ML15292A256
| ML15292A256 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 11/02/2015 |
| From: | James Kim Plant Licensing Branch IV |
| To: | Entergy Nuclear Operations |
| Kim J | |
| References | |
| CAC MF5478 | |
| Download: ML15292A256 (13) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 2, 2015 Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION-CORRECTION LETTER REGARDING STAFF REVIEW OF ENTERGY'S UPDATE TO THE IRRADIATED FUEL MANAGEMENT PLAN (CAC NO. MF5478)
Dear Sir or Madam:
By letter dated October 5, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15274A379), the Nuclear Regulatory Commission (NRC) approved the updated Vermont Yankee Nuclear Power Station (VY) Irradiated Fuel Management Plan (IFMP) on a preliminary basis.
Subsequently, the licensee pointed out that the references to the use of the Decommissioning Trust Fund (DTF) for site restoration expenditures, as stated stated in the NRC transmittal letter, safety evaluation (SE) and attached spreadsheet to the SE were in error. In addition, the line item of the $145 million from the two planned external credit facilities to fund the transfer to dry storage costs was incorrectly included in the spreadsheet. Finally, due to a minor calculation error, the closing balance of the DTF in the year 2075 was overestimated by approximately $3 million. The new estimated balance in 2075 is $152,705,000.
As a result, the NRC staff has prepared a corrected transmittal letter, safety evaluation (SE) and spreadsheet attachment to the SE to reflect the corrections of the errors made. These errors did not change the staff's conclusion on approving the updated VY IFMP on a preliminary basis.
Please contact me at 301-415-4125 or James.Kim@nrc.gov if you have any questions.
Sincerely, James Kim, Project Manager Plant licensing IV-2 and Decommissioning Transition Branch Division of-Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated cc w/encls: Distribution via Listserv
VERMONT YANKEE NUCLEAR POWER STATION CORRECTED TRANSMITTAL LETTER, SAFETY EVALUATION (SE),
AND SPREADSHEET ATTACHMENT TO THE SE REGARDING STAFF REVIEW OF ENTERGY'S UPDATE TO THE IRRADIATED FUEL MANAGEMENT PLAN
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 5, 2015 Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - REVIEW OF UPDATE TO THE IRRADIATED FUEL MANAGEMENT PLAN (TAC NO. MF5478)
Dear Sir or Madam:
Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(bb), licensees of nuclear power plants within 2 years following permanent cessation of operations must submit to the U.S. Nuclear Regulatory Commission (NRC), for review and preliminary approval, the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor, until title and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. Further, in accordance with 10 CFR, Section 50.54(bb), the licensees are to notify the NRC of any significant changes in the proposed waste management program as described in the initial notification. In addition, pursuant to Section 50.82(a)(4)(i), the licensee must submit a post-shutdown decommissioning activities report (PSDAR). A site-specific decommissioning cost estimate (DCE), containing the projected cost of managing irradiated fuel, is part of the PSDAR. On January 12, 2015, ENO Nuclear Operations, Inc. (ENO, the licensee) informed the NRC that it had permanently ceased operations of the Vermont Yankee Nuclear Power Station (VY) and removed fuel from the reactor vessel (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15013A426).
By letter dated December 19, 2014 (ADAMS Accession No. ML14358A251), ENO submitted its update to the VY Irradiated Fuel Management Plan (IFMP) to the NRC. ENO concurrently submitted the PSDAR and the site-specific DCE under a separate cover letter (ADAMS Accession No. ML14357A110). As approved by exemption dated June 17, 2015 (ADAMS Accession No. ML15128A219), ENO uses the nuclear decommissioning trust fund (DTF) for license termination and irradiated fuel management expenditures. While costs associated with these activities are discussed in the IFMP, the enclosed review focuses on the costs associated with the management of the irradiated fuel. The NRC staff is conducting a separate review of the PSDAR and the site-specific DCE.
