Text

Triennial Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)
	ML15352A046
Person / Time
Site:	Browns Ferry, Sequoyah
Issue date:	12/17/2015
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	CNL-15-212
	Download: ML15352A046 (28)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-212 December 17, 2015 10 CFR 72 .30 10 CFR 72.4 ATTN : Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington , DC 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296, and 72-052 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 , 50-328, and 72-034

Subject:

Triennial Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (ISFSls)

In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 72.30, Tennessee Valley Authority (TVA) hereby submits for Nuclear Regulatory Commission (NRC) review and approval TVA's updated decommissioning funding plans for the Independent Spent Fuel Storage Installations (ISFSls) at the Browns Ferry Nuclear Plant (BFN) and the Sequoyah Nuclear Plant (SON).

The decommissioning funding plan for the ISFSI at BFN is provided in Enclosure 1. The decommissioning funding plan for the ISFSI at SON is provided in Enclosure 2.

There are no new regulatory commitments contained in this submittal. If you have any questions regarding this matter, please contact Edward D. Schrull at 423-751-3850.

y,

~

President, Nuclear Licensing Enclosures cc: See Page 2

U.S. Nuclear Regulatory Commission CNL-15-212 Page2 December 17, 2015 Enclosures

1. Browns Ferry Nuclear Plant Independent Spent Fuel Storage Installation

. Decommissioning Funding Plan

2. Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation Decommissioning Funding Plan cc:

NRG Project Manager - Browns Ferry Nuclear Plant NRG Senior Resident Inspector - Browns Ferry Nuclear Plant NRG Project Manager - Sequoyah Nuclear Plant NRG Senior Resident Inspector - Sequoyah Nuclear Plant

Enclosure 1 Browns Ferry Nuclear Plant Independent Spent Fuel Storage Installation Decommissioning Funding Plan

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI BROWNS FERRY NUCLEAR PLANT Independent Spent Fuel Storage Installation Decommissioning Funding Plan

1. Background and Introduction In accordance with 10 CFR § 72.30, this enclosure provides a detailed cost estimate for decommissioning the Independent Spent Fuel Storage Installation (ISFSI) at the Browns Ferry Nuclear Plant (Browns Ferry) in an amount reflecting:

1. The work is 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 enclosure 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, including means for adjusting the cost estimate and associated funding levels periodically over the life of the facility; and

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

The material in Sections 1 through 6, and Tables 1 and 2, herein, were prepared based on evaluations conducted by TLG Services, Inc. Section 7, containing the financial assurance information, was prepared by Tennessee Valley Authority (TVA).

2. Spent Fuel Management Strategy The operating licenses for Browns Ferry Units 1, 2 and 3 are currently set to expire on December 20, 2033, June 28, 2034, and July 2, 2036, respectively. Approximately 24,604 spent fuel assemblies are currently projected to be generated over the life of the three units. In the absence of a firm plan by the Department of Energy (DOE) for removing spent fuel from the site, an ISFSI has been constructed to support continued plant operations. Based upon the current projection of the DOE's ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, future construction of three additional ISFSI pads to support both operations and decommissioning of Browns Ferry Units 1, 2 and 3. The ISFSI operates under a general license (License No. SFGL-27) in accordance with 10 CFR Part 72, Subpart K.

Because the DOE has not yet begun removing spent fuel from the site, it is envisioned that the spent fuel pools will contain a significant number of spent fuel assemblies at the time the units permanently cease operation, including assemblies off-loaded from the reactor vessels. To facilitate immediate dismantling operations or safe-storage operations, the fuel is assumed to be packaged in dry storage casks for storage at the CNL-15-212 E1-1 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI ISFSI. Once the spent fuel pools are emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. The current TVA spent fuel management plan for Browns Ferry spent fuel assumes that the last of the spent fuel will be removed from the site within approximately fifty years after the shutdown of Unit 1. This ensures that spent fuel is off site prior to commencing decommissioning operations in the SAFSTOR alternative.

