slide.) i 21 l This slide shows how the total radiation exposure 22 lfor immediate dismantlement compares with the total radiation 23 exposure for deferred dismantlement. Included here is the , 24 lie xpostre due to decommissioning operations. For the ac,Jeoce seconm. inc. y 25 0 passive safe storage and custodial safe storage options ! 0 9 I Il
133 , n i i D l F the exposure due to decommissioning operations would represent j in . i, the exposure for initially decommissioning and for fir.al 2l l i
, I: dismantlement.
~
Interim care exposure is shown separately. l, g ahTransportationexposureisshownseparately,andexposureto i I l 5j the general public is shown separately. 6 You can see that deferring dismantlement does result 7 in some reduction of exposure, especially to decommissioning g workers. I (Slide.) 9in In this slide we compare for the immediate dis-10 l
. 1,. .
mantlement and the deferred dismantlement options. We show ' 4 g ] the comparison of costs and exposure if a facility operator i l I g [ is going to make a choice as to whether to dismantle the plant i [ : l g immediately or defer dismantlement, or choose some other option.! ! 15 ;. There are various factors that he considers. One j U IT g of these is the cost; another is the radiation exposure. g9 There certainly are some other concerns, aspecially some l i g political and social concerns. There may be some concerns I 39 l rela Led to other plans that he may have for the f acility, but L yg at least cost and exposure are two of the concerns, two of the i, g{lfactorsthatwouldbeconsideredinmakingadeterminationas i
\\
g[towhethertodismantleimmediatelyortodeferdismantlement, , o I
..h,andnowlongtodeferdismantlement.
a x4 c 1 (Slide.) w .o . ne m n m inc.
.c.
.. This slide shows the calculations that we made P
j d,i
n' 134 4 I. I 1 d
'l I to determine the residual surface contamination level on the
)[d 0 l 2 f basis of a dose of I millirem per year to the maximally exposed l l
,hJ Incividual. We di.d this both for the facility and for the site ,' !
'i \
i 4l and we did thissfor various times after plant shutdown. I I 5 The notation that I've used here-- this number, i i 6 i f course, is 0.014 microcuries per square meter. This number 7 would be 0,:0082 microcuries per square meter, and the residual i
, < 1 g l contaminution levels were, of course, different for the l'
9 y f aci';ity than they are for the site because you have a differ-g j e c mix of radionuclides. Fu thermore, the various radienuclides li that you have present- decay with diff erent half-lives. For 12 that reason, the allowable residual contamination level changes , i o i 33q ', with time. gg Now the final slide, and we will be through with 1 33 this presentation. i ' (Slide.)
- 1 16j
;7 [ This gives our conclusions from the fuel reprocess- !
)g'ingi plant study. Some of these conclusions are the same as 19 s they were for the reactor study. ,
F. , 20 - Decommissioning is feasible with existing technology. '
- f. ,
21 l We did not postulate any exotic technology that wasn't at least , I i 22 } in an advanced stage of development, l f I 23 Certainly $67 million is a significant cost. The 7 [ waste management costs are the major fraction of the decommission- " w.5.c,<.' s,porieri. i nc. 73,ing costs, principally because much of the radioactive material u 4 ..
,, 135,
. ii I! i j , is contaminated with transuranics. It nas to be disposec of l 1 .
2 in a deep geologic disposal site. .! i L ! n , Decommissi6ning of the high-level waste storage 3 p! i a tanks is a difficult and costly activity. We postulated that ; 5 there was quite a lot of radioactivs concrete that had to be i' 6{ removed and a lot of concrete rubble that had to be packaged 1 7 and disposed of, and so one might think of ways to minimize l 8 n rete contamination, contamination of the building, by using 1 9 nore stainless steel in some of the process cells. ' t
)g y Remote maintenance would reduce cost and occupational! l
); . aposures to decommissioning because the remote maintenance ll 12 caoability could be used to decommission the plant. l j i I p~ , A low-level waste processinc capability would be i I
( , 4 I jaq advantaaeous in decommissionine the plant. s I 15 Compartmentation of the process areas is important j i 16 ' so that decommissioning workers could be working in one area i l
)7 without being exposed.to the radioactive contamination in the
)ghotherarea. !
i j9 As we saw in one of the earlier slides, there is i F I 20 lj a m dest occupational exposure reduction that results from
'l e i
21 l deferredI dismantlement.
- believe that's the last slide. I 22 ij j
l I 23h' MR. BERNERO: Are there questions on Dr. Murphy's j q 24 ll presentation? Ac..s.oroi senorrers, inc. 73 (No response.) r >
's
- H
, 136 h '
!i I e,i MR. BANCROFT: I have a deferred question for Mr.
2 J Smith,-if I may. I L l i i 3 You assumed good _ housekeeping in your study, and j l a I the history of commercial power plants is that they get dirtier 5 with age. The experience that we've had, as you said, has been so that there may be in effect increasing contamination 6 lshort, l 7 over the 40-year lifetime of the plant and an increasing con-g j tamination as the plants wear out. n i If 9 Also, your experience of good housekeeping and g eccidental contamination outside the areas where radicactivity l 11 , is supposed to be may be for government plants and the exposures I i 12 j and contamination from commercial clants mav be worse than I j n ! - , 13 ( g vernment plants , if you tnink of Surrey and Pilgrim and West l N : 4 I ' t
)g Vallev as comoared te Hanford.
ise i, - Have you taken these factors into account in talking,i 16 about a 40-year pressurized water reactor? a n' Secondly, how much variation do you expect from l
)
gi' your reference plant to the dirtiest actual plants? l 39 , MR. SMITH: We didn't directly take that into account, h i b i - 20 c in determining the estimated occupational exposure, dose rates, I ' 3 ! 21 d that would be prevalent in various operating areas of the plant, i l
- 3. 2 , We went to a number of reactor sites and gathered '
l' yy; actual measure information and made our data at those rates 24 , when we were observing all the various processes, and we con-An4mys' Arporwrs, inc. p 1 i 25 ;, structec a composite of some six or seven plants , all of which , a i l I l '. t i
.n ,
' 137 l
; ! have only operated for four to six years.
2 i I don't think there is any way we could project li 3 0 that efficiency. We simply said that this is what we know i 4 today. It may be worse down the road. We don't know how much 5 l worse, and we'ra not going to guess. . 6 MR. BANCROFT: So you haven't taken any account 7 that the plants get dirtier? B MR. SMITH: You want to keep in mind that the 9 , operator of that plant has to operate it. Exposure to his , 10 [ operating people is a very important thing to him. These guys i l
- 1 ' are highly trained. They're difficult to core by and keep, 12 and you've got to keep your exposure levels down in some viable f '13 range. They indeed keep their levels down to something they
); can live with, whatever that is.
15 MR. BANCROFT: Let me ask, to put that in perspective,, 16 ;what fraction of the cost and occupational exposures result 17 jfrom unplanned contamination of parts of the reactor site as l l 33 compared to the core areas, which are going to be contaminated i i ~ 19 ' in the normal course of events? 20 MR. SMITH: We didn't assume anything about un- l
,)
p lan'ned contamination. Many of the buildings, the fuel build-i < 22 'ing, auxiliary building and so on, contain large amounts of 73'conteninated equipment, materials and so on. i 24 'l MR. BANCROFT: Wnat about hot spots in the concrete? Am FewC Rournm, lac f 25 j MR. SMITH: You're talking about outside the l I
'h
?
4 ' il i
n-138 l il II . j buildings?
.i ,
2 MR. BANCROFT: No, inside tne building. It leaks 3jv in the co.2 rete, or contaminated areas of the steam generator l. I 4 from leaky tubes in the steam generator, things like that, j 5 MR. SMITH: We made the assumption that in any 6 areas wnere there'was a reasonable potential for leaks of con-7 taminated fluid that they had indeed leaked and we had to I l I rem ve certain quantities of the concrete from these areas. 8 , I i 9 MR. BANCROFT: When you say "certain quantities ," i l
, 1 1
10 what percentage did those add to the cost and radiation l I
;) ]er.posurethatwoulchaveresultediftheplantshadoperated ,
I i 12 ideally and only the parts that were supposed to have radiation l i 1 1 p- , h ad it? ,' l i
) *, ;
MR. SMITH: I can't answer that in detail without 15 ; going back to the details of the study, l 16 MR. BERNERO: I think if you go into the study and i j7 look at the core removal breakdown -- tnere is a viewgraph., l i g j as I recall it, tnat he has which breaks down what it takes l 19 to get the core barrel and core snrouc, the reactor coolant ' I ; 20 l system out and just say that everything else is virtually j l' 21 l u nplanned leakage. You could probably get a fair estimate of I l
\. ,
,2 ; it. :
. i .
f m u !. Do you have something to add to that, George? l 73 j MR. WAGNER: George Wagner, Commonwealth Edison. ' AceJeoeret Amrters, Inc. ; 73 In the interest of perspective also, based on 18 i:
d
" 139 ,
3 a i 1 3 l years of operation of Dresden 1 and the slowly rising ' radiation ' il - 21 levels over the life of the plant as compared to increasing l radiation levels on Dresden 2 and 3 since 1970 and 1971, we I a see no accelerated rise over time. It's a pretty constant 5 slope, over the life of our facility at least. 6 As you indicated, we have to operate the plants; 7 we have to maintain the plants. We have certain surveillance 8 lwehavetoconcuctinaccordancewithourtechspecs. We 9 have to put the plant on some kind of mid-life chemical clean-i 3 1: : jo f; ing of the piping. We've done that for Dresden 1. We're try- } n ing a dif ferent 11 processfor_Dresden2thatwillmaintainlevels{ 12 at some acceptable level. 1 33 That's why I question whether or not your data y assumed any mid-life cleaning cx: not, because as a practical t' I 15 matter there will be removal of accumulated crud over the life 16 l Of the plant just to allow yourself access to the plant. i j MR , SMITH: I 17 Yes, but so far that hasn't been demon- j
)g strated. You're in the process of attempting to demonstrate l- it now, !
19 j
- f 20 MR. WAGNER: I hope we'll have that in May.
21 I MR. BERNERO: Before we go on, I would like to go I l l 22 lbacktoDr. Murphy'slast slide. There is a conclusion in I 33 there in that last slide which was the occasion for a remark i 24 Mr. Newman made earlier in the-meeting that many of you mav z u.ser.: Ruonm. inc. c ; 2S[not have understood. ; 4 4 l- .
140 4 . t i d l. P
)y If you look at the decommissioning study for the 4
7 l fuel reprocessing plant, one discovers that the high-level 3l liquid waste tanks', the stainless steel tanks buried in the I 4 ground for temporary storage of high-level waste, are an
} extremely costly element, both in dollars and in manrem ex-i 5 <
6 Ip sure. 7 Mr. Newman suggested the option of entombing those g ; tanks as a comparison. Yes, that is indeed a comparison, ) l I 9 but they are perhaps an interesting example of design to l l jo facilitate decommissioning. l 11 f A thirc option that is not mentioned in the de-1 12 commissioning study, but it's a real option, is don't use the 13 i tanks. t In the fuel reprocessing technology, where it stops l i i
;4 ! at the point that President Carter set national policy not i
r i i : 15 Ito use it, it's interesting to note that a number of fuel l l ' 16 l reprocessing plant designs , includinc the remodeling of NFS, ! 17 the Exxon Plant and the G. E. Morris Plant, none of them plan 1 j ig ;to use such deep tanks. i
+
19 ] < It just points out a factor that I think is sig- l 1 20 lnificant in sorting out the whole decommissioning question. l 1 21,! There are both small and large factors that will come out of i 22 ithis that are useful in the design to facilitate decommissioning . 23 [( to reduce both cost and exposure. !
- i. t.
2[ What I woulc like to do -- perhaps you would like l ra.ser i nnonm. mc. h ;
;3yte stand up and stretch a little bit. We're at the peint where i.
s li ' ,
141 ; ti ! o ! I a :
;h we normally would take a break, but I hate te lose the time. '
ll 2d I'd like to go through tne questions again, anc l h -
" I 3[ this time I'll give you a personal opinion of what I perceived j I i at the State Workshops. And then I'd like to deal with the 4 l I
5 questions in subsets or small groups of topics and invite your l 6 comments from the audience, from the public, from industry, 7 for whoever you speak. g ( Slid e . ) l , 9jIIo In this set of three questions, 1, 2 and 3, which I
!i 10i j basically speak to this waole approach,what we 're doing, ,
h 11
' this Plan, witr a capital P, we discussed this with the states.
12 With the whole number of interpretive comments, 7, ! the general impression I got was that the state representatives ' i t 1 i 34 livolved thought that it was a good and reasonable approach, 13 !that they were being given ample opportunity to participate in l 1 i
~
16 the program and to get their acvice heard at a fruitful time l I l 17 l and not wait until the end. l l l gg l Tnere were many, pointed comments about the need for l r i 19 [iNRC to take care to distribute the materials to the same i
~
i 20 people, to the right people, to coordinate the distribution l l 21 of the material or materials in such a way tnat would cive the i
! l 22 , name people an opportunity both to review the material and to l
,, ;l discuss it among themselves before coming into the next work-h 74 ;, shops.
4 Ace.Feoecal Reporters, Inc, h 73 y In general I came away with the impression tna: this h y '. hl 8 f
P 142 i h I.
'i I
' h ;
) openness, getting this advice now is useful, and that struc- l 7 l tured in this fashion we will be getting information, getting I
advice from the states in a constructive fashion. B i Do you have views on this? 4 l l 5 MR. SCHENDEL: Karl Schendel, Wyoming Mineral. 6 One question is, in your dealings with the states, 7 was your emphasis on the reactor facilities and high-level g waste to the extent of this meeting? 9 i Phrased maybe another way, are tne state people i je fj grasping the application of this to those 20,000 -odc materials ! c 11 ! licenses, most of which, half of which possibly, are in agree- , h 12 ment state hands? I j3 MR. BERtTERO: Yes, they are. There is a tendency j l 14 ; in this whole topic to concentrate on the big buck item, * ! i lj reactor decommissioning. Tnere is a lot of attention to that 15 l t : 16 ,and a need for it, but the states in particular are very sen-i i 17 jsitive to the material license question. !
)g ! They actually license the majority of those, and 19 ,they are a continuing concern for the states.
i So there was a l l l l 20 j great deal of discussion of material licenses. ; I ! l 21 . s The state people did acvise us, or some of them said j t 1 I 22 that we should look more closely at such facilities for cost, l I ' 23 [ technology, feasibility and so fortn. It's not hard to see, l 24 l1 f you look at our program, that Plan, that what we are looking u.a.o,,. necom inc. 4
;3 ] at is the reactor and the uranium fuel cycle.
They were in fact, bi 0
.I H
9 143.l y ti ii 3- , saying, "Get off that point. Go loon at something else, too. I
, 2 ! Look at the other facilities." We may restructure somewhat 3, to meet that advice.
I 4 Anyone else? 3 LNo response . ) 6 Now, if we turn to the next questions, I'll take 7 Question No. 4 first: Should detailed decommissioning plans g be required' prior to the issuance of a license? 9 The impression I got from all the discussion -- , il je l and there was much discussion on this --- was that no, provided l i:"
;) that there was good assurance that the technology is available 12 and enough confidence or a bounding method was established to 13 have a good handle on the cost so that ene could be assured ,
ja that if funds were set aside for that purpose, the funds would 13
'I be adequate for the task at hand. In other words, one woulcn't 16 set aside a funding mechanism for the least expensive alterna-i
.j 7 jtivewiththeexpectationofgettingdownthereandthenchang-{
i l
)g ing their mind and going for the more expensive anc saying, j
); l" Gee, I'd like to do that, but I don't have the money." ;
I 20 So the general comment was that there ought to be l 1 l ' 21 .en ugh understanding of it, enough in the way of generic plans 22 'or generic analysis or whatever, to be able to put a good 73 price on it and to put a reasonable bound on the technology 0 7ay and nave the confidence it could be done, that that would be res.s.er,, newnen. Int ., 2e ] suf ficient. n f ' E i e
)
144 ,- pd i: ' il
)
Do any of you wish to express your view cn that? ; 2 MR. BLACKMON: Don Blackmon, Duxe Power Company. f I l' 9 i Was there any comment at the State Workshops about
~l 4 multiple-unit sites or shared facilities between joint 5
reactors and how that is going to be factored into detailed j 6 decommissioning plans or technical reports? 7 MR. BERNERO: There was a discussion of that. 8 We'll get to it, and planning and timing, the very next 9 question that would come up. I jo The discussion that I heard related to the concept ji of dealing with the site as a whole, dealing with, like your i 12 Oconee site: don't deal solely with Oconee Unit 1, but treat ( l j3 r the whole site; handle the whole thing with Oconee 1, 2 and 3 )
\
gg at an appropriate time. 15 There was discussion that that was the right way I t i 16 to do it rather than slavishly following a decommissioning i 37 l schedule for cne in-absence of the job or just before the job i l i i jg jfor the other facilities on site. You could call that site- l i ~ 19 F related decommissioning plans rather than unit facility de- !
