ML14219A736
| ML14219A736 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee, Aerotest |
| Issue date: | 02/26/2013 |
| From: | Aerotest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| SECY RAS | |
| References | |
| 13-075, 50-228-LT, ASLBP 14-931-01-LT-BD01, RAS 26308 | |
| Download: ML14219A736 (13) | |
Text
S37AF AOI400 Dominion Energy Kewaunee, Inc. "i/* Dominion 5'000 Dominion Boulevard, Glen Allen, VA 23060 DominEON Web Address: www.dom.com February 26, 2013 Attention: Document Control Desk Serial No.13-075 U. S. Nuclear Regulatory Commission NL&OS/TJS R0 Washington, D. C. 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE. INC.
KEWAUNEE POWER STATION UPDATE TO IRRADIATED FUEL MANAGEMENT PLAN PURSUANT TO 10 CFR 50.54(bb)
By letter dated December 19, 2008 (Reference 1), and as supplemented by letter dated July 1, 2009 (Reference 2), Dominion Energy Kewaunee, Inc. (DEK) submitted the Irradiated Fuel Management Plan for Kewaunee Power Station (KPS), pursuant to 10 CFR 50.54(bb). 10 CFR 50.54(bb) requires submittal of this report five years prior to the expiration of reactor operating license. This report was submitted in 2008 because, at that time, KPS was approaching five years from operating license expiration. By letter dated September 28, 2009 (Reference 3) the NRC staff notified DEK that the Irradiated Fuel Management Plan submitted by KPS in references 1 and 2 complied with 10 CFR 50.54(bb) and approved the program on a preliminary basis.
Subsequently, on February 11, 2011, NRC issued a renewed operating license for KPS which extended the expiration date of the operating license to December 21, 2033.
By letters dated November 2, 2012, and February 25, 2013 (references 4 and 5), DEK notified NRC of its intention to permanently cease power operations at KPS on May 7, 2013. Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes in the proposed Irradiated Fuel Management Plan as described in the initial notification.
DEK's determination to permanently cease operation of KPS has resulted in changes to both the timing and choice of decommissioning method from that assumed in DEK's previous report pursuant to 10 CFR 50.75(f)(3) (Reference 6), which provided DEK's preliminary decommissioning cost analysis, and report pursuant to 10 CFR 50.54(bb),
which provided DEK's Irradiated Fuel Management Plan. DEK is submitting a new site-specific decommissioning cost analysis which includes the projected cost for managing irradiated fuel as Attachment 1 to the KPS Post-Shutdown Decommissioning Activities Report (Reference 7). The changes in the timing and choice of decommissioning methodology have also resulted in changes in the manner in which DEK proposes to provide financial assurance for spent fuel management. Therefore, an update to the Irradiated Fuel Management Plan required by 10 CFR 50.54(bb) is submitted as to this letter, superseding the prior 50.54(bb) submittals. The analysis provided in Attachment 1 to this letter indicates that the existing decommissioning trust funds for KPS are adequate to fund estimated license termination (radiological decommissioning), spent fuel management, and site restoration costs. DEK recognizes 1
Serial No.13-075 Docket No. 50-305 Page 2 of 3 that use of the decommissioning funds for spent fuel management necessitates further discussions with the NRC Staff. DEK has already initiated these discussions.
If you have any questions or require additional information please contact Mr. Craig Sly at (804) 273-2784.
Sincerely, Daniel G. Stoddard Senior Vice President - Nuclear Operations Dominion Energy Kewaunee, Inc.
Attachment:
- 1. Kewaunee Power Station Updated Irradiated Fuel Management Plan - 10 CFR 50.54(bb)
References:
- 1. Letter from J. A. Price to NRC Document Control Desk, "Report Pursuant to 10 CFR 50.54(bb)," dated December 19, 2008. [ADAMS Accession No. ML083540651]
- 2. Letter from D. A. Heacock to NRC Document Control Desk, "Response to Requests for Additional Information Concerning Reports Submitted Pursuant to 10 CFR 50.54(bb) and 50.75(f)(3)," dated July 1, 2009. [ADAMS Accession No. ML091880776]
- 3. Letter from K. D. Feintuch (NRC) to D. A. Heacock (DEK), Kewaunee Power Station - Irradiated Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. ME0253 and ME0275)," dated September 28, 2009. [ADAMS Accession No. ML092321079]
- 4. Letter from David A. Heacock (DEK) to NRC Document Control Desk, "Certification of Permanent Cessation of Power Operations," dated November 2, 2012.
