ML082910294
| ML082910294 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/14/2008 |
| From: | Ted Sullivan Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 08-077 | |
| Download: ML082910294 (11) | |
Text
SEntergy Entergy Nuclear Operations, Inc.
Vermont Yankee P0.. Box 0250 320 Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 October 14, 2008 BVY 08-077 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
References:
(1)
Letter, Entergy to USNRC, Report Pursuant to 10CFR50.54(bb),
BVY 07-007, dated March 21, 2007 (2)
Letter, USNRC to Entergy, Request for Additional Information to Support the Review of the Vermont Yankee Spent Fuel Management Plan Pursuant to 10CFR50.54(bb), NVY 08-030, dated March 12, 2008 (3)
Letter, Entergy to USNRC, Response to Request for Additional Information, BVY 08-022, dated April 24, 2008 (4)
Letter, USNRC to Entergy, Review of the Spent Fuel Management Plan, NVY 08-069, dated July 16, 2008 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Revised Spent Fuel Management Plan Pursuant to 10CFR50.54(bb)
Subject:
Dear Sir or Madam,
In Reference (4), NRC staff completed a review of previous submittals (References 1 and 3) and determined that they could not provide preliminary approval of Entergy VY's spent fuel management program under 10CFR50.54(bb).
NRC staff requested in Reference (4) that a revised spent fuel management plan be submitted for review. to this letter provides Entergy VY's response to the staff's request contained in Reference (4).
There are no new regulatory commitments being made in this submittal.
Should you have any questions concerning this submittal, please contact Mr. David J.
Mannai at (802) 451-3304.
Sincerely,
-ie9,Ac--iivan We Vice President Vermont Yankee Nuclear Power Station ( 8 pages) 4Aoo/
BVY 08-077 Docket No. 50-271 Page 2 of 2 cc:
Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee P.O. Box 157 320 Governor Hunt Road Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620
Docket No. 50-271 BVY 08-077 Vermont Yankee Nuclear Power Station Revised Spent Fuel Management Plan - 1 OCFR50.54(bb)
BVY 08-077/Attachment )
Program for Maintenance of Irradiated Fuel Page 1 of 8 Vermont Yankee Nuclear Power Station Program for Maintenance of Irradiated Fuel Background and Introduction This submittal is intended to respond to the Staff's request dated July 16, 2008 for a revised spent fuel management plan for Vermont Yankee Nuclear Power Station (Vermont Yankee)
(ML081700564). Entergy Nuclear Vermont Yankee, LLC (Entergy VY or the Company) is seeking renewal of the operating license for Vermont Yankee, currently set to expire on March 21, 2012. However, pursuant to 10 CFR 50.54(bb), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit written notification to the Nuclear Regulatory Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U.S. Department of Energy (DOE) for ultimate disposal.
Entergy VY is submitting this plan to comply with the requirements of 10 CFR 50.54(bb).
Entergy VY has not determined or committed to a specific decommissioning approach for Vermont Yankee at this time. However,' it is Entergy VY's current plan for purposes of demonstrating the adequacy of funding to meet regulatory requirements to use the SAFSTOR decommissioning option based on the current license expiration date, employing a SAFSTOR period as permitted in 10 CFR §50.82(a)(3) such that decommissioning is completed within 60 years of permanent cessation of operations, coupled with a $60 million cash contribution to the decommissioning trust in 2026. VY license renewal is likely to require a need to revise this preliminary plan.
Spent Fuel Management Strategy DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue")
in which it was removed from service ("oldest fuel first allocation"). The Company's current spent fuel management plan for the Vermont Yankee spent fuel is based upon (1) a 2017 start date for repository operations, consistent with the DOE's License Application Schedule for Yucca Mountain released in 2006, and (2) the DOE's expectations for spent fuel receipt as delineated in the "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567,
BVY 08-077/Attachment )
Program for Maintenance of Irradiated Fuel Page 2 of 8 last updated in July 2004. Based on these assumptions, the Company projects that all fuel would be removed from the site as of 2042.[']
Interim storage of the spent fuel, until the DOE has completed the transfer, will be in the reactor building storage pool and/or at an Independent Spent Fuel Storage Installation (ISFSI) located on the Vermont Yankee site.