TVA's 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 submittal should be interpreted to be inconsistent with this claim.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process, the ISFSI pads will be promptly decommissioned (similar to the power reactor DEGON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. The ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The ISFSI at Browns Ferry comprises numerous contiguous pads that, for the purpose of the ISFSI decommissioning estimate, are considered a single pad. It is assumed that this ISFSI area will be expanded with three additional pads added to provide sufficient storage capacity. The design and capacity of the dry storage modules on the pads is based upon the Holtec HI-STORM 1OOS, and the Holtec HI-STORM FW dry cask storage systems. The systems consist of multi-purpose canisters (MPCs), with nominal capacities of 68 and 89 fuel assemblies, respectively. The MPCs are contained within steel-lined concrete storage overpacks.

The MPCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the fuel.

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

TVA's current spent fuel management plan for Browns Ferry spent fuel would result in 288 MPCs and overpacks being placed on the storage pads at the site. This represents 100% of the total spent fuel projected to be generated during the currently licensed operating period. This scenario would allow the spent fuel storage pools to be emptied within approximately five and one-half years following the permanent cessation of operations.

CNL-15-212 E1-2 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI The 288 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 15) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I 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 Browns Ferry operating until the end of its current licenses (2033, 2034 and 2036) and the DOE's spent fuel acceptance assumptions, as previously described.

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 small. 111 This assumption is adopted for this analysis.

The decommissioning estimate is based on the premise 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, 26 of the 288 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., 764 offloaded assemblies per reactor, 89 assemblies per cask, 3 reactors) which results in 26 overpacks. It is assumed that the casks containing low levels of neutron-induced residual radioactivity are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products. The overpacks will be segmented and packaged for disposal as low-level radioactive waste.

Holtec does not expect any residual contamination to be left on the concrete ISFSI pads.121 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 decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The MPC transfer casks, cask transporter, and ISFSI equipment storage building are also assumed to not contain any residual contamination, and to require only verification surveys to free release these items.

HI-STORM FW FSAR, Holtec International, Report Hl-2114830, Rev.O , at page 2-83 (Accession Number ML11270A045) 2 HI-STORM FW FSAR, Holtec International, Report Hl-2114830, Rev.O , at page 2-84 (Accession Number ML11270A045)

CNL-15-212 E1-3 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI The estimate is limited to costs necessary to terminate the ISFSl's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Based on TVA's review of the records maintained in accordance with §50.75(g)(1), there is no known subsurface material containing residual radioactivity in the proximity of the ISFSI that would require remediation. As such, there is no allowance for soil remediation in the estimate to decommission the ISFSI.

Low-level radioactive waste disposal costs are based on TVA's negotiated rates with Energy Solutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as RS. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. TVA, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.l31 Costs are reported in 2015 dollars and based upon an ongoing decommissioning analysis being prepared for Browns Ferry. Activity costs originally reported in 2012 dollars have been escalated to 2015 dollars using the Consumer Price Index, Services. 141

6. Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pads, transfer casks and transporter, ISFSI Equipment Storage Building, and surrounding environs are characterized, and the activity specifications and work procedures for the decontamination (shield overpack disposition) are developed.

The next phase includes the cost for craft labor to remove the activated overpacks, package in certified waste containers, transportation to the Clive, Utah 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), TVA's oversight staff, site security (industrial), and other site operating costs.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Federal and State Materials and Environmental Management Programs, NUREG-1757, Volume 3, Revision 1, February 2012 4

Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUROOOOSAS CNL-15-212 E1-4 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2083 (the year following fuel removal).

7. Financial Assurance TVA has provided a statement of intent indicating that funds for decommissioning will be obtained when necessary. This method for assuring ISFSI decommissioning funding is provided for in§ 72.30(e)(4) in the case of Federal, State, or local government licensees.

Under the provisions of the Tennessee Valley Authority Act of 1933, as amended, 16 U.S.C. §§ 831-831ee (2012), TVA is a corporate agency and instrumentality of the United States Government.

