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Category:Letter type:LR
MONTHYEARLR-N23-0079, Special Report 23-02-00 Pursuant to the Requirements of Salem Unit 1 Technical Specification 3.3.3.7, Action 10, for the Unit 1 Main Steam Line Rad Monitor Inoperable for Greater than Seven Days2023-12-0707 December 2023 Special Report 23-02-00 Pursuant to the Requirements of Salem Unit 1 Technical Specification 3.3.3.7, Action 10, for the Unit 1 Main Steam Line Rad Monitor Inoperable for Greater than Seven Days LR-N23-0077, Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 2023 & 30 Day Report for Salem Unit 1 Upflow Conversion2023-11-29029 November 2023 Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 2023 & 30 Day Report for Salem Unit 1 Upflow Conversion LR-N23-0072, Core Operating Limits Report Cycle 302023-11-0101 November 2023 Core Operating Limits Report Cycle 30 LR-N23-0065, Submittal of 2023 Annual 10 CFR 50.46 Report2023-10-0202 October 2023 Submittal of 2023 Annual 10 CFR 50.46 Report LR-N23-0045, and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement2023-09-0808 September 2023 and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement LR-N23-0055, Special Report 272/23-01-00, Pursuant to the Requirements of Technical Specification 3.3.3.1, Action 23, for the Vent Noble Gas Rad Monitor Inoperable for Greater than Seven Days2023-08-0303 August 2023 Special Report 272/23-01-00, Pursuant to the Requirements of Technical Specification 3.3.3.1, Action 23, for the Vent Noble Gas Rad Monitor Inoperable for Greater than Seven Days LR-N23-0052, Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers Per Technical Specification 4.6.2.12023-07-31031 July 2023 Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers Per Technical Specification 4.6.2.1 LR-N23-0054, In-Service Inspection Activities2023-07-26026 July 2023 In-Service Inspection Activities LR-N23-0042, Spent Fuel Cask Registration2023-07-12012 July 2023 Spent Fuel Cask Registration LR-N23-0046, Emergency Plan Document Revisions Implemented June 28, 20232023-07-10010 July 2023 Emergency Plan Document Revisions Implemented June 28, 2023 LR-N23-0005, License Amendment Request to Amend Technical Specifications (TS) 6.8.4.f for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2023-06-23023 June 2023 License Amendment Request to Amend Technical Specifications (TS) 6.8.4.f for Permanent Extension of Type a and Type C Leak Rate Test Frequencies LR-N23-0035, 2022 Annual Radioactive Effluent Release Report (ARERR)2023-04-27027 April 2023 2022 Annual Radioactive Effluent Release Report (ARERR) LR-N23-0034, 2022 Annual Radiological Environmental Operating Report (AREOR) - Salem Nuclear Generating Station, Unit Nos. 1 and 2 and Hope Creek Generating Station2023-04-27027 April 2023 2022 Annual Radiological Environmental Operating Report (AREOR) - Salem Nuclear Generating Station, Unit Nos. 1 and 2 and Hope Creek Generating Station LR-N23-0033, Core Operating Limits Report Cycle 272023-04-26026 April 2023 Core Operating Limits Report Cycle 27 LR-N23-0010, License Amendment Request Revision of Technical Specification (TS) to Delete TS Section 5.5 - Meteorological Tower Location2023-04-21021 April 2023 License Amendment Request Revision of Technical Specification (TS) to Delete TS Section 5.5 - Meteorological Tower Location LR-N23-0009, License Amendment Request (LAR) to Revise the Hope Creek Trip and Standby Auto-start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning (HVAC) Trains2023-04-18018 April 2023 License Amendment Request (LAR) to Revise the Hope Creek Trip and Standby Auto-start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning (HVAC) Trains LR-N23-0024, Submittal of Hope Creek Generating Station Technical Specification Bases Changes2023-03-29029 March 2023 Submittal of Hope Creek Generating Station Technical Specification Bases Changes LR-N23-0006, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-24024 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations LR-N23-0019, and Salem Generating Station, Units 1 and 2 - Guarantees of Payment of Deferred Premiums2023-03-21021 March 2023 and Salem Generating Station, Units 1 and 2 - Guarantees of Payment of Deferred Premiums LR-N23-0016, and Salem Generating Station, Units 1 and 2 - Report of Changes, Tests, and Experiments2023-02-28028 February 2023 and Salem Generating Station, Units 1 and 2 - Report of Changes, Tests, and Experiments LR-N23-0018, Technical Specification 6.9.1.5.b - 2022 Annual Report of SRV Challenges2023-02-27027 February 2023 