3F0320-03, Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2019

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Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2019
ML20079D922
Person / Time
Site: Crystal River  
Issue date: 03/19/2020
From: Hobbs T
Duke Energy Florida
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
3F0320-03
Download: ML20079D922 (9)


Text

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428 Docket 50-302 Docket 72-1035 Operating License No. DPR-72 10 CFR 50.82 10 CFR 50.75 March 19, 2020 3F0320-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2019

References:

1. NRC to CR-3 letter dated March 13, 2013, Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor (ADAMS Accession No. ML13058A380)
2. CR-3 to NRC letter dated December 2, 2013, Crystal River Unit 3 - Post-Shutdown Decommissioning Activities Report (ADAMS Accession No. ML13340A009)
3. NRC to CR-3 letter dated January 26, 2015, Crystal River Unit 3 Nuclear Generating Plant - Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.75(h)(2) (ADAMS Accession No. ML14247A545)
4. NRC to CR-3 letter dated March 11, 2015, Crystal River Unit 3 Nuclear Generating Plant Post-Shutdown Decommissioning Activities Report (ADAMS Accession No. ML14321A751)
5. CR-3 to NRC letter dated June 28, 2018, Crystal River Unit 3 - 2018 Decommissioning Cost Estimate (ADAMS Accession No. ML18178A181)
6. CR-3 to NRC letter dated June 28, 2018, Application for Order Consenting to Direct Transfer of Control of Licenses and Approving Conforming License Amendment (ADAMS Accession Nos. ML19170A194, ML19170A195)

Dear Sir:

In accordance with 10 CFR 50.75(f)(1), 10 CFR 50.82(a)(8)(v), 10 CFR 50.82(a)(8)(vi), and 10 CFR 50.82(a)(8)(vii), Duke Energy Florida, LLC, (DEF) is submitting the annual status of decommissioning funding, status of funding for managing irradiated fuel, and the financial assurance status report for 2019. In Reference 1, the NRC acknowledged Crystal River Unit 3 Nuclear Generating Plant (CR-3) certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. In Reference 2, DEF submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) containing a

site-specific Decommissioning Cost Estimate (DCE) pursuant to 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). Accordingly, a status of decommissioning funding pursuant to 10 CFR 50.75(f)(1), a financial assurance status report pursuant to 10 CFR 50.82(a)(8)(v) and 10 CFR

U. S. Nuclear Regulatory Commission Page 2 of 3 3F0320-03 50.82(a)(8)(vi), and a report on the status of the funding for managing irradiated fuel pursuant to 10 CFR 50.82(a)(8)(vii) are required to be submitted by March 31 of each year.

In Reference 3, the NRC provided its approval of the CR-3 exemption request to use the funds from the CR-3 Decommissioning Trust Funds for Irradiated Fuel Management and Site Restoration Costs. The financial assurance demonstration performed in this submittal has been prepared consistent with that exemption request. In Reference 4, the NRC found that the PSDAR contained the necessary information required by 10 CFR 50.82(a)(4)(i) and was consistent with the guidance of Regulatory Guide 1.185.

In Reference 5, DEF submitted an updated site-specific DCE that reflects current plant conditions, assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. This update was performed at the request of Duke Energy management to verify sufficient funds remain to continue to demonstrate financial assurance and was not performed to satisfy any NRC regulation. The cash flows in this updated DCE are being used by DEF as the basis for demonstrating funding status in this Annual Decommissioning and Irradiated Fuel Management Financial Status Report, submitted pursuant to 10 CFR 50.75 (f)(1) and 10 CFR 50.82(a)(8)(v) - (vii).

In Reference 6, DEF submitted an Application for Order Consenting to Direct Transfer of Control of Licenses and Approving Conforming License Amendment. As of December 31, 2019, the effective date of this submittal, the NRC approval and Conforming License Amendment has not been implemented; therefore, the updated site-specific DCE (Reference 5) is being used by DEF as the basis for demonstrating funding status in this Annual Decommissioning and Irradiated Fuel Management Financial Status Report, submitted pursuant to 10 CFR 50.75 (f)(1) and 10 CFR 50.82(a)(8)(v) - (vii).

The attachments to this letter contain the information required by the above regulations for DEF.

