ML20204F928
| ML20204F928 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 07/30/1986 |
| From: | Nelson R, Vincent L PACIFIC GAS & ELECTRIC CO. |
| To: | |
| References | |
| NUDOCS 8608070004 | |
| Download: ML20204F928 (13) | |
Text
~
f0k bdct O. @) M Testimony of ROBERT T. NELSON Humboldt Bay Power Plant Unit No. 3 Decommissioning Project Manager and LOUIS E. VINCENT Attorney Pacific Gas and Electric Company Before the Subcommittee on Investigations and Oversight and the Subcommittee on Energy Research and Production of the Committee on Science and Technology U.S. House of Representatives July 30, 1986 INTRODUCTION On July 22, 1986, this Committee extended an invitation to Pacific Gas and Electric Company ("PGandE") to present testimony concerning the decommissioning of the nuclear unit of the Humboldt Bay Power Plant (Unit 3). The following testimony will address in particular PGandE's present actions and future plans for decommissioning its Humboldt Unit 3, and the regulatory and financing mechanisms for those efforts.
Unit 3, which utilized a boiling water reactor, was constructed between 1960 and 1963. It is one of three units in the Humboldt plant; the other two units are thermal (oil or gus) fired. Unit 3 began commercial operation in August 1963 and operated until July 2, 1976. During the years Unit 3 operated, it had one of the 8600070004 860730 PDR ADocg 05099333 PDR
best operating records of any nuclear plant in the United States with an overall capacity factor of 63.0% and an availability factor of 85.9%.
DECOMMISSIONING OPTIONS In studying decommissioning of Unit 3, PGandE contracted with Gibbs and Hill, Inc., who subcontracted with Nuclear Energy Services to perform a study to evaluate the decommissioning alternatives for Unit 3. The decommissioning alternatives available were:
DECON In the DECON method, equipment, structures, and those portions of the facility containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use.
ENTOMB The ENTOMB alternative involves encasing radioactive contaminants in a structurally long-lived material, such as concrete. The entombed structure is appropriately maintained, and there is continued surveillance until the radioactivity is removed from the site or decays to a level that permits unrestricted use of the property.
SAFSTOR The SAFSTOR alternative involves placing a nuclear facility in a safe condition and maintaining it in that state until it is dismantled and all remaining radioactive materials are removed. The facility may be left intact except that all fuel assemblies should be removed from the reactor and radioactive fluids and wastes should be removed from the site.
The study, which was completed in 1982, stated that the most preferred decommissioning alternative would be to place the unit into Custodial SAFSTOR for a period of up to 30 years, followed by either dismantlement or entombment of the unit. The recommendation for SAFSTOR was based primarily on the fact that there are currently no facilities operating in the U.S. that could take the spent fuel which is stored onsite. PGandE will retain the spent fuel at the site until the DOE is ready to take custody in accordance with the Nuclear Waste Policy Act of 1982.
CUSTODIAL SAFSTOR PGandE announced its intention to decommission Unit 3 on June, 1983. The selected decommissioning method was custodial SAFSTOR followed by delayed DECON of the unit. This was consistent with the recommendations of the earlier decommissioning alternatives study.
Although selection of the SAFSTOR method of decommissioning was based primarily on the lack of alternatives for disposal of the reactor spent fuel assemblies, there are some additional
significant benefits of the SAFSTOR option. Since Unit 3 shares the site with two fossil plants that are planned to remsin in operation, the operation and maintenance personnel for these units can also provide the necessary surveillance for Unit 3. The 30 year SAFSTOR period will also allow radiation levels to decay. It is estimated that dismantlement after 30 years will result in total radiation exposures approximately 1/4 of those estimated for immediate dismantlement.
Additionally, over the 30 year period, additional industry and decommissioning experience and developments in technology may simplify the process and result in lower final costs and exposures.
Projects such as the Shippingport decommissioning will be observed closely to benefit from their experience. The Shippingport plant is comparable both in age and size to Humboldt Bay Unit 3 and much of its experience is expected to be applicable. I recently attended a briefing at the Shippingport facility at which the information exchange r.rogram was described. PGandE will participate in this program and plans to use the information to update our plans for the final dismantlement of Unit 3. Updates of projected costs for Unit 3 are currently required every 3 years and updates of decommissioning plans are required every 6 years by the California Public Utilities Commission. In addition to cost information, demonstration of successful decommissioning techniques and ,
information regarding radioactive waste processing and disposal '
will be extremely valuable in performing these updates.
DECOMMISSIONING PLANNING Prior to preparing the decommissioning plan for Unit 3, a review was conducted of the decommissioning experience from other nuclear facilities such as the Plum Brook Reactor Facility, Peach Bottom Unit No. 1, and the General Electric Vallecitos nuclear facilities.
