NLS2009053, Response to Nuclear Regulatory Commission Request for Additional Information Decommissioning Cost Analysis and Program for Maintenance of Irradiated Fuel
| ML092050203 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/20/2009 |
| From: | Vanderkamp D Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2009053, TAC ME1264, TAC ME1269 | |
| Download: ML092050203 (12) | |
Text
Nebraska Public Power District "Always there when you need us" NLS2009053 July 20, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Nuclear Regulatory-Commission Request for Additional Information Re: Decommissioning Cost Analysis and Program for Maintenance of Irradiated Fuel (TAC Nos.. ME1264 and ME1269)
Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1.
Letter from Carl F. Lyon, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated June 12, 2009, "Cooper Nuclear Station - Request for Additional Information Re:
Decommissioning Cost Analysis and Program for Maintenance of Irradiated Fuel (TAC Nos. ME1264 and ME1!269)"
- 2.
Letter from David W. Van Der Kamp, Nebraska Public Power District, to the U.S. Nuclear Regulatory Commission, dated December 23, 2008, "Program for Maintenance of Irradiated Fuel"
- 3.
Letter from David W. Van Der Kamp, Nebraska Public Power District, to the U.S. Nuclear Regulatory Commission, dated December 15, 2008, "Decommissioning Cost Analysis"
Dear Sir or Madam:
The purpose of this letter is for Nebraska Public Power District to submit a response to requests for additional information (RAI) from the Nuclear Regulatory Commission (NRC) (Reference 1). The RAI requested information in support of the NRC's review of the Program for Maintenance of Irradiated Fuel (Reference 2) and the Decommissioning Cost Analysis (Reference 3).
Responses to the specific RAI questions are provided in the Attachment. There are no regulatory commitments made in this submittal.
COOPER NUCLEAR STATION
.00 P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 wwwnppd.com
NLS2009053 Page 2 of 2 Should you have any questions concerning this matter, please contact me at (402) 825-2904.
Sincerely, David W. Van Der Kamp Licensing Manager
/jo Attachment Enclosure cc:
Regional Administrator w/ attachment and enclosure USNRC - Region IV Cooper Project Manager w/ attachment and enclosure USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachment and enclosure USNRC - CNS NPG Distribution w/o attachment and enclosure CNS Records w/ attachment and enclosure
NLS2009053 Attachment Page 1 of 6 Attachment Response to Nuclear Regulatory Commission Request for Additional Information Re:
Decommissioning Cost Analysis and Program for Maintenance of Irradiated Fuel (TAC Nos. ME1264 and ME1269)
Cooper Nuclear Station, Docket No. 50-298, DPR-46 Program for Maintenance of Irradiated Fuel RAI No. 1: Financial Assurance In order for a licensee to assume an earnings credit on its decommissioning funds over a SAFSTOR (safe-storage) period that is greater than a 2 percent real rate of return, the licensee must be able to recover total decommissioning costs through rates set by itself or a regulatory authority. Such rates must be subject to upward adjustments during the SAFSTOR period following the permanent shutdown of the plant involved if the actual rate of growth of the decommissioning funds does not meet or exceed the assumed or approved higher-than percent-real-earnings rate. Please provide a statement and supporting references or documents that indicate the NPPD will be able to receive upward adjustments from ratepayers to its decommissioning funds, if necessary, following permanent shutdown.
Response
Nebraska Public Power District (NPPD) is a public corporation and political subdivision of the State of Nebraska. Control of NPPD and its operations is vested in a Board of Directors consisting of 11 members popularly elected from districts comprising subdivisions of NPPD's chartered territory. The subdivisions encompass 86 of the State's 93 counties and all of five other counties except for one first class city not served directly or indirectly by NPPD in each of these five counties.
NPPD has the power and is required to fix, establish, and collect adequate rates and other charges for electrical energy and any and all commodities or services furnished by it. Such rates and charges must be fair, reasonable, and nondiscriminatory and adjusted in a fair and equitable manner to confer upon and distribute among the users and consumers of such commodities and services the benefits of a successful and profitable operation.