- 5. Letter from D. G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Cessation of Power Operations," dated February 25, 2013.
- 6. Letter from J. A. Price (DEK) to NRC Document Control Desk, "Report Pursuant to 10 CFR 50.73(f)(3)," dated December 18, 2008. [ADAMS Accession No. ML090300120]
- 7. Letter from D. G. Stoddard (DEK) to NRC Document Control Desk, "Kewaunee Power Station Post-Shutdown Decommissioning Activities Report," dated February 26, 2013.
Commitments made in this letter: None 2
Serial No.13-075 Docket No. 50-305 Page 3 of 3 cc: U. S. Nuclear Regulatory Commission Region III 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 NRC Senior Resident Inspector Kewaunee Power Station Mr. K. D. Feintuch Project Manager U. S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Theodore Smith Project Manager U. S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-F5 11555 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 3
Serial No.13-075 Docket No. 50-305 ATTACHMENT 1 KEWAUNEE POWER STATION UPDATED IRRADIATED FUEL MANAGEMENT PLAN - 10 CFR 50.54(bb)
DOMINION ENERGY KEWAUNEE, INC.
4
Serial No.13-075 Attachment 1 Page 1 of 9 Kewaunee Power Station Irradiated Fuel Management Plan - 10 CFR 50.54(bb)
I. Background and Introduction By letter dated December 19, 2008 (Reference 1), and as supplemented by letter dated July 1, 2009 (Reference 2), Dominion Energy Kewaunee, Inc. (DEK) submitted the Irradiated Fuel Management Plan for Kewaunee Power Station (KPS), pursuant to 10 CFR 50.54(bb). 10 CFR 50.54(bb) requires submittal of this report five years prior to the expiration of reactor operating license. This report was submitted in 2008 because, at that time, KPS was approaching five years from operating license expiration. By letter dated September 28, 2009 (Reference 3) the NRC staff notified DEK that the Irradiated Fuel Management Plan for KPS complied with 10 CFR 50.54(bb) and approved the program on a preliminary basis. Subsequently, on February 11, 2011, DEK received a renewed operating license which extended the expiration of the operating license to December 21, 2033.
By letters dated November 2, 2012, and February 25, 2013 (References 4 and 5), DEK notified NRC of its intention to permanently cease power operations at KPS on May 7, 2013.
Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes in the proposed Irradiated Fuel Management Plan as described in the initial notification. As a result of DEK's determination to permanently cease operation of KPS and changes to the timing and method of decommissioning, DEK is changing the KPS Irradiated Fuel Management Plan. Therefore, DEK is submitting this plan update to notify the NRC of these changes and comply with the requirements of 10 CFR 50.54(bb).
EnergySolutions, LLC has prepared a site-specific decommissioning cost analysis for KPS. The cost analysis identifies the details, schedules, and costs of spent fuel management activities associated with the Irradiated Fuel Management Plan, along with license termination and site restoration activities and costs. This decommissioning cost analysis is provided as Attachment 1 to the Kewaunee Post-Shutdown Decommissioning Activities Report (Reference 6). The cost analysis describes the basis for the assumptions regarding the Department of Energy (DOE) acceptance of spent fuel. As discussed in the EnergySolutions cost analysis, (and subject to the assumptions, qualifications, and reservations stated in the cost analysis), the KPS updated Irradiated Fuel Management Plan is based on commencement of acceptance of spent fuel by DOE in 2021, consistent with the current DOE strategy.
