NRC Public Meeting on Decommissioning, 2013-09-26

Citizens Oversight (2013-09-26) Ray Lutz

This Page: https://copswiki.org/Common/M1387
Media Link: http://youtu.be/bmCQTkREjuU%2c%20http://youtu.be/xm1Aa_Ftz_Q%20type%3d%22html%22
More Info: Nuclear Energy, Nuclear Waste, Shut San Onofre

Video of Afternoon Session

About 7 minutes were omitted at the beginning of Part 1 and 3 minutes at the beginning of Part 2 which were facilitator remarks about logistics.

Part 1

Includes presentations by NRC staff and first questions from the public
http://youtu.be/bmCQTkREjuU

Part 2

More questions. Don't miss statements by Peter Dietrich of Southern California Edison near the end, regarding the fact that they are not planning to return the site as "greenfield" level.
http://youtu.be/xm1Aa_Ftz_Q

Summary by Roger Johnson

Notes on the NRC public meeting at the Costa Omni Resort in Carlsbad, Thursday Sept. 26 6-9 PM

This was a typical NRC meeting: a moderator, 4 featured speakers (one who made 2 presentations), and a dozen other NRC officials who occupied the entire center section of the front row (a number of them gave extensive comments during the public question phase). The NRC once again chose a plush resort and a huge banquet room which probably seated over 1000. The NRC claims to have selected this distant site because they could not find anything suitable in Orange County. Some said they wanted the meeting at this distant site to reduce public attendance. The AC was cranked up making the room frigid (perhaps 60 degrees) and uncomfortable. I am guessing that there were about 200 in attendance, perhaps 75 when the evening ended. Although this was a good crowd, it appeared small in this huge room. The NRC said they expected more, but perhaps they were delighted at a smaller crowd which they could interpret as a lack of public interest. The meeting reminded me of one of the 18 grievances against King George written into the Declaration of Independence, namely that inconvenient meetings were called by the Crown in distant and cold places in order to suppress attendance.

The NRC had a table in the lobby full of NRC documents about decommissioning. One color pamphlet is called the Decommissioning Process. There are before and after aerial photos on the cover (and inside) showing nuclear power plants before and after they were demolished. The “after” photos show a green field. The NRC now uses the term Greenfield to mean site restoration. They also made it a verb: Greenfielding. This term was used often during the evening apparently in a public relations/marketing effort to make it appear that former highly radioactive sites could be made pristine. Before the meeting started, the NRC had a slide show showing other before and after photos. One disturbing series of photos showed the Maine Yankee containment domes being blown up, reduced to rubble, and then planted over. The photos remind me of the contaminated and bulldozed town of Uravan, Colorado which is now a "Greenfield." One wonders why they would show that unless they planned to do the same thing at San Onofre.

The meeting began with happy talk and rules by the moderator, and the first half of the meeting was monopolized by the speakers and their power point presentations. As usual, the focus was on the bureaucratic procedures of the NRC rather than on the substance of decommissioning. Few details were given other than lengthy lists of NRC rulings which had to be followed in a particular order. During the public questions phase, speakers gave lengthy answers and often passed the microphone back and forth so that many NRC officials could respond to the same question. The net result was that time ran out and many in the audience could never get recognized. I was sitting in the second row center and waved my hand for an hour and was ignored the entire evening.

The first speaker was Larry Camper who boasted that the NRC decommissioning team had 300 years of cumulative experience in decommissioning. They have decommissioned 50 materials sites, 13 research reactors, 11 nuclear power plants (NPP), about 80 in total. He made it clear that the licensee (Edison) had the right to choose whether to decommission the site for unrestricted use (for any purpose) or restricted use (still partly contaminated). He said that all decommissionings so far have been unrestricted. He said their goal was to end up with contamination levels no higher than 25 mrem AND as low as reasonably achievable (ALARA). This was scary and unclear but not questioned. All their technospeak may boil down to the fact that they have a procedure which says that they don’t have to do what is safe, they only have to do whatever is practical and easy to achieve (for them)..

