ML20206G535
| ML20206G535 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/18/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8606250338 | |
| Download: ML20206G535 (73) | |
Text
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' ORIGINAL UNITED STATES OF AMERICA C'
- NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Briefing on La Crosse ,
~
Request for an Exemption to Reduce Primary Property Value Insurance (Public Meeting)
Docket No.
1 i
Location: Uashington, D. C.
Date: Wednesday, June 18, 1986 Pages: 1 - 59 ANN RILEY & ASSOCIATES
('
Court Reporters 1625 I St., N.W.
8606250338 860618 Suite 921 PDR 10CFR PT9.7 PDR .iashington, D.C. 20006 (202) 293-3950
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.m 1 D 1 SCLA I MER 2
3 4
5 6 This is an unofficial transcript of a meeting of the
'7 United States Nuclear Regulatory Cawmission held on 8 6/18/86. .. In the Commission's office at 1717 H Street, 9 N . tJ . , Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 24 25
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ---
4 BRIEFING ON LA CROSSE REQUEST FOR AN EXEMPTION 5 TO REDUCE PRIMARY PROPERTY VALUE INSURANCE 6 ---
7 Public Meeting 8 Wednesday, June 18, 1986 9 1717 H Street, N.W.
10 Washington, D.C.
11 The Commission met, pursuant to notice, at 12 2:05 p.m.
13 COMMISSIONERS PRESENT:
{
14 NUNZIO J. PALLADINO, Chairman of the Commission 15 JAMES K. ASSELSTINE , Member 16 THOMAS M. ROBERTS, Member 17 FREDERICK M. BERNTHAL, Member 18 LANDO W. ZECH, JR., Member 19 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
20 S. Chilk M. Nordlinger 21 R. Vollmer J. Zwolinski 22 J. Stang W. Houston 23 AUDIENCE SPEAKERS:
24 B. Woods C. Ong 25 L. Gilbert
2 1 PROCEEDINGS 2 CHAIRMAN PALLADINO: Good afternoon, ladies and 3 gentlemen. Commissioner Bernthal has been detained but he 4 will be joining us shortly.
5 This afternoon, the Commission is meeting with the 6 staff to discuss the request of Dairyland Power Cooperative, 7 that the Lacrosse Nuclear Power Plant will be -- be exempted 8 from the Commissioner primary property amage insurance 9 " coverage requirements.
10 In 1982, the NRC received -- promulgated a rule, 10 11 CFR 50.54(W), that requires all ccmmercial reactor licensees 12 ro carry onsite property damage insurance in order to provide e" 13 assurance that funds would be available to clean up after an 14 accident. The current minimum primary insurance coverage is 15 $500 million.
16 By letter dated June 29, 1982, DPC; that is, 17 Dairyland Power Cooperative, requested an exemption from the 18 provisions of Part 50.54(W) to reduce the coverage from $500 19 million to $180 million. This request is unique because it is 20 the first operating reactor to request relief from the $500 21 million level for primary property insurance required by
___._--_22_. 50.54(W).
23 The staff has provided its evaluation of the 24 Lacrosse request in SECY 86-151. I understand that this l 25 policy statement, as well as the staff's briefing slides for i
3
, 1 this afternoon's discussion, are available on the table in the m
2 back of the room.
3 Let me ask, do any of my fellow commissioners have 4 any additional opening remarks?
5 COMMISSIONER ZECH: No.
6 COMMISSIONER ASSELSTINE: No.
7 CHAIRMAN PALLADINO: All right, then, let me turn 8 the meeting over to Dick Vollmer, Acting Deputy Director for
, 9 the Office of Nuclear Reactor Regulation.
10 MR. VOLLMER: Thank you, Mr. Chairman. As you 11 indicated, we had sent down SECY 86-151 on the insurance 12 exemption for Lacrosse, and we're meeting here because the 13 Commission indicated they would like to discuss the matter 14 further.
15 I have with me today Wayne Houston on my right who
~
16 is Deputy Director of the Division of BWR Licensing; and John 17 Zwolinski on my left who is director of one of the BWR Project 18 Directorates; and the Licensing Project Manager, John Stang.
19 And I'd like to turn it over to Mr. Stang to start the 20 briefing. He'll be talking about a --
21 CHAIRMAN PALLADINO: Could you speak into the mike?
22 I think some people in the back of the room are not getting 23 it.
24 MR. VOLLMER: He'll start out by discussing the 25 plant, which is a fairly unique plant, but I think the fact it
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1 does have some unique features gives technical basis for what
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}' 2 the staff proposes. And then he'll go into the basis for the 3 exemption request itself.
4 MR. STANG: Thank you, Mr. Vollmer. Good afternoon, 5 gentlemen. As Mr. Vollmer indicated, we're here today to 6 brief you on the Lacrosse insurance exemption. Before we get 7 into the details of the exemption we'd first like to brief you 8 a little bit on the plant design, since some of you may not be 9 familiar with Lacrosse.
10 [ Slide.]
11 We have a slide here that shows the Lacrosse site, 12 to give you a little bit of an indication. As you can see,
' /~ 13 Lacrosse is the small plant in the foreground. There is the 14 containment, the turbine building and the stack.
15 [ Slide.]
16 And this slide here gives you a little better 17 picture. Lacrosse is on the right, and on the same side is a 18 large, 350-megawatt coal-fired plant. And as you can clearly 19 see, Lacrosse is a very small nuclear reactor.
20 [ Slide.]
21 Lacrosse is located in Wisconsin, and the population 22 density around Lacrosse is very low. The five-mile radius 23 EPZ, the population density is approximately 13 people per 24 square mile. And we have a couple slides here to give you a 25 better idea. This is looking down the Mississippi, south, and
5 1 then there is the site.
O 2 [ Slide.]
3 And now looking north up the Mississippi again you 4 can see the site, to give you a little better perspective of 5 Lacrosse and its location in Wisconsin.
6 Lacrosse is one of a series of plants funded by the 7 AEC. The NSSS and its auxiliaries were funded by the AEC and 8 the balance of the plant by Dairyland Power. In 1973, the AEC 9 sold the entire plant to'Dairyland Power and provided them 10 with a provisional operating license.
11 Lacrosse, as you know, is a boiling water reactor, 12 single cycle, forced recirculation. The NSSS supplier was
( 13 Allis-Chalmers, the AE was Sargent & Lundy, and the turbine 14 supplier was Allis-Chalmers.
15 (Slide.]
16 In this next slide, we're trying to show here that 17 Lacrosse is a very small nuclear power plant. As you can see, 18 the design output, 165 megawatts thermal, 50 megawatts 19 electric. If we go down and take a look at the core, you can 20 see that number of fuel assemblies is one-tenth that of a 21 large boiling water reactor. The massive UO-2 in the core is
._ _ __22_ __1approximately-one-twentieth that of a large boiling water 23 reactor.
24 One other thing we'd like to point out is that the 25 clad for the fuel is stainless steel and not the typical zirc
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6 ;
i 1 that you see in most plants, and this would limit hydrogen A
2 problems following an accident.
3 CHAIRMAN PALLADINO: Would there not be a 4 possibility of any metal-water reaction?
5 MR. STANG: There would be some but it would be very 6 limited. In other words, Lacrosse has done a study, provided 7 us with a study, that shows hydrogen does not become a problem 8 for 16 years. Which, their postulated cleanup will only take 9 seven years.
10 CHAIRMAN PALLADINO: It doesn't become a problem for
> 11 16 minutes, you say?
- 12 MR. STANG
- Sixteen years.
13
{^ COMMISSIONER ASSELSTINE: Are there other advantages 14 to the stainless steel clad other than the lack of a hydrogen 15 problem?
i 16 MR. STANG: Well, the stainless steel clad was an 17 AEC type of design that they wanted to try at Lacrosse, and 18 Lacrosse, once they obtained the plant, just duplicated it.
19 COMMISSIONER ASSELSTINE: So I guess in terms of 20 performance -- any advantages over zire? Or disadvantages?
21 MR. STANG: Not to my knowledge.
22 COMMISSIONER BERNTHAL: There must be a reason we 23 went to zirc alloy.
24 MR. VOLLMER: Yes. There are -- one disadvantage is 25 in this thermal neutron efficiency. Of course, stainless l
! 7 1 steel is more absorptive than the zirc alloy. But at the time
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( 2 this plant was built, it wasn't clear which would be the best 3 cladding. And for example, Humboldt Bay had stainless steel 4 cladding, and this plant also. There may have been one other.
5 But generally, the path that was taken was zirc 6 alloy for perhaps a number of reasons.
7 CHAIRMAN PALLADINO: You emphasized the small size 8 of the plant. In my experience, which the last practical 9 experience was at Shippingport which was 60 megawatts, and I 10 used to think of that as a pretty good sized plant. But aside 11 from that, how does the cleanup cost, in ycur mind, relate to 12 the size of the plant? I thought I read where there was not a
"^
13 strong correlation between the two.
14 MR. STANG: Well, we'll cover that.
, 15 CHAIRMAN PALLADINO: You will? All right.
4 l
l 1*6 MR. STANG: But I can -- in NUREG-2601, which of 17 course you know was;the technical basis for the current rule 18 and the proposed rule, it basically drew that conclusion.
19 However, Lacrosse has gone through, in a very detailed study, 20 and showed through accident analysis similar to what was in 21 2601 that they're -- I won't say directly related to thermal 22 megawatts, but it did come out and very clearly show that for
~
23 the Lacrosse type of accident, it is -- I won't say 24 proportional, but it would be less than what a larger reactor 25 would be.
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8 1 CHAIRMAN PALLADINO: For the same kind of accident.
f'h s 2 MR. STANG: Yes, sir, and we will cover that in 3 detail.
, 4 MR. VOLLMER: Before we go too far, I'd like i
5 to indicate on the question on the hydrogen, there can 6 certainly be, as you know, a metal-water reaction with 7 stainless steel and water to produce hydrogen. And so the 16 8 years that was mentioned must be a radiolysis problem or i 9 something like that.
10 COMMISSIONER ASSELSTINE: Yes.
11 MR. STANG: But there can be an accident, a core i
12 melt accident, hydrogen generation with stainless steel as
/~ 13 there is with zirconium.
14 Now, the temperatures are different. I guess you 15 have to have a higher temperature with the stainless and the 16 oxidation rate I think is lower.
j 17 COMMISSIONER BERNTHAL: You'd have to have a lot of 18 hydrogen and I'm sure, and the oxidation rate would be a lot j 19 lower, I would guess, s
20 MR. VOLLMER: Yes. But I don't want to give the 21 idea that there wasn't cne, or it takes 16 years to produce 22 any. ~~' T --
- 23 COMMISSIONER ASSELSTINE
- Okay.
i i 24 MR. STANG: We have a slide to give you a better 25 representation of Lacrosse showing a primary coolant system.