5
Serial No.13-075 Attachment 1 Page 2 of 9 II. Irradiated Fuel Management Strategy Following core off-load, spent fuel will be stored in the spent fuel pool until transfer to the KPS Independent Spent Fuel Storage Installation (ISFSI). While spent fuel is stored in the spent fuel pool, spent fuel storage and handling systems will be maintained in operation. Following transfer of all spent fuel from the spent fuel pool to the KPS ISFSI, spent fuel storage and handling systems will be removed from operation. All spent fuel will be stored at the KPS ISFSI until transferred to DOE.
The Irradiated Fuel Management Plan major periods, including start and end dates and associated costs for each period are identified in Table 1 below. The identified Spent Nuclear Fuel (SNF) Periods are developed in and align with the site-specific decommissioning cost analysis (Reference 6, Attachment 1).
Table 1 Irradiated Fuel Management Plan - Summary Schedule Cost and Schedule Summary (2012 Dollars in millions)
Spent Fuel - 50.54 (bb)
Period No. Period Description Start End Years. Total Cost SNF Pd 1 Spent Fuel Planning, Cooling and Transfer to Dry Storage 7/1/2013 7/1/2020 7.00 $ 175.2 SNF Pd 2 Dry Storage During Completion SAFSTOR Preparations 7/1/2020 12/28/2020 0.49 $ 2.7 SNF Pd 3 Dry Storage During Dormancy 12/28/2020 10/19/2050 29.80 $ 161.7 SNF Pd 4 ISFSI Demolition 3/30/2073 7/31/2073 0.33 $ 2.6 Category Total _ 37.62 $ 342.2 A. Spent Fuel Planning, Cooling, and Transfer to Dry Storage (SNF Period 1)
This period begins when all spent fuel is off-loaded from the reactor vessel into the spent fuel pool and the certification of permanent defueling letter is submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(ii). During this period, measures will be planned, designed and implemented to ensure spent fuel storage and handling systems are capable of functioning to support fuel storage in the spent fuel pool, and to facilitate transfer of the spent fuel to the ISFSI. Total cost of implementation of the measures described above is expected to be approximately
$7.8 million.
Systems and structures needed to support the safe storage and transfer of spent fuel. such as security, fire protection, and environmental and radiological monitoring, will be maintained in accordance with applicable requirements.
Equipment maintenance, inspection, and operations will be performed on these systems and structures as appropriate. Annual spent fuel management costs during this period are expected to be approximately $12.5 million.
6
Serial No.13-075 Attachment 1 Page 3 of 9 During this period, the ISFSI capacity will be expanded, at a cost of approximately
$5.1 million, to accommodate transfer of all spent fuel in the SFP to dry storage.
Immediately following full core offload into the spent fuel pool, 1079 fuel assemblies will be in storage in the spent fuel pool, with an additional 256 spent fuel assemblies in storage in multi-purpose canisters (MPCs) at the ISFSI. During this period, sufficient NUHOMS Model 102 or HSM-H Horizontal Storage Modules (HSMs) and NUHOMS KPS32PT or KPS24PT Dry Shielded Canisters will be procured as required to support the transfer of all spent fuel to the ISFSI in accordance with the fuel movement schedule as outlined below in Table 2 "Spent Fuel Shipping Schedule." The total cost to move all spent fuel from the spent fuel pool to the ISFSI is expected to be $72.7 million.
During this period, spent fuel pool modifications related to Fukushima beyond design basis efforts will be implemented at an expected cost of $2.3 million All spent fuel will be in storage at the ISFSI by the completion of SNF Period 1.
B. Dry Storage during Completion of SAFSTOR Preparations (SNF Period 2)
During this period, spent fuel will have been transferred to the ISFSI while SAFSTOR preparations are completed. Programs and procedures needed to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Equipment maintenance, monitoring, inspection, and operations will be performed as necessary. Annual spent fuel management costs during this period are expected to be $5.4 million.
C. Dry Storage during Dormancy (SNF Period 3)
This period begins when the plant is in SAFSTOR. The spent fuel remains in the ISFSI while the plant is in a dormant SAFSTOR condition. Programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Equipment maintenance, monitoring, inspection, and operations will be performed as necessary. Annual spent fuel management costs during this period are expected to be $5.4 million.
As stated in the site specific decommissioning cost analysis referenced above, DEK assumes that the DOE will begin accepting spent fuel during this period.