' I 20 } commissioning plans. l A
y) { I would say that NRC would most likely treat it that \ - i 22 jway, not treat it facility by facility but, whenever a facility 1 23[ is added, to reconsicer the whole site plan. That's probably e 2a Lhow it would come out. An smo.: sewnm. ine. !i : 25 [ MR. BERICE : Dave Serick with. Environmental Policy i n L ll
145
'I.I I, l
1]~ Center. 1 , 4 l 2 l! I'd just like to comment here that there are other l l I 3 r outes to go besides the detailed decommissioning plan -- not l 1 1 4 just design a. 2ctives, but I'm sure, as Commonwealth Edison is l l
~
5 finding out and Nuclear Fuel Services in West Valley is find-6 ing out, tnat there is a lot of experience developed during l 7 the operating periods of the plant that will in the long run 8 ' benefit any eventual decommissioning process that taxes place. 9 There might well be types of decommissioning plans or types of > 10 l decc=missioning specifications , such as housexeeping, record- ! 11l Keeping, and plant decommissioning practices and experience 12 that develop along the way tha't should be worked in to a formal; i I 1 13 c ecommissioning outline , perhaps. ' 14 MR. BERNERO: Let me speak to that issue. It's a ; i i 15 ' very uood point you raised. i i 16 l! One of the things you won't see explicitly in these i 17 lgeneralpresentations,thereisdefinitelyathougntwithin IB the NRC Staff in doing these studies: it is abundantly clear
-. l ,
19l to us -- it has been clear in every cecommissioning job that I I 20 we know of -- that the people doing the work find actual 21 lj information about the f acility extremely valuable , information 22 l like exactly where tne reinforcing bars in that concrete wall t 23 i.are, where do the. pipes run, is there a dog leg in the pipe, 24
.i and if so in what direction and 30 forth.
A .serm enenm. ine. fi ; 25 We're considerinc the develonment of a Reculatory o ' c , 4 t l
- 6
146 i. j t Gul.de perhaps, some mecnanism whereby we would assure that cooc i t t y 11 2 n
? construction photographs, as-built construction drawings, l l ti
,3
!!i what you might call a good decommissioning file, is established .
q a i acring the plant life and is kept set aside for that purpose 5 so when tne time comes at the end of the plant life'you've got 3 these records in good shape. j 1 7 Right now West Valley is going through that very B j rec rd survey. Fortunately, so far it turns out to be a very 9 l good one -- the recorcs are good. I think we ought to make ,
)
l l jo j sure . that they're good with some-sort of regulatory method. i' 11 Ms. Johnsrud. , 17 DR. JOHNSRUD: I think I would have to take exception l 33 with tne general feeling expresssc at the previous meetings { ja [ that detailed plans in advance of the license aren't necessary,j li ! 15 We have recently in Pennsylvania found a pronlem l ll I i i 16 (1, with a facility at Mechanicsburg. Rather than the company 17 l that was responsible for the inadequacy of disposal at that i l l l 13l site paying the cost, those costs have now, as the result of i o I ^ 19 e a recent passage of the Mill Tailings Cleanup Bill, neen loaded I i 20 j on the taxpayer. a l 1 21 We do feel that these costs, full costs, should be ! i i
}
22 j assessed to the utilities and the other licensees, and there- j
! l 73jfarethat tne detailed decommissioning plans not only be based f N, ,
24 4 upon existing radiation standarcs but upon very conservative l l
- Ace.Feorest Aeoorters, Inc. .
23jestimatesthatallowforpossiblechanges strengthening those h J i q g N
il 147 , y e l
; standards in the future. Within, let's say, a 40-year lifetime 2
that we're talking about, that snould be incluced. l 1 I ! i 3l MR. BERNExO: For those of you who are not familiar l ! I I 4 with~ Mechanicsburg, Pennsylvania, there is one of tne so-called l l l 3 acandoned sites or remedial action sites in the DOE program. I 6 It was an old facility for* processing uranium and' radium ores. 7 Are trere any other comments on that particular g question? I
, 9l a MR. REYNOLDS: NicX Reynolds, Debevoise and LIberman.' i l
10 I think the speaker is confusing detailec technical l 1 11 ' decommissioning plans prior to licensing with financial- ! 12 assurance programs. I think maybe she ought to expand on that 33 a little bit to clarify ner statement. I jg MR. BERNERO: Ms. Johnsrud, would you care to ; i 15 i comment? l 1 h 16 DR. JOHNSRUD: From my point of view, the financial l I i i7 ldommitment for the future is in fact going to be very closely l 13 ,, related to the technical details of the decommissioning plans; !
~
19 " therefore , those do need to be spelled out in advance of the f 20 1 issuance of the license. ! i I
, MR. BERNERO: In effect, if I can put words in your e1 !
22 mouth perhaps, one must set down sufficient detail to have the i J 23 p assurance that tne responsible parties have the task bounded, i {l i . 24 have sufficient resources identified. 1 ' A M.F e ers Ahorters. inc. f ( { 23 DR. JOHNSRUD: And adequate conservatism. g . f ) l
3
' 148 -t 1 !
- i 6 7 3
MR. BERNERO: Yes. The principal dif f erence between ' , n - 2 h unit I heard at the State Workshops and what- you're saying i I ' 3, seems to be in setting a margin, what you micht call an un-l- a certainty margin, for the potential stiffening of residue ! I i 5 standards or residual activity standards, or occupational : 6 exposure standards, whatever. 7 MR. REYNOLDS: My response to that would be that g existing NRC regulations and guidelinas already require that 9 l kind- of detail to be provided prior to licensing. 1 i jo DR. JOHNSRUD: Do the existing NRC guidelines and ! a, I 11 regulations anticipate a more stringent worker and public i , t 12 exposure standard in the near future? 13 ;, MR. BERNERO: No, they do not. i 14 DR. JOHNSRUD: Thank you. l 13 MR. BERNERO: Okay, we'll go on *.o the next ques- l 16 , tion, delayed decommissioning. : i . 17 As you saw from the tecnnical presentations, it
, f 13 I looks like. on zaactor decommissioning racioisotope decay and i
19 ! !, some reasonable management of money would make it worthwhile I i I 20 to wait about 20 or 30 years for a substantial reduction in i I 21 l exposure and a little bit of financial leverage. If you I i
;; 'present worth it, as was shown in that one viewgraph, the 542 '
i
;3 l 'million becomes a present worth cost of a little under $20 I
2 [million. Ac. 5coc+ wonen. anc. o
;54 In general, there seemed to ce an expression -- or i
I! t , U
149 ; d o F 1 again, . I must emphasize this is my personal impression of ! c I 2 h wnat I heard; it's not a consensus. There seemed to be a E s l . 3 Il general comment that yes, it would be justified, delay is ! 4 justified; but there seems to De an underlying apprehension ; 3 about the possibility of default, and there is a cig' differ- ! 6 ence between the delay'in decommissioning Indian Point 1 while , 1 , 7 you're waiting for the useful life of Indian Point 2 to be j- E exhausted as against the delay in decommissioning a facility j that's all by itself, that is idle, not an income producer. 9 7 F j gg I perceived from a numoer of people their concern { L 4 a to be very careful about delay when you're not sure the company ; 1 11 1 i 12 will stick around. We all know many stories in that vein. p- ; i But delay tn decommissioning where it will achieve F
~
i I ja some reduction of exposure in a reactor seems to be clearly ; 4 l i 15 { acceptable. { t 16 i t When you come to a fuel cycle facility or reprocess-i I 37l jag station or material nandling station of some sort that's j i l dealing with very long-lived activity, tnere is, a l t of c .rse, 15 ! '[~~ 19 i little incentive to celay decommissioning for radiation 1 20 exposure because that stuff isn't decaying very rapidly. i ! 21
!P.eally ne is left only with.the financial incentive, and there ,
i i i I ' 22 1 doesn't seem to be any enthusiasm for delay to save money. d t 23 So that's the perception we had, or that I had. I i 24d' Does anyone care to comment on that? l 3..Fe-w sworws. w.j i . 25 :, (No . response . ) ! i
' 1; .
i I L i
1 l' - 150 .; ;
- l l !
i Then we have the ciscussion of Questien 6, entomb-2 ment. It goes without saying, from the presentations you've
- 1 3 heard and from questions and answers, entomDmentisadifficultl 4 question, f
5 Tnere is almcst an infinite family of entombment 6 possibilities. The. State Workshop representatives, from the
.l, 7 whole spectrum of people there, not just the technical types 8 but what I might-call political people, was that we definitely l .
I 9 needed to present a lot more analysis on decommissioning ; 10 [ alternatives with respect to entombment than we 've done so f ar . ' O 11 And we take that as a given. We are looking at i 12 entonoment. decommissioning, and in general there was no endorse-13 ment of.it as the rignt way to go, or rejection of it as the t 14 wrong way to go. i l i 15 There was.the general acvice that we've got to l 16 l analyze it further in order to make an intelligent choice. t
- 17 Would anyone else care to comment on that?
18 MR. STOUKY: Jon Stouky, NUS.
~
19 Did a.iy of the states find themselves in the position i 20 of saying, "If there is some economic incentive to the state, i 21 keep it there; we'll look more kindly on it"? i 22 MR. BERNERO: It was more in the vein of saving !
.23 an unnessary cost. When it got into reactors, I heard a lot 24 ( o f people saying, "If you can save a lot of radiation exposure
. A..re-r n.normi.ix. i
, 25 'for workers and at the same time save a lot of dollars for the ,
! 4 t
b il 9 s . - , , , , , ,
j 151- ; 11 ratepayer, it is a power plant site. If it has enough acres, l l 2 entomn the thing and go to the next one next to it. That site is not going away." 3 Tnerewasalotofdiscussioninthatvein.lt ' 4 And then there was a comment about the highly j i i . 5 radioactive pieces of the reactor ought to be treated perhaps 6 totally different than the rest of the plant, which is typically 7 lower types of radioactivity. g MR. STOUKY: I was thinking more in terms of -- as 9 1 recall in the case of Elk River, there was a lot of talk . i 1 10 I at the time it.was being cecommissionec that if they were ' h ii 11 ' f orced to leave it in Minnesota its presence, not as a 12 cenerating station but its physical presence mignt be taxed, that' t 13 ! the owner of it or the owner of another facility in Minnesota j
-i ,
-I i la ! might be forced to pay and not recover some kind of a tax.
15 ! MR. BERNERO: I don't recall anything in that vein , l 16 in tnose discussions. Ms. Jonnsrud, do you have something? I 17 l I 18 : DR. JOHNSRUD: Two points, and then I'm going to i 19 ' have to leave to get my car out before it gets towed away. ! , i i I 20 In response to this particular question, I'd like j l i i 21 ' this record to include the attitude that was expressed in the ; i l 22 DOE hearing in West Valley, New York, with respect to entomb- l I 23 ment as opposed to other uses, various options, for the West . l 24 Valley site. Ace Federef Fieporters, Inc. 25 Tne position was very clearly stated by public
i 152 ] i i i 1j interest organizations tnat they felt tne West Vallev facilitv i j 1 ! l 2 provided an extraordinary opportunity for demonstration of l l l ! 3 full decommissioning, full decontamination and return of that j j 1 l 4 site to totally unrestricted use, j i 1 5 Certainly the people in that area who expressed l 1 6 themselves at DOE's public meeting -- for once NRC wasn't on 7 the firing line -- seemed to feel that leaving a site in.the 8 radioactive condition was not an acceptable alternative. 9 I would like, since I do have to leave, to address i 10L Question 9 vary briefly, if I may. U
'l l MR. EERNERO : Feel free.
12 DR. JOHNSRUD: With respect to a maximum dose rate t 13 l of 1 millirem per year to an individual after cleanup, I would i l 1e Like this record to show that public interest organizations ! i 15 do not feel that anything other than zero dose, zero release, ; I 16 is acceptable. 1 17 MR. BERNERO: When I get to that, I will characterize l 1 18 j a response I got from the states. Tne general response was ~ I 19 that tnat's too low. i 20 DR. JOHNSRUD: I would expect that response. 21 MR. BERNERO: They said we should use something ! I i 22 nigner. 23 ; MS. WILLOUGHBY: I would like to comment to Ms. i 24 ; Johnsrud before she leaves tnat in that case we woulc have to maa.o. . Aemn n. inc. 25 j decommission Grand Central Station, necause that does not
, i i
i
153 - {- i t 1 comply with that from the radiation levels of granite. f i 2 DR. JOHNSRUD: Grand Central Station is not a i
?
3 nuclear fission facility. a MR. BERNERO: Are there any other comments on the I 5 entombment question you would like to have registered? : 6 (No response.) 7 (Slide.) 8 Now we get to the cleanup criteria. Tnis is the 1 9 non-nuclear decommissioning one. 10 t_ Tne very, very strong impression I got from all i 11 1 ne subgroup discussions was that non-nuclear decommassioning, i 12 or what I like to call non-nuclear -- it's non-radioactive l 13 6 ecommissioning, was none of our business, none of NRC's i 14 business. + i I i 15 l In general the state positions -- and you will see l i i 16 ' tnat when the report is publisned -- are in terms of once , 17 j the radioactivity is removed to safe levels it's a local land 18 ; use question or a local f acility use question, and whatever i 1
~~ ',
19 ' should be done with cooling towers or empty buildings o' ! 20 warehouses, structures of one sort or another, is a matter 21 tnan'can be handled'by local authorities through the conven-22 tional taxing mechanisms and other means -- a very, very strong i 2
, impression that we should-just-witndraw from any further con-23 .
'I J
24 [ sideration of non-nuclear decommissioning. l Ae.4.e ,w s m on m .in:. 25 i Does anyone care to comment on that or add to it, ,
- i. i b
154
.i
!! I.
.n
)
subtract from.it, deny it? I
- 2 (No response.)
{
, [l Number 8. I'm very troubled-Dy the response I t
i l L
,{ got to Number 8, because in essence I told the state people 1
5 that's not so much a question as an exnortation. Unless we ; 6 i can intelligently reach a consensus on what those cleanup 7 oriteria are, we may be poles apart on tne very meenanism of g decommissioning and'have very, very serious problems. I oy And I neard an awful lot of reate people say that
'n H
3e states' rights are states' rights. They woulc say yes, it 11 would be a nice thing to have the same standards, but the 12 , states must reserve the right to pursue their own course. I 33 , If anything, the perception I had from the State i 14 Workshops is that it is not assured that we would be marchinc, ' 15 i in step to any great degree, althougn there was a great deal j 1 16[ofdiscussionandactivityincoordinatingthiskindofwork I , r h I 17,for radioactivity cleanup criteria with the National Conference j r I gg of State Radiation Control. Program Directors. Tnat's very I 19 : active right now. '
! I I i 20 ;j .
Would anyone care to comment on this one or c,ive I 4 I 21 ! us some further advice? l 22j (No cesponse.) f I.) i' 23 [ Going on to the next one, the maximum dose rate of 24 millirem per yet2. I was struck by the fact tnct a number I
- w.p.o,,e n.ponm. inc. '<
23 of times people in the State Workshops would say in these small y i-i g .