Technical Specification 6.9.1.5.b - 2022 Annual Report of SRV Challenges LR-N23-0012, Annual Property Insurance Status Report2023-02-24024 February 2023 Annual Property Insurance Status Report LR-N23-0014, Stations Submittal of 2022 Annual Report of Fitness for Duty Performance Data Per 10 CFR 26.203(e) and 10 CFR 26.7172023-02-23023 February 2023 Stations Submittal of 2022 Annual Report of Fitness for Duty Performance Data Per 10 CFR 26.203(e) and 10 CFR 26.717 LR-N23-0003, Response to Requests for Additional Information Salem Unit 2 Relief Request S2-I4R-2112023-02-0101 February 2023 Response to Requests for Additional Information Salem Unit 2 Relief Request S2-I4R-211 LR-N23-0011, In-Service Inspection Activities - 90 Day Report: Twenty-Fourth Refueling Outage2023-01-19019 January 2023 In-Service Inspection Activities - 90 Day Report: Twenty-Fourth Refueling Outage LR-N22-0096, and Salem Generating Station, Units 1 and 2 - Request for Threshold Determination2023-01-0505 January 2023 and Salem Generating Station, Units 1 and 2 - Request for Threshold Determination LR-N22-0095, Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 20222022-12-20020 December 2022 Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - Annual Report 2022 LR-N22-0094, Emergency Plan Document Revisions Implemented November 21, 20222022-12-14014 December 2022 Emergency Plan Document Revisions Implemented November 21, 2022 LR-N22-0092, Response to Final Iolb Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG2022-12-0909 December 2022 Response to Final Iolb Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG LR-N22-0091, Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments2022-12-0202 December 2022 Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments LR-N22-0084, Response to Final Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L- 2022-LLA-0095)2022-11-17017 November 2022 Response to Final Request for Additional Information for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L- 2022-LLA-0095) LR-N22-0090, Supplement to Submittal of Salem Generating Station Updated FSAR, Revision 33, 10 CFR 71.106 Review Results and 10 CFR 54.37(b) Review Results for Salem2022-11-10010 November 2022 Supplement to Submittal of Salem Generating Station Updated FSAR, Revision 33, 10 CFR 71.106 Review Results and 10 CFR 54.37(b) Review Results for Salem LR-N22-0075, 2022 Annual 10 CFR 50.46 Report2022-09-30030 September 2022 2022 Annual 10 CFR 50.46 Report LR-N22-0065, Submittal of Relief Request Associated with the Fourth Inservice Inspection (ISI) Interval Limited Examinations2022-09-27027 September 2022 Submittal of Relief Request Associated with the Fourth Inservice Inspection (ISI) Interval Limited Examinations LR-N22-0074, Emergency Plan Evacuation Time Estimate2022-09-15015 September 2022 Emergency Plan Evacuation Time Estimate LR-N22-0066, License Amendment Request (LAR) to Relocate Technical Specifications (TS) Requirements for Reactor Head Vents to the Technical Requirements Manual (TRM)2022-08-31031 August 2022 License Amendment Request (LAR) to Relocate Technical Specifications (TS) Requirements for Reactor Head Vents to the Technical Requirements Manual (TRM) LR-N22-0063, Spent Fuel Cask Registration2022-08-10010 August 2022 Spent Fuel Cask Registration LR-N22-0068, In-Service Inspection Activities - 90-Day Report2022-08-10010 August 2022 In-Service Inspection Activities - 90-Day Report LR-N22-0012, License Amendment Request to Amend the Technical Specifications to Revise and Relocate the Reactor Coolant System Pressure and Temperature Limits and Pressurizer Overpressure Protection System Limits to a Pressure and Temperature2022-08-0707 August 2022 License Amendment Request to Amend the Technical Specifications to Revise and Relocate the Reactor Coolant System Pressure and Temperature Limits and Pressurizer Overpressure Protection System Limits to a Pressure and Temperature LR-N22-0062, Spent Fuel Cask Registration2022-07-21021 July 2022 Spent Fuel Cask Registration LR-N22-0006, License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days2022-06-29029 June 2022 License Amendment Request (LAR) to Amend Salem Unit 1 and Unit 2 Technical Specifications (TS) to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator from 72 Hours to 14 Days LR-N22-0051, License Amendment Request to Relocate Technical Specification Facility/Unit Staff Qualification Requirements to Quality Assurance Topical Report2022-06-22022 June 2022 License Amendment Request to Relocate Technical Specification Facility/Unit Staff