ML20206J616
| ML20206J616 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/16/1988 |
| From: | Erickson P, Kopp L, Petersen J Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20206J610 | List: |
| References | |
| CLI-88-07, CLI-88-7, OL-1, NUDOCS 8811290054 | |
| Download: ML20206J616 (41) | |
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4-UNITED ST ATES OF AMERIC A NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of Docket Nos. 50-443 OL-01 PUBLIC SERVICE' COMP ANY OF 50-444 OL-01 N EW H AMPSHIR E, g al.
On-site Emergency Planning
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and Safety Issues (Seabrook Station, Units 1 and 2)
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AFFIDAVIT OF JAMES C. PETERSEN, PETER B. ERICKSON AND LAURENCE I. KOPP IN RESPONSE TO JOINT INTERVENORS' DEC0t94ISSIONING CONTENTIONS 7
i James C. Petersen, and Peter B. Erickson, and Laurence I. Kopp being first duly sworn, hereby affirm that the responses to the questions set forth herein are true and correct to the best of their knowledge and belief:
L Q1: Gentlemen, please state your full name, employer, and occupation.
A1:
(Petersen)
My name is James C. Petersen.
I am employed by the U.S Nuclear Regulatory Comission as Senior financial Policy Analyst in the Office of Nuclear Peactor Regulation.
(Erickson)
My name is Peter B. Erickson.
I am employed by the U.S Nuclear Regulatory Cennission as a Project Manager in the Office of i
i Nuclear Reactor Regulation, t
1 (Kopp)
My name is Laurence I. Kopp.
I am employed by the U.S j
Huclear Regulatory Comission as a Nuclear Engineer in the Office of Nuclear Reactor Regulation.
l 02: Gentlemen, have you prepared a statement of your professional l
qualifications?
l l
0011290054 001116 PDR ADOCK 05000443 0
-m
_ _ _ _ - _ _ _ _ _ _ _ - A2:
(Petersen,Erickson,Kopp)
Yes, staterrents of our professional qualifications are attached as exhibits to this affidavit.
03: Gentlemen, what is the purpose of this affidavit?
A3:
(Petersen,Erickson,Kopp)
This affidavit addresses the question whether any of the contentions filed by intervenors New England Coalition On Nuclear Pollution (NECNP). Seacoast Anti-Pollution League (SAPL), the Town of Hampton, and the Massachusetts Attorney General raises a
significant public health and safety or environmental questions in the event Applicants are authorized to operate Unit 1 of the Seabrook Station at low power levels.
As explained in this affidavit, it is the position of the NRC Staff that none of intervenors' contentions raises a significant public health and safety or environmental question.
04: Gentlemen, are you familiar with the order (CLI-88-07) issued by the Comission on September 22, 1988?
A4:
(Petersen,Erickson)
Yes we are.
In CLI-88-07 the Comission ruled that before the Seabrook Station may be authorized to operate at low power, Applicants must first "provide reasonable assurance that adequate funds will be available so that safe decomissioning will be reasonably assured in the event that Icw power operation has occurred and a full power license is not granted for Seabcook Unit 1."
The Comission therefore directed Applicants to provide adequate documentation of their plan to fund the decemissioning of the facility af ter low power.
QS: On October 20, 1988 Applicants filed a document entitled "The Plan In Pesponse To NRC Order CLI-88-07."
Have you had an opportunity to review Applicants' Plan?
A5:
(Petersen,Ericksen)
Yes, we have.
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s'< Q6:
Please describe the major features of Applicants' Plan.
A6:
(Erickson)
The Plan responds to the Commission's order (CLI-88-07).
The Plan analyzes the effects of the proposed low power operation and states that Applicants are financially capable of decommissioning the Seabrook station should full power operations not be approved.
According to Applicants, the length of time the facility will be operated at low power is equivalent to 45 minutes at fullpower (0.75 effective full power hours (EFPH)).
If the maximum proposed power levels and test times are assunied as given by the Applic >nt, the Staff concludes that the total EFPH would be 0.6.
Therefore, the Staff agrees that the Applicants estimate of 0.75 EFPH is reasonable.
Applicants considered a number of alternative ways to dispose of the spent fuel generated during low power operation.
Among these alternatives are shipping the fuel overseas to a French reprocessing plant and to sell the fuel to other licensees which operate Westinghouse fueled reactors.
To the best of my knowledge, Applicants have not made a final determination as to which alternative they will elect to employ should it become necessary to decommission the facility after low pcwer.
It should be pointed out that the intervenors place undue emphasis on the possibility that the spent fuel generated at the Seabrook Station may be shipped to France for disposal.
As Applicants made clear in the October 28, 1988 supplement to the plan, shipping the spent fuel abroad was one of a nurber of options considered by them in
4-estimating the cost of decommissioning the facility after low power.
Letter from Edward A. Brown to NRC, supra, at 2 (October 28, 1988).
Other feasible options, such as selling the fuel to other domestic utilities, were not used to estimate the cost of decomissioning the facility after low power because shipping the fuel overseas would entail the longest period of storing fuel onsite. J_d.
In short, the "overseas shipment" option was selected by Applicants as the worst case scenario for estimating the cost of decomissioning the facility after low power.
r A less expensive and rcre likely alternative would be for Applicants to sell or transfer the spent fuel generated during low power ope /ation to other licer. sees of facilities which use 4 loop Westinghouse reactors.
Under this option, the moderately activated reactor vessel and internals would be cut up and disposed of at a low i
level waste burial ground.
Applicants' plan includes an analysis of i
low power operations at other facilities which demonstrates that low power operation at Seabrook will not cause the primary system to be contaminated above levels acceptable to release the facility for unrestricted access and shows that any minor contamination that may 4
occur can be easily removed. No credit is given for salvage value of 1
laroe components such as valves, the reactor coolant pumps or steam generators that could be used as replacement parts for other four loop Westinghouse plants.
l
)
(Petersen)
Applicants conservatively estimate that it will cost
$21.1 million to implement the Plan, and that this amount would be spent over a projected 52 month period.
The funds needed to implement the Plan are to be provided from the operating revenues of each joint owner (Applicant) and, as with all other project expenses, paid to the project account according to each joint owner's pro rata ownership share.
Applicants' aggregate operating revenues in calendar year 1987 totaled approximately $3.265 billion, which l
equates to an approximate monthly average of $272 million, t
The total $21.1 million estimated cost of implementing the Plan equates to 0.64 percent of Applicants' aggregate operating revenues for the single year 1987 and in fact would be proportionately less since the Plan's cost is projected to be spread over 52 months.
Although in dollar terms the estimated cost of implementing the Flan is sizable, the Staff notes that the estimated cost is but a small fraction of the total revenees received by Applicants from their system-wide utility operations.
i Although the Staff has concluded that Applicants' estimate of $21.1 million is reasonable, the Staff has analyzed Applicants' financial capability assuming for purposes of analysis that the cost of r
impleaenting the plan is as high as $55 million.
This figure was i
selected based on an earlier preliminary estimate by the Staff using extrapolated preliminary decomissioning cost estimates for the
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Shoreham nuclear plant.
Due to the raonitude of the Applicerts' l
I i
-_.--- combined operating revenues, the Staff has concluded that there is reasonable assurance that funding will be available to implement a plan estimated to cost this amount.
