CP-202300144, (CPNPP) - Decommissioning Report

(CPNPP) - Decommissioning Report

ML23089A250
Person / Time
Site:	Comanche Peak
Issue date:	03/30/2023
From:	John Lloyd Luminant Generation Co, Vistra Operating Co. (VistraOpCo)
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
CP-202300144, TXX-23017
Download: ML23089A250 (1)

Text

Jay J. Lloyd Comanche Peak Senior Director, Nuclear Power Plant Engineering & Regulatory Affairs (Vistra Operations Company LLC)

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043

T 254.897.5337

CP-202300144 TXX-23017 March 30, 2023

ATTN:DocumentControlDesk Ref 10CFR50.75(f)

U. S. Nuclear Regulatory Commission 10 CFR 72.30(c)

Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 and 72-74 Decommissioning Report

Reference 1. Letter TXX-21066, from S. Sewell to the NRC, Decommissioning Report, dated March 31, 2021, (ML21090A337)

Dear Sir or Madam:

Attached is the biennial decommissioning report for Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2, prepared and submitted by Vistra Operations Company LLC (Vistra OpCo / operator) pursuant to 10CFR50.75(f) and 10CFR72.30(c). Comanche Peak Power Company LLC (CP PowerCo / owner) is an unregulated utility and therefor e does not meet the definition of an electric utility as defined by 10CFR50.2.

The recovery of decommissioning funds for the eventual decommissioning of CPNPP Units 1 and 2 is assured through the collection of a non-bypassable charge which is subsequently contributed to an external trust.

The applicable sections of the citation (e.g., an Order by the rate-regulatory authority) by the regulatory authority that allows for the collection of non-bypassable charges established for the collection of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) is provided below.

The distribution utility will collect from customers and the generation company will contribute all funds collected to the decommissioning trust fund:

Enclosure to TXX-21066, Public Utility Commission of Texas (PUCT) Docket No. 50945, Item No. 23, Order dated January 29, 2021, page 2 of 7, paragraph #11.

The annual collection rate for each unit:

Enclosure to TXX-21066, PUCT Docket No. 50945, Item No. 1, 2020 Funding Analysis, Annual Projected Funding Requirement, Exhibit 4, Pages 20-24 of 24.

Enclosure to TXX-21066, PUCT Docket No. 50945, Item No. 23, Order dated January 29, 2021, Page 7 of 7, paragraph #1 and 2 of Section III.

Also, pursuant to the requirements of 10 CFR 72.30(c), Vistra OpCo is submitting the 2023 Decommissioning Funding Status Report for Comanche Peak Nuclear Power Plant (CPNPP) Independent Spent Fuel Storage Installation, Docket No. 72-74 (CPNPP ISFSI). Attachment 2 to this letter contains the information required by 10 CFR 72.30(b).

TXX-23017 Page 2 of2 The amounts to be collected for CPNPP decommissioning are based on a site specific decommissioning study that includes direct waste disposal. In addition, the radiological cost component breakdown of the 2019 Site Specific cost is included in the 2020 Financial Assurance filing (Enclosure to TXX-21066, PUCT Docket No.

50945, Item No. 1, Comanche Peak Power Company LLC Filing dated June 16, 2020, document Lll-1774-001, Rev. 0, Page xx of xxi).

When projected to the license expiration date for each unit using the 2 percent annual real rate of return as allowed per 10CFR50.75(e)(ii), the projected Nuclear Decommissioning Trust balance is greater than the escalated NRC minimum cost of decommissioning for Units 1 and 2.

Should you have any questions, please contact N. Boehmisch at (254) 897-5064 or nicholas.boehmisch@luminant.com.

