ML111940236

Letter to J.Christian Zion Nuclear Power Station, Units 1 and 2 -2011 Decommissioning Funding Status Report - Request for Additional Information (TAC Nos. J00408 and J00409)

ML111940236
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/15/2011
From:	John Hickman NRC/FSME/DWMEP/DURLD/RDB
To:	Christian J ZionSolutions
Hickman J, FSME/DWMEP,301-415-3017
References
TAC J00408, TAC J00409
Download: ML111940236 (6)

Text

July 15, 2011 Mr. John A. Christian, President ZionSolutions, LLC, and Commercial Services, EnergySolutions ZionSolutions, LLC 900 17th Street NW, Suite 1050 Washington, DC 20006

SUBJECT:

ZION NUCLEAR POWER STATION, UNITS 1 AND 2 -2011 DECOMMISSIONING FUNDING STATUS REPORT - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. J00408 AND J00409)

Dear Mr. Christian:

On March 30, 2011, ZionSolutions, LLC (ZS) submitted to the Nuclear Regulatory Commission the 2011 Decommissioning Funding Status report for Zion Nuclear Power Station (ZNPS), Units 1 and 2, as required under 10 CFR 50.75(f)(1). In order to complete our review of your Decommissioning Funding Status report we require additional information as detailed in the enclosure. Please provide a response to our request for additional information within 30 days from the date of this letter.

Sincerely,

/RA/

John B. Hickman, Project Manager Reactor Decommissioning Branch Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Docket Nos.: 50-295 and 50-304 License Nos.: DPR-39 and DPR-49

Enclosure:

Request for Additional Information cc: w/enclosures:

Zion License Transfer Service List

Mr. John A. Christian, President ZionSolutions, LLC, and Commercial Services, EnergySolutions ZionSolutions, LLC 900 17th Street NW, Suite 1050 Washington, DC 20006

SUBJECT:

ZION NUCLEAR POWER STATION, UNITS 1 AND 2 -2011 DECOMMISSIONING FUNDING STATUS REPORT - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. J00408 AND J00409)

Dear Mr. Christian:

On March 30, 2011, ZionSolutions, LLC (ZS) submitted to the Nuclear Regulatory Commission the 2011 Decommissioning Funding Status report for Zion Nuclear Power Station (ZNPS), Units 1 and 2, as required under 10 CFR 50.75(f)(1). In order to complete our review of your Decommissioning Funding Status report we require additional information as detailed in the enclosure. Please provide a response to our request for additional information within 30 days from the date of this letter.

Sincerely, John B. Hickman, Project Manager Reactor Decommissioning Branch Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Docket Nos.: 50-295 and 50-304 License Nos.: DPR-39 and DPR-49

Enclosure:

Request for Additional Information cc: w/enclosures:

Zion License Transfer Service List Distribution:

CLipa, RIII SHarwell, NRR CRegan, NRR ML111940236 OFFICE RDB DWMEP RDB RDB NAME JHickman CHolston via BWatson JHickman email (SGiebel for)

DATE 07/14/11 07/15/11 07/15/11 07/15/11 OFFICIAL RECORD COPY

Zion Nuclear Power Station, Units 1 and 2 Service List cc:

Senior Vice President and General Manager ZionSolutions, LLC John E. Matthews 101 Shiloh Blvd. Morgan, Lewis & Bockius LLP Zion, IL 60099-2797 1111 Pennsylvania Avenue, NW Washington, DC 20004 Decommissioning Plant Manager ZionSolutions, LLC Russ Workman 101 Shiloh Blvd. Deputy General Counsel Zion, IL 60099-2797 EnergySolutions 423 West 300 South, Suite 200 Director Regulatory Affairs& QA Salt Lake City, UT 84101 ZionSolutions, LLC 101 Shiloh Blvd. Matias F. Travieso-Diaz Zion, IL 60099-2797 Pillsbury Winthrop Shaw Pittman LLP 2300 N St., N.W.