Assuming an estimated cost of
$55 million, the cost of implementing the plan would amount to less i
than 2 percent of Applicants' 1987 aggregate operating revenues; in i
fact, the actual percentage cost would be much less since, as noted above, these expenses are expected to be incurred over a 52 month
- period, t
i During decomissioning after low power, total costs will be less than the current monthly costs of maintaining the facility.
This is because personnel, reactor systems surveillance and maintenance and emergency planning activities will be reduced significantly if a t
decision were made to decomission the facility after low power.
Applicants have been providing full funding of current costs for an extended period of time.
07: Mr. Petersen, do you have an opinion regarding whether the Plan provides "ressonable assurance that adequate funding for decomissioning will be available in the event that a full power license is not granted for Seabrook Unit 1" as the Comission has required?
l A7:
(Petersen)
Yes.
It is the Staff's position that the Plan l
provides the requisite reasonable assurance.
l 08: Please explain the bases for this opinion.
A8:
(Petersen)
As stated in my response to Question 6, my review of Applicants' plan reveals that Applicants' combined operating revenues vastly exceed decemissioning expenses.
Further, considering that dcccmissioning expenses would be spread over a pro,iected period of
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l i
l I
r 7
as long as 52 months, such expenses are a small fraction of the Applicants' total resources.
These funding sources are not only fully adequate for this purpose but are reliable in that they are derived from each utility's system-wide operations.
The funds are ultimately provided by Applicants' custorrers who purchase essential utility service on a continuous basis.
Q9: What is the basis for the Staff's conclusion that Applicants' plan is a bena fide one?
A9:
(Erickson)
The plan is bona fide because it is sufficiently detailed to enable the Comission to conduct a sumary review to determine whether the Seabrook Station can be decomissioned safely by Applicants after low power operation in the event a full power license is not granted.
A comprehensive decomissioning plan is not required at this time.
Section 50.82 provides that "for a facility that permanently ceases operation after July 27, 1988," this plan must be submitted "within two years following permanent cessation of operations."
(Petersen,Erickson)
The plan submitted by Applicants provides an adequate basis for estimating the cost of implementing the plan at
$21.1 million.
It is true but insignificant that Applicants' plan does not centain the type of "certification" described in 10 C.F.R. 6 50.75.
This is because Applicants are not required to submit the report containing the certification referred to in section 50.75 before July 26, 1990.
The plan submitted by Appifcants need only satisfy the requirements laid down by the Comission in CLT-88-07, i.e., provide a basis upon which the Comission can find that there
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ is reasonable assurance that funds will be available to decomission the facility after low power in the event a full power license is not granted.
Q10: Applicants state that a conservative estimate of the cost of implementing the Plan is approximately $21 million.
Do you have an opinion as to whether this estimate is reasonable?
A10: (Erickson)
The Staff finds reasonable Applicants' $21.1 million estimated cost of decomissioning the facility after low power operation for a period equivalent to 45 minutes at full power (0.75 EFPH).
This position is based upon an evaluation of Applicants' estimated costs conducted at the Staff's request by Richard I. Smith, P.E., a consultant to the NRC.
Mr. Smith evaluated the Applicants' analysis of neutron activation of the reactor vessel and internals, the potential contamination of the primary system, the proposed schedules and times, the manpower allocated, and waste disposal costs.
Mr. Smith evaluated the activation of the reactor vessel and internals by comparison with the values in NUREG/CR-0130, a previous study that he had helped prepare for the NRC.
Althcugh Mr. Smith l
concludes that Applicants underestimated the activation, he concluded that the higher dose rates that tray be produced would not have a l
significant impact on the estimated costs because all cutting and handling operations of the reactor vessel and internals would have to be done underwater in either case, i
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Mr. Smith has determined that Applicants' assumption that all of the systems external, to the reactor vessel would be releasable is reasonable.
He further concludes that even if there is some contamination of a few components these parts could be decontaminated at a cost in the range of $1 million to $2 million.
- Moreover, Applicants' October 28, 1988 letter, which provides data from 3 other PWR's operating at low power, reasonably demonstrates there would be no contamination above releasable levels even for operations up to 10 EFPH ard that such operations would have little effect on cost. Hr.
Smith concludes that the total labor costs and scheduling estimates are reasonable.
In his evaluation of the estimated transport and waste disposal costs, Mr. Smith finds that Applicants might have overestimated these costs by as much as $28 per cubic foot.
Mr.
Smith states that Applicants' supporting analysis appears reasonable with respect to potential contamination of systems external to the reactor vessel.
Mr. Smith notes, however, that decommissioning costs could doubic (to approximately $42 million) if it is necessary to renove, package, and dispose of these external systems.
As noted in the response to Question 6, Applicants are capable of funding a decommissioning plan costing more than double the estimated $21.1 million.
Therefore, funding will be adequate in the unlikely event that Applicants' estimate of $21.1 million is understated by half. A copy of Mr. Smith's evaluation is attached to this affidavit.
Q11: Does the Plan provide reasonable assurance that Applicants will tave access to funds necessary to inplement the Plan if the cost is
.- approximately $21 million?
What if the cost is closer to $55
)
million?
All: (Petersen)
The answer to both questions is yes.
The plan provides reasonable assurance that Applicants will have access to funds necessary to implement the plan regardless of whether the cost is $21 million or as high as $55 million.
In CLI-88-07, the Comission required Applicants to demonstrate there is reasonable assurance that funds are available to decommission the facility after low power operation.
Nothing in the Comission's order requires Applicants to have the required funds on hand, or in the banh, at the time they receive a license to operate the facility at Icw power.
Rather, Applicants are required to show only that there is reascrable l
assurance they can obtain the needed funds if and when they become i
needed.
Applicants have n'ade this showing.
It should be pointed i
out, however, that pursuant to sections 50.33(k)(2) and 50.75 I
l Applicants are required to file by July 26, 1990, a decomissioning report containing a certification that financial assurance for
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decomissioning will be provided in the amount specified in section 10 C.F.R. I 50.75(c).
a Intervenor SAPL is correct in pointing out that under the plan
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submitted by Applicants in response to CLI 88-07, funds eamarked for pro,iect expenses possibly may be diverted by Applicants to pay expenses for purposes other than meeting NRC requirements.
This is true but nut significant.
Holders of and applicants for NRC licenses
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are responsible for providing the funds required to carry on licensed l
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activities in accordance with NRC requirements.
This applies to all
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1 l
._ licensed activities including construction, operations and maintenance, low power testing and decomissioning.
There is no evidence that Applicants have ever diverted funds needed for project expenses for other purposes.
Q12: Mr. Petersen, Public Service Ccmpany e/ New Hampshire (PSNH), the lead co-applicant, has filed a petition in bankruptcy and some of the other co-applicants have defaulted on : heir obligations to contribute their pro rata share of the facility's maintenance expenses.
Do these circumstances preclude the Staff from finding that there is reasonable assurance that adeouate funding is available to Applicants t
to decomission the facility after low power operation?
l A12: (Petersen)
No, they do not for the following reasons.
Proiect expenses not being paid by MMWEC are being covered through November 30, 1988 by Northeast Utilities (NU), the parent holding company of Connecticut Light and Power Company (CL&P). CL&P is one of the joint owners.