This experience together with project specific guidance from the NRC staff formed the basis for Humboldt Bay Unit No. 3's Decommissioning Plan.
When the decision to decommission Unit 3 was announced, a project team was formed to plan and accomplish the decommissioning. The team was composed primarily of personnel from the Humboldt Bay Power Plant. The scope of work to place the unit into SAFSTOR does not require large numbers of outside personnel. This permits utilization of workers who are not only familiar with the unit but also with plant work practices. In addition to the onsite project team, key personnel in PGandE's general office were included to provide support in the areas of licensing, contract services, quality assurance and engineering.
Following establishment of the project team, planning sessions were held to establish a work breakdown structure, and schedule and cost estimates for the project. The following objectives were considered in the decommissioning planning:
e To modify plant facilities to support long term storage of spent fuel, minimize generation of radioactive wastes, and minimize necessary maintenance and surveillance during SAFSTOR
_5_
e To layup nonoperating plant systems e To reduce general area radiation levels in the vicinity of equipment to be operated or maintained during the SAFSTOR period to as low as reasonably achievable (ALARA) o To decontaminate plant facilities to the extent practical e To process and dispose of radioactive wastes remaining onsite at the beginning of SAFSTOR decommissioning activities and any wastes generated during decommissioning a To establish baseline conditions and a monitoring and surveillance program for the SAFSTOR period As early as possible in the project, a meeting was held with the NRC Project Manager to discuss the project and the information to be included in the decommissioning license amendment. It was deteamined that an application would be made to amend the operating i license to a possession-only license. The application would include as supporting documents:
e Revised Technical Specifications to be issued following NRC approval of the decommissioning plans e SAFSTOR Decommissioning Plan providing a physical and radiological characterization of Unit 3, a description of actions to be taken to place the unit into SAFSTOR, and a description of the programs to be in effect during SAFSTOR
e Quality Assurance Plan o Proposed Dismantlement Plan l e Environmental Report e Revised Emergency Plan e Revised Security Plan f By letter dated July 30, 1984, PGandE proposed to the NRC: (1) amendment of our license to a possess but not operate status, (2)
^
deletion of certain license conditions related to seismic modifications, (3) revision of the Techinical Specifications to reflect the possess but not operate status, (4) Decommissioning of Humboldt Bay Unit 3 in accordance with the plan included with the submittal, and (5) extension of Humboldt's license (DPR-7) for 15 j additional years to November 9, 2015, to be consistent with the decommissioning plan. On July 16, 1985, the NRC revised our Humboldt license to a possess but not operate status. Presently, the staff has issued a draft environmental statement for the decommissioning of the Humboldt facility and is currently awaiting public comments which are due August 16, 1986. The NRC also has under consideration the remaining license amendment requests for approval of the SAFSTOR plan and the decommissioning of the unit.
Pursuant to NRC regulations (10 Code of Federal Regulations) the public will have an opportunity to request a hearing with regard to these remaining license amendment requests.
l 1
PREPARATION AND DECOMMISSIONING
-l Since January, 1984, work has been ongoing to prepare Unit'3 for l SAFSTOR decommissioning. Work performed prior to the NRC approval of the Decommissioning Plan is limited to systems and equipment not required to be operational by the existing Unit 3 Operating License and to activities which may be performed under the existing license. This work has included:
e Unloading the reactor core e Flushing, draining and securing systems not required for the present cold shutdown condition e Processing, packaging and disposal of radioactive wastes Upon approval of the Decommissioning Plan and associated license amendment, SAFSTOR decommissioning activities will begin. These activities will include:
o Complete the layup of systems not required during SAFSTOR 1
e Complete the modifications of the spent fuel storage pool facilities e Complete modifications of the plant security system o Complete decontamination of systems and components
e Process,spackage, and ship the radioactive waste generated by SAFSTOR activities e When the activities to place Unit 3 into SAFSTOR are complete, perform baseline radiological surveys DECOMMISSIONING COSTS AND FUNDING On January 21, 1981, the California Public Utilitir.s Commission
^
(CPUC)' issued its Order Instituting Investigation No. 86 (OII 86)
"to ensure that adequate funds for decommissioning nuclear generating facilities will be available and to ensure that the costs of decommissioning are equitably distributed, and investigations will be instituted into present and alternative methods of financing this future cost." After hearings over-several months the commission issued its Interim Order and established three governing criteria:
- 1. The annual collections for decommissioning are to be invested in an external sinking fund and managed by an outside party;
- 2. The required funds for deccmmissioning are to be accrued assuming exemption from taxes both '.ot the annual payments and for the interest earned on the bvd;
- 3. The annual payments are to be developed based on the estimated ultimate costs to decommission.