As shown in Table 2, the cost to decommission the ISFSI at Browns Ferry Nuclear Plant is estimated to be $22,226,000. A statement of intent for this amount is provided in Attachment A. Additionally, as required by§ 72.30(b)(6), a certification of financial assurance is provided in Attachment B.

TVA will adjust the cost estimate every three years to account for changes in the costs and the extent of contamination. Following changes to the cost estimate, funding levels will be evaluated to determine if additional funding or use of a different funding mechanism is warranted.

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Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft) Residual Radioactivity ISFSI Pad (assumed size at shutdown) 776 136 No ISFSI Storage 0 verpack Holtec HI-Item HOLTEC FW STORM 100S Notes Overall Heiaht (inches) 218.5 218.5 Dimensions are nominal Outside Diameter (inches) 139.0 132.5 Dimensions are nominal Inside Diameter (inches) 77.0 73.5 Dimensions are nominal Inner Liner Thickness (inches) 1.0 1.0 Dimensions are nominal Quantity (total) 258 45 Quantity (Holtec FW, Holtec HI-STORM 100S) (total) 303 288 spent fuel + 15 GTCC Equivalent to the number of overpacks used Quantity (with residual radioactivity) 26 to store last complete core offload Packaaed Waste Quantities Inner Activated Liner Removal (cubic feet) 5,726 Outer Activated Liner Removal (cubic feet) 11,698 Activated Concrete (cubic feet) 32,274 Activated overpack miscellaneous steel (cubic feet) 13,744 Filters and DAW Waste (cubic feet) 161 Total Low-Level Radioactive Waste (cubic feet) 63,603 Low-Level Radioactive Waste (packaaed density) 74 Average weiaht density 0th er P ot en t"1a 111y Imoact e d Items Item Value Notes Transfer Cask 2 No residual radioactivity Cask Transporter 1 No residual radioactivity ISFSI Equipment Storage Buildina 1 No residual radioactivity CNL-15-212 E1-6 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI Table 2 ISFSI Decomm1ss1onmg c ost s an dWast e VI oumes Costs Waste (thousands, 2015 dollars) Volume Person-Hours NRC/NRC Removal Packaging Transport Disposal Other Total (ft3) Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 751 751 - 1,696 - -

Decontamination (activated disoosition) 654 114 1,431 10,630 - 12,828 63,603 10,741 - -

License Termination (radiological surveys) - - - - 3,158 3,158 - 27,028 - -

Subtotal 654 114 1,431 10,630 3,909 16,737 63,603 39,464 - -

Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 453 453 - - 776 Insurance - - - - 68 68 - - -

Securitv (industrial) - - - - 133 133 7,065 - -

TVA Oversight Staff - - - - 390 390 - 5,360 -

Subtotal - - - - 1,044 1,044 - 7,065 5,360 776 Total (w/o contingency) 654 114 1,431 10,630 4,953 17,781 63,603 46,529 5,360 776 Total (w/25% contingency) 22,226 CNL-15-212 E1-7 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI Attachment A ATTACHMENT A Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, TN 37902 (865) 632-2101 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296, and 72-052 STATEMENT OF INTENT The Tennessee Valley Authority (TVA) is a corporate agency and instrumentality of the United States Government created pursuant to the Tennessee Valley Authority Act of 1933, as amended, 16 U.S.C. §§ 831-831ee (2012). Pursuant to 10 CFR § 72.30(e)(4), TVA states that it will obtain the funds for decommissioning the Browns Ferry Nuclear Plant ISFSI, estimated to be $22,226,000 as described in the Decommissioning Plan, when necessary. These funds will be obtained and made available sufficiently in advance of decommissioning to prevent the delay of required activities.

A copy of the Delegation of Authority from the Chief Executive Officer to the Chief Nuclear Officer is provided in Exhibit A as evidence that I am authorized to represent TVA in this transaction. The TVA Board Practice Amendments referenced in the Delegation of Authority ded as an attachment to Exhibit A.