Illinois Emergency Management Agency Washington, D.C. 20037 1035 Outer Park Drive Springfield, IL 62704 Tom Rielly, Executive Principal Vista 360 Mayor of Zion 649 Innsbruck Zion, IL 60099 Libertyville IL 60048 Mr. Kent McKenzie, Emergency Director Spent Fuel & Decommissioning Management Coordinator Strategy Lake County Emergency Management Exelon Generation Company, LLC Agency 4300 Winfield Road 1303 N. Milwaukee Avenue Warrenville, IL 60555 Libertyville, IL 60048-1308 Associate General Counsel Regional Administrator Exelon Generation Company, LLC U.S. NRC, Region III 4300 Winfield Road 2443 Warrenville Road Warrenville, IL 60555 Lisle, IL 60532-4352 Document Control Desk - Licensing J. Bradley Fewell Exelon Generation Company, LLC Associate General Counsel 4300 Winfield Road Exelon Corporation Warrenville, IL 60555 4300 Winfield Rd.

Warrenville, IL 60555

REQUEST FOR ADDITIONAL INFORMATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR ZIONSOLUTIONS, LLC On March 30, 2011, ZionSolutions, LLC (ZS) submitted to the Nuclear Regulatory Commission (NRC) the 2011 Decommissioning Funding Status (DFS) report for Zion Nuclear Power Station (ZNPS), Units 1 and 2, as required under 10 CFR 50.75(f)(1) (ML111100603). These requests for additional information (RAI) are in response to the ZS 2011 DFS report.

RAI #1: Decommissioning Expenses On March 30, 2011, ZS reported the following in relation to the Decommissioning Trust Fund (DTF) balance for ZNPS, Units 1 and 2:

Trust Fund Amount at December 31, 2010 $788,293,000 Unit 1 Fund Amount $340,637,000 Unit 2 Fund Amount $447,656,000 Per 10 CFR 50.75(e)(2),

the NRC reserves the right to take the following steps in order to ensure a licensees adequate accumulation of decommissioning funds: review, as needed, the rate of accumulation of decommissioning funds.

Per 10 CFR 50.75(g),

each licensee shall keep records of information important to the safe and effective decommissioning of the facility in an identified location until the license is terminated by the Commission. If records of relevant information are kept for other purposes, reference to these records and their locations may be used.

Information the Commission considers important to decommissioning consists of-

[]

(3) Records of the cost estimate performed for the decommissioning funding plant or of the amount certified for decommissioning, and records of the funding method used for assuring funds if either a funding plan or certification is used.

Provide the amount spent on decommissioning, both cumulative and over the previous calendar year, in a schedule showing the expenses for each year since the permanent cessation of operations. Provide the amount withdrawn from the decommissioning trust fund for expenses related to decommissioning planning prior to the permanent cessation of operation.

Enclosure

2 RAI #2: Decommissioning Costs On March 30, 2011, ZS provided the following:

Required Minimum at December 31, 2010 $716,700,000Per 10 CFR 50.82(a)(8)(i),

decommissioning trust funds may be used by licensees if-

[]

(C) The withdrawals would not inhibit the ability of the licensee to complete funding of any shortfalls in the decommissioning trust needed to ensure the availability of funds to ultimately release the site and terminate the license.

Provide an estimate of the costs to complete decommissioning, reflecting any difference between actual and estimated costs for work performed during the year, and the decommissioning criteria upon which the estimate is based.

RAI #3: Citation for real rate of returns On March 30, 2011, ZS reported the following:

A 2% annual real rate of return is assumed in these calculations.

As stated in 10 CFR 50.75(f)(1),

the information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . .

Provide the basis for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other factors assumed in your DFS report.

RAI #4: Citation for Site-Specific Study On March 30, 2011, ZS referenced a site-specific cost estimate for the amount of decommissioning funds estimated to be required.

Per 10 CFR 50.75(e)(1)(i) and (ii),

the licensee must specifically describe the safe storage period in order to take credit for projected future earnings when it uses a site-specific estimate as the basis for using the prepayment or external sinking fund methods of financial assurance.

Provide the site specific cost estimate for ZNPS, Units 1 and 2, unless it was previously submitted to NRC. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site specific cost estimate should include a summary schedule of annual expenses, projected earnings, and end-of-year fund balances, expressed in 2010 dollars.

3 RAI #5: Amounts accumulated On March 30, 2011, ZS did not state if the amount of decommissioning funds accumulated was an after-tax amount.

The provisions of 10 CFR 50.75(f)(1) and (2) require the licensee to report the amount of funds accumulated to the end of the calendar year preceding the report.

Provide the after-tax amount of funds accumulated through December 31, 2010.