BVY 22-005, ISFSI Decommissioning Funding Plan

ISFSI Decommissioning Funding Plan

ML22073A077
Person / Time
Site:	Vermont Yankee  File:NorthStar Vermont Yankee icon.png
Issue date:	02/24/2022
From:	State S NorthStar Vermont Yankee
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
BVY 22-005
Download: ML22073A077 (12)

Text

NorthStar Vermont Yankee, LLC Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 Office: 802.451.5354 24-Hour Emergency Response: 800.283.2933 The Worlds Most Comprehensive Facility & Infrastructure Solutions Company - We Bring Answers.

Scott E. State, P.E.

Chief Nuclear Officer 10 CFR 72.30 BVY 22-005 February 24, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

ISFSI Decommissioning Funding Plan Vermont Yankee Nuclear Power Station Docket Nos. 50-271 and 72-59 License No. DPR-28

REFERENCE:

Letter, USNRC to Entergy Nuclear Operations, Inc., Order Approving Transfer of the License for the Vermont Yankee Nuclear Power Station and Conforming License Amendment (EPID# L-2017-LLM-0002), dated October 11, 2018 (ML18242A638)

Dear Sir or Madam:

The NRC Final Rule on Decommissioning Planning was published in 76 FR 35512 on June 17, 2011 with an effective date of December 17, 2012. The final rule includes a requirement (10 CFR 72.30) for each holder of a 10 CFR Part 72 License to submit, for NRC review and approval, a decommissioning funding plan for purposes of decommissioning the licensees Independent Spent Fuel Storage Installation (ISFSI), and to resubmit those plans with adjustments as necessary to account for changes in costs and the extent of contamination.

NorthStar Vermont Yankee is hereby submitting the required Funding Plan. The attached demonstrates that the surpluses in the 10 CFR 50.75 Decommissioning Trust Fund exceed the estimated costs of ISFSI decommissioning. The Trust Fund balances account for the 10 CFR Part 50 license expiration dates and the ISFSI decommissioning cost estimate (DCE) assume all of the ISFSI license termination costs are incurred in the year in which spent fuel has been fully removed from the ISFSI. The values are reported in 2021 dollars.

This letter constitutes a certification that financial assurance is provided to cover the estimated cost of ISFSI decommissioning.

This letter contains no new regulatory commitments.

BVY 22-005 / Page 2 of 2 Should you have any questions concerning this letter or require additional information, please contact me at 212.951.3660.

Best Regards, NorthStar Vermont Yankee, LLC By: _______________________________________________

Scott E. State, P.E.

Chief Nuclear Officer SES/tbs

Attachment:

10 CFR 72.30 ISFSI Decommissioning Funding Plan cc: Director, Office of Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. David C. Lew Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601 By: _______________________________________________

Scott E. State, P.E.

BVY 22-005 Docket Nos. 50-271 & 72-59 Attachment Vermont Yankee Nuclear Power Station 10 CFR 72.30 ISFSI Decommissioning Funding Plan (10 pages total including this cover sheet)

BVY 22-005 / Attachment / Page 1 of 9 10 CFR 72.30 ISFSI Decommissioning Funding Plan Vermont Yankee Nuclear Power Station ISFSI Docket 72-059

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 20111, with the rule becoming effective on December 17, 2012.

Subpart 72.30, Financial assurance and recordkeeping for decommissioning, requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document updates the funding plan previously submitted by Entergy Nuclear Operations, Inc. in December 20182.

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Vermont Yankee Nuclear Power Station (Vermont Yankee), in an amount reflecting:

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

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

2. Spent Fuel Management Strategy Vermont Yankee permanently ceased reactor operations on December 29, 20143.

Approximately 3,880 spent fuel assemblies (3,879 assemblies and 1 fuel debris canister) were generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI had been constructed and fuel casks have been emplaced thereon to support plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, a second pad was 1

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 Letter, Entergy Nuclear Operations, Inc. to USNRC, ISFSI Decommissioning Funding Plans (10 CFR 72.30),

dated December 17, 2018 (Accession No. ML18351A478).

3 BVY 15-001, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel," January 12, 2015 (Accession Number ML15013A426).

BVY 22-005 / Attachment / Page 2 of 9 constructed to support decommissioning. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K4).

Because of the DOEs breach, the spent fuel is packaged in dry storage casks for interim storage at the ISFSI.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor.

Vermont Yankees current spent fuel management plan is based in general upon: 1) a 2025 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the Vermont fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year5, the spent fuel is projected to be fully removed from the Vermont Yankee site in 2052.

NorthStar Vermont Yankee believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the Obama administrations Blue Ribbon Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...6 The report stated that [W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

[A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities.

The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually fulfill its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

4 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites.

5 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004.

6 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S.

DOE, January 11, 2013.

BVY 22-005 / Attachment / Page 3 of 9 NorthStar Vermont Yankees position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this position.

3. ISFSI Description The design and capacity of the Vermont Yankee ISFSI(s) is based upon the Holtec HI-STORM 100S dry cask storage system. The system consists of a multi-purpose canister, with a nominal capacity of 68 fuel assemblies, and a steel-lined concrete storage overpack.

