ML17044A017

Company - Notification of Changes to Decommissioning Schedule for the ISFSI

ML17044A017
Person / Time
Site:	Maine Yankee
Issue date:	01/23/2017
From:	Jonathan Brown Maine Yankee Atomic Power Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
OMY-17-001
Download: ML17044A017 (8)

Text

MAINE VANiffiE 321 Old Ferry Road, Wiscasset, Maine 04578 January 23, 2017 OMY-17-001 10 CFR 50.82(a)(7)

A1TN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Maine Yankee Atomic Power Company Maine Yankee Independent Spent Fuel Storage Installation N'RC License No. DPR-36 (NRC.Do~ket Net 50..:3()9)

Subject:

Notification of Changes in accordance with 10 CFR 50.82(a)(7)

Maine Yankee Atomic Power Company (Maine Yankee) is notifying the U.S. Nuclear Regulatory Commission .(NRC) of sigµificant changes to the decommissioning schedule in acG.ordance with 10 CFR 50~82(a)(7)'priotto incorporating these changes into the Maine Yankee Post..$hutdown Decommissioni.ng.Agtlvities.R,ep~n:t (P~DAR). This schedule: change tefiects a new de~omnns§foning cost estimate that includes :a costesiimate for ;managen:ierit _of irtadiate'd fuel and Greater than Class C waste that was approved by the Federal Energy Regulatory Commission on November 15, 2016.

Currently, the Maine Yankee PSDAR provides a schedule and cost estimate for the management of irradiated fuel and GTCC waste and decommissioning of the ISFSI for the time period of 2016 through 2033. This time period will be extended from 2016 through 2036. The attachment to this letter provides a mark-up of the Maine Yankee PSDAR that establishes the applicable changes regarding the decommissioning schedule and the cost estimate. Maine Yankee will update the Maine Yankee PSDAR to reflect this new schedule and cost estimate in February 2017.

In addition, Maine Yankee is sending a copy of this letter to the State of Maine as required by 10 CFR 50.82(a)(7).

This letter contains no commitments.

Maine Yankee Atomic Power Company OMY-17-001/January 23, 2017/Page 2 If you have any questions regarding this submittal, please do not hesitate to contact me at (207) 882-1303.

Respectfully,

~

(/ ~~l;l17/Jvf-

!1. Stanley efrown, P.E.

ISFSI Manager

Attachment:

Mark-up of Revision 3 of the Maine Yankee Post-Shutdown Decommissioning Activities Report cc: D. Donnan, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager P. J. Dostie, SNS!, State of Maine J. Hyland, State of Maine

ATTACHMENT TO OMY-17-001 MARK-UP OF REVISION 3 OF THE MAINEYANKEE POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT

MAINE YANKEE ATOMIC POWER STATION POST-SHUTDOWN DECOMMISSIONING ACTIVITIBS REPORT REVISION 43-J.r\.N.~J.A.l{-Y..!JO*l-()FEBRUARY 2017

Maine Yankee Atomic Power Station Post-Shutdown Decommissioning Activities Report shallow-land waste disposal facility. Packaged items meeting 10 CFR 61.55 Class C 01* less were shipped and buried.

The ISFSI storage pads and Vertical Concrete Casks are not expected to be significantly activated. However, the ISFSI decommissioning cost estimate assumes that the material comprising the ISFSI storage pads and Vertical Concrete Casks will be disposed of as low-level radioactive waste.

btbe1* :Decoiun1issiu1ii!lg Activitfos

• Other decommissioning activities which do not meet the definition of "major activities" include the following:

• Removal of low level waste. Radioactively contaminated or activated materials will be removed from the site as necessary to allow the site to be released for *Llnrestricted access.

ILW will be processed h1 accordance with procedures and existing commercial options, and sent to licensed disposal facilities~ Wastes may be incinerated, compacted, or otherwise processed by authorized and licensed contractors as appropriate.