Shipments of fuel to the DOE will be from the ISFSI as outlined below in Table 2, "Spent Fuel Shipping Schedule." Upon completion of this period, all spent fuel will have been transferred to the DOE. The total cost of fuel shipments to the DOE from the KPS ISFSI is expected to be approximately $0.4 million.
7
Serial No.13-075 Attachment 1 Page 4 of 9 Table 2 Spent Fuel Shipping Schedule Kewiaunee Power Station Unit I S4A FS`OR20hodoiE;Ly Spent Fuel Shipping .hedtile 2021 DOE Acm~ptance. Dry Starw~
U U I.I.:sI 1.UN U I) U 44 64 1.1-4 64 1.125 0 0 0 2010 0 64 997 128 0 0 0 45 4 128 0 0 2011 914 256 1.170 0 0 2012 44 0 0 9,58 256 1.214 0 0 0 0 2'013 121 0 0 1.079 2,56 1.3115 0 2014 0 6 IQ2 887 448 1.335 0 0 0 2015 0 0 0 887 448 1,335 0 0 0 2016 0 0 0 887 448 1.335 0 0 0 2017 0 18 576 311 1024 1.335 0 0 0 2018 0 0 0 311 1024 1,335 0 0 0 2019 0 13 311 0 1335 1.335 0 0 0 2020 o 0 0 0 1335 1.335 0 0 0 2021 0 0 0 0 1271 1.271 6M 0 64 2022 0 0 0 0 1271 1,271 0 0 0 2023 0 0 0 0 1239 1,239 32 0 32 2024 0 0 0 0 1207 1.207 32 0 32 2025 0 0 0 0 1143 j,.143 64 0 64 2026 0 0 0 0 1047 1.047 % 0 06 2-027 0 0 0 0 983 983 64 0 64 2028 0 0 0 0 919 919 64 0 6-4 20219 o 0 0 0 M.5 855 64 0 64 2030 0 0 0 0 823 823 32 0 32 2031 0 0 0 0 759 759 64 0 64 2032 0 0 0 0 695 695 64 0 64 2033 0 o 0 0 631 631 64 0 64 2034 0 0 0 5o9 599 32 0 32 2035 0 0 0 0 567 567 32 0 32 2036 0 0 0 0 535 535 32 0 32 2037 0 0 0 0 503 503 32 0 32 2038 0 0 0 0 439 439 64 0 64 2019 0 0 0 0 407 407 32 0 32 2040 0 0 0 0 375 375 32 0 32 2041 0 0 0 0 143 343 32 0 32 2042 0 0 0 0 279 '279 64 0 64 2043 0 0 0 0 247 247 32 0 32 2044 0 0 0 0 215 215 32 0 32 124W 0 0 0 0 183 183 32 0 32 2046 0 0 0 0 151 151 32 0 32 2047 0 0 0 0 87 87 64 0 64 2048 0 0 0 0 55 55 32 0 32 2049 0 0 0 0 23 23 32 0 32 2050 0 0 0 0 0 0 23 0 23 2051 0 0 0 0 0 0 0 0 0 No. Pknt SU)NIC.s fir tuel 37 Na. 1bs S/P MPCi fot crrc' 0 8
Serial No.13-075 Attachment 1 Page 5 of 9 D. ISFSI Decommissioning (SNF Period 4)
The KPS ISFSI was designed and installed under a general license in accordance with 10 CFR Part 72, "Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High Level Radioactive Waste, and Reactor-Related Greater than Class C Waste." The spent fuel storage casks are licensed in accordance with an NRC Certificate of Compliance for the Standardized NUHOMS Spent Fuel Storage System. After DOE acceptance of the spent fuel, any radiological decommissioning associated with the ISFSI would be accomplished as a part of site decommissioning under the Part 50 license. Under these assumptions, the total cost of decommissioning the KPS ISFSI is expected to be approximately $3.2 million which includes both radiological and non-radiological costs.
II1. Financial Assurance The site-specific decommissioning cost analysis prepared by EnergySolutions projects the total cost of Spent Fuel Management activities to be $342.2 million in 2012 dollars.