The report contains the following required information:

(1)

The amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c), (While DEF is identifying this amount because it is specified in 10 CFR 50.75(f)(1), it does not appear applicable to a plant that has permanently ceased operation, has submitted a site specific cost estimate, and is engaged in decommissioning.)

(2)

The amount of decommissioning funds accumulated to the end of the calendar year preceding the date of this report, (3)

A schedule of annual amounts remaining to be collected, (4)

The assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections, (5)

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v),

(6)

Any modifications occurring to a licensees current method of providing financial assurance since the last submitted report, (7)

Any material changes to trust agreements or financial assurance contracts, (8)

The amount spent on decommissioning, both cumulative and over the previous calendar year, (9)

The remaining balance of any decommissioning funds, (10) The amount provided by other financial assurance methods being relied upon,

U.S. Nuclear Regulatory Commission 3F0320-03 Page 3 of 3 (11) An estimate of the costs to complete decommissioning, reflecting any difference between actual and estimated costs for work performed during the year, (12) The decommissioning criteria upon which the estimate is based, (13) If the sum of the balance of any remaining decommissioning funds, plus earnings on such funds calculated are not greater than a 2 percent real rate of return, together with the amount provided by other financial assurance methods being relied upon, does not cover the estimated costs to complete the decommissioning, the financial assurance status report must include additional financial assurance to cover the estimated cost of completion, (14) The amount of funds accumulated to cover the cost of managing the irradiated fuel, (15) The projected cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Secretary of Energy, and (16) If the funds accumulated do not cover the projected cost (of irradiated fuel), a plan to obtain additional funds to cover the cost.

The adjustment factors for labor rates and energy costs used in Item (1) for the calculation in 1 0 CFR 50.75(c)(2) are determined using the December 2019 indices from the U.S. Department of Labor, Bureau of Labor Statistics. The adjustment factor for the cost of low-level waste burial charges used in Item (1) for the calculation in 10 CFR 50.75(c)(2) is determined using NUREG-1307, Revision 17, "Report on Waste Burial Charges."

No new regulatory commitments have been made in this letter.

If you have any questions regarding this submittal, please contact Mr. Mark Van Sicklen, Licensing Lead, Nuclear Regulatory Affairs, at (352) 501-3045.

Sincert' I wll Terry Ho~

General Manager, Decommissioning TDH/mvs Attachments: - Duke Energy Florida, Crystal River Unit 3 Funding Status Report - Crystal River Unit 3, Estimate of Costs to Complete Decommissioning and Financial Assurance Demonstration xc:

NMSS Project Manager Regional Administrator, Region I

DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 50 - 302 / 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 1 CRYSTAL RIVER UNIT 3 FUNDING STATUS REPORT

, Page 1 of 2 Footnotes next page Crystal River Item #

Unit 3 10 CFR 50.75(f)(1) - Status of decommissioning funding 1

1a. The amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c);

478,109,208 1b. The amount of decommissioning funds estimated to be required for 755,730,023 1

remaining License Termination costs.

2 The amount of decommissioning funds accumulated to the end of the 741,456,176 2,3 calendar year preceding the date of the report; 3

A schedule of the annual amounts remaining to be collected; None 4

The assumptions used regarding rates of escalation in decommissioning inflation 2.8% 4 costs, rates of earnings on decommissioning funds, and rates of other qualified rate of return 5.10% 4 factors used in funding projections; 5

Any contracts upon which the licensee is relying pursuant to None paragraph 10 CFR 50.75(e)(1)(v);

6 Any modifications occurring to a licensee's current method of providing None financial assurance since the last submitted report; and 7

Any material changes to trust agreements.

10 CFR 50.82(a)(8)(v) - Financial assurance status report 8

(A) The amount spent on decommissioning, both cumulative and over the 14,338,956 5

- Previous calendar year previous calendar year, 110,881,767 6

- Cumulative 9

The remaining balance of any decommissioning funds, and 741,456,176 2,3 10 The amount provided by other financial assurance methods being relied upon; None 11 (B) An estimate of the costs to complete decommissioning, reflecting any See Attachment 2 difference between actual and estimated costs for work performed during the year, and 12 The decommissioning criteria upon which the estimate is based; Unrestricted Release 13 (C) Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report; and None 14 (D) Any material changes to trust agreements or financial assurance contracts.