Joe . Grimes Ch" f Nuclear Officer Tennessee Valley Authority December 17, 2015 Exhibit A: Memo Delegating Authority from the Chief Executive Officer to the Chief Nuclear Officer CNL-15-212 E1-8 of 9

Tennessee Valley Authority Enclosure 1 Browns Ferry Nuclear Plant ISFSI Attachment B ATTACHMENT B Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, TN 37902 (865) 632-2101 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296, and 72-052 CERTIFICATION OF FINANCIAL ASSURANCE In accordance with 10 CFR 72.30(b)(6), I certify that financial assurance in the amount of

$22,226,000 will be made available when necessary to decommission the Browns Ferry Nuclear Plant Independent Spent Fuel Storage Installation using the financial assurance method set forth in 10 CFR 72.30(e)(4).

Should additional information be needed regarding this certification of financial assurance by the Tennessee Valley Authority, contact Joseph W. Shea, Vice President, Nuclear Licensing, at (423) 1-6887.

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Joe . Grimes Chie uclear Officer Tennessee Valley Authority December 17, 2015 CNL-15-212 E1-9 of 9

Enclosure 2 Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation Decommissioning Funding Plan

Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI SEQUOYAH NUCLEAR PLANT Independent Spent Fuel Storage Installation Decommissioning Funding Plan

1. Background and Introduction In accordance with 10 CFR § 72.30, this enclosure provides a detailed cost estimate for decommissioning the Independent Spent Fuel Storage Installation (ISFSI) at Sequoyah Nuclear Plant (Sequoyah) in an amount reflecting:

1. The work is 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 enclosure 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, including means for adjusting the cost estimate and associated funding levels periodically over the life of the facility; and

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

The material in Sections 1 through 6, and Tables 1 and 2, herein, were prepared based on evaluations conducted by TLG Services, Inc. Section 7, containing the financial assurance information, was prepared by the Tennessee Valley Authority (TVA).

2. Spent Fuel Management Strategy The operating licenses for Sequoyah Units 1 and 2 are currently set to expire on September 17, 2040, and September 15, 2041, respectively. Approximately 6,353 spent fuel assemblies are currently projected to be generated over the life of the two units. In the absence of a firm plan by the Department of Energy (DOE) for removing spent fuel from the site, an ISFSI has been constructed to support continued plant operations. Based upon the current projection of the DOE's ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, future construction of a second pad to support both operations and decommissioning of Sequoyah Units 1 and 2. The ISFSI operates under a general license (License No. SFGL-20) in accordance with 10 CFR Part 72, Subpart K.

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Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI Because the DOE has not yet begun removing spent fuel from the site, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time the units permanently cease operation, including assemblies off-loaded from the reactor vessels. To facilitate immediate dismantling operations or safe-storage operations, the fuel is assumed to be packaged in dry storage casks for storage at the ISFSI. Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. The current TVA spent fuel management plan for Sequoyah spent fuel assumes that the last of the spent fuel will be removed from the site within approximately fifty years of the shutdown of Unit 1. This ensures that spent fuel is off site prior to commencing decommissioning operations in the SAFSTOR alternative.

TVA's 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 submittal should be interpreted to be inconsistent with this claim.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI pad will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. The ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The ISFSI at Sequoyah comprises numerous contiguous pads that, for the purpose of the ISFSI decommissioning estimate, are considered a single pad. It is assumed that this ISFSI area will be expanded with an additional pad added to provide sufficient storage capacity. The design and capacity of the dry storage modules on the pads is based upon the Holtec HI-STORM 1OOS, and the Holtec HI-STORM FW dry cask storage systems. The systems consist of multi-purpose canisters (MPCs), with nominal capacities of 32 and 37 fuel assemblies, respectively. The MPCs are contained within steel-lined concrete storage overpacks.

The MPCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the fuel.

