3F1213-01, Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)
| ML13340A008 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/03/2013 |
| From: | Hobbs T Duke Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3F1213-01 | |
| Download: ML13340A008 (11) | |
Text
DUKE Crystal River Nuclear Plant 15760 W. Power Line Street ENERGY, Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.54 December 3, 2013 3F1213-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)
References:
- 1. CR-3 to NRC letter dated November 29, 2011, "Crystal River Unit 3 -
Submittal of Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in Accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3)" (ADAMS Accession No. ML11339A040)
- 2. NRC to CR-3 letter dated September 28, 2012, "Crystal River Unit 3 Nuclear Generating Plant - Review of Spent Fuel Management Program and the Preliminary Decommissioning Cost Estimate (TAC NO. ME7831)" (ADAMS Accession No. ML12262A245)
- 3. NRC to CR-3 letter dated March 13, 2013, "Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel From the Reactor" (ADAMS Accession No. ML13058A380)
- 4. CR-3 to NRC letter dated December 2, 2013, "Crystal River Unit 3 - Post-Shutdown Decommissioning Activities Report"
- 5. Issued October 9, 2013, in Docket No. 130207-El / Order No. PSC-13-0452-FOF-EI, In re: Petition for declaratory statement with respect to use of decommissioning trust fund dollars for spent fuel and other non-radiological decommissioning costs for Crystal River 3 Nuclear Plant
Dear Sir:
Pursuant to 10 CFR 50.54(bb), Duke Energy Florida, Inc. (DEF) submitted the Irradiated Fuel Management Program for Crystal River Unit 3 (CR-3) by letter dated November 29, 2011 (Reference 1). 10 CFR 50.54(bb) requires that a licensee submit this report within five years of the expiration of the reactor operating license. This report was submitted in 2011 because, at that time, CR-3 was approaching five years from operating license expiration. By letter dated September 28, 2012 (Reference 2), the NRC Staff notified CR-3 that the Irradiated Fuel Management Program submitted by CR-3 in Reference 1 complied with 10 CFR 50.54(bb) and approved the program on a preliminary basis.
U. S Nuclear Regulatory Commission Page 2 of 2 3F1213-01 In Reference 3, the NRC acknowledged CR-3's certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes in the proposed Irradiated Fuel Management Program as described in the initial notification.
DEF's determination to permanently cease operation of CR-3 has resulted in a change to the timing of the decommissioning approach that was assumed in Reference 1. This change in timing has been analyzed in the CR-3 Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 4) which also includes the costs for managing irradiated fuel and site restoration. The PSDAR approach for managing spent fuel contains some material differences from what was assumed in Reference 1. Therefore, this update to the Irradiated Fuel Management Program is being submitted concurrent with Reference 4.
The Attachment to this letter includes a discussion on financial assurance for spent fuel management and site restoration. An element of the financial assurance demonstration includes relying on decommissioning trust funds for spent fuel management and site restoration.
Use of decommissioning trust funds for spent fuel management is based upon the Declaratory Statement issued by the Florida Public Service Commission (FPSC) (Reference 5) establishing the FPSC's intention that decommissioning funds collected from DEF customers be used for license termination, spent fuel management, and site restoration purposes. DEF recognizes that use of the decommissioning funds for spent fuel management necessitates further interactions with the NRC Staff.
There are no new regulatory commitments made within this submittal.
If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Regulatory Affairs Manager at (352) 563-4796.
