31 Jan 2012

THE HIDDEN COSTS OF NUCLEAR GENERATION I guess it took the Fukushima Triple Meltdown to awaken the world to the realities of Nuclear Power. There are many nations all over the world today facing the stark reality that “DECOMMISSIONING A NUKE” is not as simple as turning off a switch, or the lights out at each site. Best-laid plans for this expensive, dangerous and fuzzy process exist. It is even difficult to define exactly what it means.  One thing is clear: It is a very expensive process for which few countries(if any) have a Reserve Fund really available – Including the USA.  The $25B Fund supposedly held by the US treasury for that purpose has disappeared, and apparently no one knows where it is.  There is a rumor that it went into our National General fund, but no one will say for sure.  Do you think we borrowed from “Peter to Pay Paul“ ? I hope so! – It could be worse if some one absconded our $25Billion.  It is pitiful!  Nothing shocks me anymore!

MONEY, MONEY, MOONY!! That is the reason most “Nuclear countries” want to “Kick the can down the road” by extending reactor life by at least 20 years. If successful (as Japan and France want), they stand to continue to profit immensely at the world’s public risk of Nuclear Disaster.  Among such countries are France, Sweden, Russia, Japan, Ukraine(site of Chernobyl) an many others. We are waiting for Japan’s official stance on denuclearization soon.

I say: It is time to smell the coffee and begin to plan how, and how soon to address Nuke Decommissioning.  Failure to do so augurs more Chernobyl’s and Fukushima’s throughout the world.  Let us see what the USA-NRC best-laid of plans says:

NUCLEAR POWER PLANT(NPP) DECOMMISSIONING **********************************************************

When a power company decides to close its nuclear power plant permanently, the facility must be decommissioned by safely removing it from service, and reducing residual radioactivity to a level that permits release of the property and termination of the operating license. The USA-Nuclear Regulatory Commission (NRC) has strict rules governing nuclear power plant decommissioning, involving cleanup of radioactively contaminated plant systems and structures, and removal of the radioactive fuel. These requirements protect workers and the public during the entire decommissioning process and the public after the “license is terminated” KAPUT!

THREE (3)TYPES OF NPP DECOMMISSIONING:  Nuke owner(licensee) may choose from: DECON, SAFSTOR, or ENTOMB.

1.  DECON (immediate dismantlement), soon after the nuclear facility closes, equipment, structures, and portions of the facility containing radioactive contaminants are removed or decontaminated to a level that permits release of the property and termination of the NRC license.

2. SAFSTOR, often considered “delayed DECON,” a nuclear facility is maintained and monitored in a condition that allows the radioactivity to decay; afterwards, it is dismantled and the property decontaminated.

3. ENTOMB, radioactive contaminants are permanently encased on site in structurally sound material such as concrete and appropriately maintained and monitored until the radioactivity decays to a level permitting restricted release of the property. To date, no NRC-licensed facilities have requested this option.  In the Ukraine, CHERNOBYL was entombed in concrete 25 years ago.  Even so, in 2011 Russia asked the world (and received) one Billion to re-“Entomb” the plant with concrete.  It seems it had began to show serious cracks all over. The Japanese too are beginning to acknowledge that it is near impossible to  keep Godzila underground for long.  Uncontrolled radiation is pure hell! It goes where it wants to go.

4. OPTIONAL COMBO The licensee may also choose to adopt a “combination of “DECON, AND SAFSTOR”  in which some portions of the facility are dismantled or decontaminated while other parts of the facility are left in SAFSTOR. The decision may be based on factors besides radioactive decay such as availability of waste disposal sites. (TO MUDDY-UP THE WATER)

APPLICABLE NRC REGULATIONS (REGS) The requirements for decommissioning a nuclear power plant are set out in NRC Reg (Title 10 of the Code of Federal Regulations, Part 20 Subpart E, and Parts 50.75, 50.82, 51.53, and 51.95). In August 1996, a revised rule went into effect that redefined the decommissioning process and required owners to provide the NRC with “early notification” (HOW SOON IS EARLY ?) of planned decommissioning activities. The rule allows no major decommissioning activities to be undertaken until after certain information has been provided to the NRC and the public.

