Four Points Group, Incorporated is an innovator and leader in commercial nuclear power plant decommissioning. Four Points Group staff has over ten years experience directly related to the decommissioning of commercial nuclear facilities. Four Points Group staff has provided a variety of technical and management services relative to the complex issues associated with decommissioning. Four Points Group staff's experience is unique in the commercial nuclear industry. Four Points Group staff was the first nuclear energy consultant to evaluate the options for the actual decommissioning of a large commercial nuclear plant and has continued to make significant contributions to utilities and regulators in their efforts to manage commercial nuclear power decommissioning.
Four Points Group's services include planning for the transition to permanent shutdown, development of decommissioning plans and cost estimates, overseeing the dismantlement of the plant and evaluating bids from decommissioning vendors. In addition, Four Points Group staff has supported utilities in evaluating options for the decommissioning, and preparing detailed decommissioning cost estimates. Four Points Group staff has also evaluated decommissioning preparations and cost estimates for several other facilities to support efforts with Congress, the federal government and several state agencies. Finally, Four Points Group staff has developed potential cost and schedule estimates for decontamination and decommissioning of over 30 commercial nuclear power plants following a severe reactor accident.
Four Points Group staff's experience in decommissioning nuclear facilities includes:
Performed detailed technical analyses of specific decommissioning technical issues, including: activation analyses of fuel and vessel internals; evaluation of methods for disposal of radioactive waste (e.g., control rods, fuel-support structures and neutron-monitoring instrumentation); calculation of the decay-heat load and fission-product inventory of the irradiated fuel; evaluation of system-operability requirements with irradiated fuel in the fuel pool; and evaluation of plant radiological history and its impact on decommissioning.
Developed draft decommissioning plans. These plans assessed the technical issues associated with decommissioning, and the details for removal and ultimate disposal of radiological hazards. The plans also included a preliminary assessment of decommissioning options, a description of the plant during long-term storage prior to decommissioning, information on organization and staffing, and an evaluation of NRC requirements relative to the plant's shutdown condition.
Evaluated technical proposals from contractors bidding to provide decommissioning services. Four Points Group staff provided technical review of proposals for various decommissioning services including: dismantlement of reactor vessel internals; segmentation of the reactor vessel; general services; and health physics. For these proposals, Four Points Group staff performed thorough technical evaluations to identify any potential technical issues.
Evaluated spent fuel disposal options. Options included onsite storage in independent storage vaults, use of the existing spent fuel pool, storage at other facilities, etc. Analysis included the cost benefit of the option, the uncertainties and a recommended course of action.
Evaluated dismantling options. Options included premature shutdown followed by decontamination and dismantlement, removal of contaminated systems prior to NRC approval of the decommissioning plan and decommissioning when the licenses for operating plants on the site were set to expire. Four Points Group staff performed a cost benefit analysis for each option, determined the option's uncertainties and recommended a course of action.
Independent review and evaluation of decommissioning cost estimates. Audited the estimators records, methods and backup information. Discovered significant errors that were corrected. Redid portion of the analysis independently to verity the final cost estimates. Made comparisons with previous estimates and developed qualitative and quantitative criteria for determining the estimate's accuracy.
Preparation of detailed cost estimates for decommissioning several nuclear power plants. The estimates were approved by the respective state utility commission and the co-owners of the plants.
Evaluated decommissioning preparations that could be undertaken while still holding a full-power operating license. These preparations included establishing and reviewing procedures for the lay-up of plant systems in order to minimize operating and maintenance costs incurred prior to dismantlement while still complying with the NRC directive to preserve all decommissioning options. Four Points Group staff further identified license amendments appropriate to reflect a permanent shutdown status, and achieve further reductions in operating and maintenance costs.
Assisted the plant staff in applying NRC guidance on prematurely shutdown plants to the planning of near-term activities for the plant's shutdown. Because specific regulations do not exist for prematurely shutdown plants, assessments of actions taken by other plants were made and used to minimize the cost and schedule impact.
Developed operating and maintenance transition plans for transition to a defueled condition. Four Points Group staff's emphasis was on minimizing unnecessary costs while complying with existing regulations. This effort included identifying the appropriate defueled plant status, and developing revised technical requirements for this defueled condition.
Established administrative procedures for quality assurance, safety oversight, procedure control and control of safety-related changes necessary for decommissioning. Four Points Group staff also provided independent technical oversight of these activities while the procedures were implemented.
Prepared initial decommissioning schedules and cost estimates. Four Points Group staff has developed costs estimates for several utilities for reactor-block decontamination from a variety of states: normal but premature shutdown, normal end-of-life shutdown, and post-accident cleanup and retirement. In addition, Four Points Group staff has performed independent analyses of detailed cost estimates produced by other industry firms.
Developed a comprehensive plan for pre-decommissioning initiatives. The initiatives included transition planning to schedule and implement the activities needed to take the plant from a full-power-producing status to decommissioning. The plan provided guidance to managers for developing detailed departmental plans for closure of the unit. The overall goal of the plan was to minimize cost by utilizing existing utility resources and ensure compliance with applicable regulations.
Evaluated the operating license to determine the overall impact of the plant shutdown on routine plant activities, such as maintenance, testing and operation of plant equipment. This evaluation was used to significantly reduce the programs and procedures needed to comply with the license. In addition, specific recommendations were made to seek regulatory relief in areas such as fire protection, security, training and quality assurance.
Developed and conducted a decommissioning seminar for the nuclear industry. This seminar addressed important issues for decommissioning planning; including an overview of decommissioning regulations, a review of the methodologies used in developing decommissioning cost and schedule estimates, analysis of the mechanisms available for decommissioning funding (including the tax consequences of each mechanism), and a review of activities necessary for decommissioning.