NUREG/CR-5884, Forwards Comments on Pnl Analysis of Decommissioning for Pwr,Draft NUREG/CR-5884

Forwards Comments on Pnl Analysis of Decommissioning for Pwr,Draft NUREG/CR-5884

ML20128C951
Person / Time
Issue date:	01/27/1993
From:	Weiss S Office of Nuclear Reactor Regulation
To:	Cool D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
References
RTR-NUREG-CR-5884 NUDOCS 9302040226
Download: ML20128C951 (5)

Text

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January 27, 1993 MEMORANDUM FOR: Donald A. Cool, Chief Radiation Protection and Health Effects Branch Office of Nuclear Regulatory Research FROM: Seymour H. Weiss, Director Non-Power Reactors and Decommissioning .

Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation

SUBJECT:

REVISED PNL ANALYSIS OF DECOMMISSIONING FOR THE REFERENCED PRESSURIZED WATER REACTOR NUREG/CR-5884 (DRAFT)

As requested in your December 14, 1992 memo, we have reviewed the above referenced document prepared by your contractor, PNL, and are providing-the i

enclosed comments. These comments were generated in a joint effort between my i

staff and Robert Wood of ILPB. While we believe that PNL is proceeding in the right direction with the decommissioni.;g study update, there are many areas where improvements are needed. As these studies will serve as the bases for. ,

revising the funding requirements of 10 CFR 50.75(c), we must ensure that proper consideration is given to the questions and issues raised in recent r decommissioning cases. ONDD remains ready to assist you in any capacity to ensure useful information is gained from the PNL decommissioning studies. The staff contact is Richard Dudley, 504-1116.

ShSklki.Ns,$/irector Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation

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[ WA6HINGTON, D.C. 20b2 ko , , , , , gl' January 27, 1993 MEMORANDUM FOR: Donald A. Cool, Chief Radiation Protection and Health Effects Branch Office of Nuclear Regulatory Research FROM: Seymour H. Weiss, Director .

Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation

SUBJECT:

REVISED PNL ANALYSIS OF DECOMMISSIONING FOR THE REFERENCED PRESSURIZED WATER REACTOR NUREG/CR-5884 (DRAFT)

As requested in your December 14, 1992 memo, we have reviewed the above referenced document prepared by your contractor, PNL, and are providing the enclosed comments. These comments were generated in a joint effort between my staff and Robert Wood of ILP8. While we believe that PNL is proceeding in the right direction with the decommissioning study update, there are many areas where improvements are needed. As these studies will serve as the bases for revising the funding requirements of 10 CFR 50.75(c), we must ensure that proper consideration is given to the questions and issues raised in recent decommissioning cases. ONDD remains ready to assist you in any capacity to-i ensure useful information is gained from the PNL decommissioning studies. The-I staff contact is Richard Dudley, 504-1116.

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• %) e b Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support

,. Office of Nuclear Reactor Regulation L

Enclosure:

As stated P

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GENERAL COMMENT

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1. PNL's cost estimates do not consider the cost of capital and present value-of money, nor does PNL explain why consideration is not given for these factors. in a note dated February 28, 1992, we recommended to RES-that PNL include the cost of money when comparing the costs of the various decommissioning alternatives, and provided a copy of the testimony of Dr. David Rosenbaum from a hearing before the Arizona Commission on the Palo Verde plants. The relative cost of the Extended SAFSTOR with '

Deferred Dismantlement option may be significantly reduced, and perhaps lower than the SAFSTOR with Deferred Dismantlement option if the time  ;

value of money is properly considered. Additionally, the security staff estimates on page E.12 contain suspect information (discussed.in detail in the specific comments below). The failure to include consideration of-the cost of money and the suspect security staffing estimates may bias the cost estimates against the Extended SAFSTOR alternative.

2. The results of the PNL revised analysis do .10t appear to be consistent with site-specific studies performed for recently shut down power reactors and operating plants. Although a large component of the cost differences may be explained by low level waste burial charges, spent fuel storage costs, and greenfield expenses, cost differences still remain after these are considered. PNL may be correct in its conclusions, but to enhance the credibility of this report, it should at least address some of. the site- 1 specific studies and offer reasons for these differences.

Sensitivity analyses of the effects of various assumptions.used in the PNL and other studies should=be performed. For example, as suggested by RES, PNL should examine in greater detail- the costs of removing '

concrete to various depths. PNL's revised analysis indicates that less conservative assumptions about concrete removal depth helps to lower overall decommissioning cost estimates from what otherwise might have been expected. PNL should also show the effect that varying LLW disposal-cost has on overall decommissioning costs.

3. We disagree with RES that Chapter 4 should be deleted. Since NRC regulations and other aspects of the regulatory environment can have significant impact .on decommissioning costs, a general reference to NRC

• decommissioning policies would be useful. Decommissioning cost analysts might find it easier to incorporate. regulatory considerations in their-evaluations if there is a ready reference to use.

