3F0323-03, Decommissioning Funding Plan for Independent Spent Fuel Storage Installation

Decommissioning Funding Plan for Independent Spent Fuel Storage Installation

ML23090A235
Person / Time
Site:	Crystal River
Issue date:	03/31/2023
From:	State S ADP CR3
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
3F0323-03
Download: ML23090A235 (1)

Text

ADP CR3, LLC 17103 Preston Road, Suite 200 l Dallas, TX 75248 Scott E. State, P.E., Chief Nuclear Officer sstate@NorthStar.com l o.682.503.2240 l c.303.898.8035 10 CFR 72.4 10 CFR 72.30(b)

March 31, 2023 3F0323-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation

References:

1. Letter, Duke Energy Florida, LLC to USNRC, Application for Order Consenting to Direct Transfer of Control of Licenses and Approving Conforming License Amendment, dated June 14, 2019 (ML19170A194)

2. Letter, USNRC to Duke Energy Florida, LLC, Crystal River Unit 3 Nuclear Generating Plant Order Approving Transfer of Licensed Authority from Duke Energy Florida, LLC to ADP CR3, LLC and draft conforming administrative license amendment (EPID L-2019-LLA-0135), dated April 1, 2020 (ADAMS Accession Nos. ML20069A023, ML20069A024. ML20069A025, ML20069A026, ML20069A027, ML20101G582 and ML20101G583)

3. Letter, ADP CR3, LLC to USNRC, Crystal River 3 ISFSI Decommissioning Trust, dated October 28, 2020 (ADAMS Accession No. ML20302A543)

4. Letters, ADP CR3, LLC to USNRC, Crystal River 3 - Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2021 and 2022, dated March 30, 2022 and March 29, 2023(ADAMS Accession Nos. ML22089A163 and ML23088A387)

Dear Sir or Madam:

In accordance with 10 CFR 72.30, Financial Assurance and Recordkeeping for Decommissioning, ADP CR3, LLC (ADP CR3) is submitting the Crystal River Nuclear Plant (CR3) decommissioning funding plan for the Independent Spent Fuel Installation (ISFSI). 10 CFR 72.30(c) requires that the decommissioning funding plan be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination at intervals not to exceed 3 years.

A change to the spent fuel management strategy was described by Duke Energy Florida, LLC (DEF), ADP CR3, LLC (ADP CR3), and ADP SF1, LLC (ADP SF1) in the application for license transfer (Reference 1) and was approved by the NRC in Reference 2. Under the terms of the license transfer, ADP CR3 became the NRC operator licensee responsible for all activities under the Crystal River Unit 3 Nuclear Plant (CR3)

U. S. Nuclear Regulatory Commission Page 2 of 3 3F0323-03 license. Under a Purchase and Sale Agreement (PSA) with DEF as part of the license transfer, ADP SF1 acquired the ISFSI, its associated equipment, the high-level radioactive and greater than Class C (GTCC) waste, and title to the spent nuclear fuel. DEF also assigned to ADP SF1 its Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste with the U.S. Department of Energy (DOE).

ADP SF1 entered into an operating agreement with ADP CR3, to possess and maintain the ISFSI, its associated equipment, and spent nuclear fuel.

As a result of the PSA, after October 1, 2020, funding for spent fuel management costs for CR3 is no longer provided by the 10 CFR 50.75 nuclear decommissioning trust (NDT). In accordance with the Decommissioning Services agreement and 10 CFR 72.30(e)(1), a dedicated ISFSI Decommissioning Trust Fund in the form of prepayment method has been established by ADP SF1 as described in Reference 3.

This letter constitutes a certification that financial assurance is provided to cover the estimated cost of ISFSI decommissioning as described in Attachment 1.

This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact me at the numbers above.

Sincerely, ADP CR3, LLC Scott E. State, P.E.

Chief Nuclear Officer Attachments:

Attachment 1 - 10 CFR 72.30 ISFSI Decommissioning Funding Plan cc: NMSS Project Manager Regional Administrator, Region I

Test U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 3 of 7 ADP CR3, LLC DOCKET NUMBERS 50 - 302 / 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 1 Crystal River Unit 3 ISFSI Decommissioning Funding Plan

Test U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 4 of 7 Crystal River Unit 3 ISFSI Decommissioning Funding Plan In accordance with 72.30(c), this decommissioning funding plan is being resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. This decommissioning funding plan updates the previous plan submitted on March 19, 2020 and specifically considers the effect of the following events on decommissioning costs:

• Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

• Facility modifications.

• Changes in authorized possession limits.

• Actual remediation costs that exceed the previous cost estimate.

