ML080180440
| ML080180440 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/18/2008 |
| From: | Purcell M Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MD5011, TAC MD5012, TAC MD5013 | |
| Download: ML080180440 (4) | |
Text
January 18, 2008 10 CFR 50.33(f)(4) 10 CFR 50.75(h) 10 CFR 50.82(a)(8)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Gentlemen:
In the Matter of )
Docket Nos. 50-259 Tennessee Valley Authority )
50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - REQUEST FOR INFORMATION CONCERNING BIENNIAL DECOMMISSIONING FUNDING REPORT (TAC NOS. MD5011, MD 5012, MD 5013)
This responds to Eva A. Browns December 20, 2007, letter to William R. Campbell, Jr.
requesting information concerning the biennial decommissioning funding report filed by TVA on March 28, 2007. Specifically, TVA has been asked to address the reduction in the reported balance of the radiological decommissioning funds set aside for Browns Ferry Units 1, 2 and 3 in comparison with TVAs decommissioning funding report filed in March 30, 2005 (as supplemented on November 15, 2005).
TVA has a single Master Decommissioning Trust Agreement (Master Trust) which provides decommissioning funds covering each of TVAs six licensed operating nuclear units. TVAs Master Trust was established to hold funds for the contemplated radiological decommissioning of its operating units in accordance with NRCs decommissioning requirements (10 CFR §§ 50.75 and 50.82). The purpose of the Master Trust is to provide reasonable assurance that sufficient funds will be available for the radiological decommissioning of each of TVAs licensed units. No funds in the Master Trust are designated for any other purposes.
U. S. Nuclear Regulatory Commission Page 2 January 18, 2008 It is, first, important to note that no funds have at any time been withdrawn or disbursed from the Master Trust except, as permitted by NRC regulations, for those necessary to pay ordinary administrative costs or other incidental expenses in connection with the operation of the trust.
Second, absolutely no funds in the Master Trust have been adjusted, reallocated or in any way designated for nonradiological purposes and/or for spent fuel management. To the extent that the NRC staff has come to understand that radiological decommissioning funds may have been otherwise earmarked, as NRCs December 20 letter suggests, we wish to clarify that such is not the case.
TVAs Master Trust is divided into six separate Funds covering each of TVAs licensed operating nuclear units. In the period of time between TVAs issuance of its 2005 and 2007 decommissioning funding reports, TVAs total trust Funds balance increased significantly -
from $797.6 million (117.2 percent of the projected Funds total balance needed to meet NRC radiological decommissioning funding levels) to $1,003.9 million (143 percent of the projected Funds total balance needed to meet NRC funding levels). The projected Funds individual balances at the end of calendar year 2006 (set forth in the tables provided in of TVAs March 28, 2007, decommissioning funding report) reflected, among other things, the fact that TVA had obtained 20-year license extensions in 2006 for each of the three Browns Ferry units. In order to avoid significant overfunding of the Browns Ferry units accounts, which would have occurred as a result of 20 reactor years per unit of additional Funds earnings, a portion of the Browns Ferry funds were reallocated for accounting purposes to TVAs other operating units. This resulted in a decrease in the Browns Ferry units Funds from the levels reported by TVA in March 2005.
With the reallocation, the Browns Ferry units individual Funds continue to exceed each of their projected Fund balances and satisfy NRCs decommissioning funding requirements.
Even without the reallocation of the amounts in the Browns Ferry units Funds, the Sequoyah Units 1 & 2 and Watts Bar Unit 1 Funds would still have exceeded each of their projected Fund balances needed to satisfy NRC funding requirements based on the funding adjustment methodology described in TVAs 2005 report. In short, the accounting change was made for the sole purpose of addressing the increased years of Browns Ferry earnings accumulation.
We want to emphasize that adequate funding levels for each operating unit's Fund have always been maintained. We now understand that the reallocation of funds from the Browns Ferry units to the other units for accounting purposes could be considered a disbursement under NRCs regulations. Accordingly, we respectfully ask that the NRC allow TVA to maintain its current funding levels and allocations as reported in our March 28, 2007, decommissioning funding report. In doing so, full decommissioning funding will continue to be assured for each of TVAs operating units and their Funds will be able to accrue value on a measured, properly graduated schedule.
We would also like to point out that our projections at this time do not indicate the need for additional contributions to any of TVA's decommissioning Funds to satisfy NRC decommissioning funding obligations. As a result, the option of adjusting funding levels through future contributions would not be a reasonable alternative to the reallocation of funds.
Finally, the funding adjustment methodology and commitment thereto described in TVA's
U. S. Nuclear Regulatory Commission Page 3 January 18, 2008 October 30, 2003, letter to the NRC (referenced in TVAs 2005 and 2007 funding reports) remains in place to adjust funding levels if needed in the future. In sum, reasonable assurance continues to exist that sufficient decommissioning funding levels will be maintained for each of TVA's licensed power reactors.
Please feel free to direct any questions to Fred Mashburn at (423) 751-8817.
Sincerely, Original signed by Michael A. Purcell Senior Licensing Manager cc: See page 4
U. S. Nuclear Regulatory Commission Page 4 January 18, 2008 Ms. Eva A. Brown, Project Manager U. S. Nuclear Regulatory Commission MS 08G9 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Dr. William D. Travers, Regional Administrator U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-8931