.S l
, 1 155 '
I i I l
) lgroupdiscussions--theywouldstart their remarks with )
1 i i 2 something like, "I am not an expert and am not qualified to 3 judge and I have to defer to experts in this, but that seems 4 Aike an awfully low number, an awfully small number, to me." 5 And there was an awful lot of discussion about its measure-6 ability or its practicality, i 7 In general I came away with the impression tnat i i 8 the state acvice was, first of all, on facilities that number 9 is too low; it snould be a higher number. No specific advice 10 on how high. Especially in tne western states , where tne 11 people are a lot more f amiliar with uranium mill tailings and ' 12 ore bodies and things like that, there are a lot more soil l i 12 scientists there. There seemed to be the feeling that that ! 14 number.or anything even remotely like it isn 't even practical ! 15 for soil cleantp, tnat we ought to take a different approach i 16 to this. i 17 l Does anyone care to add to that or comment on it? I i i Ig MR. BLACKMON: l Just one comment concerning Questions l __ 1 19 . 8 and 9. !, 20 Do you think the nontechnical people in the state i i l 21 Work' shops possibly were confused'or were scared to death with ; l :i 22 the 1 millirem number , that that would be developed as a cri- l 23 recria or woulc be hanced covn as a standard rather than a criterion and the states coulc not go under it? 1 24 I ACP.Fede*Qf f%fp0FTtf5, if4C; I 25[ Obviously, you can't measure 1 and you can't measure l t I! II o - l-i , I
j 156 - l t ' 1 , less than 1. I just wondered if there was an anteraction i 2 between those two questions on the part of the nontechnical l, 3 people. 4 MR. BERNERNO : In my own view, I con't think there l i 5 was that sort of interaction. There was a lot of ciscussion ! , 6 about the measureability or practicality, but I didn't see l 7 any interaction between the two questions as to "If you set i l ' g yours too low, we can't be more stringent." I didn't detect ! 9 any of that. - 10 There was again and again repeated advice: " Deal 11 with our experts." i 12 Does anyone else have a remark on this? l 13 ; (No response . ) I 14 l Let's go to the dollars. , l e 15 ] (Slide.) j
' l 16 The first question: Wno should pay?
i 17 There seems to De a consensus of opinion -- there 18 1s no question -- it's a cost, a routine cost of business, t 19 which should be transferred in an orderly way, in some way i i 20 jpassit on. I 21 l
, For rate-regulated electrical utilitier, there is l
22 a consensus that they should be passed on to the customers in 23 an orderly way. In other facilities where you don't have a , l 24 i regulated rate structure -- you have just the conventional w.r.o.,.: n none,s. inc. y
;$ llp rice setting by the vendor -- there it's the sort of thing b
i! H u
; .167 i
) b{ that should enter into the business planning and be passed on :
6 r 2 to the customer in some way. j I i 3 If a performance conc is necessary or an escrow i l i g account is necessary, the mechanism would be there to do so. : l l 5 On Question No. 11, shoulc financial responsibility j 6 requirements be imposed by Federal or by state, there seemed L 7 to be a general comment that the agency which licenses a facility a j should impose those responsibilities, j i i 9 It souncs like a very neat thing, and then all of j 10 a sudden, "Except . . . ." For reactors, tnere seems to be a 11 verv stronc cesire of the states to set the financial resoonsi-1 i 12 bilities and to control them, but there is a recognition that , i 13 .it's full of holes. A lot of reactors are either partially t or totally outside the state regulatory authority.
~
14 TVA is 15 not regulated; WPPSS is not regulated; tne municipals are not , I I 16 ' regulated; the wholesale for retail utilities are not regu-I l i 17 ! lated. There are so many loopholes in the state jurisdiction ! i 18 , that there's no question about it, so there is a difficulty l i, 19 ;m that regard. , i ! l ! 20 l Many people there were saying thincs like, "It would' l' i 21 ' be nice if the Federal Government had some good hard guidelines 22 l or f all-back position so there would at least be an underlying l l 23ll pattern of appropriate financial performance." i 24 Did you have a question, sir? ! Awamroi nnnnm. inc. ' 25 j MR. MORGAN: My name is Rufus Morgan, Southern 1 i
. I S -,
158 j. i i i 3g Company Services in' Atlanta. , a s I've ust found out that an amazing thing is 2ha 3 happening to some electric utilities. For instance, you
, rentioned the f act that on Millstone in Connecticut they had 5 been allowec the decommissioning costs and in Massachusetts '
6 they hadn't. You're correct: it's 10 percent of the cost in J Connecticut, and so far it's zero, or they're kicking it I g around, in Massachusetts. 9] But the FERC, just within the last few days, has ! I l 10 h passed down a preliminary decision by an administrative law judge which goes to mothballing. 3g They allowed Connecticut , l l 1 l I 12 l Light and Power only 3 percent on Number 2, which is a S450 ; 33 million plant, and 10 percent on Number 1, which cost them l jg ,$120 million; so they're only allowing 12 or 13. , j3 l My concern, since I'm in depreciation and taxes l' l 16 , anc finance , is this coes not go along with the idea that i 1 17 l te current customers who are getting the use are really paying I 1
'gj (for it . Somebody is going to have to make up for it down the i
19 ;line if this isn't adequate. I i ' i 20 This judge saic that he is accepting the FERC staff I 21 p osition that is now under study by you, by the NRC, that he l'
'2 : accepts their viewpoint on that.
~
l 2 I i i 73 [ I thought that might be interesting. ! 2 MR. BERNERO: That's a very good point. Thank you h.%,rr anonm, Inc. 33 j fbr bringing it up. i s 6 Ib +
.o
159 4 ! l It brings to mind a neat bit of acvice :nat came 1 i { 2 ] up at the State Workshops that yes, it will be a good idea to ' i 1 3
" set funds aside in an orderly way and so forth for decommission-l 4 ing, and for all those facilities that have been operating I
5 already a pro rata share should be determined, so you can start ' now , in the twelf th year of life or whatever it is , and calculate 6j 7 the money that should be set aside prior to now and dun the e Federal Government for that. 9[ (Laughter.) ; l u 4 10 j; Right now on this subject tnere is a great lag of ; L j; ' good knowledge of what it costs to decommission. The numbers ; i i 12 re being thrown around, and they're varying all over the ball- l i 13 park. In addition, many people are attempting to dodge, it l 14 lbyusingapercentage, a fraction, of the cost to construct. ! i i 15
!! I personally abhor that method.
16 : I recall that I used to work in reactor licensing , l i 17 l in NRC , and I was instrumental in licensing two identical ! i i 18 reactors in the same month, Those two identical reactors were,j i 19 of course, in different parts of the country, and they differed ' t i 20 in cost by something like a factor of 2 to 3. One was two or I 21 ! t nre'e times as expensive than the other, and they were the i 22 same plant, the same nuclear steam supply system and so forth. 22 ll The reason was one is in the Middle South and the other was
!! i 24';up in the Northeast.
AmFuws hommn, W.
. ;3 i So any attempt to co back to construction cost and I L
i O l o , , Y ' F i li - i
'I, 160 t !
l l} - 1n L use a percentage of that, I think, is the wrong way to do it. l li ' There is a great deal of interest'on the part of l 2ls ,i i' all the bocies involved with decommissioning, rate structures, i i
, allowances ano so forth to get good, narc numbers and get a l I
5 coordinated approach. ' 6 MR. BANCROFT: Michael Bancroft, Public Citizen. 7 I think I will address all these questions together. 6 I feel that the financial responsibility arrangements should 1
-j
- ] be imposed by NRC for uniformity because of this patchwork l l i
1 jo h of other,agenctes that are involved , and to ensure that when ! J 1 31 eeoommissioning is to ce done there is money to do it. Rather l i 12 than having to look around for either the state or tne Federal 1,. ' Government to come in and bail out the cost of the decommission , l ing, the funds should either ce set aside in advance in an
)g
)
15 i actual escrow account to be separately managed to produce the lr 16 ym oney later or there should be a surety bond, which should not i i l 17 l cost too much money. If the utilities -- I'm talking about a j l i i i is l reactor decommissioning - if tne utilities are so financially ! i
~~
19 j secure and guaranteed by the regulators, then the person civinc ; I 20 tne surety bond is only going to step in if they can't do it. l i 21 The reason there should be provision for the money l 1 22 in advance is that as soon as the plant goes into operation, i i l , 73dthere is radioactivity produced and there will be decommission-0 24i; igg. The expense will vary somewhat, as we've learned today, u,,.5.o neuenm inc. g 15 ;6ependtng on how long it has operatec t but the provision should W il i
. l-0 i I
., 161 ;
a D i a jybetheretoguaranteetherewillbemoneyright from the start. l b 2g The question of uncertainty of the cost and how I 3 1 much to'put aside is a problem, but certainly it's not a reason I
~
I 3 to say we will do nothing because the cost is so uncertain. I 5 Tnere may be variations later, either up or down, but the best 6 I estimate should be made at the time the plant is licensed and
/
a fund set aside for that. g I don't think that the money should be administered 9l by -- should be invested oy tne utility into its own plant, , [ , 1 g j tecause under the conditions that we ' re worried about , where i i h - 1 11 ' it becomes financially unsound, there will be other creditors ! 12 who are putting demands on the facility. The only way the I I 13 ; money will ne there is if it is a separate account. , l i l
)g MR. BERNERO: Thank you. l i
i in I MR. MORGAN: At the state meeting, State Workshop I
~
16 l in Atlanta, I celleve we were told by someone from NRC that 1 i i I l 17 l they.had gone to a number of surety firms and they could not j j l i !
' l 1E
; get a quote from a single,one. ; j t
~
19 : Our people have the same optnion, that there is no 1 I I i 20 j way to do it , that it is next to impossible. I I 21 Number 2, if we set them aside in advance, how in , ltheworldarewegoingtogetourutilitycommissionstodo l 22 j Just like the FERC now is so low on mothballing, so I nl it?
~~
74 ,1 think it's very impractical for those who have to carry it out. u..r .wa n.wnm. inc.y 25 ;, MR. BERNERO: Thank you, sir, n p-i ,
- -y y e
162
- n. t 0 ,
u l[ e i On that issue of should funds be set aside in 2 advance or accumulated curing the facility life, the impression' i, i a
,[ I got at the State Workshops was a reasonable sinking fund, i !
i
, done on a fairly well scheduled basis, was sufficient; that ,
i during the first few years either financial evaluation, tne 5 { 6 assurance that one gets through reactor licensing by the NRC 7 or through the state 's own purview, is sufficient to get , E assurance for those first few years; and then you start getting ) 9l some sinking funds building up to a significant degree.
)g I should add one other point that was made. A .
11 couple of people in my earsnot at the State Worksnops challenged i 12 whether funds shoulc be set aside at all for oecommissioning, { j3 and the argument seemed to be that if one postulates a de-34[commissioningcost in today's collars cf a few tens of millions I I 33 of dollars, 30, 40, 50 million dollars, that you're talking ; 16 [ anout a sum of money that is well within the orderly cash flow 17 j Possibilities of such a utility, tnat is, an orderly flow of , j, 1E obligations and benefits that come and go in such a large ope- ! 39 l ration. l 20 t1 l A few People said that, and my understanding was i
'3 '
hfromthereactionofothersaroundthatthatwouldbegreat 22 if they were all solely-owned facilities, solely owned by a 23 very large company; cut in some of tne other cases these things 74jareahodge-podgeofownership,anditchanges,whichcompli-4.2.sen n.mnm. inc. s
,z' cates that sort of treatment.
~' l I, 1 0 1 ii b
!l '63 f i h 0 I i !
- I
# l l
f I 1 !. MR. BERICK: Dave Berick, Environr. ental Policy t i i
; l Center,
.U e
4 '
,h I think we're having a problem cecause we're trying
~l j
t o oversimplify the situation. We're talking about a variety i 5 f different facilities. It's one thing to talk about a q 6 reactor; it's another to talk about a waste burial facility, i
)
where you've got 'a user fee that's oesigned to pay for de-7 g Commissioning, professional Care; and another thing if you're 9 talking about a mill, for example, with a single owner. You t n I
)g may be forced to deal with a variety of mechanisms rather tnan !
c l 11 " to acdress them generically. , 12 The situation we're fincing in West Valley, where , I i1 33 ; we are using a user f ee anc we are trying to assess the cost, 1 1 34 you find yourself in a difficult situation. i l Lg ! MR. BERNERO: Yes, that's a good point. ! I i 16 l i I should add that the National Conference of State , ! i i 37 [Raciation Control Program Directors had a workshop group or jg task force of their own members in tne past two years, as 1 -~ i 39 2acall -- I'm not sure of the dates. They develope: a task force; l . 20 ! report and a recommendation on a family of performance boncs, h 21 l' sure'ty arrangements that go with just such mill tailings and i i 22 =aterial. licensees. They have a whole formula, anc they're 23 g working this into a proposal for model state regulations tnat 1 i 24e }; they will hold up to all the states, su,gesting enar if that s AcpJgCpf31 NWOOf t9FS, IM. I 25 j', f acility is of a sort that would cost anywhere from zero to 11
- l. t U
U O .
,, 164 ,
il - f ! I i 1 S10 thousand to; clean up, one shoulc use Financial Mechanirm - l 2 A; it's it's $10 thousanc to s100 thousand, use Mechanism 3, ! d . I'
,9 and so on up the line.
-1I .
I a I'm oversimplifying, but they offered this to us 5 and encouraged us at NRC to look at that very closely as an 6 intelligent means to cope with the issue. 7 It is one thing to talk about a reactor, where g l you've got many people locking at it, and another where you're ; I 9 looking at a small company -- vastly cifferent circumstances. ; 39 ] Does anyone else care to comment on that? it 11 0h3 response.) i i 12 On the issue of who should hold the funds if they { i l 13 ! a re accumulated , some cf the state regulatory commissions '
)2 i started out to set them in company resources, and there seems $
- i. .
i j3 i t c be a lot of mind changing on this. In general, my con- j 11 i , 16 ; ception is most of the state people don't think 1r's appropriateI: 17 lthat theresourcessnouldn'tbeinthecashflowofthecompany.[
\
)g The State of Pennsylvania has just made a finding i I:
-~ 19 or ruling on Three Mile Island, perhaps a month ago, where they ; , 20 ) mid put it into state bonds, i 21 (Laughter.) !
! i i
22 l Tnat, of course, is somewhat self-serving for tne ; i e i ! 23 t j State of Pennsylvania, but there is a sense of third party I 24 'there, getting away from the company resources. 4c.4.omi nemners. inc. h And the point that was made by the other gentlenan, 25[d . t (b L , li -
165 ! i 0-i n 3 that wnen the time comes other creditors would be competing , l 2 l f r those company. resources, even if there were no liens on I 2 '.jl t hem to begin with. ; I 4 Now, on the uncertainties in cost or contingencies, 5 y u can go into each cost estimate and put on a contingency 6 factor and collect 25 percent more than you really think you 7 will need. You can go into groups, especially with the smaller g l licensees, tne smaller facilities, and work out a formula of I g taxation. 1
)c ; Some of the states have already cone this. The -
11 0 State of New Mexico on uranium mills has a unit tax on each 12 pound of yellowcake, U038, that's shipped, and that goes into j, , ceneral state revenues . For that the State acknowledges that t 34 l they will do a certain number of things or will take certain I j i 15 responsibilities. One can have a governmental body assuming jg . contingency responsibilities in that vein, the Federal Govern- l 37 [nent or the state governments , or we mignt cut a deal for both l 3g]nof us to do it. l l l t
~
19 ll Lastly, a tantalizing suggestion, especially for ! Il ! 20 lthe big units,-the reactors, the proposal was mace by more than 21 ne that a pool arrangement be worked out where fifty reactors , I ! 22 lli owned by fifty separate groups, anc the fifty groups each having
.n. g dresponsibilityandsomemechanismtodecommissientheirre-
{ 7a ;h; actors, and they all mutually agree to pool insure each other , Ae,.recroi stecorrert is "
- .3 ybr default, so tnat if one def aults the otner forty-nine will o l e
n i
n 156 i 9 4 jg chio in anc cav for that decc=missionine. h 2 d The cuestion immediately arises on that that cool I l' 3'!! insurance for an unclanned event, for accicents. is certainly ! l 3 a real thine, but where vou're talkinc about a decommissionina default it cets to be a little stickv. l 5 6 [ This succestion was made. Were not reiectina I - . . . t We're considerinc it.'but we see a lot of 7l it out-of-hand. 4 l ll uestion marks in it. Eh , Y Are there any comments on these contincency 9] , i ii jeh mechanisms? l l 11 p Jon. ) i 12 MR. STOUKY: I would say tnat the eroblem of' con- i 1 l jy[tincency is not so mucn the unknowns and how much does it cost ' ll i ; ja ' to take out a cubic foot.of concrete or cubic vard of concrete I: i { *] I p-[ from a wall, but to me the real problem is tne contincenev y l-l v p~ 4 associatec witn uncertainties in regulation anc otner factors, a b i 17 i external factors, such as availability of burial sites, type j l jgqi. of burial necessary, release rates, things like tnat. These !