The following statements specifically address the above events defined in 10 CFR 72.30(c). Since the submittal of the Decommissioning Funding Plan for the ISFSIs dated March 19, 2020:

1. No spills of radioactive materials producing additional residual activity in on-site subsurface material have occurred for Crystal River Nuclear Plant.

2. Modifications to the ISFSI were made in 2021 and 2022. Two additional Horizontal Storage Modules (HSMs) including roof and vent sections along with two additional shield walls were installed on the ISFSI to store two Radioactive Waste Containers (RWCs). The two RWCs filled with reactor-related Greater Than Class C (GTCC) waste were installed in 2022. These additions were incorporated into the ISFSI decommissioning costs.

3. There were no changes in authorized possession limits for any of the sites.

4. No active decommissioning has occurred for the ISFSI, thus there have not been any actual remediation costs that exceed the previous cost estimate.

The requirements of a decommissioning funding plan in 10 CFR 72.30(b) are provided below.

1. Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the CR3 ISFSI.

2. A detailed cost estimate for decommissioning, in an amount reflecting:

• The cost of an independent contractor to perform all decommissioning activities;

• An adequate contingency factor; and

• The cost of meeting the criteria for unrestricted use in 10 CFR § 20.1402.

The design and capacity of the CR-3 ISFSI is based upon the NUHOMS-32PTH1 Type 2-W spent fuel storage systems. The systems consist of a stainless-steel Dry Shielded Canister (DSC), and a concrete Horizontal Storage Module (HSM), which houses the DSC during storage. The ISFSI consists of 40 HSMs with 39 NUHOMS-32PTH1 Type 2-W DSCs that can house up to 32 spent

Test U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 5 of 7 fuel assemblies each. Two additional HSMs housing two RWCs are also located at the ISFSI.

All CR-3 spent fuel is projected to be fully removed from the site in 2036.

Details of the NUHOMS spent fuel storage system, including physical dimensions, can be found in the proprietary version of the Final Safety Analysis Report for the Transnuclear NUHOMS, Docket Number 72-1004.

The methodology used to develop this detailed cost estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates." 1 The methodology includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal and removal of components. Undistributed costs are typically time-dependent costs such as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology also uses a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In this detailed cost estimate, contingency fulfills this role.

Specifically, contingency is added to all costs at a constant 25% rate, consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757 2.

In addition, the detailed cost estimate is based on or includes the following:

• the expected ISFSI configuration after all spent fuel and Greater than-Class- C (GTCC) material has been removed from the site.

• the ISFSI pads not being contaminated, with only verification surveys to be performed;

• the costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use;

• no remediation of contaminated (radiological) soil being required in order to terminate the site operating license;

• no expected interior or exterior radioactive surface contamination of the HSMs; and 1

Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. This document is referenced in NRCs NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors.

2 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012

Test U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 6 of 7

• an allowance for module remediation of 6 modules that are assumed to have some level of neutron-induced activation after approximately 20 years of storage (i.e., to levels exceeding free-release limits). Controlled disposal costs are included for this allowance of concrete and steel.

The cost to dispose of residual radioactivity and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, forms the basis of this cost estimate.

A detailed breakdown of the cost to decommission the CR-3 ISFSI is provided below in TABLE 1

- ADP CR3 ISFSI DECOMMISSIONING COST ESTIMATE. This table also provides the estimates for various support costs that are performed and funded by ADP CR3 from the CR3 nuclear decommissioning trust. This ISFSI decommissioning cost estimate has been previously presented in ADP CR3s Annual Decommissioning and Irradiated Fuel Management Financial Status Reports for 2021 and 2022. TABLE 3.1 from those reports is reproduced below to provide the annual cash flows for ISFSI decommissioning in this report.

ADP CR3 has initiated a Firm Fixed Price subcontract to minimize the overall cost and schedule risk of the ISFSI decommissioning project.

Activity costs for ISFSI decommissioning are divided into 3 phases. The first phase covers initial planning during which the empty casks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination are developed.

The next phase includes the cost of removal, packaging, transportation, and disposal of the activated components, including supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, the verification survey, and the associated equipment and laboratory support. The cost estimate also includes costs for the NRC and NRC contractor reviews, CR3's oversight staff, site security (industrial), and other site operating costs. The contents of the ISFSI are expected to be removed and transferred to the Department of Energy beginning in 2036, with a 2037 completion date for removal of all CR3 spent fuel. The ISFSI will then be promptly decommissioned.

3. Identification of and justification for using the key assumptions contained in the DCE.

The assumptions and justification for those assumptions included in the CR3 ISFSI decommissioning cost estimate are presented in the Section 2 above.

