ML092800107
| ML092800107 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, Ginna  |
| Issue date: | 10/02/2009 |
| From: | Barron H Constellation Energy Nuclear Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME0522, TAC ME0540 | |
| Download: ML092800107 (4) | |
Text
Henry B. Barron Constellation Energy Nuclear Group President, CEO & Chief Nuclear Officer 100 Constellation Way Suite 1800P Baltimore, MD 21202 0
Constellation Energy Nuclear Group 10 CFR 50.75 October 2, 2009 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:
Document Control Desk
SUBJECT:
Nine Mile Point Nuclear Station Unit No. 1; Docket No.50-220 R. E. Ginna Nuclear Power Plant Docket No. 50-244 Response to Request for Additional Information on Decommissioning Funding
REFERENCES:
(a)
Letter from H. B. Barron (CENG) to Document Control Desk (NRC),
dated March 26, 2009, Biennial Report:
Status of Decommissioning Funding (b)
Letter from R. V. Guzman (NRC) to H. B. Barron (CENG), dated September 25, 2009, Request for Additional Information Regarding Decommission Funding Assurance for Nine Mile Point Nuclear Station, Unit No. 1 and R.E. Ginna Nuclear Power Plant (TAC Nos. ME0540 and ME0522)
In Reference (a), Constellation Energy Nuclear Group, LLC (CENG) submitted the 2009 Biennial Report on the status of the decommissioning funding for the CENG plants.
In Reference (b), the Nuclear Regulatory Commission (NRC) requested additional information on the status of the funds for Nine Mile
.Point Nuclear Station, Unit 1 and for R.E. Ginna Nuclear Power Plant.
This letter provides the information requested.
RAI-1
Nine Mile Point Nuclear Station, Unit 1 (NMP 1)
As stated to Constellation in the phone call with the NRC on June 29, 2009, the current NRC minimum decommissioning formula amount for NMPI is $511 million.
Submit an updated site specific decommissioning cost estimate which meets the requirements of 10 CFR 50.75(b)(1) which
Document Control Desk October 2, 2009 Page 2 may be "more, but not less" than the current minimum decommissioning formula amount for NMPl.
The site specific estimate should include a table of the estimated costs for radiological decommissioning, per year, for the entire decommissioning period.
R.E. Ginna Nuclear Power Plant (Ginna)
As stated to Constellation in the phone call with the NRC on June 29, 2009, the current NRC minimum decommissioning formula amount for Ginna is $357.2 million.
Submit an updated site specific decommissioning cost estimate which meets the requirements of 10 CFR 50.75(b)(1) which may be "more, but not less" than the current minimum decommissioning formula amount for Ginna.
The site specific estimate should include a table of the estimated costs for radiological decommissioning, per year, for the entire decommissioning period.
Response
Pursuant to the requirements of 10 CFR 50.75(b)(1) and recent conversations with the staff, CENG will ensure that the results of the site-specific studies will be submitted by November 20, 2009 and will be greater-than-or-equal-to the formula amount for that unit, as calculated per 10 CFR 50.75 (c)(1).
In addition, the site-specific estimate will include estimated costs for radiological decommissioning activities, per year, for the entire decommissioning period.
RAI-2
Clarify that the amounts of any proposed parent company guarantees for any plants with decommissioning shortfalls would be determined based on the difference between the greater of the NRC minimum formula amount or site-specific estimate, and the actual trust fund balance as of a specified date, plus any earnings credits, plus the value of any additional financial assurance mechanisms, as of the date of expected termination of operations. The amount of the shortfall would be reviewed and verified by NRC staff. Any discounted net present value calculations utilized to determine the amount of the potential guarantee are not currently deemed to be in accordance with 10 CFR 50.75(e)(1)(vi).
Response
Should the site-specific SAFSTOR studies not be submitted to the NRC Staff on or before November 20, 2009, Constellation Energy Group, Inc. stands ready to post a parent guarantee in the amounts shown in of the July 29, 2009 Decommissioning Plan for the two relevant units. The values in the July 29, 2009 plan are the values specified in the request for additional information above and are not calculated using a discounted net present value.
While CENG acknowledges the Staff's request for not using a discounted net present value in calculating the parent guarantee amounts, we also recognize that this is a pending industry/NRC issue that has not yet been resolved. Accordingly, we reserve our rights to use such methodology in future matters, consistent with the ultimate resolution of the issue.
Document Control Desk October 2, 2009 Page 3 If there are any questions regarding this transmittal, please contact Bruce S. Montgomery at 410-470-3777 or Bruce.S.Montgomery@constellation.com.
Sincerely, Henry B. Barron Chief Nuclear Officer Constellation Energy Nuclear Group, LLC STATE OF MARYLAND CITY OF BALTIMORE
- TO WIT:
I, Henry B. Barron, state that I am the Chief Nuclear Officer for Constellation Energy Nuclear Group, LLC, for Nine Mile Point Nuclear Station, LLC, and R.E. Ginna Nuclear Power Plant, LLC, and that I am duly authorized to execute and file. this submittal on behalf of these companies.
To the best of my knowledge and belief, the statements contained in this document with respect to these companies are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by employees and/or consultants of the companies. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
Subscribed, and sworbp)efore me, a Notary Public in and for the State of Maryland and City of Baltimore, thiZ day of
,2009.
Notg Public WITNESS my Hand and Notarial Seal:
My Commission Expires:
Date HBB/EMT
Document Control Desk October 2, 2009 Page 4 cc:
D. V. Pickett, NRC R. V. Guzman, NRC M. F. Weber, NMSS S. J. Collins, NRC S. Gray, Maryland DNR Resident Inspector, NRC (Calvert Cliffs)
Resident Inspector, NRC (Ginna)
Resident Inspector, NRC (Nine Mile Point)
A. L. Peterson, NYSERDA P. D. Eddy, New York State Department of Public Service