ML071070368

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Review of Site Specific Decommissioning Cost Estimates
ML071070368
Person / Time
Site: Byron, Braidwood, LaSalle  Constellation icon.png
Issue date: 04/24/2007
From: Gratton C
NRC/NRR/ADRO/DORL/LPLIII-2
To: Crane C
Exelon Generation Co
Gratton C, NRR, DORL, 415-1055
References
TAC MD3928, TAC MD3929, TAC MD3930, TAC MD3931, TAC MD3932
Download: ML071070368 (5)


Text

1 Once a licensee is no longer legally eligible to recover all decommissioning costs from non-bypassable charges, notwithstanding that some non-bypassible charges remain to be collected, the licensee is limited to a 2 percent real rate of return credit for the remaining operating period, and a 2 percent real rate of return credit on the trust fund balance, but only after the total annual costs for the SAFSTOR and decommissioning periods have been deducted.

April 24, 2007 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; AND LASALLE COUNTY STATION, UNITS 1 AND 2 - REVIEW OF SITE-SPECIFIC DECOMMISSIONING COST ESTIMATES (TAC NOS. MD3928 THROUGH MD3932)

Dear Mr. Crane:

The Nuclear Regulatory Commission (NRC) staff completed its review of the Exelon Generation Company, LLCs (Exelons), submittal dated December 18, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML063540225), Site-specific Decommissioning Cost Estimates, and supplemental submittal dated February 27, 2007 (ADAMS Accession No. ML070600197), Response to Request for Additional Information Regarding Site-specific Decommissioning Cost Estimate. The February 27, 2007, submittal was in response to an NRC facsimile dated February 7, 2007 (as documented in ADAMS Accession No. ML070590685, dated March 7, 2007). In addition, a conference call was held on February 22, 2007, to obtain clarification on the information requested and submitted. All of the above information was provided in response to the initial issues NRC identified based on the staffs review of the Exelons submittal, Report on the Status of Decommissioning Funding for Reactors dated March 24, 2005 (ADAMS Accession No. ML050840550).

For the subject Exelon units, the NRC staff conducted an analysis of the decommissioning costs and projected trust fund balances. For the 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 units. Once the units 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 were deducted annually before a 2 percent real rate of return was credited for each prospective years funds.1 Based on Exelons supplemental submittals, the NRC staff has concluded that Exelon has demonstrated reasonable assurance of decommissioning funding for Braidwood Station (Braidwood), Units 1 and 2, Byron Station (Byron), Unit Nos. 1 and 2, and LaSalle County Sation (LaSalle), Units 1 and 2. This closes the issues raised by the Exelon submittal dated March 31, 2005.

C. Crane During the February 22, 2007, conference call, NRC the staff raised an issue with Exelon regarding its apparent intent to use funds from the decommissioning trust for non-radiological decommissioning costs, specifically the cost of spent fuel storage. The NRC staff referred to the annual costs identified in Tables A-1 (Braidwood,Unit 1) and Table A-2 (Braidwood, Unit 2);

Table B-1 (Byron, Unit 1) and Table B-2 (Byron, Unit 2); and Table C-1 (LaSalle, Unit 1) and Table C-2 (LaSalle, Unit 2) of Exelons submittal dated December 18, 2006. In these tables, Exelon included the cost of spent fuel storage in their estimated annual expenses for SAFSTOR. As we discussed during the conference call, the decommissioning trust funds are restricted to radiological decommissioning costs. Non-radiological costs or operating expenses cannot be deducted from the decommissioning trust fund, even in instances where sufficient funds are available to complete decommissioning and pay for non-radiological costs, as is the case at LaSalle County Station, Units 1 and 2.

If you have any questions, please contact me at 301-415-1055.

Sincerely,

/RA/

Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457; STN 50-454 and STN 50-455; 50-373 and 50-374 cc: See next page

ML071070368 NRR-106 OFFICE LPL3-2/PM LPL3-2/LA PFPR/BC LPL3-2/BC NAME CGratton:mw EWhitt RCarlson (C.Pittiglio for)

RGibbs DATE 4/23/07 4/23/07 4/16/07 4/24/07

Byron/Braidwood Stations cc:

Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355 Pittsburgh, PA 15230-0355 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Dr., Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, IL 61010-9750 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 Attorney General 500 S. Second Street Springfield, IL 62701 Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109 Plant Manager - Byron Station Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Site Vice President - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 County Executive Will County Office Building 302 N. Chicago Street Joliet, IL 60432 Plant Manager - Braidwood Station Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, IL 60935 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Senior Vice President - Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

Byron/Braidwood Stations cc:

Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Regulatory Assurance - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Manager Regulatory Assurance - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Vice President - Regulatory & Legal Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood/Byron Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Midwest Operations Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 LaSalle County Station, Units 1 and 2 cc:

Manager Regulatory Assurance - LaSalle Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757 U.S. Nuclear Regulatory Commission LaSalle Resident Inspectors Office 2605 North 21st Road Marseilles, IL 61341-9756 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, IL 60603 Assistant Attorney General 100 W. Randolph St. Suite 12 Chicago, IL 60601 Chairman LaSalle County Board 707 Etna Road Ottawa, IL 61350 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351