The second speaker was Bruce Watson who went into many of the rulings such as 10 CFRPart 20 Subpart E He says that Edison will have 60 years to complete the process, up to 50 in SAFSTOR and 10 in DECOM. The radioactive waste has to be reduced only by 90%, not 100%. He made the incredible statement that they liked to go slow and stretch out the process in order to allow the decommissioning trust funds to remain invested so that interest would compound and generate more money over time. Edison will produce a PSDAR report about costs and environmental impacts. This plan must be submitted, but it does not require any approval by the NRC. A final License Termination Plan LTP must be approved by the NRC. Edison has until June 7, 2015 to submit their plan but Edison says it hopes to submit it earlier.

The third speaker (and 5th speaker) was Dr. Blair Spitzberg whose specialty is fuel safety. He carelessly stated that spent fuel has to go into cooling pools for “several years.” Regular fuel needs to be cooled in pools for 5 years and the Hi Burn fuel that Edison has been using since 1996 requires 12-15 years. It was unclear whether Dr. Spitzberg’s goal was to deceive the public about this crucial issue or to trivialize it (or both). He stated that San Onofre has two types of dry casks which are certified for transport: 24PT1 and 24PT4. They also have another type not yet certified (but Edison has applied for transport certification). This is all mute because there is no where for any of it to go, at least during our lifetime. He said that the exact number of dry casks is secret information but it can be found on storefuel.com (if someone finds these data here please circulate). He said there were 55 cannisters at San Onofre as of Dec., 2012.

Here are 2 more alarming statements Dr. Spitzberg made: First, he referred to a category called “High Risk Activities” with no explanation. If part of decommissioning involves high risk radiological activities, this should be disclosed to the public as to when they occur and what part of the public takes the risk if something goes wrong. Second, when talking about contaminated waste, he mentioned that “MOST” contaminated waste is taken out of state, implying that some contaminated waste is taken to other parts of California. Since there are no radioactive contamination waste disposal sites in California, presumably he means that it is dumped in landfills?

Also discussed was Unit #1 which is not completely decommissioned because the reactor vessel remains on site. Attempts were made to barge it through the Panama Canal to a Class C (highly contaminated) site in South Carolina but there was political opposition by the countries involved plus the fact that the barge would move so slowly that it would tie up traffic. Attempts to route it around South America were blocked by Argentina. The “solution” is to leave it at San Onofre for the time being (meaning probably decades) which makes San Onofre a Class C radioactive waste storage facility. The “plan” is to wait until it is time to move reactor vessels (the largest component needing removal) for Units 2 and 3, and then deal with them all at the same time. Since these are too large and too dangerous to ship by truck or rail, they hope that many years from now a solution will someone become apparent. It looks like a long time before #1 will get a LTP.

Some other tidbits about #1 which came up (also in Q and A) include the fact that Edison never removed the large discharge pipe into the ocean. They decided that there would be more radioactive contamination to the ocean by removing it than leaving it there (presumably contaminated), not to mention the fact that doing nothing is always cheaper and easier. If they knew before they built this pipe that it would be too dangerous ever to remove, why was it ever allowed to be built? This shows the same dangerous strategy of the NRC: build things first without concern for consequences and put off safety considerations as long as possible.

There was also discussion of a leak of radioactive liquid waste being shipped to Clive, Utah from #1. It was discovered at a truck stop in Utah. Teams went in and patched it up and the NRC claims that no one was hurt. Later I cornered the staff member who said that asked if he meant that the radioactivity didn’t harm anyone during the few days after the accident and he admitted that this is what he meant. I asked how they could possibly know if anyone was harmed since it would take at least 5 years for cancer to appear if someone inhaled radioactivity. He agreed that it was possible and they really don’t know if anyone was harmed even though they make claims to that effect.

Speaker #4 was Michael Dusaniwskyj, an economist. He said there was currently $1.7 billion in trust funds for unit #2 and $1.9 billion for #3. He said that $295 million remained earning interest for Unit 1 of which they expect to spend $206 million. No mention of where the unused $89 million will go. Back to the rate payers who have been paying for this since 1968?

