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
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~***** 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 requirements for the decommissioning of nuclear power plants are outdated and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 ,
~
, 1 decommissioning expense (Issue 2), and that the cost, toireturn the site to 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 i sion for. periodic' reporting' :
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 t : case-specific decommissioning' cost estimates.. We believe that-the review of case-specific decommissioning cost.: may require additional NRC staff resources 2- :to' support this effort, and this Lshould b2 factored into the recommendation.
I
Contact:
~L. Pittiglio,-NMSS ~
- .415-6702 i
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b 9710150114 971003 PDR- PGt , .
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,. ,. ,50 f2FR47588 PDR
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- 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 s
(PNL) reevaluation to replace the PWR and BWR funding requirements in the 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.
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