CNL-18-089, Response to Request for Additional Information Regarding Decommissioning Funding Plan Update for Browns Ferry Nuclear Plant and Sequoyah Nuclear Plant Independent Spent Fuel Storage Installations, Docket Nos. 72-052 and 72-034

Response to Request for Additional Information Regarding Decommissioning Funding Plan Update for Browns Ferry Nuclear Plant and Sequoyah Nuclear Plant Independent Spent Fuel Storage Installations, Docket Nos.72-052 and 72-034

ML18205A476
Person / Time
Site:	Browns Ferry, Sequoyah
Issue date:	07/23/2018
From:	Henderson E Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNL-18-089, EPID L-2017-FPR-0009, EPID L-2017-FPR-0064
Download: ML18205A476 (3)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-18-089 July 23, 2018 10 CFR 72.30(c)(1)-(4) 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:

Response to Request for Additional Information Regarding Decommissioning Funding Plan Update for Browns Ferry Nuclear Plant and Sequoyah Nuclear Plant Independent Spent Fuel Storage Installations, Docket Nos.72-052 and 72-034 (EPID Nos.: L-2017-FPR-0009 and L-2017-FPR-0064)

Reference:

1. TVA Letter to NRC, CNL-15-212, Triennial Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (ISFSIs), dated December 17, 2015 (ML15352A046)

2. NRC Letter to TVA, Request for Additional Information Regarding Tennessee Valley Authoritys Decommissioning Funding Plan Update for Browns Ferry and Sequoyah Independent Spent Fuel Storage Installations, dated May 17, 2018 (ML18138A109)

By letter dated December 17, 2015 (Reference 1), Tennessee Valley Authority (TVA) submitted the required decommissioning funding plan for the Independent Spent Fuel Storage Installations (ISFSIs) at the Browns Ferry Nuclear Plant (BFN) and the Sequoyah Nuclear Plant (SQN).

U.S. Nuclear Regulatory Commission CNL-18-089 Page 2 July 23, 2018 The Nuclear Regulatory Commission (NRC) staff reviewed TVA's decommissioning funding plan updates for each ISFSI and concluded that additional information is necessary to meet the intent of the requirement in 10 CFR 72.30(c) . By the Reference 2 letter, the NRC requested additional information to determine that the events listed in 10 CFR 72 .30(c)(1 )-(4) have been specifically addressed with respect to the 2015 TVA decommissioning funding plan updates submittal. The Reference 2 letter requested that TVA respond within 45 working days, i.e ., by July 23 , 2018. The TVA response to the request for additional information is provided in Enclosure 1 to this letter.

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

Respectfully ,

~cl/.~

E. K. Henderson Director, Nuclear Regulatory Affairs

Enclosure:

1. Response to Request for Additional Information cc:

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

Enclosure 1 Response to Request for Additional Information Regulatory Requirement Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the decommissioning funding plan (DFP) required to be submitted by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. The DFP must update the information submitted with the original or prior approved plan. In addition, the DFP must also specifically consider the effect of the following events on decommissioning costs, as required by 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.

Background

By letter dated December 17, 2015, Tennessee Valley Authority (TVA) submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, a DFP update for the independent spent fuel storage installation (ISFSI) at Browns Ferry Nuclear Plant, Units 1, 2, and 3 and Sequoyah Nuclear Plant, Units 1 and 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15352A046). The NRC staff reviewed TVAs DFP update and believes TVAs submittal was not sufficient to meet the intent of the requirement in 72.30(c). The DFP update does not provide sufficient information to allow the NRC to determine that the events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered.

Request for Additional Information 1 (RAI)

Provide a revised DFP that includes the effect on decommissioning costs of each of the events listed in 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.

TVA Response to RAI 1 With respect to the 2015 TVA decommissioning funding plan (DFP) updates for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 and Sequoyah Nuclear Plant, Units 1 and 2 ISFSIs submitted to the NRC by letter dated December 17, 2015 (Reference 1), the following statements are provided to specifically address the events defined in 10 CFR 72.30(c):

1. No spills of radioactive material producing additional residual radioactivity in onsite subsurface material have occurred.

2. Facility modifications have had no effect on ISFSI decommissioning costs.

3. There have been no changes in authorized possession limits.

4. No active decommissioning has occurred. Therefore, there have been no actual remediation costs that exceed the previous cost estimate.

Based on the above information and the fact that the events defined in 10 CFR 72.30(c)(1)-

(4) have had no effect on decommissioning costs, TVA concludes that the DFP update (Reference 1) for each plant's ISFSI remains valid. Therefore, TVA does not need to submit a revised DFP as requested in the NRC RAI.

References

1. TVA Letter to NRC, CNL-15-212, Triennial Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (ISFSIs), dated December 17, 2015 (ML15352A046)

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