A cash flow analysis provided in Table 3 below shows that the KPS decommissioning trust fund, with projected earnings, is sufficient to cover the estimated costs of license termination (radiological decommissioning), spent fuel management, and site restoration.
The cash flow analysis, which is based on the site-specific decommissioning cost analysis referenced above, applies an allowed 2% real rate of return during the decommissioning period and reflects the starting balance of the KPS decommissioning trust fund as of December 31, 2012.
Table 3 Annual Cash Flow Analysis Kewaunee - SAFSTOR Methodology Annual Cash Flow Analysis - Total Decomissioning, Spent Fuel Management and Site Restoration Costs (In Millions of Dollars $)
Date Amount Current Value of Qualified Fund as of 12/3112012 $ 578.609 Current Value of Non Qualified Fund as of 12131/2012 $ -
Total Trust Fund Balances as of 12/31/2012 $ 578.609 NRC Minimum as of 1213112012 $ 449.687 Start of Decommissioning 7/1/2013 Decommissioning Funds value at Calculation date 12131/2012 $ 578.609 Total Estimated Costs at Calculation date 12131/2012 $ 919.872 0.000% Cost Escalation Rate Start of Decom to End of Decom - Assumes 0% Decom cost escalation rate 2.000% Fund Growth Rate Start of Decom to End of Decom - Assumes 2% Real Rate of Return (RRoR) 9
Serial No.13-075 Attachment 1 Page 6 of 9 Table 3 (cont'd)
Annual Cash Flow Analysis Kewaunee - SAFSTOR Methodology Annual Cash Flow Analysis -Total Decomissioning, Spent Fuel Management and Site Restoration Costs (in Millions of Dollars $)
Column 2 Column 3 Column 4 Column 5 Column 6 Column 8 Column 1 Earnings Total Total Total Total Column 7 Total Beginning on License Termination Spent Fuel Mgt Site Restoration SAFSTOR End SAFSTOR of Year Trust Funds Expenditures Expenditures Expenditures Expenditures . of Year Expenditures Year Balance (Reflects 2% RRoR) (Reflects 00/6Esc) (Reflects 0% Esc) (Reflects 00/6Esc) (Reflects 0% Esc) Balance (in 1213112012 $)
2013 $ 578.609 $ 11.102 $ 30.849 $ 16.200 $ $ 47.048 $ 542.662 $ 47.048 2014 $ 542.662 $ 9.875 $ 68.819 $ 29.023 $ $ 97.842 $ 454.695 $ 97.842 2015 $ 454.695 $ 8.787 $ 4,492 $ 26.163 $ $ 30.655 $ 432.828 $ 30.655 2016 $ 432.828 $ 8.335 $ 4.492 $ 27.700 $ $ 32.192 $ 408.971 $ 32.192 2017 $ 408.971 $ 7.858 $ 4.492 $ 27.671 $ $ 32.163 $ 384.666 $ 32.163 2018 $ 384.666 $ 7.403 $ 4.492 $ 24.510 $ $ 29.002 $ 363.067 $ 29.002 2019 $ 363.067 $ 7.037 $ 4.492 $ 17.963 $ $ 22.455 $ 347.649 $ 22.455 2020 $ 347.649 $ 6.684 $ 18.169 $ 8.723 $ $ 26.891 $ 327.441 $ 26.891 2021 $ 327.441 $ 6.478 $ 1.714 $ 5.404 $ $ 7.119 $ 326.801 $ 7.119 2022 $ 326.801 $ 6.465 $ 1.714 $ 5.404 $ $ 7.119 $ 326.147 $ 7.119 2023 $ 326,147 $ 6.452 $ 1.714 $ 5.404 $ $ 7.119 $ 325.480 $ 7.119 2024 $ 325.480 $ 6.438 $ 1.714 $ 5.404 $ $ 7.119 $ 324.800 $ 7.119 2025 $ 324.800 $ 6.425 $ 1.714 $ 5.404 $ $ 7.119 $ 324.106 $ 7.119 2026 $ 324.106 $ 6.411 $ 1.714 $ 5.404 $ $ 7.119 $ 323.399 $ 7.119 2027 $ 323.399 $ 6.397 $ 1.714 $ 5.404 $ $ 7.119 $ 322.677 $ 7.119 2028 $ 322.677 $ 6.382 $ 1.714 $ 5.404 $ $ 7.119 $ 321.941 $ 7.119 2029 $ 321.941 $ 6.368 $ 1.714 $ 5.404 $ $ 7.119 $ 321.190 $ 7.119 2030 $ 321.190 $ 6.353 $ 1.714 $ 5.404 $ $ 7.119 $ 320.424 $ 7.119 2031 $ 320.424 $ 6.337 $ 1.714 $ 5.404 $ $ 7.119 $ 319.642 $ 7.119 2032 $ 319.642 $ 6.322 $ 1.714 $ 5.404 $ $ 7.119 $ 318.846 $ 7.119 2033 $ 318.846 $ 6.298 $ 2.517 $ 5.404 $ $ 7.922 $ 317.222 $ 7.922 2034 $ 317.222 $ 6.273 $ 1.714 $ 5.404 $ $ 7.119 $ 316.376 $ 7.119 2035 $ 316.376 $ 6.256 $ 1.714 $ 5.404 $ $ 7.119 $ 315.514 $ 7.119 2036 $ 315.514 $ 6.239 $ 1.714 $ 5.404 $ $ 7.119 $ 314,635 $ 7.119 2037 $ 314.635 $ 6.222 $ 1.714 $ 5.404 $ $ 7.119 $ 313.738 $ 7.119 2038 $ 313.738 $ 6.204 $ 1.714 $ 5.404 $ $ 7.119 $ 312.823 $ 7.119 2039 $ 312.823 $ 6.185 $ 1.714 $ 5.404 $ $ 7.119 $ 311.889 $ 7.119 2040 $ 311.889 $ 6.167 $ 1.714 $ 5.404 $ $ 7.119 $ 310.937 $ 7.119 2041 $ 310.937 $ 6.148 $ 1.714 $ 5.404 $ $ 7.119 $ 309.966 $ 7.119 2042 $ 309.966 $ 6.128 $ 1.714 $ 5.404 $ $ 7.119 $ 308.976 $ 7.119 2043 $ 308.976 $ 6.108 $ 1.714 $ 5.404 $ $ 7.119 $ 307.966 $ 7.119 2044 $ 307.966 $ 6.088 $ 1.714 $ 5.404 $ $ 7.119 $ 306.935 $ 7.119 2045 $ 306.935 $ 6.068 $ 1.714 $ 5.404 $ $ 7.119 $ 305.884 $ 7.119 2046 $ 305.884 $ 6.047 $ 1.714 $ 5.404 $ $ 7.119 $ 304.812 $ 7.119 2047 $ 304.812 $ 6.025 $ 1.714 $ 5.404 $ $ 7.119 $ 303.719 $ 7.119 2048 $ 303.719 $ 6.003 $ 1.714 $ 5.404 $ $ 7.119 $ 302.604 $ 7.119 2049 $ 302.604 $ 5.978 $ 1.714 $ 5.662 $ $ 7.377 $ 301.205 $ 7.377 2050 $ 301.205 $ 5.960 $ - 1.721 $ 4.676 $ - $ 6.398 $ 300.768 1 $ 6.398 10
Serial No.13-075 Attachment 1 Page 7 of 9 Table 3 (cont'd)
Annual Cash Flow Analysis Kewaunee - SAFSTOR Methodology Annual Cash Flow Analysis -Total Decomissioning, Spent Fuel Management and Site Restoration Costs (In Millions of Dollars S)
Column 2 Column 3 Column 4 Column S Column 6 Column 8 Column I Earnings Total Total Total Total Column 7 Total Beginning on License Termination Spent Fuel Mgt Site Restoration SAFSTOR End SAFSTOR of Year Trust Funds Expenditures Expenditures Expenditures Expenditures of Year Expenditures Year Balance (Reflects 2%oRRoR) (Reflects 0% Esc) (Reflects 0% Esc) (Reflects 0% Esc) (Reflects 0% Esc) Balance (in 12/3112012 $)
