ML081830279

Draft Request for Additional Information, Licensee'S Proposed Exemptions from Provisions of 10 CFR Section 50.82(a)(8)

ML081830279
Person / Time
Site:	Salem
Issue date:	06/30/2008
From:	Richard Ennis NRC/NRR/ADRO/DORL/LPLI-2
To:	Chernoff H NRC/NRR/ADRO/DORL/LPLI-2
Ennis R, NRR/DORL, 415-1420
References
TAC MD8484
Download: ML081830279 (4)

Text

June 30, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MD8484)

The attached draft request for information (RAI) was transmitted on June 30, 2008, to Mr. Jeff Keenan of PSEG Nuclear LLC (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s proposed exemption from the provisions of Section 50.82(a)(8) of Title 10 of the Code of Federal Regulations for Salem Nuclear Generating Station (Salem), Unit No. 2, dated April 7, 2008.

The proposed exemption would permit the immediate withdrawal of certain funds from the decommissioning trust funds (DTF), maintained by the licensee for Salem Unit No. 2, to pay for the disposal of certain major radioactive components. Specifically, the licensee plans to dispose of the four steam generators that were removed from Salem Unit No. 2 during the spring 2008 refueling outage.

This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees request.

Docket No. 50-311

Attachment:

Draft RAI

June 30, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MD8484)

The attached draft request for information (RAI) was transmitted on June 30, 2008, to Mr. Jeff Keenan of PSEG Nuclear LLC (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s proposed exemption from the provisions of Section 50.82(a)(8) of Title 10 of the Code of Federal Regulations for Salem Nuclear Generating Station (Salem), Unit No. 2, dated April 7, 2008.

The proposed exemption would permit the immediate withdrawal of certain funds from the decommissioning trust funds (DTF), maintained by the licensee for Salem Unit No. 2, to pay for the disposal of certain major radioactive components. Specifically, the licensee plans to dispose of the four steam generators that were removed from Salem Unit No. 2 during the spring 2008 refueling outage.

This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensee's request.

Docket No. 50-311

Attachment:

Draft RAI DISTRIBUTION PUBLIC RidsNrrDorlLpl1-2 MDusaniwskyj, DPR PDI-2 Reading RidsNrrPMREnnis SHom, DPR RidsNrrDorlDpr LPittiglio, DPR ACCESSION NO.: ML081830279 OFFICE PDI-2/PM NAME REnnis DATE 6/30/08 OFFICIAL RECORD COPY

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED EXEMPTION DECOMMISSIONG TRUST FUND SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 DOCKET NO. 50-311 By application dated April 8, 2007, PSEG Nuclear LLC (PSEG or the licensee) submitted a proposed exemption from the provisions of Section 50.82(a)(8) of Title 10 of the Code of Federal Regulations (10 CFR) for Salem Nuclear Generating Station (Salem), Unit No. 2. The proposed exemption would permit the immediate withdrawal of certain funds from the decommissioning trust funds (DTF), maintained by the licensee for Salem Unit No. 2, to pay for the disposal of certain major radioactive components. Specifically, the licensee plans to dispose of the four steam generators that were removed from Salem Unit No. 2 during the spring 2008 refueling outage.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee provided that supports the proposed exemption and would like to discuss the following issues to clarify the submittal.

1) Enclosure 2, entitled, Decommissioning Cost Analysis for the Salem Nuclear Generating Station, Units 1 and 2 (Document P07-1425-003, Revision 0) was prepared for PSEG by TLG Services, Inc. dated December 2002. What is the adjustment/escalation factor that would be used to adjust the cost estimate to 2008 dollars? What is the adjusted cost in 2008 dollars to decommission Salem Unit No. 2?

2) Enclosure 2, page xii, estimated the license termination cost for Salem Unit No. 2 as

$544.9 million in 2002 dollars and indicated that that cost included spent fuel management costs. Site restoration costs were estimated at $53.7 million for a total cost of $598.7 million in 2002 dollars. Identify the radiological part of the $544.9 million.

3) Enclosure 1,Section IV.A.1, Status of the Decommissioning Trust Fund indicated that the DTF balance as of December 31, 2006, totaled $224.8 million for PSEGs 54.7 percent ownership, and, based on the NRC formula in 10 CFR 50.75, is approximately $204.4 million for PSEGs share. In 2008 dollars, provide PSEGs amount it is responsible for of the site-specific cost estimate and exclude the spent fuel costs.

4) Enclosure 1,Section IV.A.2, Site-Specific Decommissioning Cost Estimate Is Comprehensive indicated that PSEGs share is $71.6 million for spent fuel cost. How was that cost developed and what year dollars were used as the basis for the cost? For the NRC staffs analysis, the staff assumed a 3.0 percent inflation rate, based on historical data, resulting in an estimated total cost of $700.0 million in 2008 dollars based on the TLGs 2002 cost estimate. The staff analysis estimated that PSEGs Attachment

obligation would be approximately $383.0 million, based on a 54.7 percent ownership, which included spent fuel and site restoration costs, and approximately $348.0 million for radiological and spent fuel costs, excluding site restoration cost. Based on PSEGs spent fuel cost, the staff analysis resulted in a radiological cost estimate of approximately

$277.0 million in 2008 dollars ($348.0 - $71.6). PSEGs analysis indicted that their share is $206.9 million (page 4) including a spent fuel cost of $71.6 and greenfield cost based on a 54.7 percent ownership. PSEGs estimate compared to the NRCs estimate is

$348.0 million compared to $124.8 million (page 4). The staff requests that PSEG reconcile the significant difference between PSEGs and NRCs cost estimates, as the NRC was not able to reconcile these differences.

5) Enclosure 1,Section IV.A.1, indicated that PSEGs share of the DTF is $224.8 million, as of December 31, 2006, which included $ 71.6 million in spent fuel costs (i.e., approximately $153.2 million when the spent fuel cost is subtracted). This amount includes the greenfield cost. What is the amount, in 2008 dollars, when greenfield cost is removed? The NRC staff initially applied a 2 percent real rate of return on the DTF balance of $153.2 million for the remaining plant life and the prorated credit into the immediate dismantlement period resulting in a DTF balance of $207 million. If the site restoration cost is subtracted, the DTF would not meet the NRCs formula amount and the DTF balance would be significantly less than the site-specific cost estimate. The staff requests that PSEG confirm these costs and indicate how the DTF will be supplemented. This staffs analysis did not subtract the steam generator cost from the balance as the DTF appears to be under-funded.