ML16081A136

Independent Spent Fuel Storage Installation, Decommissioning Funding Plan

ML16081A136
Person / Time
Site:	Summer, 07201038
Issue date:	03/18/2016
From:	Crosby M Santee Cooper
To:	Document Control Desk, NRC/NMSS/SFST
References
Download: ML16081A136 (12)

Text

sa~ntee cooper March 18, 2016 Michael R. Crosby U. S. Nuclear Regulatory Commission Senior Vice President Document Control Desk Nuclear Energy Director, Division of Spent Fuel Storage and Transportation fax: (843) 761-4126 Office of Nuclear Material Safety and Safeguards (843)by 761-7037r~co Washington, D. C. 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NOs. 50-395 and 72-103 8 OPERATING LICENSE NO. NPF-12 INDEPENDENT SPENT FUEL STORAGE INSTALLATION DECOMMISSIONING FUNDING PLAN Ladies and Gentlemen:

The South Carolina Public Service Authority (Authority) and South Carolina Electric & Gas Company (SCE&G) have ownership interests of one-third and two-thirds, respectively, in the Virgil C. Summer Nuclear Station, Unit 1 Independent Spent Fuel Storage Installation (ISFSI). As provided in 10 CFR 72.30 (b), each holder of, or applicant for, a license under this part must submit a. decommissioning funding plan for Nuclear Regulatory Commission (NRC) review and approval. The enclosed ISFSI Decommissioning Funding Plan (please see Attachment) provides financial assurance for the Authority's one-third share.

SCE&G will file the required decommissioning funding plan relative to its two-thirds ownership share in a separate submittal.

The estimated cost to decommission the V.C. Summer, Unit 1 ISFSI and release it for unrestricted use is $6.4 million (please see Table 2 in the Attachment). The Authority's one-third share is $2.1 million. The Attachment contains cost estimate details, including key assumptions, a description of the method of assuring funds for decommissioning, and a certification that financial assurance has been provided in the amount of the cost estimate for decommissioning.

This letter contains no new regulatory commitments. If there are any questions concemning this report, please contact me at (843) 761-4126.

Michael R. Crosby Senior Vice President Nuclear Energy MRC:trw cc:

Catherine Haney 0*

Shawn A. Williams Mark Lombard NRC Resident Inspector One Riverwood Drive Moncks Corner, SC 29461-2901

] (843) 761-8000 P.O. Box 2946101 Moncks Corner, SC 29461-6101

ATTACHMENT 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ISFSI DOCKET 72-1038 SOUTH CAROLINA PUBLIC SERVICE AUTHORITY

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,t1] with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Virgil C. Summer Nuclear Station, Unit 1 (V.C.

Summer) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate;

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The operating license for V.C. Summer is currently set to expire on August 6, 2042.

Approximately 2,757 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed with spent fuel planned to be transferred to the dry storage modules located at the ISFSI, to support continued plant operations. The ISFSI will be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[21).

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2U.S.

Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

Page 1 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Completion of the ISFSJ decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (thle "queue") in which it was discharged from the reactor. [3]

In January 2013, the DOE issued the "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission on America's Nuclear Future and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel... "[ ]The report stated,

"[W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:... [A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; Based upon DOE's latest strategy (and the potential for other, consent-based siting of consolidated interim storage facilities), South Carolina Electric & Gas (SCE&G) believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. SCE&G's current spent fuel management plan for the V.C. Summer spent fuel is based in general upon the spent fuel being fully removed from the V.C.

Summer site by 2095.

SCE&G's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. If DOE' s failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

u.s. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a)... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as... "

""Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S.

DOE, January 11, 2013 Page 2 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The V.C. Summer ISFSI is based upon Holtec International's (Holtec) HI-STORM FW System for the dry storage of used nuclear fuel. The HI-STORM FW System consists of a sealed metallic multi-purpose canister (MPC) contained within an overpack constructed from a combination of steel and concrete. The MPC can accommodate up to 37 undamaged Zircaloy-clad pressurized water fuel assemblies. The overpack provides structural protection, cooling, and radiological shielding for the MPC.

