ML20211M710
| ML20211M710 | |
| Person / Time | |
|---|---|
| Issue date: | 12/28/1995 |
| From: | Federline M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20008B465 | List:
|
| References | |
| FRN-62FR47588, RULE-PR-50 AF41-1-009, AF41-1-9, SECY-95-233-C, NUDOCS 9710150114 | |
| Download: ML20211M710 (2) | |
Text
,_.
MM Qw dd; M w i [paeg s
"k UNIIED STATES -
}b
.) ?$. A NUCLEAR REGULATORY COMMISSION W
1 *o WASHINGTON. D.C. Nh4001
~ * * * *
- December 28,'1995 1
i MEMORANDUM TO:L Bill M. Morris, Director j
Division of Regulatory Applications Office of Nuclear Regulatory Re:; ear,:n F_ ROM:.
Margaret V. Federline, Acting Director Division-of Waste Management t
Office of Nuclear Material Safety
[
.and Safeguards 1
3 SUBJECl::
COMENTS ON THE PROPOSED NUCLEAR REACTOR DEC0mISSIONING
-FINANCIAL ASSURANCE REQUIREMENTS (SECY-93-233)-
L a
~We have completed our review of.SECY-95-223 dated September 1, 1995.
t
.SECY-95-233 discusses your rulemaking plans for amending the nuclear power reactor decommissioning financial assurance rule.
SECY-95-233 also identified five issues and supporting' recommendations to.be addressed while developing the rulemaking for amending the nuclear power reactor decommissioning -
- financial-assurance requirements. Our response to these-five issues is discussed'below.
'We. agree'with the recommendation that the current financial assurance
. requirements for the decommissioning of nuclear power plants are outdated and
.need.toLbe revised (Issue 1). -In addition, we' agree that maintenance costs associated with the storage of spent fuel need not be included.as a decommissioning expense (Issue 2), and that the cost, toireturn the site to
~
1 F
its original nature beyond the removal of radioactive material should not be included as part of the decommissioning cost (Issue 3)'.. We also support the p
-recommendation that the_ regulation have a prov sion for. periodic' reporting' i
E-
- requirements on the licensees'; accumulation of funds (Issue 4). Option C(2) requiring periodic reporting adequately addresses Issue.4.
We support the
[
recommendation that in. situations where an electric utility's access to L
- collect funds-from a ratepayer is limited because of deregulation, power reactor licensees provide a formal guarantee mechanism ~(Issue 5),
Option A-2,: requiring a formal guarantee mechanism, provides reasonable i-asstrance that. adequate funding will be available for decommissioning.
E In response to_the recommendation to revise the decommissioning cost I-estimates,- we support the recomme.%iation that allows the-licensee to submit case-specific decommissioning' cost estimates.. We believe that-the review of t
case-specific decommissioning cost.: may require additional NRC staff resources
- to' support this effort, and this Lshould b2 factored into the recommendation.
2-: -
I
Contact:
~L. Pittiglio,-NMSS
~
.415-6702 i
l 2
b 9710150114 971003 PDR-PGt 1
,.,.,50 f2FR47588 PDR
y r.
- 1; p
B. Morris.
LWe'also support the-recommendation to place the inflation formula in a regulatory guide, to allow future changes to these coefficients in updating cost estimates,'while not requiring a rule change.
I We continue to question the use of the Battelle-Pacific Northwest Laboratory (PNL) reevaluation to replace the PWR and BWR funding requirements in the s
c-current rule.
Recent decommissioning experiences with the Shoreham Nuclear o
Pomer Station (SNPS)-and the fort St. Vrain (FSV) Generating Station indicate i
L that the PNL estimated cost ranges may be low.
Financial assurance based on the PNLL estimates may:not _ necessarily ensure the bulk of. the funds necessary to support decommissioning.
We agree that an adjustment in disposal volume is warranted; recent experiences at both FSV and SNPS-confirm that volume reduction has significantly reduced the volume' of low-level waste. However,-the cost of other decommissioning activities has increased significantly.
The PNL study
-(NUREG/CR-5884) estimated ~the cott of the final survey at $1.2 million and the.
4 Oak Ridge Institute for Science and Education (NUREG/CR-6714) estimated the L
final survey cost at $1.05 million. -The SNPS survey cost exceeded E
$12 million, and the FSV survey cost estimate ranges from $15 to $20 million.
We recommend that an additional study be conducted that compares actual costs, site-specific cost estimates (TLG Corporation has developed several-site-specific cost estimates), and the PNL generic study to develop a
- decommissioning cost estimate based on the comparison of these numbers. This would ensure that the bulk of the funds will be available for decommissioning.
l 1
7 0
9 1
f
!