),
D 19 can nave a very significant effect on whether tne amount is j i - i I 20 l off by 10 percent or 20 percent, or wnatever the number is, l 4 ! 21 I think in looking at decommissioning a plant what ! d I 22 you need to do is re-evaluate the decommissioning cost, not j 33[onlyinlignt of current technology associated witr decommission-34[-ing but in light of current regulations, on a fairly close
. Ac..s.o m ; s a n m .inc.c 25 j. P erlocic basis.
- E l r vi It si r
~
..167._
t- t - f F i MR. BERNERO: Thank you,
; f n i 2 ell MR. BLACKMON: Don Blackmon, Duke Power Company. l l
,. 'i , l I think that anotner thing tnat was pointed out at li
, the State Workshop in Atlanta was that the utilities commission 5
l w uld very much like to have the expertise of the NRC in coming! 6 up with a number of what it would cost to decommission a Whether that cost is $40 million, S42 7 l nuclear power reactor. , g ! million, S44 million, they don't really care today, nut they I
- n. a want something that can be worked on and updated periodically l ll 10 j tnat they can use in working with tne utilities to improve the n
33 funds to decommission the plants. ; I 12 I think that he's right; these things are going i i i g i to be continued to be looked at. The uncertainty of the i , t \ 3, ; regulations will be much more than the uncertainty of the cost j i l je ; estimates .
! l l , i 1
3 We make a value jucgment each time we make an i i l ,e i i estimate. While the estimates that are comine out
- of Battelle !
I v
)g !rightnowmaybe " soft" in.the area of labor prices, we know l
l ~ j9 lwhat labor prices in our labor are and we use it in our esti- i i ! 20 l mates. We can update it periodically; we can know how gooc l
, J 21 :! those numbers are, and that's the kind of things that we have ;
i 2<
-presented to the utilities commission. !
1 1 y
/g If NRC is going to set various decommissioning plans ! l tu ,Iy to serve as alternatives, they ought to know what the numbers '
Aco4coers Reponers. Inc. d are and update them periodically so that the utility commissions
~
3 u n* p 11 ,
'l " 168 i i
i t
; can use them.
i 9d MR. BERNERO: Thank you. !
-t .
n -
! The gentleman aptly points out that many of the 3} '
people at the State Workshops, if given free rein in the con-a l 5 duct of our studies, would have_one of these Battelle studies l l 6 for every reactor in the United States and have it updated 7 every three to five years. What they'd really like to have j i g lisanIndependentnumber. They'd like to have a good ince-
; I 9(pendent number, and they use terms like " site-specific generic !
i' ! 30q studies." J 11 There is a strong desire to have an alternate view 12 t: compare to the one that you give them, the reactor owner , I i p- si gives them, a very strong cesire on their part. One of the ! ; li l jg j; strongest pieces of advice they have, back on the first ques- ; p. i l i ~c ; tion, is the Plan adequate, many of them were saying, "Do . i
! \
je more studies; co more generic studies; more site-specific ' l I 6 37 j s tudies. " j i i l
)g j One could translate it as to study more different P
l i ~
); [ r eactors , study more comoinations, multiple-reactor sites, I
I d i 20 one plants, two plants, whatever, j
,l ! <
'1 h Well, we've covered all that was covered in the l
'I l i 22 ,i State Workshops, and I think the meeting has served a good I
73 :: purpose . b 24 ;'. We will be putting together our report on the State A .smoo sexnm. m. ,,
,c :t Workshops and' on the oublic meetinc in what amounts to a status
~ , .
I
.a I
169~ r 'i
- l d
i report on this program on wnere we're geing from nere, acjust-n 2 fI ments to the schedule and modifications, and the types of 1 e i 3: r eports ,that are being generated.
! Those of you who have j 4 registered here at_tne meeting will be receiving a copy of i
5 the summary report of this meeting and the State Workshops. l t 6 I would add, if any of you are not on the mailing 7 list for the major studies -- I mean all the documents that i g jwe.. republishing, including these great, big, heavy things i 9 j tnat will go through your floor -- I do not make a practice , l< jo h of promising the world distribution of those. We're already f 3 33 at a verv hach number, anc it costs the taxpayers a lot of j l 12 money for us to print those things and mail them. But if - 13 someone has a genuine use for those reports and is not just 1 1 ja{goingtothrowthemaway,andspecificallywritesaletter i l I i 15.] saying they want to get the whole series of reports, we will l l l i i 16 , ace you to the list. l 17 l You can write to me. I think the agenda has my ; 16 name on it. The address is Washington, D. C. 20555. ! i ~~ 19 , i I'm reluctant to just scatter tnose arounc Just ; 20 because of the sheer bulk of them. You will have a bookcase I! I 21
; full in a hurry. i' I
.2 1 MR. BLACKMON: Two tnings, if I may.
This morning we saw a slide that indacated there ! 23 h 7;[werei only 20,000 Special Nuclear Material licenses. , i
- w.5.omt rs.aonm. inc. a
,e E MR. BERNERO:
" t!
Excuse me. That's marerial licenses, : I '- l h t l. i r
' h'0 i
\
l I 1 l
170 1
=t h
a < fj-
)p source byproduct and Special Nuclear Material. ,
o i 2 MR. .BLACKMON: Is there a plan, or do you envision l
! I
, ,; the NRC increasing the scope of their technical studies to $
t
.l put together some kind of a summary report as to what all 4 f.
S tnese various licenses are? I 6 It appears to me that as far as sheer volume of 7 numbers, that's where the majority of the licenses are and l g 6ey are going to have to be dealt with, even if they're only i l co S10 or $20 decommissioning. , I
' a. l 3p ll MR. HERNERO: In response of that, your advice is I 31 fiery similar te what we got in the State Workshops. Our l i
12 original expectation was that by taking the reactors and the g uranium fuel cycle we would hav,e covered the spectrum of ; 1 y problems in sufficient detail. I 15 l Many people don't agree with that. We're in the j l ! 16 l state of reconsideration right now and are having discussions
! l 37 j on, if we do something cifferent, is there a way we can bound !
! t i ,
jg the problem? Is there a way we can get a representative
~
L 19 evaluation of those 20,000 facilitias? ; l l 20 Many f them are very simple propositions. Radio-21 ipharbacies, for example, are dealing with very short-lived ,
\ l 22 activity. You can decommission it by locking the door and l l 1 I
\ f 2, cp g ing away for vacation.
l Many of them are source manufacturers ! I J l! that make tnorium f or lenses and things like that , so we're v L I ' u..m,o sacanm. sne q 73 it 3right now discussing how we could better ecuip ourselves to
- c. ,
h 1
- 171 $
li
;{,evaluatethat large famC', of licensees, e
2 MR. BLACKMON: One other thing. I have a statement
! )
Il 3 ,; that'I was planning to make. I've already missed ny early i I
-1 i
i 4 I' flight, bu't some of the people haven't. I would like to leave 5 you a copy.of the statement. 6 MR. BERNERO: Yes, we will put it in the record. 7 MR. BLACKMON: Thank you, j g (. Statement follows.1 ; t 4 % a
!I 10li>
11 i ; I 12 l l 13 ij ! li. - 14 I < l 15 i j 16 i ! i . t i 18 i 19 I i I 20 ! I i 21 l 22 'l t i 23 I i H ' i 2 Ac .Feoerei aewriers, Inc. g 15 1 1 1 4 kl
~ . _ ,_ , ,
1
, 172 K,
u ti xxxx p STATEMENT OF DUKE PCNER CO.PANY ON DECOMMISSION-1 :: i h 3g ING CRITERIA FOR NUCLEAR FACILITIES, PUBLIC l n 0 I 3p F2ETING, OCTOBER 18, 1978. ! l
, On behalf of. Duke Power Company, I am taking this I 5 occortunity to respond to the Notice in the Federal Register 6 f Friday, August 25, 1978, concerning the decommissioning 7 criteria for n'u clear facilities. We understand that the-NRC i
g l is considering development of a more explicit overall policy ' i i 9j for nuclear facility decommissioning to include more specific n
't jo; guidance on decommissioning criteria for production and utilii-o
- 3) : cation facility licensees and by-produce, source and special 12 nuclear material licensees. l 1
. 13 i
Duke Power Company is an investor-owned utility i ja U which operates within a 20,000 square mile service area in the j3 l Piedmont Carolinas and serves approximately 1.2 million cus0 f I 16 !: tomers. Our existing generation capacicy is 12,317 MW of h l
)7 j.which approximately 2600 MW is nuclear fueled. In addition, i
)g we nave under construction.and in design 12,330 MW of nuclear 19 g generating capacity. Our commitment to nuclear energy is based i II ,'
20 ll on our review and conscientious decisions concerning the needs l 3 i l 21 of our customers for dependable, economic, safe an: environ-1 il 22l ; mentally sound electrical energy. Our decisions have taken . t I ( 23 iito account the need to decommission these nuclear facilities 9, , 24[at the end of their useful life. We have participated in the AC2 btOf*81 Reporten, I,s. a
- u. ,, decommissionine of the Parr Reactor owned by the Carolinas-Virginia i
i ) l
'f i
-4
173 i 1 l il 10 p Tube Reactor Associates. 2 i, We took the opportunity on July 14, l'378, to respond l 3 i to the six questions from the Commission set forth in the ! i ' a Federal Register Notice of March 13, 1978. We also partici- i l 5 pated as an observer at the NRC States Workshop in Atlanta in 6 September 1978. We believe that the three principal issues 7 being addressed by the NRC in,the reevaluation of its de-g {commissioningpolicyare (1) the levels of acceptability of j l i 9 ! radioactive residues, (2) financial assurance , and (3) generic - I 10 applacability of deconnissioning analyse,s. We have also taken j i i 11 : he opportunity to review NUREG-04 36, which deals with the l 1 1 12 NRC's plan for th1s decommissioning reevaluation. We believe I i l ! 13 jthat the plan as stated will prove to be an acceptable method-i le ology for the reevaluatior, and we urga the Staff to make full I . . l 15 use of the various areas of expertise within the Commission l 16 l and outside the Commission. We request that our comments on 17 l these three principal issues be mace a part of the record of ; i
! 1 18 lthis meeting anc that they be reviewed in detail by the NRC 2 19 Staff, 20 The levels of ecceptability of radioactive residues {
l 21 { is a question fundamental to the nuclear power program. While ! 22 lmany believe that any reevaluation of the decommissioninc I i ( 23 jpolicies must be tied with a Federal program of nuclear waste i 24 we do not. We believe that a facili.y can be de- i
;.c .r.ocs anon m ine. ly management ,
25 h] commissioned without adverse effects on public health and ir
l
" 174 l I I 1 safety. Existing regulations provide adequate guidance con-i 2 l sidering that most present-day generatinc reactcrs have a lonc !
3 remaining productive life. Thoogn existing regulations do not j 4 require the development of a detailed technical decommissioning i 1 5 plan at the construction permit or operating license !tage, i 6 they do contemplate the submittal of such a plan near the end 7 , of the useful life of the facility. Many utilities have ex-
' i 6 l p erience in decommissioning experimental reactors and l 9 , cecommissioning technology continues to grow. Experiences to i
ny l date have been favorable. i Until data are evaluated, or de-11 l commissioning is a closer reality, development of nere i 12 detailed regulatory criteria is technically premature and : ; j i 13 i unjustified. i I le ! We believe that the acceptable criteria for residual l l 15 llevelsofradioactivityonmaterialswhichcanbereleased 16 li for unrestricted use are those set forth in NRC Regulatory i 17 Guide 1.86. We do not believe it wise for the NRC to proposa i u3 stricter criteria without . additional experience gained from i 19 the future decommissioning of large power reactors. It may 20 be necessary for economic and radiological reasons to provide $ i
;) for' protective storage prior to final decommissioning of some !
22 facilities. This protective storage could be accomplished by j i 23 mothballing the contaminated facilities. We do not believe that l-24o ll a minimum or maximum period should be established for this
;.c,.s ,ce-e: Mporwt. Inc. p 25 ll protective storage, but do believe that specific economic and l-I
.i 4
175i h\ i , environmental considerations must be examined on a case-by-i 2 case basis'. ! 3 We believe'that buildings, structures, and components 1, k 4 which have not been contaminated with radioactive materials I i 1 1 5 at nuclear. power stations should not be associated with any , l 6 decommissioning criteria developed ny the NRC. There is no 7 necessity or technical or legal justification to extend NRC , g regulatory authority to these uncontaminated facilities. ; 9 The costs of decommissioning of nuclear power l l 10 reactors have been studied and evaluated. Studies completed lI f 11 by the AIF, the NRC, and several utilities indicate that the 12 normalized costs of decc...:.issioning are less than 10 percent of I 13 the capital costs of current projects. In the case of power i 14 reactors, we believe that funding arrangements should be the ; 15 responsibility of the licensee and.tne state utility rate i I 16 '. regulatory agencies. While the NRC should inquire into the I 17 jfinancialqualificationsofitslicensees, it doer not have ' 18 the primary authority for determining the appropriate fiscal !
~~
i 19 i 1 mechamism needed to insure that decommissioninc costs will be i i 20 met. Ina any event, regardle2s of the funcing mechanism ! 21 employed, the costs of decommissioning should be paid by the i 22 consumers of the energy produced by these facilities. State l n ; utility rate regulatory agencies are technically capable cf 24 establishing the proper methods for f uncing the deco =missioning w.r oc., nemnen, inc. q 25 : costs and must be left to do their job. It may be wortnwhile I i i t h I li .
b 6 F 17 i o
!l 1]fortheNRCtoreviewthefinancialplansthat the various t
2 , utilities have for meeting the decommissioning costs. The ! 3 , NRC can then function to ..alntain a consistency, through the ; a l post-operating license reporting requirements, in its financial l' i
)
i
.e cualifications determination- ,'
; i 1
6 We believe that the generic applicability of l l 1 7 decommissioning analyses is a desirable objective which the i g , NRC, in cooperation and coordination with the various utilities,I 1 l 1 9 ' can accomplish. By providing reasonable alternative de-l l 12 ; commissioning plans, including permanent entombment, the NRC 11 can meet its omligatiens concerning public health and safety 12 while at the same time leaving to the state agencies their 13 i responsibilities concerning funding and monitoring. i 14 In conclusion, we believe that it is inappropriate l - 15 l for the NRC to develop more specific criteria for cecommission-I 16 lingortoinvolveitselfinspecificfundingmechanismsrelating i i 17 l to decommissioning costs. The existing approaches, rules and 18 ! regulations provide an adecuate framework for the continuing
, e I
~ 19 l e volution of power reactor decommissioning. 20 : 21 22 - l 1 I 23 2d
- d. ,w.' armnen inc.