Gene Stone opened the Q&A period with a request for having a citizen group called Coalition to Decommission San Onofre officially be a part of the decommissioning process. The NRC replied briefly that they would think about it.. Another question from this group was whether residents would be warned of any activities which might lead to environmental contamination. The answer was no, residents would not be warned. The NRC bureaucratic answer was that all such activities would be treated exactly the same way as the current procedures for low level radioactive waste disposal. It was asserted that all such waste disposal would be carefully documented and eventually appear in public records. The current procedure is to wait about a year and then make quarterly reports about radioactive waste disposal into the air and ocean. The waste discharges are averaged over 90 day periods. NRC regulations carefully state that these averages must not exceed permissible levels (it is always what is permitted, not what is safe). In this way, a large release on the beginning of a quarter could be averaged with 89 days of no releases and the records would clearly indicate a low permissible average dose. The public will never know before such releases occur and they will also never know the dates and concentrations of releases even a year later. The only way to know is to install real time publically accessible monitoring, a subject which never came up in spite of all the expressed concern for transparency and public safety. Supposedly there will be a lot of radioactive monitoring by Edison and the NRC, but it will all be secret information.

Much of the discussions involved the problems caused by the use of Hi Burn fuel which is much hotter, much more radioactive, and requires about triple the amount of time in cooling pools. The NRC could not answer exactly how decisions were made (and kept from the public) about the switch in fuels. They could not answer questions about the dangers of dry cask storage for this fuel. Dr. Spitzberg admitted that Hi Burn fuel required more time in cooling pools but he did not know how much longer. At one point he said it might be 7 years (half the time that other experts cite). The NRC was quick to blame the Dept. of Energy and national politics for the failure to have any permanent nuclear waste disposal facility. They were happy to talk at length about this problem involving other parties. They maintain that they are blameless and can do nothing about it.

Many people in the audience made articulate statements of concern coupled with questions which were often brushed aside. Some mayors and city council members weighed in. One interesting speaker was Patrick Christman, Assistant Chief of Staff at Camp Pendleton who was involved in environmental protection for the camp. He later told me that the marines were concerned about the radiological dangers but considered themselves mostly observers. He was not aware that San Onofre might be a major target for terrorists, and he was not aware of the newly funded cancer streak study which will be carried out by the National Academy of Sciences in the next 2 years (all of Camp Pendleton will be part of the study).

There was only one pro-nuclear comment from the audience. This came from a representative of the Chamber of Commerce who was outraged that the general public was allowed to weigh in at all. He suggested that the NRC should stop wasting its time listening to the public and make all the decisions on their own. The NRC gave him effusive thanks for his comments. I suppose everyone knows that Edison has contributed heavily to every Chamber of Commerce in most of Southern California.

I was disappointed that there were almost no questions or discussion of the disposal of low level waste (everything that is not the fuel rods). Will they blow up the containment domes as they did in Oregon and Maine (think of all the contaminated particulate blown into the air and settling in the ocean and on our rooftops). Will they bulldoze contamination and let it stay? Will they let everything underground stay, contaminated or not? If Class A waste goes to Clive, Utah, what will be the route for the thousands of trucks? What safety precautions will they take? We assume Class C waste will go to Texas (how?) but what falls into Class B and where will it go? Who makes these classifications and how can they be trusted? Will they try to classify contaminated waste as less than A so it can go into EPA designated hazwaste sites or into landfills? How much of San Onofre will end up at the landfill off Ortega Highway, and how much will somehow end up in the ocean? Will they leave forever the 18 ft diameter 1500 ft long into the ocean? This pipe has been carrying liquid radioactive waste for a third of a century. Will the public be notified on days of “high risk” demolition? They have hazmat suits but we don’t. What about the 3 upwind schools only 2 miles away? What about the surfers?