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

E2-2 of 9

Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI TVA's current spent fuel management plan for Sequoyah spent fuel would result in 178 MPCs and overpacks being placed on the storage pad at the site. This represents 100% of the total spent fuel projected to be generated during the currently licensed operating period. This scenario would allow the spent fuel storage pools to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 178 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used forthe GTCC canisters (estimated quantity of 10) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I 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 Sequoyah operating until the end of its current licenses (2040 and 2041) and the DOE's spent fuel acceptance assumptions, as previously described.

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 small. [11 This assumption is adopted for this analysis.

The decommissioning estimate is based on the premise 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, 11 of the 178 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., 193 offloaded assemblies per reactor, 37 assemblies per cask, 2 reactors) which results in 11 overpacks. It is assumed that the casks containing low levels of neutron-induced residual radioactivity are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products. The overpacks will be segmented and packaged for disposal as low-level radioactive waste.

HI-STORM FW FSAR, Holtec International, Report Hl-2114830, Rev.O , at page 2-83 (Accession Number ML11270A045)

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Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI Holtec does not expect any residual contamination to be left on the concrete ISFSI pad.1211t 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 pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The MPC transfer casks, cask transporter, and ISFSI equipment storage building are also assumed to not contain any residual contamination, and to require only verification surveys to free release these items.

The estimate is limited to costs necessary to terminate the ISFSl's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Based on TVA's review of the records maintained in accordance with §50.75(g)(1), there is no known subsurface material containing residual radioactivity in the proximity of the ISFSI that would require remediation. As such, there is no allowance for soil remediation in the estimate to decommission the ISFSI.

Low-level radioactive waste disposal costs are based on TVA's negotiated rates with Energy Solutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as RS. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. TVA, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.l31 Costs are reported in 2015 dollars and based upon an ongoing decommissioning analysis being prepared for Sequoyah. Activity costs originally reported in 2012 dollars have been escalated to 2015 dollars using the Consumer Price Index, Services. 141 2

HI-STORM FW FSAR, Holtec International, Report Hl-2114830, Rev.a , at page 2-84 (Accession Number ML11270A045) 3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Federal and State Materials and Environmental Management Programs, NUREG-1757, Volume 3, Revision 1, February 2012 4

Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUROOOOSAS E2-4 of 9

Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI

6. Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pads, transfer casks and transporter, ISFSI Equipment Storage Building, and surrounding environs are characterized, and the activity specifications and work procedures for the decontamination (shield overpack disposition) are developed.

The next phase includes the cost for craft labor to remove the activated overpacks, package in certified waste containers, transportation to the Clive, Utah 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), TVA's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2083 (the year following fuel removal).

7. Financial Assurance TVA has provided a statement of intent indicating that funds for decommissioning will be obtained when necessary. This method for assuring ISFSI decommissioning funding is provided for in §72.30(e)(4) in the case of Federal, State, or local government licensees.

Under the provisions of the Tennessee Valley Authority Act of 1933, as amended, 16 U.S.C. §§ 831-831ee (2012), TVA is a corporate agency and instrumentality of the United States Government.

As shown in Table 2, the cost to decommission the ISFSI at Sequoyah Nuclear Plant is estimated to be $11,045,000. A statement of intent for this amount is provided in Attachment A Additionally, as required by §72.30(b)(6), a certification of financial assurance is provided in Attachment B.

TVA will adjust the cost estimate every three years to account for changes in the costs and the extent of contamination. Following changes to the cost estimate, funding levels will be evaluated to determine if additional funding or use of a different funding mechanism is warranted.