25 lI
. lie b
'i .
t i
/ :
g 177 i b
)hh MR. BERNERO: Rufus. >
i i 2 MR. MORGAN: In composing the next one of these : i, l 3 larce studies for the PWR, I would like you to consider that t 4 the actual period over which utilities would normally be able i i 5 to recover such. costs, if they're going to do it, is going i 6 to be from their in-service date until it's snut down, which , 1 7 1s more like 35 years than the 40 they've used on the other e study . I think it would be much more practical. i { 9 Number 2, if the longer lasting radiation is not i 10 lgoingtoreducea great deal over the last, say, 60 years if d ' 11 Ii' you have 100, I thank that might be a consideration if you 12 want to give an alternative to the 100 years. l l 13 MR. BERNERO: Thank you. ] l i l Wall, with that I think we have a complete meeting. l 14 i 1 15 t If no one else has anything else to add, to ask or to say, 16 I'll declare this meeting adjourned. Thank .vou verv much for 17 coming. i 15 _ (.Whereupon, at 4:25 p.m., the meeting was t 19 adjourned.) I 20 ' 21 - - - 1 J 22 ! !
! I i
23 l . i 3 f Pdfrp' RegOffert, IM. } G
- 25 l '
i
! I i
i l J
- - - - - - - -- ----u - - - ma ,
, n _,s a
y , d. 4
~
REEVALUATION AND REVISION OF NUCLEAR REGULATORY COMMISSION POLICY ON DECOMMISSIONING OF NUCLEAR FACILITIES n #n!! to JO
$Ji' 6 d .i.
3*-
t DECOMMISSIONING OF NUCLEAR FACILITIES
.1. WHAT ARE THESE FACILITIES AND WHAT DOES lT MEAN TO DECOMMISSION THEM? -
- 2. HAVE ANY BEEN DECOMMISSIONED?
- 3. WHAT ARE THE PRESENT REQUIREMENTS FOR DECOMMlpSIONING?
i
- 4. WHAT IS NRC DOING ABOUT DECOMMISSIONING?
1 1
= - . . . . . . .- - . - - - - - - . . . - - - - - - = - _ _ . - - _ - . - - - - _ . _ - . . - _ = _ _ _ . - - . . _ . . . . -
TERMINOLOGY
~
~ DECOMMISSidNING: REMOVAL FROM SERVICE AND DISPOSITION OF RESIDUE TEMPORARY DECOMMISSIONING i
^
4t SAFE STORAGE VARIOUS BARRIERS CONTINUING CARE FINAL DECOMMISSIONING DISMANTLING REMOVAL OF RESIDUE UNRESTRICTED RELEASE 1 ENTOMBMENT l - SEALING OF RESIDUE
- - . _ .__ . _ _ _ = _ _ _ - - _ -_ _ - - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ - - - _ _ _ - _ - - _ _ _ _ _ . . . - . . _ - . . .
i SCOPE COVERS
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. SEFOR 20 MOTHBALLED STRICKLER, ARKANSAS WESTINGHOUSE TEST REACTOR , 60 MOTHBALLED WALTZ. MILL', PA.
NASA PLUMBROOK 0.1 MOTHBALLED SANDUSKY,' OHIO
- GE EVESR 17 MOTHBALLED B&W ALAMEDA CO., CA.
e 6 DISMANTLED , EXCEPT FOR SOME CONCRETE STRUCTURES- LYNCHBURG, VIRGINIA HALLAM 256 ENTOMBMENT PlQUA HALLAM, NE. 45 ENTOMBMENT l- ELK RIVER PlQUA, OHIO 58 DISMANTLED BONUS ELK RIVER, MN. 50 ENTOMBMENT VBWR PUERTO RICO t 50 MOTHBALLED FERMI I ALAMEDA CO., CA. 200 MOTHBALLED CVTR MONROE CO., MI. 65 MOTHBALLED PEACH BOTTOM SOUTH CAROLINA i 115 MOTHBALLED PATHFINDER YORK CO., PA. 190 CONVERSION AND ' MOTHBALLING SIOUX FALLS, SOUTH , DAKOTA- ] g g. "'; ihi+. ' T "i:1!- !ilu 'i" '
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EXAMPLE DECOMMISSIONING REACTOR- ELK RIVER .. REACTOR OUTPUT 58.2 MWth ' ' 4 OPERATED 1962-1968 DECOMMISSIONED 1972-1974 ., o l
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METHOD OF DISMANTLING FOR
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EXTRAPOLATION OF EXPERIENCE ELK RIVER TROJAN
, REACTOR TYPES BWR PWR REACTOR OUTPUT, MWth 58.2 3500 REACTOR VESSEL WALL THICKNESS; INCHES 3 8.5 YEARS OF OPERATION 6 > 30 DISMANTLING COST ($M) 5.7* 42.1 * *
- DOES NOT INCLUDE STEAM PLANT AND ' HEAT REJECTION - 1973 DOLLARS
** INCLUDES ALL STATION FACILITIES AND LAST FULL CORE - 1978 DOLLARS l
r EXISTING CRITERIA FOR DECOMMISSIONING REACTORS
+* 10fCFR-50.33 FOR FINANCIAL QUALIFICATIONS 10 CFR 50.82 FOR DECOMMISSIONING PLANS .
E* RiGD1.86 FOR DECOMMISSIONING MODES AND RESIDUE LIMITS - 1 1 ,
- 1 FUEL CYCLEiAND OTHERS
* - 10 CFR 50 APPENDIX "F" FOR REPROCESSING PLANT
* -10fCFR 50.33 AND 10 CFR 70.23 FOR FINANCIAL QUALIFICATIONS '
- R.G. 3.5 ETC. FOR CRITERIA
- RESIDUE LIMITS -
I
~ v Q1 9* f 4
_ _ . _ - ___m . u e & _ _ _ _ -' . _ _ _ ___.2 _ ____._ ______ _ _____ _.___ _.________ w T
EVALUATION OF DECOMMISSIONING IN A REACTOR APPLICATION
- LICENSEE IDENTIFIES TENTATIVE MODE AND COST
- STAFF CONSIDERS COST AND TIMING IN 50.33 FINDING
- STAFF CONSIDERS COST IN NEPA COST-BENEFIT ANALYSIS 1
e i EXAMPLE FUNDING FOR REACTOR l DECOMMISSIONING
- DECOMMISSIONING COSTS BORNE BY CUSTOMERS SERVED :
i
- - : + ;
- CASH SINKING FUND INVESTED IN THE-UTILITY'S OWN-aASSETS' ,
JEL , UTILITY CHARGES FRACTION OF DECOMMISS10NING COST AS DEPRECIATION EXPENSE AND CREDITS c RESERVE FUND RESERVE IS DEDUCTED FROM RATE BASE AND FROM PLANT AGAINST WHICH SECURITIES CAN BE ISSUED
- TYPICAL RATE OF RETURN ON THIS RESERVE ABOUT 15%
a
WEAKNESSES OF PRESENT POLICY LACK OF RECOGNIZED CRITERIA FOR RADIOACTIVE
- o. RESIDUE IN SOILS -
ON SURFACE - IN BURIAL LACK OF CLEAR POLICY ON PERMISSIBLE MODES OF DECOMMISSIONING l- - REMOVAL VS. FIXED-IN-PLACE : l - TIMING L LACK OF CLEAR POLICY ON FINANCIAL ASSURANCE LITTLE IS BEING DONE TO SEE THAT PLANTS ARE BEING DESIGNED TO FACILITATE DECOMMISSIONING L
. - . - - _ - . - - - - . - - - - --_-x---_.2-- -_ _ _ --._-_---.-_--.-__- ---_____-_ _ _ __-- x-
WHAT IS NRC DOING?
- COMPLETE REEVALUATION OF POLICY ALL ACTIVITIES LICENSED BY NRC DETAILED TECHNICAL STUDIES RULEMAKING CLOSE COORDINATION WITH STATES MUTUAL INTERESTS RELATED RESPONSIBILITIES POTENTIAL TECHNICAL SUPPORT FOR STATE WORK i l
e
MBO B DEVELOP POLICY AND RULE - FY78 FY79 FY80 OlNlDlJlFlMl AlMlJlJl Al S OlN]DlJlFlMl A]MlJlJlAl S O lNlDlJl FlMl alm l JlJ[Ah NOTICE ' LIAISON-STATES & FERC STAFF AN ALYSIS FINANCIAL g ggggggggg LIAISON-EPA RADIOACTIVE RISK ASSESSMENT RESIDUES GENERIC R E.% CTO RS o APPLICABILITY FUEL CYCLE o o DRAFT EIS 3 POLICY 3 STATEM ENT ' PROPOSED a RULE STATE O O WORKSHOPS
e STATE WORKSHOPS PURPOSE STATE VIEWS ON JURISD'ICTION STATE VIEWS ON RESIDUES SCHEDULE DURING GENERATION OF DATA BASE PRIOR TO THOUGHT SET BY NRC STAFF AGENDA 1ST ROUND-THE PLAN APPROACH, THE QUESTIONS, , THE FIRST MAJOR REPORTS 2ND ROUND-THE MAJOR REPORTS, THE TENTATIVE THOUGHTS ON ASSURANCE, RESIDUES AND GENERIC APPLICABILITY
e HOW CAN A STATE PARTICIPATE ACTIVE ROLE IN WORKSHOPS CLARIFICATION OF JURISDICTIONS FINANCIAL ASSURANCE EXTENT OF DECOMMISSIONING REQUIRED RESIDUAL ACTIVITY LIMITS ,.
. r CRITIQUE OF TECHNICAL REPORTS ^4# '
VALIDITY OF CALCULATIONS MEASURE OF UNCERTAINTY IN COSTS NRC RULEMAKING PROCESS AFTER WORKSHOPS AND REPORTS NO REDUCTION IN OPPORTUNITIES BECAUSE OF ! WORKSHOPS SEPARATE STATE ACTIONS
QUESTIONS 1. DO THE STATES HAVE AN ACCEPTABLE ROLE IN THE PLAN?
- 2. ARE THE TECHNICAL REPORTS ADEQUATE IN COVERING THE RIGHT FACILITIES, IN CONSIDERING THE REAL l ALTERNATIVES?
- 3. SHOULD THE PLAN BE MODIFIED? HOW?
- 4. SHOULD DETAILED DECOMMISSIONING PLANS BE REQUIRED PRIOR TO THE ISSUANCE OF LICENSE?
5. IS DELAY IN DECOMMISSIONING JUSTIFIED TO SAVE MONEY?-TO RF_ DUCE RADIATION EXPOSURE? l
- 6. i IS PERMANENT ENTOMBMENT OF NUCLEAR FACILITIES AN ACCEPTABLE METHOD OF DECOMMISSIONING?
I O.UESTIONS (Cont'd.)
- 7. SHOULD DECOMMISSIONING CRITERIA EXTEND-TO.
BulLDINGS, STRUCTURES AND COMPONENTS WHICH ARE NOT CONTAMINATED WITH RADIOACTIVE MATERIALS 7 _.
- 8. CAN CLEANUP CRITERIA BE DEVELOPED BY THE FEDERAL GOVERNMENT WITH STATE ADVICE SO THAT ALL CAN ENDORSE AND FOLLOW THEM7 .
- 9. IS A. MAXIMUM DOSE RATE OF 1 MREM /YR TO ANY INDIVIDUAL AFTER CLEANUP AN ACCEPTABLE BASIS FOR SITE RELEASE? WHAT OTHER BASIS WOULD YOU RECOMMEND?
~
O.UESTIONS (CONTJ - L
- 10. WHO SHOULD PAY FOR DECOMMISSIONING?
;11. SHOULD FINANCIAL RESPONSIBILITY REQUIREMENTS BE IMPOSED BY FEDERAL OR BY STATE AUTHORITIES?
WHEN? '
- 12. SHOULD FUNDS BE SET ASIDE IN ADVANCE OR ACCUMULATED DURING FACILITY LIFE TO PAY FOR DECOMMISSIONING? l
- 13. WHO SHOULD HOLD THE FUNDS IF THEY ARE ACCU M U LATED?
- 14. HOW CAN UNCERTAINTIES IN COST OR CONTINGENCIES BE COVERED?
BY EXTRA MONEY IN ACCRUAL FOR EACH FACILITY? BY EXTRA MONEY INTO A GENERAL FUND STATE OR FEDERAL? r
RADIATION EXPOSURES 4 NATURAL SOURCES 300 -
- GUAPAR, BRAZIL,550 AVERAGE
- KERACA, INDIA, 800 AVERAGE 250 -
~
- COLORADO MOUNTAINS, NATURAL SOURCES E 150 -
2 E 100 -
- TYPICAL MEDICAL EXPOSURES
- U.S. POPULATION MEAN, NATURAL SOURCES
~
FREQUENT AIR TRAVEL 0- - OCCASIONAL AIR TRAVEL
4
- u.
F E D E R'A L - S T A T E J U R I S D I C T I'0 N Z
~
ACTIVITY EERAL STATE.
&AcTmS mD . ISSUES (PSANDOLSINALLSTATES ISSES SITE
'~~
CERTIFICATION, ETC.
' REPROCEfING PLANTS 1 i
FEL CYCLE ISSUES' UCENSES IN Au_ STATES ISSES UCENSES FOR , ,
- FACILITIES EXCEPT MILLS AND W g PLANTS IN Mill.S AND g T N
, AGREEMENTSTATES -
' IN AGREENNT STATES SOURCE-BYPRODUCT-AND ISSUES UCENSES IN NON-AGREEMENT ISSUES LICENSES IN StM (SMALL QUANTITIES) STATES AGREENNTSTATES NATURALLY OCCURRING AND NO AUTHORITY &GULATED BY STATES
' ACCELERATOR PRODUCED MATERIALS X-RAY MCHINES NOAUTHORITY REGULATEDBYSTATES
'.[
n
. - , . -, e a- a e v . , , , . - ,.mm- .*t.,,- ,& - 4.-
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f- ? o 0: 03PR logy s l DISCUSSION MATERIAL ON STUDIES OF DECOMMISSIONING A 1 FUEL REPROCESSING PLANT AND A PRESSURIZED WATER REACTOR R. I. Smith E. S. Murphy September 1978 Prepared for the U.S. Nuclear Regulatory Comission under Contract No. EY-76-C-06-1830 Pacific Northwest Laboratory Richland, Washington 99352
.d ,-
1 Contents General . Study Information R. I. Smith i 1 Decomissioning a Fuel Reprocessing Plant E. S. Murphy
-]
R. I. Smith
~
Decomissioning a Pressurized Water Reactor Background Material l l j l i l I i i i l I 1 I l i l l l l ' i
L Safety and cost infonnation was developed for the con-ceptual decomissioning of a large [1175 MW(e)] pressurized water reactor (PWR) and a large nuclear fuel reprocessing
- plant (FRP). Two approaches to decomissioning, Imediate Dismantlement.and Safe Storage with Deferred Dismantlement, were studied to obtain comparisons between costs, occupational radiation doses, potential radiation dose to the public, and.
other safety impacts. For the PWR,. Imediate Dismantlement was estimated to require about six years to complete, inc,uding two years of ; planning and preparation prior to final reactor shutdown, at a cost of $42 million, and an accumulated occupational radia-tion dose of about 1325 man-rem. . Preparations for Safe Storage were estimated to require about three years to complete, 1 including 1-1/2 years for plarming and preparation prior to
' final reactor shutdown, at a cost of $13 million and an accu-mulated occupational radiation dose of about 430 man-rem. The i annual cost during the Safe Storage period was estimated to be ,
about $80 thousand. Deferred dismantlement following a 30-year J period of Safe Storage was estimated to require about $37 million and an occupational radiation dose about 24 man-rem. For the FRP, Imediate Dismantlement was estimated to require about seven years to complete, including two years of planning and preparation prior to final plant shutdown, at a cost of $67 million, and an accumulated occupational radiation dose of about 532 man-rem. Preparations for Safe Storage were estimated to require about four years, including about 1-1/2 years for planning and preparation prior to final plant shut-down, at a cost of.$20 to $22 million and an accumulated occupational radiation dose of 72 to 84 man-rem for the cus- , todial and passive modes, respectively. The annual cost during ) the Sufe Storage period was estimated to be about $880 K for i the custodial mode and about $182 K for the passive mode. Deferred dismantlement following a 30-year period of Safe Storage was estimated to require about $50 million and an accumulated occupational radiation dose of about 226 man-rem. 2 9 ^ _ . . . _-_ W
.e
+
t S-AFETY AND COSTS OF DECOMMISSIONING NUCLEAR FUEL CYCLE FACILITIES STUDIES CONDUCTED FOR THE OFFICE OF STANDARDS DEVELOPMENT, U.S. NUCLEAR REGULATORY COMMISSION BY BATTELLE, PACIFIC NORTHWEST LABORATORIES '
s -, s, b~
; i
.a 1
i GENERAL STUDY INFORMATION O l 1 1 1 o i j l l 1 1 f l
,i 4 ;
i i
~~
DECOMMISSIONING , PREPARATION OF A FACILITY FOR RETIREMENT FROM ACTIVE SERVICE AND PLACEMENT OF THE FACILITY IN SUCH A CONDITION THAT FUTURE RISK FROM THE FACILITY TO PUBLIC SAFETY IS WITHIN ACCEPTABLE BOUNDS.
l DECOMMISSIONING STUDY OBJECTIVES
- z,-
ASCERTAIN ADEQUACY OF AVAILABLE TECHNOLbGY,- ESTIMATE CUMULATIVE RADIATION DOSE, ESTIMATE MANPOWER AND COSTS, FOR DECOMMISSIONING NUCLEAR FACILITIES VIA ALTERNATIVE MODES. l
.._-._..._..._..--....-..;'m '... -' ' - ' ' - "'"-~' ' '"'' " ' ' ' ' ''" ' "" ' ^ ' - ' ' ' ' ' " ' ' ' " " ' ' " ' " ' "' "'"
~
BASIC WORK ELEMENTS IN ' DECOMMISSIONING STUDIES
- REGULATIONS REVIEW DECOMMISSIONING EXPERIENCE
- FACILITY CHARACTERIZATION .
