L-PI-09-008, Supplement to Irradiated Fuel Management Plan and Preliminary/ Decommissioning Cost Estimates for Prairie Island Nuclear Generations Plant (PINGP)
| ML090210156 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 01/19/2009 |
| From: | Wadley M Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-PI-09-008, TAC MD9492, TAC MD9493, TAC MD9494, TAC MD9495 | |
| Download: ML090210156 (25) | |
Text
' @ @ Xcel Energy' JAN 1 9 2009 L-PI-09-008 10 CFR 50.54 10 CFR 50.75 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie lsland Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Supplement to lrradiated Fuel Management Plan and Preliminan/ Decommissioninq Cost Estimates for Prairie lsland Nuclear Generatins Plant (PINGP) (TAC Nos.
MD9492, MD9493, MD9494, AND MD9495)
References:
- 1. Nuclear Management Company, LLC (NMC) letter to US Nuclear Regulatory Commission (NRC), "lrradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for Prairie lsland Nuclear Generating Plant (PINGP)", dated August 8, 2008, Accession Number ML082260425.
- 2. NRC letter to Northern States Power Company - Minnesota, "Prairie lsland Nuclear Generating Plant, Units 1 and 2 - Request for Additional Information Related to Review of lrradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate (TAC Nos. MD9492, MD9493, MD9494, and MD9495)", dated November 18, 2008, Accession Number ML083110918.
In Reference 1, NMC* submitted the PINGP lrradiated Fuel Management Plan for NRC review and preliminary approval and the PINGP Preliminary Decommissioning Cost Estimate for NRC review and approval. To support the review of Reference 1, the NRC Staff requested additional information in Reference 2 which is provided in the Enclosure to this letter.
- On September 22, 2008, NMC transferred its operating authority to Northern States Power Company, a Minnesota Corporation (NSPM), a wholly owned subsidiary of Xcel Energy. By letter dated September 3, 2008, NSPM assumed responsibility for actions and commitments previously submitted by NMC.
171 7 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1 121
Document Control Desk Page 2 If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1 121.
Summaw of Commitments This letter contains no new commitments and no revisions to existing commitments fi&d.~+
Michael D. Wadley Site Vice president, Prairie laand Nuclear Generating Plant Units 1 and 2 Northern States Power Company - Minnesota Enclosures (1) cc:
Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC
ENCLOSURE Response to Requests for Additional Information (RAls)
Page 1 of 10
Irradiated Fuel Manaqement Plan RAI No. 1 : Enclosure 1, Section Ill, Funding for Spent Fuel Management Based on the DECON Decommissioning Option In Section Ill, the license 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.
Northern States Power Company, Minnesota (NSPM) Response:
The following is a breakdown of the annual contributions for Units 1 and 2 broken down into the components: radiological decommissioning, spent fuel management, and site restoration.
Annual Contributions Unit 1 Radiological Decommissioning 11,254,252 76.1 %
Spent Fuel Management 2,262,688 15.3%
Site Restoration 1,279,421 8.6%
Total 14,796,361 100.0%
Unit 2 Radiological Decommissioning 12,655,613 67.1%
Spent Fuel Management 4,218,637 22.4%
Site Restoration 1,972,830 10.5%
Total 18,847,080 100.0%
Total Prairie Island 33,643,440 The following is a breakdown of the trust fund balances for Units 1 and 2 broken down into the components: radiological decommissioning, spent fuel management, and site restoration.
Page 2 of 10
Trust Fund Balances Unit 1 Radiological Decommissioning 370,245,731 92%
Spent Fuel Management 24,146,461 6%
Site Restoration 8,048,820 2%
Total 402,441,012 100%
Unit 2 Radiological Decommissioning 387,142,204 90%
Spent Fuel Management 30,111,060 7%
Site Restoration 12,904,740 3%
Total 430.1 58.004 100%
Total Prairie Island The following is a breakdown of the TLG Services, Inc. cost estimate for Units 1 and 2 broken down into the components: radiological decommissioning, spent fuel management, and site restoration.