Sincerely, Terry D. Hobbs Decommissioning Director TDH/drw
Attachment:
Updated Irradiated Fuel Management Program - 10 CFR 50.54(bb) xc: NRR Project Manager Regional Administrator, Region I
DUKE ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 ATTACHMENT UPDATED IRRADIATED FUEL MANAGEMENT PROGRAM- 10 CFR 50.54(bb)
U. S. Nuclear Regulatory Commission Attachment 3F1213-01 Page 1 of 8 UPDATED IRRADIATED FUEL MANAGEMENT PROGRAM - 10 CFR 50.54(bb)
I. Background and Introduction By letter dated November 29, 2011 (Reference 1), Duke Energy Florida, Inc. (DEF) submitted the initial Program for Maintenance of Irradiated Fuel for Crystal River Unit 3 (CR-3), pursuant to 10 CFR 50.54(bb). 10 CFR 50.54(bb) requires submittal of this report five years prior to the expiration of the reactor operating license. This report was submitted in 2011 because, at that time, CR-3 was approaching five years from the scheduled operating license expiration of December 3, 2016. By letter dated September 28, 2012 (Reference 2), the NRC Staff notified CR-3 that the Irradiated Fuel Management Program submitted by CR-3 complied with 10 CFR 50.54(bb) and approved the program on a preliminary basis.
CR-3 has been shutdown since September 26, 2009, when the plant entered the Cycle 16 refueling outage to replace the steam generators. Twice during the course of the extended outage, all fuel assemblies were offloaded to the spent fuel pools. The final removal of fuel from the reactor vessel was completed on May 28, 2011. As of that date, all fuel assemblies have been removed from the reactor vessel and are located in the spent fuel pools for temporary storage. Certification of the permanent cessation of power operations and defueling was submitted by CR-3 to the Nuclear Regulatory Commission (NRC) by letter dated February 20, 2013 (Reference 3). In Reference 4, the NRC acknowledged CR-3's certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel.
Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes in the proposed Irradiated Fuel Management Program as described in the initial notification. As a result of changes in timing of the decommissioning approach, DEF is revising the CR-3 Irradiated Fuel Management Program and is submitting this program update to notify the NRC of these changes in accordance with 10 CFR 50.54(bb).
TLG Services, Inc. (TLG) was contracted by DEF to prepare the site-specific Decommissioning Cost Estimate (DCE) contained in the Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 5). The methodology used by TLG to develop the DCE follows the basic approach originally advanced by the Atomic Industrial Forum (AIF) in their program to develop a standardized model for decommissioning cost estimates. The results of its program were published as AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Reference 6). The AIF report presents a unit cost factor method for estimating direct activity costs, simplifying the estimating process. The unit cost factors used in the study reflect the latest available data, at the time of the study, concerning worker productivity during decommissioning.
II. Irradiated Fuel Management Strateav There are 1,319 fuel assemblies currently stored in the spent fuel pools at CR-3. In anticipation of reactor startup in 2011, 76 new fuel assemblies were loaded into the reactor, but were offloaded without being in a critical core. Since these fuel assemblies were never used for power generation, they are not considered irradiated fuel. DEF is actively exploring options for shipping the 76 fresh fuel assemblies offsite for reuse. The Updated Irradiated Fuel Management Program focuses on the maintenance and disposition of the 1,243 fuel assemblies that were used for power generation.
U. S. Nuclear Regulatory Commission Attachment 3F1213-01 Page 2 of 8 DEF will construct an Independent Spent Fuel Storage Installation (ISFSI) with sufficient capacity to store the 1,243 irradiated fuel assemblies. The ISFSI will be located within the CR-3 owner controlled area and will be operated under a general license per 10 CFR 72.6(b). While spent fuel is stored in the spent fuel pools, spent fuel storage and handling systems will be maintained in operation. Following the transfer of all spent fuel from the spent fuel pools to the CR-3 ISFSI, all spent fuel will be stored at the ISFSI until transferred to the Department of Energy (DOE) for interim storage and/or ultimate disposal.
The CR-3 ISFSI will utilize the standardized NUHOMS Horizontal Modular Storage System.
This system uses a dry shielded canister (DSC) that is designed to hold 32 spent fuel assemblies. The loaded DSCs are transported from the spent fuel pool to the ISFSI in a transfer cask. At the ISFSI, the loaded DSCs are placed in horizontal storage modules (HSMs).
