ML20235K093
| ML20235K093 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/10/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Cranston A SENATE |
| Shared Package | |
| ML20235K097 | List: |
| References | |
| NUDOCS 8707160150 | |
| Download: ML20235K093 (32) | |
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Q dlb The Honorable Alan Cranston JUL 10 W United States Senate Washington, DC 20510
Dear Senator Cranston:
On May 1,1987, you sent us a letter in which you forwarded a number of questions related to the Ry chn Rico Nuclear Generating Station. The questions had been sent to ynu by one of your constituents, Ms. Elaine Southard, on March 12, 1987, and they asked about the general subject areas of the Babcock & Wilcox plant reassessment, Nuclear Regulatory Commission budget and workload, radioactive waste disposal, plant licensing and relicensing, and plant decommissioning. Using the question and answer format, enclosed is our response to each of your constituent's concerns.
Sincerely, 1 Original sigacd b[ ]
Victor Stelb #
Victor Stello, Jr.
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Executive Director for Operations l
Enclosure:
As stated Distribution:
Docket File GMHolohan DCrutchfield l NRC/L PDR JMurray RWeller EDO 2846 GPA/CA (S) JLee l ED0 rf SECY CCheng TEMurley VSteilo JRichardson JSniezek DMossburg(ED02846) LShao FMiraglia PShea RStarostecki MBell PRabideau CSperpan l i
SEE PREVIOUS CONCURRENCES l LETTER REVISED IN NRR DIRECTOR'S OFFICE 6/19/87 I l
0FC :DRSP/POV :EMTB :DRSP/PDV :DRSP/AD :DRSP/D :ADP :NRR
.....:_______.....:.. ___.. __.:.... ____...:.._____.....:......___ ..:....___.....:... ___.... 4
.NAME :RWeller* :CCheng* :GKnighton* :GHolahan :DCrutchfield*:FMiraglia* :JRIchardson DATE :6/10/87 :6/9/87 :6/10/87 :6/10/87 :6/11/87 :6/16/87 :6/9/87 '
0FC :NRR :NRR :NMSS :RES : ARM :NR :NRR A l
. _ _:LShao*
NAME :__ _ _ _:RStarostecki*:MBell*
_ _ . . . . . : . . . . . . .:C$erpan* . . . _ _ . . . : . . e_zek
. . . . : . . . :PRabideau* . ._. _. _:TEdurley
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. . :/V i_____:...._____...:____________:___.._______:.________...:___________:.p ......
lDATE :6/9/87 :6/15/87 :6/9/87 :6/9/87 :6/9/87 :6/"_,N/87_ _:6/7 _ _ _ _ _ _ : _ _ j_
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..: :....._____ .: ...________:...___.___..:__ ........ l NAME :EReis* :VStel o :
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_____:....._......:______......:...b.....::.___........::...._______.::.._______...::...........
DATE :6/9/87 :(/4,/87 - -
8707160100 070710 \
hDR ADDCK05003g2 0FFICIAL RECORD COPY j
RESPONSE TO QUESTIONS RELATED TO .!
1 RANCHO SECO NUCLEAR GENERATING STATION A. B&W Reactor Plant Design Reassessment Study I Question A-1 Are you planning to allow Rancho Seco to restart before that study and its recommendations are complete?
Response
The completion of the B&W Owners Group reassessment of the B&W reactor design 1 is not a condition for NRC authorization for restart of Rancho Seco, although ,
the study is expected to be completed in advance of plant restart. Rather, the !
restart is dependent on the satisfactory resolution of the design and i progranrnatic deficiencies identified in the NRC staff and the Sacramento l Municipal Utility District (SMUD) assessments of the December 26, 1985 l overcooling event, and on the completion of SMUD's comprehensive corrective l action program. l Question A-2 When is that study scheduled to be complete? Is it on schedule?
Response l i
The NRC anticipates receiving the completed B&W Owners Group reassessment of j '
the B&W reactor design in July 1987. More is involved, however, in completing ;
I the study than that report. In late summer or early fall of 1987, the NRC is scheduled to issue an initial _ safety evaluation report (SER) on the B&W Owners
, Group reassessment, and will continue to issue SER supplements as appropriate. '
The NRC staff had originally planned to have the study finished by the end of 1986, but changed its schedule because the scope of the program was expanded and the B&W Owners Group had to respond to additional NRC concerns. The expanded study is en schedule.
Questions A-3 and A-4 Is there information in the partially done study that should be, or could be, required of Rancho Seco now, before it attempts to restart? Is that being .
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done?
Response
The B&W Owners Group effort has generated more than 170 recommendations since January 1986, and these recommendations have been sent to all B&W plants as well as to SMUD as they were developed. However, none of these recommendations have been identified as a requirement for the Rancho Seco restart. Although not required for restart, SMUD has already implemented some of them.
2 Question A-5 Are there t'udget restrictions delaying that study in any way? How?
Response ,
l There are no budget restrictions which are delaying the specific reassessment I study. Although the scope of the program was expanded causing a change in the completion date, the B&W Owners Group has supported the expanded program and has stated that it has spent more than $3 million on the reassessment effort.
The NRC staff is committed to provide the necessary resources to complete the I review in a timely manner.
With regard to a related effort concerning R&W plants, i.e., the use of the ;
Multi Loop Integral Systems Test (MIST) fat.flity to assess the capability of computer codes to accurately predict complex transients in B&W plants, i sufficient funding was not available last year to upgrade the MIST facility for that purpose. However, the NRC staff was able to revise the planned program so ,
that testing currently being conducted, and a follow-on program to be conducted, in the existing MIST facility will provide the needed data. The current program is being funded by both the NRC and industry. While we are pursuing the followron program assuming only government funding, we are still seeking industry su;irort for that effort.
Question A-6 Has the agency considered the impact of Rancho Seco restarting then having to shut down sooner than planned for modifications from that study?
-. Response SMUD is getting the recommendations from the reassessment as they are !
generated. Because none of the more than 170 recommendations generated to date would warrant shutting down any of the B&W reacter plants, the NRC staff considers it very unlikely that, once restarted, Rancho Seco would have to be shut down for other modifications. Should serious problems arise that would warrant such action, the NRC would shut down Rancho Seco.
B. NRC Budget and Workload Question B-1 In the past three years,:how much has your budget been cut?
Response ,
The following table shown how the NRC's funding budget requests have been acted on for FY 1985-1987.
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NRC Budget History (Dollars in Thousands)
Budget Request Budget Request Congressional i to OMB to Congress Appropriation l FY 1985 $496,400 $468,200 $448,200M FY 1986 $529,800 $429,000 $413,338Y FY 1987 $478,000 $405,000 $401.000Y 1/ The appropriation amounts for FY 1985 and FY 1987 do not dnelude unobligated funds carried over from the previous fiscal yeur.
-2/ This amount includes the net effect of a congressional reduction of $11.0 million, a reduction of $18.0 million due to the Gramm-Rudman- Hollings !
Act, and $13.3 million of unobligated funds carried over from the previous j
fiscal year.
Question B-2 l
l What percent of your workload is behind schedule due to lack of funds?
Response
Whenever the NRC receives less resources than it requested (as a result of the budget review and appropriation process), the agency allocates the available resources to its programs to minimize the impact on time-critical, high" priority work. The schedules for the remaining, less-time-critical, lower priority work are then adjusted to reflect available resources. These new schedules for agency work are not expected to result in significant impacts on the public health and safety or the environment. For example, in FY 1987 the programs affected as a result of reduced funding can be generally characterized i
as forward-looking efforts, intended to meet future issues and challenges; those programs essential for the NRC to ensure that the public health and i
safety and the environment are adequately protected vere not reduced below the levels required to fulfill this responsibility.
l Thus, it would not be meaningful to try to assign a percentage to any delay in agency work as a result of budget reductions.