The HI-STORM FW overpack is a rugged, heavy-walled cylindrical vessel. The main structural function of the storage overpack is provided by carbon steel, and the main shielding function is provided by plain concrete. The overpack plain concrete is enclosed by a steel weldment of cylindrical shells, a thick baseplate, and a top annular plate. A set of four equally spaced radial connectors join the inner and outer shells and define a fixed width annular space for placement of concrete. The overpack lid also has concrete to provide neutron and gamma shielding.

The on-site ISFSI at V.C. Summer is located west of the Fuel Handling Building (FHB) and northeast of Warehouses A and B in an expansion of the plant Protected Area. The ISFSI pad has been sized to store 98 HI-STORM FW storage casks with each cask capable of storing 37 Pressurized Water Reactor spent fuel assemblies, which will meet V.C. Summer's spent fuel storage needs over the 60-year licensed life of the plant.

The current spent fuel management plan for the V.C. Summer spent fuel would result in 75 spent fuel storage casks being placed on the ISFSI pad during plant operations. This conservatively assumes that no fuel is removed from the site by the DOE during plant operations or during the nine years of pool operations after the permanent cessation of operations.

The 75 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

Page 3 of 10.

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2042) and the DOE's spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[ 5' The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 5 of the 75 Holtec overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 157 offloaded assemblies, 37 assemblies per cask which results in 5 overpacks). It is assumed that these are the final casks offioaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.E61 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

There is no known subsurface material (soil contamination) in the immediate vicinity of the ISFSI pad that will require remediation to meet the criteria for license termination. As such, there is no allowance for soil remediation in the estimate.

Costs are reported in 2016 dollars and based upon an internal decommissioning analysis being prepared for V.C. Summer in 2Ol6.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. SCE&G, as licensee, will oversee the site activities.

HI-STORM FW FSAR, Holtec International, Report HI-21 14830, Rev.2, at page 2-83 (Accession Number ML13177A428) 6HI-STORMV FW FSAR, Holtec International, Report HI-21 14830, Rev. 2, at page 2-84 (Accession Number ML13177A428)

Page 4 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Low-level radioactive waste disposal costs are based on SCE&G's currently negotiated rates with the Atlantic Compact and other waste handling service providers.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[71 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

• An initial planning phase in which the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the remediation (overpack disposition) developed.

• The remediation phase includes the cost for craft labor to demolish the activated overpacks, package the steel and concrete in certified waste containers, transportation to the Atlantic Compact Regional Waste site in Barnwell, South Carolina or a bulk waste processing site in Tennessee, for disposal, as well as the costs for the supporting equipment, materials and supplies.

• The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), SCE&G's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2096, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at V.C. Summer ISFSI are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUJREG-1757, Volume 3, Revision 1, February 2012.

Page 5 ofl10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, the Authority will rely upon the money available in its deconmnissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

• Although the decommissioning trust fund is for radiological decommissioning (i.e., post-shutdown) costs only, the ISFSI decommissioning is a radiological cost.

Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by the Authority, including ISFSL decommissioning costs.

• The projected minimum certification amount, calculated pursuant to 10 CFR 50.75(c) required to demonstrate reasonable assurance of funds for decommissioning V.C. Summer is $494,859,960 (2014 dollars), based upon the NRC's latest figures for calculating that value. The Authority's one-third share is

$164,953,320.

• Based upon the Authority's V.C. Summer decommissioning trust fund balance as of December 31, 2014 as reported in the Authority's March 27, 2015 biennial Decommissioning Funding Report and considering an average real rate of return of 0.4 percent on the fund between December 31, 2014 and 2049 when plant decommissioning activities are completed, the trust fund is projected to contain a

$47,966,502 surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10 CFR 50.75(c). This surplus is more than sufficient to complete the future decommissioning of the ISFSJ (estimated cost provided in Table 2).