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l 1 COMMISSIONER ASSELSTINE: Are you going to leave ;
(' l 2 this slide that you had just previously? I had one last ;
3 question on that last item, the shutdown condenser inside 4 containment. Why was that dropped on later boilers? It seems 1
5 like a nice feature.
6 MR. STANG: Well, it is. I think, as I have run 7 into it in fire protection at a lot of the older boilers, 8 that's a very good way to go and they can rely on that and 9 they don't have a big problem.
10 COMMISSIONER ASSELSTINE: Right.
11 MR. STANG: As I understand it, seismic 12 consideration was -- seismically to stabilize the condensers
(~ 13 in these plants is very difficult.
14 COMMISSIONER ASSELSTINE: Okay.
15 MR. VOLLMER: But to answer your question, I think 16 in A45 where we're looking at shutdown, long-term shutdown and 17 so on, I think thisitype of a feature is being revisited 18 because it's a good nature --
19 COMMISSIONER ASSELSTINE: Yes. In fact, isn't this 20 what GE is talking to the Japanese about for their advanced 21 boiler?
22 MR. VOLLMER: I believe so, yes, sir.
23 COMMISSIONER ASSELSTINE: It's amazing. Okay.
24 MR. ZWOLINSKI: I'm sure you're aware that isolation 25 condensers that you find in older Mark I's are quite large,
9 10 1 and indeed, it goes back to seismic. And I think we have O( 2 difficulty locating them inside the current Mark I's 3 containments, also.
4 [ Slide.]
5 MR. STANG: As the Commissioner mentioned, we do i 6 have an isolation condenser inside the containment, and we <
7 also have a stored water source inside of containment, a 8 42,000 gallon tank. And let me trace out the primary systems I 9 for you.
i 10 Basically, we have the reactor, main steam lines, 11 turbine, condenser, condensate pumps, main feed, back into the 12 forced recirculation loop and then again back into the 13 reactor.
14 Lacrosse has three major ECCS systems, high pressure l 15 core spray -- we have two high pressure core spray pumps, an 16 alternate core spray pump which discharges directly into the 17 top of the reactor,iand something that I find very unique to 4
18 Lacrosse'is the emergency service water system, and it 19 consists of three Volkswagen-driven portable pumps that can be 20 taken down to the Mississippi and put in and can be discharged 21 right into the containment.
j 22 COMMISSIONER ROBERTS: Would you go to the slide 23 previously that you didn't show? I can't read it'. What's the 24 diameter of the containment?
25 MR. STANG: I apologize.
f
11 1 [ Slide.]
O i
2 Sixty feet.
3 CHAIRMAN PALLADINO: Sixty?
4 MR. STANG: Yes.
5 CHAIRMAN PALLADINO: In diameter?
6 MR. STANG: Yes, sir. I apologize. This was about 7 the best slide we could get of containment and get it on an 8 8 1/2 by ll.
9 Does anyone have any questions concerning any design 10 features of Lacrosse that we could answer at this time before 11 we go on?
12 CHAIRMAN PALLADINO: Apparently not for the moment.
{ 13 [ Slide.]
14 15 COMMISSIONER BERNTHAL: I've got a question on 16 containment, also. What does maximum temperature mean? Does 17 that indicate that for the entire thermal load after shutdown 18 you could only reach a maximum temperature in containment of 19 280 degrees? Is that basically what it's saying?
20 MR. STANG: Yes, sir.
21 COMMISSIONER BERNTHAL: So basically, there's no 22 accident scenario where you can~ thermally-po~-the-containment.p --
23 MR. STANG: Yes, sir.
24 COMMISSIONER BERNTHAL: Of course, the hydrogen 25 generation question is separate, but that would be pretty
= - _ - - - - . _ _ = . _ _ .
12 1 hard, I guess. Okay.
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2 CHAIRMAM'PALLADINO: Are you saying the environment 3 in the containment can get to 280 F?
4 MR. STANG: yes, sir.
5 CHAIRMAN PALLADINO: 4 Why is that? What limits it?
6 COMMISSIONER BERNTHAL: All the thermal heat.
7 That's all the heat contained in the core.
J
- 8 MR. VOLLMER: Small. primary systems.
9 CHAIRMAN PALLADINO: Well, are you counting on 10 containment sprays and things like that?.
11' MR. ZWOLINSKI: Low pressure injection. You've got 12 your' low pressure injection which will cool the reactor down,
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~
13 and the maximum amount of heat I can get out will raise the 14 containment temperature to 280 degrees. And with a major 15 LOCA, I will have a pressure increase, and the design pressure 16 is about 48 psig.
17 CHAIRMAN PALLADINO: Say that 'a gain. ,
18 MR. ZWOLINSKI: If I have a large LOCA I'll have a 19 pressure ramp-up and a temperature ' ramp-up, and I wash those
.s 20 out with my injection systems such that the maximum thermal 21 v loading on the containment will go to about 280 degrees; the 22 maximum pr' essure rise will.go to about 48 pounds. And with 23 time, that will decay out. '
24 The strategy usedihy Lacrosse in th,eir emergency procedures is to simply flood up the containment and-se;11ow for 25 1 F
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13 1 the 42,000 gallons of inventory that's in the tank in the top A
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2 of the reactor to flood down. Plus I will pump in another 50, 3 60 thousand gallons and flood to the midplane of this 4 reactor. It will become thermally stable, and with time, I 5 will move into the recovery process.
6 COMMISSIONER ASSELSTINE: Does it have a containment 7 spray system or not? It doesn't look like it.
8 CHAIRMAN PALLADINO: Well, is that a core spray?
9 MR. STANG: It has got a core spray.
10 CHAIRMAN PALLADINO: Okay, thank you.
11 [ Slide.]
12 MR. STANG: The current insurance requirements are
{ 13 based on capacity which can be provided by property insurers.
14 The total minimal currently required by 50.54(w) is 15 $585 million, $500 million of which is primary property, and 16 $85 million in excess capacity.
17 [ Slide.] i 18 This next slide --
19 CHAIRMAN PALLADINO: What is the $85 million, again? )
20 MR. STANG: Excess.
21 COMMISSIONER ROBERTS: Excuse me. What are the 22 acronyms in this?
l 23 MR. STANG: I will tell you.
24 CHAIRMAN PALLADINO: What do you mean by excess
'- 25 capacity? Do you mean this is extra that is available?
l 14 1 MR. STANG: Yes, sir.
1 0
'. 2 CHAIRMAN PALLADINO: But they don't have to buy it?
3 MR. STANG: No. The current rule requires 4 $500 million in primary property, and $85 million in excess.
1 5 That is what the current rule requires.
6 CHAIRMAN PALLADINO: Excuse me. Go ahead.
7 MR. STANG: NML is Nuclear Mutual Limited. ANI is 8 American Nuclear Insurers. We have Bob Woods from state 9 programs.
1 10 MR. WOODS: MAERP is Mutual Atomic Energy Insurance _
11 Pool. NEL2 is Nuclear Electric Insurers, Ltd. Those are both 12 captives set up by the industry itself to provide insurance.
('\ 13 MR. STANG: Going on, this next slide shows which 14 utilities, the status of which utilities have obtained or 15 received excess property damage insurance exemptions. As you 16 can see, Yankee, Big Rock Point and Lacrosse each have 17 received exemptionsifrom the staff to reduce the required 18 maximum from $585 million to $500 million.
19 COMMISSIONER BERNTHAL: I don't understand why that 20 is worthwhile. What is the big deal about knocking 85 off of 21 585? I 22 MR. STANG: Basically, the amount of insurance --
. 23 premiums that you have to pay. The less insurance you have to 24 cover, the less premium savings to the utility, basically.
25 COMMISSIONER BERNTHAL: So basically, they have
15 1 asked for, whatever it is, 12, 13 percent reduction?
O.
2 CHAIRMAN PALLADINO: I'm not sure you save 12 or 13 3 percent. That's not true on the Dairyland case.
4 MR. STANG: That is true.
5 COMMISSIONER BERNTHAL: Well, whatever you save, 6 it's a small fraction of --
7 MR. STANG: Yes, sir.
8 COMMISSIONER ASSELSTINE: But for large plants, it 9 is still just $585 million?
10 MR. STANG: Yes, sir. It is currently the large 11 plants. That is the current rule.
12 CHAIRMAN PALLADINO: I thought for large plants we 13 either talked about or required $1 billion.
{~'
14 MR. STANG: Not currently. That is in the proposed 15 rule.
16 COMMISSIONER ASSELSTINE: That is the new rule.
17 That is right. Forilarge plants, $585 million doesn't bear 18 much relation to what it takes to clean one up.
19 MR. STANG: Yes, sir. Dairyland Power will be the 20 first -- Lacrosse will be the first power reactor to come in 21 and ask for a reduction in the primary property damage limit, 22 and they are asking for a reduction from $500 million down to 23 $180 million.
24 Could we have the next slide?
25 [ Slide.] '
16 1 Dairyland Power justified their exemption based on 1%
'.. 2 an analysis they performed. They performed an analysis of 3 accident scenarios similar to accident scenarios in 4 NUREG-2601. Basically what they did, they analyzed two 5 scenarios. One was a large break LOCA below the core 6 resulting in 100 percent fuel clad damage, no fuel melt.
7 CHAIRMAN PALLADINO: Why did they assume that?
8 MR. STANG: This is very similar to a scenario in 9 2601.
10 CHAIRMAN PALLADINO: All right, go ahead.
11 MR. STANG: 2601 has a basis of scenarios, and what 12 Lacrosse did, actually the $180 million is based on the second
{^'; 13 scenario here, a large pipe break below the core resulting in 14 a LOCA, with a 100 percent fuel clad failure and a 50 percent 15 fuel melt. This was the worst case accident that was 16 postulated in 2601.
17 COMMISSIONER ASSELSTINE: Is the first accident 18 sequence basically the DBA for this plant?
19 MR. STANG: Yes, sir.
20 COMMISSIONER ASSELSTINE: And the second one then '
21 goes beyond that to assume 50 percent melt?
22 I MR. STANG: Yes, sir.
23 COMMISSIONER BERNTHAL: I don't understand why -- I 24 may be jumping ahead a little bit here. I am jumping behind 25 to jump ahead. On the previous slide, this $500 million
17 1 example that you have already given, why would we not expect
(~% ,
i 2 this to be the first of several now, then, if this one is 3 dropped to 180? I see several others here that it seems to me 4 -- certainly Big Rock Point, perhaps Yankee Rowe -- would have 5 a similar argument, would tney not?