An ISFSI has been constructed within the protected area (PA) to support continued plant operations. Depending upon the shutdown date and DOE's performance, this facility may not have sufficient capacity to support decommissioning operations. For purposes of this plan, a second, supplemental ISFSI is assumed to be required to accommodate all the assemblies discharged over the operating period of the reactor. For financial planning purposes, the cost to construct this new facility is included within the decommissioning cost reported for the SAFSTOR scenario.
In the scenario assumed for this plan, 3,719 assemblies are generated through the end of currently licensed operations in 2012. To maintain core off-load capability, ten casks are loaded during operations (680 assemblies) and placed on the PA ISFSI pad. A new, larger pad is constructed on the site (within the owner controlled area) to permit post-shutdown dry fuel storage. The ten casks are relocated to this new pad in early 2015. The assemblies stored in the reactor building's spent fuel storage pool at the time of shutdown (3,039 assemblies) are loaded into multi-purpose canisters (MPCs) and moved into storage casks on the new pad by late 2017.
During the dormancy period, the MPCs are periodically off-loaded into a DOE transport cask such that all 55 canisters are removed from the site by the year 2042. A discussion of the site-specific considerations for the management of spent fuel at Vermont Yankee may be found in Section 3.4 of the referenced decommissioning analysis.
As indicated above, the present spent fuel management plan assumes a SAFSTOR period such that decommissioning is completed within 60 years of permanent plant shutdown. Starting in 2012, the plant is put into SAFSTOR, and spent fuel is moved to a new ISFSI. DOE begins spent fuel removal activities at the site in 2017, continuing to 2042. Between 2043 and 2067, the plant continues to remain in SAFSTOR. In 2067, dismantlement of the plant commences, and the decommissioning project is completed in 2072. Major scheduling milestones are identified in Table 1 below.
In the absence of identifiable DOE cask requirements, the design and capacity of the new ISFSI is based upon a commercial dry cask storage system. The MPC has a capacity of 68 fuel assemblies at a unit cost of approximately $705,000. An additional cost of $292,000 is allocated for the concrete storage overpack.
In addition to the satisfactory resolution of current and pending legal challenges and the elimination or amendment of the administrative limit on the repository's total capacity. The Company's analysis assumes, for purposes only of this report, that the Company does not employ DOE spent fuel disposal contract allowances for up to 20% additional fuel designation for shipment to DOE each year.
BVY 08-077/Attachment 1 Program for Maintenance of Irradiated Fuel Page 3 of 8 An average cost of $274,500 was estimated for the labor and equipment to load, seal and transfer each MPC from the storage pool to the ISFSI. A cost of $76,000 was estimated for the final transfer of the MPC at the ISFSI into a DOE transport cask (50% of the cost incurred for transferring the spent fuel into a dry storage canister).
Operation of the spent fuel pool is discontinued in 2017 after the fuel has been transferred to dry storage. ISFSI operations continue throughout the dormancy period until such time that the DOE is able to complete the transfer of the Vermont Yankee fuel to a federal repository in 2042.
Dormancy activities while spent fuel is still on the site include operations and maintenance of the spent fuel pool until unloaded, procuring, loading and transferring MPCs, a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.
After all fuel has been transferred to dry storage, dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.
Decommissioning In 2067, decommissioning operations would commence. The ISFSI is scheduled to be decommissioned along with the nuclear plant facilities. It is assumed that once the MPCs containing the spent fuel assemblies have been removed, any required decontamination performed on the storage modules and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad can then be removed and the area regraded.
Financial Assurance A site-specific estimate of the cost to decommission the Vermont Yankee nuclear unit has been prepared.E21 The analysis evaluated eight possibledecommissioning scenarios, reflecting differences in the decommissioning alternative or approach selected, the expected operating license, as well as when the DOE could be expected to complete the transfer of spent fuel from the site.
Entergy VY's spent fuel management plan herein is based on Scenario 5 as submitted in that decommissioning cost estimate (ML080430658). However, Scenario 5 has been altered for this 2
"Decommissioning Cost Analysis for the Vermont Yankee Nuclear Power Station," Document No. E I -1559-002, Rev. 0, January 2007.
BVY 08-077/Attachment )
Program for Maintenance of Irradiated Fuel Page 4 of 8 spent fuel management plan by extending the period of SAFSTOR such that decommissioning is completed in 2072, 60 years following permanent cessation of operations.
This plan assumes a 2% annual real rate of return as allowed in 10 CFR 50.75. Under this plan, Entergy VY will deposit $60 million in the decommissioning trust in the year 2026.