• The Authority will continue to assess the decommissioning trust fund status in accordance with NRC requirements (e.g. 10 CFR 50.75(b)(2), 10 CFR 50.75(f)(1), 10 CFR 72.30(c)) and projected surplus, to account for the continued assurance of adequate funds for ISFSJ decommissioning. Any adjustments to the cost estimate and funding levels will be made in connection with the triennial filing required pursuant to 10 CFR 72.3 0(c). To the extent any specific regulatory actions are necessary at the time of withdrawal from the trust fund of the amount necessary for ISFSI decommissioning, the Authority will pursue such actions.

The Authority hereby certifies that financial assurance for decommissioning its one-third share of V.C. Summer's ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described above.

Page 6 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual LItem Length (fi)

Width (ft)

Radioactivity ISFSI Pad 251.5 129.0 No ISFSI Storage Overpack (Holtec FW)

Item Value Notes Overall Height (inches) 239.5 Dimensions are nominal Outside Diameter (inches) 139 Dimensions are nominal Inside Diameter (inches) 81 Dimensions are nominal Quantity 79 75 Spent fuel + 4GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 5 used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,705,088 Concrete and steel Other Low-Level Radioactive Waste (pounds) 1,766 DAW, filters and other secondary waste Lox4-Level Radioactive Waste (total packaged volume) 30,414 Cubic feet Low-Level Radioactive Waste (packaged density) 56 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

No residual radioactivity Number of Overpacks used for GTCC storage 4

No residual radioactivity Page 7 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Afttachment Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2016 dollars)

Volume Person-Hours IClass A

Oversight and Removal Packaging Transport JDisposal Other Total (cubic feet)

Craft jContractor Decommissioning Contractor Planning (characterization, specs and procedures) 290 290 1,096 Decontamination/Demolition (activated cask disposition) 132 95 147 2,096 29 2,499 30,414 2,135-License Termination (radiological surveys) 1,313 1,313 11,060-Subtotal 132 95 147 2,096 1,632 4,102 30,414 13,195 1,096 Supporting Costs NRC and NRC Contractor Fees and Costs 400 400

-776 Insurance 117 117 Property Taxes Plant Energy Budget 46 46-Non-Labor Overhead 12 12---

Corporate A&G 25 25---

Security (industrial) 206 206 5,013 SCE&G Oversight Staff 235 235 3,803 Subtotal 1,042 1,042 9,592 Total (w/o contingency) 132 95 147 2,096 2,674 5,144 30,414 13,195 10,688 Total (w/25% contingency) 165 119 184 2,620 3,342 6,430 Page 8 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Table 3 Financial Assurance 10 CFR 50.75(b) & (c) Decommissioning Estimate (2014 Dollars):

Authority's One-Third Share of Decommissioning Estimate (2014 Dollars):

Market value of the external trust fund at December 31, 2014:

$494,859,960

$164,953,320

$123, 008,921 Schedle o annal aount remini 4

tobDollecte 2014 Dollars Beginning Decommissioning, Annual Ending Real Rates Year Balance Expenditures Deposits Earnings Balance of Return 2015 123,008,921 2,198,280 511,102 125,718,303 0.0042 2016 125,718,303 2,626,140 719,109 129,063,552 0.0057 2017 129,063,552 2,626,140 521,417 132,211,109 0.0040 2018 132,211,109 2,626,140 387,379 135,224,627 0.0029 2019 135,224,627 2,626,140 508,445 138,359,212 0.0038 2020 138,359,212 2,626,140 641,987 141,627,338 0.0046 2021 141,627,338 2,626,140 642,988 144,896,467 0.0045 2022 144,896,467 2,626,140 698,401 148,221,007 0.0048 2023 148,221,007 2,626,140 752,963 151,600,110 0.0051 2024 151,600,110 2,626,140 754,969 154,981,219 0.0050 2025 154,981,219 2,626,140 756,308 158,363,667 0.0049 2026 158,363,667 2,626,140 741,142 161,730,949 0.0047 2027 161,730,949 2,626,140 740,728 165,097,817 0.0046 2028 165,097,817 2,626,140 739,638 168,463,595 0.0045 2029 168,463,595 2,626,140 721,024 171,810,759 0.0043 2030 171,810,759 2,626,140 718,169 175,155,068 0.0042 2031 175,155,068 2,626,140 714,633 178,495,841 0.0041 2032 178,495,841 2,626,140 692,564 181,814,545 0.0039 2033 181,814,545