A resolution of the NPPD (No. 08-70) adopted on June 13, 2008, confirms the District's commitment to collect sufficient funds to meet the minimum requirements of the Nuclear Regulatory Commission and to provide funding for other decommissioning-related costs including, but not limited to, provisions for restoration of the Cooper Nuclear Station (CNS) site and provisions for interim storage of spent nuclear fuel. (emphasis added)
NLS2009053 Attachment Page 2 of 6 The Board of Directors approved the decommissioning plan recommended by management and affirmed that such funding plan assumptions were reasonable and appropriate for decommissioning funding planning for CNS through January 18, 2014, and beyond. The Resolution further resolves that management will periodically review and update the assumptions, costs, and methods of funding decommissioning as a result of changing conditions and requirements, and recommend appropriate changes in funding plans to the Board of Directors.
A copy of the Resolution is provided as an enclosure to this response.
RAI No. 2: Table 5, Cooper Nuclear Station, Scenario 3 The staff requests that NPPD provide a breakdown of the estimated $3.8 million annual cost and supporting activities to support spent fuel management for CNS for the period 2020 - 2046 identified in Table 5.
Response
The details are available in the "Decommissioning Cost Analysis," specifically in Table C-3 in Appendix C.
The $3.8 million annual cost occurs in "Period 2b - SAFSTOR Dormancy with Dry Spent Fuel Storage," which runs from July 2019 to December 2046 or approximately 27.5 years. The activities reported in this period relating to spent fuel management are as follows (extracted from Table C-3):
$ thousands Activity Designation and Description (2008 dollars)
Period 2b Collateral Costs 2b.3.1 Spent Fuel Capital and Transfer 20,806 Period 2b Period-Dependent Costs 2b.4.1 Insurance 491 2b.4.7 Emergency Planning Fees 25,477 2b.4.8 ISFSI Operating Costs 2,682 2b.4.9 Security Staff Cost 27,131 2b.4.10 Utility Staff Cost 28,634 Total Period 2b Spent Fuel 2b.0 Management Cost 105,222 Duration 27.46 years Annual Cost (average) 3,833
NLS2009053 Attachment Page 3 of 6 Line 2b.3.1 ($20.806 million) addresses the cost to load and transfer 24 casks from the General Electric storage pool at Morris, Illinois, to the Department of Energy (DOE) and to transfer 50 storage canisters in storage on the CNS Independent Spent Fuel Storage Installation (ISFSI) pad to the DOE over the 27.5 year period. The "Period 2b Period Dependent Costs" are associated with CNS site operations over that same period.
RAINo. 3: Section 3. Cost Considerations This submittal indicated that CNS has an existing independent spent fuel storage installation (ISFSI) with sufficient capacity to accommodate the spent fuel remaining in the reactor building pool at shutdown. What is storage capacity of the ISFSJ? At the time of shutdown, how many modules will be stored on the ISFSI? The submittal indicated that NPPD estimates that an additional 34 multipurpose canisters will be loaded with fuelfrom the pool at time of shutdown.
Does this include the last core that will be removed when the plant is shutdown?
Response
The construction of the CNS ISFSI pad is nearing completion. It is designed to accommodate 52 Transnuclear casks. The current plan is to load eight casks in the spring of 2010 and then another eight casks in 2012. As such, in the event that the plant ceases operation on January 18, 2014, there will be 16 loaded casks on the pad. An additional 34 casks will be needed to offload the spent fuel residing in the reactor building's storage pool, including the assemblies from the last core.
Decommissioning Cost Analysis RAI No 4: Section 2. Decommissioning Alternatives In the submittal, NPPD identified six possible decommissioning scenarios for CNS, and provided the annual costs associated with each option. However, NPPD did not provide an analysis using the decommissioning funds to demonstrate adequate funds are available to address these options. Please provide the supporting analysis for each of the identified alternatives or, at a minimum, for the selected option.
Response
As described in the "Program for Maintenance of Irradiated Fuel," NPPD has identified Scenario 3 as its basis for financial planning, in the event that the plant was to cease operations on January 18, 2014. In this scenario, the nuclear unit is placed into safe-storage at the expiration of its current operating license. Decommissioning would be deferred such that termination of the license would occur within the required sixty-year period.
