Performed detailed technical analyses of specific Shoreham technical issues, including: activation analyses of Shoreham's 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 the radiological history of Shoreham and its impact on decommissioning.
Developed a draft decommissioning plan and detailed cost estimate for Shoreham. This plan assessed the technical issues associated with decommissioning, and provided a detailed plan for removal and ultimate disposal of radiological hazards.
Evaluated technical proposals from contractors bidding to provide decommissioning services to the Shoreham Decommissioning Organization. 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 performed thorough technical evaluations to identify any potential technical issues.
Evaluated decommissioning preparations for Shoreham 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 further identified license amendments appropriate to reflect a permanent shutdown status, and achieve further reductions in operating and maintenance costs.
Established the Shoreham administrative procedures for quality assurance, safety oversight, procedure control and control of safety-related changes necessary for decommissioning. Four Points Group also provided independent technical oversight of these activities while the procedures were implemented.
Developed operating and maintenance transition plans for transition of Shoreham from the operating license to a possession-only license and a defueled condition. Four Points Group'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.
San Onofre Nuclear Generating; Station, Units 1, 2 and 3
Developed a draft decommissioning plan for SONGS-1. This plan included input from other prematurely shutdown plants and an assessment of NRC guidance applicable to SONGS-1. The plan 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 spent fuel disposal options for SONGS-1. Options included onsite storage in independent storage vaults, use of the existing spent fuel pool, storage at other facilities, et cetera. Analysis included the cost benefit of the option, the uncertainties and a recommended course of action.
Evaluated dismantling options for SONGS-1. Options included decontamination and dismantlement in 1997, removal of contaminated systems prior to NRC approval of the decommissioning plan and decommissioning when the licenses for SONGS-2 and -3 expire in 2013. Performed a cost benefit analysis for each option, determined the option's uncertainties and recommended a course of action.
Reviewed, in detail, the decommissioning cost estimate for SONGS-1, -2 and -3. Audited the estimators records, methods and backup information. Discovered significant errors that were corrected. Re-performed sections of the analysis independently to verify the final cost estimate. Made comparisons with previous estimates, and developed qualitative and quantitative criteria for determining the estimate's accuracy.
Assisted the SONGS-1 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 on the SONGS-1 shutdown.
Evaluated the SONGS-1 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 a comprehensive plan for pre-decommissioning initiatives for SONGS-1. This transition plan was used 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.
Calvert Cliffs Nuclear Power, Units 1 and 2
Prepared detailed cost estimates for decommissioning Baltimore Gas and Electric Company's (BG&E's) Calvert Cliffs site. The estimate included the analysis of eight different scenarios, including early shutdown and extension of the operating license beyond the current expiration date. The estimate was performed in accordance with the AIF Study AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates".
Provided a schedule and explanation of the activities necessary to transition from fully licensed operating status to the start of actual decommissioning. The analysis included the steps required for the process and the expected manpower to accomplish the work.
Analyzed the past five years of state regulatory history related to decommissioning funding to provide insight and lessons learned. The Electric Power Research Institute (EPRI) regulatory database was accessed, testimony analyzed and recommendations made.
Congressional Office of Technology Assessment
Reviewed the decommissioning funding, spent fuel disposal plans and preparations for nine nuclear power plants as part of an overall study of the nuclear power plants as requested by the United States Congress. Conducted interviews with upper management and technical personnel. Two panel meetings were held to review the findings of the report. The panel members included intervenors, public utility commissioners, industry representatives and university professors. The results of the report were presented to the NRC Commissioners.
New Hampshire Nuclear Decommissioning Financing Committee
Four Points Group staff performed a detailed review of the cost estimate prepared for the Seabrook Nuclear Power Plant. This review included performance of an independent estimate, detailed evaluation of the costs included, comparison to other estimates, independent verification of input data and assumptions, comparison to actual decommissioning experience, performance of sensitivity analyses for factors such as waste burial charges, determination of the "most likely" decommissioning option and analysis of the required trust funding schedule for the decommissioning trust fund.
Review of the Indian Point Unit 2 Decommissioning Cost estimate and Training seminar for the New York Public service Commission
Four Points Group staff evaluated the decommissioning cost estimate for Indian Point, Unit 2. This was part of an effort to assist the New York Public Service Commission (NYPSC) staff in understanding the estimate, evaluating the projected cost of waste disposal and reviewing the staff's testimony for the rate hearing. In addition, Four Points Group staff provided the staff with a two-day training seminar on decommissioning, including the NRC rules, decommissioning technologies, estimating decommissioning costs and disposal of spent fuel.
Effects of Nuclear Power Plant Decommissioning Costs on Plant Life Cycle Decisions
Four Points Group staff provided a decommissioning cost estimate report based on a plant-specific cost estimate. The report included discussion of the generic applicability of the estimate's elements and approach. Four Points Group staff reviewed the Nuclear Regulatory Commission's (NRC's) decommissioning cost estimating model. Finally, Four Points Group staff provided input to the final Electric Power Research Institute (EPRI) report on managing the decommissioning decisions in the context of plant life cycle management.