_________2,626,140 687,259 185,127,944 0.0038 2034 185,127,944 2,626,140 662,758 188,416,842 0.0036 2035 188,416,842 2,626,140 655,691 191,698,672 0.0035 2036 191,698,672 2,626,140 628,772 194,953,584 0.0033 Page 9 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1ltacmn Attachment 2037 194,953,584 2,626,140 619,952 198,199,676 0.0032 2038 198,199,676 2,626,140 590,635 201,416,451 0.0030 2039 201,416,451 2,626,140 580,079 204,622,671 0.0029 2040 204,622,671 2,626,140 548,389 207,797,200 0.0027 2041 207,797,200 2,626,140 536,117 210,959,456 0.0026 2042 210,959,456 9,818,650 478,715 201,619,521 0.0024 2043 201,619,521 23,564,760 405,965 178,460,726 0.0023 2044 178,460,726 23,564,760 322,184 155,218,150 0.0021 2045 155,218,150 23,564,760 260,674 131,914,064 0.0020 2046 131,914,064 23,564,760 192,862 108,542,165 0.0018 2047 108,542,165 23,564,760 142,762 85,120,167 0.0017 2048 85,120,167 23,564,760 91,102 61,646,509 0.0015 2049 61,646,509 13,746,110 66,103 47,966,502 0.0014 Beginning Decommissioning

• Annual 1Ending Year Balance 1 Expenditures jDeposits Earnings jBalance Total 123,008,921 164,953,320 170,477,920 J19,432,981 47,966,502 The preceding table is excerpted from the Authority's March 27, 2015 Decommissioning Funding Status Report for V.C. Summer Nuclear Station, Unit 1 in accordance with 10 CFR 50.75(f)(1) Reporting and Recordkeeping for Decommissioning Planning and is provided for illustrative purposes.

The market value of the external trust fund at December 31, 2015 is $126,487,027.

Page 10 of 10

sa~ntee cooper March 18, 2016 Michael R. Crosby U. S. Nuclear Regulatory Commission Senior Vice President Document Control Desk Nuclear Energy Director, Division of Spent Fuel Storage and Transportation fax: (843) 761-4126 Office of Nuclear Material Safety and Safeguards (843)by 761-7037r~co Washington, D. C. 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NOs. 50-395 and 72-103 8 OPERATING LICENSE NO. NPF-12 INDEPENDENT SPENT FUEL STORAGE INSTALLATION DECOMMISSIONING FUNDING PLAN Ladies and Gentlemen:

The South Carolina Public Service Authority (Authority) and South Carolina Electric & Gas Company (SCE&G) have ownership interests of one-third and two-thirds, respectively, in the Virgil C. Summer Nuclear Station, Unit 1 Independent Spent Fuel Storage Installation (ISFSI). As provided in 10 CFR 72.30 (b), each holder of, or applicant for, a license under this part must submit a. decommissioning funding plan for Nuclear Regulatory Commission (NRC) review and approval. The enclosed ISFSI Decommissioning Funding Plan (please see Attachment) provides financial assurance for the Authority's one-third share.

SCE&G will file the required decommissioning funding plan relative to its two-thirds ownership share in a separate submittal.

The estimated cost to decommission the V.C. Summer, Unit 1 ISFSI and release it for unrestricted use is $6.4 million (please see Table 2 in the Attachment). The Authority's one-third share is $2.1 million. The Attachment contains cost estimate details, including key assumptions, a description of the method of assuring funds for decommissioning, and a certification that financial assurance has been provided in the amount of the cost estimate for decommissioning.

This letter contains no new regulatory commitments. If there are any questions concemning this report, please contact me at (843) 761-4126.

