ML20249C837
| ML20249C837 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Maine Yankee File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 06/23/1998 |
| From: | Haffer E SHEEHAN, PHINNEY, BASS & GREEN, P.A. |
| To: | Patch D NEW HAMPSHIRE, STATE OF |
| References | |
| NUDOCS 9807010284 | |
| Download: ML20249C837 (7) | |
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GREEN (603) 627-8115 1,
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June 23, 1998 ATTORNEYS AT LAW BY HAND DELIVERY 1000 Etu StarsT P.O. Box 3701 MANCHESTER Douglas Patch, Chairman New IIAursMiar Nuclear Decommissioning Financing Committee 03 05-370 FAX "
g3 NH Public Utilities Commission l if Anmu PtACs 8 Old Suncook Road Surre 325 Concord, NH 03301 PoaisuouTH Nrw HAursHrar 03801-3856 Re NDFC 98-1 FAX 603-433-3126 I
603-433 2111
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143 NORTH MAIN STREET
Dear Chairman Patch:
Suit #103 CONCORD NEw llAMrsHIRE Here are North Atlantic's responses to the follow-1 03301-5089 FAX 603-224 8899 UP data requests.
j 603-223 2020
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l Sincerely, Edwar A. Haffer EAH/smh Enclosure l
cc (w/ enc.):
Rep. Channing Brown i
Williard F. Boyle John Stephen i
Georgie A.
Thomas James P.
Fredyma George Gram l
i Sen. John S. Barnes, Jr.
Alexander Kalinski, Esq.
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Winslow Melvin l
General Counsel, PUC Michael W. Holmes, Esq.
Robert A. Backus, Esq.
Seabrook Selectmen's Office n
l V-vvaa Robert Cushing, Jr.
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9807010284 980623 E
PDR ADOCK 05000213e W
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-'e Dougles Patch, chzirman June 23, 1998-Page 2 Wynn E.-Arnold, Esq.
Mary K. Metcalf Director of Nuclear Reactor Regulation
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Kenneth J. Aupperle Rep. Jeb. E. Bradley Tracy Guyetite Kendall Wiggin cc (w/o enc. ) : Remainder of Service List gMhafferk atlantic (6783)\\lt patch 98-06-23. doc
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AFFIDAVIT I, Anthony M. Callendrello, affirm under oath that, on behalf of North Atlantic Energy Service Corporation, I have answered the following Data Requests and that my answers thereto are true to the best of my knowledge and belief:
l From the PUC Staff (Guyette): DR 1.4 l
From the OCA (Anderson): DR 2.7,2.8 From CRR (Backus): DR 4.15,4.16,4.17 DATE
^^/pdnthony M. Callendrello Rockingham, ss Date: 4 J?
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Then personally appeared before me, the above named Anthony M. Callendrello, being duly sworn, did state that he is Licensing Manager of North Atlantic Energy Senice Corporation and that he is duly authorized to execute and file the foregoing information in the name of and on the behalf of North Atlantic Energy Service Corporation and that the statements therein are true to the best of his knowledge and belief.
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' Marilyn RISullivad, Notary Public
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Response to NDFC 98-1 DR 1.4 (PUC/Guyette):
l Question / Request:
1 Are there any operating nuclear facilities in the United States that are funding their decommissioning fund at a more rapid level than equalized real dollars through the end of license life (?) If yes, please indicate the facilities, the specific funding methodology, if the current methodology has been in place from the start of operations-if not (,) when i
and why did the change occur, the regulatory body which sets decommissioning levels and methodology for each facility, the reason for funding more rapidly than equalized real dollars, and how these facilities are dealing with the tax consequences detailed in Mr.
Spitzer's testimony.
Response
Any funding approach that completes required funding contributions prior to the end of l
license life would, by definition, constitute funding that is more rapid than equalized real j
dollars through the end oflicense life.
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' Great Bay Power, as part ofits resolution to its compliance problem with the NRC decommissioning funding assurance regulation, has agreed to this type of accelerated funding for its portion of the Seabrook Station decommissionir;g obligation. The tax issues in Mr. Spitzer's testimony do not apply to this case since Great Bay Power is not l
entitled to the use of qualified funds and the associated tax advantages. New England Power has taken the position that there are business advantages to accelerated funding and is pursuing approvals in its regulatoryjurisdictions. The tax ramifications of this approach for New England Power remain to be resolved. New England Power considers that it can be successful in retaining favorable tax treatment for the accelerated funding that it is considering.
North Atlantic is not aware of any owners of other nuclear facilities in the United States who may be using accelerated funding. North Atlantic also referred this question to Mr.
Spitzer of Ropes of Gray who has advised North Atlantic that he is unaware of any such cases.
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Response to NDFC 98-1 DR 2.7 (OCA/ Anderson):
Question / Request:
t Since the technical session on April 21,1998, it is my understanding that there have been announcements for the closing of two nuclear facilities in Nebraska. Those plants may be
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g the following:
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- 1) Cooper Nuclear Plant Owner: Nebraska Public Power District
- 2) Fort Calhoun Nuclear Plant Owner: Omaha Public Power District L
As Data Request'2.7, I would ask that you confirm if it has been announced that these l
nuclear facilities will be closed; and if so, how many years did these plants run. Since North Atlantic prepared responses to the original data requests, have there been any other announcements of nuclear plant closings, other than the two Nebaraska plants that are listed above (?). If so, please provide the plant names, as well as data on how long those plants operated.
l
Response
North Atlantic has checked industry publications and the Internet home pages for the two utilities that own the plants and has found no announcement of the closing of the two plants mentioned. North Atlantic has seen no mention of the shutdown of any other plants beyond those described in the original resporse to the data request.
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6/19/98 1
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Response to NDFC 98-1 DR 2.8 (OCA/ Anderson):
i Question / Request:
In the June 5-18,1998 issue of New Hampshire Business Review (Vol. 20, No,12), an article appeared entitled "In electricity there's another ' stranded cost'; billions to close i
Seabrook" by Bob Sanders. On page 17 of that edition of the New Hampshire Business Review, David Barr as spokesman for North Atlantic was quoted as saying that the cost of operating Seabrook would be "far too high" if the rates were to reflect the "true cost" of decommissioning; and that Seabrook would have to shut down. As Data Request 2.8, please indicate what amount of money Seabrook spokesman David Barr was referring to as the "true cost of decommissioning", and what monetary effect that would have on l
Seabrook's rates.
l Responsei l
Mr. Barr's discussions with Mr. Sanders were not confined to decommissioning costs, Mr. Barr also responded to Mr. Sanders' questions regarding a hypothetical deregulated utility environment and North Atlantic's position on whether or not Seabrook Station l
would be economically viable in such a utility environment. In response to questions regarding a hypothetical deregulated business environment Mr. Barr stated North -
Atlantic's position that operational costs (e.g.,- operations, maintenance, fuel, taxes, deconunissioning, contributions to high level waste disposal fund, and others) could be covered in a deregulated environment, but that it was anlikely that the total cost which would include the sunk capital cost invested to build the facility could be covered in a deregulated environment. When Mr. Barr referred to the true cost he was referring to the 16tal cost to operate the facility and deliver power to the electrical grid--sometimes referred to as bus bar cost. Mr. Barr did not discuss the " tine cost" of decommissioning or state or imply that the expected decommissioning cost was any value other than that presented in the Seabrook Decommissioning Cost Update. Mr. Barr was misquoted.
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6/19/98-1
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Response to NDFC 98-1 DR 4.15 (CRR/Backus):
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Question / Request:
j Please fumish the PSDAR for Maine Yankee and Connecticut Yankee referenced in your earlier responses to DR 3.1.
Response
- The PSDARs are attached.
W 6/16/98 1
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4 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD EAST RAMPTON, CT 06424-3099 August 22, 1997 Docket No. 50-213 CY-97-075 Re: 10CFR50.82 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 - 0001 Haddam Neck Plant Post Shutdown Decommissioning Activities Report (PSDAR)
In accordance with 10CFR50.82 (a) (4) (i), Connecticut Yankee Atomic Power Company (CYAPCO) hereby submits to the NRC the Post Shutdown Decommissioning Activities Report (PSDAR) for the Haddam Neck Plant (HNP). In accordance with 10CFR50.82, the PSDAR includes:
- CYAPCO's selection of the DECON decommissioning option; *a description of planned decommissioning activities; *a schedule for those planned activities; *an estimate of currently expected costs; and *a discussion of the reasons for CYAPCO's conclusion that the environmental impacts associated with the planned activities are bounded by appropriate previously issued environmental impact statements.
Should plans further develop or change, CYAPCO will inform the NRC of changes in accordance with 10CFR50.82 (a) (7).