~
- WORK PLANS, METHODS, SCHEDULE
- COSTS 1 ,
- SAFETY ALLOWABLE RESIDUAL RADIOACTIVITY FINANCING ALTERNATIVES A
-___.2__.__ _ _ _ _ ____m_o.-_ - _ _ _ . _ _ _ _ _ _ _ _ _ ____ _ _ _ _ __ _ _ _ _ _ _ _ . _ _ _ _ _ _
l . l l GENERAL KEY BASES FOR DECOMMISSIONING ' - L 1 STUDIES - EVALUATE SPECIFIC REAL FACILITY AS REFERENCE CONTAMINATION LEVELS ARE ESTIMATED ASSUMING J GOOD HOUSEKEEPING - ,a
- GENERIC SITE
- SPECTRUM OF VIABLE. DECOMMISSIONING IVIODES w
e PLANS PROVIDE BALANCE OF SAFETY AND COSTS
- ALARA PRINCIPLES FOR OCCUPATIONAL EXPOSURE
- CURRENT DECOMMISSIONING TECHNOLOGY
- EFFICIENT DECOMMISSIONING PERFORMANCE p ; r:-
REFERENCE FACILITY IS ALONE ON THE SITE "
- TRU AND HIGH ACTIVITY WASTES TO GEOLOGIC DISPOSAL; OTHER RADIOACTIVE WASTES GO TO SHALLOW LAND BURIAL t
9
-_. _ _ . - . _ _ . - - - - - ---.__.____a.. - - . - _ . _ _ - - - _ . _ _ __._..-___ . . _ _ .-- ___ _ . _ . - . - - _ _ - _ '- - _ _ _ _ --._____-____.____.___a.- - - _ _ - - _ - - _-___.--
L DECOMMISSIONING MODES DIS MANTLEMENT
- COMPLETE DECONTAMINATION AND i
! REMOVAL OF RADIOACTIVITY
- NO SURVEILLANCE SAFE STORAGE m HARDENED e MAJOR DECONTAMINATION AND i (ENTOMBMENT) REMOVAL OF RADIOACTIVITY
- HARDENED ENTOMBMENT OF RESIDUALS INFREQUENT SURVEILLANCE PASSIVE
- PARTIAL DECONTAMINATION AND (PROTECTIVE REMOVAL OF RADIOACTIVITY
- STORAGE)
- SEALING OF RESIDUALS REMOTE CONTINUAL SURVEILLANCE CUSTODIAL o. PARTIAL DECONTAMINATION AND (LAYAWAY) REMOVAL OF RADIOACTIVITY (MOTHBALL)
- CONFINEMENT OF MESIDUALS CONTINUOUS SURVEILLANCE
~
L b DISPOSITION C.RITERIA DECOMMISSIONING NUCLEAR FACILITIES OBJECTIVE: DERIVE ACCEPTABLE RESIDUAL RADIOACTIVE i
- CONTAMINATION LEVELS FOR UNRESTRICTED USE
- OF DECOMMISSIONED NUCLEAR FACILITIES.
~
BASED ON RECOMMENDED DOSE (RATE) LIMITS g FOR MEMBERS OF THE PUBLIC . .
* -CONSIDER ALL POTENTIAL EXPOSURE PATHWAYS
- METHOD GENERALLY APPLICABLE TO ALL ~
NUCLEAR FACILITIES
- CONSISTENT WITH EXISTING CRITERIA FOR '
DECOMMISSIONING - _ ~ _ - _ -
- _r --- _ -. _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . - _ _ _ _ _ - _ _ _
_____-_______i-___-_--
o L GENERAL METHODOLOGY FOR CALCULATING ALLOWABLE CONTAMINATION LEVELS
.
- DEVELOP RADIONUCLIDE RELEASE SCENARIOS.
- COMPUTE ANNUAL DOSES FOR RADIONUCLIDE RELEASES
-FROM THE REFERENCE RADIONUCLIDE INVENTORY
- COMPUTE RATIO OF CALCULATED ANNUAL DOSES TO ' -
ANNUAL DOSE LIMIT -
- COMPUTE ALLOWABLE RELEASES OF REFERENCE INVENTORY 3
THAT RESULT IN THE ANNUAL DOSE LIMIT
- COMPUTE THE MAXIMUM CONTAMINATION LEVELS THAT RESULT IN THE ALLOWABLE RADIONUCLIDE RELEASES
- USE MOST RESTRICTIVE PATHWAYS AND ORGAN
- DOSES 4
4
^k'-' ' ' ' '---------- - - - - - - -# - ' - - - - - ' ' - - - - ^ ^ - - - ^ - ' - - - - - ' ' - - - - - - - ^ - - - -
_. . . = . _. j BASIC ALTERNATIVES FOR FINANCING
. DECO ~MMISSIONING j ,
. j - !L,?j ~ *
- PAY'WHEN INCURRED .
a = - ar; : -
- PREPAID . SINKING FUND . .
m . m o ANNUAL PAY' MENT SINKING FUND. s L l l
FINANCIAL ALTERNATIVES CASE- FORMULA PRESENT VALUE COST PAY WHEN p = S(I + j)" INCURRED- I $10 MILLION (1 + k)" PREPAID SINKING II + I FUND PH=S 1 + (j-i) $27 MILLION a=1 I' + n S(I+j)"
~ ~
ANNUAL PAYMENT (1+j)* ' SINKING FUND n $15.3 MILLION E (1+j)b 1 (1 + i)n-b a = 1 ' (1 + k)* _ b=1 - i = INTEREST RATE = 8% j = INFLATION RATE = 6% FUNDS ACCUMULATED
= $452 MILLION k = DISCOUNT RATE = 10% AFTER 40 YEARS
DEPRECIATION WITH NEGATIVE SALVAGE VALUE 400 . 1 i 300 -
\
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DECOMMISSIONING MODES
- IMMEDIATE DISMANTLEMENT
*
- PASSIVE SAFE STORAGE WITH DEFERRED DISMANTLEMENT
- CUSTODIAL SAFE STORAGE WITH DEFERRED DISMANTLEMENT l
TYPICAL SEQUENCE OF DISMANTLEMENT ACTIVITIES e PLANNING AND PREPARATION
-e CHEMICAL DECONTAMINATION j g e REMOVAL OF CONTAMINATED EQUIPMENT e MECHANICAL DECONTAMINATION OF STRUCTURES
- WASTE PACKAGING AND SHIPMENT e FINAL RADIATION SURVEY e . STRUCTURE DEMOLITION AND SITE RESTORATION (OPTIONAL) ,
e _ . _ _ _ _ _ _ _ ____________L '
SEQUENCE OF MAJOR DISMANTLEMENT ACTIVITIES I
+ MAIN PROCESS BLDG. -------------
1 I i I A ORAGE d EMPTY WASTE TANKS I I I SOLIDIFY WASTE , PLANNING AND SOLIDIFI- RESTORE g PR EPAR ATION SOLIDIFY AST CATION ~~-~~~~~~~[ S ITE PROCESS PLANT g WA3TE I I l
- F.R.S.S. -----------l STORE AND LOAD-OUT ,
SOLIDIFIED WASTE _j~~ AUEIll RY ~ ~j l
' t. _ _ _^ n e ^s _ _ _l 1 1 I I I I I I
-2 -1 0 1 2 3 4 5 YEARS FROM PLANT SHIJTDOWN
u j .. ., l-COSTS OF IMMEDIATE DISMANTLEMENT LABOR 21.8 (32.5%)- MATERIALS AND
. EQUIPMENT '
6.2 (9.3%) I 30.2 + .5. I%) E! WASTE MANAGEMENT
- SUBCONTRACTS 4.6 (6.9%)
UTILITIES, TAXES,ETC. 3.8 (5.7%) l I I I I i 1 5 10 15 20 25 30 35 MILLIONS OF 1978 DOLLARS e W b
. - . - _ . . . _m_ -m_ - ____ . - ._. .L _. . _ _ _. _ . _ _ ____-___________._______m___._________.__._a -
_______m___c_ - .,v_.__-'t___ -___m_-__.___.____.____-w_ . . _ _ _ _- - > <
COSTS OF IMMEDIATE DISMANTLEMENT LABOR lj LIQUID WASTE STORAGE MATERIALS AND EQUIPMENT f! 3
~ ~
WASTE MANAGEMENT 8I- - l SUBCONTRACTS m iB UTILITIES, TAXES, ETC. I I I I l 5 10 15 20 25 30 MILLIONS OF 1978 DOLLARS
, - . . - __s _m .___.__s _ _ . - _ _ _--__.--.__mm .- ._
RADIOACTIVE MATERIAL. DISPOSAL
;' DEEP GEOLOGICAL i
DISPOSAL COST VOLUME , SHALLOW ' LAND P5 BURIAL _ d. . DISPOSAL cost TRANSPORTATION [
. VOLUM E ONTAINERS a
l
~
i I i l 0 5 10 15 20 25 30 MILLIONS OF 1978 DOLLARS I I I I I l l-0 1 2 3 4 5- 6 THOUSANDS OF CUBIC METERS . e
- e,_ w w. - . --,i. -~ -
__._m _ _ _ _ _ _ _ _ _ _ _ _ ___m.__________2___ . _ _ _ _ .________.____________________.____._______________.e
E n + RADIATION DOSES FROM DISMANTLEMENT OF
; REFERENCE FUEL REPROCESSING PLANT I 250
- 7. 6 241
[ x (;
.e h.
200 - 197 2 *: tu . v2 ,: ' O ~' O 150 - Z O ro - P 5 a 100 -
<t .
T tu p r 51
'g 50 -
f . a 4 +g 2 -
+ 20 20 19 o E 3 E RE M AIN LIQUID WASTE FUEL AUXILIARIES TRANSPORT GENERAL PROCESS WASTE SOLIDIFl- RECEIVING WORKFRS PUBLIC BLDG. STORAGE CATION AND PLANT STORAGE
-_ ,- * - - - __.___________._______-_______._m_m_________ u _ . _ _ _ _ _ m.______s__________________.u_ .
't OCCUPATIONAL RADIATION DOSES FROM DISMANTLEMENT OF REFERENCE FUEL REPROCESSING PLANT AVERAGE-FACILITY AREA MAN YEARS MAN-REM MAN-REM / QUARTER MAIN PROCESS BUILDING 51.4 241 ,1.17 LIQUID WASTE STO. RAGE 51.8 197 0.95 WASTE SOLIDIFICATION PLANT 27.1 51.2 0.47 FUEL RECEIVING' AND STORAGE 9.3 19.8 0.53 AUXILIAnitiS 2.7 3.3 0.30 TOTALS. 142 512 0.90
. _ _ _ _ . _ . _ - _ . . . ____a_ __ mm . _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _
--__________-__.___._a vw
TYPICAL SEQUENCE OF SAFE STORAGE ACTIVITIES
- PLANNING AND PREPARATION
- CHEMICAL DECONTAMINATION
- MECHANICAL DECONTAMINATION AND FIXING g OF RESIDUAL CONTAMINATION
- EQUIPMENT DEACTIVATION
- ISOLATION OF CONTAMINATED AREAS
- FINAL PREPARATIONS FOR SURVEILLANCE AND N.AINTENANCE
- INTERIM CARE P
=m--+-. ,sw-a- , -
_s,.. .- .__ _ _ _...___ m.._m_ _. ..-_.. _ . _ . _ _ . _ _ _ _ _ __ _u .._ _ . .__.__ _ _ _ _ _ _ _ _ _ _ _ _ - . m_______-_____ _.___-___.__.-._._,.___._ _ _ . . _ ________________._____..__ _
SUMMARY
OF DECOMMISSIONING COSTS F o 160 ' 157 _ $8 FINAL DISMANTLEMENT k ljj INTERIM CARE o -j 120 -
~ .'
5o [n% INITIAL DECOMMISSIONING co 100 - 90 7.;g g 80 - 74 77 . 78 o m 60 - y; 40 - ? . ad h5 20 - 8 0 0 10 30 100 10 30 100 DISMANTLEMENT AFTER DISMANTLEMENT AFTER PASSIVE SAFE STORAGE CUSTODIAL SAFE STORAGE YtiARS AFTER SHUTDOWN WHEN DISMANTLEMENT BEGINS _j
COSTS OF PASSIVE SAFE STORAGE WITH DISMANTLEMENT AFTER 30 YEARS 28.0 (36.1%) LABOR . MATERIALS AND EQUIPMENT bl! 8.1 (10.5%) U 30.7 (39.6%) WASTE 1 .g.; ..
~
-. f.
3 MANAGEMENT
' ~ ~
6 - - x PREPARATIONS SUBCONTRACTS l1xp4 5.3 (6.8%) NxI FOR SAFE STORAGE l!!! !!l lNTERIM CARE TA S,ETC. - ' DEFERRED DISM ANTLEM ENT-1 I I I __ I I , 5 10 15 20 25 30 35 MILLIONS OF 1978 DOLLARS
l' COSTS OF.CUSTOD!AL SAFE STORAGE WITH DISMANTLEMENT-AFTER 30 YEARS LABOR 37.3(39.1%) h\\\\k\\\\\%
^ " A QU P T 9.5 (10.0%) ,
30.7 (32.2%) , ' e NAGEMENT h SUBCONTRACTS 4' I~ I PREPARATIONS FOR SAFE STORAGE UTILITIES, "~~~"~""'""""" 13.0(13.6%)
!!!l INTERIM CARE
~
TAXES,ETC. ' ~ DEFERRED I I I DISMANTLEMENT I I I 5 10 15 20 l 25 30 35 40 - MILLIONS OF 1978 DOLLARS 3 _ , _ _
$ E- - ' - - * ~ ~ ' "
RADIATION DOSES FROM DECOMMISSIONING 600 O 500 - x / 468 h GENERAL PUBLIC 460 .M' O TR ANSPORTATION g E " INTERIM CARE py 400 5y ' 343 DECOMMISSIONING 322
~
<Z 300 -
m< Cl $ P 200 - 183 3 ' 141 . ililiill fu (q
,'00 _
- u. I lh \
0 10 30 100 10 30 100 DISMANTLEMENT AFTER DISMANTLEMENT AFTER PASSIVE SAFE STORAGE CUSTODIAL SAFE STORAGE YEARS AFTER SHUTDOWN WHEN DISMANTLEMENT BEGINS
-_ __- .___ _________ _ _ - -_ __ _ __ . -_ .-. . _ - _ _ _ _ - _ - = _ _ _ _ _ _ _ - _ _ _ .
