AEP-NRC-2018-71, Independent Spent Fuel Storage Installation - Decommissioning Funding Plan

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Independent Spent Fuel Storage Installation - Decommissioning Funding Plan
ML18341A133
Person / Time
Site: Cook, 07200072  American Electric Power icon.png
Issue date: 12/03/2018
From: Lies Q
American Electric Power, Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
AEP-NRC-2018-71
Download: ML18341A133 (6)
v • d • e


Text

a:

INDIANA MICHIGAN POW/ER A unit of American Electric Power December 3, 2018 Docket No.:

50-315 50-316 72-072 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1 and Unit 2 DECOMMISSIONING FUNDING PLAN FOR INDEPENDENT SPENT FUEL STORAGE INSTALLATION Indiana Michigan Power Cook Nuclear Plant One Cook Piace Bridgman, Ml 49106 lndianaMichiganPower.com AEP-NRC-2018-71 10 CFR 72.30(b) 10 CFR 50.4 In accordance with the requirements of 10 CFR 72.30(b), Indiana Michigan Power Company (l&M),

the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, is submitting the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for Nuclear Regulatory Commission review and approval. to this letter provides l&M's ISFSI Decommissioning Funding Plan for CNP. to this letter provides the current decommissioning study for CNP. There are no new or revised commitments in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director at (269) 466-2649.

Sincerely, Q.S:J:~lL Site Vice President KMH/mll

Enclosures:

1. Independent Spent Fuel Storage Installation Decommissioning Funding Plan for Cook Nuclear Plant
2. Decommissioning Study of the D.C. Cook Nuclear Power Plant conducted by Knight Cost Engineering Services, LLC, dated January 21, 2016, Revision 0

U. S. Nuclear Regulatory Commission Page2 c:

R. J. Ancona, MPSC R. F. Kuntz, NRC Washington DC MDEQ-RMD/RPS NRC Resident Inspector S. K. West, Regional Administrator, NRC Region Ill A. J. Williamson - Ft. Wayne AEP, w/o enclosure AEP-NRC-2018-71

ENCLOSURE 1 TO AEP-NRC-2018-71 Independent Spent Fuel Storage Installation Decommissioning Funding Plan for Cook Nuclear Plant

I I

I I

lndependentSpent Fuel Storage Installation Decommissioning Funding Plan.

, for Cook Nuclear Plant As described in 10 CFR 72.13(c), 10 CFR 72.30(b) and (c) applies to licensees with a General License for an Independent Spent Fuel Storage Installation (ISFSI). Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2 has a General License for an ISFSI and therefore is obligated to meet the requirements of 10 CFR 72.30(b).

This Decommissioning Funding Plan provides the required information for U. S.

Nuclear Regulatory Commission review and approval as described in 10 CFR 72.30(b) and (c).

  • 10 CFR 72.30(b)(1) requires information on how reasonable assurance will be provided that funds.will be available to decommission the CNP ISFSI.
  • The projected costs of decommissioning the CNP are collected through jurisdictional rates and earnings on prior collections which are held in external trust*. funds.

The projected

. decommissioning costs are based on a site-specific study that is updated periodically. A recent

  • site specific study was completed January 21, 2016, by Knight Cost Engineering Services (Knight CES).

The site-specific study, provided as Enclosure 2 to. this letter, includes the

. estimates for the cost of d~commissioning the CNP ISFSI. All funds collected for the eventual decommissioning of CNP (including those for decommissioning the ISFSI) are deposited to a Nuclear Decommissioning Trust (NOT) fund that is external to the company.

_10 CFR 72.30(b)(2) requires a detailed cost estimate (DCE) for decommissioning, in an amount that reflects the following:

(i)

The cost of an independent contractor to perform all decommissioning activities; (ii)

  • An adequate contingency factor; and (iii)

The cost of meeting the 1 O CFR 20.1402 criteria for unrestricted use The Knight CES Decommissioning Study assumes that a decommissioning general contractor would be selected to perform the decommissioning activities.