NU has advanced $4.7 million (through CL&P) under this j
conrnitment as of September 20, 1988 which covers MMWEC's share of expenses through October 31, 1988.
In addition, NU has scheduled i
additional payrents totaling between $1.7 and $2.7 million, depending l
l on actual expenses of the project, to cover MwWEC's share through November 30, 1988.
The higher level of expenses is attributable in l
part to ramp-up costs af ter issuance of a low-power license if the j,
costs are incurred prior to November 30, 1988.
F 1
For the perind after Novenber 1988, Applicants have presented a plan for financing MMWEC's share of costs into 1990, by which tire Applicants expect to begin comercial operation.
PSNH has signed an
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aereement with HMWEC to resolve the concerns over the long-term j
funding of MMWEC's share of Seabrook expenses.
The agreement is contingent upon several conditions, including approvals by the directors of PSNH and MMWEC and the Bankruptcy Court.
More importantly, in a public meeting held on November 3, 1988, the Chairman of the executive comittee of the joint owners of the Seabrook project represented to the Staff that in the event the plan is not approved by the court prior to December 1,1988, the other f
co-applicants will advance the funds needed to cover MMWEC's share of L
the facility's costs until such time as the agreement becomes fully i
effective.
i 2
The Staff concludes that Applicants have presented a reasonable plan i
for financing MWEC's share of Seabrook costs including operating and j
low power testing costs and the costs of decomissioning the facility after low power operation, if that is required.
The Staff will continue to monitor closely implementation of the plan to fund MMWEC's share of costs, including satisfaction of the conditions in the pSNH/MMWEC agreement.
4 I
Applicants indicated in submittels to the Staff that Vermont Electric Generation and Transmission Cooperative, Inc. (VEG&T), owner of a 0.4 l
t percent interest in the facility, is in default en payment of its f
share of project costs in the aggregate amount of $2.4 million.
l t
l VEG&T discontinued funding its share of project costs in February 1986.
Its share of project costs for the twelve months through August 1989 is estimated to be approximately $0.6 millier.
Other l
i joint owrcrs have to date made supplementary payments to the project j
I a
1 to cover the deficiency caused by VEG8T's failure to pay. Applicants submitted a schedule showing the amount's, timing and contributors of supplementary payments.
Applicants anticipate that this arrangement will continue through August 1989.
The Staff is continuing to monitor closely the coverage of VEG&T's share of project expenses in the same manner that it is monitoring all aspects of Seabrook funding, including funding by each individual joint owner.
This includes the plan for funding deconsnissioning after low power l
operation, if that is required.
f PSNH owns a 35.6 percent interest and is responsible for this percentage of all project costs.
Since its barkruptcy filing in January 1988, PSNH has continued to operate its electric utility business.
Activities leading toward the comercial operation of
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Seabrook have continued without interruption.
Applicants indicate that PSNH has ret each Seabrook bill on time and in full since the bankruptcy filing and that PSNH is up to-date on its payrents due to the project.
l j,
In the event a full power license is granted and the unit begins cornercial operation, PSNH's share of all reasonable costs of operation will be recovered from its ratepayers (as will the share of l
costs of each joint owner).
Also, the plant capital investrnent (construction cost) will be eligible for inclusien in rate base, thus allowing both a recovery of the investment and a return on it.
The i
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issuance of a full power license would significantly improve the cash flow and financial standing of PSNH and of the other joint owners.
New England Coalition On Nuclear Pollution Q13: Have you had an opportunity to review the contentiers filed by NECNP against Applicants' plan?
e A13: (Petrsen,Erickson)
Yes we have.
Q14: NECNP Contention 1 alleges that Applicants' decomissioning schedule "is unrealistic, and fails to assess the situation with regard to radioactive vJste disposal, as required by the decorinissioning rule.
Do you agree that Applicants' decomissioning schedule is anrealistic?
Ala: (Ericksen)
No, I do not. Applicants' decomissioning schedule is reasona'ule in view of the potential for resale of the fuel to other utilities which have comparable Westinghouse reactors.
Also, the fact that the reactor will operate et low pcwer only fcr a period equivalent to 45 minutes of full power operation (0.75 EFFH) will result in very little, if any, contamination of the primary system ind only moderate activation of the reactor vessel.
Existing low level waste burial facilitics should be sufficient to handle the disposal of the reactor vessel and its internals as well as the minor amount of contaminated components fro;n the primary system.
With regard to hECNP's claim that Applicants' plan fails to assess the situation with resNct to radioactive waste disposal, I must point out again that under the Corrission's decommissioni.99 regulations, such information need not be submitted by Applicants until July 26, 1990.
Applicants' schedule appears reasonable but even if it is overly optiraistic the added costs resulting from delays in shipping fuel or 1
in completing DECON operations or both would not be excessive.
The cost of maintaining the la Crosse facility in a SAFSTOR mode with fuel on site is between $2.0 and $2.5 million per year.
The cost of l
i maintaining the Humboldt Bay Unit No. 3 in a SAFSTOR mode is between j
0.8 and $1.0 million per year.
Although these plants are much i
I smaller than the Seabrook Station, each of them has much more spent fuel and the fuel is much more radioactive because each of these facilities operated at full pcwer for cany years.
Similarly, after
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fuel is removed from the Seabrook site and until DECON is i
i ccmplete the cost of retaining the residual radioactivity would be i
reduced even more.
NUREG/CR-0130 Addendum 4 estimates the cost of j
retaining a PWR in the SAFSTOR mcde without fuel onsite at $128,000 t
per year (1986 dollars).
This cost is for a 1100 MWe PWR that operated at full power for 30 years.
The Seabrook annual cost should i
be no more thar that amount and would probably be much less because
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of the very low level of residual radioactivity.
j Q15: Is NECNP correct that Applicants were required to "assess the l
situation with regard to radioactive waste disposal"?
j A15: (Erickson)
No.
As I indicated in ry response to the preceding l
t question, there is no merit to NECNP's claim that Applicants' plan is i
deficient because it fails to assess the situation with respect to t
radioactive ; oste disposal.
Under the Cceission's decomissioning regulations, such infornation need not be submitted by Applicants
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until July 26, 1990.
In CLI-88-07 the Comission required cnly Applicants provice a basis upon which it could find that there is f
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f reasonable assurance that funds will be available to decomission the Seabrook Station after low power should it become necessary to do so.
Nothing in the Comission's order suggests that it intended to i
require Applicants to do in 30 days what the regulations give them two years to do.
Q16: NECNP also contends that "Applicants' election of the DECON option i
(removal and transportation offsite of reactor parts and fuel) is i
inappropriate." Do you agree?
P A16: (Erickson)
No. Applicants' election of the DECON option is acceptable as it has proposed a logical way to remove the spent fuel from the site for reuse by another licensee.
Also, the minimal contamination, if any, of the primary system and the moderate activation of the reactor vessel would allow the DECON option to be successfully concluded in a reasonable time period and the facility returned to unrestricted access.
Q17: NECNP Contention 2 alleges that Applicants have underestimated the costs of decontrissioning Seabrook Unit 1 "because the estimated costs do not include packing #nd transportation of spent fuel and spent fuel reprocessing byproducts, post-processing storage of spent fuel products, or long-tern onsite storage of contaminated reactor parts."
