L-2012-442, Units 1 & 2 - ISFSI Decommissioning Funding Plans

Units 1 & 2 - ISFSI Decommissioning Funding Plans

ML12354A134
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold, 07200061, 07200062
Issue date:	12/17/2012
From:	Larry Nicholson Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
L-2012-442
Download: ML12354A134 (12)

Text

KDEC-1 7 2012 L-2012-442 10 CFR 72.30(b)

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Docket No. 72-61 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Docket No. 72-62 NextEra Energy Seabrook, LLC Seabrook Station Docket No. 50-443 Docket No. 72-63 NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center Docket No. 50-331 Docket No 72-32 NextEra Energy Point Beach, LLC Point Beach Units 1 and 2 Docket Nos. 50-266, 50-301 Docket No. 72-05 ISFSI Decommissioninq Fundinq Plans Pursuant to 10 CFR 72.30(b), attached are the ISFSI Decommissioning Funding Plans for the following Florida Power and Light and NextEra Energy units (FPL/NextEra):

• St. Lucie Units 1 and 2

• Turkey Point Units 3 and 4

• Seabrook Unit 1

• Duane Arnold Energy Center

• Point Beach Units 1 and 2 Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408

L-2012-442 Page 2 of 2 The attached ISFSI Decommissioning Funding Plans include ISFSI decommissioning cost estimates excerpted from existing reactor decommissioning cost estimates. Each existing reactor cost estimate assumes that the ISFSI, which has a Part 72 general license, will remain in service following the decommissioning and release of the other portions of the site under Part 50. As a result, in all cases, the cost estimates assume that the Part 50 license will be maintained until the ISFSI is decommissioned and the license may be terminated. Decommissioning is defined in 10 CFR 50.2 as the removal of a site from service and reduction of residual radioactivity to a level that permits the termination of the license, so the Part 50 license cannot be terminated until the ISFSI meets residual radioactivity requirements. As a result, the decommissioning of an ISFSI with a Part 72 general license is necessarily a Part 50 decommissioning cost covered by 10 CFR 50.75.

For this reason, the attached ISFSI Decommissioning Funding Plans rely on "the methods of 10 CFR 50.75(b), (e), and (h), as applicable" as allowed under new 10 CFR 72.30(e)(5), to demonstrate ISFSI decommissioning financial assurance and do not provide either a new ISFSI-specific decommissioning cost estimate or new ISFSI-specific decommissioning financial assurance methods. Specifically, the Decommissioning Funding Plans rely on the most recent biennial decommissioning funding status reports submitted to the NRC pursuant to 10 CFR 50.75.*

In order to facilitate the 3-year update required under new 10 CFR 72.30(c) for the fleet, FPL/NextEra has requested vendor bids for the completion of new ISFSI decommissioning cost estimates for each site to be completed in the first quarter 2013.

FPL/NextEra understands that there have been a number of requests for NRC guidance on the implementation of the recently amended ISFSI decommissioning financial assurance rules as they are applied to Part 72 general licensees. We believe that a workshop or other public meeting could be very helpful in reaching a common understanding of the new requirements.

Should there be any questions, please contact Mark Dryden at (561) 694-4430.

Very truly yours, Larry Nicholson Director, Licensing Attachment

• Reference - FPL/NextEra Letter L-2011-058, Decommissioning Fund Status Reports, dated March 23, 2011 (ML110840036)

L-2012-442 - Attachment Page 1 of 10 St. Lucie Nuclear Plant Units 1 and 2 Florida Power & Light Company (FPL)

Florida Municipal Power Agency (FMPA) (Unit 2)

Orlando Utilities Commission (OUC) (Unit 2)

ISFSI Decommissioning Funding Plan 10 C.F.R. 72.30(b)

(1) FPL (St. Lucie Units 1 and 2) and the joint owners of St. Lucie Unit 2 demonstrate reasonable assurance of decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h). As is reported in the 2011 St. Lucie decommissioning funding status ("DFS") report, the calculated minimum decommissioning financial assurance at that time for Unit 1 was $439,235,100 and FPL had accumulated a total of $696,049,692 in the Decommissioning Trust Fund ("DTF") by the end of the calendar year 2010. For Unit 2, the calculated minimum decommissioning financial assurance at that time for all three owners was $439,235,100. FPL and the joint owners had accumulated a total of

$665,711,437 in their respective Unit 2 DTFs by the end of the calendar year 2010. As is explained in the 2011 DFS report, the total reported fund balances include funds collected for decommissioning, site restoration, and spent fuel management. Under the definition of decommissioning in 10 C.F.R. § 50.2, these funds will be available for decommissioning the site, including the ISFSI.

