DECOMMISSIONING IS INEVITABLE: PLANNING SOONER RATHER THAN LATER CAN HAVE BIG PAYOFFS FOR NUCLEAR POWER PLANTS AND UTILITIES

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1 DECOMMISSIONING IS INEVITABLE: PLANNING SOONER RATHER THAN LATER CAN HAVE BIG PAYOFFS FOR NUCLEAR POWER PLANTS AND UTILITIES ABSTRACT Michael C. Kirkland, Stephanie Weisband Vector Resources, Inc. It is inevitable that every nuclear facility must one day be retired and safely decommissioned. One of the conditions imposed by the United States Nuclear Regulatory Commission (NRC) when it issues a commercial nuclear plant-operating license is that the licensee commit to decommissioning the plant after it shuts down. Utility owners tend to postpone decommissioning decisions until after a decision is made to terminate the reactor s operating license. This paper puts forth a concept to perform meaningful and significant decommissioning planning while the reactor is still operating as a cost reduction and decommissioning schedule improvement initiative. Justification for early decommissioning planning as well as a scope of work for the planning effort is provided. Decommissioning costs are large and often exceed the reactor s initial construction cost. The NRC initially licenses reactors to operate for 40 years and many of these plants are nearing the end of their licensed period. For many of these plants, decommissioning is looming on the horizon. Although some utilities are applying for operating license extensions, deregulation and economic considerations could have more of an effect on life expectancies of nuclear plants than aging. Decommissioning should be considered as an integral and important part of a nuclear plant s life cycle management. Planning for decommissioning should begin before a decision is made to shut down the reactor. Decommissioning planning, if initiated well before plant shutdown, will not only reduce the life cycle costs of the facilities, but also improve the quality of the planning effort and shorten the decommissioning schedule. Since decommissioning is a reality that faces every commercial reactor, prudent management dictates that reactor owners make decommissioning planning part of normal reactor operations and reduce the overall cost to the ratepayers. INTRODUCTION Decommissioning is a reality that faces every commercial reactor. Today, there are over 100 commercial power reactors operating in the United States, and these facilities are aging. No new reactors have been ordered since the late 1970 s. The United States Nuclear Regulatory Commission (NRC) initially licenses reactors to operate for 40 years; therefore, many reactors are nearing the end of their licensed period. This licensing period by itself shows that without modifying factors, the commercial nuclear industry in the United States has begun to face a wave of decommissioning activity. Based on an assumed 40-year license life, Figure 1 shows the number of commercial nuclear reactors in the United States that face license expiration and potential shutdown per year through 2036 (1).

2 26 24 Number of Licenses Scheduled To Expire Year Fig. 1. Operating License Expiration Schedule for U.S. Commercial Reactors Two key factors, however, have altered the time when power reactors permanently shut down: economics of power generation in an electricity market undergoing deregulation and license renewal. In December 1991, the NRC issued under the Code of Federal Regulations (CFR), Title 10, Part 54 Requirements for Renewal of Operating Licenses for Nuclear Power Plants. This rule describes what must be done to demonstrate that a commercial power reactor can continue to be operated for up to an additional 20 years beyond the expiration of the original 40 year license. The NRC issued an amendment to this rule (60 FR 22491, May 8, 1995) to provide for a more stable and predictable regulatory process. Additional guidance documents were issued through the mid 1990 s to provide further detail and support regarding actions required for this license extension. Several reactors have submitted applications for license extension, and others have indicated the intent to pursue this option. Operating license extensions could postpone decommissioning for some reactors, however there are other factors that may determine the shutdown date for these and other reactors. Deregulation is an important issue that utilities are facing and may cause some less efficient nuclear plants to be shut down due to competition from other energy sources. Many states and other countries have completed or are in the process of deregulating the electric power utilities within their jurisdiction, which may include nuclear power plants. Utility deregulation, following the practice within the airline, rail, and telecommunications industries within the United States, typically provides consumers with increased choices in their provider of