Is this a valid criticism?
A17: (Kopp)
No.
The Seabrook fuel assemblies are the Westinghouse Standard Fuel Asserbly (SFA) type and are composed of a 17x17 array of ur;niuo dioxide
( 00, ',
fuel rods.
These assemblies are mechanically and neutronically ccmpatible with other Westinghouse fueled reactors using SFAs and may be used in any of these cores.
The low enrichment of the Seabrook fuel is tyoical of initial core values and somewhat lower than the enrichment of typical reload fuel.
Therefor *, the nost feasible use of this fuel is in initial first
- r. cycle cores.
However, a utility may be wil'ing to modify it, r: load fuel pattern to take advantage of the less expensive Seabrook fuel.
'The slight irradiation of this fuel resulting from the less than one j
effective full power hour during low power testing would have negligible effect on the nuclear properties of the fuel and the fuel still would be usable in other Westinghouse 17x17 cores.
This irradiation would require the fuel to be stored in the spent fuel pool of the utility accepting the fuel -ather than in its fresh fuel facility.
However, unf rradiated fuel has been stored in spent fuel j
pools before transfer into a reactor core on numerous occasions and i
so this is not a problem.
The Staff concludes that selling slightly
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trradiated Seabrook fuel to another utility is a feasible option.
(Erickson)
There would be no fuel reprocessing byproducts and no post-processi'q storage of spent fuel prcducts with this option for reuse of the fusi at another Westinghouse reactor facility.
Long tem storage of et ntaminated reactor parts is not expected as DECON could proceed prc eptly at this facility.
As indicated in the response to Question 14, even i' there was long term storage the cost is estirrated to be no more than $128,000 per year.
Q19: NECNp contention 3 alleges that "given the inevitable delays in obtaining space in waste disposal facilities, Applicants have not shown that adequate funding will be available to pay for long-term wiste storage ecsts.
is this a valid criticism?
A18: (Erickson)
No, the disposal of spent fuel will not depend on the ese of a federal repetitory as the fuel would he reused by another licensec with Westirghouse reacto. Also, the inventory of low len1 radioactive wene would prirrarily consist of the reactor vessel and
- _ _ _ _ _ _ _ _ _ _ _ its internals.
Existing low level waste disposal facilities in the United States should easily handle this amount of low level waste.
Further, as indicated above, even if the activated reactor vessel components remained on site for a long time the annual cost is estimated to be no more than $128,000.
Q19: Gentlemen, is it your opinion then that none of NECNP's contentions raises a significant public health and safety or environtrental concern regarding the authorization of low power operation at the Seabrook Stction?
AIS: (Petersen,Erickson)
Yes it is.
As, we have explained in our responses to the preceding questions. Applicants have provided reasonable assuranc-th='
they can obtain the funds needed to decommission the facility ':ter low power operation.
Town of Hampton Q20: Gentlemen, have you reviewed the contention filed on November 2, 1988 by the T:wn of Hampton?
A20: (Petersen Erickson)
Yes we have.
The Town of Hampton raises many of the same concerns as decs NECNP but lumps them into a single contention.
For example, the lown alleges that Applicants were requireo but failed to consider "the current situation with regard te disposal of high-level and low-level radioactive waste."
Similarly, the Town argues that given the inevitable delays in obtaining space in waste disposal facilities Applicants have not shown that adequate funding will be available to pay for long-term waste storage costs.
The Town also rakes sce claims not made by NECNP, Included in this catecory is the claim that "Applicants' plan must provide that fur.d5
l needed to complete decomissioning will be placed in an account segregated from' licensee assets and outside the licensee's administrative control during on-site storage, or othorwise comply with the requirements to reasonably assure adequate funding."
Another is that Applicants' plan is ambiguous regarding whether the spent fuel that is reprocessed in France is to be returned to the Seabrook Station for storage and whether funds will t'e available to meet this expense.
Q21: Does the Town of Hampton's contention raise a significavit public health and safety or enviror. mental concern regarding the authorization of low power operation at the Seabrook Station?
A21: (Erickson)
No it does not.
The Town of Hampton does not raise a significant public health and safety or environrental concern.
As explained earlier, the spent fuel can be transferred to and used by another Westinghouse reactor licensee.
Also, the minimal amount of residual radioactivity consisting primarily at the activated reactor vessel and its internals can be safely removed and sent to a low level waste disposci i cility.
(Petersen)
I agree with Pr. Erickson that the Towr of Hampton's contention does not raise a significant safety or environmental issue.
As Mr. Erickson indicated in his response to Question 14, if the activated reactor vessel components remained on site for o lono a
time the annual cost is estimated to be no more than !!28,000 per year. This would be a minimal funding requirerrent for the Applicants considering that their aggregate crerating revenues in calendar year 1987 totaled approximately
$3.265
- billion, or er average of
- _ _ _ _ _ _ _ _ _ f approximately $272 million per month.
Another measure of the Applicants' funding capability is that they are successfully funding the monthly Seabrook operating budget of $10 million to $11 million, plus an additional $2 millien per month for emergency planning and comunity talations activities.
If a decision were made to decomission the facility, these expenditures would be significantly reduced because of anticipated personnel reductions and the virtual elimination of emergency planning activities.
I do not acree with the Town of Hampton that the plan submitted by Applicants in response to CLI-88-07 is required to be fully prefunded or to establish an external sinking fund.
It is true, however, that by Jrly 26, 1990, Applicants are required by 10 C.F.R. I 50.75 to su'
.t a
decomissioning report containing a certification of financial assurance that funds for decomissioning will be provided by one of the following methods: (1) prepayment; (ii) an external sinking fund; or (iii) a surety bond, insurance policy, or other guarantee method.
Notning in CLI-88-07, however, indicates that the Commission inter.ded to impose this obligation on Applicants in advance of that date.
Rather, the Comission required only that the Applicants provide a basis upen which it could find that there is reasonable assurance that adeouate funding for decomissioning will
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1 be availabic in the event that a full pewer license is not granted.
As stated earlier, the Applicants have demonstrated that there is reasonable assurance that funds will be available to decomission the facility in that situation. Applicants have reasonably estir:ated the
. - _ _ _ _ _ - _ _ _ _ _. _ _ cost of decomissioning the facility after low power to be approximately $21.1 million.
And, as I indicated in 'ny response to Questions 6,
8, and 11. the Staff has concluded, based on its analysis of the Applicants' financial resources, that there is reasonable assurance that Applicants are capable of decomissioning the facility after low power even if the actual cost of doing so were to exceed this estimate by as riuch as $35 million.
Seacoast Anti-Pollution League 022: Gentlemen, have you reviewed the contentions filed on November 2, 1988 by the Seacoast Anti-Pollution League?
A22: (Petersen,Erickson)
Yes we have.
The Seacoast Anti-Pollution l
League (SAPL) has three contentions.
Fir;' SAPL claims that Applicants have not provided adequate documentatien of their plan or appropriate comitments under that plan as required by CLI-88-07, in that it "does not fully document the reasonably anticipated necessary handling of irradiated fuel from low power operation and does not provide appropriate financial and institutional comitments for handlir.g said irradiated f uel. "
- Second, SAPL contends that Applicants "have not provided ' appropriate comitments' to fund the decomissioning plan" as required by the Comission.