Based on its review of ENO's submittal, the NRC staff finds that the licensee's updated program to manage and provide funding for the management of all irradiated fuel is adequate and provides sufficient detail regarding the associated funding mechanisms. Further, the staff has determined that the elected actions within the program are consistent with NRC requirements for licensed possession of irradiated nuclear fuel and that these actions will be implemented in a
timely basis. Therefore, the staff concludes that the updated VY IFMP complies with 10 CFR 50.54(bb) and approves the updated plan on a preliminary basis. Further, based on the staff's calculated positive ending balance (as provided in the Attachment of the safety evaluation), the staff finds that the licensee has demonstrated reasonable assurance that funding will be available to maintain the lFMP until the fuel is transferred to the Department of Energy for permanent disposal.
The NRC staff recognizes that the IFMP analysis is based on a reported DTF balance that may fluctuate over time. Should a material decline in the DTF balance occur, the staffs analysis and findings may be impacted. However, in accordance with 10 CFR 50.82(a)(8)(vii), the licensee must annually submit to the NRC, by March 31, a report on the status of its funding for managing irradiated fuel. Further, in accordance with 10 CFR 50.54(bb), the licensee shall notify the NRC of any significant changes to the IFMP. Accordingly, the regulations provide a means of informing the NRC staff of fluctuations in the reported DTF balance and significant changes to the IFMP.
If you have any questions, please contact me at 301-415-4125 or James.Kim@nrc.gov.
Sincerely, James Kim, Project Manager Plant licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
Safety Evaluation cc w/enclosure: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION IRRADIATED FUEL MANAGEMENT PLAN ENTERGY NUCLEAR OPERATIONS. INC.
VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271
1.0 INTRODUCTION
By letter dated December 19, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14358A251), Entergy Nuclear Operations, Inc. (ENO, the licensee),
submitted its update to the Vermont Yankee Nuclear Power Station (VY) Irradiated Fuel Management Plan (IFMP) to the U.S. Nuclear Regulatory Commission (NRC). ENO concurrently submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) and the Site Specific Decommissioning Cost Estimate (DCE), under a separate cover letter (ADAMS Accession No. ML14357A110), which are currently under NRC staff review.
2.0 BACKGROUND
As stated in the VY PSDAR. the VY site is located in the town of Vernon, Vermont, in Windham County on the west shore of the Connecticut River immediately upstream of the Vernon Hydroelectric Station.
VY is a General Electric boiling water reactor nuclear steam supply system licensed to generate 1,912 megawatts-thermal. The current facility operating license for VY expires at midnight, March 21, 2032. The principal structures at VY include a reactor building, primary containment, control building, radwaste building, intake and discharge structures, turbine building, cooling towers, and main stack.
The major milestones related to the VY construction and operational history are as follows:
- Construction Permit Issued: December 11, 1967
- Operating License Issued: March 21, 1972
- Commercial Operation: November 30, 1972
- Initial Operating License Expiration: March 21, 2012
- Renewed Operating License Expiration: March 21, 2032 Enclosure
By letter dated January 12, 2015, ENO informed the NRC that it had permanently ceased operations and removed fuel from the reactor vessel at VY (ADAMS Accession No. ML15013A426). Pursuant to 10 CFR 50.51 (b), "Continuation of license," it states, in part, that "the license for a facility that has permanently ceased operations continues in effect beyond the expiration date to authorize ownership and possession of the ... utilization facility until the Commission notifies the licensee in writing that the license has been terminated."
The NRC staff notes that as approved by exemption dated June 17, 2015 (ADAMS Accession No. ML15128A219}, ENO uses the nuclear decommissioning trust fund (DTF) for license termination and irradiated fuel management expenditures. While costs associated with these activities are discussed in the IFMP, this review focuses on the costs associated with the management of irradiated fuel. A separate review of the PSDAR and the site-specific DCE is currently being performed by the NRC staff.
During the period that the license remains in effect, 10 CFR 50.51 (b) requires that ENO:
- 1. Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility including the storage, control, and maintenance of the spent fuel in a safe condition and
- 2. Conduct activities in accordance with restrictions applicable to the facility pursuant to NRC regulations and the 10 CFR Part 50 facility license.