(2) TLG Services, Inc. has performed a detailed Decommissioning Study ("DS") for St. Lucie, dated December 2010. The DS includes an estimate for ISFSI Decontamination of approximately $1,729,000 per unit in 2010 dollars (a total of

$3,458,000 divided evenly for the shared ISFSI). This value includes an average contingency factor of 17.7%. Escalated to 2012 dollars (CPI-U), this amount is approximately $1,819,000 per unit. The DS reflects the cost of decommissioning performed by a decommissioning operations contractor to a standard to allow the release of the site for unrestricted use.

(3) The ISFSI portion of the St. Lucie DS uses the following key assumptions:

" The ISFSI will continue to operate under a general license following the amendment of the operating license(s) to release the adjacent property.

Assuming the DOE starts accepting fuel from the St. Lucie spent fuel storage pools in 2032, transfer of spent fuel from the ISFSI is anticipated to begin in 2049, and continue through the year 2073.

• At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The NRC will terminate the Part 50 license when it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI.

L-2012-442 - Attachment Page 2 of 10

" Spent fuel is stored on the ISFSI in multi-purpose canisters, with a concrete overpack. For purposes of the cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required decontamination performed on the storage overpack (some minor activation is assumed), and the license for the facility terminated, the concrete overpacks can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad is then removed and the area regraded.

• A Transnuclear NUHOMS-32PT system (with a 32 fuel assembly capacity) is assumed for future acquisitions.

(4) FPL and the joint owners of St. Lucie Unit 2 demonstrate financial assurance for decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h).

As discussed in Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" if the amount in the decommissioning trust fund, escalated using the real rate of return allowed by 10 C.F.R. § 50.75, does not meet or exceed the minimum calculated under 10 C.F.R § 50.75, the licensee will correct the shortfall by the time of the next biennial DFS report.

(5) FPL has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

(6) As reflected in the 2011 biennial decommissioning funding status report, FPL had accumulated $696,049,692 in the DTF for St. Lucie Unit 1 and FPL and the joint owners had accumulated a total of $665,711,437 in the DTFs for St. Lucie Unit 2 at the end of calendar year 2010. DTF balances for the end of calendar year 2012 will be reported in the next biennial DFS report in March 2013.

L-2012-442 - Attachment Page 3 of 10 Turkey Point Nuclear Plant, Units 3 and 4 Florida Power & Light Company (FPL)

ISFSI Decommissioning Funding Plan 10 C.F.R. 72.30(b)

(1) FPL (Turkey Point Units 3 and 4) demonstrates reasonable assurance of decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h).

As is reported in the 2011 Turkey Point decommissioning funding status ("DFS")

report, the calculated minimum decommissioning financial assurance at that time for Unit 3 was $423,579,900 and FPL had accumulated a total of $583,819,707 in the Decommissioning Trust Fund ("DTF") by the end of the calendar year 2010.

For Unit 4, the 2011 DFS report showed a calculated minimum decommissioning financial assurance of $423,579,900 and FPL had accumulated a total of

$657,399,673 in the DTF by the end of the calendar year 2010. As is explained in the 2011 DFS report, the total reported fund balances include funds collected for decommissioning, spent fuel management, and site restoration. Under the definition of decommissioning in 10 C.F.R. § 50.2, these funds will be available for decommissioning the site, including the ISFSI.