Two low points stuck out for me. First was the discussion about the safety of the spent fuel pools. The NRC went on and on about how it had a 5/8 inch steel lining, walls 4 feet thick, and a foundation 3 feet thick, and it was way above sea level (19.75 feet to be exact). Therefore it would be impervious to earthquakes and tsunamis. When asked about safety from above, perhaps by terrorist attacks, the question was cut off and never answered. When pressed about drone attacks and terrorism, Bruce Watson dragged out the old study claiming that an airplane could crash into the containment dome and not cause it to collapse. He would not respond to attacks on the fuel pools or dry cask storage and used the NRC line that San Onofre was just as safe as any other nuclear power plant in the country. (Which is true because all of them are unsafe.) I am familiar with the National Academy of Sciences special study about the vulnerability of NPP to terrorism and the research done by Sandia Labs about 9/ll type plane crashes. Privately he admitted that such crashes or missile attacks or any high explosives might lead to catastrophe if they targeted the pools or dry casks (which is why the NRC only takes about containment dome safety). I told them that the Sandia Labs also found that a truck bomb exploding at a NPP perimeter a few hundred feet from a fuel pool would likely cause a catastrophe. He did not know this. But he did know that the fuel pools and openly stored dry casks are about 200 feet from public road Old Pacific Highway and about 300 ft from Interstate 5. Everyone knows that NPP designed in the 1960s were never designed to protect against terrorism. The NRC pretends that no such attacks are likely and it is the Pentagon’s problem, not theirs.

The other low point was the last question from Pete Dietrich, Edison chief nuclear engineer. He complained about the continual reference to “Greenfield” status which suggested that Edison would have to make the site pretty when they leave. When pressed, the NRC said that the site would not have to be returned to a “Greenfield” which pleased the public. They only had to please the US Navy, the owner. The bottom line is that Edison has to do only what is acceptable to the Navy, perhaps what one might find at a military base used as an artillery range. This is a clue as to what we can expect from Edison.

Summary by Glenn Pascall

Summary of Presentations
by the U.S. Nuclear Regulatory Commission
re Decommissioning
Of the San Onofre Nuclear Power Plant
Carlsbad, California
September 26, 2013

Larry Camper, Director, Division of Waste Management and Environmental Protection

The NRC licenses and regulates the nation’s civilian use of radioactive materials to protect public health and safety, promote the common defense and security, and protect the environment. Our primary mission during the decommissioning phase is health and safety.

Decommissioning Requirements

Section 10 CFR Subpart E of NRC’s decommissioning regulations state the goals of removing a facility safely from service and reducing radioactivity to a level that permits release of the property for unrestricted use, or under restricted conditions. In either event, the license to operate the plant is terminated when the property is released.

All decommissioned plants to date have achieved unrestricted release, based on reduction of radioactivity to the required level for this status.

On-Site Decommissioning Team

All areas of NRC decommissioning staff expertise will be represented on the San Onofre team, which will include: mechanical, civil, chemical, and nuclear, geotechnical, and industrial engineers; health physicists, environmental scientists and engineers, hydro-geologists, mathematicians, biologist and chemists.

Decommissioning Completions

Decommissioning is process that includes a wide range of sites whose activities generate radioactivity. In the last 15 years, some 80 sites have been decommissioned. Of these, eleven were nuclear plants:

• Rancho Seco, 2009
• Big Rock Point, 2007
• Connecticut Yankee, 2007
• Pathfinder, 2007
• Yankee Rowe, 2007
• Trojan, 2005
• Maine Yankee, 2005
• Saxton, 2005
• For Saint Vrain, 1997
• Shorham, 1995
• Shippingport, 1988

Decommissioning Milestones

Key milestones in decommissioning are:

• Certification of permanent cessation of plant operations
• Certification of permanent removal of nuclear fuel from the reactor
• Post-shutdown decommissioning activities report ((PSDAR) – a major tool
• Decommissioning and environmental remediation – on-site
• License termination plan
• Final status survey – on-site
• NRC confirmatory survey
• Termination or reduction of Part 50 license

Decommissioning Release Requirements

There are two pathways to release: restricted and unrestricted, based on a maximum radiation dose standard of less than 25 mrem (0.25 mSv/a) and as low as reasonably achievable. This “total effective dose equivalent” (TEDE) is based on the average member of the critical group, in all pathways, for a 1000-year period of performance. The 0.25 mSv/a standard is monitored by legally enforceable institutional controls. If these controls fail, doses must not exceed 1 – 5 mSv/a in specified circumstances.