2008 TLG Services, Inc. Cost Estimate Unit 1 Radiological Decommissioning Spent Fuel Management Site Restoration Total Unit 2 Radiological Decommissioning Spent Fuel Management Site Restoration Total Total Prairie Island
Prairie Island Nuclear Generating Plant Preliminary Decommissioninn 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 PlNGP established separate funds/subaccounts to address their cost associated with spent fuel?
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 identified 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.
NSPM Response:
Currently each trust fund has a separate subaccount for each rate jurisdiction. Further separation of the jurisdictional subaccounts will be established in January 2009 for radiological decommissioning, spent fuel management, and site restoration. Thus, there will be 18 subaccounts for each nuclear unit. A schematic of the subaccount structure is shown below.
As explained in section 1.3.1 of the 2008 Prairie Island Nuclear Generating Plant Decommissioning Cost Estimate the funding requirement for management of irradiated fuel is fulfilled through inclusion of certain cost elements in the decommissioning cost estimate, associated with the isolation and continued operation of the spent fuel pool and ISFSI.
Page 4 of 10
Trust Fund Balances
/n=ota~etail
/
Radiological Decommissioning 1 North Dakota Retail Spent Fuel Management Site Restoration Radiological Decommissioning Spent Fuel Management Site Restoration South Dakota Retail Spent Fuel Management Site Restoration Radiological Decommissioning Spent Fuel Management r
C, I Minnesota Wholesale (
Radiological Decommissioning (
I 1
Spent Fuel Management 1
Wisconsin Retail Site Restoration Radiological Decommissioning 1
I Spent Fuel Management I
Wisconsin Wholesale Site Restoration Radiological Decommissioning Spent Fuel Management Site Restoration Minnesota Retail Spent Fuel Management Site Restoration Radiological Decommissioning Wisconsin Retail Minnesota Wholesale Spent Fuel Management Site Restoration Radiological Decommissioning Spent Fuel Management Site Restoration Radiological Decommissioning Spent Fuel Management Site Restoration Wisconsin Wholesale Page 5 of 10 Spent Fuel Management Site Restoration Radiological Decommissioning
Prairie Island Nuclear Generating Plant Preliminarv Decommissioninrr Cost Estimate 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 Enclosure 2, "Summary of Annual D&D, Irradiated Fuel, and Site Restoration Costs." Based on this review, the NRC staffs 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.
NSPM Response:
The "Site D&Dn column in Table 1 of Enclosure 2, also referred to as radiological decommissioning costs, is the total of both Prairie Island units. The table below shows the units individually as well as the total. The analysis of sufficiency of funds is done by individual unit.
Prairie Island Unit Costs Unit 1 Unit 2 Total Site Page 6 of 10
Unit 1 Unit 2 Total Site The tables below demonstrate that the 1.79 percent real rate of return applied to the current balance reconcile when the annual contributions are added and the annual costs are subtracted. The balance is more than adequate to cover the costs of radiological decommissioning.