Sincerely,

Jay)~

2023 Decommissioning Funding Status Report for Comanche Peak Nuclear Power Plant Units l and 2 2023 Decommissioning Funding Status Report for Comanche Peak Nuclear Power Plant Units 1 and 2 Independent Spent Fuel Storage Installation

c (email) - Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP Uohn.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

NRC Decommissioning Funding Status Report for Financial Assurance at December 31, 2022

L uminant G e ne r at io n C o mpany L L C Comanche Peak Nuclear Power Plant (CPNPP)

Information is submitted to provide Financial Assurance Unit # 1 Unit # 2

1. The minimum amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

At December 31, 2022 Using NRC 10 CFR 50.75(c) formul as (Note 1) $ 407.2 million $ 407.2 million Site-specific study (Note 2) $ 920.4 million $ 950.2 million

2. The amount accumulated at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75 (b) and (c).

Investment categories per Regulatory Guide 1.159 2.6.2. (Not e 3)

Cash 2% 2%

U.S. Equities 60% 60%

U.S. Fixed Income 38% 38%100% 100%

Market Value at December 31, 2022 $ 795.4 million $ 852.3 million

3. A schedule of the annual amounts remaining to be collected for items in 10 CFR 50.75 (b) and (c). Unit # 1Unit # 2 Years 2023 through 2029 ( 7 years ) 14.0 million 5.4 million Year 2030 3.5 million 5.4 million Year 2031 5.4 million Year 2032 5.4 million Year 2033 1.3 million Totals $ 101.4 million $ 54.9 million

4. The assumptions used regarding escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. Unit # 1Unit # 2 Estimated Escalation rate for decommissioning costs (Note 4) 2.6680% 2.6400%

Estimated Earnings rates on decommissioning funds (Note 5) 2023 through 2029 3.73% 3.73%

2030 through 2091 3.04% 3.04%

2092 and thereafter 2.19% 2.19%

Rates of other factors used in funding projections None None

5. Any power s al e cont r act s upon which licensee is relying to certifying financial assurance. None None

6. Modifications to licensee's method of pr ovi d i ng financial assurance since pr e vi ous r eport. None None

7. Material changes to trust agreement. None None

NOTE: All forecast data are based on the Decommissioning Cost Study and Funding Analysis filed with the Public Utility Commission of Texas on June 16, 2020 and is subject to approval by the Commission.

Note 1 Labor (South) and Energy are based on BLS (Lx=3.027, Ex=3.443) as of December 2022. Burial inflation factors are based on NUREG 1307, Report on Waste Burial Charges, Revision 19 (Bx=6.650).

Note 2 The Site Specific Decommissioning Cost estimates for unit 1 and 2, with a 10% contingency adjustment, are provided in the Enclosure to the referenced letter, pages 192-197. See the Financial Escalation Analysis Document L11-1774-002, Rev. 0, beginning Page 14 and 22 of 29.

Note 3 The after-tax amount of funds accumulated through December 31, 2022 is provided below.

Tax Basis Market Value After Tax Unit 1 $480,459,974.90 $795,427,245.46 $732,433,791.35 Unit 2 $507,999,926.51 $852,308,089.75 $783,446,457.10 Total $988,459,901.41 $1,647,735,335.21 $1,515,880,248.45

Note: Calculation of after tax balance assumes 20% tax rate.

Note 4 The rate of escalation in decommissioning costs for Unit 1 and 2 are provided in the Enclosure to the referenced letter, page 185. See the Financial Escalation Analysis Document L11-1774-002, Rev. 0, Page 7 of 37.

Note 5 The rate of earnings on decommissioning funds is provided in the Enclosure to the referenced letter, page 229-231. See Exhibit 2 of Funding Analysis dated June 2020. pg 13-15 of 24. The Net Expected Investment Returns Allocation Factor in this schedule represents the weighted average allocations during the referenced Period as established in the June 16, 2020 filing. to TXX-23017 Page 1 of 3 2023 Decommissioning Funding Status Report for Comanche Peak Nuclear Power Plant Units 1 and 2 Independent Spent Fuel Storage Installation

Pursuant to 10 CFR 72.30(c), each licensee for an Independent Spent Fuel Storage Installation (ISFSI), including an ISFSI licensed under the Ge neral License provided for in 10 CFR Part 72, Subpart K, is required, at intervals not to exceed 3 years, to resubmit a decommissioning funding plan with adjustments as necessary to account for changes in costs and the extent of contamination, as well as information regardin g the financial assurance provided for funding such costs. Vistra Operations Company LLC (Vistra OpCo) provides the following information regarding the Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2 Independent Spent Fuel Storage Installation, Docket No. 72-74 (CPNPP ISFSI):

1. Information on how reasonable assuranc e will be provided that funds will be available to decommission the ISFSI:

See response to number 4 below, which di scusses the appropriate method of financial assurance contemplated under 10 CFR 72.30(e).