In addition, 10CFR50. 82 (a) (8) (iii) requires that CYAPCO submit, within 2 years following permanent cessation of operations, an updated site-specific decommissioning cost estimate. CYAPCO intends to submit the site-specific estimate under separate cover on a schedule consistent with the rule. At that time, and in light of the rate case currently pending before the Federal Energy Regulatory Commission, CYAPCO intends to address the decommissioning funding issues identified in 10CFR50.82 (c).
Similarly, 10CFR50. 54 (bb) requires that CYAPCO submit, within 2 years following permanent cessation of operations, a spent fuel management program describing its management and funding plans of the CYAPCO spent fuel until title and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. CYAPCO intends to submit this plan under separate cover on a schedule consistent with the regulation.
If you should have any questions, please contact Mr. G.
P. van Noordennen at (860) 267-3938.
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i en Vu y truly yours, l
CONNECTICUT YANKEE ATOMIC POWER COMPANY i
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T. C. Feigenbaum Executive Vice President and Chief Nuclear Officer l
Enclosure l
cc: H.
J.' Miller, Region I Administrator M. B. Fairtile, NRC Senior Project Manager, : NRR W,'J.
Raymond,. Senior Resident Inspector, Haddam Neck Plant
.K. T. A..McCarthy, Director, CT DEP Monitoring and Radiation Division.
- Haddam Neck Plant
' Post Shutdown Decommissioning Activities Report August.1997 Table of Contents INTRODUCTION 1 L
BACKGROUND 1 1
I DESCRIPTION OF. PLANNED DECOMMISSIONING ACTIVITIES 2' t.
1 Decommissioning Activities and Planning 2 Planning Activities ~(Pricr to Submittal of the PSDAR) 2 Plant ~ Dismantlement 2
~ MAJOR DECOP91ISSIONING ACTIVITIES 3 l
.\\ l -Reactor Vessel and Internals 3 I
' Pressurizer 4 Reactor Coolant System (RCS) and Other Large Bore Piping 4 Containment 4 Spent Fuel Pool 5
, OTHER DECOMMISSIONING CONSIDERATIONS 5 Chemical. Decontamination of Primary Coolant Systems 5 General Decommissioning Activities - Removal of. Radiological
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Compon:;nts & Structures 5 Decontamination Methods 6 Dismantlement Methods 6 Special or Unusual Programs 7 Removal of Low Level Radioactive Waste (LLW) and Compaction or l
Incineration 7 I
Soil Remediation 7 l-Processing and Disposal Site Locations 7 Removal of Mixed Wastes 7 Storage / Removal of Spent Fuel and GTCC Waste 8 SITE RESTORATION 8 SCHEDULE FOR DECOMMISSIONING ACTIVITIES 8 ESTIMATE OF EXPECTED DECOMMISSIONING COSTS 8 ENVIRONMENTAL IMPACTS 9 REFERENCES 11 LIST OF ACRONYMS i
CYAPCO Connecticut Yankee Atomic Power Company DECON Innediate Decontamination and Dismantlement Option
'DF Decontamination Factor DOE Department of Energy ENTOMB Encasement in Concrete with Future Dismantlement Option FGEIS Final Generic Environmental Impact Statement GTCC Greater Than Class C HEPA High Efficiency. Particulate Air [ filter)
HNP Haddam Neck Plant i
LPSI Low Pressure Safety Injection._.
NRC Nuclear Regulatory _ Commission PSDAR Post Shutdown Decommissioning Activities Report RCS Reactor Coolant System RHR Residual Heat Removal System SAFSTOR Delayed Decontamination and Dismantlement Option i
.UFSAR Updated Final Safety Analysis Report 10CFR61 Licensing Requirements for Land Disposal of Radioactive
. Waste ICCFR71 Packaging and Transportation of Radioactive Material l : 3 cf 13 -
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_______-._________________a
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Hiddtm N;ck Pltnt Post Shutdown Decommissioning Activities Report i
INTRODUCTION Under the provisions of 10CFR50.82 (a) (4) (i), Connecticut Yankee Atomic Power Company (CYAPCO) hereby submits this Post Shutdown J
Decommissioning Activities Report (PSDAR) to describe planned decommissioning activities and the schedule for those activities, i
prov;de an estimate of expected costs, and discuss the reasons for i
concluding that the environmental impacts associated with site-specific decommissioning activities are bounded by appropriate previously issued environmental impact statements, specifically NUREG-0506, " Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" [ Reference 1] and the Haddam Neck Plant site-specific Final Environmental Statement [ Reference I
2] and Environmental Assessment (Reference 3].
BACKGROUND i
The Haddam Neck Plant (ENP) achieved initial criticality on July
-24, 1967, began commercial operation on January 1, 1968, and
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operated 28 years echieving an overall capacity factor of approximately 70 percent. The nuclear steam supply system is a four loop pressurized water reactor (PWR) designed by Westinghouse Electric Corporation with a thermal power design limit of 1825 MWt.
The turbine generator was rated to produce 619 MWe.
Defueling began on November 13, 1996 and was completed on November I
15, 1996, with all fuel assemblies being placed into the spent fuel pool for temporary storage. For economic reasons, CYAPCO opted to cease commercial operation of the HNP on December 4, 1996.
Certification of permanent cessation of operation and removal of i
fuel, in accordance with 10CFR50.82 (a) (1) (i) and (ii), was l
submitted to the U.S. Nuclear Regulatory Commission on December 5, i
1996 [ Reference 4].
l CYAPCO's primary goal is to decommission the ENP in a safe and cost effective manner. CYAPCO will decontaminate and dismantle the HNP, resulting in the timely removal of the existing nuclear plant in accordance with one of the options found acceptable to the NRC in its Final Generic Environmental Impact Statement (FGEIS). The NRC regulations refer to this option as the DECON alternative resulting in prompt dismantlement of the site. Completion of the DECON option is contingent upon continued access to one or more low level waste disposal sites. Currently, the HNP has access to Chem Nuclear -
Barnwell, South Carolina and Envirocare - South Clive, Utah. If there are any future changes in this regard, CYAPCO will inform the NRC of revised plans in accordance with 10CFR50.82 (a) (7).
DESCRIPTION OF PLANNED DECOMMISSIONING ACTIVITIES Decommissioning Activities and Planning The activities planned for decommissioning of the HNP reflect the selection of the DECON option for the site. CYAPCO will complete the detailed planning required for each decommissioning activity prior to the start of such activity.
Planning Activities (Prior to Submittal of the PSDAR)
The time period between the decision to permanently shut down and decommission the plant and the submittal of this PSDAR to the NRC has been utilized by CYAPCO to establish a decommissioning 4 cfl3 06/16/98 11:43:50
s organiz0 tion, pr:p;ra gubmitttle for a revis d EmirgLncy Plin, n raviccd S:curity Plcn, o revierd Qunlity ASturtnca Program, rsvissd Technical Specifications, and to initiate planning for decommissioning activities.
Ongoing planning and preparation for decommissioning includes the following generalized types of tasks:
- Review existing plant programs to assess their applicability to decommissioning,
- Review and reclassify systems important to j
decommissioning operations,
- Revise procedures and license basis j
documents to reflect the plant's defueled and permanently shutdown configuration,
- Initiate radiological and hazardous material characterization of the site,
- Design and procure equipment and facilities to support decommissioning activities,
- Prepare detailed i
(area-by-area) work breakdown structures for decontamination / dismantling activities,
- Prepare a dose estimate for decommissioning activities, and
- Evaluate disposition options I
for facility components and structures.
A key step in decommissioning planning was the selection of a project staff and establishment of an organizational structure with prior decommissioning experience. This step mobilized key management personnel with decommissioning experience, permanent CYAPCO management and staff personnel, additional supplemental staff and specialty contractors (utilized as needed).
I Plant Dismantlement l
l The decommissioning planning is based on selecting the DECON option and is expected to result in the decontamination and/or dismantlement of the majority of plant structures and facilities by the year 2004. The few facilities and structures that have to remair to support spent fuel and greater than class C (GTCC) waste storstp. will be decontaminated and/or dismantled after the spent fuel And GTCC wastes are taken by the DOE.
The following describes activities included in the dismantlement j
period:
- Establish site construction power distribution system,
- Perform primary systems decontamination,
- Perform asbestos abatement j
program,
- Separate the fuel building from the rest of the site's j
mechanical and electrical systems,
- Conduct decommissioning I
activities, including major component removal,
- Conduct decontamination of facility surfaces, components and piping systems as required,
- Conduct soil remediation as required,
- Ship and I
properly dispose of all remaining radioactive materials, and
- Perform comprehensive final status survey to demonstrate compliance with approved site release criteria [10CFR20, subpart
)
E).