Third, SAPL contends that the "initiation of low power testing at Seabrook in these unique circumstances and at this time would be contrary to the Comission's general policy of keeping radioactivity levels 'as lcw as reasonably achievable' (ALARA) and contrary to the requirements of the National Envirormental Policy Act [NEPA),"
~ 22 -
Q23: Do any of SAPL's contentions raise a significant public health and safety or environmental concern regarding the authorization of low power operation at the Seabrook Station?
A23: (Petersen,Erickson)
No, none of them raises a significant public health and safety or environmental concern reg H ing the authorization of low power operation.
Q24: Please explain why you have reached this conclusion with regard to SAPL Contention 17 l
A24: (Erickson)
Contrary to SAPL's assertion, the plan submitted by Applicants adequately documents the manner in which the spent fuel generated during low pewer operation will be disposed of.
As 1 indicated earlier, at least two alternatives were considered by Applicants.
The first is shipping the spent fuel to a French reprocessing facility; the other is selling it to a domestic licensee.
Of the two, the. latter is the less expensive and rnere likely.
The spent fuel generated during low power operation at the Seabrook Station is similar to that used at many PVR's with Vestinghouse reactors and thus can be transferred to and used at these facilities as Applicants have suggested.
Since the fuel has considerable value at these facilities, the cost of transfer of this fuel would likely be offset by the sale price of fuel. Therefore, it is the Staff's position that disposing of the spent fuel generated at Seabrook by selling er transferring it to other utilities is a reasonable and logical alternative.
It is not necessary for the Staf' to evaluate the suggested alternative of sending the fuel to France for reprocessing as this alternative is not 14ely to be employed.
As I noted earlier, the
- __-_______ _ ___ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ "overseas shiperent" option was selected by Applicants because it has the greatest potential for increasing the estimated cost of decomissioning the facility after low power.
Q25: Please explain why you have concluded that SAPL Contention 2 does not raise a significant public health and safety or environmental concern with respect to low power operation of the Seabrook Station?
A25: (Petersen)
SAPL's contention essentially repeats the the claks made by the other intervenors that Applicants do not have access to j
the funding needed to decomission the facility after low power operation.
Since my prior responses fully explain why there is no merit to this claim, I need only briefly sumarize the Staff's position en this matter.
The estimated costs of decomissioning the facility are but a small fraction of Applicants' combined system-wide operating revenues.
I These revenues are the source of funds for operating, raintaining, j
and decomissioning Unit 1 of the Seabreok Station in the event a full power license is not granted.
The assumption that decomissioning can be accon plished within the present rnonthly I
operating budget which averages $10 million to $11 million is
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reasenable because during the decomissioning phase personnel and emergency plannino expenditures would be significantly reduced from j
current levels.
It is also important to note that the financial burden of deconnissioning will be spread out over an estimated 52
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Because of this spreading out of costs, monthly f
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- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. decomissioning expenditures would be a very small fraction of Applicants' combined system-wide operating revenues.
The Staff recognizes that such a funding method (i.e., from current operating revenues) is oifferent from the funding requirements for a post-comercial operation decomissioning as specified in the regulation (10 C.F.R.
I 50.75) recently adopted by the Comission.
l Acceptable funding methods under section 50.75 include prepayment, 1
l external sinking funds, and surety bonds, insurance policies, or l
cther guarantee instruirents.
The Seabrook joint owners will be I
required to comply with the funding and reporting requirements of the rule by July 26, 1990.
(See 10 C.F.R. I 50.33(k)(2)).
Applicants' plan to fund decomissioning after low power is sufficient for present purposes because (1) the cost is substantially less than a post-conrercial decomissioning; (2) the decomissioning expenditures will be spread cut over an estimated 52 renth period; and (3) monthly decomissioning expenditures are projected to be a small fraction of the joint owners' combined system-wide operating revenues.
For these reasons, the Staff cor,cludes there is reasonable assurance that Applicants will be able to obtain the funds needed to safely decomission the facility after low power operation, Q26: Gentlemen, are you familiar with the text of SAPL Contention 37 o
A26: (Petersen,Ericksen)
Yes, we are. SAPL Contention 3 asserts that authorizing the Seabrook Station to operate at low power would be contrary to the Comission's general policy of keeping radioactivity
levels 'as low as reasonably achievable' (ALAKA) and contrary to the requirements of the National Environmental Policy Act [NEPA)."
i Q27: Gentlemen, have you reviewed the contention to deterrnine whether it raises a significant safety or environmental issue?
A27: (Petersen,Erickson)
No, we have not.
The question raised in SAPL Contention 3 is beyond the scope of the Comission's order in CLI-88-07 because it seeks to have the Comission deny Applicants permission to operate at low power even where, as is the case here, there is reasonable assurance that Applicants can obtain the funding needed to decomission the facility after low power operation, i
Massachuetts Attorney General Q28: Gentlemen, have you reviewed the contention filed on November ?, 1988 by the Massachusetts Attorney General?
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A28: (Petersen,Ericksen)
Yes, we have. The Attorney General's single f
contention challenges the adequacy of Applicants' decomissioning
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plan as well as the sufficiency of funds available to Applicants to irrplement the plan.
In these respects, the Attorney General's 1
i contention raises generally the same kinds of questions as are raised
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by NECNP, SAPL, and the Town of Hampton. There are nine bases to the Attorney General's centention, many of which contain several i
I subparts.
t Q29: Does the Staff have an opinion as to whether the Attorney General's contention raises a
significant public health and safety or i
environrrental concern with respect to low power operation of Unit 1 of the Seabrook Station?
A29: (Petersen,Erickson)
Yes.
It is the Staff's position that the t
Attorney General's contentinn does not raise a significant public
(
l health and safety or environmental question.
t
_ _ _ _ _ _ _ _ _.. 030: What are the bases for this position?
A30: (Petersen,Erickson)
The Attorney General repeats many of the charges made by the other intervenors and therefore our prior answers are applicable to his cantentions, also.
For example, bases (a) and (b) of the Attorrey General's contention assert that the plan submitted by Applicants must comply with the requirements set forth in 10 C.F.R.
Il 50.33(k)(1) and 50.75.
The Attorney General is incorrect.
Section 50.33(k) is inapplicable to Applicants in any case because by its terms it applies to "applicants for an operating license [.]"
Applicants, however, already possess an operating license to load fuel.
It is section 50.33(k)(2) -- which applies to "a
hqlder of an operating license" -- which covers Applicants' situation.
As we have explained earlier, the text of section 50.33(k)(2) makes clear that Applicants need not suteit the information referred to in section 50.75 until July 26, 1990.
Nothing in CLI-88-07 indicates that the Conunission intended to reduce the tin Applicants have to fulfill this obligation from 2 years to 30 days.
(Erickson)
In basis (c) of his contention, the Attorney General alleges that Applicants have not sufficiently docuwented the bases for their estimate of the cost of decomissioning the facility after low power.
The Attorney General questions the reasonableness of the
$21.1 million estimate because this figure is substantially less than the estimated cost of deccmissioning a facility that has operated at full power for the full term of the license. This is not surprising.
__ As I have explained earlier, decomissioning the Seabrook Station after low power will much less costly than the decomissioning of a facility after full power operation.
