BVY 09-022, Update to Spent Fuel Management Plan
| ML091040287 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 04/01/2009 |
| From: | Michael Colomb Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 09-022, TAC MD8035, TAC MD8051 | |
| Download: ML091040287 (8) | |
Text
Entergy Nuclear Operations, Inc.
Vermont Yankee P.O. Box 0250 Entergy 320 Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 April 1, 2009 BVY 09-022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
References:
.(1) Letter, USNRC to Entergy, ."Safety Evaluation - Spent Fuel Management Program .and Preliminary Decommissioning Cost Estimate (TAC No.s MD8035 and .MD8051), NVY 09-009, dated February 3, 2009.
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Update to Vermont Yankee Spent Fuel Management Plan
Dear Sir or Madam,
In Reference (1), NRC staff completed a review of previous submittals and provided preliminary approval of Entergy Vermont Yankee's (VY) spent fuel management program in accordance with 10CFR50.54(bb). NRC staff requested in Reference (1) that revised spent fuel management plan funding information be submitted should there be a material decline in the fund balance.
Without making a determination whether there has been any material decline in the fund balance, Attachment 1 to this letter provides VY's revised information to the staff's request contained in Reference (1).
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, Michael J. tplbmb Site Vice President Vermont Yankee Nuclear Power Station (6 pages) A-0oo
BVY 09-022 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 09-022 Attachment 1 Vermont Yankee Nuclear Power Station Revised Spent Fuel Management Plan Information - 10CFR50.54(bb)
Vermont Yankee Nuclear Power Station Updated Program for Maintenance of Irradiated Fuel Background and Introduction On March 21, 2007, Entergy Vermont Yankee (VY) submitted a "Report Pursuant to 10 CFR 50.54(bb)," (Accession No. ML070860696), and on February 6, 2008, a "Report Pursuant to 10 CFR 50.75(f)(3)," (Accession No. ML080430658), related to the Vermont Yankee Nuclear Power Station. In response to a NRC staff request for additional information, on April 24, 2008, VY submitted a "Response to Request for Additional Information," (Accession No. ML081200753), and on October 14, 2008, a "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)", (Accession No. ML082910294).
On February 3, 2009, the NRC staff approved VY's program for the long-term storage of spent fuel and found that the preliminary decommissioning cost estimate to be reasonable. In its approval letter, the staff stated an expectation that VY would update the financial aspects of its spent fuel management program if there were a material decline in the decommissioning trust fund balance.
Without making any determination of whether any trust fund balance decline is considered material or not, VY is submitting this update to the October 14, 2008 submittal. The program outlined in this submittal is viewed by VY as a tool to estimate costs, but is not intended to reflect details of the actual implementation. For example, depending on Department of Energy's (DOE) actual performance under its spent fuel disposal contracts, VY may not have to build the ISFSI discussed herein.
Changes in the Base Estimate The decommissioning cost reported in the October 14, 2008 submittal was $875.152 million (expressed in 2007 dollars). The radiological portion of the cost was approximately $656.118 million and the spent fuel management portion $219.034 million. Spent fuel management costs were based upon the premise that the DOE would begin receiving spent fuel from commercial reactors in 2017.
The decommissioning cost presented in this submittal is $909.66 million (expressed in 2008 dollars). The radiological portion of the cost is approximately $674.33 million and the spent fuel management portion $235.33 million. The increase is due to 1) a revision to the assumed DOE start date for receiving spent fuel and 2) a one year escalation of the cost basis (from 2007 to 2008).
The current estimate assumes a three-year slip in the start of DOE acceptance (from 2017 to 2020). The 2020 date is based upon statements made by Edward F. Sproat III, former Director of the DOE's Office of Civilian Radioactive Waste Management (OCRWM) in
testimony to Congress in 2008 and by the OCRWM's "Project Decision Schedule" (DOE/RW-0604) released in January 2009.
This change resulted in a corresponding three year slip in the final year of acceptance of the VY fuel (from 2042 to 2045).
No other changes were made to the decommissioning scenario or assumptions described in the October 14, 2008 submittal.
Financial Assurance The decommissioning trust fund balance for VY was reported at $372.01 million as of December 31, 2008.
The following table provides a schedule of estimated expenditures for license termination and spent fuel management costs in 2008 dollars. The source for this information is the latest decommissioning estimate, escalated to 2008 dollars. Costs are included for the design and construction of the Independent Spent Fuel Storage Installation (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 was escalated at 2% per year.
VY fully expects to recover the cost for spent fuel management from the DOE.['] As such, cost reimbursements are included as income and on a three-year offset from the spent fuel management expenditures (i.e., compensation would be received approximately three years after the expense was incurred).
In an order in Docket 03-2663C, the U.S. Court of Federal Claims has entered judgment in favor of VY and against DOE for DOE's failure to accept spent fuel pursuant to VY Station's Standard Contract. With liability established, VY is now in a position to pursue damages as they are incurred. VY will continue its suits against DOE for spent fuel storage damages as they accrue, including through the decommissioning period. VY fully expects that DOE will pay VY damages for storage of SNF at the VY Station until DOE takes title to the station's SNF. As such, and allowing for some delay from the time when VY incurs spent fuel storage costs until DOE pays the company's claims, VY does not expect to have to use significant, additional decommissioning-trust funds to pay for SNF storage. This analysis reflects that assumption.