Preparation of Nine Mile Point Units 1 and 2 Decommissioning Cost Estimates
Four Points Group staff developed a decommissioning cost estimate for Niagara Mohawk Power Corporation's (NMPC's) Nine Mile Point Units 1 and 2 nuclear power plants. Four Points Group staff utilized site-specific information such as labor rates, equipment inventories, staff salaries and other data to prepare the estimates. Four Points Group staff input the information and data into the Decommissioning Cost Analysis System (DECAS), a PC-based computer program for estimating decommissioning costs. DECAS was then used to develop the costs for several different scenarios to determine the least cost decommissioning option. Finally, Four Points Group staff provided NMPC with training in DECAS to allow NMPC to update the estimate in the future without the need of outside assistance.
Four Points Group staff developed a comprehensive training course on decommissioning. The course included the basis for the decommissioning rule, the details of the rule, implementation of the rule and current uncertainties. The course also included discussion of current decommissioning works such as Shoreham, Fort St. Vrain, Yankee Rowe and San Onofre.
Preparation of Vermont Yankee Nuclear Power Plant Decommissioning Cost Estimates
Four Points Group staff developed a decommissioning cost estimate for the Vermont Yankee Nuclear Power Corporation for the Vermont Yankee Nuclear Power Plant. Four Points Group staff utilized site-specific information such as labor rates, equipment inventories, staff salaries and other data to prepare the estimates. Four Points Group staff input the information and data into the Decommissioning Cost Analysis System (DECAS), a PC-based computer program for estimating decommissioning costs. DECAS was then used to develop the costs for several different scenarios to determine the least cost decommissioning option. Finally, Four Points Group staff provided Vermont Yankee with training in DECAS to allow Vermont Yankee to update the estimate in the future without the need of outside assistance.
Analysis of Severe Accident Clean-up Costs
Four Points Group staff provided American Nuclear Insurers (ANI) with an analysis of the estimated costs required to cleanup a commercial nuclear power plant after a severe accident. The analysis used several industry recognized studies on severe accidents, decommissioning costs associated with the Three Mile Island, Unit 2 (TMI-2) accident and related Nuclear Regulatory Commission (NRC) data. Four Points Group staff developed an innovative method for estimating the costs. First, the Industry Degraded Core Rulemaking (IDCOR) analysis on severe accidents was evaluated for information related to accident sequence end-states. Four end-states for a "generic" 800 MWe boiling water reactor (BWR) and pressurized water reactor (PWR) were chosen. The cost estimates for TMI were then adjusted using severe accident scaling factors and the NRC data to estimate the costs for cleanup from IDCOR end-states. The study received industry-wide peer review, was well-received and is known as the "1989 Four Points Group Study."
Decommissioning Oversight of the Trojan Nuclear Power Plant
Provide independent review and assessment of the cost and safety of the Trojan Nuclear Power Plant decommissioning. This includes interviewing responsible plant personnel, evaluating the progress of decommissioning implementation and plans for disposal of spent fuel. As part of a multi-disciplinary team, Four Points Group staff attends quarterly committee meetings and conducts detailed tours of the plant. The oversight committee provides feedback to upper management.
Severe Accident Cost Study
Four Points Group staff provided the first site-specific severe accident cost analysis for a commercial nuclear power plant. The analysis of the Waterford-3 plant included calculation of end-state damage costs, evaluation of insurance payouts and incorporation of risk assessment data. Four Points Group staff also provided an update to the study to account for changes in labor rates, burial costs and the risk assessment.
Review of Trojan Decommissioning Cost Estimate and Related Computer Program
Four Points Group staff performed a detailed review of the Nuclear Regulatory Commission (NRC) decommissioning cost estimate for Trojan and evaluated the NRC Decommissioning Cost Estimating Computer Program (CECP). Four Points Group staff's review found significant deficiencies such as improper scaling, low staffing levels and difficult user interface. Four Points Group staff's review was provided to both the Department of Energy (DOE) and the NRC.
Review of the Decommissioning Estimate for the New England Nuclear Power Plants
Four Points Group staff evaluated the decommissioning cost estimates and funding plans for all nine New England nuclear power plants. Four Points Group staff analyzed the estimates against specific criteria related to the disposal of low level radioactive waste and the storage of spent fuel. Each plant's estimate was adjusted accordingly and the decommissioning shortfall determined. The effect of pre-mature decommissioning was also evaluated.
Comprehensive Evaluation of Decommissioning Unit Cost Factors and Reactor Vessel Disposal Options
Four Points Group staff evaluated decommissioning unit cost factors for Mitsubishi Material Corporation. The evaluation included cost factors used in a number of recent decommissioning cost estimates. Four Points Group staff developed an detailed process for analyzing the cost factors to enable the Japanese to understand the unit cost factor approach to estimating and be capable of using US experience in development of their own estimates. In addition, Four Points Group staff evaluated the disposal options for the reactor vessel including shipment to a waste disposal as its own container.
Review of the Turkey Point and St Lucie Decommissioning Cost Estimates
Four Points Group staff provided a review of the Turkey Point and St Lucie decommissioning cost estimates for the Florida Public Service Commission. The review pointed a number of inconsistencies in the estimates spent fuel storage costs, unit cost factors, use of contingency, etc. Four Points Group staff presented the review as part of a decommissioning course for about 20 employees of the Commission staff.