RS-07-031, Response to Request for Additional Information Regarding Site-specific Decommissioning Cost Estimates

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Response to Request for Additional Information Regarding Site-specific Decommissioning Cost Estimates
ML070600197
Person / Time
Site: Byron, Braidwood, LaSalle  Constellation icon.png
Issue date: 02/27/2007
From: Simpson P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, NRC/NRR/ADRO
References
RS-07-031
Download: ML070600197 (5)


Text

Exelon Generation wwwexeloncorp.com 4300 Winfield Road Warrenville, IL 60555 RS-07-031 February 27, 2007 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001

References:

(1)

Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Exelon.

Nuclear 10 CFR 50.75(b)(1)

Subject:

Response to Request for Additional Information Regarding Site-specific Decommissioning Cost Estimates Letter from Exelon Generation Company, LLC, "Report on Status of Decommissioning Funding for Reactors," to NRC dated March 31, 2006 (2)

Letter from Exelon Generation Company, LLC, "Site-specific Decommissioning Cost Estimates," to NRC dated December 18, 2006 In Reference 1, Exelon Generation Company, LLC (Exelon) committed to submit site-specific decommissioning cost estimates for Braidwood Station, Byron Station and LaSalle County Station to the NRC by December 31, 2006. These cost estimates were provided to the NRC in Reference 2.

The NRC requested additional information via facsimile dated February 7, 2007, to support their review of Reference 2. A conference call occurred on February 22, 2007, between Exelon and the NRC to obtain clarification of the information request. The attachment to this letter provides the requested information.

February 27, 2007 U. S. Nuclear Regulatory Commission Page 2 There are no commitments contained in this letter.

If you have any questions about this letter or enclosures, please contact me at (630) 657-2823.

Respectfully, Patrick R. Simpson Manager - Licensing

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Attachment - Response to NRC Request for Additional Information

NRC_ Request On December 18, 2006 Exelon Generation Company, LLC (EGC, the licensee) submitted letter RS-06-176, which included site-specific cost estimates and identified SAFSTOR periods for Braidwood Station (Braidwood) Units 1 and 2; Byron Station (Byron), Unit Nos. 1 and 2; and LaSalle County Station (LaSalle) Units 1 and 2. The information was submitted in response to questions raised by the Nuclear Regulatory Commission (NRC) staff following its review of letter RS-05-035, "Report on the Status of Decommissioning Funding for Reactors," dated March 24, 2005.

The NRC staff conducted an independent analysis of the decommissioning costs for the EGC plants identified in the licensee's December 18, 2006, letter. For the independent analysis, the NRC staff applied a 2 percent real rate of return credit to the trust fund balance for the licensed operating period for these plants. Once the plants were projected to enter into SAFSTOR, the NRC staff applied a 2 percent real rate of return on the annual fund ; however, total annual costs identified in Tables A-1 (Braidwood Unit 1), Table A-2 (Braidwood Unit 2), Table B-1 (Byron Unit 1), Table B-2 (Byron Unit 2),

Table C-1 (LaSalle Unit 1), and Table C-2 (LaSalle Unit 2) were deducted annually before the 2 percent real rate of return was credited for each prospective year.

The NRC staff's analysis indicates that EGC has sufficient funds to complete decommissioning of the LaSalle units. However, for both Braidwood Units 1 and 2, and Byron Unit Nos. 1 and 2, the NRC staff needs additional information to determine whether its trust funds are sufficient to complete decommissioning.

EGC did not identify any additional or separate funds to address the costs of spent fuel storage, which were included in the annual costs in Table A-1 and A-2 for Braidwood, and Tables B-1 and B-2 for Bryon. The total annual costs identified in these tables were included in the NRC staff's analysis. Please identify any additional or separate funds to address spent fuel storage expenses, or other costs identified in your submittal.

Exelon Response Response to Request for Additional Information In response to the NRC's above request and consistent with the discussions which occurred between the NRC and Exelon on February 22, 2007, Exelon has created the following table which provides clarification and updating of the information provided in the cost estimation studies previously provided in the Exelon letter dated December 18, 2006. The table lists the estimated cash flows for radiological decommissioning each of the subject units in 2007 dollars. These cash flows are for radiological decommissioning only and do not reflect expenditures for any other purpose. In addition, the following table differs from Tables A-1, A-2, B-1, B-2, C-1, and C-2, in that the labor costs during the SAFSTOR periods are adjusted such that both units at a site share the cost equally rather than the majority of the labor costs being allocated to the first unit. The amount of funds in the decommissioning trusts for each unit as of December 31, 2006, are also provided.

Any spent fuel management expenses associated with these units can be paid by Exelon operating revenues and other assets, as needed. Pursuant to 10 CFR Attachment

Response to Request for Additional Information Attachment 50.54(bb), Exelon will submit spent fuel management plans five years before expiration of the reactor operating licenses. At that time, Exelon will elect one or more mechanisms for the payment of the spent fuel management costs.

Trust Fund Balame (an of IujlM)

Total Funding Requhed at Shutdown Funding AvellaMe at Shutdown unn penart Funded Radlologlcal Decommissioning Cash Flows (in thousands, 2007$)

Site Percent Funded