The structures and facilities that will remain after the dismantlement period to store the spent fuel and GTCC waste are as follows:
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- The spent fuel building and the systems necessary to accomplish 3
fuel cooling (Note: modifications will be made early in the HNP i
decommissioning process to permit the spent fuel building and its j
fuel cooling systems to operate independently from the rest of the j
site),
- Support facilities consisting of a control room, a security access point, and work areas necessary for spent fuel pool operations, and *A security perimeter (e.g., security fence, an intrusion monitoring system, lighting, etc.)
j For present planning purposes it is assumed that wet storage will be continued until the spent fuel is shipped from the site. CYAPCO l
will appropriately advise the NRC of any future changes to its j
plans in this area.
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MAJOR DECOMMISSIONING ACTIVITIES 10CFR50.2 defines major decommissioning as any activity that results in permanent removal of major radioactive components (e.g.,
reactor vessel and internals, steam generators, pressurizer, large bore reactor coolant system piping, and other large components that i
are radioactive to a comparable degree), permanently modifies the structure of the containment, or results in dismantling components for shipment containing GTCC waste.
The following discusses the planned major decommissioning activities at the HNP:
Reactor Vessel and Internals The reactor vessel and internals are described in the Updated Final Safety Analysis Report (UFSAR) Section 5.3.
An engineering evaluation determined two technically feasible alternatives for removal of the reactor vessel and internals. These alternatives are (1) removal of the vessel (including reactor head) with the internals inti.ct, and (2) segmentation of the internals followed by remeval of she vessel (including reactor head). The schedule shown in Figure 1 for large component removal activities is expected to bound both the alternative of removing the vessel with the internals intact and the alternative of internals segmentation followed by vessel removal.
Estimates of radionuclides concentrations in the vessel from neutron activation show that the limits for a 10CFR61 (disposal site) package will not be exceeded, and the specific activity of the package would be within the limitations for a 10CFR71 (shipment) package. This allows the vessel (including internals) to be qualified for normal conditions of transport. In both alternatives, the vessel (with or without the internals) would be shipped to a low level radioactive waste disposal facility inside an approved container.
Final al will be based on'ternative selection (expected 4th quarter 1997) an evaluation of parameters associated with project planning and execution, considering the following: safety impacts, personnel exposure, schedule impact, disposal facility availability, ease of execution cost, and regulatory acceptance.
A portion of the highly activated reactor vessel internals, if segmented, will be characterized as GTCC waste. The GTCC material may be stored in the ENP spent fuel pool until it can be transferred to the DOE.
Steam Generators The steam generators are described 5n UFSAR Section 5.4.
An engineering evaluation determined two technically feasible alternatives for removal of the steam generators. These alternatives are (1) intact removal, and (2) partial segmentation.
The schedule shown in Figure 1 is expected to bound either alternative.
Final alternative selection (expected 4th quarter 1997) will be based on an evaluation of parameters associated with project planning and execution, considering the following: safety impacts, personnel exposure, schedule impact, disposal facility availability, ease of execution and cost.
Pressurizer The pressurizer is described in UFSAR Section 5.4.
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l The proccurizsr will be ramovsd intact in accord:nca with tha general decommissioning activities and shipped to a disposal facility.
Reactor Coolant System (RCS) and Other Large Bore Piping The reactor coolant system and other large bore piping is described in UFSAR Section 5.4.
The RCS and any other large bore piping will be decontaminated as appropriate and removed in accordance with the general decommissioning activities.
Containment The containment is described in UFSAR Section 6.2.
-The containment surfaces and structure (as appropriate) will be decontaminated and dismantled in accordance with the general decommissioning activities.
Spent Fuel Pool The spent fuel pool is described in UFSAR Section 9.1.
Once all spent fuel and any GTCC waste are removed from the spent i
P fuel pool, the facility will be 6 contaminated and dismantled in
-accordance with the general decommissioning activities.
OTHER DECOMMISSIONING CONSIDERATIONS
'The decontamination and/or dismantlement of contaminated systems, structures and components may be accomplished by decontamination in place, dismantlement and decontamination, or dismantlement and disposal. A combination of these methods may be utilized to reduce contamination levels, worker radiation exposures and project costs.
General considerations applicable to these activities are described
- below, Chemical Decontamination of Primary Coolant Systems o
A chemical decontamination of the primary coolant systems will be performed prior to conducting major decommissioning activities. The
' chemical decontamination is a significant ALARA initiative being performed to reduce personnel exposure during decommissioning work activities. The decontamination effort is expected to include the entire reactor coolant, system (RCS) (including reactor vessel, steam generators and pressurizer) as well as portions of the
.following appended systems: letdown _and charging, residual heat removal (RHR), loop fill and drains, seal injection and return, and selected dead leg piping. Sither the RCS pumps or the low pressure safety injection (LPSI) pumps will be used to provide the necessary decontamination flow. Modifications may be necessary to establish-the required flow paths. The decontamination operation will be controlled by approved plant procedures.
-General Decommissioning Activities Relating to Removal of Radiological Components'& Structures
' Components will be safely and efficiently removed using the techniques and methods determined to be the most appropriate for
'the particular circumstances and as specified in engineering
. documents called decommissioning work packages. Openings in components will typically be covered and sealed to minimize the l
apread of contamination. The components may be moved to a i
processing area for volume reduction and packaging into containers 7 of 13 '
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Contaminated concrete and structural steel components will be decontaminated and/or removed when contaminated and uncontaminated systems and equipment have been removed from the area or building.
The contaminated concrete will then be removed and packaged into containers for shipment to a low level radioactive vaste disposal facility. Contaminated structural steel components may be moved to a processing area for decontamination, volume reduction and packaging into containers for shipment to a prc:essing facility for decontamination or low level radioactive waste disposal facility.
Buried contaminated components (e.g., piping, drains) will be l
decontaminated in place or excavated. After excavation, the components will be examined to ensure that they are physically sound prior to cutting and removal. Appropriate contamination controls will be employed to minimize the spread of contamination and protect personnel.
Decontamination Methods Contaminated systems and components will be removed and sent to an off-site processing facility or to a low level radioactive waste disposal facility. On-site decontamination of systems and components will generally be limited to activities needed to maintain personnel exposure as low as is reasonably achievable, to expedite equipment removal, and to control the spread of contamination.
Application of coatings and hand wiping will be the preferred methods for stabilizing or removing loose surface contamination. If other methods are utilized (e.g., grit blasting, high pressure water), airborne contamination control and waste processing systems will be used as necessary to control and monitor any releases of contamination.
Contaminated and activated concrete as well as other contaminated materials will be removed and sent to a low level radioactive waste disposal! facility. Removal of concrete will be performed using a method which controls the removal depth to minimize the waste volume produced (e.g.,
scabbling, scarifying). Vacuum removal of the dust and debris with HEPA filtration of the effluent will be used to minimize the need for additional respiratory protection control measures.
These methods are the most practicable and widely utilized at this time. However, as new decontamination technologies are developed, they will be considered and used if appropriate.
Dismantlement Methods Dismantlement methods can be divided into two basic types:
- Mechanical Methods - Mechanical methods machine the surfaces of the material that is being cut. These methods typically are capable of cutting remotely without generating significant amounts of airborne contamination. This attribute makes those methods attractive for most of the contaminated piping, equipment, and components that will be removed at the HNP. The outside diametm machining method is best suited for cutting large bore contaminated piping. Smaller bore contaminated piping, tubing, and supports can be cut using any of the mechanical w?thods (e.g., band saws, reciprocating saws, hydraulic shears..
- Thermal Methods - Thernal methods nelt or vaporize the surfaces of material that is being cut. The cutting debris is transported from the cut region with a gas jet or water spray. Although thermal methods are significantly quicker than mechanical methods, they have high power requirements S of l3 06/16/98 11:43:50
l cnd gansrate airborns contamination whsn used on contaminated 8
systems in air. Gensration of airborns contamination can be easily l
controlled when the method is used underwater. Thermal methods are i
. suitable for segmenting large vessels in areas that can easily be sealed, filtered, or maintained underwater. The method is also suitable for use at a cutting station with air filtration. Thermal nethods are appropriate for removing structural steel if it has been decontaminated or if a local contamination envelope with HEPA filtration is established. Appropriate lead paint removal controls must also be implemented.
These methods are the most practicable and widely utilized at this time. However, new dismantlement technologies developed prior to
'the commencement of actual decommissioning activities will be l
considered and used if appropriate.
Special or Unusual Programs There are no special or unusual programs. All procedures and processes that will be used at the HNP are consistent-with those i
considered in the Final Generic Environmental Impact Statement (FGEIS).
Removal of Low Level' Radioactive Waste (LLW) and Compaction or Incineration LLW will be processed in accordance with plant procedures and sent to LLW disposal facilities. Some LLW may be incinerated off-site at a licensed facility. No incineration will occur on-site. Onsite compaction is not expected to be used at this time.