6 MR. ZWOLINSKI: I am under the belief that we would 7 expect to see on a case basis some of the smaller power plants 8 asking us for relief should this one be granted.
9 COMMISSIONER BERNTHAL: And if our new rule for i
10 $1 billion -- I don't even know where that stands -- if that 11 goes through, then do these exemptions still apply?
12 MR. ZWOLINSKI: The way the rule is phrased right
^
, 13 now, yes, they would still apply.
14 CHAIRMAN PALLADINO: You wouldn't up these?
15 MR. ZWOLINSKI: No, you wouldn't up these. I guess 16 I would characterize this activity as a rebaselining of the 17 correct amount of insurance this particular plant should 18 have. As commissioner Asselstine pointed out, when you get to 19 the much larger facilities, when you get to the $1.06 billion, 20 that is probably the right level, and maybe it isn't even 21 enough. I don't know. I haven't studied that particular
! 22 activity. But both at Big Rock Point and Yankee, two of the 23 smaller operating reactors, I would anticipate that they would 24 at least look at this with a great deal of interest. I am N- 25 i sure the ratepayers would request that they look at this.
l I
i
18 1 COMMISSIONER BERNTHAL: What do you mean by damage?
O i 2 You are really talking about the probability for a 3 catastrophic core melt, no matter what the size of the core 4 is; isn't that what you mean when you say damage, cleanup, 5 basically? You can't have that kind of catastrophically big 6 cleanup job for cases like this where you can't have the 7 catastrophic core melt, or at least it is highly improbable.
8 CHAIRMAN PALLADINO: Are you considering in the 9 analysis accidents that would lead to a core in about the 10 same state as TMI-1, or 2, excuse me?
11 MR. STANG: Yes, sir. Basically we went all the way 12 up to a 50 percent fuel melt, to 100 percent clad damage and
- 13 50 percent fuel melt, and that is my understanding. I feel 14 TMI was around a 5 percent fuel melt.
15 COMMISSIONER BERNTHAL: But you didn't answer my 16 question. Would you address the question of whether the point 17 that is being made here is that you cannot with this plant 18 have a circumstance where you would have a big mess to clean 19 up, or at least the odds of that are much lower than they are 20 for larger plants? Is that the essential point here?
21 MR. STANG: Yes. I think what we are trying to 22 emphasize is we have such a small size and a small amount to 23 clean up that the $180 million more than covers it.
24 MR. VOLLMER: I don't think it's a matter of the 25 odds; I think it's a matter of the size of the job to clean it
19 1 up, presuming you have something that is comparable to TMI-2,
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i, _ 2 a fairly extensive core melt, and the judgment is that to 3 clean that up, you would require less than you would have to I 4 pay to clean up a large reactor under the guidelines here of 5 2601.
l 6 COMMISSIONER BERNTHAL: Well, let's assume the worst 7 case, where this is one-tenth, more or less, I guess, and you 1
8 scatter it all through the containment. You are saying that 9 the mere fact that the total radiation inventory or 10 radioactivity inventory is one-tenth makes it sufficiently 11 easier, that it is really a lot easier to clean the whole 12 thing up as compared to ten times that amount scattered 13 around?
14 MR. ZWOLINSKI: Your magnitudes are sufficiently 15 less as to cause a reduction in cost. It is not one for one.
16 If you are talking, for example, noble gases or iodine, you 17 are talking factorsi of 10 and as much as 20 less, and 18 therefore it is just not as expensive to clean that up. I 19 think a very key point, and I want to come back to this, is we 20 presented the design characteristics of the facility. It 21 takes about 90,000 gallons to cover the midplane of the core, 22 and once we cover the midplane of the core, we will reach a 23 posture of being essentially stabilized.
24 CHAIRMAN PALLADINO: Do you mean 90,000 in the i
x- 25 containment?
20 1 MR. ZWOLINSKI: That is correct.
O.
- i. 2 COMMISSIONER BERNTHAL: But that is the point I'm 3 getting at. You are really resting your argument more on the 4 low probability of scattering that core throughout 5 containment, are you not, than you are on there being, as you 6 say, a linear correlation between cleaning up one-tenth a mess 7 compared to a full mess?
8 COMMISSIONER ASSELSTINE: But if you assume 50 9 percent melt, that can't be right.
10 MR. VOLLMER: Yes. My understanding is it is the 11 amount of mess you have to clean up. Now, correct me. You 12 guys are more expert on it. But that is my understanding
! ~
i 13 because you have already assumed'you could have a substantial 14 core melt.
15 COMMISSIONER ASSELSTINE: The impression I had was 16 the key factor was that it stays in the containment and that 17 drove the lower cleanup cost level more than anything else, 18 and I guess I would be interested in hearing a bit more about 19 what the basis is for that assumption, that the stuff won't i 20 get outside the containment into the auxiliary building and i
21 the penetrations won't fail or whatever so that you have a 22 high degree of assurance that even with a 50 percent melt, the 23 stuff stays bottled up in the containment.
24 MR. ZWOLINSKI: A key assumption in the work that i .
! '- 25 was done in NUREG-2601 is the fact that we will indeed keep i
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s I
21 1
1 the containment bottled up. Now, you do have penetrations.
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2 You do have a series of valves. You do have valves that will 3 leak. There are systems in place which will process liquid as 4 well as airborne waste.
5 COMMISSIONER ASSELSTINE: Even if you have got a 6 melt and have fission products, large quantities of fission 7 products released into this big bowl of water?
8 MR. ZWOLINSKI: The analysis does not take us beyond 9 the -- the analysis assumes that we are able to bottle things
. 10 up. I am talking about leakage through two isolation valves, 11 for example, which would be a small number, not a very large i
12 number. So my plant, systems can indeed handle that kind of a i '; 13 release.
14 COMMISSIONER ASSELSTINE: I guess what I am 15 wondering is are you really confident that that is a realistic 16 analysis, that you can really count on it staying bottled up 17 in there? If the 50 percent melt is what we considered for 18 the other plants, if that is the basis for what we used to 19 make the determination on the financial insurance for cleanup 20 for the other plants, fine. But I gather the big difference 21 is that in the other plants, one of the big reasons the cost
. 22 is higher is because you can't on things staying in the 23 containment, you have to plan to clean up auxiliary buildings 24 and things like that as well, just as we had to do at TMI.
-- 25 MR. VOLLMER: I might point out that, as John had
j 22 1 indicated earlier, if you look at this plant relative to a lot ix 2 of the current plants, much is outside in the reactor building 3 in the larger plants. Much of that equipment is inside in 4 this particular containment building.
5 CHAIRMAN PALLADINO: But is a risk of contaminating 6 the auxiliary building or any other area so much less in this 7 plant than, say, at TMI?
8 COMMISSIONER ASSELSTINE: That is the key, question.
9 CHAIRMAN PALLADINO: Yes. I am following up in a 10 different way. I have a series of other questions I want to 11 follow up on that, too. You know, my impression of insurance 12 is to protect you against a big loss that you don't expect
' ~
13 rather than one that you do expect, and making assumptions 14 causes some surprises, as TMI-2, and I am not quite clear why 15 it wouldn't or couldn't cause similar surprises here.
16 MR. VOLLMER: I think you can't predict with 17 precision what would happen in the event of an accident, of I
18 course, but the judgments that have been made, which are 19 expanded upon in the NUREG, would be that there is a set of 20 criteria, which I think John will be getting to a little bit 21 later, which would allow you to decide how much it costs to 22 clean up a plant that suffers a severe accident, and using 23 these particular guidelines, then, you develop a cost figure.
24 It would appear that the $180 million or that 25 ballpark would be cufficient to cover a very major accident in i
. . ~ . . - - . . , - . . . ,. , ,~_---,-,__.,._..-...,r---. . . . . , , , - , - , _ _ . _ . . . _ _ . . _ . _ . - _ _ . - - _ . - --..-_-,c -.-- _ - , ,
-4 e..a . _ . _ _ m _ - --
23 1 this particular plant, and that is why we are requesting a )
(~% l
'\ 2 very case-specific exemption and the plant itself is evaluated )
3 by the utility and by the staff to have insurance that would 4 be adequate to cover a major accident.
5 CHAIRMAN PALLADINO: At TMI-2, the time, the cost 6 encompassed a lot of things that I don't know were' considered 7 here. I remember they had to develop a submerged 8 demineralizer system and another system for cleaning up the 9 Water. They had to devise or check their cranes. They had to 10 fuss around with getting some of the internals, and I gather
! 11 on the boiling water reactor, you have a lot more internals on 12 top of that. If they are stopped, you could be a long time 13 3(
js developing equipment. You have to first clean up that 1.4 containment, too, if any of it got out. Then you have to 15 develop special tools. You have to train people. There is an 16 adaption of TV exploration techniques.
l 17 I just am concerned that while one can do a lot of 18 calculation on a certain set of assumptions, TMI showed that 19 you get a lot of surprises that you have to learn to deal with
, 20 as you go along, and when you are talking about six or seven 21 years to do a cleanup, that can eat a lot of money up in a 22 short period of time. What I am concerned about is that if 3
23 there is a limited amount of insurance, the insurance company 24 says, well, I will pay you off, and then the rest of it is
! 25 still for Dairyland to cope with.
I
24 1 If you follow the TMI scenario, the utility comes in
,~,,
2 and says, well, we are going to go bankrupt, so the state and 3 everybody else rushes around and makes up the difference. I 4 know I'm putting a lot of stuff together, but I am giving you 5 my concerns and I why I wanted to ask for discussion of this.
6 MR. VOLLMER: I think the points the point you raise 7 are some of the lessons out of TMI. If we could go to the 1
8 second to the last slide, at least to give you a view of the 9 types of things that were considered in this evaluation, you 10 may disagree with the evaluation or disagree with whether or 11 not it considers enough things, but I think it does include 12 the very types of things you have mentioned.
13 (Slide.]
14 MR. STANG: Let me go through real quick the
! 15 ' accident recovery scenario that Lacrosse has. And, 3
16 Commissioner Asselstine, I want to come back to the question 17 you had, because I kant to add something to that a little bit 18 later.
19 Well, at Lacrosse you have your accident, your 50 4 20 percent fuel melt accident, and you plan emergency procedures 21 to rapidly flood the core. You have five paths to get the i
22 water into the containment. So we flood up to the core i
1 23 midplane, and after we've flooded up to the core midplane, you 24 are thermally stable. There is no more stabilization that you l
Yi 25 have to do to that reactor. That's it.
l
25 1 Now we can start -- we're into the recovery. And
. O.
l\ 2 for the accident scenario, what Lacrosse has done, they've 3 divided it into three phases.