The NRC is undertaking a major' review of its current' decommissioning regulatory process and therefore it is likely that some process ~ changes -

I may occur in the near future. Consequently, the scope of Chapter _4 g

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should be reduced such that a general overview of the current NRC '

decommissioning process is presented. More detailed comments on Chapter 4 are presented in the Specific Comments section below and should be addressed when condensing this chapter. -

4. The plant specific decommissioning experience contained in Chapter 3 requires updating. We will provide RES with the updated information by February 15, 1993.

5. Due to the uncertainties related to fuel disposition for licensees in decommissioning, we believe it would be useful for PNL to extract from their cost data, annual SAFSTOR cost estimates for fuel maintained in the fuel pool and fuel maintained in an onsite ISFSI.

6. The PNL study assumes offsite nuclear liability-insurance is maintained  ;

until termination of a plants possession only license. Some licensees of permanently shut down facilities have requested substantial reductions in the required primary level of liability insurance (currently $200 million) and to be eliminated from the secondary level of liability insurance

($63 million risk sharing pool). The Commission is reviewing these requests and may issue guidance which will allow substantial reductions in the primary level of insurance and/or elimination from participation in  ;

the secondary level of insurance for permanently shut down licensees holding a possession only license. Consequently, PNL should include a consideration of the effect that a substantial reduction in the reouired primary level of insurance would have on the costs of the three decommissioning alternatives.

SPECIFIC COMMENTS Page 2.1 Cost and radiation dose figures are provided for 3 decommissioning alternatives. The revised analysis should clarify that the cost figures do not include a dollar value for man-rem doses. Also, it would be helpful to include a sensitivity analysis of the effect on cost of a value of $1000/ man-rem.

Also, PNL indicates that a reactor must be disabled before a POL can be issued. That is incorrect. There is no requirement to " disable" a -eactor for POL issuance or -for any other stage of the decommissioning process. The use of gravel in the reactor vessel to disable the Pathfinder reactor was apparently done to allow -

conversion from a Part 50 license to a byproduct Part 30 license, but this resulted in an expensive problem during final decommis-sioning. The new decommissioning rule does not allow the conversion of a Part 50 license to a Part 30 license and there. is no logic in destroying components to " disable" the reactor.

Page 2.2 PNL indicates that the fuel would be removed from the pool'to dry storage. While this may-be done by some utilities, most utilities

• currently in SAFSTOR have chosen to leave the fuel in the spent fuel pool until DOE accepts it. The revised analysis should also consider this scenario,

Page 2.3 PNL should include our criteria for direct radiation of 5 microR/hr above background at one meter for gamma emitting radionuclides with an overall dose objective of 10 millirem per year (staff requirements memorandum dated April 6, 1992, page 3. " Action Plan to Ensure Timely Remediation of Sites Listed in the Site Decommissioning Managemcnt Plan"). Regulatory Guide 1.86 is applicable to surface contamination only, not the activated steel or cor: rete near the reactor core. The NRC has consistently used this direct radiation criteria for all research and power reactor decommissioning since 1982.

Page 4.16 The discussion concerning annual fees is incomplete. After a POL has been granted, a licensee is no longer assessed annual fees.

Hourly fees remain, however, for plant specific licensing actions.

Accordingly, PNL should ensure that annual fees are not factored into their cost estimates.

Page 4.21 The discussion in the first paragraph on the " case-by-case" rule needs to be revised to reflect that the rule is now effective.

Additionally, the discussion concerning the use of an "A" bond rating is inaccurate. The final rule 57 FR 30385) explains the additional criteria that the NRC would(consider if a facility's bond rating fell below "A" so that funding into the storage period could continue.

Page 5.4 The discussion on Trojan needs to be updated.

Page E.12 Table E.4. assumes that all spent fuel has been transferred to 00E, therefore, there is no NRC requirement for security patrolman or security shift supervisors. With no fuel onsite, Regulatory Guide 1.86 Section C.3 and NRC practice clearly allows access .

control of the residual radioactivity with multiple locked barriers, welded closures, concrete shielding material and intrusion alarms. The cost could therefore be reduced by about $400,000 per.

year.

Page E.16 PNL concludes fthere is no significant cost driver to encourage use of this (extended SAFSTOR) alternative." Will the estimates of' Table E.4 (see above comment on Page E.12) when corrected, demonstrate a cost advantage of extended SAFSTOR7 What about the-t major reduction in waste volume by decay (supported by PNL data on

' page E.16)7 PNL also concludes, "The viability of this scenario duends entirely upon the premise that the contaminated material (not activated) will decay to levels of radioactivity that satisfy the criteria for unrestricted use (0.002 mrem /hr) as given in Regulatory Guide 1.86, by the end of the 60-year period following reactor shutdown." Extended SAFSTOR viability does not " depend i

entirely" on that premise (see Page E.12 discussion above). Also l 0.002 mrem /hr (2.0 microrem/hr) is DR1 consistent with. current release criteria.

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q Page E.17-Table E.6. bases its cost estimates on the cost projections of Table E.4 above. Thus, any changes made to Table E.4 must also be made to Table E.6.

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