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Soil Remediation l
. Soils and pavement will be surveyed and characterized in accordance with the site radiological characterization program. As necessary, L
soils and pavement will be remediated (i.e., removed, processed and disposed of at a licensed facility) if determined to contain contamination levels above the NRC site release (iOCFR20, subpart
-E] guideline values.
I Processi!ng and. Disposal Site Locations i
l Currently, there are several facilities available for (1) the processing of waste materials to achieve volume reduction prior to disposal or (2) the disposal of low level radioactive waste.
These locations include (but are not limited to) Chem Nuclear -
Barnwell, South Carolina; Envirocare - South Clive, Utah; Scientific Ecology Group (SEG) - Oak Ridge, Tennessee; Hake -
Memphis, Tennessee; and US Ecology-- Oak Ridge, Tennessee.
Removal of Mixed Wastes
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' Mixed wastes will be managed according to all applicable federal and state regulations including NRC handling, storage, and transportation regulations.
Mixed wastes from the HNP will be transported only by authorized end licensed transporters and shipped only to authorized and l
licensed facilities. If technology, resources, and approved processes.are available, processes will be evaluated to render the mixed waste non-hazardous.
Storage / Removal of Spent Fuel and GTCC Waste Spent fuel-and GTCC waste are currently planned to be stored wet in the spent fuel pool for the duration of the decommissioning until the DOE is: ready to take such waste. Since the availability of a i
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h licinrad DOE high 1sval wasta rspository is uncartain, a preciso dstarmin tion of wh n spnnt fusi cnd GTCC w:ste will be removed from the HNP site is not possible. Current projections are that the turnover of spent fuel and GTCC waste to the DOE will be completed by January 2022 (based on an initial shipment start date in January 2006 and DOE's current acceptance schedule). CYAPCO will appropriately notify the NRC of any changes to its plans in this area.
SITE RESTORATION Following dismantlement and decontamination of structures, systems, and components in a given work area, the structures and area will be surveyed to demonstrate that they meet NRC site release criteria (10CFR20, nubpart E]. Successful completion of this survey in conjunction with oversight and confirmatory surveys by the NRC will allow remaining structures, systems, and components to be released for unrestricted use.
Following transfer of spent fuel and GTCC waste to a DOE facility (or to dry storage), structures, systems, and components used to support wet spent fuel storage will be decontaminated and/or dismantled. The portion of the site that has not yet been surveyed will be surveyed to demonstrate that it meets NRC site release criteria (10CFR20, subpart E]. Successful completion of this survey will allow remaining components and structures to be demolished by conventional methods. Ultimately, CYAPCO's license for the site will be terminated, and the site will be released for unrestricted use.
SCHEDULE FOR DECOMMISSIONING ACTIVITIES Figure 1 presents the schedule and milestones for major decommissioning activities. This schedule is based on the assumption that spent fuel and GTCC waste will be retained in wet storage until the DOE transfers such waste to an offsite facility (as stated above, for planning purposes, this is considered complete in 2022). Activities requiring significant NRC licensing effort and resources are also shown on Figure 1.
ESTIMATEiOF EXDECTED DECOMMISSIONING COSTS In December 1996, CYAPCO filed an updated decommissioning cost estimate [ Reference 5) with the Federal Energy Regulatory Commission (FERC). The decommissioning cost estimate was updated to reflect a pricing structure change for low level radioactive waste disposal at Barnwell, South Carolina, new industry experience in asbestos abatement, contaminated soil remediation activities, new industry experience in the final site survey, and scope of primary systems decontamination to lower exposures to workers during decommissioning. The current estimated cost to complete decommissioning is $426.7 million in 1996 dollars. CYAPCO will submit a further update on decommissioning funding matters, in light of the FERC rate case developments, in accordance with 10CFR50. 82 (8) (iii) and 50. 82 (c).
The current 1996 updated estimate, which will be identified as CY/FERC-96, is the basis for current HNP decommissioning plans and considered all decommissioning options - DECON, SAFSTOR, and ENTOMB. The CY/FERC-96 submittal assumes prompt removal / dismantling, (DECON), and is based on an analysis of the HNP systems, components, and structures. The estimate is also based on the radioactive waste disposal options available to CYAPCO in late 1996 (e.g., alternative waste disposal sites, barge transport, and various radwaste reprocessor). This estimate also includes provisions for site restoration, and for storage of spent fuel and GTCC wastes on the HNP site until 2022.
l The CY/FERC-96 decommissioning cost estimate, expressed in terms of l
l 10 0f l3 0'6/16/98 11:43:50
m _ _ _ _ _ _ _ _
_r 1996 dollcra, io cummarizid en follows:
g cPlanning/ Preparation $ 76,248,000* *Large Component Removal I
46,550,000
- Dismantlement Activities 149,655,000
- Low Level Waste Shipping / Burial 71,928,000
- Spent Fuel Storage 82,345,000
- Total Cost to Remove / Dismantle CY $426,726,000 e Includes asbestos abatement, RCS decon, & SFP island An external sinking fund, in accordance with 10CFR50.75 (e), was
]
octablished in April 1984, and amended in 1987, to accumulate CYAPCO decommissioning funds. Certification was provided in July 1990 (Reference 6] to certify the obligation of each wholesale purchaser from CYAPCO to be responsible for its share of the HNP l
d: commissioning costs pursuant to the terms of the power contracts.
ENVIRONMENTAL IMPACTS CYAPCO has performed an environmental review to evaluate all actual or potential environmental impacts associated with the proposed d: commissioning activities. This evaluation used as its basis NUREG-0586, " Final Generic Environmental Impact Statement (FGEIS) on Decommissioning of Nuclear Facilities," [ Reference 1] and two previous site-specific environmental assessments from the conversion of the provisional operating license to a full-term operating license [ Reference 2], and most recently, from the ra-capture of the construction period time duration (Reference 3].
This environmental review concludes that the impacts due to d: commissioning of the HNP will be bounded by the previously issued (environmental impact statements, specifically the FGEIS and previously issued environmental assessments. This is principally due to the following reasons:
The postulated impacts associated with the method chosen, DECON, h ve already been considered in the FGEIS.
There are no unique aspects of the plant or decommissioning tschniques to be utilized that would invalidate the conclusions r7 ached in the4FGEIS.
The methods to be employed to dismantle and decontaminate the site cre standard construction based techniques fully considered in the FGEIS The site-specific person-rem estimate for all decommissioning cetivities has been conservatively calculated using methods similar to and consistent with the FGEIS, Specifically, this review concludes that the HNP decommissioning will result in generally positive environmental effects, in that:
Radiological sources that create the potential for radiation cxposure to site workers and the public will be eliminated.
The site will be returned to a condition that will be acceptable for unrestricted use.
The thermal impact on the Connecticut River from facility operations will be eliminated.
Noise levels in the vicinity of the facility will be reduced.
Hazardous materials and chemicals will be removed.
Local traffic will be reduced (fewer employees, contractors and materials shipments than are required to support an operating nuclear power plant).
11of13 06/16/98 11:43:50 I
~
3 Furth;rmora, tha HNP dicommicioning will be cccomplich d with no significant adverse environmental impacts in that:
No site specific factors pertaining to the HNP would alter the conclusions of the FGEIS.
Radiation dose to the public will be minimal.
Radiation dose to decommissioning workers will be a fraction of the operating experience.
I Decommissioning is not an imminent health or safety problem and 1
will generally have a positive environmental impact.
The total occupational radiation exposure (excludes public and 1
transportation dose) impact for the proposed decommissioning l
cctivities has been conservatively estimated at approximately 935 l
person-rem, which is less than *he 1,115 person-rem exposure l
Catimate of the FGEIS for a PWR. This estimate is conservative and l
is based primarily on January 1997 plant dose rate surveys with no l
credit for (1) decay in place of isotopes (such as Co-60 ),
(2) l cequenced removal of higher dose rate components first, (3) cggressive ALARA program initiatives, (4) increased worker Gfficiency with experience, or (5) smaller scale decontamination i
initiatives.
s Radiation exposure due to transportation of radioactive waste (includes both occupational and offsite radiation exposures) has been conservatively estimated The occupational exposure is approximately 61 person-rem. The cumulative radiation exposure to s
on-lookers and the general public is approximately 11 person-rem.
1 These values are bounded by the FGEIS values of 100 person-rem for transportation occupational exposure and 21 person-rem for the general public exposure.
Radiation exposure to off-site individuals for expected conditions, a
or from postulated accidents, is bounded by the Environmental l
Protection Agency's Protective Action Guides and NRC regulations.