In addition, the regulation at 10 CFR 50.82(a)(9) states that a power reactor licensee must submit an application for termination of the license at least two years prior to the license termination date and that the application must be accompanied or preceded by a license termination plan to be submitted for NRC approval.
3.0 REGULATORY EVALUATION
3.1 Regulatory Requirements Title 10 of the Code of Federal Regulations (1 O CFR) Section 50.54(bb) states, in part:
For nuclear power reactors licensed by the NRC, the licensee shall, within 2 years following permanent cessation of operation ... submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of the operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository.
Section 50.54(bb) of 10 CFR further states:
The licensee must demonstrate to NRC that the elected actions will be consistent with NRC requirements for licensed possession of irradiated nuclear fuel and that the actions
will be implemented on a timely basis. Where implementation of such actions requires NRC authorizations, the licensee shall verify in the notification that submittals for such actions have been or will be made to NRC and shall identify them. A copy of the notification shall be retained by the licensee as a record until expiration of the reactor operating license. The licensee shall notify the NRC of any significant changes in the proposed waste management program as described in the initial notification.
In addition, 10 CFR 50.82(a)(4)(i) states, in part, that the site-specific DCE that is submitted as part of the PSDAR includes the projected costs of managing irradiated fuel.
3.2 Information Submitted in Support of the IFMP Review The NRC staff reviewed the following information submitted in support of the VY IFMP:
- Estimated cost to isolate the spent fuel pool (SFP) and fuel handling systems. For the decontamination (DECON) option, the cost to isolate the SFP and fuel handling systems may be considered as part of the preparation for DECON;
- Estimated cost to construct an independent spent fuel storage installation (ISFSI) or a combination of weUdry storage;
- Estimated annual cost for the operation of the selected option (wet or dry storage or a combination of the two) until the Department of Energy (DOE) takes possession of the fuel;
- Estimated cost for the preparation, packaging, and shipping of the fuel to DOE;
- Estimated cost to decommission the spent fuel storage facility; and
- Brief discussion of the selected storage method or methods, and the estimated time for these activities.
4.0 TECHNICAL EVALUATION
ENO submitted a program for the management of irradiated fuel (Program) on March 21, 2007, and a revised Program on October 14, 2008, pursuant to 10 CFR 50.54(bb). This regulation requires power reactor licensees to submit a spent fuel management and funding program for NRC review five years prior to the expiration of a reactor operating license. At that time, the VY operating license was set to expire on March 21, 2012. On February 3, 2009, the NRC staff approved the VY Program on a preliminary basis and determined that the preliminary DCE was reasonable.
Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes to their proposed spent fuel management programs. As a result of its decision to permanently cease operations at VY, and related changes to the anticipated schedule of decommissioning and irradiated fuel management activities, and decommissioning funding
assumptions, ENO modified the VY Program and submitted it for review and preliminary approval to the NRC on December 19, 2014. This updated Program supersedes all prior versions of the Program.
Pursuant to 10 CFR 50.82(a)(4)(i), on December 19, 2014, ENO also submitted to the NRC a PS DAR for VY that included a site-specific DCE as an attachment. The site-specific DCE describes the bases for the assumptions regarding the DOE's acceptance of spent fuel from VY.
As discussed in the site-specific DCE, the Program is based on the assumption that DOE will commence acceptance of VY's spent fuel in 2026 and complete removal of all spent fuel from the site in 2052, consistent with the current DOE spent fuel management and acceptance strategy.
The site-specific DCE identifies the details, schedules, and costs of spent fuel management activities, along with license termination and site restoration activities and costs.
At the time of shutdown, there were 368 fuel assemblies residing in the reactor as part of the last operating cycle, 2,628 spent fuel assemblies stored in the SFP, and 884 assemblies stored in 13 dry storage casks on an ISFSI pad. The current ISFSI pad was constructed to support 36 dry storage casks (the pad has four additional unused storage locations to allow ENO to move the casks, if needed). VY completed fuel loading campaigns to the ISFSI in 2008, 2011, and 2012.