Question B-3 How many employees have you cut back or failed to get, relative to your declared need? As a %?
Response
The following table shows how the NRC's staffing budget requests have been acted on for FY 1985-1987. The differences between the requests to OMB and congressional allocations range from 4% to 6%.
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NRC Staff History (Staff in Full-Time Equivalent)
Budget Budget .
Request Request to . Congressional to OMB Congress Allocation FY 1985 3,641 3,491 3,491 FY 1986 3,731 3,491 3,491 FY.1987 3,491 3,369 3,369 Question B-4 In these next few years what are actual projected budget cuts you are prepar-ing to accommodate? How?
Response
The following table shows the NP.C's budget request for FY 1988.
FY 1988 Budget Request (Dollars in Thousands; Staff in Full-Time Equivalent)
Budget Request Budget Request to 0MB to Congress
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$427,800 3,250 $427,800 3,250 The NRC submitted its FY 1988 budget request of $427,800,000 to the Congress in January 1987. Several congressional committee hearings have.been held on this request, and NRC anticipates a few more will be held. The House of l Representatives passed the Energy and Water Development Appropriations Bill in late June which contained appropriations for the NRC in the amount of
$417,800,000. As of July 1,1987, the Energy and Water Development Subcommittee of the Senate Appropriations Committee has not marked up or !
reported out a bill. The House and Senate Authorization Committees have i reported out bills to authorize appropriations for the NRC in the amount of
$427,800,000.
Question B-5 If so, how has your budget affected your inspection, analysis and er.forcement of recommendations and modifications on the Rancho Seco Nuclear Plant in the past four years relative to your performance admissions in the followup report to the December 26, 1985 incident that has shut down the plant ever since?
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Response
l The level of funding for the NRC over the last several years has been ,
sufficient to enable the agency to provide the programs appropriate to the I l regulatory oversight of the nation's commercial nuclear power reactors. At l Rancho Seco, the NRC has increased regional inspections, management meetings, i and enforcement meetings; civil penalties have been issued; and NRC management !
has increased its contact with Rancho Seco management. The agency has been i able to provide the regulatory programs desired at Rancho Seco and has not been constrained from implementing these initiatives for lack of adequate funding.
l l Question B-6 Please explain in detail what you meant by your comments about your own agency performance in the February 1986 IIT report about the December 26, 1985 !
incident at Rancho Seco? What caused those failures? Who and/or what was responsible? And what system-wide changes have you made since then to correct for those weaknesses?
Response
The staff's Incident Investigation Team (IIT) documented its findings and con-clusions about the December 1985 overcooling incident in a report entitled
" Loss of Integrated Control System Power and Overcooling Transient at Rancho l Seco on December 26, 1985," NUREG-1195, issued February 1986. The IIT i concluded that the fundamental causes for the incident were design weaknesses !
and vulnerabilities in the integrated control system and in the equipment controlled by that system. Further, the IIT stated that SMUD and the NRC staff knew about these problems and could have prevented the incioent. Although the I NRC staff did a good job of analyzing the precursor events to the December 1985 !
overcooling incident and in developing appropriate recommendations for j corrective action, it did not do an adequate job of following up on its recommendations. Thus, the management systems in place at the time of the Rancho Seco overcooling incident were not adequate to properly track the i resolution of identified concerns to ensure the implementation of responsible ;
corrective action. In response to this deficiency, in April 1986, the NRC '
staff placed in operation an automated management system, called the Safety :
Issues Management System, to manage and track identified safety issues for all power reactor plants. (It should be noted that the NRC staff identified the need for this management system several years ago and its development was i initiatedinSeptember1984.) That management system is designed to track an ;
issue from the time it is identified, through its study and technical resolution, through the stage in which requirements are imposed on licensees, j throughout the implementation of the requirements by the licensees, and to the l eventual verification by NRC, as necessary, that the prescribed cction was taken. With this management system in place, the NRC staff will be able to do a significantly better job in tracking the corrective actions licensees take in response to identified issues so that events like the Rancho Seco over-cooling incident can be prevented.
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C. Radioactive Wste Disposal Question C-1 1s your disposal program on schedule? Sites? Money? ~ Technology? 1 Response ,
1 The U.S. Department of Energy (DOE) is responsible for selecting a site and developing a repository for disposing of high-level radioactive waste (HLW),
including spent nuclear fuel from commercial nuclear power plants. DOE has recently submitted to Congress a draft amendment to its Mission Plan that would extend the date by which an HLW repository would be in operation from 1998 to the year 2003. In May 1986, DOE recommended to the President, and the President approved, three sites for further detailed study to determine'their suitability for development as an HLW repository. DOE is scheduled to publish its detailed study plans, called " Site Characterization Plans," later this year.
DOE collects a fee from nuclear utilities and others possessing HLW. These fees are held in a Nuclear Weste Fund, which is uted to offset the costs of DOE's HLW program. DOE is required to perform an annual assessment of the adequacy of the fees to cover the costc of its program; to date, it has found that the fees are adequate. j i
Finally, after considering alternative technologies for disposing of HLW, DOE selected deep geologic disposal as the appropriate one. NRC has issued regulations applicable to deep geologic disposal of HLW which must be met by l DOE, and which will provide reasonable assurance that applicable U.S. Environ- l mental Protection Agency general environmental radiation standards will be met. !
1 Question C-2 )
i If the Federal Government hasn't removed the waste they agreed to dispose of by i their commitment date in the 1990's, are you scheduled to take over the total economic responsibility and burden of babysitting it regardless of whether it I has been moved or not? l
Response
DOE has signed a contract with SMUD, which operates the Rancho Seco Station, to 'l accept title to the spent nuclear fuel, to transport the spent fuel from the site, and to dispose of the spent nuclear fuel. The contract provides that these services are to begin no later than January 31, 1998. DOE's waste acceptance strategy proposed in its draft Mission Plan Amendment would still provide for waste acceptance by 1998. >
D. Licensing and Relicensing Question D-1 What is the likelihood of the Rancho Seco plant being relicensed in 2009, when considering the embrittlement problems they have experienced?
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Response j i
We assume that the embrittlement problems mentioned refer to the overcooling !
transients of December 26, 1985 and March 20, 1978 at Rancho Seco. It should I be noted that the staff's evaluation of those two transients showed that they ]
did not affect the structural integrity of the rector vessel or any other j plant component. !
With regard to the relicensing of Rancho Seco considering reactor vessel embrit-tlement, such a request would require the staff to perform a comprehensive review of all issues concerning the embrittlement or change in fracture tough-ness of the reactor vessel and other components over the requested license extension period. The only component that is subject to a i change in original fracture toughness, because of radiation embrittlement, is I the reactor vessel which contains the nuclear reactor core. Changes in material fracture tough-ness are monitored by an ongoing material surveillance program that, by design, will demonstrate the effects of continued future operation through accelerated radiation effects on the surveillance specimen material fracture toughness. Therefore, at this time, we cannot predict the likelihood of relicensing Rancho Seco in 2009. Whether the licensee will request an extension to the operating license most likely will be based on economic factors, such as plant capacity, availability, and operating costs as well as the integrity of components and systems.
Question D-2 l Estimate as well as you can what percent of value of that plant would need to be revamped, or rebuilt for relicensing? (Forexample % of the cost to rebuild today). Keep in mind the radioactive contamination.