Michael R. Crosby Senior Vice President Nuclear Energy MRC:trw cc:

Catherine Haney 0*

Shawn A. Williams Mark Lombard NRC Resident Inspector One Riverwood Drive Moncks Corner, SC 29461-2901

] (843) 761-8000 P.O. Box 2946101 Moncks Corner, SC 29461-6101

ATTACHMENT 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ISFSI DOCKET 72-1038 SOUTH CAROLINA PUBLIC SERVICE AUTHORITY

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,t1] with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Virgil C. Summer Nuclear Station, Unit 1 (V.C.

Summer) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate;

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The operating license for V.C. Summer is currently set to expire on August 6, 2042.

Approximately 2,757 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed with spent fuel planned to be transferred to the dry storage modules located at the ISFSI, to support continued plant operations. The ISFSI will be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[21).

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2U.S.

Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

Page 1 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Completion of the ISFSJ decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (thle "queue") in which it was discharged from the reactor. [3]

In January 2013, the DOE issued the "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission on America's Nuclear Future and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel... "[ ]The report stated,

"[W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:... [A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; Based upon DOE's latest strategy (and the potential for other, consent-based siting of consolidated interim storage facilities), South Carolina Electric & Gas (SCE&G) believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. SCE&G's current spent fuel management plan for the V.C. Summer spent fuel is based in general upon the spent fuel being fully removed from the V.C.

Summer site by 2095.

SCE&G's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. If DOE' s failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

u.s. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a)... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as... "

""Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S.

DOE, January 11, 2013 Page 2 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The V.C. Summer ISFSI is based upon Holtec International's (Holtec) HI-STORM FW System for the dry storage of used nuclear fuel. The HI-STORM FW System consists of a sealed metallic multi-purpose canister (MPC) contained within an overpack constructed from a combination of steel and concrete. The MPC can accommodate up to 37 undamaged Zircaloy-clad pressurized water fuel assemblies. The overpack provides structural protection, cooling, and radiological shielding for the MPC.

The HI-STORM FW overpack is a rugged, heavy-walled cylindrical vessel. The main structural function of the storage overpack is provided by carbon steel, and the main shielding function is provided by plain concrete. The overpack plain concrete is enclosed by a steel weldment of cylindrical shells, a thick baseplate, and a top annular plate. A set of four equally spaced radial connectors join the inner and outer shells and define a fixed width annular space for placement of concrete. The overpack lid also has concrete to provide neutron and gamma shielding.

The on-site ISFSI at V.C. Summer is located west of the Fuel Handling Building (FHB) and northeast of Warehouses A and B in an expansion of the plant Protected Area. The ISFSI pad has been sized to store 98 HI-STORM FW storage casks with each cask capable of storing 37 Pressurized Water Reactor spent fuel assemblies, which will meet V.C. Summer's spent fuel storage needs over the 60-year licensed life of the plant.

The current spent fuel management plan for the V.C. Summer spent fuel would result in 75 spent fuel storage casks being placed on the ISFSI pad during plant operations. This conservatively assumes that no fuel is removed from the site by the DOE during plant operations or during the nine years of pool operations after the permanent cessation of operations.

The 75 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

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South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2042) and the DOE's spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[ 5' The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 5 of the 75 Holtec overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 157 offloaded assemblies, 37 assemblies per cask which results in 5 overpacks). It is assumed that these are the final casks offioaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.E61 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

There is no known subsurface material (soil contamination) in the immediate vicinity of the ISFSI pad that will require remediation to meet the criteria for license termination. As such, there is no allowance for soil remediation in the estimate.

Costs are reported in 2016 dollars and based upon an internal decommissioning analysis being prepared for V.C. Summer in 2Ol6.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. SCE&G, as licensee, will oversee the site activities.

HI-STORM FW FSAR, Holtec International, Report HI-21 14830, Rev.2, at page 2-83 (Accession Number ML13177A428) 6HI-STORMV FW FSAR, Holtec International, Report HI-21 14830, Rev. 2, at page 2-84 (Accession Number ML13177A428)

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South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Low-level radioactive waste disposal costs are based on SCE&G's currently negotiated rates with the Atlantic Compact and other waste handling service providers.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[71 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

• An initial planning phase in which the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the remediation (overpack disposition) developed.