During the process of pathways to release, financial assurance of capability must be provided by an independent third party, and the licensee and NRC must satisfy requirements for public input and outreach.

Agenda for this Public Meeting

At this meeting, we will provide an overview of NRC decommissioning, the reactor decommissioning process, the decommissioning inspection program, decommission funding, and spent fuel management. Waste confidence is an issue we can speak to.

We are very engaged in decommissioning. This public meeting is not part of the required process but it is important to us. A hearing is required once the utility submits its decommissioning plan, because decommissioning involves a license amendment. Other events that will result in meetings include filing the Post Shutdown Decommissioning Activities Report (PSDAR) and the License Termination Plan.

Bruce Watson, Chief, Reactor Decommissioning Branch, Office of Federal, State, Materials Safety and Environmental Protection

NRC monitors the radiological level at sites. Four reactors went inactive in 2011. Humboldt Bay and Zion, Illinois are now in decommissioning. A resident inspector is on site during the process.

ISFSI

Document 10CFR contains the rules on power reactor licensing and license termination. Part 72 contains the Independent Spent Fuel Storage Installation (ISFSI) license, which covers where spent fuel goes during decommissioning.

Reactor Decommissioning Options

• DECON: Equipment and structures are removed or decontaminated to a radiological level that permits unrestricted release of the site.
• SAFSTOR: The plant is placed in a safe, stable condition and maintained in that state until it is subsequently decontaminated to a radiological level that permits release.
• ENTOMB: The plant is encased in a structurally long-lived substance to allow decade until radiological levels permit unrestricted release. Note: The ENTOMB option has not been used and is not currently available.

Reactor Decommissioning Process

The process is required to be completed within 60 years. During the first 50 years the plant is placed in SAFSTOR to achieve a 99% drop in radiation and a 90% drop in waste volume due to radioactive decay during that time. At the 50-year point, 7 – 10 years remains to complete actual decommissioning.

The amount of money in the Decommissioning Fund may increase during this time. The 60-year timeframe also corresponds to the 20-year cycle for life extensions at multi-unit sites.

Strategy Factors in Decommissioning

• Multi-unit site safety
• Amount of decommissioning funds available
• Access to radioactive waste disposal capacity (off-site vs. on-site)
• Future use of site
• Stakeholder concerns and priorities
• Special concerns
• New business model. - Under the new business model, the utility hands off the license to a decommissioning company that does the job and returns the site – and the waste - to the utility. This model is being used in the Zion decommissioning.

Power Reactor Decommissioning Process (PSDAR)

Within 30 days of permanently ceasing operations, the licensee must send a letter to the NRC notifying and certifying this operational status. A similar certification must be provided by the licensee when fuel has been permanently removed from the reactor vessel.

Within two years of the cessation of operations, the licensee must submit a Post-Shutdown Decommissioning Activities Report (PSDAR).

The PSDAR is a letter from the licensee to the NRC. This letter is received and reviewed, but not “approved” by the NRC.

The PSDAR must contain: a description and schedule for planned decommissioning activities, an estimate of expected costs, and a review of environmental impacts of decommissioning within the parameters of Environmental Impact Statements (EIS) applicable to the project.

Upon receipt of the PSDAR from the licensee, the NRC publishes a notice in the Federal Register, followed by a public meeting to discuss the PSDAR and solicit comments. As noted above, the NRC does not approve the PSDAR and the licensee may begin decommissioning 90 days after the NRC receives the PSDAR.

License Termination Plan (LTP)

As the licensee performs site decommissioning, the NRC conducts site inspections on a continuous basis. At least two years prior to requesting license determination, the licensee must submit a license termination plan (LTP). At that point the NRC publishes a notice in the Federal Register and holds a public meeting to discuss the LTP.

