 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
|
Prepared Witness Testimony The House Committee on Energy and Commerce
Comprehensive National Energy Policy
Subcommittee on Energy and Air Quality
Mr. Jeff Benjamin
Mr. Chairman and Members of the Subcommittee: I am Jeff Benjamin, Vice President of Licensing and Regulatory Affairs for Exelon Nuclear, a subsidiary of Exelon Corporation. Thank you for the opportunity to share Exelon Corporation's views on the nuclear energy provisions of Chairman Barton's draft comprehensive energy legislation being considered by the Subcommittee. Exelon Corporation is one of the largest electric suppliers in the United States, with major interregional operations in generation, transmission, distribution and marketing. Our two utilities, Commonwealth Edison of Chicago and PECO Energy of Philadelphia, serve approximately 5.1 million retail customers, the largest customer base in the country. Exelon and our affiliates own or control generation totaling over 40,000 megawatts, the largest generation portfolio in the country. Our wholesale power marketing division, known as the Power Team, markets the output of our generation portfolio throughout the lower 48 states and Canada with a perfect delivery record. Exelon Nuclear owns the nation's largest fleet of commercial nuclear plants, operating 17 reactors at 10 sites in Illinois, Pennsylvania, and New Jersey. These plants - with 17,800 net megawatts of total operating capacity - represent roughly 20 percent of the nuclear capacity in the United States. During 2002, Exelon's fleet of nuclear plants operated at an average capacity factor of over 92 percent and produced 118.7 million megawatt-hours of electricity, about 3 percent of all the electricity generated in the United States last year. All of this electricity was generated without emitting any criteria air pollutants or greenhouse gases. In fact, Exelon's nuclear fleet avoided the emissions of over 119 million tons of CO2 during 2002. Exelon achieved this performance while refueling 11 reactors in a record average of 22 days and completing the year without a single lost-time or restricted-duty injury at 9 of our 10 plant sites. As Congress considers changes to America's energy policy, it is important to recognize the role of nuclear power and to make changes to Federal policy that will promote a diversity of generation technologies in the future. Exelon firmly believes that nuclear power will continue to play a valuable role in providing the nation with a safe, affordable, and environmentally-friendly supply of electricity, and I encourage the committee to move forward with many of the nuclear energy-related proposals included in Chairman Barton's draft legislation. Comments on Title IV Subtitle A. Price-Anderson Act Renewal Subtitle A of Title IV would renew the Price-Anderson Act, legislation that ensures that the public is quickly compensated in the event of a radiological event at a commercial nuclear reactor. Exelon supports Price-Anderson renewal, both to continue the operation of our current fleet of nuclear plants with contractor support and to provide an essential prerequisite to the potential construction of new nuclear plants. While the draft legislation includes the Price-Anderson provisions approved by the House of Representatives last year, Exelon would encourage the committee to support the Price-Anderson renewal language for commercial nuclear facilities that was agreed to last year by House and Senate conferees to H.R. 4 during conference committee consideration of that legislation. One section of the draft proposal that was not included in last year's conference agreement (Section 4012) addresses the issue of nuclear facility threats. This section of the bill would direct the President, in conjunction with the Nuclear Regulatory Commission (NRC) and other federal, state and local agencies and private entities, to assess the types of threats faced by commercial nuclear facilities. The provision would also direct the President to assess the nature of any threat posed by enemies of the United States and to classify threats as being the primary responsibility of the Federal government or NRC licensees. Much of what is included in Section 4012 has been overtaken by events, namely the creation of the Department of Homeland and the NRC's current effort to develop a revised Design Basis Threat. However, Exelon believes that it remains critical for all relevant agencies of the Federal government - in conjunction with state and local agencies and private entities - to fully examine the new threat environment facing the nation's critical infrastructure industries and to classify threats as being the primary responsibility of either the government or private industry. This should be done prior to the issuance of a new Design Basis Threat. Additional comments on the issue of nuclear security are included later in my testimony. Subtitle B. Miscellaneous Matters Subtitle B includes a number of miscellaneous provisions to amend the Atomic Energy Act. Section 4021 would clarify that the 40-year license period for commercial nuclear reactors begins once the reactor commences operation, not upon approval of the license. Exelon supports this change, which codifies existing Commission policy. Sections 4022 through 4025 address miscellaneous NRC-related issues that have been requested by the Commission. Exelon has no objection to these provisions. Sections 4026 through 4028 include provisions requested by the NRC to address security-related issues. Exelon has no objection to these provisions. Nuclear Security Protection of the health and safety of the public and our employees is of paramount importance to the nuclear power industry. The industry has worked closely with a variety of Federal, state and local officials to identify safeguards and resources