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Response
As stated above (response to D-1), any decisions to relicense Rancho Seco likely will be based on economic factors such as plant availability and operating costs, recognizing that such costs increase during the lifetime of the plant while plant availability generally decreases. As such, this decision-making process is similar in principle to other business-related decisions such as keeping operational an aging steel plant or an electricity-generating coal plant. The levels of radioactive contamination in plant I systems and components likely will not be a significant factor in any relicensing decisions for several reasons. First, radioactively contaminated components and parts in the plant systems are replaced, as needed, during the plant operating life and disposed of as low level waste. As such, this contamination ceases to be an operational problem. Secondly, all operating reactor plants have established programs in place for minimizing occupational radiation exposure. As plant components and parts become radioactive, they are decontaminated (e.g., chemically) and/or shielded (e.g., lead curtain), as necessary, to minimize exposure. Recent trends at operating plants indicate that, in general, occupational exposure has been decreasing over the years, lending credence to the effectiveness of plant health physics programs. Thus,
radioactive contamination likely will not be a significant factor in any decisions related to relicensing Rancho Seco. ;
Regarding estimates and costs of the parts of the plant that might have to be refurbished or replaced for relicensing, the NRC staff has no data or experience from which an estimate might be made, inasmuch as no licensed facility has, as yet, been relicensed. The staff can only speculate about those costs. The costs could range from essentially nothing (if no refurbish- I I
ment is required at the time of relicensing) to very significant amounts (several hundred million dollars or more if a major plant overhaul is deemed necessary). It is our understanding, for example, that the present overhaul of Rancho Seco will cost roughly $200 million and other licensed facilities have undergone similar overhauls at corresponding costs. Recognize that inflation alone in the value of the dollar is a factor that will have a significant bearing on the total projected cost of any plant refurbishment and this is a difficult figure to project meaningfully to the year 2008.
Question D-3 Do you have specific guidelines for relicensing a B&W plant established yet?
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Response
Although the Commission's regulations provide the authority for renewing an operating license when the existing license expires (10 CFR 50.51), the NRC staff does not have specific guidelines for granting license renewals for licensed commercial nuclear power plants, including B&W plants. However, the NRC has a program underway for developing such guidelines. The Commission is planning to issue a proposed Policy Statement on license renewal for public comment. Taking the comments received into consideration, the Commission will issue a final Policy Statement on license renewal. Further, over the next several years, the Commission plans to issue proposed regulations for granting license renewals and, thereafter, final regulations that will reflect public comments on the proposed rules. After the final regulations on license renewal have been issued, the NRC staff plans to produce related regulatory guides and standard review plans.
Question D-4 ,
Have or are you considering shortening the license term of Rancho Seco because of the embrittlement accidents that have already happened? What is your reasoning about this? j 1
Response !
Again, we assume that the " embrittlement accidents that have already happened" refer to the overcooling transients of December 26, 1985 and March 20, 1978, 3 during which the pressure and temperature of the coolant within the Rancho Seco l reactor vessel entered what is conservatively designated as the " pressurized l thermal shock" (PTS) region. It has been determined that the transients to date during which the PTS region was entered have not affected the structural i
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-g-integrity nf the reactor vessel or any other plant component. Therefore, we have no reason to shorten the license term of Rancho Seco as a result of those transients.
Question D_5 Has SMUD discussed with you, or asked for, a license extension now, or before 2009, because of their restart and rehab work now? Is there any likelihood of this?
Response
I SMUD has neither asked for nor initiated any discussions to date related to an extension of its operating license for Rancho Seco. Inasmuch as the Commission regulations (10 CFR 50.51) permit the granting of extensions to such licenses, SMUD could request a license extension at some future time.
Question D-6 According to code, are you allowed to grant extensions to the existing license?
Response
The Commission's regulations (10 CFR 50.51) state that each license will be issued for a fixed period of time to be specified in the license but in no case to exceed 40 years from the date of issuance. Some operating licenses were issued for 40-year terms commencing with the is:.uance of the construction permits for these facilities. Depending on the time required for construction, '
the licenses for these facilities provide for an effective operating license term less than 40 years. The Commission's regulations permit the granting of extensions to these licenses so that the full 40 years of operation intended by the rule (10 CFR 50.51) may be achieved.
E. Plant Decommissioning Question E-1 Based upon the knowledge gained from the 3M Nuclear Waste disposal fiasco and your most current data, what do you estimate the cost of decommissioning a nuclear plant to be? A B&W plant to be? As a % of new construction cost, what will it be roughly?
Response
The NRC had one of its principal contractors, Battelle Pacific Northwest Laboratories (PNL), develop an analysis of estimated costs of decommissioning various nuclear facilities, including pressurized water reactors (PWRs). This was done on a generic basis, based on an engineering evaluation of activities involved in decommissioning. In doing these analyses, PNL considered plant design, estimated conditions in the plant at the time of shutdown, proven decontamination and dismantling methods, and radiation protection requirements
for workers and the public. The analyses included principal cost factors such as labor necessary to complete the work and the cost of waste disposal. Based on these considerations, the PNL analyses estimated the cost of decommissioning to be approximately $100 million for a PWR in current dollars. This cost does not include the cost of demolition and removal of the nonradioactive nortions of the plant or restoration of the site. The cost of decommissioning a B&W plant is estimated to be approximately the same as that for the PWR plant i indicated above. The studies done by PNL have not identified a specific l relationship between construction costs and decommissioning costs. This is because many of the principal factors that enter into the two costs are unrelated.
Question E-2 Does decommissioning include removing ALL high level radioactive contaminated structural members?
Response
On February 11, 1985, the NRC issued a proposed rule containing decommissioning criteria for nuclear facilities. In that document, decommissioning is defined as removing a facility safely from service and reducing residual radioactivity to a level that permits release of the property for unrestricted use and termi- j nation of license. Based on that definition, decommissioning would include removal of all radioactive material exceeding residual levels considered acceptable for releasing the property for unrestricted use and for terminating j the plant license. i Question E-3 What does decommissioning include? What does it not include that has a major
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fiscal impact on the plant's owners? Does that include dismantling of the containment areas? Does that require SMUD maintaining nuclear waste storage?
Response
Decommissioning includes removing components, materials, and structures having '
radioactive contamination exceeding residual radioactivity levels considered acceptable for releasing the property for unrestricted use and for terminating the NRC license. This includes dismantling radioactively contami-nated components, systems, and structures in the containment area. The decommissioning would be divided into four major activities: planning and preparation; decontamination and dismantling of systems, components, and structures; disposal of radioactive material; and the final radiation survey and termination of license.
Decommissioning does not include removing nonradioactive structures and materials; to remove these could cost plant owners more than $20 million for a typical large reactor, i
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i If a plant is decommissioned by what is commonly referred to as "immediate dismantlement," all radioactivity above acceptable residual levels is removed within a few years after the plant has permanently ceased operations and the license is terminated. In this situation, SMUD would not maintain nuclear waste storage. If disposal capacity for nuclear wastes removed from the plant during decommissioning is unavailable, there are provisions in the proposed regulation (which is referred to in response to E-2) to allow for delay in completing decommissioning; this would permit nuclear wastes to be stored on site temporarily. Once the wastes had been removed and the plant had been cleaned up, a radiation survey showing radioactivity levels in the plant to be below acceptable residual levels would permit the plant license to be terminated.