(2) TLG Services, Inc. has performed a detailed Decommissioning Study ("DS") for Turkey Point, dated December 2010. The DS includes an estimate for ISFSI Decontamination of $1,670,000 per unit in 2010 dollars (a total of $3,342,000 divided evenly for the shared ISFSI). This value includes an average contingency factor of approximately 16%. Escalated to 2012 dollars (CPI-U), this amount is

$1,757,000 per unit. The DS reflects the cost of decommissioning performed by a decommissioning operations contractor to a standard to allow release of the site for unrestricted use.

(3) The ISFSI portion of the Turkey Point DS uses the following key assumptions:

" The ISFSI will continue to operate under a general license following the amendment of the operating license(s) to release the adjacent property.

Assuming the DOE starts accepting fuel from the Turkey Point spent fuel storage pools in 2031, transfer of spent fuel from the ISFSI is anticipated to begin in 2039, and continue through the year 2072.

• At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The NRC will terminate the Part 50 license when it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI.

L-2012-442 - Attachment Page 4 of 10

• Spent fuel is stored on the ISFSI in multi-purpose canisters, with a concrete overpack. For purposes of the cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required decontamination performed on the storage overpack (some minor activation is assumed), and the license for the facility terminated, the concrete overpacks can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad is then removed and the area regraded.

" A Transnuclear NUHOMS-32PT system (with a 32 fuel assembly capacity) is assumed for future acquisitions.

(4) FPL demonstrates financial assurance for decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h). As discussed in Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" if the amount in the decommissioning trust fund, escalated using the real rate of return allowed by 10 C.F.R. § 50.75, does not meet or exceed the minimum calculated under 10 C.F.R § 50.75, the licensee will correct the shortfall by the time of the next biennial DFS report.

(5) FPL has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

(6) As reflected in the 2011 biennial DFS report, FPL had accumulated $583,819,707 and $657,399,673 in the DTFs for Units 3 and 4, respectively, at the end of calendar year 2010. DTF balances for the end of calendar year 2012 will be reported in the next biennial DFS report in March 2013.

L-2012-442 - Attachment Page 5 of 10 Seabrook Station NextEra Energy Seabrook, LLC (NextEra),

Hudson Light and Power Department (Hudson),

Massachusetts Municipal Wholesale Electric Company (MMWEC),

Taunton Municipal Lighting Plant (Taunton)

ISFSI Decommissioning Funding Plan 10 C.F.R. 72.30(b)

(1) NextEra Energy Seabrook, LLC and the joint owners of Seabrook Station, MMWEC, Hudson, and Taunton, demonstrate reasonable assurance of decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h).

As is reported in the 2011 Seabrook decommissioning funding status ("DFS")

report, the calculated minimum decommissioning financial assurance at that time for all four owners was $482,023,500 and the joint owners had accumulated a total of $403,160,241 in their respective Decommissioning Trust Funds ("DTFs")

by the end of calendar year 2010. The 2011 DFS report identified $113,300,202 in total additional contributions (excluding escrow contributions) by the end of the period of currently licensed operations in 2030 and a total projected 2030 balance (excluding escrow accounts) of $1.7 billion. As is explained in the 2011 DFS report, the total reported fund balance includes funds collected for decommissioning, spent fuel management, and site restoration. Under the definition of decommissioning in 10 C.F.R. § 50.2, these funds will be available for decommissioning the site, including the ISFSI.

(2) TLG Services, Inc. has performed a detailed Decommissioning Cost Analysis

("DCA") for the Seabrook Station, dated May, 2011. The DCA includes an estimate for ISFSI Decontamination and License Termination of $2,446,000 in 2010 dollars. This value includes an average contingency factor of 16.4%.

Escalated to 2012 dollars (CPI-U), this amount is $2,573,000. The DCA reflects the cost of decommissioning managed by a decommissioning operations contractor to a standard to allow the release of the site for unrestricted use.

(3) The ISFSI portion of the Seabrook Station DCA uses the following key assumptions:

The ISFSI will continue to operate under a general license following the amendment of the operating license to release the adjacent property.

Assuming the DOE starts accepting fuel in 2022, transfer of spent fuel from Seabrook Station is anticipated to begin in 2032, at the earliest.

Pursuant to the New Hampshire Nuclear Decommissioning Finance Committee's directive in its 2009 Order, fuel is assumed to remain on site until 2100.