The study also includes

. contingency factors for the various aspects of the decommissioning process, it details and justifies the contingency factors used. The cost estimate also details separately the costs for radiological decommissioning and decontamination, as well as the costs for spent nuclear fuel storage and disposal and the costs to restore the plant site to a Greenfield condition. The study consists of one decommissioning scenario. The cost estimated for ISFSI decommissioning is

$~6,952,278 (see Knight CES Decommissioning Study pages 11 -13, 23, and 30-31).

10 CFR 72.30(b)(3) requires Identification of and justification* for using the key_

assumptions contained in the DCE.

Section 4.0 of the Knight CES Decommissioning Study (pages 14 - 16), describes specific key assumptions regarding the decommissioning cost estimates and contains the justification for the assumptions being made.

to AEP-NRG-2018-71 Page2 10 CFR 72.30(b)(4) requires* a description of the method, of assuring funds for decommissioning from 10 CFR 72.30(e), including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.*

As previously described, l&M. collects the projected costs of decommissioning through

. jurisdictional rates and earnings on prior collections held in external trust funds.

l&M's **

jurisdictional. state commissions review the projected decommissioning costs and the current status of the decommissioning trust fund as part of regulatory proceedings, and can adjust the ongoing amount that will be recovered in rates for decommissioning funding. In addition, l&M

  • periodically submits a Funding Adequacy Study to the state jurisdictional commissions that
  • updates the cost projections and the funded status of the NOT. If the funded status of the NOT was inadequate as compared to the cost estimates, l&M could initiate a rate request to seek a

. revision in the amount collected from customers and contributed to the trust fund.

10 CFR 72,.30(b)(5) requires the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

CNP utilizes the HI-STORM 100 Cask System, which consists of a multi:..purpose canister (MPC) enclosure vessel which is placed inside of a HI-STORM overpack for ISFSI pad storage.

The MPC is loaded, dried, backfilled with helium gas, sealed (welded shut), and decontaminated inside the plant prior to being placed inside the concrete HI-STORM overpack.

  • As described in the Safety Analysis Report, the MPC uses multiple confinement barriers provided bi the fuel. cladding and the MPC enclosure vessel to assure that there is no release of radioactive material to the environment. All confinement boundary components are maintained within their Code-allowable stress limits during normal and off-normal storage conditions. The
    • peak confinement boundary component temperatures and pressures are within the design basis limits for all normal and off-normal conditions of storage. The Holtec MPC design, welding, testing, and inspection requirements meet the guidance of ISG-18 such that leakage from the confinement boundary may. be considered non-credible. Since the MPC confinement vessel remains intact, and the design bases temperatures and pressure are not exceeded, leakage from the MPC confinement boundary is not credible during normal and off-normal conditions of storage..
  • As such there is no source of onsite subsurface material containing residual radioactivity that
  • will require remediation as a result of ISFSI operations and no volume has been assumed in the
  • decommis.sioning cost estimate for the ISFSI.

10 CFR 72.30(b)(6) requires a certification that financial assurance for deco;,missioning has been provided in the amount of the cost estimate for decommissioning.

  • l&M, the licensee for CNP Unit 1 and Unit 2 hereby certifies, as evidenced by letter from Q. Lies, l&M to NRC, Donald.C. Cook NuclearPlant Unit 1 and Unit 2 Response to Request for
  • Additional Information Concerning 2017 Decommissioning Funding Status
Report,

. ML18225A067, dated August 9, 2018, filed. pursuant to 10 CFR 50.75(f)(1), that financial

  • assurance for decommissioning CNP Unit 1 and Unit 2, as well as the ISFSI, has been
  • . provided. This an:iount meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to AEP-NRC-2018 Page 3*

. to 10 c*FR 72~30(e)(5) provides the requisite financial assurance of the ISFSI decommissioning cost.

10 CFR 72.30(c) requires a description of the effect of the -following events on decommissioning costs:

1.
  • Spills -of radioactive materials producing additional residual radioactivity -in onsite subsurface material:. None
2.. Facility Modifications: None
3. *. Changes in authorized possession limits: None
4. Actual remediation costs that exceed the previous cost estimate: None
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