1 4 The first phase, a duration of 16 months, is the 5 recovery and the planning phase, and you set up the 6 post-accident monitoring. You select --
7 CHAIRMAN PALLADINO: Where are you on this?
i 8 MR. STANG: Well, I'm not on --
9 COMMISSIONER ASSELSTINE: It's not on the Vu-graph.
j 10 CHAIRMAN PALLADINO: Oh, you're not on the slide.
j 11 MR. STANG: Sir, it is in the SECY paper, if you'd 12 like to follow along.
4 13 COMMISSIONER ASSELSTINE: It looks like page 6 of 14 the attachment.
15 MR. STANG: Starting on page 4, 3.1.
16 CHAIRMAN PALLADINO: Of Enclosure 17
- 17 MR. STANG
- s Right -- oh, I'm sorry. That's 3.2.
18 I'm sorry. Page 5. And I basically have it summarized.
19 Basically what you are doing, you are bringing all 20 your people onsite to start your clean-up. You're erecting 21 your temporary buildings. You're letting reactivity decay.
1 22 You're getting ready to actually start, and then you go into i
23 what the call Phase II.
24 Now Phase II is the actual clean-up of the
\- 25 containment building itself. It's postulated to last 48 l
j 26 1 months.
,em 2 What we have is, once you're flooded up to your core 3 midplane, you can no longer use your normal containment access 4 airlock. What you have to do is and what is done in the 5 study, once it's thermally stable, they will flood up all the i
6 way to the 701 elevation, and they will cut in a new airlock 7 into the containment.
8 COMMISSIONER ASSELSTINE: You assume vessel failure, 9 right?
10 MR. STANG: No, sir.
11 COMMISSIONER ASSELSTINE: No? The vessel is still 12 okay, even though you've got 50 percent melt inside? Okay.
13 MR. ZWOLINSKI: In the primary system.
14 CHAIRMAN PALLADINO: Which level are you going to 15 come in on?
16 MR. STANG: 701. It's marked right there with the 17 arrow. i 18 CHAIRMAN PALLADINO: I can't read the numbers.
19 MR. STANG: I apologize, sir.
20 CHAIRMAN PALLADINO: Could you point to it on there?
i 21 MR. STANG: At the top, right at the top of the 4
22 stairs.
23 CHAIRMAN PALLADINO: At the top of the stairs.
24 Thank you.
25 COMMISSIONER ASSELSTINE: So you have to cut a new 6
m,, -- --ewv. - , - - - - - , . _ . -
-,,c , ,. .- - - _ .
a 27 l 1 hole in?
s
', 2 MR. STANGs Yes, sir.
3 COMMISSIONER ASSELSTINE: Sounds more complicated
) 4 than TMI in some respects.
5 CHAIRMAN PALLADINO: It's what?
6 COMMISSIONER ASSELSTINE: It sounds more complicated 7 than TMI.
8 MR. STANG: Much more complicated, because what they 9 did in the scenario, they chose a below-core break. So in j 10 that case, you only had one way to go, and that was to flood j 11 up, and then you automatically lose your normal access.
1 12 This takes approximately 48 months, and once they
, 13 prepare everything for decontamination, and then --
t
(.
14 CHAIRMAN PALLADINO: Is this all of Phase II?
15 MR. STANG: Yes, sir.
16 CHAIRMAN PALLADINO: 48 months in addition to 167 17 MR. STANG:i Correct. In other words, Phase II i
18 starts at the end of 16 months.
i 19 And then in Phase III, which is a duration of 17 20 months, you're removing the damaged fuel and the core rubble.
21 You're shipping offsite.
_____22 COMMISSIONER ASSELSTINE: So seven years worth of 23 work.
24 MR. STANG: I think it's approximately 6.7.
i
\. 25
)
COMMISSIONER ASSELSTINE: And $180 million will do ;
_ . _ . _ . - _ _ - . _ - - - - - - - _ . - _ - _ _ . _ .- _ _ -----_- . -_.-__ .. _ _ _ . _ _ _ _ _ _ _ _ _ . - - , . _ . ~ - _ . _ _
28 1 it over seven years?
2 MR. STANG: Yes, sir.
3 COMMISSIONER ASSELSTINE: Do you have any idea how 4 the costs would change if you assumed contamination in the 5 auxiliary building as well? What would that do to the cost 6 estimates?
7 MR. ZWOLINSKI: If you are talking a large 8 contamination in the auxiliary building, the cost estimates 9 will increase.
10 CHAIRMAN PALLADINO: What?
11 MR. ZWOLINSKI: The cost estimates will increase if 12 somehow we contaminate the auxiliary building.
13 COMMISSIONER ASSELSTINE: Do you have any idea by i
14 how much?
15 MR. ZWOLINSKI: I'm sorry. I don't have that.
16 The guiding document, the methodology contained in 17 this NUREG-2601 evolved from a hard look at Trojan and at 18 WPPS-2, and the methodology that evolved was one that was i 19 applied to Lacrosse, and it turns out the results, for i
20 example, on WPPS-2 were almost a billion dollars, and 21 insurance was required.
22 Once again, some key assumptions are that my 23 containment will indeed contain this accident.
24 COMMISSIONER ASSELSTINE: Right.
I ..
25 MR. ZWOLINSKI: And isolation, for example, a
..c, - , . , _ - - . - , - - _ , , , - . , ., . , - - _ , . - ..n. , --m,.m----- ._, , _. - . - , , . , -m, ,
29 1 question you raised earlier, I will be able to isolate the 0 2
\ containment. I think that's fundamental to the methodology 3 which is contained in the NUREG, and that's one reason that
~~
- 4 the utility did not carry the arguments beyond -- we're 5 relying on systems that are tested very frequently, as far as 6 isolation capability.
7 COMMISSIONER ASSELSTINE: But that methodology 8 doesn't lead you to that assumption for the other two plants, 9 does it?
l 10 Do you assume that everything stays in the j 11 containment for WNP and Trojan?
12 MR. ZWOLINSKI: It's my understanding that this
, , 13 NUREG --
14 COMMISSIONER ASSELSTINE: No clean-up of the 15 auxiliary building or anything like that?
16 MR. ZWOLINSKI: That's correct.
~
17 COMMISSIONER ASSELSTINE: Oh, I didn't realize that.
18 CHAIRMAN PALLADINO: Is the NUREG going to 19 differentiate among sizes of plants, or is it still concluding 20 or making the premise that the clean-up costs will now vary
- 21 essentially with the size? i 22 MR. ZWOLINSKI
- The NUREG report does acknowledge 23 that with different size reactors, there is the potential for 24 varying degrees of insurance coverage. It does not explicitly
\
' " 25 state that for a small plant such as Lacrosse, it ought to be i
- - - - = - - - - - - - - - - - - - - - - - - --
30 1 some level of insurance. It does address that point.
O 5
2 I guess the key thought there is that WPPS being a I
i 3 boiler, the baseline cost was approximately a million 4 dollars. What we're doing with this proposed exemption for t
5 Lacrosse is saying, "What should be the baseline 6 plant-specifically?"
! 7 The numerical values that have been presented to the 8 staff and that we've evaluated reflect something on the order 9 of $125 million to perform this actual recovery task. There 10 are margins that are built into the numbers, and then there is 11 a 25 percent contingency factor in addition. That's where the 12 $180 million came from.
13 CHAIRMAN PALLADINO: Well, one of the problems I'm l 14 having is that at TMI-2 they seem to have spent $250 million 15 before they even got started, and it didn't have anything to
- 16, do with the size of the plant. It did have to do with the 17 fact that some of the auxiliary -- the auxiliary building had 18 contamination. But there were problems in getting started.
J
! 19 It just ate up money like you can't believe. And I don't know 1
20 what makes this different.
i
! 21 COMMISSIONER BERNTHAL: But, Joe, it clearly is r 22- -different.--It-sounds like you're arguing that tae cap should I
23 be three times a billion dollars rather than --
24 CHAIRMAN PALLADINO: No, no. All I'm trying to 25 understand is why they think this is so much lower than a
l
- 31 l
1 plant like TMI.
i
(~s.
t 2 COMMISSIONER BERNTHAL: Well, there must be a 3 . difference because there's ten times less inventory. So the l
4 flipside of the argument would be that the others ought to be i 5 3 or 4 billion. Maybe this one ought to be a billion, but in 6 that case, the others ought to be 3 or 4 or 5 billion.
7 CHAIRMAN PALLADINO: Well, if I knew exactly 8 everything that's going to happen, I could probably say, well, 9 I believe the calculation. Somehow I just don't have a great j 10 feeling, especially when I look at the saving in cost versus 11 the risk that's being assumed and the feeling that in the end 12 the risk, compared to what you're saving, just doesn't make 13 sense to me.
{~
14 MR. STANG: One point I'd like to make, and getting i
15 back to Commissioner Asselstine's comments, the current i
16 insurance requirements are tied directly to the amount that l
17 you can buy, has nothing to do with any analysis, and the new i
18 rule is the same way. In other words, hey, we can buy 1.06 19 billion dollars, and our rule is going to say, "You shall buy 20 1.06 billion dollars."
21 The current rule says, in the past you've been able 22 to buy so much. NUREG-2601, which Pacific Northwest Lab put l 23 together for the NRC, basically said, " Hey, for a TMI type 24 accident and even a more severe than TMI, a 50 percent fuel i '
25 melt type accident for a reactor like WNP-2 or Trojan, those
32 1 size PWR and BWR reactors, that the cost is about $980 in 2 million."
3 COMMISSIONER ASSELSTINE: Refresh my memory. What's 4 the estimate now for the clean-up at TMI-2?
5 MR. STANG: That I --
6 COMMISSIONER ASSELSTINE: It's well over that, isn't 7 it?
8 MR. STANG: That I don't have the information on.
9 CHAIRMAN PALLADINO: It seems to me it was about a 10 billion dollars or something like that.
- 11 COMMISSIONER ASSELSTINE
- Yes, I thought it was a
- 12 little bit over a billion.
13 CHAIRMAN PALLADINO: Or a little less than a 14 billion. I think it was a little less than a billion.
15 Excuse me. Go ahead.
16 MR. STANG: That's just one thing I wanted to clear 17 up to make sure. i 18 what Lacrosse did, Lacrosse used the similar 19 technology in 2601, and the Staff reviewed it and used 2601 as 20 a benchmark. And what we did, we went to Pacific Northwest i
21 Labs and had them help us review the Licensee's exemption 22 request.
23 (Chairman Palladino leaves the hearing room.)
24 MR. STANG: And with PNL we felt very strongly that 1,
\
i 25 we had performed a very thorough analysis of this. PNL went
33 1 to the plant with myself. We investigated the containment.
2 That question came up: Did we feel that the containment will 3 withstand this type of accident? And yes, in fact, they came 4 back and said, "Yes, this type of accident, 50 percent fuel
, 5 melt, we will -- that the containment will withstand it."