NLS2009053 Attachment Page 4 of 6 Decommissioning costs for this scenario are allocated into the three major categories of license termination, spent fuel management, and site restoration. The cost for radiological remediation (to the extent needed to terminate the operating license) is identified as $674.964 million in the "Decommissioning Cost Analysis" (in 2008 nominal dollars).
The decommissioning funding plan is shown in following table. It uses a 2.5% real growth, as authorized by the District's Board of Directors, in the trust fund over time to demonstrate that the identified scenario is financially viable (i.e., that a surplus is shown in the fund at the completion of decommissioning).
Basis Year 2008 Beginning Fund Balance
$403.437 (end of 2007)
Annual Escalation 0.00%
Annual Earnings 2.50%
A B
C Decommissioning 50.75 Total Cost Trust Fund License Escalated Escalated at 2.5%
Termination at 0%
(minus expenses)
Year Cost (millions)
(millions)
(millions) 2007 403.437 2008'
-413.523 2009 423.861 2010 434.458 2011 445.319 2012 456.452 2013 467.863 2014 43.626 43.626 435.934 2015 50.453 50.453 396.379 2016 5.399 5.399 400.889 2017 5.385 5.385 405.526 2018 5.385 5.385 410.279 2019 4.830 4.830 415.706 2020 4.185 4.185 421.914 2021 4.174 4.174 428.288 2022 4.174 4.174 434.821 2023 4.174 4.174 441.518 2024 4.185 4.185 448.371 2025 4.174 4.174 455.406 1
As noted in NPPD's Biennial Decommissioning Funding Status Report, dated March 24, 2009, the actual fund balance at the end of calendar year 2008 was $425,910,483. Thus, this calculation is a conservative analysis of decommissioning funding.
NLQ-200905 3 Attachment Page 5 of 6 2026 4.174 4.174 462.617 2027 4.174 4.174 470.008 2028 4.185 4.185 477.573 2029 4.174 4.174 485.338 2030 4.174 4.174 493.297 2031 4.174 4.174 501.455 2032 4.185 4.185 509.806 2033 4.174 4.174 518.377 2034 4.174 4.174 527.162 2035 4.174 4.174 536.167 2036 4.185 4.185 545.386 2037 4.174 4.174 554.847 2038 4.174 4.174 564.544 2039 4.174 4.174 574.484 2040 4.185 4.185 584.661 2041 4.174 4.174 595.104 2042 4.174 4.174 605.808 2043 4.174 4.174 616.779 2044 4.185 4.185 628.013 2045 4.174 4.174 639.539 2046 4.173 4.173 651.354 2047 4.146 4.146 663.492 2048 4.157 4.157 675.922 2049 4.146 4.146 688.674 2050 4.146 4.146 701.745 2051 4.146 4.146 715.143 2052 4.157 4.157 728.865 2053 4.146 4.146 742.941 2054 4.146 4.146 757.369 2055 4.146 4.146 772.157 2056 4.157 4.157 787.304 2057 4.146 4.146 802.841 2058 4.146 4.146 818.766 2059 4.146 4.146 835.089 2060 4.157 4.157 851.809 2061 4.146 4.146 868.958 2062 4.146 4.146 886.536 2063 4.146 4.146 904.553 2064 4.157 4.157 923.010 2065 4.146 4.146 941.939 2066 4.146 4.146 961.341 2067 4.146 4.146 981.229 2068 27.415 27.415 978.345
NLS2009053 Attachment Page 6 of 6 Calculations:
3 2069 63.494 63.494 939.310 2070 100.380 100.380 862.413 2071 63.571 63.571 820.402 2072 63.745 63.745 777.167 2073 39.826 39.826 756.770 2074 1.485 1.485 774.204 2075 0.084 0.084 793.475 674.973 674.973 Column B = (A)*( 1+.00)"(current year - 2008)
Column C = (Previous year's fund balance) * (1 +.025) - B (current year's decommissioning expenditures)
RAI No. 5: Section 2.1. DECON The submittal focuses on DECON as the preferred option for decommissioning, and Section 2.1 provides detailed discussions on the preferred DECON option. However, the Irradiated Fuel Management Program submittal uses the SAFSTOR option as the mechanism for addressing the radiological and spent fuel management costs. Please confirm which option is the preferred decommissioning option.