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Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft) Residual Radioactivity ISFSI Pad (assumed size at shutdown) 486 115 No ISFSI Storage 0 verpac k Holtec HI-Item HOLTEC FW STORM 100S Notes Overall Heiqht (inches) 209.0 218.5 Dimensions are nominal Outside Diameter (inches) 139.0 132.5 Dimensions are nominal Inside Diameter (inches) 77.0 73.5 Dimensions are nominal Inner Liner Thickness (inches) 1.0 1.0 Dimensions are nominal Quantity (total) 144 44 Quantity (Holtec FW, Holtec HI-STORM 1OOS) (total) 188 178 spent fuel + 10 GTCC Equivalent to the number of overpacks used to store last Quantity (with residual radioactivity) 11 complete core offload Packaged Waste Quantities Inner Activated Liner Removal (cubic feet) 2,306 Outer Activated Liner Removal (cubic feet) 4,745 Activated Concrete (cubic feet) 13,091 Activated overpack miscellaneous steel (cubic feet) 5,815 Filters and DAW Waste (cubic feet) 102 Total Low-Level Radioactive Waste (cubic feet) 26,059 Low-Level Radioactive Waste (packaged density) 74 Average weight density Oh . II1y Impacte di terns t er Potent1a Item Value Notes Transfer Cask 2 No residual radioactivity Cask Transporter 1 No residual radioactivity ISFSI Eauipment Storage BuildinQ 1 No residual radioactivity E2-6 of 9

Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2015 dollars) Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3) Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 538 538 - 1,432 - -

Decontamination (activated disposition) 290 53 619 4,335 - 5,297 26,059 4,458 - -

License Termination (radiological surveys) - - - - 2,172 2,172 - 17,425 - -

Subtotal 290 53 619 4,335 2,710 8,007 26,059 23,315 - -

Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 433 433 - - 776 Insurance - - - - 68 68 - - -

Security (industrial) - - - - 86 86 4,349 - -

TVA Oversight Staff - - - - 242 242 - 3,322 -

Subtotal - - - - 829 829 - 4,349 3,322 776 Total (w/o contingency) 290 53 619 4,335 3,539 8,836 26,509 27,664 3,322 776 Total (w/25% contingency) 11,045 E2-7 of 9

Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI Attachment A ATTACHMENT A Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, TN 37902 (865) 632-2101 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327, 50-328, and 72-034 STATEMENT OF INTENT The Tennessee Valley Authority (TVA) is a corporate agency and instrumentality of the United States Government created pursuant to the Tennessee Valley Authority Act of 1933, as amended, 16 U.S.C. §§ 831-831ee (2012). Pursuant to 10 CFR § 72.30(e)(4), TVA states that it will obtain the funds for decommissioning the Sequoyah Nuclear Plant ISFSI, estimated to be

$11,045,000 as described in the Decommissioning Plan, when necessary. These funds will be obtained and made available sufficiently in advance of decommissioning to prevent the delay of required activities.

A copy of the Delegation of Authority from the Chief Executive Officer to the Chief Nuclear Officer is provided in Exhibit A as evidence that I am authorized to represent TVA in this transaction. The TVA Board Practice Amendments referenced in the Delegation of Authority ded as an attachment to Exhibit A.

Joe . Grimes Chi Nuclear Officer Tennessee Valley Authority December 17, 2015 Exhibit A: Memo Delegating Authority from the Chief Executive Officer to the Chief Nuclear Officer E2-8 of 9

Tennessee Valley Authority Enclosure 2 Sequoyah Nuclear Plant ISFSI Attachment B ATTACHMENT B Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, TN 37902 (865) 632-2101 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRG Docket Nos. 50-327, 50-328, and 72-034 CERTIFICATION OF FINANCIAL ASSURANCE In accordance with 10 CFR 72.30(b)(6), I certify that financial assurance in the amount of

$11,045,000 will be made available when necessary to decommission the Sequoyah Nuclear Plant Independent Spent Fuel Storage Installation using the financial assurance method set forth in 10 CFR 72.30(e)(4).

Should additional information be needed regarding this certification of financial assurance by the Tenne see Valley Authority, contact Joseph W. Shea, Vice President, Nuclear Licensing, at (423) 1-6887.