This is because low power operation will result in little, if any, contamination of the primary system and only moderate activation of reactor vessel. The base.1 for the estimated cost of decomissioning the facility are documenteo in the plan submitted by Applicants.
That estimate has been evaluatid by the Staff and found reasonable.
(Erickson, Petersen)
In basis (d) of his contention, the Attorney General alleges, without factual support, that Applicants' cost estimates are premised upon unreasonable and unsupportable assurptions regarding the issuance of needed approvals by the Comission, the U.S. Departirent of Transportation, and other agencies of the Government.
In this affidavit, we have explained why the Staff finds Applicants' estimate of the cost of decomissioning the facility af ter low power reasonable.
Moreover, it should be noted that the Staff has found that there is reasonable assurance that funds will be available to deccmission the facility after low power even if the actual cost of doing so exceeds the estimated cost by as much as $35 million.
(Erickson,Petersen)
In bases (e), (s), and (h) of his contention, the Attorney General alleges that Applicants' cost estimate is understated because it assurtes a 7 percent contingency factor whereas the industry average is 25 percent, fails to account fully for
, decomissioning activities that must coatirac during the likely period that spent fuel is stored onsite, and understates the duration of low power operation. Assuming these claims are true, they are not significant.
As noted above, the Staff has found that there is reasonable assurance that funds will be available to decomission the facility after low power even if the actual cost of doing so exceeds the estimated cost by as truch as $35 million, wt..ch is more than 150%
of the estimated cost.
(Petersen)
In basis (i) of his contention, the Attorney General alleges that Applicants' have not demonstrated that there is reasonable assurance that funds will be available to decommission the facility after low power.
In my response to Question 12, I addressed this point at length and explained why the reasonable assurance required by CLI-88-07 exists.
(Erickson,Petersen)
In basis (f) of his contention, the Attorney General criticizes Applicants for not identifying the sites where the spent fuel generated durine low power operation will be disposed and for not specifying the tems and conditions of such shipments.
The Attorney General's criticism is not valid because, as we have noted repeatedly, the regulations requiring a licensee to assess the waste disposal situation are not applicable to the plan submitted by Applicants in response to CLI-88-07.
Rather, the Commission required cnly that Applicants provide a basis upon which it could find that there is reasonable assurance that funds will be available to
r decomission the facility after low power.
The plan submitted by Applicants does this.
Q31: Gentlemen, does this complete your affidavit?
A31: (Petersen,Erickson,Kopp)
Yes, it does, i
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' James C. Petersen i
Peter B. Erickson
$6'J4/e tYls-
- Laurence I. Kopp g
Subscribed to and sworn before me this 16th day of November 1988 k
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Pacific Northwest Laboratories l
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Tebhoae m 376 3844 Telen 154874 t
November 9, 1988 j
l Mr. Peter B. Erickson Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 l
Dear Mr. Erickson:
l In response to your urgei't request, I have reviewed The Plan in Response to i
l NRC Order CLI-88-07 (hereinafter called The Plan), and the letter dated October I
28, 1988 supplementing the information presented in the plan, submitted by I
the New Hampshire Yankee (NHY) division of Public Service of New Hangshire.
The primary focus of my reiview was on the development of the estimated costs i
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for performing the decomissioning of the Seabrook 1 station following low-power testing during which the reactor would be in operation for the equivalent of not more than 1 effective full-power hour. Principal attention was paid to the portions of the reactor that would become radioactive as a result of neutron activation during this limited amount of operation, for the purpose f
of estimating the activation levels, and the resultant effect on packaging, j
transport, and disposal costs for removing of those materials from the Seabrook site. Another area examined was the contention that the contamination levels in the piping systems exterior to the reactor vessel would be very low, and could be decontaminated to levels that would permit unrestricted relea u of the piping, pumps, heat exchangers, tanks, etc. A third area examined was t
the proposed schedules and the tines and manpower allocated to accomplishing j
the various tasks proposed under tae Plan, t
My conclusions and supporting infonution are presented in the body of this i
letter. My qualifications to perfoim this review are presented in the copy of my resume, which is attached to this letter.
l Activated Materials A simple calculation was made to estimate the expected suFlace dose rates from the reactor vessel and the vessel internal structures, based on the detailed calculations performed and reported originally in NUREG/CR-0130, the l
1 ATrAtaAT i
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Battelle Peter B. Erickson November 9, 1988 Page 2 reference PWR study.
To a first approximation, the activation of the reactor vessel and its internals can be expressed by:
Aj = Napj (1 -le-t) where t is the number of full-power years of irradiation seen, by the material, and pi is the neutron flux level appropriate for full poner operation.
In NUREG/CR-0130, the time was 30 full-power years.
In the Seabrook case, the time is expected to not exceed 1 full-poner hour, or 1.14 x 10-4 full poner years.
The ratio of the Seabrook irradiation to the irradiation of the reference PWR is :
R = [1 - e-(0.131)(1.14 E-4) ] / (1 - e-(0.131)(30) ]
= 1.54 E-5 when the principal radionuclide is 60Co. Applying this reduction factur to the surface dose rates reported in Table C.3-1 of NUREG/CR-0130, the average dose rate from the core shroud ranges from about 2 to 6 R/hr.
Similarly, the surface dose rates from the core barrel and the vessel wall are in the range of 1 R/hr and 6 mR/hr, respectively. Obviously, the shroud and core barrel dose rates are significantly greater than the average value of 500 mR/hr postulated by NHY in the Plan for the vessel and its internals, and the vessel wall is significantly loner. On a mass-average basis, the 500 mR/hr value may be reasonable, in any event, the higher dose rates on the internals would not have any significant effect on the estimated costs because all of the cutting and handling operations would have to take place underwater in either case.
Appropriate loading of vessel wall segments together with the higher activity materials within the shipping containers could adequately shield the higher activity materials and the net result on the packaging costs would be essentially negligible.
An examination of the NHY cost estimate shows that the cost of transport and disposal for the activated materials was assumed to be 590.00 per cubic foot.
Using the January 1988 cost schedule from the Barnnell disposal site, and assuming that the containers satisfy the DOT regulations of less than 10 nA/hr at 2 meters from the edge of the vehicle, I calculated disposal costs to be in the $51-$52 per cubic foot range.
The transport costs, assuming 1000 miles betneen the Seabrook site and Barnnell, would add an additional $12-$13 per cubic foot if the containers were shipped by legal-weight truck (no more than 3 containers per shipment).
Thus, the total transport and disposal costs that I calculate are in the $62 $63 per cubic foot range, considerably less than the $90 per cubic foot postulated by NHY, making their estimate quite conservative.
Release of Pipino Systems External to the Reactor In their October 28th letter, hHY presents information from several other stations on the concentrations of radioactive materials in the coolant streams follo^ ' m los poner operatien at those stations.
the analysis is based en
Peter B. Erickson November 9, 1988 Page 3 the premise that since the isotopes of most concern (60Co and 137Cs) were undetectable in those coolant streams, the concentrations must have been less than the loner limit of detection (LLD).
Then, assuming concentrations slightly greater than the LLD, and assuming that all of the dissolved material plates out on the internal surfaces of the steam generator tubes, a calculation is presented that demonstrates the contamination levels on the steam generator tubing to be less than the limit for unrestricted release as given in Regulatory Guide 1.86 (< 1000 disintegrations pe' minute per 100 square centimeters of surface).