Prairie Island Unit 1 Beginning Balance Payment Annuity 11,254,252 11,254,252 11,254,252 11,254,252 9,003,401 Balance Before lnterest 381,499,983 399,583,084 41 7,989,873 436,726,144 430,582,943 364,746,378 265,368,338 200,455,431 157,238,584 140,688,154 133,496,472 126,150,059 11 8,698,145 111,112,842 103,391,762 95,506,474 87,506,040 79,362,398 71,072,985 62,609.1 92 50,567,896 27,663,062 23,213,230 23,544,747 23,917,198 24,345,316 24,781,097 25,224,679 25,676,200 26,135,804 26,603,635 27,079,840 27,564,570 28,057,975 28,560,213 29,071,441 29,591,820 30,121,513 30,660,688 31,209,515 31,768,165 32,336,815 32,915,644 33,504,834 23,590,571 24,012,842 Assumed lnterest 6,828,850 7,152,537 7,482,019 7,817,398 7,707,435 6,528,960 4,750,093 3,588,152 2,814,571 2,518,318 2,389,587 2,258,086 2,124,697 1,988,920 1,850,713 1,709,566 1,566,358 1,420,587 1,272,206 1,120,705 905,165 495,169 415,517 421,451 428,118 435,781 443,582 451,522 459,604 467,831 476,205 484,729 493,406 502,238 51 1,228 520,379 529,694 539,175 548,826 558,650 568,650 578,829 589,190 599,737 422,271 429,830 Ending Balance 388,328,832 406,735,621 425,471,892 444,543,542 438,290,378 371,275,338 270,118,431 204,043,584 160,053,154 143,206.472 135,886,059 128,408,145 120,822,842 113,101,762 105,242,474 97,216,040 89,072,398 80,782,985 72,345,192 63,729,896 51,473,062 28,158,230 23,628,747 23,966,198 24,345,316 24,781,097 25,224,679 25,676,200 26,135,804 26,603,635 27,079,840 27,564,570 28,057,975 28,560,213 29,071,441 29,591,820 30,121,513 30,660,688 31,209,515 31,768,165 32,336,815 32,915,644 33,504,834 34,104,571 24,012,842 24,442,672 Page 8 of 10
Prairie Island Unit 2 Beginning Balance 387,142,204 406,954,198 427,120,827 447,648,438 468,543,493 489,812,570 499,332,942 449,214,480 355,421,649 267,265,574 201,730,042 161,023,680 154,010,998 146,900,272 139,662,264 132,294,696 124,767,766 1 17,133,586 109,362,754 101,452,825 93,373,825 78,471,769 37,753,675 28,760,434 29,238,601 29,740,597 30,272,953 30,814,839 31,366,425 31,927,884 32,499,393 33,081,132 33,673,284 34,276,036 34,889,577 35,514,100 36,149,803 36,796,884 37,455,549 38,126,003 38,808,458 39,503,130 40,210,236 40,929,999 41,662,646 31,706,207 Payment Annuity 12,655,613 12,655,613 12,655,613 12,655,613 12,655,613 10,124,490 Balance Before Interest 399,797,817 419,609,811 439,776,439 460,304,051 481,199,106 490,552,060 441,314,942 349,171,480 262,565,649 198,182,574 158,192,042 151,302,680 144,316,998 137,206,272 129,968,264 122,573,696 11 5,073,766 107,439,586 99,668,754 91,731,825 77,091,825 37,089,769 28,254,675 28,724,434 29,217,601 29,740,597 30,272,953 30,814,839 31,366,425 31,927,884 32,499,393 33,081,132 33,673,284 34,276,036 34,889,577 35,514,100 36,149,803 36,796,884 37,455,549 38,126,003 38,808,458 39,503,130 40,210,236 40,929,999 31,148,646 31,706,207 Assumed Interest 7,156,381 7,511,016 7,871,998 8,239,443 8,613,464 8,780,882 7,899,537 6,250,169 4,699,925 3,547,468 2,831,638 2,708,318 2,583,274 2,455,992 2,326,432 2,194,069 2,059,820 1,923,169 1,784,071 1,642,000 1,379,944 663,907 505,759 514,167 522,995 532,357 541,886 551,586 561,459 571,509 581,739 592,152 602,752 613,541 624,523 635,702 647,081 658,664 670,454 682,455 694,671 707,106 719,763 732,647 557,561 567,541 Ending Balance 406,954,198 427,120,827 447,648,438 468,543,493 489,812,570 499,332,942 449,214,480 355,421,649 267,265,574 201,730,042 161,023,680 154,010,998 146,900,272 139,662,264 132,294,696 124,767,766 117,133,586 109,362,754 101,452,825 93,373,825 78,471,769 37,753,675 28,760,434 29,238,601 29,740,597 30,272,953 30,814,839 31,366,425 31,927,884 32,499,393 33,081,132 33,673,284 34,276,036 34,889,577 35,514,100 36,149,803 36,796,884 37,455,549 38,126,003 38,808,458 39,503,130 40,210,236 40,929,999 41,662,646 31,706,207 32,273,748
Prairie Island Nuclear Generatinn Plant Preliminary Decommissioninn Cost Estimate 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 indentifies 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 dividedlallocated. Please provide a breakdown of the annual expenses identified in Tables 3.1 and 3.2 of Attachment 1.