The major periods in the Irradiated Fuel Management Program, including start and end dates as well as associated costs, are identified in Table 1 below. The cost and schedule information, including the basis for the assumed DOE transfer date, is taken from the PSDAR.
Table 1 Irradiated Fuel Management Program Summary Schedule and Costs Fuel Management Cost (Thousands of Duration Decommissioning Periods Start End 2013 dollars) (years)
Period 1: Planning and Preparations 2013 2015 33,638 2 Period 2a: Dormancy with Wet Fuel Storage 2015 2019 147,032 4 Period 2b: Dormancy with Dry Fuel Storage 2019 2036 84,835 17 Total 265,505 23 The $265,505,000 includes the costs to load and transfer the DSCs, as well as operations and maintenance costs (e.g., staffing, security, insurance, and licensing fees, etc.). It does not include $93.8M for ISFSI capital costs such as construction of the pad/apron and purchasing NUHOMS components. The basis for separating out the ISFSI capital costs is provided in Section III.
Irradiated Fuel Management in Period 1 - Planning and Preparations The Irradiated Fuel Management Program activities that occur in Period 1 are as follows:
- Creation of an organizational structure to support the decommissioning plan and evolving emergency planning and site security requirements.
- Design and installation of an alternate spent fuel cooling system, including air-cooled heat exchangers to be located on the control complex roof and piped into the existing service
U. S. Nuclear Regulatory Commission Attachment 3F1213-01 Page 3 of 8 water system and chilled water system.
- Isolation of the spent fuel pools and fuel handling systems so that safe-storage operations may commence on the balance of the plant.
- Initiation of construction of the ISFSI pad and acquisition of the dry fuel storage modules.
- Shipment of the 76 fresh fuel assemblies offsite.
If for some reason the fresh fuel assemblies are not shipped offsite in Period 1, additional DSCs/HSMs are available onsite for storing the 76 assemblies on the ISFSI pad.
Irradiated Fuel Management in Period 2a - Dormancy with Wet Fuel Storage The Irradiated Fuel Management Program activities that occur in Period 2a include completion of ISFSI construction. Once the ISFSI has been constructed, the spent fuel will be loaded into DSCs and transferred to the HSMs located on the ISFSI pad. The projected schedule for transferring spent fuel from the pools to the ISFSI is outlined in Table 2. The pools will be drained and prepared for long-term storage after spent fuel transfer is completed.
Irradiated Fuel Management in Period 2b - Dormancy with Dry Fuel Storage Dormancy activities include a 24-hour security force as well as preventive and corrective maintenance on security systems, area lighting, and site facilities. Routine radiological inspections of contaminated structures will also be performed and site environmental and radiation monitoring programs will continue to be conducted.
The principal Irradiated Fuel Management Program activity that occurs in Period 2b is the transfer of the spent fuel from the ISFSI to a DOE facility expected to begin in 2035 and be completed at the end of 2036. Table 2 contains the detailed projection for transferring spent fuel to DOE.
Table 2 Decommissioning Fuel Movement Schedule CR-3 Pool Fresh Fuel Pool to ISFSI ISFSI Casks Inventory Shipment ISFSI Inventory ISFSI Casks Transferred Year (assemblies) (assemblies) (assemblies) (assemblies) Loaded to DOE 2013 1319 0 2014 1319 0 2015 1243 76 0 2016 1243 0 2017 635 608 608 19 0 2018 0 635 1243 20 0 2019-2034 0 1243 0 2035 0 635 19 2036 0 0 20
U. S. Nuclear Regulatory Attachment 3F1213-01 Page 4 of 8 Ill. Financial Assurance Attachment 1 of the PSDAR (Reference 5) contains an estimate of the costs for license termination, spent fuel management, and site restoration. Tables 3.2, 3.3, and 3.4 in Attachment 1 delineate the annual expenditures for license termination, spent fuel management, and site restoration respectively (Reference 5). This annual expenditure information is used in the cash flow analysis in Table 3. The purpose of the cash flow analysis is to demonstrate that the balance in the CR-3 Decommissioning Trust Fund (DTF) is sufficient to cover license termination, spent fuel management, and site restoration expenses excluding ISFSI capital costs. The analysis in Table 3 assumes a 1.65% real rate of return on the DTF and 0%
escalation on license termination, spent fuel management, and site restoration costs.