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EXAMPLES OF DISPOSITION CRITERIA FOR THE REFERENCE FUEL REPROCESSING PLANT FOR UNRESTRICTED USE . ALLOWABLE RESIDUAL TIME CONTAMINATION LEVEL, uCi/m2, AFTER PLANT SHUTDOWN BASED ON MAXIMUM ANNUAL LOCATION YEARS DOSE OF 1 mrem /yr FACILITY 0 1.4 E-2 S 10 1.5 E-2 30 1.7E-2 100 2.0E-2 SITE O 8.2 E-3 10 5.6E-3 30 4.3 E-3 100 3.2E-3
r CONCLUSIONS FROM FUEL REPROCESSING PLANT STUDY i
- DECOMMISSIONING IS FEASIBLE WITH EXISTING TECHNOLOGY.
- DECOMMISSIONING COSTS ARE SIGNIFICANT BUT NOT '
EXORBITANT
- 5 WASTE MANAGEMENT COSTS ARE HIGH
~
- HLLW STORAGE DECOMMISSIONING IS DIFFICULT, COSTLY g ,.
- INCENTIVES TO MINIMlZE CONCRETE CONTAMINATION e.
- REMOTE MAINTENANCE REDUCES COSTS, OCCUPATIONAL EXPOSURES
- LLW PROCESSING CAPABILITY IS ADVANTAGEOUS
- COMPARTMENTATION OF PROCESS AREAS IS ADVANTAGEOUS
,i MODEST OCCUPATIONAL EXPOSURE INCENTIVE TO DEFER i- DISMANTLEMENT ;
DECOMMISSIONING A PRESSURIZED WATER REACTOR 4 33
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CORE SHROUD RADIOACTIVITY AT REACTOR SHUTDOWN RADIONUCl.lDE 55Fe 50Co 53Ni 83Mo "C $4Nb 58Ni 1 1 HALF LIFE (YEARS) 2.7 5.3 100 3,500 5,750 20,000 80,000 cn EMISSIONS IB,7 8,7 8 IB,7 8 g,7 IB,7 RADIOACTIVITY 1.3 x 105 9.6 x 105 1.2 x 105 3.6 x 10- 1.5 x 102 5.4 7.4 x 102 (Ci) EXTERNAL DOSE RATE O.11 560,000 - - - 2.0 0.09 (R/hr)
DECAY OF ACTIVATION PRODUCTS 10a , , , , 10-i TOTAL CURIES _ NORMAllZED RADIOACTIVITY LEVEL 10 2 - - 10-' .- _. TOTAL - DOSE RATE l NORMAUZED RADIATION DOSE RATE 10" -
**Nb DOSE RATE 10-5
**Co DOSE _
RATE 10 -, Ni DOSE RATE : 55Fe DOSE
/ ' RATE - - -
10 0 20 40 60 80 100 120 140 YEARS AFTER REACTOR SHUT DOWN
i H COSTS OF IMMEDIATE DISMANTLEMENT ii l
- ,! STAFF LABOR 11.2 (26.7%)
. 6.5 0.
^ '
MATERIAL SPOSA ACTIVATED CONTAMINATED RAD 10.8 (25.5%) 3.I 1.7 3.2 DEMOLITION TOWER CONT. OTHER 8.0 (19.0%) g ELECTRICITY 4.4 (10.4%) SPENT FUEL SHIPMENT 3.1 (7.3%) EQUIPMENT AND SUPPLIES 3.0 (7.0%) NUCLEAR INSURANCE 1.0 (2.4%) CONTR ACTOR SERVICES 0.7 (1.6%) I 1 f t t 0 2 4 6 8 10 12 MILLIONS OF 1978 DOLLARS
RADIOACTIVE MATERIAL DISPOSAL COSTS 6 r - -- - - 7 l i deep 13,510 m3 5 - I a 2.25 lgg1gic disposal [7 // . shallow 8 1.6 land CO I i - burial 4 - i - 2 ' O l1191 m3l
- +:.:::.:.:.:::::
3 0- .:+:+:+:+:. transport 3 __I
- jjj::,:j jgj-j f M 2 :!:. 0. 6 :,::_::_:
- !::::::::j:j:j:j:
v> 2 -
.::j:!:::!:::::::'::
2568 m3 containers 1 - 2.2 40.4yM g,g 618 m3
-::0.4 :+:-: ;40.2Mu, a =i:j oo.5j:
z *;:::: 0 5 0.5 @E ACTIVATED CONTAINMENT OTHER RADIOACTIVE COMPONENTS BUILDING BUILDINGS WASTE CONTAMINATED MATERIAL
EXPENDITURE PATTERN DURING IMMEDIATE 15 DISMANTLEMENT 14 - ' DEM OLI-13 . TION
/ -
, s 12 - 1 k
- / .
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> LECTRIC POWE p -a;s:s g ;; .
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; s s M ,,.' 3 N b S UPPLIES ..f- A O 'xxx xxxvvvvvvw W ' n/M,A_enewswz
/ / / / / / / , eew/aawer
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-2 -1 1 2 3 4 YEAR OF EXPENDITURE RELATIVE TO REACTOR S 40
_ _ _ _ _ _ . - - - - - - - - - - - - - - - - - - - ~
1 COSTS OF PREPARATIONS FOR SAFE STORAGE STAFF LABOR kb] h I'. i ;2 ,'[h.i 72 MO D ' d5k51 4.5 (36.2%) SPENT FUEL SHIPMENT - k',
' .~. 'h .. h
. hn 'i 3.1 (24.4%)
ELECTRICITY / h4 .~i g 2.3 (18.5%) 3 EQUIPMENT ,:_
" r,
; ),g [g,$g}
AND SUPPLIES RADIOACTIVE q MATERIAL DISPOSAL Ef f . 0.7 (5.4%) NUCLEAR INSUR ANCE 0.4 (2.9%) CONT 9 ACTOR SERVICES 0.4 (3.0%) i I i t 0 1 2 3 4 5 MILLIONS OF 1978 DOLLARS O
111l l ' A 4zz3< m zU mm E 2: J ! zm_ 0 1 2 3 4 6 7 8 9 E Y E X P A-2 R "' E N O ^ D . F - I T E #Ae. - X N6 U 0 P- 1 E #Dsi R N #e F E D f./ i I T .. b E-
. __ OP RA n..- /LS U A. Z sFS nUP R .
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OU RR T , I O AN R E GG A E C3 P T R O E R P S A H R U4 T A D T I O W
' O N N S
ll l ,11I 1Ijl i ;1 li
CUMULATIVE COSTS FOR DEFERRED DISMANTLEMENT-R 80 uim A - IMMEDIATE DISMANTLEMENT F cc B DISMANTLEMENT DEFERRED 10 YEARS
$U $ 70 -
C - DISMANTLEMENT DEFERRED 30 YEARS o O D - DISMANTLEMENT DEFERRED 50 YEARS ~ 60 - E - DISMANTLEMENT DEFERRED 100 YEARS _z .
.h S- B 50.2 C 51.8 E 50.8 50 -
( D 46.8
, jz- A 42.1 f
y 40' ( oz g O 30 - ms J hm 20 -
<z
-s O r-J 10 3]
)
ou O i i i i I i l l I I I I
-10 0 10 20 30 40 50 60 70 80 90 100 110 YEARS SINCE REACTOR SHUTDOWN
= _ _ _ _ _ -
6
/
CUMULATIVE PRESENT VALUE COSTS FOR DEFERRED-DISMANTLEMENT l-80 . A - IMMEDIATE DISMANTLEMENT
- B - DISMANTLEMENT DEFERRED 10 YEARS
- u. C - DISMANTLEMENT DEFERRED 30 YEARS Of D - DISMANTLEMENT DEFERRED 50 YEARS WFm 60 -
E - DISMANTLEMENT DEFERRED 100 YEARS oc 3=5<8-fa$ 50 ~ z iE o 2 y z u. - A ' B 36.4 m Q O -40 ANNUAL INFLATION RATE: 6% [$$
.[ f ANNUAL DISCOUNT RATE: 10%
mjO
> 3 30 -
C 24.8 I l
< d D 18.3 ' B ggE 20 -
f .r , E 14.8 2O '
, r, d 10 -
5 E' ; 4 d l l l l l 1 I l l 1
-10 0 10 20 30 40 50 60 70 80 90 100 110 YEARS SINCE REACTOR SHUTDOWN
t: RADIATION DOSES 500 FROM 489' VARIOUS DECOMMISSIONING ACTIVITIES IMMEDIATE
, ! DISM ANTLEMENT-l400 -
l. g g PREPARATIONS FOR. w ~ SAFE STORAGE
- 8 300 -
)
i L. 227 s e200 -
.j 176 5
,2 134 40 m
E:-:-
- i :p :::-: 100
$100
;E
^58 ::' -
8 5 30 22 15 !!!! :i!!! 14 0 REACTOR AUXfLIARY FUEL SPENT FUEL MISC. TRANSPORT GENERAL BUILDING BUILDING BUILDING HANDLING WORKERS PUBLIC c- . c..
- - - ~ ~ ~ ~ '
l= RADIATION DOSES-FROM DECOMMISSIONING W 1400 0 E - Transportation Q 1200 -
, g -- Dismantlement ,
h_1000 4 m Preparations for Safe Storage 800 - aT 4 m l- "$ 600 - 2E F 4'00 - 200 1 0 0 ' ; - MA \ 0 10 30 50-', 100 YEARS AFTER SHUTDOWN WHEN DISMANTLEMENT BEGINS
)
.~
COST AND EXPOSURE COMPARISONS FOR
. DECOMMISSIONING A PWR l 70' 1400 . z 1220 DOLLARS $
z 60 - E0:0 MAN REM - 1200$4 52 5 8 !!!!! 50 47
. 50 -
- 9 _
1000e
$5 42 !!!!!!. '* $
E! 40 - Yiiii @ - 800 $ z3 .:.:.:. ::::::: -z a 9-mm :.:+: :-:o: 9
" ..-.... .... s-
*" +:+
s5 3r .+: 600 s
- .:. - :0:.. o
@E 9 ::::::' 460 440 -$
q :+:.: 420 400 8 5 a LP - 200 3 N 0 TE 10 YEARS 30 YEARS - ' 50 YEARS
.tEMENT SAFE STORAGE WITH DISMANTLEMENT DEFERRED (YEA IS)
~: . . . . _ m, - _ m. . . _ . _ _ . _ - _ .- _ __; _.c.___.._..._.__-m--._____m_.___._-__.__._._.__...___.__._m_.-_
9
SUMMARY
OF THE DISPOSITION CRITERIA FOR THE 1 REFERENCE PWR FACILITY AND REFERENCE SITE ACCEPTABLE RESIDUAL CONTAMINATION LEVELS FOR AN ANNUAL DOSE LIMIT OF 1 mn.m PER YEAR
' SURFACE CONTAMINATION SOIL CONTAM! NATION TIME AFTER ,
i SHUTDOWN MIXED TO 1 cm MIXED TO 15 cm (YEARS) ( Ci/m2) . (pCi/g) (pCi/g) .
' PWR FACILITY O 2.3 x 10-' -
100 3.2 x 10-2 --- SITE (GESMO) 0 1.4 x 10-2 9.4 x 10-1 6.2. x 10-2 . 100 1.1 x 10-2 7.4 x 10-1J 4.9 x 10-2 SITE (NUREG-0218) ' O 1.1 x 10-2 7.4 x 10- 4.9.x 10-2
' 100 6.6 x 10-3 4.4 x 10 .i -
2.9 x 10-2 W sw. m ma m m.m.m -~~mn---a.n...s maa.-_.n._,-= _--- - - a t_ - - - - -c.__ -- ._ a - _ -m _._.<--.--an_t-__aser-_a-
.- __-a1 -
.,____,--__.a- ---_-_ -___ _ _ --__.--_-_-_----___..=.---______,__,.--:_.------1_-__---a_.1- __ -- t .--- u --:s_._:--
- n.1x..----.
. _ . - = . .
~
~
CONCLUSIONS FROM PWR STUDY
- DECOMMISSIONING CAN BE ACCOMPLISHED USING PRESENT-DAY TECHNOLOGY i
- COSTS ARE SIGNIFICANT,-BUT MANAGEABLE .
- OCCUPATIONAL RADIATION DOSES ARE
.e SIGNIFICANT, BUT MANAGEABLE-
- PUBLIC RADIATION DOSES ARE SMALL, MOSTLY -
FROM TRANSPORT OF RADIOACTIVE-MATERIALS i
- THERE ARE COST'AND DOSE REDUCTION INCENT!VES TO DESIGN BETTER FOR DECOMMISSIONING
=
$ :\
_ _ . _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ -- _ _ _ . _ _ - _ _ - _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ ~ _ -
A BACKGROUND MATERIAL i l l l I l l T 50
- ~.' , }{yj .; gyy[yf; ., 7 9 ,
~
i l TECHNIC AL APPROACH FOR DECOMMISS IONING STUDY SELECT AND CHARACTERIZE FACILilYlSITE . _ PERFORM SAETY _ ANALYSES i f COMPARE SAETY, DECOMfilSS10NING : DECOMA 10NING COSTS, AND ALTERNATIVES PLANS AND OTHER EFFECTS - TECHNIQUES ESTIMATE COSTS AND : DEVELOP GENERAllZED DISPOSITION CRITERIA u lj
i l l
SUMMARY
OF DECOMM1SSIONING MODE CHARACTERISTICS ! Mode Facility Status Plant / Site Use Dismantlement- Plant Equipment ~- removed Plant - Unrestricted Continuing. Care Staff - none Site - Unrestricted Security - none Environmental. Monitoring - none Radioactivity.- removed Surveillance - none Structures - removal optional Safe Storage ! I Hardened Plant Equipment - none Plant - Conditional operating Non-nuclear Continuing Care Staff - Site - Conditional ' nnne on site Non-nuclear Security - hardened barriers, r'encing and posting Environmental Monitoring - infrequent Radioactivity - hardened i sealing Surveillance - infrequent Structures - partial removal optional ~- Passive Plant Equipment - none Plant - Nuclear Only operating . Site - Conditional i Continuing Care Staff - Non-nuclear i cptional (onsite) - ! routinc inspections i Security - remote alarms l Environmental Monitoring - routine periodic Radioactivity - immobilized / sometimes sealed Surveillance - periodic Structures - intact Custodial Plant Equipment - some Plant - Nuclear Only operating Site - Nuclear Only l Continuing Care Staff - some ! required Security continuous Environmental Monitoring - continuous Radioactivity - confined Surveillance - continuous Structures - intact 52 ! s
GENER AllZE D DE COMMISSIONING PATHW AYS AND ALTERNATIVES FOR MANY FUEL CYCLE FACILITIES-
._.._._.___._._._.._._._._.._._._..__._..__._.._,_.._._.q j ESSENil ALLY NO USE FOR NONRAD10 ACTIVE OPERAIl0NS l RESTRICTED OR I UNRESTRICIED j<
j i 'CONDIT10NAL USE j USE - INCREASING s i._._ _._.-._ j(SURVEILLANCE AND j CUSTODIAL MONITORING ._ DECOMMISSIONING PLANT I g WORK ! IN OPERATIO 1 SAFE STORAGE rh ' REQUIRED) . l
, I
" AC i 50A j c _ ;
g 7._._ . . _ . _ . _ . _ . . _ . _ . . g I i PASSIVE SAFE! gY _ _ _ __ _ _ _,_ p, _ RAD 10ACTIVliY_,_ _, _,!_ _, j_
-I l-STORAGE l DECAY -l
, .i i ,. .