necessary to respond to potential threats to plant security, and we are fully supportive of taking all reasonable and necessary steps - whether they be by licensees or the government - to ensure that nuclear plants are able to withstand an attack by terrorists. Commercial nuclear power plants are regarded by many to be the most well-protected industrial facilities in the United States today. Indeed, many other industries are turning to the nuclear industry as a model for providing security at a variety of commercial facilities. For example, in addition to unique physical protections employed at commercial nuclear facilities, the nuclear industry is alone among critical infrastructure industries in using the Federal Bureau of Investigations to run criminal background checks on applicants for positions at sensitive facilities. Since September 11, 2001, the nuclear industry has undertaken extensive measures to enhance security at the nation's 72 commercial nuclear reactor sites, including actions to harden site access, increase security resources, and improve operational readiness. To harden site access, Exelon has:
To increase security resources, Exelon has:
To enhance operational readiness, Exelon has:
Mr. Chairman, I want to stress the multiplicity of concrete actions we have taken since September 11, 2001, to respond to the increased security needs of our Nation and to further enhance our already substantial preparedness. Revision of the Design Basis Threat Since shortly after September 11, the Nuclear Regulatory Commission has been engaged in a top-to-bottom review of the Design Basis Threat (DBT), which defines the nature of threats against which nuclear plant operators are responsible for defending, to reevaluate its adequacy. As an interim measure, the Commission issued Orders on February 25, 2002, that impose significant additional requirements on licensees pending the completion of a more comprehensive review of safeguards and security program requirements. On January 2, 2003, the NRC provided the nuclear industry an opportunity to comment on the "Staff View of Adversary Attributes for Radiological Sabotage." This staff document contains a proposed change to the Design Basis Threat. The NRC proposal contains several significant changes that, if implemented, present a number of considerable policy and legal challenges. These challenges must be addressed by the NRC, in formal consultation with the Department of Homeland Security, other relevant Departments of the Administration, state and local responders and Congress, prior to moving forward with changes to the current DBT. The Future of Nuclear Energy I would now like to discuss Exelon's view on the viability of the nuclear option going forward. Exelon has had a consistent standard for operating our nuclear plants - we will only operate them if they are economical and safe. Opponents of nuclear power frequently claim that the nuclear industry is heavily subsidized. Yet, unlike other generation sources, the nuclear industry incurs several costs unique to electric generators. First, our industry pays for the cost of being regulated by a Federal entity (the Nuclear Regulatory Commission) through the payment of NRC user fees. Second, the industry funds an "industry watchdog" group - the Institute of Nuclear Power Operations - whose main focus is plant safety and the sharing of best practices. Third, the industry fully prepays our ultimate environmental cleanup costs through plant-specific decommissioning funds and the Nuclear Waste Fund. This prevents future generations from inheriting the burden of radiological decommissioning and waste disposal after our plants have shut down. With regard to new nuclear plants, Exelon strongly believes that nuclear power is an option for the future that must be maintained. We also believe that any new nuclear investment must be based on rigorous financial and risk evaluations that reflect the reality of a deregulated market. We are one of three companies pursuing approval of an Early Site Permit (ESP) from the NRC. We are seeking an ESP for our Clinton site in central Illinois with the objective of "banking" the site for potential use in the future (the permit would be good for 20 years). Importantly, this process will serve to test the NRC's process for determining site adequacy. We are also working with the NRC through NEI to develop improved licensing processes for the consideration of new plants. All of these efforts are focused on ensuring that when new plants are built there is a well-defined and predictable regulatory process in place. Even without the addition of new plants, the industry is dramatically increasing the amount of electricity generated from the nuclear sector. Exelon has been a leader in uprating the output of our existing units. In Illinois alone, we have added nearly 800 megawatts of capacity to our plants since 1998 at a cost of just under $300/installed kilowatt. This compares to roughly $800-1000/installed kilowatt to build a new gas or coal plant. Coincident with these uprates, our plants are running more efficiently and safely than ever before. The industry has also been active in pursuing the renewal of operating licenses for existing plants. Exelon has submitted an application to the NRC to extend the licenses for Peach Bottom, Quad Cities, and Dresden for an additional 20 years. The preparation of the Peach Bottom submittal alone involved over 30 man-years of engineering effort to meet the application requirements and to assure the plant can operate safely for another 20 years. We are expecting approval of our Peach Bottom submittal in May. Conclusion Mr. Chairman, thank you for the opportunity to discuss these issues with you. Exelon looks forward to working with you and members of the subcommittee as you consider energy legislation this year.
|
|||||||||||
|