Joe P. Grimes Chi Nuclear Officer Tennessee Valley Authority December 17, 2015 E2-9 of 9

Exhibit A TENNESSEE VALLEY AUTHORITY Memo Delegating Authority from the Chief Executive Officer to the Chief Nuclear Officer

December 15, 2015 William D. Johnson, WT 7B-K FUNDING OF ESTIMATED COSTS FOR DECOMMISSIONING TENNESSEE VALLEY AUTHORITY - INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS AT BROWNS FERRY AND SEQUOYAH NUCLEAR PLANTS The Tennessee Valley Authority is required to submit decommissioning funding plans to the Nuclear Regulatory Commission on or before December 17, 2015. The purpose of the funding plans is to provide reasonable assurance that funds will be available to decommission the Independent Spent Fuel Storage Installations (ISFSls) at the Browns Ferry and Sequoyah Nuclear Plants after the plants cease operations. The funding plans will contain a cost estimate for decommissioning each ISFSI as well as a statement of intent indicating that sufficient funds for decommissioning will be obtained when necessary.

The latest cost studies estimate that approximately $22.3 million and $11.1 million will be required to decommission the ISFSls at Browns Ferry and Sequoyah, respectively. Authority to approve decommissioning projects in these amounts is within your authority under the Tennessee Valley Authority Board Practice entitled Capital Projects Approvals (originally approved by the Board on January 28, 2007 and amended on November 17, 2011). In particular, the Board Practice provides that the Chief Executive Officer has the authority to approve any capital project provided the project amount does not exceed $50 million. Additionally, with regard to the authority to contract for the ISFSls, the TVA Board Practice on Procurement Contract Approvals (originally approved by the Board on November 30, 2006 and amended on November 17, 2011) authorizes the Chief Executive Officer to approve any procurement contract that does not exceed $100 million if its term does not exceed 5 years, and any contract that does not exceed $25 million if its term exceeds 5 years. I have attached the appropriate TVA Board Practice documents for ease of reference.

Based upon the above-mentioned ISFSI decommissioning cost estimates, the approval of the decommissioning activities for each project fall within the Chief Executive Officer's authority under the applicable TVA Board Practices. Accordingly, I request that you delegate to the Chief Nuclear Officer the authority to submit appropriate certification statements and statements of intent for the Browns Ferry Nuclear Plant and Sequoyah Nuclear Plant Independent Spent Fuel Storage Installations in the amounts of $22.3 million and $11.1 million, respectively.

nature below indicates your approval.

h P. Grimes Chief Nuclear Officer 5

cc: See Page 2

William D. Johnson Page2 December 15, 2015 GRW Attachments cc: J. W. Shea, LP 3R-C S. A. Vance, WT 6A-K EDMS, WT CA-K

PROPOSED BOARD RESOLUTION (TVA Board Practice Amendments)

WHEREAS the Board has from time to time adopted certain practices to address various Board and Board Committee processes and activities or to provide guidance in interpreting provisions of the Bylaws of the Tennessee Valley Authority; and WHEREAS th e Board has reviewed the existing practices and desires to make amendments to reflect the functions of the various Board Committees rather than the forma l Committee names; and WHEREAS the Board believes it would be useful and appropriate to adopt a practice allowing the grouping of non -controversia l, ministeria l items together for Board consideration at a public board meeting when considered appropriate by the Chairman of the Board and the Chief Executive Officer; BE IT RESOLVED , Thai the Board hereby amends the TVA Board Practices to make such administrative changes as reflected in the document attached hereto and filed with the records of the Board as Exhibit l! - !1-1 l {2 ; an d BE IT RESOLVED , FURTHER, That the Board hereby adopts the TVA Board Practice entitled Consent Agenda as reflected in the same Exhibit

fy._l...:~:.J- 11-11-11 IC Resolution of The Board of Directors of the Tennessee Valley Authority (Establishing the Board Practice System)