The LTP must include information characterizing site radiology levels, remaining dismantlement activities, plans to complete remediation of the site, and detailed plans for the final radiation survey. An important part of the LTP is the licensee’s demonstration of how the final inspection will meet NRC requirements.

In cases where restricted release is requested, the LTP will include a description of the end use of the site. In all cases, the LTP will include an updated site-specific estimate of remaining decommissioning costs. The LTP will also contain an updated environmental report if there have been significant changes in relevant conditions or information.

Upon receipt of the LTP, the NRC begins a detailed technical review that takes about one year. The NRC will request further information if needed. The LTP also provides the basis for public meetings and opportunity for a hearing.

NRC approval of the LTP is in the form of an amendment to the license. The licensee performs the remaining decommissioning activities, which the NRC reviews using independent in-process and confirmatory surveys to verify licensee survey results.

The process concludes with a Final Status Survey Report (FSSR) submitted by the licensee. The FSSR contains final radiological reports, on which the NRC performs confirmatory surveys. If the findings are consistent with the FSSR, the NRC terminates the license by letter and provides notice of this action in the Federal Register.

San Onofre Decommissioning Schedule: Key Time Milestones

• June 7, 2013: SCE certifies permanent cessation of operations for Units 2 and 3
• June 28: SCE certifies Unit 3 has been defueled
• July 22: SCE certifies Unit 2 has been defueled
• 2014 calendar year: SCE tells NRC it intends to submit the decommissioning plan in this timeframe.
• June 7, 2015: Latest date for SCE to submit decommissioning plan
• August 6, 2015: Latest date for public meeting on decommissioning plan

Blair Spitzberg, Chief, Fuels Safety and Decommissioning Branch, NRC Region IV

The NRC Inspection Program for Decommissioning Reactors

The inspection program’s role is to establish and ensure compliance with requirements contained in NRC regulations, safety standards, license conditions and technical specifications. It performs this role through licensing reviews done by NRC national headquarters and safety inspections, with enforcement actions where needed, by NRC Region IV staff.

Inspections of decommissioning activities are generally scheduled during periods of higher-risk activity. During and after remediation activities, NRC conducts independent radiological measurements to confirm the accuracy of survey methodologies used by licensees.

Inspection of physical security is part of the process. A key area is inspection of spent fuel safety, including the Independent Spent Fuel Storage Installation (ISFSI).

The goal is objective verification of the safe conduct of licensee activities. NRC verifies the adequacy of licensee controls to ensure that safety problems and violations are promptly identified and corrected, and effective actions taken to prevent recurrence. Licensees often bring in contractors. The NRC monitors their performance by monitoring trends in licensee safety performance.

Core Inspection Tasks

• Review of decommissioning organization, management and cost controls
• Review of impact on safety of design changes and modifications
• Review of self-assessments, audits and corrective actions
• Occupational (workforce) radiation exposure
• Inspections to confirm final survey results
• Spent fuel safety
• Transportation of radioactive material
• Environmental monitoring of effluent and red-waste treatment
• Review of contingency response procedures

Inspection Procedures

Routine inspection schedules are planned about a year in advance, with adjustments made as needed. The timing of inspections may be announced or unannounced. Exit meetings are held to review approved inspections. Post-exit, there is a 30-day goal for normal inspection reports and a 45-day goal for reports of team inspections.

Each inspection is followed promptly by an NRC debriefing for management, including any significant findings. Enforcement includes civil penalties for violations revealed through inspections. The final step is to track and follow up on any safety issues to the point of closure.

Blair Spitzberg, Chief, Fuels Safety and Decommissioning Branch, NRC Region IV

Spent Fuel Storage at San Onofre: Fuel Pools

Spent fuel must have active heat removal in a pool for several years after leaving the operating reactor. After this period it can be passively cooled by air.

Spent fuel is being safely stored at San Onofre in fuel pools and in the on-site Independent Spent Fuel Storage Installation (ISFSI). Spent fuel pools are able to withstand the same degree of environmental hazard as the reactors, and will be operated by certified fuel handlers on shift around the clock.

