RS-16-190, Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plans for Clinton Power Station
| ML16251A032 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/06/2016 |
| From: | Gullott D Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| RS-16-190 | |
| Download: ML16251A032 (7) | |
Text
4300 Winfield Road ExeLon G Warrenville, IL 60555 www.exeloncorp.com RS-16-190
September 6, 2016 ATTN: Document Control Desk Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket Nos. 50-461 and 72-1046
Subject:
Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plans for Clinton Power Station In accordance with 10 CFR 72.30, "Financial assurance and recordkeeping for decommissioning," Exelon Generation Company, LLC (EGC) is submitting the proposed ISFSI decommissioning funding plans for Clinton Power Station.
This submittal is subdivided as follows: provides a description of the proposed ISFSI decommissioning funding plan.
provides details of the ISFSI decommissioning funding estimate.
There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter please contact Ms. Lisa A. Simpson at (630) 657-2815.
Respectfully, David M. Gullott Manager Licensing cc:
NRC Regional Administrator Region III NRC Senior Resident Inspector Clinton Power Station Attachments:
- 1. Proposed ISFSI Decommissioning Funding Plan for Clinton Power Station
- 2. ISFSI Decommissioning Funding Estimate for Clinton Power Station
ATTACHMENT 1 Proposed ISFSI Decommissioning Funding Plan for Clinton Power Station 1.0
SUMMARY
DESCRIPTION 2.0
DETAILED DESCRIPTION 2.1
Reasonable Assurance of Funds Availability 2.2
Detailed Cost Estimate 2.3
Assumptions 2.4
Method of Assurance 2.5
Volume of Subsurface Residual Radioactivity Requiring Remediation 2.6
Certification of Financial Assurance
==3.0
REFERENCES==
Page 1 of 4
ATTACHMENT 1 Proposed ISFSI Decommissioning Funding Plan for Clinton Power Station 1.0
SUMMARY
DESCRIPTION Exelon Generation Company, LLC (EGC) maintains decommissioning cost estimates (DCEs) for each of its nuclear units, which are periodically updated. Embedded in the DCEs maintained by EGC are the costs associated with decommissioning the Independent Spent Fuel Storage Installations (ISFSIs) co-located at the sites. The cost for decommissioning the ISFSI at Clinton Power Station (CPS) has never been provided to the NRC because CPS did not have an ISFSI and was not subject to 10 CFR 72. As early as September 9, 2016, CPS will begin using an ISFSI. This submittal is consistent with NRC guidance that general licensees submit a decommissioning funding plan to the NRC no later than the date that the general licensee first uses a spent fuel storage cask to store spent fuel (Reference 1). EGC provides the following information from its cost estimate to support its decommissioning funding plan for the CPS ISFSI in accordance with the requirements of 10 CFR 72.30.
EGC notes that radiological decommissioning costs for ISFSIs typically consist of the costs associated with removing and disposing of small volumes of neutron-activated concrete and certain structural steel components. No impact is expected upon soil and groundwater at CPS during the storage periods contemplated in the cost estimate. EGC also notes that induced radioactivity at the CPS ISFSI is not expected to result in residual radioactivity in excess of 25 mRem/year in an unrestricted release scenario, were no action to be taken to remediate the site.
However, since EGC anticipates that there may be small but measurable amounts of induced radioactivity present, and release of this material from CPS will require it to be disposed of at a NRC-licensed radioactive waste disposal facility, EGC has included these costs in its cost estimate.
2.0
DETAILED DESCRIPTION 2.1
Reasonable Assurance of Funds Availability There are currently insufficient funds in the CPS decommissioning trust fund for ISFSI decommissioning. EGC is evaluating the alternate funding mechanisms allowed by 10 CFR 72.30(e) to provide funding assurance. EGC intends to monitor funding assurance and new developments for CPS to assess the status of funding assurance and to take such actions as may be necessary to resolve any continuing funding shortfalls before the next decommissioning funding status report, which is due on March 31, 2017. EGC in previous decommissioning funding status reports (Reference 2) has included updates to ISFSI decommissioning funding at its other sites to meet the requirements of 10 CFR 72.30(c) and will continue to do so.