6 COMMISSIONER ASSELSTINE: Okay.
4 7 MR. STANG: Basically I think we have already gone 8 through it. The Staff, with the help of Pacific Northwest 9 Labs, analyzed Dairyland Power's exemption request and all of 10 the information provided. We evaluated the accident scenarios
[ 11 and found them to be similar to NUREG-2601, which again we i
4 1
12 used as a benchmark.
13 We evaluated the post-accident operations, and we
(
a 14 assessed the estimates for the clean-up costs and found them 15 to be very conservative and in accordance with what NUREG-2601 16 had found would be required to clean up a larger reactor.
17 In additio'n to this, the Licensee put a 25 percent 18 contingency on the figure that they came out with.
, 19 And finally, the Staff finds that the accidents 20 evaluated by the Licensee are sufficient to establish an 21 adequate level of primary property damage insurance coverage 3 22 as' required-by-10-CFR-50.-54(w), and-that-the-Licensee has 23 provided an adequate technical justification for the exemption i
! 24 request.
- ' 25 (Chairman Palladino reenters the hearing room.]
1
+
34 i
1 COMMISSIONER ASSELSTINE: Let me ask you something I {~h 2 on Item No. 2 on that last slide.
l 3 Are you really sure about that statement that the 4 contingency was intended to include inflation as well?
5 MR. STANG: Yes.
6 COMMISSIONER ASSELSTINE: You're sure?
7 MR. STANG: Yes. We looked at some figures, as a .
8 matter of fact, just recently looked at some figures. We 4
1 9 backed out for a 3 percent inflation rate in addition to I
10 escalation for utility labor cost and low-level rad waste I
- 11 burial, because that has gone -- won't even come close to 12 following inflation. And a 25 percent contingency is adequate 13 for at least ten years.
j{
k 14 COMMISSIONER ASSELSTINE: But they intend.-- the 15 idea really was that that was to include not only a 25 percent
{
16 contingency, but also that the contingency would also include l
4
! 17 an adjustment for ihflation, because quite frankly, when I J .
j 18 look at some of the documents, they don't seem to be adding in l 19 inflation. The 25 percent contingency seemed more based upon, i
20 "Well, if we're wrong, we want to provide a margin for error, t
! 21 and that's why we're putting in the 25 percent, exclusive of 22 any effects of inflation."
l 23 MR. ZWOLINSKI: We pursued this with Dairyland i
24 Power, and the Staff is of the impression that it does account I' 25 to some extent for inflation, Commissioner. The bottom line l
4
. - . , -,,_,-,.,,._-..,,....,r,- ,__~,--,.%e,--- - - , - , . , . , , - - - . . _ - - . _ . _ - . _ . , __,,.. ,___ --. - -. . - , - ~ ., - . . - . - . _ . , , , , , . - , .
35 1 in our attempt to rebaseline this particular facility and in
. (~N
'N 2 granting an exemption is that we're not going to walk away 3 from these folks once the exemption would be granted.
4 Time marches on. We may indeed promulgate another 5 update to 50.54(w) which talks about escalation as far as 6 inflation, other margins that we may want to impose,
, 7 priorities as far as use of resources. These folks would all 8 fall underneath that umbrella. In other words, if there was 9 an escalation due to inflation of 10 percent in a given year, 10 and the rule has been put in place -- this is the generic rule 11 -- Dairyland Power would be affected by that 10 percent 12 increase. So their 180 would be moved up to 198.
- { 13 This was, I think the original intent of the new 14 rule. It also puts a burden on the Office Director of NRR to 15 ensure that the resources are allocated in the direction to 16 ensure the public health and safety is insured first.
17 There is aipriority to the dispersement of 18 resources. Nothing that we are proposing today would 19 circumvent what 1s being proposed in 50.54(W). What we are 20 doing is we are requesting that these folks be allowed to i 21 re-baseline to the $180 million figure, which does contain 22 some margin, some contingency factors. We could debate how 23 much it is. It turns out we have settled on the $180 million.
24 COMMISSIONER ZECH: Are you telling us that there is
'- 25 some provision to insure that the funds that you are talking
36 1 about here will in fact be available and will not be siphoned
,O l 2 off for other purposes? In other words, are these funds
- 3 immune from creditors, bankruptcy? Will they withstand the 4 challenge of other events? Are these earmarked for property 1
5 damage and clean-up?
6 CHAIRMAN PALLADINO: Which funds is this?
7 COMMISSIONER ZECH: The funds we are talking about 8 for insurance.
9 MR. ZWOLINSKI: The funds for the insurance art 10 earmarked for the $180 million; yes, sir, Commissioner Zech.
11 They can't use those funds on the books for other events.
12 CHAIRMAN PALLADINO: They don't show unless they 13 have an accident.
{
14 COMMISSIONER ZECH: Could they use those insurance 15 funds for other events or do they have to use them for the I
16 funds that you are talking to us about here?
17 MR. ZWOLINSKI: They have to use it for accident
, 18 clean-up, and that would be at the discretion of the Director 19 of Office of Nuclear Regulation as far as --
20 COMMISSIONER ZECH: What provision do we have that 21 ensures they will be available? That they will not be used 22 for other things? T - - - - -
23 MR. ZWOLINSKI: I am getting too far into 50.54(W),
24 Commissioner Zech.
\ 25 COMMISSIONER ZECH: Well, I asked this question i
37 1 about two years ago, as I recall, and I'm not sure I got a p 2 real answer yet. I just wanted to make sure I did.
3 CHAIRMAN PALLADINO: I would like to follow you.
4 Are you talking about the funds you would get in the event of 5 an accident?
6 COMMISSIONER ZECH: Yes.
7 CHAIRMAN PALLADINO: If you get the $180 million, 8 let's assume --
9 COMMISSIONER ZECH: The insurance funds.
10 COMMISSIONER BERNTHAL: I think that was for 11 de-commissioning, if I remember right.
12 COMMISSIONER ZECH: I'm not talking about 13 de-commissioning. I'm not talking about Price Anderson. I'm 14 talking about the insurance funds for property damage.
15 MR. ZWOLINSKI: In 50.54(W), as it is being 16 proposed, there are four principal thrusts which the agency is 17 recommending or thd staff is recommending to bring before the 18 Commission.
19 One of those is in the area of priority of 20 disbursement of the funds.
21 COMMISSIONER ZECH: That is what I thought you 22 said. This is why I asked you to make sure.
23 MR. ZWOLINSKI: In that particular area, I don't 24 know all the details. I am aware that as it is currently i
25 written and will be brought before -- I think it is at CRGR
. l 38 j 1 right now -- the mandate falls on the Office Director of NRR.
s 2 COMMISSIONER ZECH: I recognize I am asking you kind
, 3 of a generic question, not necessarily applicable to Lacrosse,
- 4 but it is an important question, I think. We just want to 5 make sure that the funds that we think we have available for i 6 these purposes are indeed available.
7 MS. GILBERT: Linda Gilbert, ELD. Perhaps I can 3
8 clarify a little bit. The exemption as the staff has i
! 9 currently worded it says subject to further order of the
. 10 Commission. The reason for that qualification was to take i 11 into account anything that might come up later in the generic 12 rulemaking that we would want to modify for the exemption.
~
13 One of those things would be this de-contamination priority.
14 COMMISSIONER ASSELSTINE: Right now, with the 15 insurance policies, is it fair to say that basically they get 16 a check from the insurance company and there is nothing that 17 mandates that they spend the money in a particular way?
18 MS. GILBERT: That's correct, although as a 19 practical matter, I don't think the insurer would release the 20 funds if the expenses hadn't already been incurred for which 21 payment was due. It is true that we don't --
22 COMMISSIONER ASSELSTINE: In fact, as I recall in j - 23 GPU it came out in installments any way.
i 24 MS. GILBERT: Right. We don't have anything 1
{\.
4 25 currently in effect that would put a limitation on that.
39
, 1 COMMISSIONER ASSELSTINE: It is not like your car O
+ -
2 where you get a check and if you don't want to fix your car, 3 you don't have to fix it.
4 [ Laughter.]
- 5 COMMISSIONER ROBERTS: I can tell you a story about 6
that.
7 [ Laughter.]
- 8 COMMISSIONER ROBERTS
- With my 16 year old daughter.
9 COMMISSIONER ASSELSTINE: If you are wrong about the
- 10 $180 million, say you are wrong by $100 million, and it is
! 11 actually $280 million, this is a small plant but it is also a 12 small company. Where could they get the money? In the case 13 of GPU, GPU ended up coming up with a fair amount of money.
l{,
14 Ultimately their ratepayers came up with it. A good portion 15 of the added clean-up costs that go beyond the property j 16 insurance that was available at the time came from the utility 17 and it was a largeriutility with substantial other generating 18 capacity.
- 19 What would happen in this case if they had an
! 20 accident that cost $280 million, the plant was wiped out, l 21 where would they get the money?
22
~
MR. ZWOLINSKI:
I understand, Commissioner. I could 23 at best speculate. I'd have to go back to the utility and i 24 request them to address that type of an issue. Again, you 25 talk about ratepayers. You are also talking about a company
a ,; .
40 j 1 that does have other generation capability.
/~m 2 COMMISSIONER ASSELSTINE: Hod did it comptre with, <
3 say -- what is the percentage that is other than Lacrosse? Do 4 you remember? .
-5 MR. ZWOLINSKI: Lacrosse is 7 pe'rcent. f,was going 6 to say five, but a small percentage of she company.-
s 7 COMMISSIONER ASSELSTINE: All right. I gathes they i
8 are hooked up with member cooperatives as well. Do:you know 9 if they can assess --
10 MR. ZWOLINSKI: I'm sorry, Commissioner.
11 CHAIRMAN PALLADINO: In kh case of TMI, there were _
12 also Federal funds -- ~
~
Has the utility told \you they
~
I~ 13 COMMISSIONER ZECH:
14 would indeed use these insurdnce funds for on-site clean-up?
15 MR. ZWOLINSKI: They have said that --
16 COMMISSIONER ZECH: As they are supposed to or they 17 legally understand;that is why they would get the funds. I 1
18 appreciate that. Has the utility said[they would indeed put 19 them for clean-up purposes?
20 MR. ZWOLINSKI: It is on the docket and in'their 21 application for exemption that the funds ~that they would need 22 to have, should they have this type of an accide,nt, would be 23 usedintheclean-upofthisparticulakaccident.
24 I would have to rely on their application for ,
25 exemption. ,
., - _ . . . . . -- - . . . , . . - _ . .- }, . . . , , ,
41 1 COMMISSIONER ZECH: I would be interested to know 2 that somewhere or other they made that commitment.