L-2012-442 - Attachment Page 6 of 10

" At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The NRC will terminate the Part 50 license if it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI.

• The ISFSI was designed using a NUHOMS HD system (multi-purpose canister and a horizontal concrete storage module).

" Once emptied, the internal canister support structure is assumed to be removed from the storage module for controlled disposal.

• It is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required decontamination performed, and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete.

(4) NextEra and the joint owners of the Seabrook Station demonstrate financial assurance for decommissioning funding using the methods of 10 C.F.R.

§ 50.75(b), (e), and (h). As discussed in Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" if the amount in the decommissioning trust fund, escalated using the real rate of return allowed by 10 C.F.R. § 50.75, does not meet or exceed the minimum calculated under 10 C.F.R

§ 50.75, the licensee will correct the shortfall by the time of the next biennial DFS report.

(5) NextEra has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

(6) As reflected in the 2011 biennial DFS report, NextEra and the joint owners had accumulated $403,160,241 in their respective DTFs at the end of calendar year 2010, and projected a total balance of $1.7 billion in the DTFs by 2030. DTF balances for the end of calendar year 2012 will be reported in the next biennial DFS report in March 2013.

L-2012-442 - Attachment Page 7 of 10 Duane Arnold Energy Center (DAEC)

NextEra Energy Duane Arnold, LLC (NextEra),

Central Iowa Power Cooperative (CIPCO),

Corn Belt Power Cooperative (Corn Belt)

ISFSI Decommissioning Funding Plan 10 C.F.R. 72.30(b)

(1) NextEra and the joint owners of the DAEC, CIPCO and Corn Belt, demonstrate reasonable assurance of decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h). As is reported in the 2011 DAEC decommissioning funding status ("DFS") report, the calculated minimum decommissioning financial assurance at that time for all three owners was

$553,314,520 and the joint owners had accumulated a total of $272,053,850 in their respective Decommissioning Trust Funds ("DTFs") by the end of calendar year 2010. The 2011 DFS report identified $7,100,000 in total additional contributions by the end of 2015. The 2011 DFS report relied upon a site specific cost estimate and the SAFSTOR decommissioning funding alternative with a total escalated cost of $603,358,000, as shown in Attachment 2 of the DFS Report.

The SAFSTOR Alternative cost flow shows a total balance of $1.397 billion in 2093 at the conclusion of the SAFSTOR period. Under the definition of decommissioning in 10 C.F.R. § 50.2, these funds will be available for decommissioning the site, including the ISFSI.

(2) EnergySolutions, LLC has performed a detailed Decommissioning Cost Estimate Study ("DCES") for the DAEC, dated January, 2010. The DCES includes an estimate for ISFSI license termination of $365,000 in 2008 dollars. This value includes an average contingency factor of 13%. Escalated to 2012 dollars (CPI-U), this amount is $400,251. The DCES reflects the cost of decommissioning performed by a decommissioning general contractor to a standard to allow the release of the site for unrestricted use.

(3) The ISFSI portion of the DAEC DCES uses the following key assumptions:

" EnergySolutions developed prompt dismantlement (DECON) and delayed dismantlement (SAFSTOR) project schedules based on a shutdown date of February 21, 2014 for Scenarios 1 and 2. For Scenarios 3 and 4, with a 20 year license extension, a shutdown date of February 21, 2034 was used (In its 2011 DFS Report, DAEC relies upon Scenario 4, SAFSTOR and license extension).

• At the end of SAFSTOR Period 10, site decontamination results in partial Part 50 license termination. Full Part 50 license termination is not achieved until the Dry Period 4, ISFSI Decommissioning.

• The Horizontal Storage Modules (HSMs) are assumed to have no activated concrete. The ISFSI demolition cost also assumes no activation or surface contamination of the HSMs.

L-2012-442 - Attachment Page 8 of 10 (4) NextEra and the joint owners of DAEC demonstrate financial assurance for decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h).

As discussed in Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" if the amount in the decommissioning trust fund, escalated using the real rate of return allowed by 10 C.F.R. § 50.75, does not meet or exceed the minimum calculated under 10 C.F.R § 50.75, the licensee will correct the shortfall by the time of the next biennial DFS report.