Each spent fuel pool has redundant and independent cooling systems, power supplies, pool water sources, and other safety and emergency equipment. Both spent fuel pools and the IFSFI are protected by the San Onofre physical security force and its associated security systems.

Inspections of fuel pool safety will continue semi-annually under NRC spent fuel safety rules for permanently shut reactors.

Spent Fuel Storage at San Onofre: Dry Cask

Due to the lack of a national repository, the ISFSI is a cask storage facility needed as an alternative to spent fuel pools. The Nuclear Waste Policy Act of 1982 and 1987 amendments laid out a process for licensing a geologic repository, but that may be decades away.

Dry cask storage was developed to meet the need for expanded on-site storage due to lack of a national repository. Casks are stored in ISFSIs at multiple locations around the U.S. because there is no place to ship the fuel after it cools in pools.

The ISFSI at San Onofre utilizes the Transnuclear Advanced NUHOMS Horizontal Modular Storage System. Its major components are the dry-shielded canister (DSC) and the horizontal storage module (HSM). Each DSC has a 5/8^th inch stainless steel shell with steel internal spacer disks, a welded internal confinement boundary and a separate welded lid.

The DSC is placed horizontally inside each AHSM module, into a steel support structure. The AHSM has steel walls more than 4 feet thick and roof slabs about five feet thick which provide additional structural protection and radiation shielding. The ISFSI pads are steel-reinforced concrete with a minimum 3-feet thickness.

The ISFSI at San Onofre is designed for high-seismicity sites. The Design Basis Earthquake used for the ISFSI is 2.24 times more powerful than that used in licensing the San Onofre reactors.

The San Onofre ISFSI is 19.75 feet above sea level. A maximum flood condition of 29 feet was evaluated, which would put the ISFSI pad under 9 feet of water. The design basis of the pad is to withstand a submersion in 50 feet of water. The maximum wave height under tsunami conditions is estimated at 27 feet – less than the maximum flood conditions evaluated for the site. If the ISFSI were temporarily flooded during a tsunami, no adverse thermal effects would occur. None of these calculations include any estimate of impact mitigation from the 28 foot seawall at San Onofre.

Inspection of the ISFSI are normally performed every two years under NRC regulations. Routine inspections are normally scheduled during ongoing cask loading operations. NRC tries to time ISFSI inspections at times of active loading.

Michael Dusaniwskyj, Economist, Financial Analysis & International Projects Branch, Office of Nuclear Reactor Regulation

Funding Decommissioning: NRC Requirements and Expectations

The process of funding decommissioning begins when a nuclear power plant license is issues. Decommissioning funding should be adequate when decommissioning begins. The NRC regulates safety, not commerce. Therefore, the NRC requirement to provide reasonable assurance of adequate funding for decommissioning is based on protection of public health and safety. Methodologie deemed acceptable by the NRC are provided in 10 CFR 50.75(e).

Assurance of adequate funding for decommissioning is an obligation taken on by the licensee when the NRC issues a license. The NRC maintains a comprehensive, regulation-based program to provide reasonable assurance that sufficient funds will be available for radiological decontamination and other essential decommissioning functions for each U.S. commercial nuclear facility. The NRC monitors the amount and adequacy of funds to decommission each plant to NRC standards on decontamination and waste management.

Note: Site restoration at “greenfield” levels is not under NRC jurisdiction, which ceases once the radiological reduction threshold is reached.

San Onofre Decommissioning Costs

Funds are kept in a dedicated trust account. The NRC monitors not only the amount but the purchasing power adequacy of these funds over time.

As of December 31, 2012, the San Onofre decommissioning account contained the following amounts:

• $1,666,100,000 for Unit 2
• $1,890,800,000 for Unit 3
• $295,700,000 for Unit 1 in remaining funds versus
• $206,500,000 for Unit 1 estimated remaining costs

(note: Unit 1 is partially decommissioned but the reactor vessel remains on site)

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