Question E-4 How did you decide upon the amount required to be set aside by SMUD for ,
decommissioning? Or did yau? Did you issue guidelines for this? What are !
those criteria and how long ago were they revised? Since the 3M experience? ;
Response <
Currently there are no specific requirements in the NRC regulations that a utility set aside funds for decommissioning. The proposed rule referred to in 4 the response to E-2 contains requirements that, early in plant life, licensees ;
establish funding provisions to provide reasonable assurance that funds are ,
available for decommissioning. According to these proposed require-ments, a utility would have to determine a level _ of funding for decommissioning and establish a method to set aside the appropriate funds. The proposed rule also !
contains requirements for periodically. adjusting the funding level, including a
- specific requirement that a cost estimate and plans for adjusting funding levels, if necessary, be submitted to NRC five years before the end of operations based on a then current assessment of major factors that could '
affect decommissioning costs. In addition, the proposed rule contains requirements that a licensee's decommissioning plan contain an updated decom- .
missioning cost estimate and a plan for ensuring that funds will be available !
to complete decommissioning. This step-wise approach to decommissioning !
funding over facility life will provide reasonable assurance that the Comission's objective is met; namely, that at the time of decommissioning .
sufficient funds are available to decommission the facility in a manner that protects public health and safety. The level of funds necessary and the !
funding methods allowed are based on an extensive data base, developed by PNL (referred to in response to E-1 above) and by other NRC contractors, which has been revised recently to take into account current information pertinent to decommissioning.
It is expected that the proposed rule on decommissioning will be issued as an effective rule in the last quarter of 1987. ,
l Question E-5 Do you have decommissioning guidelines, fiscal and physical, for B&W plants specifically?
Res por.se Specific decommissioning requirements for B&W plants are not considered necessary because existing requirements on decommissioning and those being proposed are considered broad enough to be applicable to all plants, including those manufactured by B&W.
Question E-6 If not a requirement of the NRC, what do you recommend that SMUD be setting aside as a realistic decommissioning fund to fully pay for decommissioning by the year 2009? Is that consistent with today's costs in construction and related industries?
Response
As noted in response to earlier comments, although there are no current NRC I
regulations on decommissioning funding, proposed rules that are expected to be issued later in 1987 will contain requirements on setting aside funds for decommissioning. The specific amount necessary for SMUD to set aside is not contained in the proposed rule, although as indicated in the response to E-1, our contractor PNL has indicated that, for a generic plant that is similar to the SMUD plant, decommissioning is estimated to cost approximately $100 million in current dollars. As noted earlier, this amount does not include costs of demolishing nonradioactive components and structures or costs of restoring the site. With the updating provisions of the rule, discussed in response tc E-4,
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the amount of funds available in 2009 will of course be greater than $100 million. As discussed in the response to E-1, the estimate is based on factors considered important in decommissioning nuclear reactors and has been revised
! to account for recent information.
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L ,
l The Honorable Alan Cranston
' United States Senate Washington, DC 20510
Dear Senator Cranston:
On May 1,1987 you sent us 'a letter in which you forwarded a number of
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questions related to the Rancho Se'o c Nuclear Generating Station. The questions had been sent to you by one of your\ constituents, Ms. Elaine Southard, on
\
March 12, 1987 and they asked about th eneral subject areas of the Babcock &
Wilcox plant reassessment, Nuclear Regulatory Commission budget and workload,
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radioactive waste disposal, plant licensing'and relicensing, and plant decommissioning. Using the question and' answer format, we have responded to each of your constituent's concerns.
Sincerely, I
l Victor Stello, ExecutiveDirectb. :
for Operations i
Enclosure:
As stated DISTRIBUTION Docket File G. M. Holahan NRC/L PDR OGC-Bethesda
.ED0 # GPA/CA(3) -
1 ED0 Reading SECY .
T. Murley/J. Sniezek V. Stello F. Miraglia D. Mossburg, PMAS (ED0#002846)w/ incoming i PD5 Reading . P. Shea' '
D. M. Crutchfield R. Weller !
J. Lee C. Cheng ,
J. Richardson L. Shao 4 ,
R. Starostecki M. Bell /C. Serpan '(
P. Rabideau v i '
- SEE PREVIOUS CONCURRENCES
- DRSP/PDV *NRR/EMTB *DRSP/D:PDV *DRSP/AD *DRSP/D *ADP NRR ;
RWeller/EAL CCheng GWKnighton GMHolahan DMCrutchfield FMiraglia JRichardson !'
6/10/87 6/9/87 6/10/87 6/10/87 6/11/87 6/16/87 6/9/8A
- NRR NRR *NMSS/HLWM *RES/MEB
- ARM /DBA DDONRR DONRA LShao RStarostecki MBell CSerpan PRabideau JSniezek TMurley ,
6/9/87 6/15/87 6/9/87 6/9/87 6/9/87 6/ /87- 6/ /87 ED0 *0GC-Beth
- ARM /PPMB \ l VStello EReis
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6/ /87 6/9/87 6/18/87 i
l The Honorable Alan Cranston United States Senate -l
. Washington, DC 20510- l
Dear Senator Cranston:
On May 1,1987 you sent us a letter in which you forwarded a number of.
questions related to.the Rancho Seco Nuclear Generating Station. The questions j had been sent to you'by one of your constituents, Ms. Elaine Sou ard, on .
March 12, 1987 and they asked about the-general subject areas f the Babcock &
i Wilcox plant reass sment, Nuclear Regulatory Commission b get and workload, I
-)
radioactive waste disp al, plant licensing and relicen ng, and plant
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i decommissioning. Using t question and answer fo.. t, we have responded to each of your constituent's c cerns.
Since ly, l
l l
Victor Stello, Jr. 1 Executive Director i for Operations
Enclosure:
As stated DISTRIBUTION i Docket File G.- . Holahan !
NRC/L PDR 0 .-Bethesda !
ED0 # A/CA (3) 1 EDO Reading SECY j T. Furley/J. Sniezek V. Stello )
F. Miraglia D. Mossburg, PMAS (ED0#002846)w coming l' PD5 Reading P. Shea D. M. Crutchfield R. Weller !
J. Lee C. Cheng ;
J. Richardson L. Shao i R. Starostecki M. Bell /C. Serpan '
P. Rabideau r
.l
- SEE PREVIOUS CONCURRENCES O~Q- l l
- DRSP/PDV *NRR/EMTB *DRSP/D:PDV *DRSP/AD *DRSP/D *ADP - *NRR .