3 electricity, and the promise of reduced costs for a kilowatt of electricity. This transition forces each electric generation asset to be viewed as an individual profit center, rather than on the historic regulated basis of cost of operation plus regulated profit. When placed under this economic microscope, some commercial power reactors did not withstand the test and were permanently shut down prior to the expiration of the 40-year license. Additional power reactors may shut down in the future for the same reason (2). In addition to deregulation issues that reactor owners are facing, some plants may require significant repairs, upgrades, and equipment replacement to avoid problems and failures that many plants have experienced in the past. The conditions of aging reactor facilities may affect future license extension decisions and may even result in decisions to shut down reactors before the initial operating license expires. As an example, Trojan, owned by Portland General Electric, was permanently shut down in 1993 for economic reasons. Currently, most decommissioning planning is accomplished in accordance with CFR, Title 10, Part 50 after the decision is made to shut down a reactor. That timing and sequence of decisions places a large burden on the reactor owners regarding decommissioning options. Utility owners may be forced into some decommissioning decisions by expediency rather than applying a systematic planning methodology to reach decisions based more on optimization of the entire decommissioning process. Decades ago, when commercial reactors were designed and constructed, decommissioning was not considered a high priority and very little planning for decommissioning occurred as part of the life cycle of the reactor. Reactor decommissioning is inevitable and there are prudent actions that could be taken now to streamline the decommissioning effort, reduce decommissioning costs and schedule, and improve some safety aspects of the decommissioning. Decommissioning costs are staggering and because of their magnitude warrant full management attention throughout the life of the reactor. Some early commercial reactors cost between $20 million and $100 million to construct. Today s costs of decommissioning nuclear reactors can be as high as $500 million and often exceed by several times the initial construction cost of the early reactor facilities. For instance, Yankee Rowe was a small reactor that began operations in 1960 and was permanently shut down in the early 1990 s after 31 years of operation. Yankee Rowe cost less than $40 million to construct and decommissioning costs apparently will exceed $400 million. Reactors such as Big Rock Point and Maine Yankee are other examples where decommissioning costs will exceed original construction costs. With rising decommissioning costs there are concerns that nuclear reactor decommissioning funds will not cover actual decommissioning costs for reactors that will undergo decommissioning in the near future. Decommissioning funds of many utilities are substantially underfunded and, at this time, are not large enough to cover the current cost of decommissioning. Dramatic decommissioning cost saving actions will be required to ensure that commercial plants don t become a liability to the ratepayers after the plants are shut down. PLANNING FOR DECOMMISSIONING Significant savings can be realized by initiating the decommissioning planning effort, in a systematic fashion, prior to permanent reactor shutdown, and well before a decision to shut down is even made. The planning would take place while the reactor is still operational and

4 information and historical resources are readily available. A comprehensive, well formulated planning program would identify the scope of the decommissioning effort, begin preparation of required planning documents, identify and resolve waste management issues, establish a cost estimate for decommissioning, and address the safety aspects, cost, and schedule of the decommissioning. The discussion points below provide information as to how decommissioning planning can be initiated, the scope of the planning effort, and benefits that can be realized by beginning the planning effort while the reactor is still operational. Why Plan For Decommissioning While the Plant Is Operational? The NRC, under provisions of CFR, Title 10, Part Reporting and Recordkeeping for Decommissioning Planning, requires that some decommissioning planning take place prior to reactor shutdown. However, the planning actions specified in this rule are concentrated on financial assurance and record keeping rather than a detailed decommissioning planning effort. Typically, the majority of the planning effort for a commercial reactor decommissioning is performed after reactor shutdown and takes six months to a year to reach a point that physical decommissioning can occur. Based on several examples, it is not unusual for a reactor decommissioning planning effort to consume 30,000 to 40,000 labor hours. Following the planning period, the physical decommissioning effort is typically performed over several years. By initiating the decommissioning planning effort early, the overall decommissioning schedule will be shortened considerably. Other benefits listed below will result as well: Time and money will be saved thus benefiting ratepayers. Planning can be done systematically, with less schedule pressure, i.e., not on the decommissioning critical path. Necessary information is readily available while the reactor is operational and records are intact. Timely access to reliable information can speed up the decommissioning planning effort, reduce uncertainty and risks in the planned decommissioning work, and result in cost and schedule efficiencies. Personnel resources (history and expertise) are still available while the plant is operating. Some of the more knowledgeable people will leave for other jobs as soon as possible after the decommissioning announcement is made and others will continue to leave as opportunities become available. Valuable experience that would aid in the decommissioning effort goes with them. Valuable experience/history will also be lost due to layoffs after shutdown. After a reactor enters the decommissioning phase, the employees are literally working themselves out of a job and morale could suffer along with the decommissioning effort. This letdown is not experienced when decommissioning planning is started while the reactor is still in the operating phase of its life cycle.