Doses due to the release of radionuclides in effluents will be I
negligibile in comparison to allowable limits.
j No significant impacts are expected from the disposal of low level radioactive waste. The total volume of HNP low level radioactive waste for disposal has been estimated at 283,117 cubic feet which j
is well bounded by the FGEIS volume of 647,600 cubic feet The l
Ectual HNP volume may be further reduced by additional utilization J
of volume reduction techniques.
Finally, the non-radiological environmental impacts from decommissioning are temporary and are not significant. The largest occupational risk associated with decommissioning HNP is related to the risk of industrial accidents. The primary environmental effects are short term, small increases in noise levels and dust in the immediate vicinity of the site, and truck traffic to and from the site for hauling equipment and waste. No significant socioeconomic impacts, other than those associated with cessation of operation (loss of jobs and taxes), or impacts to local culture, terrestrial or aquatic resources have been identified.
1 i
Given the low level of contamination and the expected volume of I
waste, disposal of low level radioactive waste off-site in a timely manner should be possible. If for any reason some portion of these wastes needs to be stored temporarily on-site, adequate space exists. No significant environmental impacts are anticipated from temporary on-site storage because all applicable federal and state regulations will be complied with.
12 of 13 06/16/98 11:43:51
r o-REFERENCES l
1.NUREG-0586, " Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," August, 1988.
2.USNRC, Final Environmental Statement, Haddam Neck (Connecticut Yankee) Nuclear Power Plant, Docket No. 50-213 October 1973.
- 3. Letter, USNRC to CYAPCO, " Environmental Assessment for Proposed License Extension," dated November 23, 1987.
- 4. Letter, CYAPCO to USNRC, "Haddam Neck Plant Certifications Of Permanent Cessation Of Power Operation And That Fuel Has Been Permanently Removed From The Reactor," dated December 5, 1996.
5." Decommissioning Cost Study for the Connecticut Yankee Nuclear Power Plant," dated December, 1996. 6. Letter, CYAPCO to USNRC,
" Decommissioning Financial Assurance Certification Report," dated July 18, 1990.
FIGURE 1 DECOMMISSIONING SCHEDULE For a copy of the schedule please call CY Licensing, Janice Costin at ext. 3102
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August 27, 1997 MN-97-99 MJM-97-14 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555
References:
(a) License No. DPR-36 (Docket No. 50-309)
~(b) Letter: M. Sellman to USNRC; " Certifications of Permanent Cessation of Power Operation and Permanent Removal of Fuel From the Reactor"; MN-97-89; dated August 7, 1997 LSubjects Post Shutdown Decommissioning Activities Report i
Gentlemen By Reference (b), Maine Yankee informed the USNRC that all fuel assemblies had been removed from the Maine Yankee reactor and that the Board of Directors had voted to. permanently cease operations of Maine Yankee and begin the decommissioning process.
1 10CFR50. 82 (a) (4 ) (i) requires that " Prior to or within 2 years following permanent cessation of operations, the licensee shall submit a post-shutdown decommissioning activities report (PSDAR) to the NRC. and a copy to the affected State (s). "
Maine Yankee is submitting the attached Maine Yankee Atomic Power Station Post Shutdown Decommissioning Activities Report in accordance with 10CFR50.82 requirements.
Please Montact me if you have any questions.
Very truly yours, Michael J. Meisner, Vice President Nuclear Safety and Regulatory Affairs Attachment l
l MAINE YANKEE ATOMIC POWER STATION
, 1 POST SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT Table of Contents I. INTRODUCTION II. OVERVIEW OF THE PSDAR
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III. DESCRIPTION OF PLAUNED DECOMMISSIONING ACTIVITIES Planning Site Characterization Decontamination-Major Decommissioning Activities Other Decommissioning Activities Storage of Spent Fuel Final Site Survey and Termination of License Site Restoration IV. SCHEDULE FOR DECOMMISSIONING ACTIVITIES
\\
V. DECOMMISSIONING COST ESTIMATE VI. ENVIRONMENTAL IMPACTS VII. REFERENCES j
j I.
INTRODUCTION Under the provisions of 10CFR50.82 (a) (4) (i), this Post Shutdown Decommissioning Activities Report (PSDAR) is submitted to describe Maine Yankee's planned decommissioning activities and schedule, provide an estime.te of expected costs, and discuss the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities are bounded by the appropriate previously issued environmental impact statements (EIS), specifically NUREG-0586, " Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" (Reference 1) and Maine Yankee's Site Specific EIS (Reference 2).
The reactor was shutdown on December 6, 1996 and has not been operated since. On June 20, 1997 transfer of all fuel assemblies from the reactor vessel into the Spent Fuel Pool for temporary storage was completed. On August 6, 1997 the Maine Yankee Board of Directors voted to permanently cease further operation of the plant. Certification to the Nuclear Regulatory Commission of the permanent cessation of operation and permanent removal of fuel from the reactor vessel, in accordance with 10CFR50.82 (a) (1) (i) & (ii),
was filed on August 7, 1997 (Reference 3).
II. OVERVIEW OF THE PSDAR The goal of Maine Yankee is to decommission the plant safely and in a cost effective manner. Prompt decommissioning satisfies both objectives. Therefore, Maine Yankee will decontaminate and dismantle the plant in a manner that results in the prompt removal of the existing nuclear plant, which is one of the approaches found acceptable to the NRC in its Final Generic EIS. The NRC refers to this approach as the DECON alternative. The DECON schedule is presented in Section-IV. See Section V for a discussion of the cost estimate and Section VI for a review of environmental impacts.
Completion of the DECON schedule is contingent upon two key factors:
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- Continued access to one or more federally licensed low level w ste disposal sites, and
- Timely funding of the decommissioning activities.
I l
Currently Maine Yankee has access to the Barnwell, S.C.
facility.
The State of Maine is also a member of the Texas compact and proposes, together with the States of Texas and Vermont, to catablish a low level waste facility in Texas. The compact has been cpproved by the States and is awaiting approval by the US Congress.
The schedule for construction of the Texas Compact facility has not been made final.
i 1
Maine Yankee has considered the possibility that during decontamination and dismantlement, access to the Barnwell low level l
waste disposal site could be denied prior to the opening of the Texas Compact facility.
Due to premature shutdown, Maine Yankee has a shortfall in its decommissioning fund collection schedule which will not support the DECON schedule absent additional provisions. Three options are t
cvailable to resolve the shortfall j
- Request approval to accelerate collection of payments into the i
fund to support the DECON schedule, s
I
- Finance the temporary shortfall once the FERC has resolved the
{
upcoming rate case, or
- Extend the DECON schedule consistent with the current fund l
payment collection rate.
1 Consistent with 10CFR50 R2(c) for prematurely decommissioned j
facilities, Maine Yankee will appropriately address the funding ghortfall. Under any eventuality (unavailability of a low level waste disposal site, temporary shortfall in decommissioning funding, or other unforeseen circumstances), 10CFR50.82 requires Maine Yankee maintain the capability to suspend decontamination and dismantlement. Should such conditions arise, Maine Yankee will be prepared.'to suspend dismantlement and maintain the facility in a zafe storage condition with appropriate funding.
l III. DESCRIPTION OF PLANNED DECOMMISSIONING ACTIVITIES Maine Yankee plans to decommission by pronpt dismantlement. Our intent is to complete the decontamination and dismantlement of the majority of plant structures and facilities within approximately reven years of cessation of operations. The few facilities and i
etructures required to support the spent fuel and greater-than-class-C waste storage will be decontaminated and dismantled after the Department of Energy (DOE) has taken
)
possession of the stored materials. Prior to that time, it may l
become cost effective to transfer the spent fuel from wet storage to dry storage. If Maine Yankee determines to follow that course, the spent fuel pool may be replaced by a fuel transfer facility, ceveral concrete pads, and a number of dry fuel / waste storage i
containers. Further information regarding the Maine Yankee program i
for funding and management of spent fuel will be submitted to the l
Commission in accordance with 10CFR50.54 (bb).
The following discussion provides an outline of the decommissioning 1
plans. This PSDAR description is an overview of Maine Yankee's current intentions. The detailed planning required for each decommissioning activity will be completed prior to the start of work for that activity, l
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.u http://serch.becht el.co...eports/309/309psdar.txt http://s;rch.bechtel.com/ftp2/ inspect / reports /309/309psdar.txt Planning Planning and preparation for decommissioning will include the following general types of activities:
- Develop decommissioning organization structure and select project ctaff
- Review and reclassify systems, structures, and components consistent with cessation of operations
- Review and revise plant licensing basis documents as necessary, consistent with cessation of operations 1
- Review and revise plant programs and procedures as necessary, consistent with cessation o'
>perations 1
- Design the longer term approach to spent fuel pool cooling and 1
isolation from the remainder of the plant
- Prepare detailed (area-hy-area) decommissioning procedures and cost estimates Site Characterization About the first six to eight months of the dee: commissioning period will be devoted to a detailed site characteris:ation. Surveys will be designed and conducted to establish the contamination and radiation levels throughout the facility. This information will be used in developing the detailed (area-by-area) procedures to ensure that contaminated materials are removed and to ensure that worker exposure is maintained as low as reasonably achievable. Surveys of the outdoor areas will be performed in order to confirm the locations of known contaminated soil and to identify any previously unknown contaminated soils.