The Vermont Yankee spent fuel management plan resulted in 58 spent fuel storage casks being placed on the storage pads at the site (including the casks generated during plant operations). There will also be one storage overpack used for the storage of Greater-than-Class-C (GTCC) waste placed on the storage pad.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

4. Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the current spent fuel inventory at the site (3,880 assemblies) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, the second pad was needed to accommodate all the casks used to store spent fuel at the site, including those casks placed on the initial ISFSI pad during plant operations.

The second ISFSI pad is 93 feet by 106 feet and has a maximum capacity of 25 casks.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small7. The decommissioning estimate is based on the conservative assumption that some of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 6 of the 58 overpacks are assumed to be affected, i.e.,

contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 368 offloaded assemblies, 68 assemblies per cask) which results in 6 overpacks.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads8. It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pads in the 7

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 14.

8 Ibid. page 2-206.

BVY 22-005 / Attachment / Page 4 of 9 decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to support termination of the NRC license and meet the §20.1402 criteria for unrestricted use.

The decommissioning cost study9 developed for Vermont Yankee and filed with the NRC as part of the license transfer from Entergy to Northstar, included the potential cost for the remediation of radiologically contaminated soil on site, which includes the ISFSI. This study was based upon a review of the sites radiological records and associated affected areas.

However, during the construction of the existing ISFSI, the soil excavated was replaced with engineered fill. This material is not expected to become contaminated from the operation of the ISFSI. The second pad is located adjacent to the first.

For purposes of the funding plan, ISFSI decommissioning is considered an independent project. Consistent with the estimate included with the Post Shutdown Decommissioning Activities Report10, in order to provide a more efficient decommissioning effort, NorthStar VY has initiated a series of Firm Fixed Price and Fixed Unit Price subcontracts to minimize the overall cost and schedule risk of the project.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications of note since the previous update that affect the decommissioning cost estimate.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

5. Cost Considerations The estimated cost to decommission the ISFSI pads and release the facility and dry storage systems for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (overpack disposition) developed.

9 Letter, NorthStar to USNRC, Notification of Revised Post-Shutdown Decommissioning Activities Report (Revised PSDAR), Section 4.0, Estimate of Expected Decommissioning and Spent Fuel Management Costs dated April 6, 2017 (Accession Number ML17096A394).

10 Ibid.

BVY 22-005 / Attachment / Page 5 of 9 The next phase includes the cost for craft labor to demolish the activated overpacks, packaging in certified waste containers, transportation to the Andrews, TX site, disposal, as well as the costs for the supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor), site security (industrial),

and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2052, the year following all spent fuel removal.

6. Financial Assurance ISFSI operations at Vermont Yankee are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible according to a judgment entered against the DOE under federal law and the Standard Contract11. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, NorthStar will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility and dry storage systems for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

The decommissioning trust fund is for radiological decommissioning costs and spent fuel management costs12. The ISFSI decommissioning is a radiological cost. To the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning and spent fuel management, these funds would be available to address costs incurred, including ISFSI decommissioning costs.

The projected amount necessary for decommissioning Vermont Yankee is $348.316 million, including spent fuel management costs, based upon the March 2021 10 CFR 50.75(f) filing for Vermont Yankee13.

The current decommissioning trust fund balance was $388.025 million (as of December 31, 2020), which is in excess of the projected costs as shown in Table 314.

Based on the remaining decommissioning trust fund balance in Table 3 below, projected fund earnings (assuming an annual 2% growth rate), and expected expenditures, the trust fund is expected to have an excess of $68.544 million over the estimated license 11 Vermont Yankee Nuclear Power Corporation and Entergy Nuclear Vermont Yankee, LLC v. United States, Court of Federal Claims, Nos. 02-898C and 03-2663C (2006).

12 Entergy Nuclear Operations, Inc. obtained an exemption that allows the use of Vermont Yankee trust funds for spent fuel management activities. See NRC Approval of Exemption Request for Spent Fuel Management, 80 Fed. Reg. 35992 (June 23, 2015).

13 Letter, NorthStar Vermont Yankee to USNRC, Status of Decommissioning and Spent Fuel Management Fund for Year Ending 2020, March 29, 2021, (Accession Number ML21106A269).

14 Ibid. Attachment 3, Table 3.

BVY 22-005 / Attachment / Page 6 of 9 termination and spent fuel management costs.