USA-NRC ESCAPE CLAUSE FOR NUKE OWNERS: To be acceptable, decommissioning must be completed within 60 years of the plant ceasing operations. A time beyond that would be considered only when necessary to protect public health and safety in accordance with NRC regulations.

OPPORTUNITY FOR PUBLIC INVOLVEMENT Several opportunities are provided for public involvement during the decommissioning process. A public meeting is held in the vicinity of the facility after submittal of a “Post-Shutdown Decommissioning Activities Report (PSDAR)” to the NRC. Another public meeting is held when NRC receives the License Termination Plan (LTP). 

LTP AMENDMENTS  A public hearing is provided prior to issuance of a license amendment approving the LTP or any other license amendment request. In addition, when NRC holds a meeting with the licensee, members of the public may observe the meeting (except when the discussion involves proprietary, sensitive, safeguards, or classified information); THAT IS THE FLY IN THE OINTMENT!  THE NPP OWNERS GET TO WRITE THEIR OWN TICKET!

PHASES OF DECOMMISSIONING: The requirements for NPP decommissioning activities are:

(1) Initial activities

(2) Major decommissioning and storage

(3) License termination

1. INITIAL ACTIVITIES: When a nuclear power plant licensee shuts down the plant permanently, it must (a) Submit a written certification of permanent cessation of operations to the NRC within 30 days. (b)When radioactive nuclear fuel is permanently removed from the reactor vessel, the owner must submit another written certification to the NRC, surrendering its authority to operate the reactor or load fuel into the reactor vessel. This eliminates the obligation to adhere to certain requirements needed only during reactor operation. (c )Within two(2) years after submitting the certification of permanent closure, the licensee must submit a  “Post-shutdown Decommissioning Activities Report (PSDAR)” to the NRC. This report provides a description of the planned decommissioning activities, along with a schedule for accomplishing them, and an estimate of the expected costs. The PSDAR must discuss the reasons for concluding that environmental impacts associated with the site-specific decommissioning activities have already been addressed in previous environmental analyses. Otherwise, the licensee must request a license amendment for approval of the activities and submit to the NRC a report on the additional impacts of decommissioning on the environment. (d) After receiving a PSDAR, the NRC publishes a notice of receipt in the Federal Register, makes the report available for public review and comment, and holds a public meeting in the vicinity of the plant to discuss the licensee’s intentions.

2. MAJOR DECOMMISSIONING AND STORAGE (ACTUAL BEGINNING OF DISMANTLEMENT) May begin 90 days after the NRC receives the PSDAR.  the NPP owner can begin major decommissioning activities without specific NRC approval. These could include permanent removal of such major components as the reactor vessel, steam generators, large piping systems, pumps, and valves.  However, decommissioning activities conducted without specific prior NRC approval must not prevent release of the site for possible unrestricted use, result in there being no reasonable assurance that adequate funds will be available for decommissioning, or cause any significant environmental impact not previously reviewed.  If any decommissioning activity (Licensee) does not meet these terms, the licensee is required to submit a “License amendment request”, which would provide an opportunity for a public hearing.

3. LICENSE TERMINATION The owner is required to submit a License Termination Plan(LTP) within two(2) years of the anticipated license termination. The plan addresses each of the following: (a) site characterization, (b)identification of remaining site dismantlement activities,  (c)plans for site remediation, (d)detailed plans for final radiation surveys for release of the site, (e)method for demonstrating compliance with the radiological criteria for license termination, (f)updated site-specific estimates of remaining decommissioning costs, and (g)a supplement to the environmental report that describes any new information or significant environmental changes associated with the owner’s proposed termination activities.  Most plans envision releasing the site to the public for unrestricted use, meaning any residual radiation would be below NRC’s limits of 25 millirem annual exposure and there would be no further regulatory controls by the NRC. Any plan proposing release of a site for restricted use must: (a) describe the site’s end use, (b) documentation on public consultation, (c) institutional controls, and financial assurance needed to comply with the requirements for license termination (d) for restricted release, The LTP requires NRC approval of a license amendment. Before approval can be given, an opportunity for hearing is published and a public meeting is held near the NPP plant site. The NRC uses a standard review plan – NUREG-1700, “Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans” to ensure high quality and uniformity of LTP reviews. The standard review plan is available to the public, so that NRC’s review process is understood clearly.  IF the remaining dismantlement has been performed in accordance with the approved LTP, and the termination survey demonstrates that the facility, and site are suitable for release, the NRC issues a letter terminating the operating license.