The decommissioning trust fund balance for Vermont Yankee was reported at $439.567 million as of December 31, 2007.
Table 2 below provides a schedule of estimated expenditures for the license termination and spent fuel management costs in 2007 dollars. The source for this information is the latest decommissioning estimate, escalated from 2006 dollars to 2007 dollars. Costs are included for the design and construction of the ISFSI, the relocation of the spent fuel from the pool to the ISFSI pad, and eventual transfer of the fuel to the DOE.
To demonstrate the adequacy of the existing funds to cover both license termination and spent fuel management, the fund balance going forward is escalated at 2% per year. In year 2026, Entergy VY deposits an additional $60 million into the decommissioning fund. The results of this analysis demonstrate that the balance in the decommissioning trust is adequate to fund both the decommissioning and spent fuel management costs, with a surplus shown at the end of the decommissioning project.
NRC Approvals This spent fuel management plan assumes withdrawals from the decommissioning trust for spent fuel management purposes. Entergy VY will make appropriate submittals for an exemption in accordance with 10 CFR §50.12 from the requirements of 10 CFR
§50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for spent fuel management expenses. Entergy VY will periodically revisit the amount of the cash contribution required to the decommissioning fund to ensure that spent fuel management withdrawals would not inhibit the ability of the licensee to complete radiological decommissioning, and will make further contributions if required for that purpose.
BVY 08-077/Attachment 1 Program for Maintenance of Irradiated Fuel Page 5 of 8 Table 1 Projected Schedule and Milestones Major Milestones and Fuel-Related Events Currently scheduled cessation of plant operations New ISFSI available Casks transferred from PA ISFSI to New ISFSI First MPC transferred from p9lto New ISFSI______
Last MPC transferred fromppooi to New ISFSI End of wet storage pool operations (66 months)
IDOE begins to receive commercial spent fuel
- . M. a r ch..2 0.....
.March 2012 2015 (beginning of Is quarter) 2.1......---
.b.........
I..n....
..... u r e r...
2015 (by end of 1st quarter) 2015 (3 qduarter) 2017 (3' quarter)
September 2017 March 31, 2017 2018 (4t quarter)
December 2042 2067
.2.......7.....
2067 -2072 1 st Vermont Yankee fuel assembly removed from site Last Vermont Yankee fuel assembly leaves site D..ecom m iss.ion
.in g..
Operatio ns.C.om m ence................
.ISFS.. decommI.ssoned
... (concurrent with......te......t..s..........
other.site.fac
BVY 08-077 /Attachment 1 Program for Maintenance of Irradiated Fuel Page 6 of 8 Table 2 Vermont Yankee Nuclear Power Station Decommissioning Funding Plan Scenario 5: 2012 Shutdown, Extended SAFSTOR Alternative, 2017 DOE Start Date (thousands of 2007 dollars)
Basis Year 2007 Fund B alance
$439.567 Annual Escalation 0.00%
Annual Earnings 2.00%
A B
C D
E F
Total License Termination 50.75 50.54(bb) and Decommissioning License Spent Fuel Spent Fuel Total Cost Trust Fund Termination Management Management Escalated at Contributions Escalated at 2%
Cost Cost Cost 0%
to Trust Fund (minus expenses)
Year (millions)
(millions)
(millions)
(millions)
(millions)
(millions) 2007 439.567 2008 448.358 2009 457.326 2010 466.472 2011
-,-475.801 2012 32.668 13.597 46.265 46.265 439.052 2013 37.246 27.864 65.110 65.110 382.724 2014 3.816 28.362 32.178 32.178 358.200 2015 3.816 28.362 32.178 32.178 333.186 2016 3.826 28.440 32.266 32.266 307.584 2017 3.815 20.377 24.192 24.192 289.543 2018 3.813 2.956 6.769 6.769 288.565 2019 3.813 2.569 6.382 6.382 287.955 2020 3.823 2.808 6.631 6.631 287.083 2021 3.813 2.879 6.692 6.692 286.132 2022 3.813 2.879 6.692 6.692 285.163 2023 3.813 2.801 6.614 6.614 284.252 2024 3.823 2.731 6.554 6.554 283.383 2025 3.813 2.724 6.537 6.537 282.514 2026 3.813 2.724 6.537 6.537 60.000 341.627 2027 3.813 2.724 6.537 6.537 341.923 2028 3.823 2.731 6.554 6.554 342.207 2029 3.813 2.647 6.460 6.460 342.591 2030 3.813 2.724 6.537 6.537 342.906 2031 3.813 2.724 6.537 6.537 343.227
BVY 08-077/Attachment 1 Program for Maintenance of Irradiated Fuel Page 7 of 8 Table 2 (continued)
Vermont Yankee Nuclear Power Station Decommissioning Funding Plan Scenario 5: 2012 Shutdown, Extended SAFSTOR Alternative, 2017 DOE Start Date (thousands of 2007 dollars)
Basis Year 2007 Fund Balance
$439.567 Annual Escalation 0.00%
Annual Earnings 2.00%
A B
C D
E.