NSPM Response:
The breakdown of Tables 3.1 and 3.2 is provided in Attachment 1 to Enclosures 1 and 2, Tables 3.1 a through c and Tables 3.2 a through c, with Tables 3.la and 3.2a providing radiological decommissioning costs, Tables 3.1 b and 3.2b providing spent fuel management costs, and Tables 3.1 c and 3. 2 ~
providing site restoration costs. The cost elements for each column of Tables 3.1 and 3.2 are the sum of the cost elements for that column and year from the corresponding Tables 3.1 a through c or Tables 3.2 a through c which are provided as Attachment 1 to this Enclosure for ease of reference.
Page 10 of 10 Enclosure Selected Pages from Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant August 2008 by TLG Services, Inc.
12 pages follow
Prairie Island Nuclear Generating Plant Decommisswninp Cost AnabsB DocumentXOl-IS86-002, Rev. 0 Section 3, Page 21 of 34 TABLE 3.la PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generating Plant Deco~sssioning Cost An*&
Document XOl-1586002, Rev. 0 Seetion 3, Page 22 of 34 TABLE 3.la (continued)
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generaling Plant Dccommisswning Cost Adysis Document XO-158002 Rev. 0 S&n 3, Page 23 of 34 TABLE 3.lb PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial 0th~~
Total Note: Columns may not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generating Plant Decomnrisswning Cost Analysis Document XOI-1586-002, Rev. 0 Section 3, Page 24 of 34 TABLE 3.1 b (continued)
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipinent &
Year Labor Materials Energy Burial Other Total Note: Colu~nns may not add due to rounding TLG Services, Inc.
Prase Island Nuclear Generating Plant Decommissioning Cosl AnaIysD Document XOI-1586-002, Rev. 0 Section 3, Page 25 of 34 TABLE 3. 1 ~
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prain'e Island Nuclear Generating Plant Dccommksioning Cast Analysis Document XOI-1586-002, Rev. 0 Section 3, Page 26 of 34 TABLE 3.lc (continued)
PRAIRlE ISLAND NUCLEAR GEIWRATLNG PLANT, UNIT 1 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns inay not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generalirg Plant DecommDsioning Cost Analysis Doczrment XOI-1586-002, Rev. 0 Secdbn 3, Page 29 of 34 TABLE 3.2a PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generating Plant Deco~nmkswning Cost Analysk Document XOI-1586-002, Rev. 0 Section 3, Page 30 of 34 TABLE 3.2a (continued)
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Colu~ms may not add due to rounding TLG $ervices, Inc.
Prairie Island Nuclear Generating Plant Decommisswning Cost An@&
Document XOZ-1586-002, Rev. 0 Section 3, Page 31 of 34 TABLE 3.2b PRAIRIE ISLAND NUCLEAR GENEFWTING PLANT, UNIT 2 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prnide Island Naclear Generating Plant Decommissioning Cost Analysis Document XOl-1586-002, Rev. 0 Section 3, Page 32 of 34 TABLE 3.2b (continued)
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generating Phnt Decommisswning Cost Analysis DocumentX01-1586-002, Rev. 0 Section 3, Page 33 of 34 TABLE 3.2~
PRAIRIE ISLAND NUCLEAR GENEFUTLNG PLANT, UNIT 2 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.
Prairie Island Nuclear Generating Plant Decommissioniitg Cost Andpis Document XOI-1586-002, Rev. 0 Section 3, Page 34 of34 TABLE 3.2~
(continued)
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total Note: Columns may not add due to rounding TLG Services, Inc.