ML083110918
| ML083110918 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 11/18/2008 |
| From: | Thomas Wengert Plant Licensing Branch III |
| To: | Wadley M Northern States Power Co |
| Wengert, Thomas NRR/DORL 415-4037 | |
| References | |
| TAC MD9492, TAC MD9493, TAC MD9494, TAC MD9495 | |
| Download: ML083110918 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 18, 2008 Mr. Michael D. Wadley Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION RELATED TO REVIEW OF IRRADIATED FUEL MANAGEMENT PLAN AND PRELIMINARY DECOMMISSIONING COST ESTIMATE (TAC NOS. MD9492, MD9493, MD9494, AND MD9495)
Dear Mr. Wadley:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 8,2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082260425), Nuclear Management Company, LLC, a predecessor license holder to the Northern States Power Company, a Minnesota Corporation, submitted a request for review and approval of the Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate for the Prairie Island Nuclear Generating Plant, Units 1 and 2.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on November 12, 2008, it was agreed that you would provide a response within 60 days of the date of this letter.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.
Sincerely,
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Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306
Enclosure:
Request for Additional Information cc w/encl: Distribution via ListServ
REQUEST FOR ADDITIONAL INFORMATION (RAI)
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 In reviewing the Nuclear Management Company, LLC" (the licensee), submittal dated August 8, 2008, which submitted the Irradiated Fuel Management Plan and the Preliminary Decommissioning Cost Estimate in accordance with Title 10 of the Code ofFederal Regulations (10 CFR), Part 50, Section 50.54(bb) and 10 CFR 50.75(f)(3) for the Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP), the U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following information is needed in order to complete its review:
Irradiated Fuel Management Plan RAI No.1: Enclosure 1,Section III, Funding for Spent Fuel Management Based on the DECON Decommissioning Option In Section III, the licensee stated that the Trust Funds are being supplemented with total annual contributions of approximately $15 million for Unit 1 and $19 million for Unit 2 based on a prescribed schedule per Minnesota Public Utility Commission direction and that these contributions will be used for radiological decommissioning and to pay for irradiated fuel management. The licensee's submittal entitled, "Decommissioning Funding Status" dated March 30, 2007, identified annual amounts to be collected for Unit 1 of approximately $14.8 million and a projected real rate of return of 1.79 percent for 6.8 years, and an annual amount of approximately $18.8 million and a projected real rate of return of 1.79 percent for 7.8 years for Unit 2. The March 30, 2007, submittal identified annual contributions that are consistent with the amount identified in the August 8, 2008, submittal; however, it is not clear to the NRC staff how much of these annual contributions, as well as the current trust balances, are to be allocated to support spent fuel management and site restoration, as compared to radiological decommissioning. Please clarify the allocation.
Prairie Island Nuclear Generating Plant Preliminary Decommissioning Cost Estimate RAI No.2: Enclosure 2,Section IV, Preliminary Cost Estimate Considerations In its submittal, the licensee stated that decommissioning "... includes continuation of spent fuel transfer from the spent fuel pool to the [Independent Spent Fuel Storage Installation (ISFSI)],
commencement of shipments of irradiated fuel from spent fuel pool to the ISFSI... " Has PINGP established separate funds/subaccounts to address their cost associated with spent fuel?
ENCLOSURE
- On September 22,2008, Nuclear Management Company, LLC (NMC), transferred its operating authority to Northern States Power Company, a Minnesota Corporation (NSPM). By letter dated September 3,2008, NSPM stated that it would assume responsibility for actions and commitments submitted by NMC.
- 2 Withdrawals from decommissioning trust funds under 10 CFR 50.82(a)(8)(i)(A) are limited to legitimate decommissioning activities consistent with the definition of decommissioning. For the scenario that was indentified in the submittal, the licensee did not acknowledge in the discussion whether separate subaccounts have been established for spent fuel management expenses. If separate accounts for non-radiological costs have not been established, the licensee must request 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. Please identify the source of funds to address the spent fuel costs.
RAI No.3: Enclosure 2,Section V, Plans for Adjusting Levels of Funding In Section V, the licensee stated that Xcel Energy applies "reasonable earnings rates" to the decommissioning funds throughout the decommissioning period, and that Xcel Energy believes there is reasonable assurance that adequate decommissioning funds will be available to decommission PINGP. Please identify the earnings rates that are applied to support this conclusion.
The NRC staff applied both PINGP's 1.79 percent real rate of return identified in the March 2007 submittal, and a 2 percent real rate of return on the current balance and the supplemental annual contributions for the designated periods, and subtracted the costs identified in Table 1 of, "Summary of Annual D&D, Irradiated Fuel, and Site Restoration Costs." Based on this review, the NRC staff's analysis did not support PINGP's conclusion. The staff could not reconcile the difference in their analysis compared to PINGP's analysis. Please provide supporting information and analysis to demonstrate that adequate commissioning funds will be available.
RAI No.4: Attachment 1 to Enclosures 1 and 2, Decommissioning Cost Analysis, Table 3.1 and Table 3.2 The last column in both Table 3.1 and Table 3.2 identifies the total annual expenses for each unit. However, the breakdown of the annual expenses is not identified. For example, in Table 3.1, for the period from 2019 to 2028, annual expenses of approximately $15 million per year are identified, but it is not clear how the $15 million per year is divided/allocated. Please provide a breakdown of the annual expenses identified in Tables 3.1 and 3.2 of Attachment 1.
Mr. Michael D. Wadley November 18, 2008 Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089 SUB"IECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION RELATED TO REVIEW OF IRRADIATED FUEL MANAGEMENT PLAN AND PRELIMINARY DECOMMISSIONING COST ESTIMATE (TAC NOS. MD9492, MD9493, MD9494, AND MD9495)
Dear Mr. Wadley:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 8, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082260425), Nuclear Management Company, LLC, a predecessor license holder to the Northern States Power Company, a Minnesota Corporation, submitted a request for review and approval of the Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate for the Prairie Island Nuclear Generating Plant, Units 1 and 2.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on November 12, 2008, it was agreed that you would provide a response within 60 days of the date of this letter.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.
Sincerely, lRAI Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306
Enclosure:
Request for Additional Information cc w/encl: Distribution via ListServ DISTRIBUTION:
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