• Removal of mixed wastes. If mixed wastes are generated, they will be managed according to all applicable federal and state regulations to the extent they are not inconsistent with NRC handling, storage, and transportation regulations. Mixed wastes from Maine Yankee will be transported only by authorized and licensed transporters and shipped only to authorized and licensed facilities. Processes to render the mixed wastes nonhazardous wilJ be evaluated if technology, resources. and approved processes ere available.

.Stol'ilge of SpelifFuel Congress passed the "Nuclear Waste Polioy Act" in 1982, assigning the responsibility fo1*

disposal of spent nuclear fuel created by the commercial nuoleal' generating plants to the Department ofEnergy (DOB). This legislation also c1*eated a Nuclear Waste Fund to cover the cost ofthe program, which is funded, in part, by the sale of electricity :from the Maine Yankee plant (and an estimated equivalent for assemblies in*adiated prior to April, 1983). The target date for startup of the federal Waste Management System was originally 1998.

\

The backlog of spent fuel in the national inventory, delays in site characterization, and intermittent pr~gress in the development of a waste transportation system, make it necessary to reflect spent fuel storage in the cost and schedule of commercial reactor decommissioning. For planning purposes, Maine Yankee bas assllmed that the high"level waste reposito1y or some interim storage facility will be operational by ~2034-. Spent fuel and GTCC waste will be stored at the Maine Yankee ISFSI until DOE takes possession of the material and l'emoves it from the site.

Page6 of14 Revision 4a.

Maine Yankee Atomic Power Station Post-Shutdown Decommissioning Activities Report Period 3 .. Site Restoration e Demolition of the ISFSI storage pads, Vertical Conc1*ete Casks, and i*emainlng buildings and other structures will be performed using conventional demolition techniques. Site Areas affected by the dismantling activities will be cleaned and the ISFSI area gnded as required to prevent ponding and inhibit the refloating of subsurface materials.

• The Maine Yankee ISFSI is expected to be operated until ~2034, when the spent fuel and GTCC waste is expected to be removed from the site. Using this assumption, the Maine Yankee license will be terminated after the ISFSI is decommissioned. This is scheduled to occur in ~2036.

V. DECOMISSIONING COST ESTIMATE The cu1Tent *IZec4~1'Gl-Bl*1e-1ig.y-T~~H~R-l-aF.y*G{*m~1nilfflien*t.f'!l!R:G-}at,l~l'El¥00-decommissioning cost estimate Ef)ee-1~11-l.~~%-9091 and cost estimate for management of spent fuel and CJTCC waste (Docket# ER 16-2726-000) ~s-aeaei:l-enwas filed with the Federal Energy Regulatory Commission (FERC) ou Septelllber 30, 2016 and app1*oved by FERC on November 15, 20 t 6 with no objections from the State t\gencie.c; that wet*e parly to the Ap1*i1 30, 20 l 3-tke Stipulation and Settlement Agreement l:letwtie1~~M¥(\ollGQ.anaincludh1g the Connecticut Public Utilities Regulatory Authority, the Connecticut qffice of Consumer Counsel, the Maine Public Utilities Commission, the Maine Office of Public Advocate, the Massachusetts Department of Public Utilities, and the Attorney General ofMassachusetts-c~nted-/\J'1'il-:.~.

This cost estimate Includes the cost associated with the projected ISFSI decommissioning costs and a funding assumption of 15 years of operations costs to manage spent fuel and GTCC waste.

A funding mechanism provides that damage awards and settlement proceeds that MYAPCO receives in future phases of its litigation with the DepaJ'tment ofEnergy (DOE) will be applied to maintain the adequacy of the Nuclear Decommissioning Trust (NDT) to cover 15 years ofISFSI operations (as well as all other projected decommissioning costs). In addition, MYAPCO has the right to 1*esume collection of decommissioning charges from its custoiners subject to the submittal of a proposal under section 205 ofthe Federal Power Act, if needed.