2. A detailed cost estimate (DCE) for decommissioning:

In a report dated May 2020, TLG Services, Inc. (TLG) (Enclosure to TXX-21066 prepared a site specific Decommissioning Cost Study (with an adequate contingency factor) for the Comanche Peak Nuclear Power Plant (CPNPP) that included the costs of decommissioning the ISFSI. The TLG Report determined the total cost of decommissioning the CPNPP ISFSI to be:

2019 Dollars Escalation Factor (%) 2022 Dollars (million) (from TLG Report) (million)

(Note 1) (Note 2)

Unit 1 5.2 2.668 5.63 Unit 2 5.2 2.640 5.63 Total 11.26

This cost estimate includes the cost of an independent contractor to perform all decommissioning activities and the cost of meeting the 10 CFR 20.1402 criteria for unrestricted release.

Below is the effect of the following on th e detailed cost estimate since the previous report.

Spills of radioactive material producing additional None residual radioactivity in onsite subsurface material Facility modifications None (Note 3)

Changes in authorized possession limits None to TXX-23017 Page 2 of 3 2023 Decommissioning Funding Status Report for Comanche Peak Nuclear Power Plant Units 1 and 2 Independent Spent Fuel Storage Installation

Actual remediation costs that exceed the previous None cost estimate

3. Identification of and justification fo r using the key assumptions contained in the decommissioning cost estimate:

The assumptions used in the development of the decommissioning cost estimate and their justification can be found in the TLG Report.

4. A description of the method of assuring funds for decommissioning from 10 CFR 72.30(e), including means of adjusting cost estimates and associated funding levels periodically over the life of the facility:

Vistra OpCo is using the external sinking fund method as authorized in 10 CFR 72.30(e)(5) and 50.75(e)(1)(ii). Vistra OpCo recovers its costs for decommissioning through cost of service ratemaking, including the estimated costs to decommission the CPNPP ISFSI, which are included in the TLG Report. Purs uant to Substantive Rule 25.303(f)(2) of the Public Utility Commission of Texas (PUCT), th e TLG Report is updated, and the required annual funding amount necessary to deco mmission CPNPP is adjusted under the jurisdiction of the PUCT.

In the event that funds remaining to be plac ed into the Vistra OpCos external sinking funds are no longer approved for recovery in rates by competent rate making authorities, Vistra OpCo will make changes to provide financial assurance using one or more of the methods stated in 10 CFR 72.30(e)(1)-(4).

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

There has been no event at the ISFSI facility to lead us to believe there is subsurface contamination. Therefore, Vistra OpCo a ssumes that there is no volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

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

The submission of this report serves as ce rtification that financial assurance has been provided in the amount of the cost estimate for decommissioning.

to TXX-23017 Page 3 of 3 2023 Decommissioning Funding Status Report for Comanche Peak Nuclear Power Plant Units 1 and 2 Independent Spent Fuel Storage Installation

Note 1 The cost is without contingency is provided in Enclosure to letter TXX-21066 (Public Utility Commission of Texas (PUC T) Docket No. 50945, Item No. 1, document Lll-1774-001, Rev. 0, Appendix E, page 2 of 2, Table E, "Comanche Peak Nuclear Power Plant ISFSI Decommissioning Cost Estimate").

Note 2 The rate of escalation in decommissi oning costs are provided in the Enclosure to TXX-21066 (PUCT Docket No. 50945, Item No.1, document Lll-1774-002, Rev.

0, Table 1, "Escalation Summary")

Note 3 Enclosure to TXX-21066 (PUCT Docket No. 50945, Item 1, document Lll-1703-002, Rev. 0, dated May 2020, page viii of xxi) states in part, "The only substantive changes made to the plant inventory from the 2014 analysis (that would impact decommissioning) is the addi tion of the Stator Rewind building."

These changes (Stator Rewind building) are within the scope of the analysis under 10 CFR 50.75 which is included in Attachment 1 to TXX-21066.