This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

BVY 22-005 / Attachment / Page 7 of 9 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft)

Residual Radioactivity ISFSI Pad (1) 132 106 No ISFSI Pad (2) 93 106 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.0 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 59 58 spent fuel + 1 GTCC Quantity (with residual radioactivity) 6 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste (total packaged volume) 17,232 Cubic Feet Low-Level Radioactive Waste (packaged density) 94 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 1

No residual radioactivity

BVY 22-005 / Attachment / Page 8 of 9 Table 2 NorthStar Vermont Yankee - ISFSI Decommissioning Costs and Waste Volumes Costs (thousands of 2021 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total Class A (Cubic feet)

Craft Oversight and Contractor Decommissioning Planning (characterization, specs & procedures)

$175

$175 1,325 Decontamination/Demolition (activated cask disposition)

$285

$126

$866

$1,274

$26

$2,577 17,792 2,878 License Termination (radiological surveys)

$702

$702 4,557 Subtotal

$285

$126

$866

$1,274

$903

$3,454 17,792 7,435 1,325 Supporting Costs Contracted Services

$239

$239

- 1,806 NRC/State Fees

$126

$126 Insurance

$119

$119 All Labor - Loaded

$770

$770 5,833 Materials & Supplies

$25

$25 Misc./Personal Expenses

$22

$22 Property and other Taxes

$184

$184 Utilities

$24

$24 ISFSI Fuel Management & Operations

$116

$116

- 881 Subtotal

$0

$0

$0

$0

$1,625

$1,625

- 8,520 GRAND TOTAL

$285

$125

$866

$1,274

$2,528

$5,079

BVY 22-005 / Attachment / Page 9 of 9 Table 3 Financial Assurance Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Year License Termination Cost Spent Fuel Cost Total Expenses Beginning of Period Funded Balance Withdrawals Contributions DOE Recovery Contributions NorthStar Escrow Deposits /

Distributions Annual Earnings on Fund End-Of-Year Fund Balance 2021

$86,715

$4,241

$90,956

$388,025

$90,956

$0

$9,335

$5,941

$312,345 2022

$78,575

$4,241

$82,816

$312,345

$82,816

$0

$8,228

$4,591

$242,348 2023

$68,701

$4,241

$72,942

$242,348

$72,942

$10,000

$0

$3,588

$182,993 2024

$66,661

$4,241

$70,902

$182,993

$70,902

$21,205

$0

$2,666

$135,962 2025

$33,572

$4,241

$37,813

$135,962

$37,813

$4,241

$0

$2,048

$104,438 2026

$10,637

$4,241

$14,878

$104,438

$14,878

$4,241

$0

$1,876

$95,677 2027

$8,944

$8,944

$95,677

$8,944

$4,241

-$55,137

$1,819

$37,656 2028

$8,944

$8,944

$37,656

$8,944

$8,944

$0

$753

$38,409 2029

$8,944

$8,944

$38,409

$8,944

$8,944

$0

$768

$39,177 2030

$8,944

$8,944

$39,177

$8,944

$8,944

$0

$784

$39,961 2031

$8,944

$8,944

$39,961

$8,944

$8,944

$0

$799

$40,760 2032

$8,944

$8,944

$40,760

$8,944

$8,944

$0

$815

$41,575 2033

$8,944

$8,944

$41,575

$8,944

$8,944

$0

$832

$42,407 2034

$8,944

$8,944

$42,407

$8,944

$8,944

$0

$848

$43,255 2035

$8,944

$8,944

$43,255

$8,944

$8,944

$0

$865

$44,120 2036

$8,944

$8,944

$44,120

$8,944

$8,944

$0

$882

$45,003 2037

$8,944

$8,944

$45,003

$8,944

$8,944

$0

$900

$45,903 2038

$8,944

$8,944

$45,903

$8,944

$8,944

$0

$918

$46,821 2039

$8,944

$8,944

$46,821

$8,944

$8,944

$0

$936

$47,757 2040

$8,944

$8,944

$47,757

$8,944

$8,944

$0

$955

$48,712 2041

$8,944

$8,944

$48,712

$8,944

$8,944

$0

$974

$49,686 2042

$8,944

$8,944

$49,686

$8,944

$8,944

$0

$994

$50,680 2043

$8,944

$8,944

$50,680

$8,944

$8,944

$0

$1,014

$51,694 2044

$8,944

$8,944

$51,694

$8,944

$8,944

$0

$1,034

$52,728 2045

$8,944

$8,944

$52,728

$8,944

$8,944

$0

$1,055

$53,782 2046

$8,944

$8,944

$53,782

$8,944

$8,944

$0

$1,076

$54,858 2047

$8,944

$8,944

$54,858

$8,944

$8,944

$0

$1,097

$55,955 2048

$8,944

$8,944

$55,955

$8,944

$8,944

$0

$1,119

$57,074 2049

$8,944

$8,944

$57,074

$8,944

$8,944

$0

$1,141

$58,216 2050

$8,944

$8,944

$58,216

$8,944

$8,944

$0

$1,164

$59,380 2051

$8,944

$8,944

$59,380

$8,944

$8,944

$0

$1,188

$60,568 2052

$3,454

$8,944

$12,398

$60,568

$12,398

$8,944

$0

$1,142

$58,256 2053

$58,256

$0

$8,944

$0

$1,344

$68,544 TOTAL

$348,316

$257,995

$606,311

$388,025

$606,311

$276,477

-$37,574

$47,927

$68,544 Vermont Yankee Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management (Thousands of 2021 Dollars) - See column definitions below