Next Steps in the Retirement of the San Onofre Nuclear Generating Station - SONGS
Posted June 17, 2013
Now that Southern California Edison (SCE) has decided to permanently retire the San Onofre Nuclear Generating Station (SONGS) (the plant has been shut down since early 2012), the company must begin the process of decommissioning, which involves safely removing SONGS from service, reducing the residual radioactivity low enough so as to allow the release of the property, and formal termination of its Nuclear Regulatory Commission (NRC) operating license. There are basically four steps to this process. First, the reactor operator must unload spent fuel from the core to the pool for final cooling. Second, remaining spent fuel in the pool is transferred into dry storage (in a cask) onsite. Third, there is a potentially long waiting period of decades until some portion of the radioactivity has decayed and the decommissioning fund is fully collected. And finally, fourth, the plant is dismantled and the site is returned to “restricted” or “unrestricted” use.
California, by way of the state’s Public Utilities Commission, adopted a policy that required utilities to set up an independently administered fund early on to handle decommissioning costs, a fund that is external to the utility’s assets and more or less beyond their control. Hopefully, as a result SONGS will avoid much controversy along these lines. This is not always the case, however, where the decommissioning process has seen a fair amount of controversy for decades, mostly over the costs, timing, and final cleanup standards. Describing the process at the Zion Nuclear Generating Station in Illinois in 2010, the New York Times noted: “the cost of dismantling the vast steel and concrete building, with multiple areas of radioactive contamination, would exceed $1 billion, double what it had cost to build the reactors in the 1970s. Nor could Commonwealth Edison walk away from the plant, because of the contamination.”
Under NRC regulations, typically have 60 years to complete decommissioning operations. Whether to immediately begin decontamination and dismantling (referred to as DECON by the NRC) or delay this until a later date allowing the decay of radioactive materials before any further actions (known as SAFSTOR), the NRC oversight process will remain in effect, along with other agencies such as the Occupational Safety and Health Administration (OSHA), Department of Transportation and the Environmental Protection Agency (EPA). In pursuing either of the DECON or SAFSTOR options, a complete decommissioning will eventually depend on the approval of the NRC and the availability of waste disposal sites.
In 1996, NRC wrote a new rule that stated no major decommissioning activities to be undertaken until after specific planning documents are provided to the NRC and to the public. The NRC will hold a public meeting after the submittal of the post-shutdown decommissioning activities report (PSDAR) and another meeting following the license termination plan (LTP). According to a Nuclear Energy Institute (NEI) fact sheet on decommissioning, the operator must submit its PSDAR within two years following the shutdown. This report will describe the planned decommissioning options (DECON, SAFSTOR, etc.), schedules for completion, discussion of how activities will adhere to previously issued EISs, and estimates of the costs. The licensee will not be able to access the full fund for decommissioning until their cost-estimates have been accepted by the NRC.
An opportunity for a public hearing request will be provided prior to the issuance of a license amendment approving the License Termination Plan. According to 10 CFR 20.1405, upon receipt of the LTP or decommissioning plan, the Commission shall notify and solicit comments from local/State governments and tribes that could be affected, as well as the EPA if the licensee intends to decommission according to 10 CFR 20.1404. Following this, the NRC will publish a notice in the Federal Register (as well as local forums) to solicit comments from the public. At the end of 90 days, if the NRC has no objections, they may begin decommissioning.
The entire process involves three main stages: (1) initial activities, (2) major decommissioning activities, and (3) license termination activities. A short description of each of these stages is provided on the NRC’s webpage fact sheet on decommissioning, which describes the steps required by the licensee and the NRC, as well as requirements to involve the public and control the use of the decommissioning fund.
For more information, see Table in NRC’s webpage fact sheet on decommissioning.
Once the plant is permanently shut down and the necessary planning phases have been submitted to the NRC, the plant will at some point begin decontaminating and/or removing contaminated equipment and materials, and placing spent fuel in dry storage until its final disposal. The removal of all this material and equipment is to reduce any exposures that may occur to workers as they continue with the decommissioning process.
Following this step, they still must deal with the remaining contamination during a cleanup phase that involves using chemical, physical, electrical, and ultrasonic processes to remove radioactive material from areas like inside pipes or on floors and walls that were previously inaccessible. This removed material will be concentrated, packaged and transported to a low-level waste site or stored onsite.
The decontamination process can take over 5 years to complete and is a pre-requisite for terminating the license.
NRC requires the owner to establish a fund for each reactor that aims to deal with those costs that are specifically related to the portion of the site that has been contaminated by radioactive material, but does not require funds for dismantling buildings/facilities that do not pose a radiation hazard to workers or the public. Companies must review their funds and all associated planning each year and report to the NRC every two years estimating the minimum amount of money required for decommissioning operations and the adequacy of the fund being used to accumulate it. The size of the fund is supposed to be adjusted periodically to reflect current costs for labor, required energy, disposal, and potentially use any innovations in technology that would impact this assessment. Industry compliance with these requirements is not precise. As the New York Times noted last year, “Entergy is at least $90 million short of the projected $560 million cost of dismantling Vermont Yankee; the company is at least $500 million short of the $1.5 billion estimated cost of dismantling Indian Point 2 and 3.”
The size of funds generally range from $300 million to $400 million and the formulas for calculating the minimum requirement as reported in the operators two-year reports to the NRC can be found in 10 CFR 50.75(c). For SONGS (which is a PWR with a greater than 3400 MWt power level), the minimum required is $105 million (January 1986 dollars) and must also incorporate an adjustment factor at least equal to 0.65 L + 0.13 E + 0.22 B, where L and E are escalation factors for labor and energy, respectively, and are to be taken from regional data of U.S. Department of Labor Bureau of Labor Statistics and B is an escalation factor for waste burial and is to be taken from NRC report NUREG-1307, "Report on Waste Burial Charges."
- 10 CFR Part 20 Subpart E
- 10 CFR Part 50.75 Reporting and recordkeeping for decommissioning planning
- 10 CFR Part 50.82 Termination of license
- 10 CFR Part 51.53 Postconstruction environmental reports
- 10 CFR Part 51.95 Final Environmental Impact Statements—Production and Utilization Facilities
 See, Aging Nuclear Power Plants: Managing Plant Life and Decommissioning, September 1993, Office of Technology Assessment, https://www.fas.org/sgp/othergov/doe/lanl/lib-www/ota/00418532.pdf; and for a more recent treatment in the press, see As Reactors Age, the Money to Close Them Lags, Matthew L. Wald., March 20, 2012, found online at http://www.nytimes.com/2012/03/21/science/earth/as-nuclear-reactors-age-funds-to-close-them-lag.html?partner=rss&emc=rss&pagewanted=all.
 See, After the Nuclear Plant Powers Down, New York Times, Matthew L. Wald, Nov. 22, 2010, online at http://www.nytimes.com/2010/11/23/business/23nuke.html?pagewanted=all&_r=0
 See, As Reactors Age, the Money to Close Them Lags, Matthew L. Wald., March 20, 2012, found online at http://www.nytimes.com/2012/03/21/science/earth/as-nuclear-reactors-age-funds-to-close-them-lag.html?partner=rss&emc=rss&pagewanted=all.