(5) NextEra has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

(6) As reflected in the 2011 biennial DFS report, NextEra and the joint owners had accumulated $272,053,850 in their respective DTFs at the end of calendar year 2010, and projected a total balance of $1.397 billion in the DTFs by the end of the SAFSTOR decommissioning in 2093. DTF balances for the end of calendar year 2012 will be reported in the next biennial DFS report in March 2013.

L-2012-442 - Attachment Page 9 of 10 Point Beach Nuclear Plant, Units 1 and 2 NextEra Energy Point Beach, LLC (NextEra)

ISFSI Decommissioning Funding Plan 10 C.F.R. 72.30(b)

(1) NextEra (Point Beach Units 1 and 2) demonstrates reasonable assurance of decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h).

As is reported in the 2011 Point Beach decommissioning funding status ("DFS")

report, the calculated minimum decommissioning financial assurance at that time for Unit 1 was $398,528,276 and NextEra had accumulated a total of

$260,164,914 in the Decommissioning Trust Fund ("DTF") by the end of the calendar year 2010. The 2011 DFS report projected a total of $413,488,047 at shutdown for Unit 1. For Unit 2, the 2011 DFS report showed a calculated minimum decommissioning financial assurance of $398,528,276 and NextEra had accumulated a total of $245,135,466 in the DTF by the end of the calendar year 2010. The 2011 DFS report projected a total of $408,653,331 at shutdown for Unit 2. Under the definition of decommissioning in 10 C.F.R. § 50.2, these funds will be available for decommissioning the site, including the ISFSI.

(2) EnergySolutions, LLC has performed a detailed Decommissioning Cost Update of the Point Beach Power Plant ("DCU"), dated May, 2011. The DCU includes an estimate for ISFSI license termination costs of $513,000 in 2011 dollars. This value includes an average contingency factor of 10.1%. Escalated to 2012 dollars (CPI-U), this amount is $524,000. The DCU reflects the cost of decommissioning performed by a third party contractor to a standard to allow the release of the site for unrestricted use.

(3) The ISFSI portion of the Point Beach DCU uses the following key assumptions:

" The facility has an existing ISFSI licensed for operation. The ISFSI is located on the PBNP site outside the protected area, but within the owner controlled area. The PBNP ISFSI utilizes NUHOMS-32P Dry Shielded Canisters (DSCs) which are stored in concrete Horizontal Storage Modules (HSMs). The PBNP ISFSI also currently utilizes 16 Single Purpose DSC's.

• On-site dry storage at the site contains 16 DSCs that are Single Purpose Canisters (SPCs) and currently not licensed for transportation. It is assumed for this study that the 16 Single Purpose Dry Storage Canisters currently on-site will be licensed for transportation and spent fuel assemblies will not require transfer to Dual Purpose Canisters.

• An ISFSI sufficient to accept all post-shutdown dry storage canisters is assumed to exist at PBNP at the time of decommissioning.

• The ISFSI pad and HSMs are assumed to have no activated concrete or surface contamination.

• It is assumed that the 10 CFR Part 50 license will be maintained until DOE has taken possession of the spent fuel.

L-2012-442 - Attachment Page 10 of 10 (4) NextEra demonstrates financial assurance for decommissioning funding using the methods of 10 C.F.R. § 50.75(b), (e), and (h). As discussed in Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" if the amount in the decommissioning trust fund, escalated using the real rate of return allowed by 10 C.F.R. § 50.75, does not meet or exceed the minimum calculated under 10 C.F.R § 50.75, the licensee will correct the shortfall by the time of the next biennial DFS report.

(5) NextEra has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

(6) As reflected in the 2011 biennial DFS report, NextEra had accumulated

$260,164,914 and $245,135,466 in the DTFs for Unit 1 and 2, respectively, at the end of calendar year 2010, and projected a total balance at shutdown of

$413,488,047 and $408,653,331, respectively. DTF balances for the end of calendar year 2012 will be reported in the next biennial DFS report in March 2013.