Following the permanent cessation of operations, the reactor building will be operated as an interim wet fuel storage facility for approximately 5-1/2 years. During this time, the spent fuel residing in the SFP will be transferred to the ISFSI. The ISFSI will remain operational until DOE is able to accept the title to the fuel and completes the transfer of the fuel offsite. Spent fuel management is estimated to cost $368 million, in nominal 2014 dollars.
According to the licensee's updated Program, the current DTF balance of $655 million (as of October 31, 2014), along with the projected fund earnings during the SAFSTOR period (assuming an annual 2-percent growth rate) and $145 million from the two planned external credit facilities to fund the transfer to dry fuel storage costs, are expected to provide reasonable assurance for funding from the DTF for the estimated license termination and spent fuel management plan.
The attached spreadsheet incorporates the annual costs associated with the two major categories of the decommissioning process (i.e., license termination and irradiated fuel management), as described in the DCE of the VY PSDAR and the IFMP. In addition, annual calculations allowing for a 2-percent real rate of return have been added. All values are in thousands of 2014 dollars.
5.0 CONCLUSION
Based on its review of EN O's submittal, the NRC staff finds that the licensee's updated program to manage and provide funding for the management of all irradiated fuel is adequate and provides sufficient detail regarding the associated funding mechanisms. Further, the staff has determined that the elected actions within the program are consistent with NRC requirements for licensed possession of irradiated nuclear fuel and that these actions will be implemented in a
timely basis. Therefore, the staff concludes that the updated VY IFMP complies with 10 CFR 50.54(bb) and approves the updated plan on a preliminary basis. Further, based on the staff's calculated positive ending balance (as provided in the Attachment of this safety evaluation), the staff finds that the licensee has demonstrated reasonable assurance that funding will be available to maintain the IFMP until the fuel is transferred to the Department of Energy for permanent disposal.
Principal Contributor: Michael Dusaniwskyj Date: october 5, 2015
Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Radiological Decontamination and Spent Fuel Management Opening DTF Radiological Spent Fuel Site Closing DTF Year 2% Interest Balance Decontamination Management Restoration Balance 2014 $654,960 $15, 165 $0 $0 $2, 133 $641,928 2015 $641,928 $81, 198 $4,318 $0 $11, 128 $567,540 2016 $567,540 $36,126 $21,893 $0 $10,190 $519,711 2017 $519,711 $10,823 $20, 176 $0 $9,774 $498,487 2018 $498,487 $9,548 $20,686 $0 $9,365 $477,618 2019 $477,618 $8,173 $20,168 $0 $8,986 $458,262 2020 $458,262 $17,763 $10,325 $0 $8,603 $438,778 2021 $438,778 $5,241 $3,996 $0 $8,591 $438,131 2022 $438,131 $5, 191 $3,996 $0 $8,579 $437,523 2023 $437,523 $5,191 $3,996 $0 $8,567 $436,903 2024 $436,903 $3,650 $4,007 $0 $8,585 $437,831 2025 $437,831 $3,591 $3,996 $0 $8,605 $438,849 2026 $438,849 $3,733 $3,996 $0 $8,622 $439,742 2027 $439,742 $3,783 $3,996 $0 $8,639 $440,603 2028 $440,603 $3,742 $4,007 $0 $8,657 $441,511 