2051 $ 300.768 $ 5.998 $ 1.731 $ $ $ 1.731 $ 305.035 $ 1.731 2052 $ 305.035 $ 6.083 $ 1.731 $ $ $ 1.731 $ 309.388 $ 1.731 2053 $ 309.388 $ 6.170 $ 1.731 $ $ $ 1.731 $ 313.827 $ 1.731 2054 $ 313.827 $ 6.259 $ 1.731 $ $ $ 1.731 $ 318.356 $ 1.731 2055 $ 318.356 $ 6.350 $ 1.731 $ $ $ 1.731 $ 322.975 $ 1.731 2056 $ 322.975 $ 6.442 $ 1.731 $ $ $ 1.731 $ 327.686 $ 1.731 2057 $ 327.686 $ 6.536 $ 1.731 $ $ $ 1.731 $ 332.492 $ 1.731 2058 $ 332.492 $ 6.633 $ 1.731 $ $ $ 1.731 $ 337.394 $ 1.731 2059 $ 337.394 $ 6.731 $ 1.731 $ $ $ 1.731 $ 342.393 $ 1.731 2060 $ 342.393 $ 6.831 $ 1.731 $ $ $ 1.731 $ 347.493 $ 1.731 2061 $ 347.493 $ 6.933 $ 1.731 $ $ $ 1.731 $ 352.695 $ 1.731 2062 $ 352.695 $ 7.037 $ 1,731 $ $ $ 1.731 $ 358.001 $ 1.731 2063 $ 358.001 $ 7.143 $ 1.731 $ $ $ 1.731 $ 363.413 $ 1.731 2064 $ 363.413 $ 7.251 $ 1.731 $ $ $ 1.731 $ 368.933 $ 1.731 2065 $ 368.933 $ 7.361 $ 1.731 $ $ $ 1.731 $ 374.563 $ 1.731 2066 $ 374.563 $ 7.474 $ 1.731 $ $ $ 1.731 $ 380.307 $ 1.731 2067 $ 380.307 $ 7.474 $ 13.169 $ $ $ 13.169 $ 374.612 $ 13.169 2068 $ 374.612 $ 7.266 $ 22.670 $ $ $ 22.670 $ 359.208 $ 22.670 2069 $ 359.208 $ 6.507 $ 67.698 $ $ $ 67.698 $ 298.017 $ 67.698 2070 $ 298.017 $ 4.874 $ 108.612 $ $ $ 108.612 $ 194.279 $ 108.612 2071 $ 194.279 $ 2.893 $ 99.265 $ $ $ 99.265 $ 97.907 $ 99.265 2072 $ 97.907 $ 1.626 $ 11.087 $ $ 22.132 $ 33.219 $ 66.314 $ 33.219 2073 $ 66.314 $ 1.172 $ 0.109 $ 2.622 $ 12.671 $ 15.402 ,. $ 15.402 Cash Flow Cost Estimate (in 12/31120125)
Cash Flow Cost Estimate (Reflects 0% Escalation ', 0W, : :
Estimated Fund Balance - end of Decommissioning (Reflects 0.0% Escalation & 2.0% Real Rate of Return Fund Growth Rate)
Estimated Fund Balance - end of Decommissioning (Discounted to 2013 $) 1 Discount Rate = 2.00%
Table 3 Definitions:
Column 1: Be-ginning of Year Balance Reflects the beginning-of-year Trust Fund balance at a 0.0% escalation rate and 2% Real Rate of Return (RRoR) on fund growth.
Column 2: Earnings on Trust Funds Reflects earnings on funds remaining in the trust. A 2.0% RRoR Fund growth rate is used for 2013 through 2073 which reflects the allowed 2.0% real rate of return over a 0.0% cost escalation rate. The annual 2.0% RRoR earnings are calculated on the beginning balance plus 50% of the projected annual expenditure for each year.
Column 3: Total License Termination Expenditures Reflects the annual License Termination Plan cost portion of the EnergySolutions Cost Analysis (Attachment 1 to Reference 6) at a 0.0% escalation rate.