Decontamination Several different techniques can be employed in decontamination of surfaces. These typically include wiping, washing, vacuuming, and water jets. The interior surfaces of piping systems can be decontaminated using various chemical solutions. The objectives of the decontamination effort are two-fold: First, to' reduce the radiation levels throughout the facility in order to minimize personnel expecure during dismantlement; and second, te clean as much material as possible to unrestricted use levels, thereby permitting disposal as salvage and minimizing the quantities of material that must be disposed of by burial as radioactive waste.
Present plans call for chemical dec'5ntamination of the RCS prior to dismantlement. Prior to performing the decontamination, an engineering evaluation will be performed in order to determine if the dose reduction obtained justifies the costs asscciated with the decontamination. Any decontamination method used will involve standard processes with well understood chemical interactions, and the resulting waste will be disposed of in accordance with plant procedures and applicable regulations.
I Major Decommissioning Activities 10 CFR 50.2 defines " major decommissioning activity" as any activity that results in parmanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than' Class C waste in accordance with 10 CFR 61.55. The
-major activities are summarized as follows:
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- Removal of the steam generators and the pressurizer. The external surfaces will be decontaminated as required, and all openings will I
I be seal-welded. These components will serve as their own disposal 4
containers.
1 1
- Segmentation of the upper and lower core support structures, and package segments in shielded casks.Several technically feasible 1
alternatives are available for removal of the reactor vessel and 3
the reactor internals. The vessel could be removed with the 1
internals intact and included, the internals could be segmented and the vessel removed separately, or both the internals and the vessel f
could be segmented. Maine Yankee believes that the radionuclides concentrations (due to neutron activation) may allow the
)
vessel / internals assembly to be disposed of as q
low-specific-activity waste. Final alternative selection will be j
based on an evaluation of activity levels, ease of execution, q
personnel exposure, schedule constraints, disposal facility availability, and cost.
j s
- Disassembly and segmentation of the remaining reactor internals, and package segments in shielded casks.1 1
- Greater than Class C (GTCC) components will be segmented as necessary for storage with the spent fuel (either in the spent fuel 1
pool or in dry shielded containers).
l
- Segment the reactor vessel, and place the segments into shielded 1
containers, or prepare the vessel for shipment intact.1
--Segment the neutron shield tank structure formerly surrounding
)
the reactor vessel, and place segments into shielded containers.
j
- Segment the RCS and other large-bor? piping, decontaminate and scrap or dispose of as appropriate considering the residual activity level.
- Modifications to the containment structure may be necessary to permit removal of large components. Interior surfaces may be damaged puring. decontamination activities (which require removal of
)
concrete to a depth of several inches). Demolition of the structure J
is considered to be a site restoration activity.
- Once all spent fuel is removed from the spent fuel pool, the j
spent fuel facility will be decontaminated and dismantled.
l Segmenting operations will be developed as appropriate for the various components and/or selected portions of the facility. These operations may include the use of remote cutting equipment, contamination control envelopes or other contamination barriers, and underwater cutting techniques. tegments may be placed in liners i
and stored using a remote or shielded crane. The liners would be l
loaded into shielded transport casks for disposal at a commercial shallow-land waste disposal facility. Packaged items meeting 10 CFR 61.55 Class C or less will be shipped and buried.
Other Decommissioning Activities Other decommissioning activities which do not meet the definition of amajor activities" include the following:
- A number of documents will be prepared and submitted by Maine Yankee as required by applicable regulations. These include the following:
- The Post-Shutdown Decommissioning Activities Report (PSDAR). This document fulfils the requirements of 10 CFR 50.82 (a) (4) (i).
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- A proposed change to the Technical Specifications will be
)j submitted by Maine Yankee. The non-operating status of the plant will be reflected in the revised Technical Specifications by deleting the Specifications pertinent to systems no longer needed, c.nd revising the administrative requirements, i
1
- A detailed, site-specific decommissioning cost estimate will be l
l submitted pursuant to 10 CFR 50.82 (a) (8) (iii).
- A license termination plan will be submitted pursuant to 10 CFR 50.82 (a) (9).
- The program by which Maine Yankee intends to manage, and provide funding for the management of, the irradiated fuel until title to
)
the fuel and possession of the fuel is transferred to the Secretary
)
of the Department of Energy, will be submitted pursuant to 10 CFR 50.54 (bb).
- Removal of low level waste. Radioactively contaminated or activated materials will be removed from the site as necessary to allow the site to be released for unrestricted access. LLW will be i
I processed in accordance with plant procedures and existing commercial options, and sent to licensed disposal facilities.
Wastes may be incinerated, compacted, or otherwise processed by authorized and licensed contractors as appropriate.
- Removal of mixed wastes. If mixed wastes are generated, they will be managed according to all applicable federal and state regulations to the extent they are not inconsistent with NRC i
handling, storage, and transportation regulations. Mixed wastes
{
from Maine Yankee will be transported only by autho..* zed and licensed transporters and shipped only to authorized and licensed facilities. Processes to render the mixed wastes nonhazardous will be evaluated if technology, resources, and approved processes are i
available, j
Storage of Spent Fuel Congress passed the " Nuclear Waste Policy Act" in 1982, assigning the responsibility for disposal of spent nuclear fuel created by i
the commercial nuclear generating plants to the Department of Energy (DOE). This legislation also created a Nuclear Waste Fund to cover the cost of the program, which is funded, in part, by the sale of electricity from the Maine Yankee plant (and an estimated equivalent for assemblies irradiated prior to April, 1983). The target date for startup of the federal Waste Management System was originally 1998.
The backlog of spent fuel in the national inventory, delays in site characterization, and intermittent progress in the development of a waste transportation system, make it necessary to reflect spent fuel storage in the cost and schedule of commercial reactor decommissioning. After several delays, DOE estimates that the i
geologic repository will be operational sometime between the years 2010 and 2015. For planning purposes, Maine Yankee has assumed that the high-level waste repository or some interim storage facility will be operational by 2010. There are currently 1432 spent fuel assemblies, and 4 cages containing fuel (consolidated assemblies, or failed rod holders) residing in the spent fuel pool. Interim storage of this fuel until DOE has completed the transfer is intended to be in an independent facility to be constructed at the l
Maine Yankee plant site in accordance with the requirements of 10CFR72. This will allow Maine Yankee to proceed with the decommissioning of the generating facility and the termination of j
its operating license in the shortest time possible.
The issue of storing spent fuel onsite is specifically addressed in 06/16/98 11:49:56 6 of 13 j
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10CFR51.23, which states, "The commission has made a generic determination that, if necessary, spent fuel generated in any reactor can be stored safely cnd without significant environmental impacts for at least 30 years beyond the licensed life for operation... of that reactor at its spent fuel storage basin or at either onsite or offsite independent epent fuel storage installations.... Accordingly... no discussion of any environmental impact of spent fuel storage in reactor facility storage pools or independent spent fuel storage installations (ISFSI) for the period following the term of the reactor operating license is required in any environmental report, environmental impact statement, environmental assessment, or other analysis prepared in connection with the issuance or cmendment of an operating license for a nuclear ceactor..."
Maine Yankee will continue to maintain and protect systems and crets critical to the storage of the spent fuel.
Final Site Survey and Termination of License l
Maine Yankee will prepare a License Termination Plan, which will include the details of the final radiological survey to be performed once the decontamination activities are completed. It is anticipated that the License Termination Plan will follow the guidance provided by NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination" (Reference 5]. This document delineates the statistical approaches to survey j
design and data interpretation used by the Environmental Protection Agency (EPA). It also identifies state-of-the-art, commercially available, instrumentation and procedures for conducting
{
radiological surveys. Use of this guidance ensures that survey I
design and implementation are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are j
catisfied. Once the survey is complete, the results will be provided to the NRC in a format that can be verified.
{
I Site Restoration Although not within the scope of NRC regulation, Maine Yankee is presently considering restoring the site to a condition comparable to-a natural state. This would be done in the following manner:
- Components and materials meeting NRC release criteria may be removed from the site and disposed of as scrap, as salvage, or at regional land fills,
- Decontaminated structures will be demolished and removed to an approximate depth of three feet below grade.
- The site will be back-filled with clean material, graded, and landscaped.
IV. SCHEDULE FOR DECOMMISSIONING ACTIVITIES Maine Yankee intends to pursue decommissioning by pronpt
' dismantlement. The schedule outlined below reflects this intention.