_9_
)
A word of explanation is in order. " Ultimate cost" refers to estimating the cost of decommissioning at the future date on which the decommissioning is to occur, and then dividing that cost equally among the years between the present and that future date. i This is to be contrasted with the " current cost" methodology which takes the cost of decommissioning in the year in which it is to be performed and attempts to adjust the contribution between the present and that future date based on inflation and related factors. In each year, then, the ratepayers will be contributing an equal amount in value rather than an equal amount in dollars.
On September 19, 1983, PGandE filed its Application with the CPUC to recover its unrecovered net capital investment in the Humboldt Nuclear Unit, and to collect the necessary decommissioning funds.
After hearings which stretched over two years, on December 4, 1985, ,
\
the Commission authorized PGandE to collect in an external or trust '
fund the necessary decommissioning funds (estimated $58 million expressed in 1986 dollars) over a four-year period. The actual collection has been delayed pending regulations under the Tax l
Reform Act of 1984 which would set tax treatement of the funds, r Briefly summarized, under PGandE's proposed external fund or Trust Agreement, most supervisory and administrative control of the Trust is in the hands of a Committee. The Committee will have the power to select trustees and investment advisers and to establish investment trust policy, among other matters. The Committee would be established and Committee members selected by the CPUC. The operating and administrative control of the trust would be retained by the CPUC through its control of Committee memberships.
~ .
On July 10, 1986, the Internal Revenue Service issued its Temporary Regulations governing nuclear decommissioning cost under the Internal Revenue Code. While PGandE has not had a chance to study fully the new regulations, it appears that approximately 50% of the Humboldt decommissioning cost will received favorable tax treatment.
1 On January 1, 1985, the State of California's Nuclear Facility Decommissioning Act of 1985 became effective. Basically, that Act directs the establishment of external sinking funds for decommis-sioning purposes for all nuclear plants in the State, with the filing of a decommissioning cost estimate with the Public Utilities Commission, and a review of that cost estimate at each general rate case of the involved utility. The statute specifically acknowledged j the NRC's role in defining decommissioning activities, and requires that the fund be managed so as to qualify for the tax deductions pursuant to Internal Revenue Code, Section 468A.
SAFETY ISSUES In preparing the SAFSTOR Decommissioning Plan extensive safety analyses were conducted. Due to the time since Unit 3 last operated, the potential for, and any consequences of, an accident at the facility during SAFSTOR have been greatly reduced.
,_._,...,_..,-_._,,,,,,__,_,.,__,--_,,__._,,_,.n., -- _
_~____,_,___.,_m. , , _ , , , _ , _ _ . . . _ _ _ _ _ _ , _ , _ . _ . . . . . _ ,
e The amount of decay heat being generated in the spent fuel has decreased to the point that the fuel no longer needs water for cooling. The fuel can be adequately cooled by air to prevent any fuel melting. This eliminates the need for backup cooling systems.
e Almost all of the radioactive gases present in spent reactor fuel have decayed away. If the only significant radioactive gas remaining (Krypton-85) were released, the maximum estimated offsite doses would be a fraction of an individual's annual background radioaction exposure.
s e Due to extensive decontamination of the facility and disposal of low level radioactive wastes, the quantity of radioactivity existing onsite and the concentration of radioactivity in emmissions from the plant are much lower than when the unit was operating. It has been shown'through e:sironmental monitoring that no significant environmental ;
effects occurred when the unit was operating so it is not likely that SAFSTOR will result in any environmental ;
effects. l
-l 1
1 Because seismic issues were a major concern while the unit was '
operating, the SAFSTOR analysis took the conservative approach that no credit would be taken for the ability of the facility to
. . . . . ~ . - , - _ -.. _ -. _.__.._, _ , _ _ . _ . - . , - - . _ _ _ . . - . . . . _ . - ._
withstand an earthquake. The safety studies assumed the spent fuel was damaged by the earthquake and the containment facility was also damaged. The study determined that there would be no significant offsite consequences from the event. Since the spent fuel storage racks were assumed to fail during an earthquake, we are modifying the individual fuel assemblies.
The project to decommission Humboldt Bay Unit 3 will demonstrate that custodial SAFSTOR is a viable option for the decommissioning of a commerical nuclear facility. It can also serve both as a model and an experiment for future decommissionings, much as does Shippingport. Therefore, PGandE is willing to entertain technical and financial involvement from the private or government sectors.
l l
l
_ _ _ _ _ .