Qualification Requirements to Quality Assurance Topical Report LR-N22-0044, Emergency Plan Document Revisions Implemented November, 20212022-05-19019 May 2022 Emergency Plan Document Revisions Implemented November, 2021 LR-N22-0043, Core Operating Limits Report - Cycle 292022-05-0909 May 2022 Core Operating Limits Report - Cycle 29 LR-N22-0040, 2021 Annual Radiological Environmental Operating Report2022-04-28028 April 2022 2021 Annual Radiological Environmental Operating Report LR-N22-0041, 2021 Annual Radioactive Effluent Release Report (Rerr)2022-04-28028 April 2022 2021 Annual Radioactive Effluent Release Report (Rerr) LR-N22-0039, Emergency Plan Document Revisions Implemented March 24, 20222022-04-21021 April 2022 Emergency Plan Document Revisions Implemented March 24, 2022 LR-N21-0052, Request for Relief from ASME Code Defect Removal for Service Water Buried Piping2022-04-0707 April 2022 Request for Relief from ASME Code Defect Removal for Service Water Buried Piping LR-N22-0022, Response to Request for Additional Information Relief Request S1-14R-210, Alternative Examination of Welds2022-03-21021 March 2022 Response to Request for Additional Information Relief Request S1-14R-210, Alternative Examination of Welds LR-N22-0023, Guarantees of Payment of Deferred Premiums2022-03-21021 March 2022 Guarantees of Payment of Deferred Premiums 2023-09-08
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PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 OPSEG Nuclear LLC 10 CFR 50. 75(f)(1)
LR-N11-0240 August 01,2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
Response to Request for Additional Information, 2011 NRC Decommissioning Funding Status Report
References:
(1) LR-N11-0086, NRC Decommissioning Funding Status Report, dated March 31, 2011 (2) NRC Letter to Mr. Thomas Joyce, Request for Additional Information Regarding 2011 Decommissioning Funding Status Report, dated July 1, 2011 In Reference 1 PSEG Nuclear LLC (PSEG) submitted a status report of the decommissioning funds for the subject facilities. In Reference 2 the NRC provided PSEG a Request for Additional Information (RAI) regarding the Reference 1 report. Attachment 1 to this submittal provides the responses to the RAI.
There are no commitments contained in this letter.
If you have any questions or require additional information, please do not hesitate to contact Ms.
Emily Maguire at (856)339-1023.
LR-N 11-0240 August 01, 2011 Page 2 Sincerely, OoJ)R-il-J Paul R. Duke, JV~~ _~ \
licensing Manager cc: Mr. W. Dean, Administrator, Region I, NRC Mr. R. Ennis, Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Manager IV, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator LR~N11-0240 Response to Request for Additional Information By letter dated March 31, 2011 (Agencywide Documents Access and Management System Accession No. ML110900521), PSEG Nuclear LLC (PSEG or the licensee) submitted the 2011 Decommissioning Funding Status (DFS) Report for Hope Creek Generating Station (Hope Creek), Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2, and Peach Bottom Atomic Power Station (Peach Bottom), Units 2 and 3, as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.75(f)(1).
RAt #1: Minimum Decommissioning Financial Assurance calculation According to 10 CFR 50.75(f)(1), the amount provided in the DFS report should be "the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c)."
In the DFS report dated March 31, 2011, PSEG reported an amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) less than the amountcalculated by the NRC staff for PSEG's portion of ownership for Salem Units 1 and 2 and greater than the amount calculated by the NRC staff for Hope Creek. The formulas for the factors used by the NRC staff can be found using NUREG-1307, Revision 14. For example, the calculations for the Labor and Energy Adjustment Factors can be found on pages 7 and 8 of NUREG-1307, Revision 14.
Provide the labor, energy, and burial factors used in your calculation of the minimum requirement for decommissioning financial assurance and, if necessary, a corrected submittal for that part of the DFS report.
PSEG Response PSEG used the following factors in the calculation of the minimum decommissioning funding requirements:
Plant Labor Energy Burial Hope Creek 2.454 2.319 12.54 Salem 2.454 2.263 12.28 Peach Bottom 2.454 2.319 12.54 The Labor Adjustment Factor was computed in accordance with NUREG-1307, section 3.1; however, the Northeast Region Employment Cost Index (ECI) for 4th Quarter 2010 was used instead of the ECI for 1st Quarter 2010.
