ML20154N507

Statement to Environment & Atmosphere Subcommittee of House Committee on Science & Technology Re Nuclear Reactor Decommissiong on 770615

ML20154N507
Person / Time
Issue date:	06/15/1977
From:	NRC
To:
References
TASK-TF, TASK-URFO NUDOCS 9810220008
Download: ML20154N507 (11)

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STATEMENT TO THE '

ENVIRONMENT AND THE ATMOSPHERE SUBCOMMITTEE OF THE HOUSE CordliITTEE ON SCIENCE AND

, TECHNOLOGY REGARDING l

NUCLEAR REACTOR DEC0t/JiISSIONING U. S. Nuclear. Regulatory Commission June 15, 1977 9810220008 770615 PDR MISC g 9810220008 PDR

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Background

.This testimony discusses the decommissioning of nuclear reactor facilities.

Decommission 1ng nuclear reactors is not new to the NRC.

, Various concepts for decommissioning have been under study and have been put into practice for q

a number of years.

Since 1960, 5 licensed nuclear power plants, 4 demonstration nuclear power plants, 6 licensed test reactors, 28 licensed research reactors and 20 licensed ,

critical facilities have been decommissioned. The experience gained in these decommissioning actions has been factored into the present Nuclear Regulatory Commission (NRC) requirements for reactor decommissioning.

Current Regulations and Guides for Decommissionine of Licensed Reacters Regulations applicable to licensed reactor decommissioning are described in the Code of Federal Regulations Title 10. Title 10 CFR Part 50 Section 50.82,

" Application for Termination of Licenses" provides rules by which a licensee may make application to the NRC for authorization to dismantle a reactor I facility and terminate its license upon satisfactory completion of dismantlement.

Title 10 CFR Part 50 Section 50.59, " Authorization of Changes, Tests and Experiments" and Section 50 90, " Application for Amendment of License or Construction Permit" provides the rules by which a licensee may amend his license to attain a " possession only" status. This state of a facility license results from NRC approval of deletion of requirements in the facility Technical Specifications that are applicable to reactor operations.

Title 10 CFR Part 20, " Standards for Protection A6ainst Radiation" establishes procedural requirements and the radicactivity concentration limits for release of radioactive material to the environment.

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V ('~)h Title 10 CFR Part 51 Section 51.5, " Requirement for Environmental Impact Statements, Negative Declaration and Impact Appraisals" requires the preparation of either an environmental impact statement or a negative declaration for license amendments or orders authorizins the dismantling or decommissioning of nuclear power or test reactors. An environmental impact appraisal must be . . .

prepared to support the negative declaration. Negative declarations and environmental impact appraisals have been prepared by the NRC staff for dismantling and other decommissioning actions involving licensed reactors as required by Title 10 CFR Part 51 3ection 51.5.

I Iitle 10 CFR Part 50 Section 50 33 " Contents of Applications; General Information" requires that an applicant for a license show financial ability (a) to operate the plant and (b) to cover the cost of permanently shutting down the facility and maintaining it in a safe condition, i.e., meet decommissioning costs. Title 10 CFR Part 50 Section 50.71 " Maintenance of Records, Making of Reports" requires a licensee to file a copy of its annual financial report with the NRC. This

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urequirement continues in effect until the license is terminated.

Regulatory Guide 1.861 " Termination of Operating Licenses for Nuclear Reactors"

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describes conditions and procedures currently acceptable by the NRC staff for cach decommissioning alternative. Published in 1974, this guide has been 1

distributed to utilities and other organizations that possess facility operating licenses.

1 l Regulatory Guides are issued to describe and make availabe to the public I methods acceptable to the NRC staff of implementing specific parts of the l Commission's regulations, to delineate techniques used by the staff in i evaluating specific problems or postulated accidents, or to provide guidance I to applicants. Regulatory Guides are not substitutes for regulations and l

compliance with them is not required. Methods and solutions different from l those set out in the guides will be acceptable if they provide a basis for the l findings requisite to the issuance or continuance of a permit or license by the Commission.

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Metho'ds for Decommissionirir

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~l The three. methods of decommissioning delineated in Regulatory Guide 1.86 as l

-acceptable to-the NRC are mothballing, entombment, and dismantling.

- .Mothballing,is the process of placing a facility in a non-operating status. ,The ,

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facility'may be left intact except that all reactor fuel, radioactive fluids and' .-

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! non-fixed radioactive wastes such as ion exhange resins, contaminated scrap.