RWeller/EAL CCheng GWVnighton GMHolahan DMCrutchfield- FMiraglia JRichardson' 6/10/87 6/9/87 6/10/87 6/10/87 6/11/87. 6/16/87 '6/9/87-
- NRR *NRR- *NMSS/HLWM *RES/MEB
- ARM /DBA DDONRR DONRR LShao 'RStarostecki MBell CSerpan PRabideau JSniezek TMurley 6/9/87 6/15/87 6/9/87 6/9/87 6/9/87 6/ /87 6/ /87 ;
E00 *0GC-Beth ARM /PPBM VStello EReis hh 6/ /87 6/9/87 6/f/87* Telephone concurrence to E. A. Licitra ;
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The Honorable Alan Cranston United States Senate Washington, DC 20510 '
Dear Senator Cranston:
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On May 1,198'7 you sent us a letter in which you orwarded a number of
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questions related to the Rancho Seco Nuclear Gener ting Station. The questions had been sent to you by 'one of your constituen , Ms. Elaine Southard, on l March 12, 1987 and they asked bout the gen al subject areas of the Babcock &
Wilcox plant reassessment, Nucl' ear Regul ory Commission budget and workload, N
l radioactive waste disposal, plant lic sing and relicensing, and plant decommissioning. Using the questip a answer format, we have responded to each of your constituent's conc rns. N
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Sincerely, Victor ExecutiveStello, DirectorJr. \ '
for Operations
Enclosure:
As stated DISTRIBUTION Docket File G. M. Holahan NRC/L PDR OGC-Bethesda EDO # GPA/CA (3)
E00 Reading SECY T. Murley/J. Sniezek V. Stello F. Miraglia D. Mossburg, PMAS (ED0# )w/ incoming PD5 Reading P. Shea D. M. Crutchfield R. Weller J. Lee C. Cheng J. Richardson L. Shao R. Starostecki M. Bell /C. Serpan P. Rabideau
- SEE PREVIOUS CONCURRENCES
- DRSP/PDV *NRR/EMTB *DRSP/D:PDV *DRSP/AD *DRSP/D $ *NRR RWeller/EAL CCheng GWKnighton GMHolahan DMCrutchfield F. lia JRichardson 6/10/87 6/9/87 6/10/87 6/10/87 6/11/87 6/, /87 6/9/87
- NRR *NRR *NMSS/HLWM *RES/MEB
- ARM /DBA DD NRR DONRR LShao RStarostecki MBell CSerpan PRabideau JSniezek TMurley 6/9/87 6/15/87 6/9/87 6/9/87 6/9/87 6/ /87 6/ /87 EDO *0GC-Beth VStello EReis 6/ /87 6/9/87
- Telephone concurrence to E. A. Licitra
. I J
The Honorable Alan Cranston i United States Senate Washington, DC 20510
Dear' Senator Cranston:
On May 1, 1987 you ent us a letter in which you.foivarded a number of questions related to the ancho Seco Nuclear Generating Station. The questions l had been sent to you by on of your constituents, Ms'. Elaine Southard, on I March 12, 1987 and they aske about the general su'bject areas of the Babcock &
Wilcox plant reassessment, Nu lear Regulatory Commission budget and workload, l radioactive waste disposal, pl nt licensing and relicensing, and plant decommissioning. Usingthequetionandanskerformat,wehaverespondedto each of your constituent's concer s. /'
/
/ )
! incsrely, )
/
/ \
Vi tor Stello, Jr.
Exe'utive Director
./ f r Operations l
Enclosure:
/
/
l As stated
! DISTRIBUTION f
/
Docket File G. M.eHolahan NRC/L PDR OGC-Bethesda l ED0 # GPA/CA(3)
ED0 Reading SECY T. Murley/J. Sniezek V./ Stello F. Miraglia D! Mossburg, PMAS ED0# )w/ incoming PD5 Reading P. Shea D. M. Crutchfield R. Weller J. Lee ;C. Cheng J. Richardson L. Shao R. Starostecki M. Bell /C. Ser P. Rabideau- \Y.
DR / DV *NRR/EMTB D ,
V -
ADP *NRR & b hRWeller CCheng G n GMHolahan 0 field FMiraglia JRichardson/g, a 6//v/87' 6 6//d /87 6//O/87 6/ /87 6/ /87 6/9/87 r
- NRR NRR .
- NMSS/HLWM *RES/MEB
- ARM /DBA DDONRR DONRR LShao RSt tecki MBell CSerpan PRabideau JSniezek TMurley 6/9/87 6/l 87 6/9/87 6/9/87M 6/9/87 6/ /87- :6/ /87 ED0 *0GC-Beth VStello EReis e Q 6/ /87 6/9/87 -
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- Telephone concurrence to E. A. Licitra a_ - _ _ - _ - _ _ _ _ _ _ _ _ - _ - . ._ - ---_ -_ - _--_-_-__-__-_2
RESPONSE TO QUESTIONS RELATED TO RANCHO SEC0 NUCLEAR GENERATING STATION A. B&W Reactor Plant Design Reassessment Study Question A-1 Are you planning to allow Rancho Seco to restart before that study and its !
recommendations are complete?
) O 4I pg,e fyg e/y/f m 14 u.?sc muk/C Response 46 ,7 , a ip p The completion of the B&W Owners Group reassessment of the B&W reac.or design j is not a condition for NRC authorization for restart of Rancho Sec Rather, I the restart 'is dependent on the satisfactory resolution of the des n and programmatic deficiencies identified in the NRC staff and the Sacramento Municipal Utility District (SMUD) assessments of the December 26, 1985 overcooling event', nd on the completion of SMUD's comprehensive corrective action program.
\ i Question A-2 '\
When is that study sched'uled to be complete? Is it on schedule?
Response I" h M-Re cnd of June 1987- t ' hen NRC anticipates Mydng ' the completed B&W v Owners Group reassessment of thex B&W reactor design ore is involved, however, &
in completing the study than thatireport. In late summer or early fall of 1987, the NRC is scheduled to issue an i'nitial safety evaluation report (SER) on the B&W Owners Group reassessment, and Will continue to issue SER supplements as appropriate. The NRC staff had originally planned to have the study finished by the end of 1986, but changed its schedule because the scope of the program was expanded and the B&W Owners Group ha'd,to respond to additional NRC concerns.
The expandec' study is on schedule. N
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Questions A-3 and A-4 \
Is there information in the partially done stu y that should be, or could be, required of Rancho Seco now, before it attempts 'to restart? Is that being done?
Response
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The B&W Owners Group effort has generated more than 170 xrecommendations since .
January 1986, and these recommendations have been sent to all B&W plants as !
well as to SMUD as they were developed. However, none of'these recommendations have been identified as a requirement for the Rancho Seco restart. Although not required for restart, SMUD has already implemented some of them.
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i RESPONSE T0 QUESTIONS RELATED T0 RANCHO SECO NUCLEAR GENERATING STATION A. B&W Reactor Plant Design Reassessment Study s ,
Question A-1 '
s Are you planning to allow Rancho Seco to restart before + hat study and its recommendations are complete?
Response
The completion of the B&W Owners Group reassessment of the B&W reactor design is not a condition for NRC authorization for restart of Rancho Seco, although the study is expected to be completed in advance of plant restart. Rather, the restart is dependent on the satisfactory resolution of the design and programmatic deficiencies identified in the NRC staff and the Sacramento Municipal Utility District (SMdD) assessments of the December 26, 1985 overcooling event, and on the comp.letion of SMUD's comprehensive corrective action program.
Question A-2 When is that study scheduled to be complete? Is it on schedule?
Response
The NRC anticipates receiving the completed B&W Owners Group reassessment of the B&W reactor design in July 1987. More isiinvolved, however, in completing the study thcn that report. In late summer or'early fall of 1987, the NRC is scheduled to issue an initial safety evaluation' report (SER) on the B&W Owners Group reassessment, and will continue to issue SER supplements as appropriate.
The NRC staff had originally planned to have the s'tudy finished by the end of 1986, but changed its schedule because the scope of1the program was expanded and the B&W Owners Group had to respond to additional,NRC concerns. The expanded study is on schedule. j Questions A-3 and A-4 Is there information in the partially done study that shobl.d be, or could be, required of Rancho Seco now, before it attempts to restart? Is that being done?
Response
The B&W Owners Group effort has generated more than 170 recommendations since January 1986, and these recommendations have been sent to all B&W plants as well as to SMUD as they were developed. However, none of these recommendations have been identified as a requirement for the Rancho Seco restart. Although not required for restart, SMUD has already implemented some of them. !
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l Question A-5 Are there budget restrictions delaying that study in any way? How?
Response
There are no budget restrictions which are delaying the specific reassessment study. Although the scope of the program was expanded causing a change in the completion date, the B&W Owners Group has supported the expanded program and has stated that it has spent more than $3 million on the reassessment effort.
l The NRC staff is committed to provide the necessary resources to complete the review in a timely manner.
