L-13-270, Response to a Request for Additional Information Related to the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2: Davis-Besse Nuclear Power Station, Unit No. 1: and Perry Nuclear Power Plant, Unit No

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Response to a Request for Additional Information Related to the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2: Davis-Besse Nuclear Power Station, Unit No. 1: and Perry Nuclear Power Plant, Unit No
ML13247A054
Person / Time
Site: Beaver Valley, Davis Besse, Perry
Issue date: 08/22/2013
From: Halnon G
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML13247A048 List:
References
L-13-270, TAC MF2162, TAC MF2163, TAC MF2186, TAC MF2229
Download: ML13247A054 (7)


Text

341 White Pond Dr.

Akron, Ohio 44320 FirsneyNuic/ear Opertig Company*

August 22, 2013 L-1 3-270 10 CFR 50.75(f)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Response to a Request for Additional Information Related to the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2: Davis-Besse Nuclear Power Station, Unit No. 1: and Perry Nuclear Power Plant, Unit No. 1 (TAC Nos. MF2162, MF2163, MF 2186, and MF2229)

Pursuant to 10 CFR 50.75(f), the FirstEnergy Nuclear Operating Company (FENOC) submitted the biennial decommissioning funding status reports for Beaver Valley Power Station, Unit Nos. 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1 to the Nuclear Regulatory Commission (NRC) by letter dated March 25, 2013 (Accession No. ML13084A374). By letter dated July 18, 2013 (Accession No. ML13191A252), the NRC staff requested additional information to complete their review. Attachment 1, and Enclosures A and B contain the responses to the requested information.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.

Sincerely, irec Dire~ctor enon

-leet Regulatory Affairs ( r

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station, Unit No. 1 Perry Nuclear Power Plant, Unit No. 1 L-1 3-270 Page 2 Attachments:

1. Response To Request For Additional Information

Enclosures:

A. Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station, May 2011 B. Financial Escalation Analysis for the Decommissioning of Davis-Besse Nuclear Power Station, May 2011 cc: NRC Region I Administrator NRC Region III Administrator NRC Resident Inspector (Beaver Valley)

NRC Resident Inspector (Davis-Besse)

NRC Resident Inspector (Perry)

NRC Project Manager (Beaver Valley)

NRC Project Manager (Davis-Besse)

NRC Project Manager (Perry)

Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board

Attachment 1 L-1 3-270 Response To Request For Additional Information Page 1 of 4 By letter dated March 25, 2013 (Accession No. ML13084A374), the FirstEnergy Nuclear Operating Company (FENOC) submitted the biennial decommissioning funding status (DFS) reports for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS Unit Nos. 1 and 2); Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS);

and Perry Nuclear Power Plant, Unit No. 1 (PNPP) to the Nuclear Regulatory Commission (NRC). By letter dated July 18, 2013 (Accession No. ML13191A252), the NRC staff requested additional information on the reports to complete their review.

The responses to the request for additional information (RAI) are provided below. The NRC staff questions are presented in bold type, followed by the FENOC responses.

Beaver Valley Power Station, Unit Nos. 1 and 2

1. Per 10 CFR 50.75(f)(1), licensees must identify "the amount accumulated to the end of the calendar year preceding the date of the report." This actual amount is dedicated for activities that relate to the definition of "decommission," as specified in 10 CFR 50.2, "Definitions." By letter dated March 25, 2013, FENOC provided the amount accumulated in the decommissioning trust fund at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75(b) and (c).

The NRC staff requests that FENOC indicate what portion of the accumulated fund balances are for radiological decommissioning activities only. Specifically, FENOC should indicate whether any of the $250,935,980 for BVPS, Unit No. 1, and

$320,196,005 for BVPS, Unit No. 2, is for non-radiological decommissioning costs such as spent fuel management or other non-radiological decommissioning activities.

Response

The accumulated fund balances for BVPS Unit Nos. 1 and 2 are for radiological decommissioning.