5 Decommissioning problem areas such as waste characterization, handling, and disposal will be identified and plans made for them now so that surprises and delays will be minimized after shutdown. While the reactor is still operational, there is time to plan for decommissioning to achieve the best results, while not adversely affecting the reactor operations. A thorough planning effort is the result when sufficient time is allowed. The length of time between shutdown and start of the physical decommissioning effort (material out the door) will be shortened considerably when pre-shutdown planning is done. Early decommissioning planning can also ease the impact of an unplanned, permanent reactor shutdown. Typically, some of the older nuclear units have experienced serious mechanical problems, requiring expensive repairs, upgrades, and replacements. Unplanned, permanent shutdowns can be devastating to a utility. An unplanned shutdown further complicates the decommissioning effort since the reactor may have higher priorities that deal with the reason for the shutdown. An orderly, systematic decommissioning planning effort is needed prior to permanent shutdown for the following reasons. After the reactor is shut down, the decommissioning objective quickly evolves to a material out the door mentality to show progress and, as a result, the planning effort may suffer a schedule squeeze. If the reactor is shut down prematurely, decommissioning planning may suffer even more than in a planned shutdown. As a result, inadequate planning will lead to longer and more expensive decommissionings. What Kinds of Decommissioning Planning Can Be Performed While the Plant Is Still Operational? Many activities required for decommissioning can be performed while the plant is still operational. A most important result of performing these decommissioning planning activities early is that quality cost estimates can be made. The NRC goes to substantial lengths to ensure that both adequate records are in place and that steps are being taken to ensure the availability of decommissioning funds. Described below are some of the decommissioning planning activities that can be performed before a plant shutdown decision is made. Document and catalog information that will not change regardless of when documentation occurs such as operating history, records of spills, or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site. These records may be limited to instances when significant contamination remains after any cleanup procedures or when there is reasonable likelihood that contaminants may have spread to inaccessible areas as in the case of possible seepage into porous materials like concrete. These records should include any known information on the identification of involved nuclides, quantities, forms, and concentrations. Develop a transition plan that describes the process of progressing from normal operations to decommissioning. The plan should identify and describe all actions necessary to reach the

6 decommissioning phase of the reactor. The decommissioning organization should also be described in the transition plan. Extensive management input to decommissioning is essential. By planning and evaluating a decommissioning organization, required areas of expertise can be identified and actions can be taken to ensure that personnel will be available when needed. The transition plan should be formally approved by management; thus, providing assurance that an approved, viable decommissioning plan is in place. Initiate the characterization plan. Characterization of the reactor facility and the surrounding environs is one of the most important activities governing the decommissioning process and forming the basis of the decommissioning cost estimate and schedule. Substantial progress can be made on a characterization plan while the plant is still operating. For instance, all component parts of the characterization plan can be identified and a methodology established for completing the identified tasks. If radiation/contamination levels are found to be excessive, a decontamination program can be evaluated and included in the cost estimate and not be a surprise addition to the cost estimate after the plant has been shut down. Additionally, waste streams can be identified and methodology developed for dealing with these waste streams. Identify major technical actions necessary to carry out decommissioning safely and effectively, e.g., flushing systems or components to reduce radiation levels, partial disassembly of components to remove radioactive or hazardous parts, etc. Assess the current situation with regard to disposal of high-level and low-level radioactive waste such as the license restrictions (curie content, radionuclides, material form, etc.) of potential treatment/disposal facilities. Identify specific issues requiring action such as interim management of spent nuclear fuel, develop a preliminary path forward for all identified issues, and determine their effects on the decommissioning cost estimate. Develop initial residual radioactivity criteria for the site and specific areas within the site based on history and source terms. Evaluate other site-specific factors and information that could affect decommissioning planning and cost. For example, several areas will need to be investigated during the final survey such as the location and extent of oil or hazardous material spills, underground fuel storage tanks, and site storm water drainage and underground sewers that are potential pathways for hazardous or radioactive liquid diversion. Therefore, the histories of these areas will be valuable in the decommissioning planning site characterization. Evaluate various end state scenarios with the pros and cons of each in sufficient detail to allow a reasonable and credible decision on the option chosen for the site. Develop the decommissioning plan based on the most probable end state scenario. Develop the Safety Analysis Plan to assure proper consideration is given to the anticipated hazards that will be encountered in the decommissioning.