' materials:and contaminated chemicals.are removed. The existing license is amended

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.to'a " possession only" status and continues in effect until residual radioactivity-decaystolevelsacceptabieforreleasetounrestrictedaccessoruntilresidual -

. radioactivity is removed. The " possession only" license is a reactor facility  !

j. license that permits a licensee to possess the facility but prohibits operation

-of.-the facility as a nuclear reactor.

i p Entombment / protective storage consists of removing all fuel assemblies, radio-active fluids-and wastes followed by the sealins of remaining radioactive material within a structure integral with the biologica1 shield or by some

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.other method-to prevent unauthorized. access into radiation areas.- A program

.of inspection,. facility radiation surveys and environmental sampling is required

.for a licensed facility that has been entombed. However, the annual costs of L

access control would be less than for the first discussed alternative of moth-balling as security guards would probably not be required. The entombment of L

the facility would permit this relaxation of security guard access control because.pNysical~ access to the " sealed" residual radioactivity would be i,

made-very difficult.

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.Dismantlins is-defined as removal of all fuel, radioactive fluids and waste,

.cnd all radioactive structures. Surface contamination levels have been established in Regulatory-Guide 1.86 (Table 1) which must be met prior to -l

' termination.of,the' facility license. In addition to meeting the surface con,- , , ,

j tamination levels, the acceptability of the presence of materials which have I been made radioactive by neutron activation would be evaluated on a case-by- j case basis prior to termination of the license. In general, however, all sig-

nificantly activated components, such as the reactor structural components near .

1 the core, would have to be ruoved to meet the surface contamination lirits (Table 1). '

'A~brief description of the major activities that would be involved in-decommissioning a nuclear power reactor are described belcw. I The first step that would be taken in decommissioning a reactor facility l.

would be to remove all of the fuel from the reactor and using appro-l ~

priate containers ship the spent fuel to off-site sterage facilities. .

When all of the spent fuel is removed from the facility essentially all of the high level waste'will have been accounted for.

2. The spent. resin materials, radioactive liquid and other non-fixed radio-a active materials will be packaged for shipment to off-site facilities.

This~ activity is part of normal operation, and poses no unusual ,

technical problems.-

Decontamination of radioactive components by use of appropriate chemical

-3 agents would be undertaken as necessary. Since it is expected that the

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I components would probably ; earded, strong chemical agents can I

be u' sed and effective decontamination, achieved. The radioactive E

decontamination! solutions used:for this purpose would again be I

removed.to.off-site-disposal.

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4. --Removal of components ~with induced radioactivity. If it is desired even 1

the most highly radioactive components of the primary system could be l ' dismantled and shipped for off-site disposal. There is, however, P . strong economic consideration as well as other factors which will be

. discussed later which make it desirable to postpone the ultimate dis- 1 l

mantling:for long periods of time. Some development work may be required i i

for this phase of the decommisioning operation if early dismantling is,

' desired. . Experience'With dismantling the Elk River components provide clear evidence that such-techniques are practical.

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<The foregoing operations-would also be generally applicable to decom-minsioning of fuel reprocessing facilities. A unique differ ence is that i in a reprocessing plant the separated fission products (high level waste) i ;must befsolidified and' shipped off-site. This process has not been i L i demonstrated on a commercial scale for a fuel reprocessing facility.

L ' In.the case of the' reactor the fission products are contained in irradiated fuel which is ea>sily' transported to a reprocessing i

plant or in the future to a disposal facility. There are over 25 i

' years of experience in transporting irradiated spent fuel elements  ;

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without mishaps.

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To date, all but one of the 11 licensees of power or test reactors have chosen nothballing as the alternative for decommissioning. A recent Atomic Industrial

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Forum (AIF) report indicates that modern 1100 MWe nuclear plants may be moth-balled, also, but will probably be dismantled at some time in the future. In this respect, the AIF report estimates that after Cobalt 60 radiation has decay d gufficiently (approximately 100 years) the residual radioactivity would be ricoved. The 11 smaller test and power reactors now nothballed may retain possession'only or by-product material licenses until radioactivity has decayed to levels acceptable for license termination. More likely, however, the residual radioactivity will be removed from these facilities also at so=etime in the future to allow the licenses to be terminated. The Saxton facility licensee for instance has indicated that the residual radioactivity may be removed after about 50 years.

The AIF study confirms our conclusion that per=anent entombment is not a practicable elternative in dece=missioning modern (1100 MWe) nuclear power plants because the concentrations of Ni 63 and Ni 59 would be too high relative to 10 CFR Part 20 concentration and radiation exposure limits. The AIF study indicated, however, that temporary entombment (about 100 years) may be the best alternative for certain nuclear power plants.

The Commission does not currently require that a specific decommissioning alterna-tiva be selected at the time of licensing but the Commission does examine various decommissioning plans and their costs and environmental impacts prior to issuance of r_n operating license for a commercial power reactor or test reactor. We assure 2

Atomic Industrial Forum, AIF/NES P009, "An Engineering Evaluation of Nuclear Power Reactor Decommissioning Alternatives," Nove=ber 1976. This study was performed by the Atomic Industrial Forum for its nuclear industry members to aid in establishing preferred decommissioning alternatives. This study is still under review by the NRC.