In fact, the 01culated rest.lt is a factor of 10 below the limit.
From the information presented, the assumption that all of the systems external to the reactor vessel would be releasabit' appears to be a reasonable one.
NHY has also postulated an extensive sampling program to assure that these systems are in fact releasable.
Some 25% of the piping is postulated to be cut, in locations expected from other reattor ex,terience to have concentrations of deposited radionuclides, to perform measurements on the interior of the piping, valves, tanks, etc.
These samplirg activities are included in the cost estimate.
In any event, a simple chemical decontamination of those systems could be performed if necessary, to assure meeting the release limits, at a cost in the range of $1 to $2 million.
Schedule and Manponer Estimates I have reviewed the detailed schedules and the manponer allocations presented in The Plan.
In several instances, the total duration of the decommissioning ef fort could be shortened by performing some activities in parallel, thereby reducing the over head costs of the project.
While individual estimators could quibble over the details of specific activities, the total labor estimates and the work durations appear to be realistic and conservative, overall.
Cautionary Co rent The key assumption in the hHY analysis is that the systems external to the reactor vessel are or can readily be made releasable for unrestricted use.
With this assurption, the bulk of the labor and disposal costs associated with decomissioning a large station at the end of life are eliminated.
For the conditions expected to result from the low poner testing at Seabrook, the information presented in support of this assumption appears reasonable.
Ho^ever, should it be necessary to remove, package and dispose of these systems at a lon-level waste site. the costs of the project could easily be doubled.
In addition, significant delays in receiving the possession-only license could increase the project costs by lengthening the period that the station rust remain under its operations technical specifications, thereby requiring continued ope ations staffing.
De'ays in removing the fuel from the site beyond the time postulated in The Plan would also increase labor costs from the security forces required by the presence of the spent nuclear fuel.
()BaHelle Peter B. Erickson November 9, 1988 Page 4 I trust the above analyses and comments will be of assistance to you in your deliberations related to the acceptability of The Plan.
If you have any questions about any of the material, please let me know.
Sincerely h 'E. E m Richard I. Smith, P.E.
Staff Engineer Waste Systems Department Attachment c {4 }e l*
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RICHARD 1. SMITH Staff Engineer Waste Systems Development and Engineering Section Waste Systems Department Education B.S.
Physics, Washington State University M.S.
Applied Physics, University of California at Los Angeles P.E.
Nuclear Engineering, State of Washington P.E.
Nuclear Engineering, State of California Experience Mr. Smith's training and experience in shysics and engineering has been utilized in many programs and projects. He las contributed to and managed a variety of programs in the area of experimental reactor neutronics. He has contributed to and managed an extensive program that examined decommissioning of licensed nuclear facilities, and is currently engaged in concept evaluation and conceptual design for the Monitored Retrievable Storage program and in system analyses for the Systems Integration program, all related to the management and disposal of high-level radioactive waste, o Experimental Reactor Neutronics Mr. Smith served as an experimentalist, and subsequently as a section manager, responsible for programs of research in reactor neutronics utilizing a number of research and test reactors.
Major areas of effort included plutonium recycle neutronics experiments in light water reactors, and high temperature neutronics experiments in support of the high temperature gas-cooled reactor and molten-salt reactor programs, o Nuclear Facility Decomissioning Mr. Smith contributed to, and subsequently managed, a six-year program sponsored by tha U.S. Nuclear Regulatory Commission that examined t*.e technology, safety and costs of decomissioning licensed reference nuclear facilities.
These studies, which covered reactors, fuel cycle facilities, and non-fuel cycle nuclear facilities, are knenn and used throughout the world.
As a result of these studies, Mr. Smith was invited by the International Atomic Energy Agency (IAEA) to participate in the development of a report on the decommissioning of nuclear facilities, dealing with the status of the technology for decontamination, disassembly, and waste management.
He was the princip61 author of the report and participated in the international working group that reviened and finalized the report.
He was subsequently invited to perform a similar role in the preparation of a second report that dealt with decontamination of nuclear facilities to facilitate inspection, maintenance, modification or plant decomissioning, e Nuclear Waste Storage Mr. Smith has contributed to and led a variety of research and development tasks related to the storage esf nuclear wastes.
He led a study that developed a pre-corceptual design for a Monitored Retrievable Storage (MRS) facility co-located with a geologic waste repository and estimated the life cycle costs at the f acility for seseral possible storage scenarios.
He led the effort that develcped descriptiens
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of MRS facilities, utilizing each of the principal storage concept r
candidates, and estimated the life cycle costs at these facilities for a common throughput, capacity, and waste form scenario.
He was a principal participant in the concept ranking and recommendation effort that led to DOE's selection of two MRS concepts for further development.
He participated in the development of the advanced conceptual design for an MRS facility in support of the MRS Proposal to Congress. He is presently
[
a technical consultant to and participant in the Systems Integration l
program.
4 L
Mr. Smith is a member of the American Nuclear Society. He is the author or coauthor of several articles published in Nuclear Science and Engineering i
and in Nuclear Technology, has presented papers at national meetings of the American Nuclear Society and at an international symposium on decommissioning of nuclear facilities in Vienna, and has participated in and made )resentations at a series of MRC-State Workshops on decommissioning.
He has autiored over i
50 formal and/or informal reports of research sponsored by the U.S. AEC, ERDA,
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NRC, and by EPRI and other organizations.
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l JAMES C. PETERSEN PROFESSIONAL QUALIFICATIONS OFFICE OF NUCliAR REACTOR REGULATION I am a Senior Financial Policy Analyst in the Office of Nuclear Reactor fRegulation,U.S.NuclearRegulatoryCommission.
I am responsible for the re-view and evaluation of the financial qualifications of nuclear facility license applicants to pursue proposed activities under a license, primarily the construc-tion and operation of nuclear facilities.
In this regard, I have prepared fi-nancial qualifications analyses for inclusion in the Staff's Safety Evaluations and for presentation as evidence on the record of the Atomic tafe+/ and Licensing Board's safety hearings.
I have served as a Staff witness lefore the Atomic Safety and Licensing Board in numerous proceedings. My work also involves keep-ing abreast of developments in the financial markets and in the electric utility and nuclear industries.
I received a Bachelor of Science in Business Administration degree (awarded cum laude) with a major in Accounting from the University of Denver in 1968.
I have continued my formal education through college and university courses in finance, math, economics and computer science and through several intensive short courses.
I an a member of Beta Gamma Sigma, the national business admin-istration honorary; and Beta Alpha Psi, the national accounting honorary, which presented me with its award for outstanding service.
Fren 1968 through 2973, I was employed in a number of assignments on the staff of the Controller of the Atomic Energy Comnission. These assignments in-cluded reviewing, designing and irplementing accounting systems and procedures for AEC offices and AEC contractors.
I also assisted in the financial review of nuclear facility license applicants during the period when that function was performed by independent staff merbers of the AEC Office of the Controller.
That function was subsequently transferred in its entirety to the NRC.
In Jan-l uary of 1974, I joined the regulatory staff and assumed responsibilities in the l
financial qualifications review of nuclear facility Itcense applicants.