As discussed above, the actual schedule may differ in response to the availability of waste disposal facilities, economic resources or unforeseen circumstances.
Period 1 - Preparation / Planning Activities include site characterizations, engineering evaluations l
cnd planning, development of detailed procedures for dismantlement l
cad disposal, design and procurement of special tools, and site 7 of13 06/16/98 11:49:56
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l preparation activities. Maine Yankee intends to complete these
- cetivitiesfapproximately eight months following cessation of operations.
L Decontamination of components and piping systems as required to minimize worker exposure.
-1 Period 2 -; Decommissioning Operations and License Termination j
Preliminary activities such as the construction of temporary j
facilities (e.g., changing rooms, laydown areas, upgrading i
roadways), design and fabrication of special shielding and contamination control envelopes, modification of the refueling cavity to support the segmentation activities, and procurement of shipping containers and liners.
Removal of NSSS components as discussed above under the heading i
l:
" Major Decommissioning ~ Activities." These activities should be completed approximately three and a half years following cessation of operations.
.l Removal of the remaining plant systems and' components as they
.become nonessential to the decommissioning program or worker health I
and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems, etc.).
Removal of contaminated equipment and material from all contaminated areas until radiation surveys indicate that the structures can be released for unrestricted access and conventional demolition. Decontamination of remaining site buildings and facilities. Decontamination and dismantlement of the spent fuel pool and associated systems once the spent fuel is moved to an independent storage facility. These activities should be completed approximately five years following cessation of operations.
Final site survey and license termination, as discussed above under the heading " Final Site Survey and Termination of License." These ectivities should be completed approximately seven years following cessation of operations.
.1 Period 3 - Site Restoration
-Demolition of the remaining portions of the containment structure cnd-interior portions of the reactor building using. controlled blasting techniques. Removal.of remaining buildings and other site structures using conventional demolition techniques. Site areas affected by the dismantling activities will be cleaned and the plant area graded as required to prevent pending and. inhibit the refloating of subsurface materials. These activities should be completed approximately eight years _following cessation of operations.
Additional detail is included in the following. schedule.
- V. DECOMMISSIONING COST ESTIMATE
' Current Cost. Estimate - 1993 The current Maine Yankee decommissioning cost estimate was prepared by TLG Services Inc., a specialty contractor in the field, in 1993.
The methodology used by TLG to develop the decommissioning cost
. estimate follows the basic approach originally advanced by the l
Atomic Industrial Forum (now Nuclear Energy Institute) in their
" program to develop a standardized model for decommissioning cost estimates. The results of this program were published as AIF/NESP-036, AGuidelines for Producing Commercial Nuclear Power
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field experience.
The current decommissioning cost estimate was part of a FERC rate case settlement finalized in 1994 and is summarized in the following table. The distinctions between decommissioning costs, fuel storage costs and greenfield costs are not part of the current estimate. They represent approximations intended to clarify the discussion below.
It should be noted that the scope of previously performed cost estimates does not coincide with the scope of the estimate presented here. The definition of decommission used by the NRC is provided in 10 CFR 50.2: Decommission means to remove (as a facility) safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of license.
The Commission amplified this definition when it issued the decommissioning rule, by noting that:
Decommissioning activities do not include the removal and disposal of spent fuel which is considered to be an operational activity or the removal and disposal of nonradioactive structures and materials beyond that necessary to terminate the license. Disposal of nonradioactive hazardous waste not necessary for NRC license termination is not covered in detail by these regulations but would be treated by other appropriate agencies having responsibility over these wastes. [53 Fed. Reg. 24018,24019 (June 27, 1988]. Similarly, the generic EIS (Reference 1) notes that these non-rr.diological wastes are not covered by the EIS, but would be addressed by other agencies.
The estimate provided in Reference 1, therefore, does not include the costs associated with storing the spent fuel while waiting for the Depa'rtment.of Energy (DOE) to take possession of the stored materials; and it does not include the costs associated with l
restoring the site to a " green field" condition.
Updated Decommissioning Cost Estimate The detailed site-specific cost estimate required by 10CFR50. 82 (a) (8 ) (iii) will be prepared and submitted to the NRC prior to August 7, 1999. This updated decommissioning cost estimate i
l is currently being prepared by TLG utilizing a similar methodology I
as discussed above. Following appropriate internal review, the updated decommissioning cost estimate is expected to be presented to the FERC as part of a ratemaking case in approximately mid-October, 1997.
Although the magnitude is not clear, it is likely that the updated decommissioning cost estimate will exceed that presented in the 1993 study. Several factors may lead to an increase. For example, i
certain costs were not included in the 1993 study. The 1993 study I
included more optimistic assumptions about DOE's ability to take possession of spent fuel - assuming approximately 10 years of spent fuel storage at Maine Yankee vice the approximately 25 years of spent fuel storage that will be considered under the new cost estimate. Because of the relatively short fuel storage period, the 1993 study did not consider the more economical use of long-term dry cask storage. Therefore, the costs of siting, constructing and licensing an independent spent fuel storage facility for the dry cask storage of fuel must also be considered.
9 0f l3 06/1698 11:49:57
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http //serch.bechtel.co...eports/309/309psdar.txt http://serch.bechtel.com/ftp2/ inspect / reports /309/309psdar.txt Maina Ycnkso Summary of Decommissioning Costs (1)
(thousands of dollars)
Key Tasks / Milestone l'993 1997(2)
Plant DismantlementStaffing $100, 205 $119, 496LLW Burial $70, 189$83, 702 Equipment Removal $36, 373 $43, 375LLW Packaging and Shipping $11, 474 $13, 683 Decontamination Activities $5, 058$6, 032 Decommissioning Planning Activities $2, 981$3, 5550ther Costs (3) $4, 267 $4, 988 Subtotal $230, 547 $274, 932 Spent Fuel Management $44, 775 $53, 395 Site Restoration (Greenfielding)$41, 300 $49, 251 Total Decommissioning Estimate $316, 622 $377, 578 Notes:
(1)' Prompt decommissioning technique (DECON)
-(2) 1993 dollars escalated at 4.5% per year to 1997 dollars (3) Other costs such as insurance, property taxes, energy, NRC and State fees, etc.
VI. ENVIRONMENTAL IMPACTS 10 CFR'50.82 (a) (4) (1) describes the Post-Shutdown Decommissioning Activities Report (PSDAR), and requires that it include "a
' discussion that provides the reasons for concluding that the environmental impacts associated with the site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements." The following discussion provides our reasons for drawing that conclusion, based
.on three,previously issued documents: 1) Maine Yankee Atomic Power
. Station l Environmental Report, Supplement One, dated April 19, 1972 (Reference 4); 2) the Final Environmental Statement Related to Operation of Maine' Yankee Atomic Power Station, dated July 1972 (Reference 2]; and 3) NUREG-0586, " Final Generic Environmental Impact Statement (GEIS) on decommissioning nuclear facilities" (Reference 1].
First, it is-noted that decommissioning the Maine Yankee plant will have generally positive environmental effects, in that:
- Radiological sources that create the potential for radiation exposure to site workers and the public will be eliminated
- Decommissioning will return the site to a condition allowing a
unrestricted use
- Further, the Maine Yankee plant decommissioning will be
. accomplished with no significant adverse environmental impacts, in
!that:
- No Maine Yankee site specific factors would alter the conclusions of the GEIS or the earlier environmental report and statement
- Radiation dose to the public will be minimal
--Radiation dose to decommissioning workers will be a small fraction of the operating experience
- The' low-level radioactive waste removed from the site will occupy a.small burial volume at approved waste disposal sites I
l I
- 10 of 13.
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- The non-radiological environmental impacts are temporary and not significant i
The effects of decommissioning activities with respect to specific l
environmental issues are discussed briefly below.
)
l Radiation Dose to the Public Radiation dose to the public will be maintained below comparable levels when the plant was operating through the continued j
application of radiation protection and contamination controls combined with the reduced source term available in the facility.
l Occupational Radiation Exposure l
j Maine Yankee has estimated that a total of 9.46 person-Sv (946 l
person-rem) will be incurred during the decommissioning of Maine j
Yankee. This total includes the exposure from decontamination and dismantlement activities and the exposure during transportation of the low-level wastes.
NUREG-0586 [ Reference 1], Table 4.3-2, estimates a total dose of 12.15 person-Sv (1215 person-rem) for the DECON alternative for the j
reference plant. While the Maine Yankee decommissioning will delay the decontamination and dismantlement of selected plant areasThe spent fuel pool cannot be decommissioned until the spent fuel can be transferred into an independent storage facility, and the l
independent storage facility cannot be decommissioned until the DOE i
removes the spent fuel. until the DOE takes possession of the spent fuel, the plan closely resembles the DECON alternative of I
NUREG-0586. The 9.46 person-Sv (946 person-rem) total dose for the Maine Yankee decommissioning is below the 12.15 person-Sv (1215 person-rem) total dose that was found acceptable for decommissioning the reference PWR in the " Final Generic Environmental Impact Statement on decommissioning of nuclear facilit es," NUREG-0586 [ Reference 3].