Table Inputs:
- 1. Total costs reported (i.e., there is no cost allocation by ownership share)
- 2. The City of Tallahassee funds can only be used for License Termination activities per NRC Order (ADAMS Accession No. ML020670117) dated September 8, 1999
- 3. The aggregate fund balance, as of September 30, 2013, used as year-end 2013 balance
- 4. $93.8M in ISFSI capital costs funded from sources outside the DTF are not included in the Spent Fuel Management Cost total Table 3 Decommissioning Funding Plan (thousands, dollars)
Basis Year 2013 Fund Balance $778,565 (thousands)
Annual Escalation 0.00%
Annual Earnings 1.65%
A B C D E F Total License Termination, Spent Fuel Decommissioning 50.75 50.54(bb) Management Trust Fund License Spent Fuel Site and Site Total Cost Escalated at Termination Management Restoration Restoration Escalated at 1.65%
Cost Cost Cost Cost 0% (minus expenses)
Year (thousands) (thousands) (thousands) (thousands) (thousands) (thousands) 2013 33,652 9,408 - 43,060 43,060 735,504 2014 67,500 16,198 - 83,698 83,698 663,943 2015 47,935 26,020 - 73,955 73,955 600,942 2016 6,831 35,780 - 42,612 42,612 568,246 2017 6,812 35,683 - 42,495 42,495 535,127 2018 6,812 35,683 - 42,495 42,495 501,462 2019 6,275 23,675 - 29,950 29,950 479,786
U. S. Nuclear Regulatory Attachment 3F1213-01 Page 5 of 8 Table 3 (continued)
Decommissioning Funding Plan (thousands, dollars)
Basis Year 2013 Fund Balance $778,565 (thousands)
Annual Escalation 0.00%
Annual Earnings 1.65%
A B C D E F Total License Termination, Spent Fuel Decommissioning 50.75 50.54(bb) Management Trust Fund License Spent Fuel Site and Site Total Cost Escalated at Termination Management Restoration Restoration Escalated at 1.65%
Cost Cost Cost Cost 0% (minus expenses)
Year (thousands) (thousands) (thousands) (thousands) (thousands) (thousands) 2020 5,437 4,611 - 10,048 10,048 477,655 2021 5,422 4,598 - 10,020 10,020 475,516 2022 5,422 4,598 - 10,020 10,020 473,342 2023 5,422 4,598 - 10,020 10,020 471,132 2024 5,437 4,611 - 10,048 10,048 468,858 2025 5,422 4,598 - 10,020 10,020 466,574 2026 5,422 4,598 - 10,020 10,020 464,253 2027 5,422 4,598 - 10,020 10,020 461,893 2028 5,437 4,611 - 10,048 10,048 459,466 2029 5,422 4,598 - 10,020 10,020 457,028 2030 5,422 4,598 - 10,020 10,020 454,548 2031 5,422 4,598 - 10,020 10,020 452,028 2032 5,437 4,611 - 10,048 10,048 449,439 2033 5,422 4,598 - 10,020 10,020 446,835 2034 5,422 4,598 - 10,020 10,020 444,188 2035 5,422 7,358 - 12,780 12,780 438,737 2036 5,437 6,681 - 12,118 12,118 433,858 2037 5,390 - - 5,390 5,390 435,627 2038 5,390 - - 5,390 5,390 437,425 2039 5,390 - - 5,390 5,390 439,253 2040 5,404 - - 5,404 5,404 441,096 2041 5,390 - 5,390 5,390 442,985 2042 5,390 - 5,390 5,390 444,904 2043 5,390 - 5,390 5,390 446,855 2044 5,404 - - 5,404 5,404 448,824 2045 5,390 - - 5,390 5,390 450,840 2046 5,390 - - 5,390 5,390 452,889 2047 5,390 - - 5,390 5,390 454,972 2048 5,404 - - 5,404 5,404 457,075