I have l
worked in NRC financial analysis since that time, except for a one-year assign-nent at the U.S. Department of Energy where I worked on the financing of coal gasification ard geotherral electric projects.
I I
STATEMENT OF PROFESSIONAL QUALIFICATIONS OF PETER B. ERICKSON
=
My name is Peter B. Erickson.
I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager in the Office of Nuclear Peactor Regulation.
I received a B.S. Degree in Electrical Engineering from Montana State College in 1956 and an M.S.
Degree in Systems Management from the University of Southern California (Extension Courses) in 1973.
I have been involved in various nuclear reactor programs since 1956.
I have been employed in Idaho, Los Alanos, N.M., Nevada and Maryland.
For the past 16 years I have been assigned Project Manager duties, with the AEC and the NRC for neny licensed research and power reactors with ar errhasis on those reactors undergoing decomissioning.
I beve also had a major roie in the development o' NRC guidance and rule charges on reacter decomis sionirp.
I was the ?#C Project Manager in the decomissiening of Femi 1 Sexton, the N.S. Savannah, Plumbrcok Test Reactor, NC State Pool Reactor and a number of other research and test reacters.
At the present tine I am the NRC Project Haneger for the La Crosse BWR, Humboldt Fay Unit 3, Indian Point Unit 1, Fermi Unit 1. Peach Bottem Unit 1. Dresden Unit 1 and the Vallecites Boiling Waster Peacter.
Each of these plarts is invnived in decomissioning, In June 1987 I provided testimony on reactor decomissiong for the o
Arizona Corporation Ccarlission at a rate hearing for the Palo Verde facility.
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O STATEMENT OF PROFESSIONAL QUALIFICATIONS CF DR. LAURENCE l. KOPP Education:
Fairleigh Dickinson University, B.S. Physics,1956 Stevens Institute of Technology, M.S. Physics,1959 University of Maryland, Ph.D., Nuclear Engineering,1968 Professional Experience:
U.S. Nuclear Regulatory Commission Nuclear Engineer (1965 - present)
Safety evaluations of reactor core design as described in applications for Construction Permits and Operating Licenses, topical repor ts submitted by reactor vendors and licensees on safety-related subjects, criticality analyses of fresh and spent fuel storage racks.
Westinghouse Astronuclear Laboratory Senior Scientist (1963 - 1965)
Design and analyses of reactor physics aspects of nuclear propulsion systems related to NERVA program including development of computer programs.
Martin-Marietta Corporation Senior Engineer (1959 - 1963)
Design and analyses of reactor physics aspects of advanced concept reactors such as the fluidized bed and compact space reactors.
Developtrent of analytical methods and computer codes for nuclear reactor design and analysis.
Federal Electric Corporation Senior Programmer (1957 - 1959)
Developed and programmed various computer codes for DEWLINE project including payroll, statistical analysis of failure rates, and inventory cont.
Curtiss Wright Research Division Physicist (1956 - 1957)
Assisted in development and programming of reactor analysis me'. hods.
Professional Societies:
American Nuclear Society (June 1985 - present)
Chairman of ANS-10 national committee on Mathematics and Computations Standards.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION REFORE THE COMMISSION In the Matter of Docket Mos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 OL-01 i
NEW HAMPSHIRE, et al.
On-site Emergency Planning and Safety Issues (SeabrookStation, Units 1and2)
I CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO INTERVENORS' MOTIONS TO REOPEN REC 0R0 AND ADMIT LATE-FILED DEcom!SS10NING CONTENTIONS" in the i
above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by i
deposit in the Nuclear Regulatory Comission's internal mail system, this 16th day of November 1988:
Samuel J. Chilk (15)*
H. J. Flynn, Esq.
I Office of the Secretary Assistant General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management I
Washington, DC 20555 Agency i
500 C Street, S.W.
Sheldon J. Wolfe, Esq. Chairman
- Washington, DC 20472 Administrative Judge Atomic Safety and Licensing Board Calvin A. Carrey U.S. Nuclear Regulatory Comission City Hall Washington, DC 20555 126 Daniel Street Portsmouth, NH 03801 Dr. Jerry Farbour' Administrative Judge Robert Carrigg, Chaiman Atomic Safety and Licensing Board Board of Selectr4n U.S. Nuclear Regulatory Comission Town Office Washington, DC 20555 Atlantic Avenue North Hampton, NH 03870 Mr. Emeth A. Luebke Administrative Judge Judith H. Mizner, Esq.
4515 Willard Avenue Silverglate, Gertner, Baker, Chevy Chase, Maryland 20815 Fine, & Good 88 Board Street Philip Ahren Esq.
Boston, PA 02110 Assistant Attorney General Office of the Attorney General J. P. Nadeau State House Station Board of Selectmen Augusta ME 04333 10 Central Street Rye, NH 03870 Thomas G. Digran, Jr., Esq.
Robert K. Gad, I!!, Esc.
Ropes & Gray 225 Frank 1tr. Street Poston, MA 012110
, - -, - l Carol S. Sneider, Esq.
R. Scott Hill-Whilton. Esq.
Assistant Attorney General Lagoulis, Clerk. Hill Whilton Office of the Attorney General
& McGuire One Ashburton Place, 19th Floor 79 State Street Boston, MA 02108 Newburyport, MA 01950 George Dana Bisbee, Esq.
Alkn Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Street 20 Franklin o
Concord, NH 03301 Exeter, NH 03833 l
r Diane Curran Esq.
William Armst'ong Harmon, Curran & Tousley Civil Defense Direr; tor 2001 S Street, NW Town of Exeter Suite 430 10 Front Street Washington, DC 20009 Exeter, NH 03833 Gary W. Holmes, Esq.
Robert A. Backus, Esq.
Holmes & Ellis Backus, Meyer & Solomon 47 Winnacunnet Road 116 Lowell Street
(
Hampton, NH 83842 Manchester, NH 03106 i
Atomic Safety and Licensing Paul McEachern, Esq.
f Appeal Panel (8)*
Matthew T. Brock, Esq.
I U.S. Nuclear Regulatory Comissien Shatnes & McEachern Washington, DC 20555 25 Maplewood Avenue l
P.O. Box 360
(
Atomic Safety and Licensing Fortsmouth, NH 03801 1
Coard Panel (1)*
U.S. Nuclear Regulatory Comission Charles P. Graham, Esq.
Washington, DC 20555 McKay, Murphy & Graham 100 Main Street l
Docketing and Service Section*
Amesbury, MA 01913 l
Office of the Secretary 1
U.S. Nuclear Regulatory Comission Sandra Gavutis, Chair. an t
Washington, DC 20555 Peard of Selectmen PFD #1, Box 1154 l
Peter J. Matthews, Mayor Kensingten NH 03827 i
l City Hall Newburyport, MN 09150 William S. Lord
(
Board of Selectan Ashod N. Aririan, Esq.
Town Hall - Friend Street l
Town Counsel for Merrimac Amesbury, MA 01913 L
376 Main Street l
Haverhill, MA C8130 Sheldon J. Wolfe, Esq.
A$ninistrative Judge 1110 Wirbledon Drive McLean, VA 22101 i
L f
F
Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen l
13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey United States Senate 531 Hart Senate Office Building Washington, DC 20510 f
9 h
Yhtuj' Grt[or;fp'la n er *y Counse(or
- Staff 0
.