Despite closing its Wisconsin nuclear plant prematurely last year, Dominion Resources wants to keep its options open in Virginia, where it is considering a third unit at its North Anna nuclear plant.

But it hasn’t done any analysis to compare the risks of a new plant against an increasing reliance on natural gas-fired generation, Virginia State Corporation Commission staff said in a filing last week.

Responding to Dominion Virginia Power’s 2013 Integrated Resource Plan, staff said such an analysis should be included in the company’s next IRP in 2015 in order to determine which option the company should follow in the future.

Dominion “believes that uncertainty associated with the price of natural gas over the long term is a greater risk than the development cost uncertainty of a nuclear unit. However, the company concedes that no analysis has been performed to support this assertion,” SCC staff said. Staff said Dominion has indicated a willingness to conduct the analysis.

Two Plans

In its 2013 IRP, Dominion presented two different plans, one it called the “Base Plan” that calls for the expansion of generating capacity through new natural gas-fired plants, and one it calls the “Fuel Diversity Plan,” which includes low-emission options and does not rely so heavily on natural gas.

Both plans are very similar in the short run, with the major difference being that the latter plan includes the construction of North Anna 3. The company has chosen to follow the Base Plan, the least cost option, but it will also continue to go “forward with reasonable development efforts of additional resources included in the Fuel Diversity Plan,” which “would preserve the company’s ability to implement these alternatives should future conditions warrant,” SCC staff noted.

While natural gas plant projects have low development cost risk, the historically volatile fluctuating fuel price creates the risk of high operating costs. Nuclear plants generally have low operating costs, but their construction is very complicated and prone to cost overruns.

“In other words, there is a risk trade-off of higher operating cost risks with the Base Plan and higher project development cost risks with the Fuel Diversity Plan,” SCC staff said. “Staff was unable to determine whether the Base Plan contains too much operating cost risk, or whether the development cost risk associated with the Fuel Diversity Plan is greater than or less than the reduction in operating cost risk the Fuel Diversity Plan would achieve, because the company did not perform an analysis of this risk trade-off in its IRP.”

Dominion, which applied for Nuclear Regulatory Commission approval of North Anna 3 in 2003, has not committed to building the unit. In its IRP, the company said it would make its final decision once it received a Combined Operating License from the NRC. The unit would be completed no earlier than 2024.

Risky Business

The recent boom in natural gas production, resulting in cheap prices, has not been kind to the nuclear industry. Dominion learned this the hard way last year, when the company was forced to close the 556-MW Kewaunee Power Station, which it had purchased in 2005 for $192 million. After utilities did not renew their power contracts with the Wisconsin plant and Dominion failed to buy other nuclear plants in the region, the company attempted to sell Kewaunee in 2011. When it became apparent there were no buyers, Dominion closed it.

Kewaunee, which opened in 1974, closed a year shy of its 40th birthday, when its license would have needed renewal. Staff at the plant are now beginning the long process of decommissioning it.

With North Anna 3, Dominion seeks to keep all of its options on the table. Mark Kanz, local affairs manager for Kewaunee, recently told Nuclear Power International magazine that the prospect of North Anna 3 “proves that the company sees the benefit of nuclear and is looking forward to continuing that into the future.”

SCC staff also wants the company to compare the costs of building a third unit with the costs of extending the operating licenses of the first two, along with the licenses of the two units at its Surry nuclear plant.

“Given that these units still provide extremely efficient and dependable baseload generation for the company, and given the extremely high costs of constructing new nuclear plants, staff believes that the company should engage in serious discussions with discussions with the NRC to determine whether renewing these licenses is possible.”

The staff noted that it is unknown whether the NRC would grant renewals to the current units. The units would be 60-years-old when their licenses — already extended by 20 years — expired. The NRC expects the first application for an extension beyond 60 years to be filed in 2018 or 2019. Without additional license extensions, the country would face a wave of nuclear plant retirements during the next decade.