10 CFR 50.82(a)(8)(vi) 15 10 CFR 50.82(a)(8)(vii) - Report on the status of funding for managing irradiated fuel 16 (A) The amount of funds accumulated to cover the cost of managing the irradiated fuel; 17 (B) The projected cost of managing irradiated fuel until title to the fuel See Attachment 2 and possession of the fuel is transferred to the Secretary of Energy; and 18 None None If the sum of the balance of any remaining decommissioning funds, plus earnings on such funds calculated at not greater than a 2 percent real rate of return, together with the amount provided by other financial assurance methods being relied upon, does not cover the estimated cost to complete the decommissioning, the financial assurance status report must include additional financial assurance to cover the estimated cost of completion.

As demonstrated in Attachment 2, funds accumulated cover estimated cost of completion.

As demonstrated in Attachment 2, funds accumulated cover estimated cost of completion.

(C) If the funds accumulated do not cover the projected cost, a plan to obtain additional funds to cover the cost.

As demonstrated in Attachment 2, funds accumulated cover projected cost of managing irradiated fuel.

NRC Decommissioning Funding Status Report Report Dated as of December 31, 2019 Duke Energy Florida Crystal River Unit 3 100% Ownership

, Page 2 of 2 Footnotes:

1 Total amount of License Termination costs in Attachment 2.

2 Amount is net of 2019 tax obligations.

3 Represents (a) the full fund balance of DEF's qualified and non-qualified decommissioning funds, which, in accordance with the NRC exemption request approval (ADAMS Accession No. 14247A545), can also be used for Spent Fuel Management and Site Restoration costs, and (b) 100% of the funds held by the City of Tallahassee on behalf of DEF, which pursuant to NRC order (ADAMS Accession No. ML020670117) will only be used for NRC radiological decommissioning.

4 Represents values approved by the Florida Public Service Commission in Order No. PSC-14-0702-PAA-EI, issued December 22, 2014, which became effective and final pursuant to Order No. PSC-15-0067-CO-EI, issued on January 23, 2015.

5 Represents the amount actually disbursed from the fund in calendar year 2019 for License Termination costs, not the costs incurred in calendar year 2019. Disbursed amounts in 2019 include costs incurred from October 2018 through October 2019. Outstanding license termination costs of $745,221 for November 2019 and a credit of

$1,873,283 for December 2019 are expected after December 31, 2019.

6 Represents the cumulative amount actually disbursed from the fund as of December 31, 2019 for License Termination costs, not the cumulative costs incurred as of December 31, 2019. Outstanding license termination costs of $745,221 for November 2019 and a credit of $1,873,283 for December 2019 are expected after December 31, 2019.

DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 50 - 302 / 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 2 CRYSTAL RIVER UNIT 3, ESTIMATE OF COSTS TO COMPLETE DECOMMISSIONING AND FINANCIAL ASSURANCE DEMONSTRATION

, Page 1 of 2 Notes next page License Termination Cost (in thousands)

Spent Fuel Cost (in thousands)

Site Restoration Cost (in thousands)

Total Cost (in thousands)

Annual Earnings on Decommissioning Trust Fund at 2%

(in thousands)

All Owners Decommissioning Trust Fund Year-End Balance (in thousands) 2019 741,456 2020 7,757 3,110 0