Response
The submittal describes each decommissioning scenario. However, as described in the "Program for Maintenance of Irradiated Fuel," NPPD has identified Scenario 3 (2014 SAFSTOR) as its basis for financial planning, in the event that the plant was to cease operations on January 18, 2014. In this scenario, the nuclear unit is placed into safe-storage at the expiration of its current operating license. Decommissioning would be deferred such that termination of the license would occur within the required sixty-year period.
RAI No. 6: Section 3.4. Site-Specific Considerations The submittal did not indicate ifNPPD had completed a 10 CFR 50. 75(g)(1) review of its records to address any potential spills that could result in contaminated soil or groundwater, and its potential impact on costs. Please state whether or not NPPD has completed the review.
Response
Yes, NPPD has completed a 10 CFR 50.75(g)(1) review of its records to address any potential spills that could result in contaminated soil or groundwater. The records describe a single, minor event (drum overflow) that resulted in contamination of the adjacent soil. The total area impacted by the event was approximately 36 square feet (and less than a foot in depth). The event is expected to have a negligible impact on the total cost to decommission CNS.
NLS2009053 Enclosure Enclosure to Response to Question #1 Resolution of Nebraska Public Power District
RESOLUTION OF NEBRASKA PUBLIC POWER DISTRICT No. 08-70 Adopted: June 13, 2008 WHEREAS, the District is required by Nuclear Regulatory Commission (NRC)
Regulation (10 CFR 50.75) to provide sufficient funding for the dismantlement and disposal of radioactive structures and materials as necessary at the time of termination of the District's Operating License for Cooper Nuclear Station (CNS); and WHEREAS, the District established an External Decommissioning Fund pursuant to Board Resolution No. 90-75 in May 1990 to provide assurance that funds will be available when needed for required decommissioning activities; and WHEREAS, the District is committed to collecting sufficient funds to meet the minimum requirements of the NRC and to provide funding of other decommissioning-related costs including, but not limited to, provisions for restoration of the CNS site and provisions for interim storage of spent nuclear fuel; and WHEREAS, the District has conducted periodic site specific studies of the costs of decommissioning CNS; and
- WHEREAS, management has developed and has recommended a
decommissioning funding plan for CNS to the Board of Directors that will provide funding for future decommissioning and other related costs; and WHEREAS, the following assumptions were made in developing the decommissioning funding plan:
- 1.
Decommissioning will commence in January 2014 upon termination of the existing Operating License, or at a later date (subject to NRC approval of a twenty-year renewal of the CNS Operating License) as determined by the Board of Directors; and
- 2.
The SAFSTOR (safe storage with delayed dismantlement) methodology will be utilized to decommission CNS; and
- 3.
An annual escalation rate for decommissioning costs of 3.0%; and
- 4.
A nominal rate of investment return of 5.5% on monies in the decommissioning fund(s); and
- 5.
A corresponding real rate of investment return of 2.5%; and
- 6.
Fees of the External Decommissioning Fund trustee and investment managers will be paid for from the External Decommissioning Fund.
Resolution No. 08-70 Adopted: June 13, 2008 Page 2 NOW, THEREFORE, BE IT RESOLVED that the Board of Directors approves the decommissioning plan recommended by management and affirms that such funding plan assumptions are reasonable and appropriate for decommissioning funding planning for CNS through January 18, 2014, and beyond, as determined by the Board of Directors at a later date, and is in the best interests of NPPD and its ratepayers.
BE IT FURTHER RESOLVED that management is directed to periodically review and update the assumptions, costs and methods of funding decommissioning as a result of changing conditions (to include Operating License renewal) and requirements, and recommend appropriate changes in funding plans to the Board of Directors.
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©4 Correspondence Number:
NLS2009053 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None 4-4 4-4 4-4 4-4 4-4 4-4 4-4 I PROCEDURE 0.42 REVISION 23 PAGE 18 OF 25 1