U. S. Nuclear Regulatory Attachment 3F1213-01 Page 6 of 8 Table 3 (continued)
Decommissioning Funding Plan (thousands, dollars)
Basis Year 2013 Fund Balance $778,565 (thousands)
Annual Escalation 0.00%
Annual Earnings 1.65%
A B C D E F Total License Termination, Spent Fuel Decommissioning 50.75 50.54(bb) Management Trust Fund License Spent Fuel Site and Site Total Cost Escalated at Termination Management Restoration Restoration Escalated at 1.65%
Cost Cost Cost Cost 0% (minus expenses)
Year (thousands) (thousands) (thousands) (thousands) (thousands) (thousands) 2049 5,390 - 5,390 5,390 459,227 2050 5,390 - 5,390 5,390 461,414 2051 5,390 - 5,390 5,390 463,638 2052 5,404 - - 5,404 5,404 465,883 2053 5,390 - 5,390 5,390 468,181 2054 5,390 - 5,390 5,390 470,516 2055 5,390 - 5,390 5,390 472,890 2056 5,404 - 5,404 5,404 475,288 2057 5,390 - - 5,390 5,390 477,740 2058 5,390 - 5,390 5,390 480,233 2059 5,390 - 5,390 5,390 482,767 2060 5,404 - 5,404 5,404 485,329 2061 5,390 - 5,390 5,390 487,947 2062 5,390 - 5,390 5,390 490,608 2063 5,390 - 5,390 5,390 493,314 2064 5,404 - 5,404 5,404 496,049 2065 5,390 - 5,390 5,390 498,844 2066 5,390 - 5,390 5,390 501,685 2067 28,461 408 28,868 28,868 481,094 2068 64,677 1,319 65,995 65,995 423,037 2069 118,071 1,629 119,700 119,700 310,318 2070 89,757 997 90,754 90,754 224,684 2071 75,541 680 76,221 76,221 152,170 2072 50,584 265 50,848 50,848 103,833 2073 4,857 - 27,260 32,117 32,117 73,430 2074 93 - 20,164 20,257 20,257 54,385 Total 861,902 265,505 52,721 1,180,128 1,180,128
_ _ _ J _ _ _ j _ _ _ _ _ _ _ _ I _ _ _ I _ _
U. S. Nuclear Regulatory Attachment 3F1213-01 Page 7 of 8 Table Definitions Column A: 50.75 License Termination Cost Reflects the annual License Termination (for radiological decontamination and dismantlement) portion of the cost estimate (PSDAR, Attachment 1, Table 3.2).
Column B: 50.54(bb) Spent Fuel Management Cost Reflects the annual Spent Fuel Management (for loading and transferring the DSCs as well as ISFSI operations and maintenance) portion of the cost estimate (PSDAR, Attachment 1, Table 3.3).
Column C: Site Restoration Cost Reflects the annual Site Restoration (for dismantlement of non-contaminated site structures) portion of the cost estimate (PSDAR, Attachment 1, Table 3.4).
Column D: Total License Termination, Spent Fuel Management and Site Restoration Cost Reflects the total annual License Termination, Spent Fuel Management, and Site Restoration cost.
Calculation for Column D = A + B + C Column E: Total Cost Escalated at 0%
Reflects the total annual License Termination, Spent Fuel Management, and Site Restoration cost at a 0.0% escalation rate.