2029 $441,511 $3,733 $3,996 $0 $8,676 $442,457 2030 $442,457 $3,783 $3,996 $0 $8,694 $443,372 2031 $443,372 $3,733 $3,996 $0 $8,713 $444,356 2032 $444,356 $3,742 $4,007 $0 $8,732 $445,339 2033 $445,339 $3,783 $3,996 $0 $8,751 $446,311 2034 $446,311 $3,733 $3,996 $0 $8,772 $447,354 2035 $447,354 $3,733 $3,996 $0 $8,792 $448,417 2036 $448,417 $3,792 $4,007 $0 $8,812 $449,430 2037 $449,430 $3,733 $3,996 $0 $8,834 $450,535 2038 $450,535 $3,733 $3,996 $0 $8,856 $451,663 2039 $451,663 $3,783 $3,996 $0 $8,878 $452,761 2040 $452,761 $3,742 $4,007 $0 $8,900 $453,913 2041 $453,913 $3,733 $3,996 $0 $8,924 $455,107 2042 $455,107 $3,783 $3,996 $0 $8,947 $456,275 2043 $456,275 $3,733 $3,996 $0 $8,971 $457,517 2044 $457,517 $3,742 $4,007 $0 $8,995 $458,763 2045 $458,763 $3,783 $3,996 $0 $9,020 $460,004 2046 $460,004 $3,733 $3,996 $0 $9,045 $461,320 2047 $461,320 $3,733 $3,996 $0 $9,072 $462,663 2048 $462,663 $3,792 $4,007 $0 $9,097 $463,961 2049 $463,961 $3,733 $3,996 $0 $9,125 $465,357 2050 $465,357 $3,733 $3,996 $0 $9,153 $466,781 2051 $466,781 $3,783 $3,996 $0 $9,180 $468,182 2052 $468,182 $3,742 $4,007 $0 $9,209 $469,641 2053 $469,641 $3,583 $0 $0 $9,321 $475,379 2054 $475,379 $3,633 $0 $0 $9,435 $481,181 2055 $481, 181 $3,583 $0 $0 $9,552 $487,150 Attachment (Revised)
2056 $487,150 $3,591 $0 $0 $9,671 $493,230 2057 $493,230 $3,633 $0 $0 $9,792 $499,389 2058 $499,389 $3,583 $0 $0 $9,916 $505,723 2059 $505,723 $3,583 $0 $0 $10,043 $512,182 2060 $512, 182 $3,641 $0 $0 $10, 171 $518,712 2061 $518,712 $3,583 $0 $0 $10,303 $525,432 2062 $525,432 $3,583 $0 $0 $10,437 $532,286 2063 $532,286 $3,633 $0 $0 $10,573 $539,226 2064 $539,226 $3,591 $0 $0 $10,713 $546,347 2065 $546,347 $3,583 $0 $0 $10,855 $553,620 2066 $553,620 $3,633 $0 $0 $11,000 $560,986 2067 $560,986 $3,583 $0 $0 $11,148 $568,552 2068 $568,552 $43,277 $0 $0 $10,505 $535,780 2069 $535,780 $92,030 $0 $0 $8,875 $452,625 2070 $452,625 $104,519 $0 $0 $6,962 $355,068 2071 $355,068 $84,524 $0 $0 $5,411 $275,955 2072 $275,955 $84,953 $0 $0 $3,820 $194,822 2073 $194,822 $50,139 $0 $0 $2,894 $147,577 2074 $147,577 $512 $0 $0 $2,941 $150,006 2075 $150,006 $295 $0 $0 $2,994 $152,705 Totals $817,232 $225,526 $0 Notes: (1) All costs are in 2014 dollars (in thousands)
(2) DTF Opening Balance as of 10/31/2014, so the Year 2014 interest earned was based on 2 months.
(3) Does not assume Site Restoration expenditures from DTF (4) Spent Fuel Management amounts for 2014 thru 2020 represent the Net Effect of $145 Million from External Credits to fund the Transfer of Spent Fuel to Dry Fuel Storage Costs.
Attachment (Revised)
Please contact me at 301-415-4125 or James.Kim@nrc.gov if you have any questions.
Sincerely, IRA/
James Kim, Project Manager Plant licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated cc w/encls: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL4-2 R/F RidsACRS_MailCTR Resource RidsRgn1 Mail Center Resource RidsNrrDirslfib Resource RidsNrrDorlDpr Resource RidsNrrDorllpl4-2 Resource RidsNrrLAPBlechman Resource RidsNrrPMVermontYankee Resource MDusaniwskyj, NRR ADAMS Accession No.: ML15292A256 OGC-NLO subject OFFICE DORL/LPLIV-2/PM DORL/LPLIV-2/LA DI RS/I FIB/BC DORL/LPLIV-2/BC to comments NAME JKim PBlechman ABower AG hash MKhanna DATE 10/19/2015 10/27/2015 10/29/2015 10/27/2015 11/02/2015