WHEREAS the Board , from time to lime , may choose to adopt certain practices to govern various Board and Board Committee processes and activities or to interpret provisions of the Bylaws of The Tennessee Valley Authority in order to provide guidance to Board Members or the Chief Executive Officer in those cases where an amendment to the Bylaws to accomplish such purposes might not be necessary; and WHEREAS the Board believes that it would be useful and appropriate to establish a system for compiling and maintaining these various practices that the Board may approve in the future; BE IT RESOLVED , That the Board hereby establishes a TVA Board Practices system , into which all future actions by the Board in adopting such practices or providing such interpretative guidance regarding the Bylaws of The Tennessee Valley Authority shall be compiled, indexed , and maintained by the Corporate Secretary in a manner that shall assure convenient access for Board Members and for the Chief Executive Officer and TVA management.

Approved by the Board of Directors of the Tennessee Valley Authority November 30, 2006

TVA Board Practice Capital Projects Approvals

Background

Section 3.2(i) of the Bylaws of The Tennessee Valley Authority provides , among other things ,

that TVA's Chief Executive Officer (CEO ) has all authorities and duties "necessary or appropriate to carry out projects and activities approved by the Board of Directors or to maintain continuity and/or reliability of ongoing operations."

The Board acknowledges that a routine part of maintaining continuity and/or reliability of ongoing operations involves undertaking capital projects. By adopting this TVA Board Practice, the Board is providing more definitive guidance to the CEO as to what cap ital projects the Board generally considers to be within the CEO's approval authority under Section 3.2(i) of the Bylaws. It is intended by the Board to enable the CEO to assume authority to approve capita l projects up to a specified dollar amount.

Guidance

The CEO may approve a cap ital project that has been specified by line-item in a Board-approved budget, provided that capital projects in amounts greater than $100 million will be presented for review to the committee with oversight responsibility for the budget Operations. Environment. an~fel.y-Geffiffifttee-(in coordi nation with other Board Committees, as appropriate).

The CEO may assume the authority to approve any capital project not specified by line-item in a Board-approved budget provided the project amount does not exceed

$50 million .

Notwithstanding the foregoing , the CEO may determine that a capital project should be submitted to the Board for its consideration and approval on the grounds th at new. special, or novel considerations are involved.

Approved by the Board of Directors of the Tennessee Va lley Authority January 25 , 2007

TVA Board Practice Procurement Contract Approvals

Background

Section 3.2(i) of the Bylaws of The Tennessee Valley Authority provides , among other things, that TV A's Chief Executive Officer (CEO) has all authorities and duties "necessary or appropriate to carry out projects and activities approved by the Board of Directors or to maintain continuity and/or reliability of ongoing operations ."

The Board acknowledges that a routine part of carrying out approved projects and activities and maintaining continuity and/or reliability of ongoing operations involves committing TV A to contracts under which TVA purchases or sells products or services (Procurement Contracts ).

I For the purposes of this TVA Board Practice, Procurement Contracts do not include contracts for fuel-related transactions or contracts for the purchase or sale of electric power.

The Board further acknowledges that, in the absence of guidance from the Board, many Procurement Contracts into which TVA enters could reasonably be considered to fall within the scope of the CEO's authorities under Section 3.2(i) of the Bylaws, regardless of the dollar amount to which the particular Procurement Contract would commit TVA or the length of its term.

By adopting this TVA Board Practice, the Board is providing more definitive guidance to the CEO as to what Procurement Contracts the Board generally considers to be within the CEO's approval authority under Section 3.2(i) of the Bylaws. It is intended by the Board to enable the CEO to assume authority to approve a Procurement Contract that commits TVA up to a specified dollar amount or for a term of up to a specified number of years.

Guidance The CEO may approve any Procurement Contract which falls within the following parameters .

as applicable:

The contract amount does not exceed $100 million and its term does not exceed 5 years .

The contract amount does not exceed $25 million and its term exceeds 5 years .

Notwithstanding the foregoing, the CEO may determine that a Procurement Contract, as described above. should be submitted to the Board for its consideration and approval on the grounds that new. special, or novel considerations are involved.