Calculation for Column E= Column D = (D)*(l +0%)A(current year- 2013)
Column F: Decommissioning Trust Fund Escalated at 1.65%
Reflects the difference between earnings on the Decommissioning Trust Fund and annual decommissioning expenditures.
A 1.65 % real rate of return fund growth rate is used for 2013 through 2074 over a 0 % cost escalation rate.
Calculation for Column F = (Previous year's fund balance) * (1 + .0165) - E (current year's decommissioning expenditures).
The cash flow calculation in Table 3 indicates that a surplus of approximately $54M is available in the DTF after 60 years. The cash flow analysis assumes withdrawals from the DTF for spent fuel management and site restoration purposes. Use of the decommissioning trust fund for spent fuel management and site restoration is based upon the Declaratory Statement issued by the Florida Public Service Commission (FPSC) (Reference 7) establishing the FPSC's intention that decommissioning funds collected from DEF customers be used for license termination, spent fuel management, and site restoration purposes. DEF recognizes that use of decommissioning funds for spent fuel management and site restoration necessitates further discussions with and approval by the NRC Staff, which includes an exemption from 10 CFR 50.82(a)(8)(i)(A). DEF has initiated these discussions.
With respect to the $93.8M estimate for ISFSI capital costs, these costs are not recoverable from the DTF. Because DEF may obtain reimbursement from the DOE for these costs, Internal Revenue Service (IRS) regulations do not permit recovery of these costs from a qualified DTF.
Instead DEF anticipates that these capital expenses will most likely be recovered through a Revised Settlement Agreement that was recently approved by the FPSC in Order No PSC 0598-FOF-EI (Reference 8). Paragraph 5e(1) of the Revised Settlement Agreement allows DEF to petition the FPSC for ISFSI capital expenses.
U. S. Nuclear Regulatory Attachment 3F1213-01 Page 8 of 8 IV. Summary The spent fuel management activities described in this updated Irradiated Fuel Management Program must be performed in conjunction with license termination activities. The annual cash flow analysis in the updated program demonstrates that the CR-3 DTF with projected earnings is sufficient to cover license termination, spent fuel management, and site restoration expenses excluding ISFSI capital costs.
DEF is an electric utility as defined in 10 CFR 50.2 and is regulated by the FPSC pursuant to Chapter 366 of the Florida Statutes. FPSC Order No PSC-13-0598-FOF-EI allows DEF to petition the FPSC for ISFSI capital costs. Financial assurance for ISFSI capital costs is provided by the Florida Statutes and the FPSC Order.
V. References
- 1. CR-3 to NRC letter, "Crystal River Unit 3 - Submittal of Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in Accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3)," dated November 29, 2011. (ADAMS Accession No. ML11339A040)
- 2. NRC to CR-3 letter, "Crystal River Unit 3 Nuclear Generating Plant - Review of Spent Fuel Management Program and the Preliminary Decommissioning Cost Estimate (TAC NO.
ME7831)," dated September 28, 2012. (ADAMS Accession No. ML12262A245)
- 3. CR-3 to NRC letter, "Crystal River Unit 3 - Certification of Permanent Cessation of Power Operations and that Fuel Has Been Permanently Removed from the Reactor," dated February 20, 2013. (ADAMS Accession No. ML13056A005)
- 4. NRC to CR-3 letter, "Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel From the Reactor,"
dated March 13, 2013. (ADAMS Accession No. ML13058A380)
- 5. CR-3 to NRC letter, "Crystal River Unit 3 - Post-Shutdown Decommissioning Activities Report," dated December 2, 2013.
- 6. AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," Atomic Industrial Forum, dated May 1986.
- 7. Issued October 9, 2013, in Docket No. 130207-El / Order No. PSC-13-0452-FOF-EI, In re:
Petition for declaratory statement with respect to use of decommissioning trust fund dollars for spent fuel and other non-radiologicaldecommissioning costs for Crystal River 3 Nuclear Plant, Florida Public Service Commission.