FUNDING OF DECOMMISSIONING EXPENSES Initially, the owner can use up to 3 % of its funds set aside for decommissioning planning.  An additional 20 % can be used 90 days after submittal of the PSDAR. The remaining “decommissioning trust funds” are then available when the owner submits a detailed “site-specific” cost estimate to the NRC. Each nuclear power plant licensee must report to the NRC every two(2) years the status of its decommissioning funding for each reactor, or share of a reactor that it owns. The report must estimate the minimum amount needed for decommissioning by using the formulas found in Reg.10 CFR 50.75(c). Licensees may alternatively determine a “site-specific” funding estimate, provided that amount is greater than the generic decommissioning estimate.

ESTIMATED DECOMMISSIONING COSTS Although there are many factors that affect reactor decommissioning costs, generally range from $300 million to $400 million. (SUCH FIGURES ARE CLEARLY VERY, VERY LOW IN TODAYS WORLD, AND SUBJECT TO REMEDIATION INCREASES ON SPECIFIC SITES) Approximately 70 % of licensees are authorized to accumulate decommissioning funds over the operating life of their plants. EXCEPTIONS TO THE RULE : The owners – generally traditional, rate-regulated electric utilities, or indirectly regulated generation companies – are not required today to have all of the funds needed for decommissioning. The remaining licensees must provide financial assurance through other methods such as prepaid decommissioning funds and/or a surety method or guarantee. The staff performs an independent analysis of each of these reports to determine whether licensees are providing reasonable “decommissioning funding assurance” for radiological decommissioning of the reactor at the permanent termination of operation. Before a NPP begins operations, the licensee must establish, or obtain a financial mechanism – such as a trust fund, or a guarantee from its parent company – to ensure that there will be sufficient money to pay for the ultimate decommissioning of the facility.

“SPENT FUEL” DISPOSAL PROVISIONS (ENTER: ISFSI’s).  Several NPPs completed decommissioning in the 1990s, without a viable option for disposing of their spent nuclear fuel, because the federal government did not construct a geologic repository as planned. Accordingly, the NRC implemented regulations allowing licensees to sell off part of their land once it meets NRC release criteria, while maintaining a small parcel under license for storing the spent fuel. These stand-alone facilities, called Independent Spent Fuel Storage Installations(ISFSIs)”, remain under license and NRC regulation. Licensees are responsible for their security, and for maintaining insurance and funding for eventual decommissioning.

CONTAMINATION AND DECOMMISSIONING “LESSONS LEARNED” As more facilities complete decommissioning, the NRC is implementing “lessons learned” in order to improve the program and focus on the prevention of future legacy sites. Applications for new reactors must now describe how design and operations will minimize contamination during the plant’s operating life, and facilitate eventual decommissioning. The agency is developing new regulations that will require plant operators to be more vigilant in preventing contamination during operations, and cleaning-up and monitoring any contamination that does occur.

USA-NRC REPORTS 23 REQUESTS FOR DECOMMISSIONING From Oct 1967 to 2011.  Only three(3) Licensees have obtained an NRC letter terminating the operating license.  “Pathfinder”(1967), Saxton (1972), and “Shoreham” (1989).  Seven (7) NPPs are still in Independent Spent Fuel Storage Installations(ISFSI) You know! – what do we do with this “spent fuel” crap! ).  The remaining 13 NPPs, are in one of the other tree(3) stages of decommissioning.  DECOMMISSIONING IS NOT A PROCESS NPP OWNERS LIKE AT ALL! – Of course not – it costs them money.  This is one well meaning plan by the NRC that will bear questionable fruits in the future given the impasse at the USA-NRC today.  Their source is linked below.

Edward Oliver Gonzalez (gonzedo)

P.S. Please excuse my extensive use of acronyms on this article.  It would be too long without them. This post has received more comments than any other by a long shot.