The Energy Adjustment Factor was computed in accordance with NUREG-1307, section 3.2; however, the producer price indexes for 4th Quarter 2010 were used instead of the indexes for May 2010.
The Burial Factors for Hope Creek and Salem were taken from NUREG-1307, Table 2.1, for "Atlantic Compact, Direct Disposal with Vendors." The Burial Factor for Peach Bottom was taken from NUREG-1307, Table 2.1, for "Generic LLW Disposal Site, Direct Disposal with Vendors."
LR-N11-0240 RAI #2: Citation for real rate of returns As stated in 10 CFR 50.75(f)(1):
the information in [the DFS] report must include [ ... ] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections ...
In the DFS report dated March 31, 2011, PSEG stated that for the purpose of determining if the NRC's minimum requirements are met, PSEG has used an annual rate of return of 2%, as permitted by 10 CFR 50.75(e)(1)(ii).
Provide the citation by the regulatory entity (e.g., an Order by the rate-regulatory authority) that allows for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other factors assumed in your DFS report for
[Hope Creek, J Peach Bottom Units 2 and 3 and Salem Unit Nos. 1 and 2.
PSEG Response PSEG is no longer under the jurisdiction of a rate-setting authority, and therefore utilizes the rate of earnings that 10 CFR 50.75(e)(1)(i) allows when a higher rate has not been authorized by a rate-making authority~ In accordance with the provisions of 10 CFR 50.75(e)(1)(ii), PSEG has taken credit for earnings on decommissioning funds using a 2 percent annual real rate of return for Hope Creek, Peach Bottom Units 2 and 3, and Salem Unit Nos. 1 and 2.
RAI #3: Site-Specific Cost Estimate Appendix A to PSEG's DFS report dated March 31, 2011, shows that the amount of years remaining to start decommissioning is different than the remaining years for operations for each of the units (e.g. Hope Creek has 15.32 remaining years to end of operating license life and 58.8 remaining years to start of decommissioning). This difference appears to be based on an assumption of a 40-year SAFESTOR period plus 3.5 years of dismantlement as shown in Note 3 of Appendix A.
Although submittal of a site-specific cost estimate is not explicitly stated in 10 CFR 50.75(c)(1)(i) and (ii), if the information in the DFS report is based on a site-specific cost estimate, the NRC staff requests that this information be provided for Hope Creek, Salem Unit Nos. 1 and 2 and Peach Bottom Units 2 and 3 so that the staff can perform its independent analysis. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site-specific cost estimate should include a summary schedule of annual expenses, projected earnings, and end-of-year fund balances, expressed in 2010 dollars.
PSEG Response A site-specific cost estimate for Hope Creek was submitted on June 23, 2009 (ADAMS Accession No. ML091820277).
PSEG will provide an update to the Hope Creek site-specific cost estimate expressed in 2010 dollars. PSEG plans to submit the update by September 15,2011.
lR-N 11-0240 For Salem Unit Nos. 1 and 2 and Peach Bottom Units 2 and 3, the projected fund value at end of operating life (EOl) exceeds the minimum required amount, without accounting for SAFESTOR. However, PSEG will provide site-specific cost estimates for Salem Unit Nos. 1 and 2 and Peach Bottom Units 2 and 3 by September 15, 2011.
RAI #4: Amounts accumulated The provisions of 10 CFR 50.75(f)(1) and (2) require the licensee to report the amount of funds accumulated to the end of the calendar year preceding the report.
In the DFS report dated March 31, 2011, PSEG did not state if the amount of decommissioning funds accumulated was an after-tax amount.
Provide the after-tax amount of funds accumulated through December 31, 2010.
PSEG Response The table below provides the after-tax market values for the trust as of December 31,2010.
Plant After-tax amount of funds accumulated through December 31,2010 ($ Thousands)
Hope Creek 390,030 Salem Unit 1 251,954 Salem Unit 2 230,825 Peach Bottom Unit 2 212,694 Peach Bottom Unit 3 215,347 Total 1,300,850 The after-tax values were developed by applying a 20% federal tax rate on the qualified unrealized gain position as of December 2010. No adjustment was made to the non-qualified component of the trust as all tax payments are made by the Company and not the trust.