7 Develop preliminary training and qualification plans for decontamination workers to assure the required quality and safety of the decommissioning will be achieved. Outline scenarios for dose pathway modeling and define data required. Develop a strategy for dealing with regulators and the public that will become a basic and integrated part of the decommissioning schedule. Develop the basic outline and ground rules for the Final Status Survey Plan. Establish plans for survey grids, survey methodology, and data quality objectives. Identify and evaluate decommissioning contracting strategy alternatives. Evaluate spent fuel storage/disposition alternatives. Produce a high level cost estimate on which to base management decisions for decommissioning options. Also, develop a high level sequence of operations/events to identify the scope of the decommissioning effort. Determine where the problem areas are and document a possible path forward for those areas. Develop a decommissioning safety program that is quite different from a normal reactor operations safety program. Determine options for end use of the site. How Does the Utility Benefit? Utilities can benefit in several ways by performing decommissioning planning while their plants are still operating. Some of the main benefits are presented below. Improved Safety Many safety aspects of decommissioning associated with both planned and unplanned permanent shutdowns can be readily addressed during a planning effort. However, in an unplanned shutdown, safety questions must often be resolved before decommissioning can begin. By planning for the decommissioning effort before shutdown, some of the issues associated with the premature shutdown may already have a path forward and can be implemented quickly. Cost Savings and Schedule Reduction Typically, after a reactor shuts down, a planning period of about six months is needed before physical decommissioning work (i.e., material out the door ) can proceed. Most of this planning can be done earlier, thereby improving the overall decommissioning schedule by months. With a full operating staff available that is most knowledgeable of the plant and its

8 history, the planning can be done efficiently and may also result in a higher quality plan that is safer, less expensive, and faster to implement. The reduction in schedule results in a corresponding reduction in the decommissioning costs. Bearing in mind that a reactor decommissioning can be accomplished in approximately three to five years, taking six months off the schedule represents a significant savings to the ratepayers. A conservative estimate is that performing decommissioning planning prior to reactor shutdown could save up to 10% of the total decommissioning costs. By performing additional activities as part of the decommissioning planning process, further cost savings could be realized. For instance, activities such as technical specification changes and safety analyses must be documented. Integrating these activities with other planning efforts would ensure a comprehensive, well developed decommissioning strategy that could be implemented more efficiently. These two activities alone could save up to $10 million. In the cases of premature shutdown, the period before active decontamination and decommissioning is closer to one year. By performing decommissioning planning activities before a decision is made to shut down the reactor, utilities can often furlough the bulk of the site staff early an action, by itself, that can yield savings on the order of $20 million. Many factors make up the total decommissioning costs and these factors should receive careful consideration and high priority during decommissioning planning. Risks can be reduced, the scope of the decommissioning project can be properly identified, and a high quality cost estimate can be developed through a comprehensive planning effort. Recent history has shown that the following points are often underestimated in reactor decommissioning projects. Spent fuel management and disposal program Until the United States Department of Energy (DOE) establishes a geologic repository for permanent disposal of commercial spent nuclear fuel, utilities will be responsible for interim management of their spent fuel. In many cases, the totality of this expense, which can be 10 s of millions of dollars, is not initially included in decommissioning cost estimates, and therefore is not specifically recognized in the decommissioning fund. Development of the appropriate credible end state. Facility characterization This area can be greatly enhanced by the development and maintenance of historical records important to decommissioning. Waste management including characterization, temporary storage, packaging, transportation, and disposal. The final survey With a well documented history, a thorough site characterization, quality work controls and decommissioning plan work completion documentation, the extent of the final survey can be reduced significantly.