Page 2 of 4
ATTACHMENT 1 Proposed ISFSI Decommissioning Funding Plan for Clinton Power Station 2.2
Detailed Cost Estimate provides an excerpt from EGC's DCE for CPS detailing the costs of ISFSI decommissioning in 2016 dollars. Attachment 2 shows the cost for an independent contractor to perform all decommissioning activities, with an adequate contingency factor, to meet the 10 CFR 20.1402 criteria for unrestricted use. Contingency has been added at an overall rate of 25%. This is consistent with the evaluation criteria referenced by the NRC in NUREG-1757 (Reference 3).
2.3
Assumptions EGC has made the following assumptions within the DCE with respect to ISFSI decommissioning:
- 1. Decommissioning costs in Attachment 2 are escalated from 2015 dollars to 2016 dollars using a unit specific escalation rate consistent with that used for the plant cost estimate.
- 3. Costs are expected to be incurred beginning in the year after which DOE has accepted all spent fuel from CPS for disposal. For the purposes of the cost estimate, the transfer of the CPS spent fuel to the DOE is assumed to be completed in 2035.
2.4
Method of Assurance EGC is evaluating the various funding mechanisms allowed in 10 CFR 72.30(e) to provide funding assurance. In order to meet the requirements of 10 CFR 72.30(b)(4), EGC periodically updates the CPS DCE, including ISFSI decommissioning costs, and adjusts the funding levels, as necessary, in accordance with 10 CFR 50.75.
2.5
Volume of Subsurface Residual Radioactivity Requiring Remediation EGC has not identified any onsite, subsurface material containing residual radioactivity at the ISFSI.
2.6
Certification of Financial Assurance EGC is currently evaluating the funding mechanisms allowed by 10 CFR 72.30(e) to provide funding assurance. EGC intends to monitor funding assurance and new developments so that CPS can assess the status of funding assurance and take such actions as may be necessary to resolve any continuing funding shortfalls for these funds on or before the next decommissioning funding status report, which is due on March 31, 2017.
Page 3 of 4
ATTACHMENT 1 Proposed ISFSI Decommissioning Funding Plan for Clinton Power Station
==3.0
REFERENCES==
- 1. Letter from Mark Lombard (U.S. Nuclear Regulatory Commission) to Pamela B.
Cowan (Exelon Generation), "Clarification Regarding the Timing of Submittal of a Decommissioning Funding Plan per Title 10 of the Code of Federal Regulations Section 72.30(b) for Future Independent Spent Fuel Storage Installations," dated August 21, 2013
- 2. Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," dated March 31, 2015
- 3. NUREG-1757, Vol. 3, Rev. 1, "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," dated February 2012 Page 4 of 4
ISFSI Decommissioning Funding Estimate for Clinton Power Station Page 1 of 2
ATTACHMENT 2 ISFSI Decommissioning Funding Estimate for Clinton Power Station Clinton Power Station*
Activity Description Removal Costs Packaging Costs Transport Costs LLRW Disposal Costs Other Costs Total Costs" Burial Volume Class A (W)
Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Panning (characterization, specs, and procedures) 256 256 1,048 Decontan',lation (activated HS".l disposition) 128 70 361 982 1,542 16,295 1,367 LicenseTerrr'nation (radiological surveys) 1,145 1,145 9,116 Subtotal 128 70 361 982 1,402 2,943 16,295 10,483 1,048 Supporting Costs SRC and NRC Contractor Fees and Costs 420 420 776 Insurance 77 77 Property Taxes 337 337 Plant Energy Budget 52 52 Security Staff Cost 183 183 3,429 Oversight Staff Cost 369 369 3.77' Subtotal 1,440 1,440 7.976 Total (w/o contingency) 128 70 361 982 2,840 4,382 16.295 10,483 9.024 Total (w/25% contingency) 5,477
- Costs in thousands of 2016 do"ars
"'Total Costs may not add due to rounding Page 2 of 2