- -l I
W I i l. N l-l-
! \ !_. RADl0ACilVliY l
l N HARDENED SAFE l DECAY ! l
- I STORAGE ~~~"I~-~~>~~~~ --~j--~~~-~~T~~~* -
(ENTOMBMENT) i -j l l j < < r o . DEFERRED ! . I i i I DISMANTLEMENT- [ j j , i_____._._._.._._._.._._.._.____._._._..._. , I lMMEDI ATE : i l j j DISMANi1EMENT .i L._..._._.i..__.__._.__.__.._._1.._._._._..__.__.__._.._._.__._,. I APPROXIMATE TIME : h DECISION POINT h DEClSiON POINT INCLUDING POSSIBillTY FOR CONVERTING TO OTHER NUCLEAR USE l l DECOMM!SS10NING ACTION
-- UNLIKELY ROUTE
. - - - - .. -- .-- .cw . --. , - - - . _ - - - , . - _ _ _ _ _ . _ . _ _ . _ . _ - _ - _
. al__--_-.__.--_.______x_- - - - - _ _ _ - . _ _ . _ _ _ _ . - - - - _ . _ _ _ - - _ _ _ _ _ - - . - _ _ _ . . _ _ - _ _ _ .
~
GENERIC ORGANIZATION OF DECOMMISSIONING REPORTS . Report Titles: SAFETY AND COSTS OF DECOMMISSIONING A REFERENCE NUCLEAR I Main Report I i
- 1. Introduction 1 i
- 2. Sumary
- 3. Review of Decomissioning Experience -
- 1ricludes lessons on past decomissioning
- 4. Decomissioning Alternatives and Study Approach l
- 5. Regulatory Considerations for Decomissioning
- 6. Approaches to Financing of Decomissioning
- Includes section on taxation j
- 7. Characteristics of the Reference , , _ Facility
. Site facility description and reference inventory, dose rates
- 8. Methodology for Detennining Acceptable Contamination Levels for the Decommis::ioned Reference Facility ,
CA. Environmental Monitoring and Record Keeping is a separate section for LLW Burial Ground Study Only
- 9. Decomissioning Activities
[LLW study ma have one section for safe storage and one section for di smantlement
- 10. Decomissioning Costs
- Cost of all activities will be sumarized here, including plant organizatior, and manpower, materials and services, waste disposal and transportation
- 11. Public and Occupatio'nal Safety
- Routine and accident, including non-radiological
- 12. Discussion of Results
- 13. Design [and Operational for LLW and Mill Tailings Only] Considerations to Facilitate Decommissioning
- 14. Glossary 54
,t
GENERIC ORGANIZATION OF DECOMMISSIONING REPORTS Appendix A. Reference,, , _ Facility Description B. Reference. Site Description C. Estimates of Residual Radioactivity D. Financial Considerations E. Radiation Dose Methodology
- Include details for " disposition criteria" derivation and dose calculational models used throughout the report and any detailed calculational results F. Decomissioning Activities for Imediate Dismantlement G, Decommissioning Activities for Safe Storage
- Includes deferred dismantlement
- For the mill study, sections F and G may be decommissioning of the mill plant and tailings, respectively'.
H. Cost Assessment Details I. Safety Assessment Details J. Environmental Monitoring (for LLW study and possibly mill tailings) K. Record Keeping (for LLW study and possibly mill tailings) 55 J
1
SUMMARY
OF ACTIVITIES FOR DECOMMISSIONING FUEL' CYCLE FACillTIES s i i PASSIVE SAFE CUSTODIAL SAFE STORAGE, STORAGE, INTERIM INTERIM HARDENED CONTINUING CONTINUING SAFE STORAGE CARE AND - CARE AND IMMEDIATE EVENTUAL ACTIVITY EVENTUAL PLANNING AND DISMANTLEMENT (ENTOMBMENT) DISMANTLEMENT DISMANTLEMENT I PREPARATION X X X ! X CHEMICAL DECONTAMINATION X X X X EQUIPMENT ] DEACTIVATION X X X X EQUlPMENT R EMOVAL X X e RELOCATION e
. X X MECHANICAL DECONTAMINATION X X X X IMMEDIATE DEMOLITION AND SITE
, RESTORATION X FIXtNG OF RESIDUAL RADIOACTIVITY X X X (SOLATION OF CONTAMINATED .
AREAS X X* INTERIM CONTINUING - CARE, SURVEILLANCE PARTIAL X X ULTIMATE DEMOLITION AND SITE RESTO R ATION POSSIBLE e # X = APPLIES e = APPLIES AFTER INTERIM CARE 56 t
1 DECOMMISSIONING HISTORY. REACTORS 5 POWER REACTORS 4 DEMO REACTORS 6 TEST REACTORS 50 RESEARCH REACTORS
- MODES - PROTECTIVE STORAGE, ENTOMBMENT AND DISMANTLING ,
O FUEL CYCLE FACILITIES U MILLS - 22 INACTIVE, ALL SOME DECOMMISSIONING, TAILINGS MAJOR PROBLEM, RISK NOT FULLY , DEFINED i UF8 CONVERSION - NONE TO DATE, ANTICIPATE NO PROBLEMS FUEL FAB - ONE DECOMMISSIONED, SEVERAL DECONTAMINATED AND RELEASED REPROCESSING - NONE.-NFS SITUATION INCONSISTENT WITH t CURRENT POLICY L. BURIAL GROUNDS - NONE 4
#' _ _ _ x..-mm.<x__x___-_ _ _ _ .__m_m___.m _.m_._____m__==______m__ _ =_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ __._m_____________-_m___.__m____ m __ -.._._._.___.__,_u.- _.m._m_-____ ______ _ _ . _ ___a_____.__.___ ,.__m__
- e
.. i 1
s l l TARI3t A Digest of Ndear Reactor DecommesseoningnW type ed s ea, f acssy heme C.. Monsormg lese leorege Decorrems. g, Decommew MeeceNaneown and tocasen nearsor tr.e Caego,)bt p,,,, gk) esoneng Lacree $satus System Meeiures saaned tsonmg Cose iniormenori l l Hel-1 Faned.8uad 1A iMW Jiemssuted - - - Ina - - Momogeneous
. neanon tsun-Deentt H%
Mai 2 Flued-fuel TR c1 MW Denmsmeed - - - 1%4 -. - 1 Mornopeneous Aeeder ispen- j meert> MNL l Aff Fluid. fuel TR iMW Desmentled - - - IMS -
.- l LAween '
Reenee tspefe. monel MNL P*+ 2A P'***utteed M 10 MWit) Deementled - - - 19h4 - - iPortahee wewr type. 4 i Medaum Power hght water ' Mamt nuadeeseed and Cseertional sooted
#97R s Craphne PR - ble $torege, -
Consmucus Consenuous 1%k15'1 - - IHen8ced Pro- moderated. 4 kndby, survenance maentenance
)
1 suctson teac. water cooled 6Aetwed, toes, e toe 411 (tayawev) Rist nand, W A CYTR Carchno-Pressure lube. heavy weise LPR 66 MWsg) Safe lecrage Dvoroduct Periodic Weided eineurt iWO - - imoshtwited) per 10 CPR surweehance locked doon, WrEems Tube (0,0) coceed E secussy fence I Acactori and modevered l Part, SC ' 6tasiam Craphne DPR 2% MW p; Ensomhed Oper ateg psot requwed Weideo closure. 1%9 - Malum, toeb moderased, Decommesuonmg authorisaison concrete cover took 3 years todeum coo *ed termansied weatheeproofed PNef Orgeruc coceed DPR 45 MW pj tatombed Opewating Noi required 1%9 Welesed clo. ore - Decommisuaeung (Pagua DeuCleef and moderesed authorssation Concrete cowr, took ) yeart 4 Powee f adeity) sermenated waterprooted } Pious. Ohe BONUS WWR wsth DML 10 Mw m Eniomhed Opeearms Not reovered Weided eiosuee. 1970 - -. , e8oikog Nir. nuclear auper. authoriwson concrete cover.
- clea Supon heaftre es*mmated locked doors, heePer Pttirer tecurtly bence kimon)
Escon, herto Ence Wehen keed Asomics imet. M TR 50 hw Demamled - - - W1 - Seteerch nateenal Model Reactor 1-94, home. We5hension, DC geneous-fuend Pashlinder gWR LPs 110 MW Se8e tuotege Weided teoivee, m Two cent licunne C orwinvous 192 517M - Seous f ans.10 nucher supee. (mothballed) 10 07R $0 poseep escurwy fort,0} securiev 6ence sins
- with steam soon.only and by.
l Plam conwruon product 10 CFA 30 . Isa.1 tiound metas TR - Deactwesed, - Pubhc acrew - 19t) 1?'$,000 (cost d eptennemde comed Dedeuted a via P stsonal to conven for Netsonal f one treade, deconiarm. nased. con Park Service pubisc access M- _ . en temver htT1 = werted for onsvi 1%6 1d4ho pubiac acreis se ton memor PW R LTR 23.5 Mway noe necesse Ponansson intrunon welded <fonwee. 19'J -lisM Owned. opee-6anisty emothballed) oniv a6erme locked doors, ased, and de-haston, P A secutify fence commisuoned by SNI (Santon l Pour. seat tapero I ment Corporven) l
$ pot nottum eoided. LfR
- 20 MW g) 5efe liorage Deproduct intrumon Weided closues 19') -
rnouthee,t taw tenoihbelledy to sease alarme locked doors, tapemnemal escurte, 'ence Istl 04 toe Essetot) tre,cteer, At lik tewee SWR, toisil DPR Desme inled Operauns ' poot tegurred hood required
$8 MW te) 1974 461SM t _ . g t eecier:lik fuel supon and partial author:wien took 3 years kreer. Men. healmg converwon aerrveneied A512 - M 10 MW ' Dumontled - - 194 -
4Aeroepace j _ l A Worth, TA
... . . . .. - - - ~ -
CTR - M 10MW Desmentled - - - 19/4 - f[srounal Tent
- wor, U.S o torce .
asAAP 4 A Worth,11 l l al A - M jMW Domemned - - - 994 - - A6ecuen,1ese Awemtarl U1 Aar Derve . DeAAf Pl. Worth. T1. 6er sepsenesson of notes see she honorn of stie nest page +. . f o , 1
+
, +
6 4 e e i l l 1 l 1 A111 M. (Coritenued; I 1 i Tepe of t ear l f actiwy home C. 4 Moresorms 5sfe storage Decommn. Deconwn e. uniceaanecem and Loseson Reector f ree Caeservebe pows, gamgi c) esoning to;e,w, Saavus Sywem Messeret poned moreng Cost J in:_ flRMi t Soslawsi coosed, LPR M Mwgp Sale 5 orere Poeiseosos' Conamuous Lected ecors, Monese Co. tem W5 56 95M - imothbone4 ontyi8l secue4, securey feme Aa'q'h, lorcelb i Peebl4 Pressunaed M $ 4 Mugl Denhertt6ed - - -
- weier TyDe. 19?$
- 4Poneo6e Medsome Peasef bgfe weser Plaftll fnocerMed and Mcneurdo Isa- coceed Ison, Ante *ctecs 1
HTR Gasphne TR 2een Pommer Demem>d - fHansend leu mooerated W7 SG.)$M -
)
Remoort Escheaaid, w A l eaw Pool tit a Mw pp Pesteady typroduct hooi reguned hot requeed - - - 1 Lynchburg. W4 Damentled per 10 CfR j i JD CE ivlit BWR with LTR 1. .ew gy 5ete Storage Poseenuon d Amme.m (o, nuew supes- Cone,muous Locute doors. , 5 tmoehmetem oney weu *, sorce =curar wace CA heat 1
- m. Piu, t,$ e wane, in , Mw ,,, se. i.0,. P- Commuo L ,ed doo.s. -
s tenok , 5a* - - dusky, Ohse tmnthbaneth only secuttry lorceID necurny koce 'j l Peach borsom ) Cas cooled. LPR 115 Mwggy la4 5torage Possesuon Cononooia necev ee ntab. - - i
*a '
Tosh Co, PesW graptete ImothbaNed) only escurety forceM hshed mooseped V9m t $wt LPR 50Mw gi Sede '-orage Poseensson Continuous (% euscuog tecked daiws - - - emothbeRed ente secuety lotee@ 6ecumy fe sce aohns wee < wnh unem R ewor piana conver. Alameda Co. CA sfion wellenghonne Tank LTR 40 Mwnj Safe $torage Poesseuon Contmucus Locked doort - - - i Ieu Reettet imothballedj only eeq;urity forceM gen,rity lenge waha Meil. P4 . T 5El Cieepnete PP Jo Mw n; 1 eve Storage - . (keshum Reec. rricoerated, In progreggth, - - modeteed 1%e emothbened . Etw Ispe'u lot $tum conded 19t,7); dre to E MWp) 8 menti, AJ, Sense trianthng parted Sunene, C & fl9?ap j 1RL ford TR 5 anew gg Partially - - linduernel Lineetirected 1g*' Lest than 6_ d%mamned use l>v NL fridug-Reanor Labe $1M fofortet 171c,, itses lacorpcea Research Rede- Med, Decom. lewn Plameboro, nuyi onmg noch Ni .two yeared) f NOTI 51 ACRONTM5e I le>gyng speces > the tabular Columnt fads (, ate 36sther was unabst to locate the maormahon from M lhe hie 8Mure Medd@d AtomfC Inlefnetton&l
$WE &nshng water Reeclef (bl(.a. .l.,e.ro. tte.t.
Of R ee.dW1 Y N O Deve49 amens flRDA, '
..Pe e Pomes P'tufact6on PR
- Produchon R eader (afC) Mhet + Hohheld hatronal Latioratory, formetty Oet Redge Neisonal gpt a tegensed Powee Remor Laboamore tORNL)
HTCR - High fenperature Cas Coosed Reansw LIE e %erente(flest React (as DPP W LAM = Lol Alamob bChemd6C Lafso#alorV Demon 6trattoft POwef PWat rARf ' 9'euglear Aefotoece Re6earch Iacthty M e IWhtsry N A bA = NahorneeAeronauttCs and 5Date Admmystrcen TR e 11e Resetor II,penmenasutegeacetu NRT$ - hahonel 8eador lesamtbeaten SRL $avarman Rivee Lacerstory IC)Poewer f asagt we given M electrical fe' os thermal ly megawatis (MW) or kilowatts (kw) l Id$95p~roduct Lice < stet erwy to enhet "Bvotosfue NRC* asped in accordance w4th 10 Cf R Part JD I or '9nwoskn:ilerente abued by~an'a'gl " : ave in accorsiance wah authotely grensed by' ! 10 CPR Pen lith l M'fet to be riar.ed in see, parage imoshbailedu peo. ded ugnehcant esper=nce in developens l tneerna 84 neethoxb - l Mesosan.conme required an vt.ei. e for me*dRC e=ura, due in othee lo.te had onuie noi been wcure, force..eveasbeisty unretmed to the decom. aebie, the ~RC me, he.e requ es 1 otner cofttrol staedauses le 8. manised escurtty or exete controll. IG'inie 10 CSA Part SQ 4 SE 5%.
- Authorusten ce Changes. Teus and taceewnenu" and i 5610
Appheaten inw A. : of Licente ce Conuructen Pemen" proeione the eums av whsch a hcomee may smend he hceme en obtam 4 : nenly simus. Once thei pensesssonenly he:ense # genuetl. feedor operateur: It fios perpretited.
J lh lhe $R1 footory o oniy 1 of 6 complete 6ecomammmen and desmenthng programs as the ' A4 lange insgenga. CA,, QQ(. owned ute at part of the Al Decontammmen and Despouten of Iaohteet bugtem.
* ' il'The one n th, Ant for o J.m 2 commemal reacce in be approved to, the governmens for unseereacied use. " d I
*1 1
1 1 J d e
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