9 Other Benefits Most utilities are very good at operating a reactor, but generally lack decommissioning experience. A comprehensive decommissioning planning effort, while the reactor is operating, will make the utility staff familiar with the decommissioning requirements and procedures. Then, regardless of the contracting method used by the utility, it will be more capable of managing the decommissioning effort. Additionally, by initiating the planning effort, utilities can achieve substantial progress toward a safe, efficient, and less costly decommissioning without taking reactor personnel away from their day-to-day responsibilities of operating the reactor. When Should Planning for Decommissioning Occur? Decommissioning could well be the single largest expense a utility faces during the life cycle of a reactor and should receive continuing management attention commensurate with its cost. Due to the large expense associated with decommissioning, planning for decommissioning should be done on a continuing basis as part of the life cycle management of the reactor facility. Then, as decisions pertaining to reactor shutdown and decommissioning come to the forefront, there will be a basis to make more informed decisions regarding the approach to decommissioning. For instance, equipment replacement or operational changes should be made in light of how decommissioning would be affected and improved by the change. Additionally, there may be actions such as data recording or survey locations that may be changed slightly with no detrimental impact on continuing operations that would form the basis of a history needed for the decommissioning effort. The pace of planning for decommissioning should accelerate as the planned shutdown date approaches. Availability of Decommissioning Funds The NRC requires utilities to maintain a decommissioning fund to ensure that sufficient funds are available to perform decommissioning after the reactor is shut down. Although some utilities may not be aware of the benefits of early planning for decommissioning, restrictions on the use of decommissioning funds are the primary reason that planning does not occur prior to shutdown. Utilities use operating and maintenance (O&M) funds to conduct the day-to-day business of operating a nuclear plant. Currently, any significant decommissioning planning activities undertaken by a utility on an operating reactor would be financed by O&M funds until the utility has notified the NRC of its intent to shutdown the reactor. Once the NRC is notified, some of the decommissioning funds become available to the utility. It should be noted that NRC requires some decommissioning planning activities to occur while the reactor is still operational, but NRC regulations have been interpreted to mean that decommissioning funds cannot be used to finance significant decommissioning activities prior to the decision to shut down a reactor. Restricted use of decommissioning funds while the affected reactor is operating shows NRC s intent to provide assurance to the ratepayers and the general public that decommissioning funds will be available when needed for the utility to perform decommissioning. In addition to NRC requirements, funding for the decommissioning of power reactors may also be subject to the regulation of federal or state government agencies.

10 When a decision is made to terminate the operating license as specified in CFR, Title 10, Part 50.82, Termination of License, decommissioning funds may be used by licensees if: The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in 10 CFR 50.2, Definitions; The expenditure would not reduce the value of the decommissioning trust below an amount necessary to place and maintain the reactor in a safe storage condition if unforeseen conditions or expenses arise; and The withdrawals would not inhibit the ability of the licensee to complete funding of any shortfalls in the decommissioning trust needed to ensure the availability of funds to ultimately release the site and terminate the license. The NRC regulations state that initially, three percent of the generic amount specified in CFR, Title 10, Part may be used for decommissioning planning. For licensees that have submitted the certifications required under CFR, Title 10, Part 50.82(a)(1) and commencing 90 days after the NRC has received the Preliminary Site Decommissioning Activities Report (PSDAR), an additional 20 percent of the fund may be used. A site-specific decommissioning cost estimate must be submitted to the NRC prior to the licensee using any funding in excess of these amounts. NRC regulations require that utilities maintain a decommissioning fund and provide a specific methodology for determining funding levels for reactor decommissioning. Given the potential cost savings and other advantages delineated in this paper that can result from decommissioning planning prior to reactor shutdown, some new regulatory initiatives may be advisable to allow the use of decommissioning funds for approved planning activities. CONCLUSION The major thrust of early planning for decommissioning should be to reduce unknowns in the decommissioning process, in the cost estimate, and in risks associated with decommissioning. Reducing uncertainties will contribute to more credible and defensible decisions by utility management on the appropriate decommissioning scenario. Now is the time to begin the decommissioning planning for many reactors since they are reaching the end of their operational life and will require decommissioning at unprecedented levels in the not too distant future. Although decommissioning is inevitable in the reactor life cycle, meaningful decommissioning planning is often put off until the plants are shut down. Decommissioning costs are large, often exceeding the initial cost of construction. By initiating the planning effort several years prior to reactor shutdown, actions can be taken early on to reduce the cost and improve the schedule of reactor decommissioning as well as improving the safety aspects of decommissioning.

11 REFERENCES (1) NRC Information Digest, NUREG-1350, Volume 12. (2) Aker, R. and M.C. Kirkland, The Nuclear and Related Industry, in Nuclear Facility Decommissioning and Decontamination Handbook, American Society of Mechanical Engineers (draft, February 2000).