3 COMMISSIONER BERNTHAL: Yes. I would say -- my 4 staff has just reminded me that your memory is better than 5 mine, Lando. You raised that issue in fact back in the Fall 6 of 1984 in this very area. I'm not sure we ever got an answer 7 to that question.
8 Has anybody ever looked at the policy and what it 9 says? Do they get a policy like I do for my car? Do we know 10 what it says? Commissioner Zech did raise that issue. I 11 realize now I am looking at that old SECY paper, and it was in 1 12 the SRM. I'm not sure it was ever resolved.
13
{' COMMISSIONER ZECH: I'm not sure either, which is 14 why I brought it up today. I recognize it is a matter of 15 trust and confidence and so forth. I think it is important 1G enough that we should be assured that the funds that we think 17 are available for clean-up will indeed be available for 18 clean-up.
19 MR. ZWOLINSKI: I understand. I am of the belief 20 that the new 50.54(W) acknowledges this particular point, as 21 far as resource distribution. The current rule does not. As 22 far as these folks and granting the exemption, to that 23 specific point, and I'm the one who writes and signs the 24 documents that leave the Agency and represent the Agency, 25 working with Lacrosse, I'm sure I can get the legal staff to
42 1 support me in writing a letter which would gain concurrence 2 from the utility or a letter from the utility committing to 3 use the resources, much'along the vein you are speaking.
4 COMMISSIONER ZECH: I appreciate that. Also -- it 5 is more generic than just Lacrosse. I think it should be 6 applicable to all the utilities. I would appreciate if you 7 would look into that also.
8 MR. VOLLMER: We will do that; yes, sir.
9 COMMISSIONER ASSELSTINE: It sounds like you are 10 planning a generic rule.
11 MR. VOLLMER: Yes.
12 CHAIRMAN PALLADINO: Let me ask another question.
13 As I' understand it, the reason for proposing this is to save 14 on the premium costs.
15 MR. ZWOLINSKI: That's correct.
16 CHAIRMAN PALLADINO: If I remember correctly, it is 17 roughly $600,000 now and by making this reduction, it would go 18 down to $400,000, a difference of $200,000. In the process 19 though, you are increasing the potential burden by $320 20 million, if I did my arithmetic right.
21 Could you give me your feeling about weighing of the 22 cost / benefit in this situation?
23 MR. ZWOLINSKI: Let me give it a shot. I haven't 24 studied this particular question. I guess what I think we 25 have here is a business that is saying to itself, how much
. 43 1 insurance must I carry should I have one of these severe 2 accidents, such that the company does not go bankrupt or 3 suffer undue hardships throughout the community and so on and 4 so forth.
5 The company is saying to us, we think the right 6 amount of insurance is approximately $180 million. They are 7 further stating you, the regulator, are requiring us to 8 maintain $500 million. It is not sound business practice for 9 us to maintain or carry insurance in excess or in addition to 10 the $180 million, which we feel covers our particular 11 facility.
12 In other words, we are requiring them to be over 13 insured by about $300 million.
14 CHAIRMAN PALLADINO: In their opinion.
15 MR. ZWOLINSKI: That was presented to us in their 16 request for exemption. The staff has reviewed their work and 17 the staff concurs with their analysis. I think the staff is 18 supporting the licensee's analysis. Therefore, I would say 19 much of us tend to agree with what Lacrosse has presented.
20 CHAIRMAN PALLADINO: What I am having a problem 21 with, I go back to TMI-2. I forgot what their insurance was, 22 $300 million or $324 million or $224 million. They had made 23 the implicit decision that was as much as they had to carry.
24 The accident almost brought them to bankruptcy.
25 MR. ZWOLINSKI: I understand.
44 1 CHAIRMAN PALLADINO: Again, then it took a lot of 2 extra financial help to keep them going. Here, I don't have 3 the same degree of confidence. TMI put a good bit of its own 4 money in there. I'm not sure that the situation here might 5 not be the same.
6 MR. ZWOLINSKI: Chairman, I guess a foundation to 7 the entire activity has been this new reg 2601, which the 8 staff has endorsed as containing the methodology which has led 9 us to the proposed rulemaking of the $1.06 billion. If one 10 accepts that methodology as being credible, then that 11 methodology when utilized for Lacrosse, the figure turns out 12 to be $180 million.
13 CHAIRMAN PALLADINO: I asked you earlier if you were
{~
14 going to do this on a case by case basis and set the rate on a 15 case by case basis, doing the methodology, and I got a mixed 16 answer.
17 MR. ZWOLINSKI: I am of the belief that you will see 18 on a case basis, some of the smaller reactors requesting some 19 relief. The two that come to mind are Big Rock Point. It is
{
i 20 a 78 megawatt boiler. The next smallest one I believe is 21 Yankee, which is about 175. I think once you start going 22 beyond that, I'm not --
23 COMMISSIONER ASSELSTINE: Then you get to 300 pretty 24 fast.
'-- 25 MR. ZWOLINSKI: Exactly right. I'm not sure we are
~
45 1 going to see too many others come in and challenge or ask us s
2 to re-think or re-baseline.
3 CHAIRMAN PALLADINO: No, but I thought you said the 4 methodology was set forth with the implication that you are 5 going to do it case by case. It not, then you do the 6 methodology and you set your rate or you set it by classes. I 7 gather by putting half a million for some of these plants, you 8 have started to do that by classes.
9 If we start to subdivide even more, I just get 10 uneasy.
11 MR. ZWOLINSKI: The class distinction is the fact 12 that you have a few reactors that are really fairly small.
13 The preponderance are going to'be covered by the new rule and
{'
14 I wouldn't expect to see the staff being asked to grant an 15 exemption or a request for some relief -- folks will simply 16 purchase that amount of insurance.
17 CHAIRMAN PALLADINO: Are you saying that the 18 methodology would show a significant difference between this 19 plant and the other one, Yankee?
20 MR. ZWOLINSKI: I think the correct interpretation
~
21 is the methodology, should it be used on a case by case basis ,
i 22 for plants with small reactors -- I'm thinking of thermal 23 loading principally, it takes me up to Yankee, which is 24 something on the order of 500 megawatts thermal. I think the 25 rest of them -- you have a big jump to larger thermal loading 1
4 46 1 that the plants would not on a case basis be able to make the 1
m 2 argument to have reduced amounts of insurance.
3 Lacrosse is 50 megawatts electric, and Big Rock 4 again is 78. And then we have a jump going all the way up to 5 Yankee. It's almost a 100 megawatt jump.
6 COMMISSIONER ASSELSTINE: Right.
i 7 MR. ZWOLINSKI: It's not even clear that Yankee 8 would fall into this category of being able to request relief 9 in this area.
10 COMMISSIONER BERNTHAL: What's our biggest 1
11 non-electrically generating research reactor megawattage, or 12 thermal megawattage?
13 MR. ZWOLINSKI: There's a test facility at the 14 University of Missouri which is about 20 megawatts electric.
15 COMMISSIONER BERNTHAL: Are we requiring them to 16 carry $50 million --
17 MR. ZWOLINSKI: Oh, excuse me. I'm sorry. I meant 18 thermal.
19 CHAIRMAN PALLADINO: It's thermal as compared to 20 here. It might be 150 --
21 COMMISSIONER BERNTHAL: Are we requiring them to 22 carry 30, 40, 50 million dollars in clean-up insurance?
23 MR. ZWOLINSKI: Those facilities, to the best of my 24 knowledge, are not required --
~
25 COMMISSIONER BERNTHAL: Or 10 or 5?
47 1 MR. ZWOLINSKI: They are not required to carry 7.s 2 primary insurance coverage. They do have liability, as I 3 understand.
4 COMMISSIONER BERNTHAL: You know, the thing that 5 bothers me about this, I guess, is that by any measure, this 6 is probably one of the safest plants we've got. There are 7 inequities in the way these insurance costs are distributed.
8 We know some of the plants are newer, they are better 9 designed, and some are older. Not all the plants are as well 10 run. And yet we are, by and large, going to set a single 11 number for the vast majority of the larger plants. l 12 Whether the floor here should be $180 million or $1 13 billion or whether, as the Chairman seems to imply, all of 14 them ought to be a lot higher -- I don't know -- but why not 15 just have a straightforward formula? Why not a buck a watt 16 for required insurance coverage or something like that?
17 It's inequitable anyway. Otherwise you're going to 18 have somebody who is a 400 megawatt plant coming in and 19 saying, "Well, we think we ought to be $700 million instead of 20 a billion."
21 MR. ZWOLINSKI: To that point, the Staff accepts 22 this NUREG-2601, the methodology contained, and one would have 23 to go through that methodology and justify the number that 24 they come up with, and I'm not sure --
N 25 COMMISSIONER BERNTHAL: But surely we aren't going
48 1 to spend the time and resources, nor are the utilities, to do
'(',
2 that kind of analysis for every plant.
3 MR. ZWOLINSKI: I think it would be very easy to go 4 the other way. I can take the 1.06 or the 585 and just work 5 it backwards and establish what is the cutoff point, and that 6 might be the 175.
7 COMMISSIONER BERNTHAL: What are you talking about?
8 MR. ZWOLINSKI: I'm sorry?
9 COMMISSIONER BERNTHAL: Working backwards to 10 establish?
11 MR. ZWOLINSKI: Okay. If I was doing the analysis 12 and asked to say what is the cutoff point as far as reactors 13 that would come in and request relief-by an exemption, how 14 many are going to be coming in, what have you, I would ask 15 some questions of the Staff. I would do an analysis which 16 would say, "What does the $585 million really cover following 17 the methodology of 2601?"
18 COMMISSIONER BERNTHAL: Have you done that analysis 19 for a 1000 megawatt plant? What do you really think it would 20 cost to clean up a core melt, 1000 megawatt accident?
21 MR. ZWOLINSKI: Okay. WNP-2 is one of the --
22 COMMISSIONER BERNTHAL: And a billion dollars does 23 it.
24 MR. ZWOLINSKI: That's correct.
25 COMMISSIONER ASSELSTINE: ,And it all stays in the i
49 1 containment?
m.
2 MR. ZWOLINSKI: That's a key assumption which is in 3 --
4 COMMISSIONER ASSELSTINE: Which drives the costs.
5 MR. ZWOLINSKI: I'm sure it does.
6 CHAIRMAN PALLADINO: But that flies in the face of 7 the statement that's saying that there is not much correlation 8 between the clean-up costs and the size of the plant. You 9 know, you're talking about different size plants.
10 MR. ZWOLINSKI: I don't want to mislead everyone.
11 It's not a one-to-one correlation. There is a dramatic 12 difference in the amount of core material, massive uranium
('"
(
13 oxide.