With regard to a related effort concerning B&W plants, i.e., the use of the f Multi Loop Integral Systems Test (MIST) facility to assess the capability of l computer codes to accurately predict complex transients in B&W plants, l sufficient funding was not available last year to upgrade the MIST facility for that purpose. However, the NRC staff was able to revise the planned program so that testing currently being conducted, and a follow-on program to be conducted, in the existing MIST facility will provide the needed data. The I current program is being funded by both the NRC and industry. While we are I pursuing the follow-on program assuming only government funding, we are still {
seeking industry support for that effort.
l Question A-6 l
l Has the agency considered the impact of Rancho Seco restarting then having to shut down sooner than planned for modifications from that study?
l l Response SMUD is getting the recommendations from the reassessment as they are generated. 1 Because none of the more than 170 recommendations generated to date would I l warrant shutting down any of the B&W reactor plants, the NRC staff considers it very unlikely that, once restarted, Rancho Seco would have to be shut down for other modifications. Should serious problems arise that would warrant such action, the NRC would shut down Rancho Seco.
B. NRC Budget and Workload )
Question B-1 9
In the past three years, how much has your budget been cut?
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Response
The following table shows how the NRC's funding budget requests have been acted on for FY 1985-1987.
NRC Budget History (Dollars in Thousands)
Budget Request Budget Request Congressional to OMB to Congress Appropriation FY 1935 $496,400 $468,200 $448,2001/
FY 1986 $529,800 $429,000 $413,338 2/
FY 1987 $478,000 $405,000 $401,0001/
-1/ The appropriation amounts for FY 1985 and FY 1987 do not include unobligated funds carried over from the previous fiscal year.
-2/ This amount includes the net effect of a congressional reduction of
$11.0 million, a reduction of $18.0 million due to the Gramm-Rudman-Hollings Act, and $13.3 million of unobligated funds carried over from the previous fiscal year.
Question B-2 What percent of your workload is behind schedule due to lack of funds?
Response
Whenever the NRC receives less resources than it requested (as a result of the l budget review and appropriation process), the agency allocates the available resources to its programs to minimize the impact on time-critical, high-priority work. The schedules for the remaining, less-time-critical, lower priority work are then adjusted to reflect available resources. These new schedules for agency work are not expected to result in significant impacts on the public health and safety or the environment. For example, in FY 1987 the programs affected as a result of reduced funding can be generally characterized as forward-looking efforts, intended to meet future issues and challenges; those programs essential for the NRC to ensure that the public health and safety and the environment are adequately protected were not reduced below the levels required to fulfill this responsibility.
Thus, it would not be meaningful to try to assign a percentage to any delay in agency work as a result of budget reductions.
1 Ouestion B-3 How many employees have you cut back or failed to get, relative to your declared need? As a %?
Response j
! The following table shows how the NRC's staffing budget requests have been I acted on for FY 1985-1987. The differences between the requests to OMB and j congressional allocations range from 4% to 6%.
NRC Staff History (Staff in Full-Time Equivalent) J Budget Budget Request Request to Congressional to 0MB Congress Allocation FY 1985 3,641 3,491 3,491 FY 1986 3,731 3,491 3,491 FY 1987 3,491 3,369 3,369 i 3
Ouestion B-4 In these next few years what are actual projected budget cuts you are prepar-ing to accommodate? How?
Response
The following table shows the NRC's budget request for FY 1988.
l FY 1988 Budget Request (Dollars in Thousands; Staff in Full-Time Equivalent)
Budget Request Budget Request I to 0MB to Congress i $ FTE $ FTE
$427,800 3,250 $427,800 3,250 The NRC submitted its FY 1988 budget request of $427,800,000 to the Congress in January 1987. Several congressional committee hearings have been held on this request, and NRC anticipates a few more will be held. ^: ef June 10, ^ ^ i 1221r 1 kn;te Sbccmittea of_Nycle g h gg h tign 7ppggtgj ggt ; bj)) tg h 3 b
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ns
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amm m,
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p A 9 2.0. L tk M 4 $4K1@p/W.
authorize appr ations for the NRC S-1128) in the amount f $427,800,0 i 1 in FY 1988; d th House of Repre nta ives Committee o nte for and I su' ar Af" airs and he Co ittee.on Ene y and ommerce report d out a bill to ,!
au'hnrize ppropria ions for th NRC (H.R 1315) in t amount )f $427, 00, 00 in FY 198 . As of J ne 10,19 7, no appro riations mmittee reports ave becn iss d. Althoug we ca ot predict th final ongressiona' acti on:
NRC s F 1988 budget r ue , we hope that C r will enact 1 gis tion that w 11-provide NRC wi its full budget request of $427,800,00 .
Question.B-5 If so, how has your budget affected your inspection, analysis and enforcement of recommendations and modifications on the Rancho Seco Nuclear Plant in the past four years relative to your performance admissions in the followup report !
to the December 26, 1985 incident that has shut down the plant ever since? '
Response
l The level of funding for the NRC over the last several years has been j sufficient to enable the agency to provide the programs appropriate to the i
regulatory oversight of the nation's commercial nuclear power reactors. At {
Rancho Seco, the NRC has increased regional inspections, management meetings, i and enforcement meetings; civil penalties have been issued; and NRC management ;
has increased its contact with Rancho Seco management. The agency has been i able to provide the regulatory programs desired at Rancho Seco and has not been constrained from implementing these initiatives for lack of adequate funding.
l Question B-6 Please explain in detail what yuu meant by your comments about your own agency performance in the February 1986 IIT report about the December 26, 1985 incident l at Rancho Seco? What caused those failures? Who and/or what was responsible?
l And what system-wide changes have you made since then to correct for those l weaknesses?
Response
The staff's Incident Investigation Team (IIT) documented its findings and con-clusions about the December 1985 overcooling incident in a report entitled
" Loss of Integrated Control System Power and Overcooling Transient at Rancho Seco on December 26, 1985," NUREG-1195, issued February 1986. The IIT concluded that the fundamental causes for the incident were design weaknesses and vulnerabilities in the integrated control system and in the equipment controlled by that system. Further, the IIT stated that SMUD and the NRC staff knew about these problems and could have prevented the incident.
Although the NRC staff did a good job of analyzing the precursor events to the December 1985 overcooling incident and in developing appropriate recommenda-tions for corrective action, it did not do an adequate job of following up on i
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its recommendations. Thus, the management systems in place at the time of the Rancho Seco overcooling incident were not adequate to properly track the resolution of identified concerns to ensure the implementation of responsible corrective action. In response to this deficiency, in April 1986, the NRC staff placed in operation an automated management system, called the Safety Issues Management System, to manage and track identified safety issues for all power reactor plants. (It should be noted that the NRC staff identified the j need for this management system several years ago and its development was J initiatedinSeptember1984.) That management system is designed to track an !
issue from the time it is identified, through its study and technical resolution, through the stage in which requirements are imposed on licensees, j throughout the implementation of the requirements by the licensees, and to the
. eventual verification by NRC, as necessary, that the prescribed action was I taken. With this management system in place, the NRC staff will be able to do a significantly better job in tracking the corrective actions licensees take in response to identified issues so that events like the Rancho Seco over-cooling incident can be prevented.
C. Radioactive Waste Disposal l Question C-1 l
Is your disposal program on schedule? Sites? Money? Technology?
Response
The U.S. Department of Energy (DOE) is responsible for selecting a site and developing a repository for disposing of high-level radioactive waste (HLW),
including spent nuclear fuel from commercial nuclear power plants. DOE has recently submitted to Congress a draft amendment to its Mission Plan that i would extend the date by which an HLW repository would be in operation from 1998 to the year 2003. In May 1986, DOE recommended to the President, and the President approved, three sites for further detailed study to determine their suitability for development as an HLW repository. DOE is scheduled to publish its detailed study plans, called " Site Characterization Plans," later this year.