Low-Level Radioactive Waste Burial Volume Maine Yankee estimates the low-level waste burial volume for immediate dismantlement as 209,000 cubic feet (or 5,920 cubic meters). The GEIS estimates the volume as 18,340 cubic meters. The Maine Yankee estimate assumes the use of present-day volume reduction techniques not credited in the GEIS. For high level waste requiring deep geological burial (greater than class C waste),
Maine Yankee astimates 227 cubic feet (or 6.5 cubic meters). The GEIS estimates the volume of high level waste as 88 cubic meters.
These estimates thus support the conclusion that the previously issued environmental statements are bounding, since the disposal of waste will require fewer resources (i.e.,
less waste disposal facility area) than considered in the GEIS.
Non-Radiological Environmental Impacts The non-radiological environmental impacts from the Maine Yankee decommissioning are temporary and not significant. The largest occupational risk associated with the decommissioning is the risk of industrial accidents. This will be addressed by adherence to work controls during decommissioning, similar to the procedures followed during power operation. Procedures controlling work related to asbestos, lead, and other non-radiological hazards will also remain in place during the decommissioning. The primary environmental effects of the decommissioning are temporary, small increases in noise levels and dust in the immediate vicinity of the 11cf13 06/16/98 11:49:57
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Additional Considerations While not quantitative, the following considerations are also relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed.
The release of effluents will continue to be controlled by plant procedures throughout the decommissioning. With respect to radiological releases, Maine Yankee will continue to operate in accordance with the Offsite Dose Calculation Manual (ODCM) during the decommissioning activities. Releases of non-radiological offluents will continue to be controlled per the requirements of the NPDES and State of Maine permits. Systems used to treat or control effluents during power operation may be replaced by temporary or mobile systems as the decommissioning proceeds.
Radiation protection principles used during plant operation will remain in effect during decommissioning to ensure that protective techniques, clothing, and breathing apparatus are used as appropriate.
Sufficient decontamination prior to dismantlement will be performed to ensure that individual and integrated doses will not exceed those estimated in the final generic environmental impact statement.
Detailed site radiologic surveys will be performed following cessation of operation to confirm the burial volume of low-level radioactive waste, and highly activated components which require l
deep geological disposal.
1 l
Detailed site radiologic surveys will be performed following cessation of operation to identify the requirements for decontaminating the ground surrounding the plant.
Transport of radioactive waste will be in accordance with plant l
procedures, applicable federal regulations, and the requirements of l
the receiving facility.
Plant ventilation systems (or alternate, temporary systems) will be maintained as long as needed in the areas they service.
Site access control will be maintaihed during decommissioning to ensure that residual contamination is minimized or eliminated as radiation pathways to the public during decommissioning.
Conclusion Based on the above, Maine Yankee concludes that the environmental impacts associated with the site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements. Should unforeseen circumstances arise that may challenge a bounding environmental impact, Maine Yankee will seek prior NRC review and approval before proceeding.
REFERENCES
- 1. NUREG-0586, " Final Generic Environmental Impact Statement on 12 of13 06/16/98 11:49:57
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Decommissioning of Nuclear Facilities," dated August, 1988
~2.
" Final Environmental' Statement related to operation of Maine Yankee Atomic Power Station," dated July 1972
- 3. MN-97-89, MY Letter to NRC,." Certifications of Permanent Cessation of Power Operation and Permanent Removal of Fuel From the Reactor," dated 8/7/97
- 4. Maine-Yankee Atomic Power Station Environmental Report, Supplement One, dated April 19, 1972 (MYAPC to AEC)
- 5. NUREG/CR-5849,'" Manual for Conducting Radiological Surveys in Support of License Termination."
- 6. AIF/NESP-036, " Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates"
- END FILE ***
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i 13 cf13 06/16/98 11:49:57 l
Response to NDFC 98-1 DR 4.16 (CRR/Backus):
Question / Request:
With regard to the plants using Westinghouse Model F steam generators with thermally treated Inconel 600 tubes listed in the response to DR 3.3, please provide the following:
A. The years of commercial operation of each of the reactors.
B. The current status of tube degradation from any source in the steam generators l
in these reactors detected to date, including number of plugged tubes and number with existing cracking or wall thinning.
i
Response
A. The dates for commercial operation for the plants in the United States with thermally l
treated Inconel 600 tubes was provided in the response to DR 1.1 (listing of all operating commercial nuclear power plants). KORI Unit 2, a Korean plant, went into l
commercial operation ~in July 1983.
B. EPRI maintains a database of steam generator tube degradation history for nuclear power plants in the United States and abroad. Data is reported through year end 1996 l
in the following categories:
l
- 1. Wastage and thinning of the tube wall
- 2. Denting at support plate intersections
- 3. Denting at and above the tubesheet
- 4.
- Pitting
- 5. Secondary side stress corrosion and/or intergranular attack at support plate locations
- 6. Secondary side stress corrosion and/or intergranular attack at tubesheet locations
- 7. Primary side stress corrosion cracking at tubesheet locations
- 8. Primary side stress corrosion cracking at U-bend locations
- 9. Tube fretting and wear at preheater locations
- 10. Tube fretting and wear at Anti-Vibration Bar (AVB) locations
- 11. Tube fretting and wear due to loose parts or foreign objects i
- 12. High cycle fatigue
~
13.Cause other than those above or cause unknown (examples include tube damage from manufacturing process, scratches, burrs, erosion, or various defects or inspection indications that can't clearly be put into one of the L
categories above). This category also typically includes tubes plugged for l
vanous reasons before the units went into operation.
i t
(
6/19/98-1
!~
0
' Seabrook Station:
1 The most recent inspection results for Seabrook Station's steam generators were provided in the response to DR 4.8. The only tube plugging has been for fretting and wear at anti-vibration bar locations or the reasons under "other". A total of 48 tubes have been
. plugged to date for the Seabrook Station steam generators. This total includes 11 tubes that were plugged before the unit went into operation. No tubes have been sleeved.
Millstone 3:
A total of 39 tubes have been plugged,28 for item 10 (anti-vibration bar wear) and 11 for item 13 (other). The total includes 5 tubes plugged before the unit went into operation.
No tubes have been sleeved.
I
.WolfCreek:
A total of 93 tubes have been plugged,75 for item 10 ( anti-vibration bar wear) and 18 for item 13 (other). The total includes 15 tubes plugged before the unit went into operation.' No tubes have been sleeved.
D t.
Vogtle 1:
- A total of 31 tubes have been plugged,9 for item 10 (anti-vibration bar wear) and 22 for item 13 (other). The total includes 6 tubes plugged before the unit went into operation, go tubes have been sleeved.
Vogtle 2:
1 A total of 24 tubes have been plugged, 8 for item 10 (anti-vibration bar wear) and 16 for
' item 13 (other). The total includes 15 tubes plugged before the unit went into operation.
No tubes have been sleeved.'
KORI Unit 2:
- A total of 253 tubes have been plugged; I for item #4 (pitting),130 for item #6 (secondary side stress corrosion and/or intergranular attack at tubesheet locations), 80 for
' item #10 (anti-vibration bar wear), and 9 for item #13 (other). The total includes 27 tubes plugged before the unit went into operation. In 1988 2 tubes were sleeved.
6/19/98 2
L
n'c Response to NDFC 98-1 DR 4.17 (CRR/Backus):
t.
i Question / Request:
In regard to Questions DR 4.10 and 4.11 that " North Atlantic does not have any information on how these funding schedules, if adopted, would impact the rates for either PSNH or the New Hampshire Electric Cooperative," please provide the rate impact as best as it can be determined. (CRR is aware that NAESCO is the operator of Seabrook, and not a utility selling at retail. However, it is CRR's understanding that NAESCO is acting as the operating agent on behalf of the joint owners, including an NU subsidiary now owning the share formerly owned by PSNH, and NHEC. Therefore, it is CRR's opinion that NAESCO should be able to get a response to this question, as originally sought, in order to provide information important to the Committee, and the parties.
Therefore, by this request, CRR renews its original request and presses for an answer.)
Response
The annual funding requirements and rate impact estimates for the base case (years 1999 through 2015 only) and for the two accelerated funding scenarios in DR 4.10 and 4.11 for North Atlantic Energy Corporation and the New Hampshire Electric Cooperative are provided in the following tables. This information was provided to North Atlantic by Public Service of New Hampshire and the New Hampshire Electric Cooperative.
M 6/19/98 1
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