14 I guess I'm looking at a factor of 20 less. If I' 15 look at noble gases, I'm looking at a factor of 10 less than a 16 larger facility. I can go down the line, and I find that a 17 smaller reactor is simply going to be easier to clean up than l
18 a larger reactor. It's not one to one. i l
19 COMMISSIONER BERNTHAL: But let me just comment.
I 20 What he is saying supports the point that it's not
- 21 proportional. I mean, Washington Power is 20 times the power 22 of this one, and it's only a five times difference in their 23 estimated clean-up cost, or six times.
i 24 MR. VOLLMER: Right. l l
l l'- 25 COMMISSIONER BERNTHAL: So that's exactly --
50 1 MR. ZWOLINSKI: We're going from a billion down to 2 --
3 COMMISSIONER BERNTHAL: Exactly. 980 million down to 4 180 million with a 20 times difference in power.
l 5 CHAIRMAN PALLADINO: Well, Cookie Ong had a comment.
6 MR. ONG: Since there is so much emphasis given to 7 the methodology of NUREG-2601, I want to point out, though, 8 that actually in that report they do allow for some 9 contamination getting outside of the containment structure.
10 That's not entirely true that it's all bottled up. They say 11 the severe contamination, of course, is contained, but there 12 is -- they do postulate, you know, some moderate, what they
{
13 call moderate contamination getting out to the support 14 buildings, other structures and other equipment.
15 So, you know, it's sort of -- you've got to be 16 careful in saying something is exactly, you know, the 17 methodology of PNL,ibecause that's not entirely true, because 18 let's face it, you know, three years when we faced this in the 19 proposed rulemaking, you filed the NUREG-2601, and you come 20 out with about $400 million, you know, but the Commission saw 21 fit to raise that number in the proposed rule to $900 million, 22 because PNL was careful to point out that there are a lot of 23 costs that were not covered in their study, like 24 stabilization, although in reviewing the Lacrosse submittal,
'\ ~ 25 you know, it seems like a reasonable handling of l
l
51 1 stabilization; therefore, they don't have any stabilization 2 costs in there.
3 And the baseline cost, you know, were something, if 4 I remember right, around $120 million at TMI, and PNL pointed 5 out, when they came up with $400 million, they didn't include 6 that. But we could see that this is a small plant, and I 7 guess they put everybody to work, you know, cleaning up, so 8 there will be no further kind of cost.
9 But one thing to remember, the $1 billion -- and PNL 10 reported $1.034 billion to clean up TMI -- $209 million was 11 for inflation alone. So that's nothing to sneeze at. And, 12 you know, if you're going to talk about 2601 methodology, you 13 ought to include, you know -- at least consider the cost that
{
14 PNL said that somebody ought to consider, but, you know, we 15 had no magic crystal ball. We just wound up with a bottom 16 line, " Gee, I guess it would cost anywhere between a half a 17 billion and a billion dollars for a plant as big as Trojan or 18 WPPS-2."
19 Thank you.
20 COMMISSIONER BERNTHAL: You didn't take any 21 consideration of core melt probability in comparing this 1000 22 megawatt plant and this plant?
23 MR. ZWOLINSKI: No.
'24 COMMISSIONER BERNTHAL: You assumed 50 percent?
25 That's just inequitable, too, you see. What's wrong with the
52 1 idea of just saying a buck a watt or two dollars a watt or
,.~.
2 whatever?
3 CHAIRMAN PALLADINO: That's a different subject.
4 MR. ZWOLINSKI: Our counsel to the utility when the 5 subject first came up was that we had this dccument, 2601, we 6 think you should follow that methodology, should you want to 7 propose an exemption, and that's what was done.
8 COMMISSIONER ASSELSTINE: Fred, I think your point 9 is a good one for the utility to make to their insurance 10 company, go to their insurance company and say, "Look, it's 11 just like a house with smoke detectors, and I've got a better 12 chance of avoiding your having to pay for the cost of my 13 plant, to pay off on the insurance premium; therefore, I ought 14 to get a break on my premiums.
15 MR. VOLLMER: Well, I think if you look, they're 16 paying less per dollar of insurance value now than the larger 17 plants are already.i 18 CHAIRMAN PALLADINO: Yes. I don't know why, but 19 they seem to have a good break.
20 COMMISSIONER ZECH: Well, I think that's the reason 21 they probably do.
22 CHAIRMAN PALLADINO: Maybe all this will bring about 23 a result that I hope doesn't come about where they get 24 increased rates.
25 But let's see if you have any more to present or any l
l t
53 1 other questions.
C'.
2 MR. ZWOLINSKI: The Staff developed the SECY paper 3 with the intent that if the commission was silent, we would go 4 ahead and issue the exemption. And as Dick pointed out, we 5 are discussing it today. It is the Staff's recommendation 6 that we would like to move forward and issue this exemption.
7 CHAIRMAN PALLADINO: Well, I thought we had changed 8 this to a notation paper. I'm going to urge the commissioners 9 to try to vote within the next two days, today or tomorrow, or 10 by Friday anyhow, 11 MR. VOLLMER: I would also mention or reiterate, we 12 didn't look -- your basic question of the risk of exceeding 13 this thing, that wasn't part of the Staff consideration. We 14 went on the best judgment that we had, basically on the NUREG, 15 and so that is not a factor either pro, being a small plant 16 having less risk, or the uncertainties that one might 17 encounter if you do;have a large accident.
18 Now the second thing I wanted to mention is that the 19 Staff will definitely assure generically and Lacrosse-specific 20 that your concerns that they will use the funds for this ;
i
- 21 . purpose, we will make sure that that is somehow worked into 22 either the exemption or the Licensee commitment.
23 COMMISSIONER ZECH: Thank,you.
24 CHAIRMAN PALLADINO: Where do we stand on the new v 25 260l? Has that come to the Commission?
l
( ._. - _ . . _ _ . - - - - - - - - - - - - , - - - - - - - - - - - - - - - - -
54 1 COMMISSIONER ASSELSTINE: It has gone to CRGR.
O '
\ 2 MR. VOLLMER: Oh, the rule? The rule, yes.
! 3 CHAIRMAN PALLADINO: The revised NUREG that you have 4 been talking about.
5 MR. VOLLMER: We're talking about the revised rule 6 for increasing the --
7 CHAIRMAN PALLADINO: You're not revising the NUREG?
8 MR. VOLLMER: No. The NUREG is final. But the rule 9 itself is going to --
10 CHAIRMAN PALLADINO: What about the NUREG?
11 MR. STANG: It is final.
12 MR. VOLLMER: It is final.
13 CHAIRMAN PALLADINO: I thought you were revising it.
14 MR. STANG: No.
15 MR. VCLLMER: No.
16 COMMISSIONER ASSELSTINE: The double recoverage 17 basically. ;
! 18 MR. ZWOLINSKI: And the rule is with CRGR.
I 19 If I md.ght just take a second, we opened the 20 conversation, the discussion today, trying to give you a l
21 picture of Lacrosse and why it has some unique features. It's i
- 22 a little bit different than the typical boiler. And we really 23 felt that the arguments one should make regarding insurance j 24 first fell on us as technical practitioners as to how safe can x- 25 this plant be, how well is it designed, what does it really
55 1 look like, and that's one of the principal reasons that we R
(_' 2 feel strongly that there is some merit in their case, and we 3 think a strong case has been made that when you can get to i
4 essentially a passive system with the addition of only 90,000 1
5 gallons of water, that's a very comforting feeling very 6 quickly, and I have 42,000 gallons already in containment.
7 We tried to show that there were a number of sources 8 of inventory. Should all else fail, we have EW engines that 9 we can hook up to the -- take down to the Mississippi River 10 and pump into the containment.
11 It's one of how rapid can I move to ensure I'm at a 12 stabilization point, and that tends to be the 90,000 gallons 13
{ of inventory in the containment.
14 So the technical arguments that we were trying to 15 lay before you are really what drive the Staff as far as the 16 conclusion that this number seems to be representative and 17 realistic for this facility.
18 COMMISSIONER BERNTHAL: Let me ask a question.
19 CHAIRMAN PALLADINO: I missed the last phrases.
20 MR. ZWOLINSKI: That the $180 million seems to be i
21 representative for a facility of this size.
- ~
22 COMMISSIONER BERNTHAL: Let me ask a question that 23 is -- maybe you don't have to answer at this point.
1 24 You said this was before CRGR?
,' \- 25 MR. VOLLMER: The rule, the new rule.
56 1 MR. ZWOLINSKI: The new rule, 50.54(w).
(1 2 COMMISSIONER BERNTHAL: The rule is before CRGR.
3 MR. ZWOLINSKI: Yes. I i
4 COMMISSIONER BERNTHAL: Howdoyouprove{
5 cost / benefit on this, because after all, somebodyl pays for the i
6 clean-up if there is an accident, dollar for dollt{r. A
)
, 7 clean-up gets made; it gets paid for.
{
k 8 If you require a utility to buy insurance:jand the
,4 9 costbecomesthedollarfordollaroftheclean-uphpresumably, 10 plus the cut that the private sector takes, it see'.js to me no 11 matter what you do, thecosttothepublicforthe{ !: lean-up is i
12 higher with a mandated rule and a mandated insurani 4 pool than
{; 13 it is if you don't have any insurance at all.
14 How do you prove cost / benefit to the publi a?
15 MR. ZWOLINSKI: What I'd like to do, Commi Isioner, 16 if I could, is have you ask that question to the fc[kks that Y
17 are sponsoring thatirule.
16 COMMISSIONER ASSELSTINE: I would think the one 19 benefit, Fred, would be to reduce uncertainty. You don't have 20 to go through this agonizing process we went through with TMI 21 about where is the money going to come from and putting 22 together that kind of a fragile --
23 COMMISSIONER BERNTHAL: Well, I'm being the devil's 24 advocate. How many dollars of uncertainty --
\~ 25 MR. ZWOLINSKI: Commissioner --
l l
l _ - - - _
57 1 COMMISSIONER ASSELSTINE: For anybody that had to go
, 2 through that process, it's worth a lot.
3 MR. ZWOLINSKI: Commissioner, Bob Woods from our 4 State Programs Office, the folks that are most knowledgeable 5 about the development of this NUREG is available, should you 6 like to pose that question to him.
7 COMMISSIONER BERNTHAL: I think it is best deferred 8 until we discuss the rule. I just thought I'd give you a 9 little food for thought.
10 MR. ZWOLINSKI: Food for my thought?
11 [ Laughter.]
12 COMMISSIONER ASSELSTINE: If they'd save $200,000 a 13 year by cutting it down to $180 million, what would the 14 savings be if we split the difference and said $350 million 15 instead of 180?