DOE collects a fee from nuclear utilities and others possessing HLW. These fees are held in a Nuclear Waste Fund, which is used to offset the costs of DOE's HLW program. DOE is required to perform an annual assessment of the adequacy of the fees to cover the costs of its program; to date, it has found that the fees are adequate.
Finally, after considering alternative technologies for disposing of HLW, DOE selected deep geologic disposal as the appropriate one. NRC has issued regulations applicable to deep geologic disposal of HLW which must be met by DOE, und which will provide reasonable assurance that applicable U.S. Environ-mental Protection Agency general environmental radiation standards will be met.
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j Question C-2 If the Federal Government hasn't removed the waste they agreed to dispose of by their commitment date in the 1990's, are you scheduled to take over the total economic responsibility and burden of babysitting it regardless of whether it has been moved or not? I
Response
DOE has signed a contract with SMUD, which operates the Rancho Seco Station, to accept title to the spent nuclear fuel, to transport the spent fuel from the site, and to dispose of the spent nuclear fuel. The contract provides l that these services are to begin no later than January 31, 1998. DOE's waste ,
acceptance strategy proposed in its draft Mission Plan Amendment would still l provide for waste acceptance by 1993. j D. Licensing and Relicensing j Question D-1 What is the likelihood of the Rancho Seco plant being relicensed in 2009, when considering the embrittlement problems they have experienced?
Response
We assume that the embrittlement problems mentioned refer to the overcooling transients of December 26, 1985 and March 20, 1978 at Rancho Seco. It should be noted that the staff's evaluation of those two transients showed that they did not affect the structural integrity of the reactor vessel or any other plant component.
With regard to the relicensing of Rancho Seco considering reactor vessel embrit- i tiement, such a request would require the staff to perform a comprehensive l review of all issues concerning the embrittlement or change in fracture tough- i ress of the reactor vessel and other compcnents over the requested license extension period. The only component that is subject to a change in original fracture toughness, because of radiation embrittlement, is the reactor vessel which contains the nuclear reactor core. Changes in material fracture tough-ness are monitored by an ongoing material surveillance program that, by design, will demonstrate the effects of continued future operation through accelerated radiation effects on the surveillance specimen material fracture toughness.
Therefore, at this time, we cannot predict the likelihood of relicensing Rancho Seco in 2009. Whether the licensee will request an extension to the operating license most likely will be based on economic factors, such as plant capacity, availability, and operating costs as well as the integrity of components and systems.
Question D-2 Estimate as well as you can what percent of value of that plant would need to be revamped, or rebuilt for relicensing? (For example % of the cost to rebuild today). Keep in mind the radioactive contamination. '
Response
As stated above (response to D-1), any decisions to relicense Rancho Seco f likely will be based on economic factors such as plant availability and operating costs, recognizing that such costs increase during the lifetime {
i of the plant while plant availability generally decreases. As such, this H decision-making process is similar in principle to other business-related decisions such as keeping operational an aging steel plant or an electricity-x
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generating coal plant. The levels of radioactive contamination in plant systems and components likely will not be a significant factor in any relicensing decisions for several reasons. First, radioactively contaminated
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components and parts in the plant systems are replaced, as needed, durir,g the plant operating life and disposed of as low level waste. As such, this ,
contamination ceases to be an operational problem. Secondly, all operating '
reactor plants have established programs in place for minimizing occupational
) radiation exposure. As plant components and parts become radioactive, they are decontaminated (e.g., chemically) and/or shielded (e.g., lead curtain), as necessary, to minimize exposure. Recent trends at operating plants indicate that, in general, occupational exposure has been decreasing over the years, j lending credence to the effectiveness of plant health physics programs. Thus, radioactive contamination litely will not be a significant factor in any decisions related to relicensing Rancho Seco.
Regarding estimates and costs of the parts of the plant that might have to be refurbished or replaced for relicensing, the NRC staff has no data or experience from which an estimate might be made, inasmuch as no licensed facility has, as yet, been relicensed. The staff can only speculate about those costs. The costs could range from essentially nothing (if no refurbish- t ment is required at the time of relicensing) to very significant amounts j (several hundred million dollars or more if a major plant overhaul is deemed necessary). It is our understanding, for example, that the present overhaul of J Rancho Seco will cost roughly $200 million and other licensed facilities have undergone similar overhauls at corresponding costs. Recognize that inflation alone in the value of.the dollar is a factor that will have a significant bearing on the total projected cost of any plant refurbishment and this is a difficult figure to project meaningfully to the year 2008.
Question D-3 Do you have specific guidelines for relicensing a B&W plant established yet?
Response
Although the Commission's regulations provide the authority for renewing an i operating license when the existing license expires (10 CFR 50.51), the NRC staff does not have specific guidelines for granting license renewals for licensed commercial nuclear power plants, including B&W plants. However, the NRC has a program underway for developing such guidelines. <The Commission is planning to issue a proposed Policy Statement on license renewal for public comment. Taking the comments received into consideration, the Commission will' issue a final Policy Statement on license renewal. Further, over the next ,
several years, the Commission plans to issue proposed regulations for granting '
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l i l license renewals and, thereafter, final regulations that will reflect public comments on the proposed rules. After the final regulations on license renewal have been issued, the NRC staff plans to produce related regulatory guides and standard review plans.
Question D-4 Have or are you considering shortening the license term of Rancho Seco because of the embrittlement accidents that have already happened? What is your reasoning about this?
Response !
l l Again, we assume that the " embrittlement accidents that have already happened" refer to the overcooling transients of December 26, 1985 and March 20, 1978, during which the pressure and temperature of the coolant within the Rancho l Seco reactor vessel entered what is conservatively designated as the i " pressurized thermal shock" (PTS) region. It has been determined that the transients to date during which the PTS region was entered have not affected the structural integrity of the reactor vessel or any other plant component.
Therefore, we have no reason to shorten the license term of Rancho Seco as a result of those transients.
Question D-5 Has SMUD discussed with you, or asked for, a license extension now, or before 2009, because of their restart and rehab work now? Is there any likelihood of this?
Response
SMUD has neither asked for nor initiated any discussions to date related to an extension of its operating license for Rancho Seco. Inasmuch as the Commission regulations (10 CFR 50.51) permit the granting of extensions to such licenses, SMUD could request a license extension at some future time.
Question D-6 According to code, are you allowed to grant extensions to the existing license? :
Response
l The Commission's regulations (10 CFR 50.51) state that each license will be issued for a fixed period of time to be specified in the license but in no case to exceed 40 years from the date of issuance. Some operating' licenses were issued for 40-year terms commencing with the issuance of the construction permits for these facilities. Depending on the time required for construc-tion, the licenses for these facilities provide for an effective operating license term less than 40 years. The Commission's regulations permit the granting of extensions to these licenses so that the full 40 years of operation intended by the rule (10 CFR 50.51) may be achieved.