10,867 14,720 745,309 2021 7,735 3,188 0

10,923 14,797 749,183 2022 7,735 3,102 0

10,837 14,875 753,221 2023 7,735 3,102 0

10,837 14,956 757,340 2024 7,757 3,196 0

10,953 15,037 761,424 2025 7,735 3,102 0

10,837 15,120 765,707 2026 7,735 3,102 0

10,837 15,206 770,076 2027 7,735 3,188 0

10,923 15,292 774,445 2028 7,757 3,110 0

10,867 15,380 778,958 2029 7,735 3,102 0

10,837 15,471 783,592 2030 7,735 3,188 0

10,923 15,563 788,232 2031 7,735 3,102 0

10,837 15,656 793,051 2032 7,757 3,110 0

10,867 15,752 797,936 2033 7,735 3,188 0

10,923 15,849 802,862 2034 7,735 3,102 0

10,837 15,949 807,974 2035 7,735 3,102 0

10,837 16,051 813,188 2036 7,757 3,196 0

10,953 16,154 818,389 2037 7,735 8,320 0

16,056 16,207 818,540 2038 4,132 0

0 4,132 16,329 830,738 2039 4,132 86 0

4,218 16,573 843,092 2040 4,144 0

4,144 16,820 855,768 2041 4,132 0

4,132 17,074 868,710 2042 4,132 0

4,132 17,333 881,910 2043 4,132 0

4,132 17,597 895,375 2044 4,144 0

4,144 17,866 909,097 2045 4,132 0

4,132 18,141 923,105 2046 4,132 0

4,132 18,421 937,393 2047 4,132 0

4,132 18,707 951,967 2048 4,144 0

4,144 18,998 966,821 2049 4,132 0

4,132 19,295 981,984 2050 4,132 0

4,132 19,598 997,450 2051 4,132 0

4,132 19,908 1,013,225 2052 4,144 0

4,144 20,223 1,029,304 2053 4,132 0

4,132 20,545 1,045,716 2054 4,132 0

4,132 20,873 1,062,457 2055 4,132 0

4,132 21,208 1,079,532 2056 4,144 0

4,144 21,549 1,096,938 2057 4,132 0

4,132 21,897 1,114,703 2058 4,132 0

4,132 22,253 1,132,823 2059 4,132 0

4,132 22,615 1,151,306 2060 4,144 0

4,144 22,985 1,170,146 2061 4,132 0

4,132 23,362 1,189,375 2062 4,132 0

4,132 23,746 1,208,989 2063 4,132 0

4,132 24,138 1,228,995 2064 4,144 0

4,144 24,538 1,249,390 2065 4,132 0

4,132 24,946 1,270,204 2066 4,132 0

4,132 25,363 1,291,434 2067 27,098 448 27,546 25,553 1,289,441 2068 68,213 1,434 69,647 25,092 1,244,886 2069 133,736 1,678 135,414 23,544 1,133,016 2070 111,475 1,269 112,744 21,533 1,041,805 2071 90,745 888 91,633 19,920 970,092 2072 59,544 345 59,889 18,803 929,005 2073 5,549 27,540 33,089 18,249 914,166 2074 102 20,371 20,472 18,079 911,772 Total1

$755,730

$61,693

$53,972

$871,395

$1,041,711 Crystal River Unit 3 - Financial Assurance Demonstration December 31, 2019

, Page 2 of 2 Notes:

License Termination Cost - Reflects the License Termination cost portion of the Decommissioning Cost Estimate (DCE) escalated to 2019 dollars at the Consumer Price Index escalation rate of 2.5% for 2018 and 2.3% for 2019.

Spent Fuel Management Cost - Reflects the Spent Fuel Management cost portion of the Decommissioning Cost Estimate (DCE) escalated to 2019 dollars at the Consumer Price Index escalation rate of 2.5% for 2018 and 2.3% for 2019.

Site Restoration Cost - Reflects the Site Restoration cost portion of the Decommissioning Cost Estimate (DCE) escalated to 2019 dollars at the Consumer Price Index escalation rate of 2.5% for 2018 and 2.3% for 2019.

Total Cost - Reflects the sum of the License Termination, Spent Fuel Management and Site Restoration costs.

Projected Annual Earnings on Decommissioning Trust Fund at 2% - Reflects earnings on funds remaining in the trusts. Pursuant to 10 CFR 50.82(a)(8)(vi), a 2% real rate of return is used in this financial analysis. The earnings are calculated on the previous year's end-of-year fund balance (Column F) less 50% of the given year's annual expenses.

All Owners Decommissioning Trust Fund Year-End Balance - Reflects the end-of year fund balance of all funds after all projected earnings are added and projected expenditures are deducted. The 2019 end-of-year fund balance includes 100% of the $7,300,493 in funds held by the City of Tallahassee on behalf of Duke Energy Florida, which pursuant to NRC order (ADAMS Accession No. ML020670117) will only be used for NRC radiological decommissioning.

For the purposes of demonstrating financial assurance in accordance with 10 CFR 50.82(a)(8)(vi), the methodology and assumptions in this analysis are consistent with the March 28, 2014, Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(2) (ADAMS Accession No. ML14098A037), which was approved by NRC on January 26, 2015 (ADAMS Accession No. ML14247A545).

1 Total may not add due to rounding.