16 CHAIRMAN PALLADINO: What are we going to split?
17 That 250? i 18 COMMISSIONER ASSELSTINE: 350.
19 CHAIRMAN PALLADINO: 350.
20 MR. ZWOLINSKI: It's not straight line, and I'd have 21 to ask the utility.
22 COMMISSIONER ASSELSTINE: Okay. Does it get 23 cheaper as you go up in increments or more expensive?
24 Cheaper?
\
'-- 25 MR. ZWOLINSKI: I think so; yes, it's cheaper.
l .
58 1 CHAIRMAN PALLADINO: You're going down to
,' ' T.
s 2 two-thirds, does it save them one-third of the premium?
3 MR. ZWOLINSKI: If we do attempt to seek some middle 4 ground or some alternate number, I would be sensitive that we 5 may be challenging the quality and the integrity of the 6 methodology that has been established. >
7 COMMISSIONER ASSELSTINE: Yes, although -- you're 8 right about the methodology, but at the same time I get the 9 impression that the 1.06 or whatever it is billion is based a 10 whole lot more on that's the most that can be obtained, rather 11 than -- the methodology provides some degree of comfort that 4
12 that's in the ballpark of what you'd really need, but I 13 thought the driving force really was, "We want you to buy 14 whatever you can buy," and that's what you can buy.
15 MR. ZWOLINSKI: I agree with you on that.
16 COMMISSIONER ASSELSTINE: Am I right on that?
l 17 CHAIRMAN PALLADINO: There are many factors that go 18 into evaluating accidents, and I am not impugning your 19 methodology if I choose to do something different from what 20 you recommend. I have to take into account other factors that 21 I am not confident have been looked at or considered in 22 assessing-this-situation-in -this- plant.-
23 So I am not saying how I am going to vote, but I am 24 just saying I don't want you to feel that I am impugning your 25 methodology when I do that.
i
59 1 MR VOLLMER: Thank you. We appreciate that.
O Y v 2 CHAIRMAN PALLADINO: Any other questions that 3 Commissioners have?
4 (All Commissioners answered "no."]
5 CHAIRMAN PALLADINO: Anything more? Well, let me 6 urge that we do get our votes in by Friday of this week. As a 7 matter of fact, if it could be by Friday morning, then you 8 might have an answer by Friday afternoon.
9 Now, before we adjourn, we do have an affirmation 10 item. I would like to take a few minutes to make sure I 11 understand the item, and suppose we put affirmation in ten 12 minutes.
13 We stand adjourned.
14 [Whereupon, at 3:30 p.m. the meeting was concluded.]
15 16 17 i 18 19 20 21 22 23 24
'- 25 l
1 2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5 meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7 TITLE OF MEETING: Briefing on La Crosse Request for an Exemption to Reduce Primary Property Value Insurance 8 PLACE OF MEETING: Washington, D.C.
9 DATE OF MEETING: Wednesday, June 18, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
17 i 18 - -- $0A---
i zanne Y g 19 i
20 21 22 Ann Riley & Associates, Ltd.
[
23 l
1 24 l 25
LA CROSSE BOILING WATER REACTOR PROPERTY DAMAGE INSURANCE EXEMPTION i
JUNE 18, 1986
- i o PLANT l DESCRIPTION o EXEMPTION REQUEST o ANALYSIS AND CONCLUSION I
l
1 l LA CROSSE B0ILING WATER REACTOR (LACBWR) PLANT DESCRIPTION
- EAST BANK OF THE MISSISSIPPI RIVER IN VERNON COUNTY, WISCONSIN-j LOCATION:
APPR0XIMATELY 1 MILE SOUTH OF GENOA, WISCONSIN AND APPR0XIMATELY 19 MILES SOUTH OF LA CROSSE, WISCONSIN i
i POPULATION DENSITY: LOW POPULATION WITHIN 30 MILE RADIUS OF THE PLANT IS l
140,000'. THERE ARE TWO CITIES AND A POPULATION OF
! 320,000 WITHIN 50 MILE RADIUS 4
HISTORY: LACBWR IS ONE OF A SERIES OF DEMONSTRATION PLANTS FUNDED IN PART 1
BY THE AEC. THE NSSS AND ITS AUXILIARIES WERE FUNDED BY AEC, AND THE BALANCE OF THE Pl. ANT BY THE DAIRYLAND POWER COOPERATIVE. IN 1973 AEC SOLD THE PLANT TO THE DAIRYLAND POWER COOPERATIVE AND PROVIDED THEM WITH A PROVISIONAL OPERATING LICENSE.
i TYPE: BOILING WATER REACTOR, SINGLE-CYCLE, FORCED RECIRCULATION ,
)
N S-S S SUPPLIER /AE/ TURBINE SUPPLIER: ALLIS-CHALMERS/SARGENT-LUNDY/ALLIS-CHALMERS
~
l LACBWR DESIGN FEATURES
! DESIGN OUTPUT 165 MWT 50 MWE (NET) l CONTAINMENT TYPE: DRY, STEEL, INTERNAL CONCRETE SHIELDING DESIGN: DESIGN TO WITHSTAND THE INSTANTANE0US RELEASE OF ALL ENERGY FROM THE PRIMARY SYSTEM FREE VOLUME:
~
264,200 CU. FT.
i MAXIMUM INTERNAL PRESSURE: 52 PSIG MAXIMUM TEMPERATURE: 280*F CORE NUMBER OF FUEL ASSEMBLIES: 72 (LARGE BWR 748)
MASS OF U02 : (17,190 LBS) (LARGE BWR 342,000 LBS.)
NUMBER OF CONTROL R0DS: 29 (LARGE BWR 172)
LENGTH OF ACTIVE FUEL: 83 INCHES (AVERAGE HEIGHT FOR GE BWR 148")
CLAD: STAINLESS STEEL (LIMITS HYDROGEN PROBLEM FOLLOWING ACCIDENT)
- PRIMARY COOLANT SYSTEM INCLUDES
- SHUTDOWN CONDENSER INSIDE CONTAINMENT
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l
e PROPERTY INSURANCE CURRENT RULE (10 CFR 50.54(W))
4
- 1. REQUIREMENTS PEGGED TO CAPACITY PROVIDED BY PROPERTY INSURERS.
PRIMARY CAPACITY FROM EITHER NML OR ANI/MAERP $500M EXCESS CAPACITY FROM EITHER ANI/MAERP ($85M) OR NEIL-II ($550M) $85M
$585M TOTAL MINIMUM CURRENTLY REQUIRED
a (STATilS OF EXEMPTIONS FROM PROPERTY DAMAGE INSilRANCE RULE)
STATilS REQUESTED MAXIMilM COVERAGE LICENSEE / REACTOR (SIZE)
$100,000,000 GRANTED 11/3/8?
PACIFIC GAS & ELECTRIC C0 /HUMBOLDT BAY (63 MW(E))
$500,000,000 GRANTED 6/10/83 YANKEE ATOMIC ELECTRIC J
C0./ YANKEE NtJCLEAR (175 MW(E))
$5n0,000,000 GRANTED 11/3/8?
CONSUMERS POWER CO / BIG ROCK P0 INT (72 MW(E))
$500,000,000 AWAITING FilRTHER PUBLIC SERVICE CO. OF LICENSEE INPilT COLORAD0/ FORT ST. VRAIN l
(330 MW(E))
$500,000,000 GRANTED 0/]'/83 DAIRYLAND POWER COOP./
LA CROSSE (50 MW(E))
$180,000,000 UNDER CONSIDERATION DAIRYLAND POWER C00P./
LA CROSSE (50 MW(E))
a .
DAIRYLAND POWER COOPERATIVE EXEMPTION REQUEST EXEMPTION REQUESTED: DAIRYLAND POWER COOPERATIVE (DPC) REQUESTED TO REDUCE THE
- AMOUNT OF PRIMARY PROPERTY DAMAGE INSURANCE FROM 500 MILLION DOLLARS TO 180 MILLION DOLLARS FROM LACBWR.
- DPC ANALYZED ACCIDENT SCENARIOS IN NUREG/CR-2601, DPC JUSTIFICATION: 1. ,
" TECHNOLOGY, SAFETY AND COST OF DECOMMISSIONING -
REFERENCE 1.lGHT-WATER-REACTORS FOLLOWING POSTULATED ACCIDENTS."
A. ACCIDENT SCENARIO .#1 - LARGE PIPE BREAK BELOW THE CORE CAUSING A LOCA RESULTING IN 100% FUEL CLAD FAILURE NO FUEL MELT. -
B. ACCIDENT SCENARIO #2 - LARGE PIPE BREAK BELOW THE CORE CAUSING A LOCA RESULTING IN 100% FUEL CLAD FAILURE AND A 50% FUEL MELT.
_ NUREG/CR-2601 IS THE PRINCIPLE TECHNICAL BASIS FOR THE
~ CURRENT AND PROPOSED INSURANCE RULE. (0 CFR 50.54W.
- 2. A FUNDAMENTAL CONCLUSION IS THAT DAMAGE FROM THE WORST CASE ACCIDENT AT LACBWR WOULD BE A SMALL FRACTION OF A SIMILAR ACCIDENT AT LARGER PLANTS. .
- 3. DIFFERENCE IN INSURANCE PREMIUM FOR
$500 MILLION VS, $180..MILLION IS $203,000 PER -
YEAR WHICH IS A SIGNIFICANT COST REDUCTION FOR DPC=.
. ~
._ ._ _ _ _ _ . a
NRC STAFF ANALYSIS 1.
LACBWR ACCIDENT SCENARIOS ARE EQUIVALENT TO SCENARIOS IN NUREG/CR-2601.
THE STAFF FINDS THE ACCIDENTS EVALUATED BY THE LICENSEE ARE SUFFICIENT TO ESTABLISH AN ADEQUATE LEVEL OF PRIMARY PROPERTY DAMAGE INSURANCE.
- 2. STAFF CONCLUDES $180 MILLION D0LLARS IS A SUFFICIENT LEVEL OF INSURANCE FOR A 50% FUEL MELT ACCIDENT.
CONSISTENT WITH NUREG/CR-2601 COST ESTIMATES CONSERVATIVE CONTINGENCY OF 25% IS INCLUDED FOR ESCALATION OF COSTS AND INFLATION.
- 3. EXEMPTION IS WARRANTED.
e l
NRC STAFF INTENTIONS
- 1. IT IS THE STAFF'S INTENTION TO GRANT LACBWR AN EXEMPTION TO P 10 CFR 50,54(w).
- 2. DEAL WITH GENERIC ISSUES IN GENERIC 50,54(w) RULEMAKING, .
MARGIN REQUIRED .
USE OF INSURANCE AVAILABLE CORRECTION FOR INFLATION PRIORITY CONTROL OF FUNDS IN ACCIDENT REC 0VERY
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