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1 E. Plant Decommissioning Question E-1 ;
i Based upon the knowledge gained from the 3M Nuclear Waste disposal fiasco and ;
your most current data, what do you estimate the cost of decommissioning a !
nuclear plant to be? A B&W plant to be? As a % of new construction cost, what will'it be roughly?-
Response
The NRC had one of its principal contractors,.Battelle Pacific Northwest i Laboratories (PNL), develop an analysis of estimated costs of decommissioning )
various. nuclear facilities, including pressurized water reactors (PWRs). This was done on a generic basis, based on an engineering. evaluation of activities involved in decommissioning. In doing these analyses, PNL considered plant
- design, estimated conditions in the plant at the time of shutdown, proven decontamination and dismantling methods, and radiation protection requirements for workers.and the public. The analyses included principal cost factors such j as labor necessary to complete the work and the cost of waste disposal. Based !
on these considerations, the PNL analyses estimated the cost of decommissioning I to be approximately $100 million for a PWR in current dollars. This cost does not include the cost of demolition and removal of'the nonradioactive portions of the plant or restoration of the site. The cost of decommissioning a B&W plant is estimated to be approximately the same as~that for the PWR plant {
indicated above. The studies done by PNL have not identified a specific relationship between construction costs and decommissioning costs. This is because many of the principal factors that enter into the two costs are unrelated.
Question E-2 Does decommissioning include removing ALL high level radioactive contaminated structural members?
Response
On February 11, 1985, the NRC issued a proposed rule containing decommissioning criteria for nuclear facilities. In that document, decommissioning is defined as removing a facility safely from' service and reducing residual radioactivity to a level that permits release of the property for unrestricted use and termi- a nation of license. Based on that definition, decommissioning would include removal of all radioactive material exceeding residual levels considered i acceptable for releasing the property for' unrestricted use and for terminating the olant license.
Question E-3 What does decommissioning include? What does it ci,t include that has a major fiscal impact on the plant's owners? Does that include dismantling of the containment areas? Does that require SMUD maintaining nuclear waste storage?
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Response
i Decommissioning includes removing components, materials, and structures having radioactive contamination exceeding residual radioactivity levels i considered acceptable for releasing the property for unrestricted use and for '
terminating the NRC license. This includes dismantling radioactively contami- ,
nated components, systems, and structures in the containment area. The l decommissioning would be divided into four major activities: planning and ;
preparation; decontamination and dismantling of. systems, components, and structures; disposal of radioactive material; and the final radiation survey and termination of license. I Decommissioning does not include removing nonradioactive structures and i materials; to remove these could cost plant owners more than $20 million for a <
typical large reactor.
If a plant is decommissioned by what is commonly referred to as "immediate dismantlement," all radioactivity above acceptable residual levels is removed within a few years after the plant has permanently ceased operations and the license is terminated. In this situation, SMUD would not maintain nuclear waste storage. If disposal capacity for nuclear wastes removed from the plant during decommissioning is unavailable, there are provisions in the proposed 3 regulation (which is referred to in response to E-2) to allow for delay in completing tiecommissioning; this would permit nuclear wastes to be stored on site temporarily. Once the wastes had been removed and the plant had been l l cleaned up, a radiation survey showing radioactivity levels in the plant to '
be below acceptable residual levels would permit the plant license to be ,
terminated. <
Question E-4 How did you decide upon the amount required to be set aside by SMUD for I decommissioning? Or did you? Did you issue guidelines for this? What are those criteria and how long ago were they revised? Since the 3M experience?
Response
Currently there are no specific requirements in the NRC regulations that a utility set aside funds for decommissioning. The proposed rule referred to in the response to E-2 contains requirements 'that, early in plant life, licensees establish funding provisions to provide reasonable assurance that funds are available for decommissioning. According to these proposed require-ments, a utility would have to determine a level of funding for decommissioning and establish a method to set aside the appropriate funds. The proposed rule also contains requirements for periodically adjusting the funding level, including a specific requirement that a cost estimate and plans for adjusting funding levels, if necessary, be submitted to NRC five years before the end of I
operations based on a then current assessment of major factors that could affect decommissioning costs. In addition, the proposed rule contains requirements that a licensee's decommissioning plan contain an updated decom-i missioning cost e. stimate and a plan for ensuring that funds will be available l to complete decommissioning. This step-wise approach to decommissioning 1
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funding over facility life will provide reasonable assurance that the )
Commission's objective is met; namely, that at the time of decommissioning )
sufficient funds are available to decommission the facility in a manner that '
protects public health and safety. The level of funds necessary and the i funding methods allowed are based on an extensive data base, developed by PNL l (referred to in response to E-1 above) and by other NRC contractors, which has l been revised recently to take into account current information pertinent to I decommissioning. I It is expected that the proposed rule on decommissioning will be issued as an effective rule in the last quarter of 1987. l j Question E-5 1 1 Do you have decommissioning guidelines, fiscal and physical, for B&W plants j specifically? !
Response
Specific deconnissioning requirements for B&W plants are not considered necessary because existing requirements on decommissioning and those being proposed are considered broad enough to be applicable to all plants, including those manufactured by B&W.
Question E-6 l
If not a requirement of the NRC, what do you recommend that SMUD be setting j aside as a realistic decommissioning fund to fully pay for decommissioning by ,
the year 20097 Is that consistent with today's costs in construction and j related industries?
Response
As noted in response to earlier comments, although there are no current NRC regulations on decommissioning funding, proposed rules that are expected to be issued later in 1987 will contain requirements on setting aside funds for decounissioning. The specific amount necessary for SMUD to set aside is not contained in the proposed rule, although as indicated in the response to E-1, our contractor PNL has indicated that, for a generic plant that is similar to the SMUD plant, decommissioning is estimated to cost approximately $100 million in current dollars. As noted earlier, this amount does not include costs of demolishing nonradioactive components and structures or costs of restoring the site. With the updating provisions of the rule, discussed in response to E-4, the amount of funds available in 2009 will of course be greater than $100 million. As discussed in the response to E-1, the estimate is based on factors considered important in decommissioning nuclear reactors and has been revised to account for recent information.
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FROM: DUE: 05/27/87 EDO CONTROL: .002846-
- DOC-DT: .05/01/87 SEN.LALAN CRANSTON gMy# F FINAL REPLY:
1 39, C/M/27 i
OCA'
,FOR SIGNATURE OF: ** ' GREEN ** SECY NO: 87-534 EXECUTIVE DIRECTOR DESC: ROUTING:
ENCLOSES LETTER FROM ELAINE SOUTHARD CONCERNING JMARTIN RANCHO SECO MURRAY DATE: 05/12/87 ASSIGNED TO: NRR CONTACT: MURLEY SPECIAL INSTRUCTIONS OR REMARKS: '
1/ (b RETURN INCOMING WITH REPLY. [' (7 MARK ENVELOPE ATTNs JIM KOHLENBERGER.
REF. EDO 2246 1py r
j )J . t NRR RECEIVED: 05/12/87 GM(0 ACTION:
.DRSP:CRUTCHFIELD_]~ "
NRR ROUTING: MURLEY/SNIEZEK MIRAGLIA STAROSTECKI BLAHA FUNCHES MOSSBil1G
. \ ur-p..
nyfy ACTION DUE TO NRR DIRECTOR'S OFFICE BY IM/F'7 -
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1 1
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- i OFFICE OF THE SECRETARY j CORRESPONDENCE CONTROL TICKET j i
PAPER NUMBER: . CRC-87-0534 LOGGING DATE: May 8 87 )
)
ACTION OFFICE: EDO j
.i AUTHOR: A. Cranston--Const Ref l AFFILIATION: 'U.S. SENATE {
l LETTER DATE: May 1 87 FILE CODE: C&R-2 BP j l
SUBJECT:
Various questions re nuclear plants and procedures q l
l ACTION: Direct Reply DISTRIBUTION: OCA to Ack SPECIAL HANDLING: None NOTES: Elaine Southard 1 DATE DUE: May 22 87 SIGNATURE: . DATE SIGNED:
AFFILIATION:
s Rec'd Off. EDO g - // - 7 7 -
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