• The remediation phase includes the cost for craft labor to demolish the activated overpacks, package the steel and concrete in certified waste containers, transportation to the Atlantic Compact Regional Waste site in Barnwell, South Carolina or a bulk waste processing site in Tennessee, for disposal, as well as the costs for the supporting equipment, materials and supplies.

• The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), SCE&G's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2096, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at V.C. Summer ISFSI are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUJREG-1757, Volume 3, Revision 1, February 2012.

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South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, the Authority will rely upon the money available in its deconmnissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

• Although the decommissioning trust fund is for radiological decommissioning (i.e., post-shutdown) costs only, the ISFSI decommissioning is a radiological cost.

Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by the Authority, including ISFSL decommissioning costs.

• The projected minimum certification amount, calculated pursuant to 10 CFR 50.75(c) required to demonstrate reasonable assurance of funds for decommissioning V.C. Summer is $494,859,960 (2014 dollars), based upon the NRC's latest figures for calculating that value. The Authority's one-third share is

$164,953,320.

• Based upon the Authority's V.C. Summer decommissioning trust fund balance as of December 31, 2014 as reported in the Authority's March 27, 2015 biennial Decommissioning Funding Report and considering an average real rate of return of 0.4 percent on the fund between December 31, 2014 and 2049 when plant decommissioning activities are completed, the trust fund is projected to contain a

$47,966,502 surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10 CFR 50.75(c). This surplus is more than sufficient to complete the future decommissioning of the ISFSJ (estimated cost provided in Table 2).

• The Authority will continue to assess the decommissioning trust fund status in accordance with NRC requirements (e.g. 10 CFR 50.75(b)(2), 10 CFR 50.75(f)(1), 10 CFR 72.30(c)) and projected surplus, to account for the continued assurance of adequate funds for ISFSJ decommissioning. Any adjustments to the cost estimate and funding levels will be made in connection with the triennial filing required pursuant to 10 CFR 72.3 0(c). To the extent any specific regulatory actions are necessary at the time of withdrawal from the trust fund of the amount necessary for ISFSI decommissioning, the Authority will pursue such actions.

The Authority hereby certifies that financial assurance for decommissioning its one-third share of V.C. Summer's ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described above.

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South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual LItem Length (fi)

Width (ft)

Radioactivity ISFSI Pad 251.5 129.0 No ISFSI Storage Overpack (Holtec FW)

Item Value Notes Overall Height (inches) 239.5 Dimensions are nominal Outside Diameter (inches) 139 Dimensions are nominal Inside Diameter (inches) 81 Dimensions are nominal Quantity 79 75 Spent fuel + 4GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 5 used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,705,088 Concrete and steel Other Low-Level Radioactive Waste (pounds) 1,766 DAW, filters and other secondary waste Lox4-Level Radioactive Waste (total packaged volume) 30,414 Cubic feet Low-Level Radioactive Waste (packaged density) 56 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

No residual radioactivity Number of Overpacks used for GTCC storage 4

No residual radioactivity Page 7 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Afttachment Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2016 dollars)

Volume Person-Hours IClass A

Oversight and Removal Packaging Transport JDisposal Other Total (cubic feet)

Craft jContractor Decommissioning Contractor Planning (characterization, specs and procedures) 290 290 1,096 Decontamination/Demolition (activated cask disposition) 132 95 147 2,096 29 2,499 30,414 2,135-License Termination (radiological surveys) 1,313 1,313 11,060-Subtotal 132 95 147 2,096 1,632 4,102 30,414 13,195 1,096 Supporting Costs NRC and NRC Contractor Fees and Costs 400 400

-776 Insurance 117 117 Property Taxes Plant Energy Budget 46 46-Non-Labor Overhead 12 12---