Vermont Yankee Nuclear Power Station Decommissioning Funding Plan Scenario 5: 2012 Shutdown, Extended SAFSTOR Alternative, 2020 DOE Start Date Basis Year 2008 Fund Balance $372.01 million Annual Escalation 0.00% -1 Annual Earnings 2.00% +
4 4 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 DOE Escalated at 2%
Cost Cost Cost 0% Reimbursement (minus expenses)
Year (millions) (millions) (millions) (millions) . (millions) (millions) 2008 372.012 2009 379.452 2010 387.041 2011 394.782 2012 32.682 13.607 46.289 46.289 356.389 2013 40.282 27.400 67.682 67.682 295.835 2014 3.935 29.322 33.257 33.257 268.494 2015 3.935 29.322 33.257 33.257 13.607 25,4.214 2016 3.946 29.402 33.348 33.348 27.400 253.350 2017 3.935 23.217 27.152 27.152 29.322 260.587 2018 3.933 2.553 6.486 6.486 29.322 288.635 2019 3.933 2.553 6.486 6.486 29.402 317.324 2020 3.943 6.310 10.253 10.253 23.217 336.634 2021 3.933 2.943 6.876 6.876 2.553 339.044 2022 3.933 2.553 6.486 6.486 2.553 341.892 2023 3.933 2.787 6.720 6.720 6.310 348.320 2024 3.943 2.872 6.815 6.815 2.943 351.414 2025 3.933 2.865 6.798 6.798 2.553 354.198 2026 3.933 2.787 6.720 6.720 2.787 357.348 2027 3.933 2.709 6.642 6.642 2.872 360.725 2028 3.943 2.716 6.659 6.659 2.865 364.146 2029 3.933 2.709 6.642 6.642 2.787 367.574 2030 3.933 2.709 6.642 6.642 2.709 370.992 2031 3.933 4 2.709 +
6.642 4 6.642 2.716 374.486 2032 3.943 2.638 6.581 6.581 2.709 378.104 2033 3.933 2.709 6.642 6.642 2.709 381.733 2034 3.933 2.709 6.642 6.642 2.709 385.435 2035 3.933 2.553 6.486 6.486 2.638 389.295
Vermont Yankee Nuclear Power Station Decommissioning Funding Plan Scenario 5: 2012 Shutdown, Extended SAFSTOR Alternative, 2020 DOE Start Date Basis Year 2008 Fund Balance $372.01 million Annual Escalation 0.00%
Annual Earnings 2.00%
I- 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 T'ermination Management Management Escalated at DOE Escalated at 2%
Cost Cost Cost 0%. Reimbursement (minus expenses)
Year (millions) (millions) (millions) (millions) (millions) (millions) 2036 3.943 2.638 6.581 6.581 2.709 393.209 2037 3'933 2.631 ,6.564 6.564 2.709 397.218 2038 3.933 2.787 6.720 6.720 2.553 400.996 2039 3.933 2.631 .6.564 6.5,64 2.638 405.090 2040 3.943 .2.716 6.659 6.659 2.631 409.164 2041 3.933 2.709 6.642 6.642 2.787 413.492 2042 3.933 2.709 6.642 6.642 2.631 417.751 2043 3.933 2.709 6.642 6.642 2.716 422.180 2044 3.943 2.638 6.581 6.581 2.709 426.751 2045 3.933 2.936 6.869 6.869' 2.709 *431.126 2046 3.931 3.931 3.931 ______ 2.709
- 438.527 2047 3.931 3.931 3.931 2.638 446.004 2048 3.942 3.942 3.942 2.936 453.918 2049 3.931 3.931 3.931 .459.066 2050 3.931 3.931 3.931 464.316 2051 3.931 3.931 3.931 469.671 2052 3.942 3.942 3.942 475.123 2053 3.931 3.931 3.931 480.694 2054 3.931 .3.931 3.931 486.377 2055 3.931 3.93 1 3.931 2056 3.942 3.942 3.942 498.075 2057 3.931 3.931 3.931 504.106 2058 3.931 3.931 3.931 510.257 2059 3.931 3.931 3.931 516.531 2060 3.942 3.942 3.942 522.920 2061 3.931 3.93 1 3.931 3.931 529.447 2062 .......... 3.931
- 3.931 3.931 536.1l05 2063 3.93 1 3.931 542.896
Vermont Yankee Nuclear Power Station Decommissioning Funding Plan Scenario 5: 2012 Shutdown, Extended SAFSTOR Alternative, 2020 DOE Start Date Basis Year 2008 Fund Balance $372.01 million 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 DOE Escalated at 2%
Cost Cost Cost 0% Reimbursement (minus expenses)
Year (millions) (millions) (millions) (millions) (millions) (millions) 2064 3.942 3.942 3.942 549.812 2065 3.931 3.931 3.931 556.877 2066 27.779 27.779 27.779 540.236 2067 81.017 81.017 81.017 - 470.023 2068 108.329 0.512 108.841 108.841 - 370.583 2069 62.090 1.026 63.116 63.116 - 314.879 2070 62.090 1.026 63.116 63.116 - 258.060 2071 47.745 0.492 48.237 48.237 0.512 215.496 2072 7.634 0.272 7.906 7.906 1.026 212.926 2073 0.060 0.249 0.309 0.309 1.026 217.902 2074 0.492 222.752 2075 0.272 227.479 2076 .... _0.249 232.277 674.328 235.335 909.663 909.663 235.335 Calculations:
Column C =A+B Column D = (C)*(I +0%)A(current year - 2008) or for 0%, D = C Column E = Contributions to trust fund from the DOE Column F = (Previous year's fund balance) * (I + .02) - D (current year's decommissioning expenditures) + E (contributions)