F Total License Termination 50.75 50.54(bb) and Decommissioning License Spent Fuel Spent Fuel Total Cost Trust Fund Termination Management Management Escalated at Contributions Escalated at 2%
Cost Cost Cost 0%
to Trust Fund (minus expenses)
Year (millions)
(millions)
(millions)
(millions)
(millions)
(millions) 2032 3.823 2.576 6.399 6.399 343.693 2033 3.813 2.647 6.460 6.460 344.107.
2034 3.813 2.647 6.460 6.460 344.529 2035 3.813 2.801 6.614 6.614 344.805 2036 3.823 2.654 6.477 6.477 345.225 2037 3.813 2.724 6.537 6.537 345.592 2038 3.813 2.724 6.537 6.537 345.967 2039 3.813 2.724 6.537 6.537 346.349 2040 3.823 2.731 6.554 6.554 346.722 2041 3.813 2.647 6.460 6.460 347.197 2042 3.859 3.063 6.922 6.922 347.219 2043 3.812 3.812 3.812 350.351 2044 3.812 3.812 3.812 353.546 2045 3.812 3.812 3.812 356.805 2046 3.812 3.812 3.812 360.129 2047 3.812 3.812 3.812 363.520 2048 3.812 3.812 3.812 366.978 2049 3.812 3.812 3.812 370.505 2050 3.812 3.812 3.812 374.104 2051 2052 3.812 3.812 3.812 377.774 381.517 3.812 2053 3.812 2054 2055 2056 3.812 3.812 3.812 3.812
,3.812 3.812 3.812 3.812 3.812 3.812 3.812 3.812 385.335 389.230 393.203 397.255 3.812
BVY 08-077 /Attachmentl Program for Maintenance of Irradiated Fuel Page 8 of 8 Table 2 (continued)
Vermont Yankee Nuclear Power Station Decommissioning Funding Plan Scenario 5: 2012 Shutdown, Extended SAFSTOR Alternative, 2017 DOE Start Date (thousands of 2007 dollars)
Basis Year 2007 Fund Balance
$439.567 Annual Escalation 0.00%
Annual Earnings 2.00%
A B
C D
E F
Total License Termination 50.75 50.54(bb) and Decommissioning License Spent Fuel Spent Fuel Total Cost Trust Fund Termination Management Management Escalated at Contributions Escalated at 2%
Cost Cost Cost 0%
to Trust Fund (minus expenses)
Year
('millions)
(millions)
(millions)
(millions)
(millions)
(millions) 2057 3.812 3.812 3.812 401.388 2058 3.812 3.812 3.812 405.604 2059 3.812 3.812 3.812 409.904 2060 3.812 3.812 3.812 414.290 2061 3.812 3.812 3.812 418.764 2062 3.812 3.812 3.812 423.327 2063 3.812 3.812 3.812 427.981 2064 3.812 3.812 3.812
.432.729 2065 3.812 3.812 3.812 437.572 2066 3.812 3.812 3.812 442.511 2067 34.248 34.248 34.248 417.113 2068 106.707 106.707 106.707 318.749 2069 83.372 0.735 84.107 84.107 241.017 2070 2071 60.237 0.994 61.231 61.2 :31
+
60.237 0.994 61.231 61.231 184.606 127.067 89.647 S2072 39.211 0.750 If 39.961 39.961 1_.._.
656.118
. 219.034]
875.1521 875.152 r
- 6. 0.00 Calculations:
Column C = A + B Column D = (C)*(l+0%)A(current year - 2007) or for 0%, D = C Column E = Contributions to trust fund Column F = (Previous year's fund balance) * (1 +.02) - D (current year's decommissioning expenditures) +E (contributions)