Corporate A&G 25 25---

Security (industrial) 206 206 5,013 SCE&G Oversight Staff 235 235 3,803 Subtotal 1,042 1,042 9,592 Total (w/o contingency) 132 95 147 2,096 2,674 5,144 30,414 13,195 10,688 Total (w/25% contingency) 165 119 184 2,620 3,342 6,430 Page 8 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Table 3 Financial Assurance 10 CFR 50.75(b) & (c) Decommissioning Estimate (2014 Dollars):

Authority's One-Third Share of Decommissioning Estimate (2014 Dollars):

Market value of the external trust fund at December 31, 2014:

$494,859,960

$164,953,320

$123, 008,921 Schedle o annal aount remini 4

tobDollecte 2014 Dollars Beginning Decommissioning, Annual Ending Real Rates Year Balance Expenditures Deposits Earnings Balance of Return 2015 123,008,921 2,198,280 511,102 125,718,303 0.0042 2016 125,718,303 2,626,140 719,109 129,063,552 0.0057 2017 129,063,552 2,626,140 521,417 132,211,109 0.0040 2018 132,211,109 2,626,140 387,379 135,224,627 0.0029 2019 135,224,627 2,626,140 508,445 138,359,212 0.0038 2020 138,359,212 2,626,140 641,987 141,627,338 0.0046 2021 141,627,338 2,626,140 642,988 144,896,467 0.0045 2022 144,896,467 2,626,140 698,401 148,221,007 0.0048 2023 148,221,007 2,626,140 752,963 151,600,110 0.0051 2024 151,600,110 2,626,140 754,969 154,981,219 0.0050 2025 154,981,219 2,626,140 756,308 158,363,667 0.0049 2026 158,363,667 2,626,140 741,142 161,730,949 0.0047 2027 161,730,949 2,626,140 740,728 165,097,817 0.0046 2028 165,097,817 2,626,140 739,638 168,463,595 0.0045 2029 168,463,595 2,626,140 721,024 171,810,759 0.0043 2030 171,810,759 2,626,140 718,169 175,155,068 0.0042 2031 175,155,068 2,626,140 714,633 178,495,841 0.0041 2032 178,495,841 2,626,140 692,564 181,814,545 0.0039 2033 181,814,545

_________2,626,140 687,259 185,127,944 0.0038 2034 185,127,944 2,626,140 662,758 188,416,842 0.0036 2035 188,416,842 2,626,140 655,691 191,698,672 0.0035 2036 191,698,672 2,626,140 628,772 194,953,584 0.0033 Page 9 of 10

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1ltacmn Attachment 2037 194,953,584 2,626,140 619,952 198,199,676 0.0032 2038 198,199,676 2,626,140 590,635 201,416,451 0.0030 2039 201,416,451 2,626,140 580,079 204,622,671 0.0029 2040 204,622,671 2,626,140 548,389 207,797,200 0.0027 2041 207,797,200 2,626,140 536,117 210,959,456 0.0026 2042 210,959,456 9,818,650 478,715 201,619,521 0.0024 2043 201,619,521 23,564,760 405,965 178,460,726 0.0023 2044 178,460,726 23,564,760 322,184 155,218,150 0.0021 2045 155,218,150 23,564,760 260,674 131,914,064 0.0020 2046 131,914,064 23,564,760 192,862 108,542,165 0.0018 2047 108,542,165 23,564,760 142,762 85,120,167 0.0017 2048 85,120,167 23,564,760 91,102 61,646,509 0.0015 2049 61,646,509 13,746,110 66,103 47,966,502 0.0014 Beginning Decommissioning

• Annual 1Ending Year Balance 1 Expenditures jDeposits Earnings jBalance Total 123,008,921 164,953,320 170,477,920 J19,432,981 47,966,502 The preceding table is excerpted from the Authority's March 27, 2015 Decommissioning Funding Status Report for V.C. Summer Nuclear Station, Unit 1 in accordance with 10 CFR 50.75(f)(1) Reporting and Recordkeeping for Decommissioning Planning and is provided for illustrative purposes.

The market value of the external trust fund at December 31, 2015 is $126,487,027.

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