Davis-Besse Nuclear Power Station, Unit No. I

1. Per 10 CFR 50.75(f)(1), licensees must identify "the amount accumulated to the end of the calendar year preceding the date of the report." This actual amount is dedicated for activities that relate to the definition of "decommission," as specified in 10 CFR 50.2, "Definitions." By letter dated March 25, 2013, FENOC provided the amount accumulated in the decommissioning trust fund at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75(b) and (c).

L-13-270 Page 2 of 4 The NRC staff requests that FENOC indicate what portion of the accumulated fund balances are for radiological decommissioning activities only. Specifically, FENOC should indicate whether any of the $478,270,692 for DBNPS is for non-radiological decommissioning costs such as spent fuel management or other non-radiological decommissioning activities.

Response

The accumulated fund balance for DBNPS is for radiological decommissioning.

2. Per 10 CFR 50.75(f)(3), "each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission." As presently scheduled, termination of operations for the DBNPS is currently set for April 2017.

Submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission the DBNPS.

Response

Enclosure A, "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," dated May 2011, is the current decommissioning cost estimate (DCE) for DBNPS. The analysis is based on 2010 dollars. Enclosure B, "Financial Escalation Analysis for the Decommissioning of Davis-Besse Nuclear Power Station," dated May 2011, contains an analysis of the escalation of the costs to decommission DBNPS to the projected year of expenditure.

Table 1 provides a conversion of Table 6.1, "Decommissioning Cost Elements (thousands of 2010 dollars)," contained in Enclosure A from 2010 dollars to 2012 dollars. A factor of 3.5 percent per year was used in the conversion.

L-13-270 Page 3 of 4 Table 1 Decommissioning Cost Elements (thousands of 2012 dollars)

Cost Element Total 1 Decontamination 11,125 Removal 131,338 Packaging 17,469 Transportation 13,707 Waste Disposal 62,303 Off-site Waste Processing 22,305 Program Management ' 538,031 Spent Fuel Pool Isolation 12,295 Spent Fuel (ISFSI Related)

  • 209,342 Insurance and Regulatory Fees 53,070 Energy 17,400 Characterization and Licensing Surveys 18,793 Property Taxes 131,601 Miscellaneous Equipment 7,075 Site O&M 23,024 Corporate A&G 32,661 Other 4 1,289 Total 1,302,828 Cost Element Total License Termination 568,117 Spent Fuel Management 654,318 Site Restoration 80,390 Total 1,302,825 Notes:
1. Columns may not add due to rounding.
2. Includes engineering costs.
3. Excludes program management costs (staffing) but includes costs for spent fuel loading/transfer costs/spent fuel pool operations and maintenance, and emergency planning fees.
4. Disposal of clean asbestos containing materials, e.g., from the cooling tower.

Conversion of the decommissioning costs to 2012 dollars was performed because the FENOC biennial decommissioning funding status report (Accession No. ML13084A374) provided the value of external trust funds as of December 31, 2012.

L-13-270 Page 4 of 4 Perry Nuclear Power Plant, Unit No. I

1. Per 10 CFR 50.75(f)(1), licensees must identify "the amount accumulated to the end of the calendar year preceding the date of the report." This actual amount is dedicated for activities that relate to the definition of "decommission," as specified in 10 CFR 50.2, "Definitions." By letter dated March 25, 2013, FENOC provided the amount accumulated in the decommissioning trust fund at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75(b) and (c).

The NRC staff requests that FENOC indicate what portion of the accumulated fund balances are for radiological decommissioning activities only. Specifically, FENOC should indicate whether any of the $462,378,077 for PNPP is for non-radiological decommissioning costs such as spent fuel management or other non-radiological decommissioning activities.

Response

The accumulated fund balance for PNPP is for radiological decommissioning.

Enclosure A L-13-270 Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station, May 2011 (Ninety-six pages follow)