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ourselves in each case that feasible decommissioning alternatives, including citernatives for complete dismantling, exist and that the applicant either ptssesses or has reasonable assurance of obtaining the necessary funds, cs required by our Regulations (10 CFR 50 33F). We do not require bonds

{cr' setting aside of any contingency funds at the operating license stage end do not impose any particular decommissioning plan as a condition of the -

operating license.

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'Fcderal and State regulatory commissions have historically treated plant i

d: commissioning and maintenance costs as allowable operating expenses I r&coverable through rates chargeable to customers. It is therefore l l

reasonable to assume that the decommissioning and subsequent maintenance i

costs would be charged to operating expenses either in the year they are incurred or amortized over a period of years according to the policy of the

, rate making regulatory authorities.

Th3 cost to decommission has been shown by the AIF study and our independent cve.luation referred to above to be a small factor in the overall cost of cp rating a nuclear power plant. Our environmental statements consider the impacts of decommissioning for the-alternatives previously described.

Estimated costs of decommissioning for mothballing are about $1 million plus cn annual maintenance charge on the order of $100,000. Estimates or entomb-c nt or dismantling show a large variation arising from different assumptions as to level of restoration. For example, complete restoration, including regrading, his been estimated to cost $70 million. At present land values, consideration

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of an economic balance alone likely would not justify a high level of g restoration. However, planning required of the applicant at this stage will ensure that variety of choice for restoration is maintained until the end of useful plant life. The licensee should be able to fund these costs out of * * ',

current revenue.

Therefore, we do not perceive the cost of decommissioning nuclear power reactors several decades from now -- as a crisis situation or a problem t

that requires crash efforts to resolve.

We do believe that an orderly effort to establish procedures and requirements to provide greater assurance that these funds will be available should be initiated.

For the large modern plants, it is clear that postponing the removal of certain components until the radioactivity has decayed to permit more direct access for dismantlement may prove to be the most desirable alternative with respect to the environment, radiological effects and cost. The degree of dismantlement would be determined by an economic and environ = ental study involving the land and scrap value versus the complete demolition and removal of the complex. The AIF study concluded that the most cost effective means of decomissioning a facility would involve either an initial mothballing or sntombinE approach followed by dismantling. It would appear.that this cpproach, if it is proven as the most cost effective, has several distinct advantges. Perhaps the most important factor is that the reactor facilities

.cre located on sites which have favorable characteristics as energy production centers.

Therefore, after a reactor facility has been used for its designed lifetime mothballing or entombing until the induced radioactivity levels are f

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reduced to acceptable values could be easily accommodated. This is especially true if the utility continues to use the particular site as an electrical i generating center. 'While predictions as far into the future as 100 years  :

would be viewed with so=e reservation continued assessment of that activity would'be available to the NRC. If for any reason a site were to be considered for other uses, dismantling of the facility could always be achieved..

.In light of the fact that decommissioning of a nuclear power reactor will not occur until about thirty-five years after the issuance of an operating license, it'should be recognized that requiring a specific plan for decommissioning at the time.of licensing may foreclose other more desirable methods which may be developed in the future unless the plan can be changed in the future. Assuming bthelatter,itappearsthatourpresentpracticeofassuringthatvarious citernatives have been considered provides for the necessary assurance that geconomically viable methods of decommissioning will be available when needed.

Since EPA is responsible for developing generally applicable environmental standards, any criteria the NRC develops for acceptable levels of contamination must be consistent with EPA standards. In the meantime, however, the NRC i

-hns provided guidance for use with respect to acceptable surface decontamination limits.(Table 1, Regulatory Guide 1.86). Specific guidance for materials i

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-which have been activated during the operation of the reactor are being

- dcVeloped in the current study underway at Battelle Northwest Laboratories.

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There are essentially no high level radioactive was.tes which are an integral j' part of-a nuclear power reactor. These fuel elements will be shipped off-L site for ultimate storage. All'other radioactive waste - solid, liquid, and .

gas -- would-be packaged and removed from the site at a time and in a manner

l deemed most practical. It is important to note that the high level wastes contained in the reactor fuel are in a form that is readily transportable _to ultimate storage facilities without further' processing.

Therefore,'in summary, the 'JRC

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1.- Has established considerable effort to the study of decommissioning nuclear reactors.

2. Has established reactor decommissioning alternatives acceptable to the NRC.

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3. .Has had experience in decommissioning over 50 licensed reactors.

4.- Does consider decommissioning at the time of issuance of a Construction Permit and again at the time of issuance of an Operating License.

5. Does have studies in progress on reactor decommissioning including costs,

' methods, and acceptable levels for unrestricted relase of radioactive materials.

.b. Does believe that an orderly effort should be initiated to establish i s

sprocedures and requirements to. provide greater assurance that funds to accomplish decommissioning will be available when needed.

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