11
Serial No.13-075 Attachment 1 Page 8 of 9 Column 4: Total Spent Fuel Management Expenditures Reflects the annual Irradiated Fuel Management Plan cost portion of the EnergySolutions Cost Analysis (Attachment 1 to Reference 6) at a 0.0% escalation rate.
Column 5: Total Site Restoration Expenditures Reflects the annual Site Restoration Plan cost portion of the EnergySolutions Cost Analysis (Attachment 1 to Reference 6) at a 0.0% escalation rate.
Column 6: Total SAFSTOR Expenditures Reflects the annual Total Decommissioning Plan cost from the EnergySolutions Cost Analysis (Attachment 1 to Reference 6) at a 0.0% escalation rate.
Column 7: End of Year Balance Reflects the end of year Trust Fund Balance after all projected earnings are added and all projected expenditures are deducted for the year specified at a 0.0% escalation rate and 2.0% RRoR on fund growth.
Column 8: Total SAFSTOR Expenditures Reflects the total of License Termination, Spent Fuel Management, and Site Restoration annual costs from the EnergySolutions Cost Analysis (Attachment 1 to Reference 6) in 2012 dollars.
This cash flow analysis indicates that approximately $52 million will remain in the KPS decommissioning trust fund after all decommissioning activities including radiological decommissioning, spent fuel management, and site restoration are completed based on a 0.0% escalation rate and a 2.0% Real Rate of Return on Trust Funds.
A Parent Support Agreement in the amount of $60 million is in place for the purposes of supplementing DEK in the event of an operational outage lasting six months or more and for decommissioning of the plant. This Parent Support Agreement will remain in place and provides additional financial assurance for decommissioning and spent fuel management.
IV. NRC Approvals This spent fuel management plan assumes withdrawals from the decommissioning trust for spent fuel management purposes. DEK recognizes that use of the decommissioning funds for spent fuel management necessitates further discussions with and approval by the NRC Staff, which may include an exemption from 10 CFR 50.82(a)(8)(i)(A). DEK has initiated these discussions.
In accordance with 10 CFR 50.82(a)(8)(vii), DEK will annually submit to the NRC by March 3 1 st a report on the status of the funding for managing spent fuel. The report will include, current through the end of the previous calendar year, the amount of funds accumulated to cover the cost of managing the spent fuel, the projected cost of managing spent fuel until title to the fuel and possession of the fuel is transferred to the 12
Serial No.13-075 Attachment 1 Page 9 of 9 Secretary of Energy, and if the funds accumulated do not cover the projected cost, a plan to provide additional funding assurance using one of the methods allowed by NRC regulations.
V. Summary The spent fuel management activities described in this updated Irradiated Fuel Management Plan must be performed in conjunction with license termination activities.
The annual cash flow analysis in this plan demonstrates that the KPS decommissioning trust fund with projected earnings is sufficient to cover the estimated costs of License Termination (radiological decommissioning), Spent Fuel Management, and .Site Restoration.
References:
- 1. Letter from J. A. Price to NRC Document Control Desk, "Report Pursuant to 10 CFR 50.54(bb)," dated December 19, 2008. [ADAMS Accession No. ML083540651]
- 2. Letter from D. A. Heacock to NRC Document Control Desk, "Response to Requests for Additional Information Concerning Reports Submitted Pursuant to 10 CFR 50.54(bb) and 50.75(f)(3)," dated July 1, 2009. [ADAMS Accession No. ML091880776]
- 3. Letter from K. D. Feintuch (NRC) to D. A. Heacock (DEK), "Kewaunee Power Station - Irradiated Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. ME0253 and ME0275)," dated September 28, 2009.
[ADAMS Accession No. ML092321079]
- 4. Letter from David A. Heacock (DEK) to NRC Document Control Desk, "Certification of Permanent Cessation of Power Operations," dated November 2, 2012.
- 5. Letter from D. G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Cessation of Power Operations," dated February 25, 2013.
- 6. Letter from D. G. Stoddard (DEK) to NRC Document Control Desk, "Kewaunee Power Station Post-Shutdown Decommissioning Activities Report," dated February 26,2013.
13