Test U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 7 of 7

4. A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

In accordance with the Order approving the direct transfers to ADP CR3, LLC (ADP CR3) of the Duke Energy Florida, LLC (DEF) licensed authority under Facility Operating License No. DPR 72 for the Crystal River Unit 3 Nuclear Generating Plant (CR3) (the Facility License) and the general license for the CR3 Independent Spent Fuel Storage Installation (ISFSI) (the Licenses) to possess, maintain, and decommission CR3 and the ISFSI (collectively, the CR3 Facility),

dated April 1, 2020 (Reference 1), ADP CR3, submitted the Crystal River 3 ISFSI Decommissioning Trust Agreement on October 28, 2020 in Reference 3.

In accordance with the Decommissioning Services Agreement, ADP SF1 would establish the CR3 ISFSI Decommissioning Trust for the purpose of holding funds to decommission the ISFSI.

The Crystal River ISFSI Decommissioning Trust was executed on 10/1/20. As described in the License Transfer Application, the initial deposit of $3.95M was made to establish the trust.

The current balance of $3.886M, at the 50.82(a)(8)(vi) allowed rate of return of 2%, is expected to grow to $5.127M by 2037 when ISFSI decommissioning costs are projected to be incurred. As provided in the ADP CR3s Annual Decommissioning and Irradiated Fuel Management Financial Status Reports for 2021 and 2022 (Reference 4), $4.587M is the decommissioning cost estimate for the CR3 ISFSI, therefore the ISFSI Decommissioning Trust is considered fully funded, in accordance with 72.30(e)(1), Prepayment method, with no future contributions planned.

5. The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

6. A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

ADP CR3 hereby certifies that financial assurance for decommissioning the CR3 ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described in Part 4 above.

U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 8 of 7 TABLE 1 - ADP CR3 ISFSI DECOMMISSIONING COST ESTIMATE Crystal River Unit 3 - ISFSI Decommissioning Costs and Waste Volumes Costs Waste Person-Hours (Thousands of 2023 dollars) Volume Class A (Cubic Oversight and Removal Packaging Transport Disposal Other Total Craft feet) Contractor Decommissioning Contractor (Paid from ISFSI Demo Trust Acct.)

Planning

- - - - $231 $231 0 0 1,458 (characterization, specs & procedures)

Decontamination/Demolition

$377 $166 $1,146 $1,685 $35 $3,409 16,619 5,444 (Active Cask Disposition)

License Termination

- - - - $947 $947 0 5,729 -

(radiological surveys)

Subtotal $377 $166 $1,146 $1,685 $1,213 $4,587 16,619 11,173 1,458 Supporting Costs (Funded by ADP CR3, LLC)

Contracted Services - - - - $239 $239 0 0 1,992 NRC/State Fees - - - - $126 $126 0 0 -

Insurance - - - - $119 $119 0 0 -

All Labor - Loaded - - - - $770 $770 0 0 6,417 Materials & Supplies - - - - $25 $25 0 0 -

Misc./Personal Expenses - - - - $22 $22 0 0 -

Property & Other Taxes (Entergy Estimate) - - - - $184 $184 0 0 -

Utilities - - - - $24 $24 0 0 -

ISFSI Fuel Management & Operations - - - - $116 $116 0 0 967 Subtotal $0 $0 $0 $0 $1,625 $1,625 0 0 9,375 GRAND TOTAL $377 $166 $1,146 $1,685 $2,838 $6,212 16,619 11,173 10,833

Test U. S. Nuclear Regulatory Commission Attachment 1 3F0323-03 Page 9 of 7 TABLE 3.1 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - ISFSI Decommissioning - TABLE 3.1 (Thousands of 2023 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Spent Fuel Beginning of End-Of-Year ADP ADP Annual Earnings Year Management Period Fund Fund Withdrawals Distributions on Fund

- ISFSI Demo Balance Balance 2023 $0 $3,886 $0 $0 $78 $3,964 2024 $0 $3,964 $0 $0 $79 $4,043 2025 $0 $4,043 $0 $0 $81 $4,124 2026 $0 $4,124 $0 $0 $82 $4,206 2027 $0 $4,206 $0 $0 $84 $4,290 2028 $0 $4,290 $0 $0 $86 $4,376 2029 $0 $4,376 $0 $0 $88 $4,464 2030 $0 $4,464 $0 $0 $89 $4,553 2031 $0 $4,553 $0 $0 $91 $4,644 2032 $0 $4,644 $0 $0 $93 $4,737 2033 $0 $4,737 $0 $0 $95 $4,832 2034 $0 $4,832 $0 $0 $97 $4,928 2035 $0 $4,928 $0 $0 $99 $5,027 2036 $0 $5,027 $0 $0 $101 $5,127 2037 $4,587 $5,127 $4,587 -$540 $0 $0 TOTAL $4,587 $3,886 $4,587 -$540 $1,241 $0