MYAPCO has an account within its NDT entitled, ..ISFSI Radiological Decom," that segregates the funds for radiological decommissioning of the ISFSI from the larger balance of funds for ongoing management of spent :fuel and GTCC waste held in the NDT.

The assumptions of the current decommissioning cost estimate are discussed in the Decommissioning Funding Plan submitted to the NRC on December 16, 2015 in acco1*dance with 10 CPR n.30(c) (Reference 9). The decommissioning cost estimate incorporates the most recent assumptions with respect to the remaining decommissioning activities and related costs (i.e., those associated with the Maine Yankee ISFSI). The total un-escalated cost estimate for decommissioning the ISFSI, .including contingency is approximately ~28.1 million in 291 S and 2016 dollal'S;-liespeettvely. This includes approximately $21.'3 millio.¥1 m-Nil

$22. l million for radiological removal ti1 291 S afld-2fH-6-t~l'eSt>eeti¥ely;-and approximately Page 9 of14 Revision~

Maine Yankee Atomic Power Station Post-Shutdown Decommissioning Activities Report f5*iTltlltefl-at'lcl.-$6.0 million fol' non-radiological removal in 2QU aaEl 2016 dollars AiSfleeti¥ely.

ISFSI operations will continue until DOE removes the spent fuel and GTCC waste, allowing for the decommissioning of the ISFSI. MY.APCO expects that the lSFSI op*erating costs will continue to cover a number of categories, including costs fol' insurance, labor, security, matelials and supplies, miscellaneous expenses, outside services, prope1ty taxes, regulatory fees, rentals and leases and utilities. The un~escalated cost estimate for the management of spent fuel and GTCC waste ti*om 2016 through ~2036, lt1cluding contingency, is ,~G!M-frl-illiaB and

$198.6' minion in 2915 1H1EI 2016 dollars, EeSf'eetiwly. This is baseEl-eit~tl:i*es*mmte

-submitted la the l'mS oo-fleaembel' 16, 2.IH~ (~l!PeR~r

'Ibe total un-escalated cost estimate iA lQ I(; elellara is approximately $19*1.~ n:iillien aed

$226.7-W9rl--million in 2915 aad 2016 dolla1*s,p~eea~ for decotnmissioning the ISFSI and managing the storage of spent fuel ond GTCC waste for the time period of 2016 through

~2036.

MYAPCO will co11tlnue to inform the NRC regardb1g the status of this funding by complying with the obligations defined in: J) 10 CFR 50.75(f)(l) and (2) to submit an annual Decommissioning Funding Status Report; 2) 10CFR S0.82(a)(8)(v) to submit an annual financial assurance status report regarding decommissioning funding; 3) IO CFR 72.30(c) to resubmit the decom.missioning funding plan at intervals not to exceed three years; and

4) 10 CFR S0.82(a)(8)(vii) to submit an annual report regarding the status of the funding for managbtg irradiated fuel.

VI. ENVIRONMENTAL IMPACTS 10CFR 50.82 (a)(4)(i) describes the Post-Shutdown Decommissioning Activities Report (PSDAR), and requires that it include a disct1ssion that provides the reasons for concluding that the environmental impacts associated with the site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements," The following discussion provides our reasons for drawing that concJusion, based on three previously issued documents: 1) Maine Yankee Atomic Po~cr Station Environmental Repo1t1 Supplement One, dated Aprill9, 1972 [Reference 4]; 2) the Final Environmental Statement Related to Operation of Maine Yankee Atomic Power Station, dated July 1972 [Reference 2]; and 3) NUREG-0586, "Final Generic Environmental Impact Statement (GEIS) on decommissioning nuclear facilides"

[Reference l].

Decommissioning the Maine Yankee plant and ISFSI will have generally positive environmental effects, in that:

• Radiological sources that create the potential for radiation exposure to site workers and the public will be eliminated

.-.* Decommissioning will return the site to a condition allowing unrestricted use Page 10ofl4 Revlsion43

Maine Yankee Atomic Power Station Post-Shutdown De~o~missioning Activities Report

4. Maine Yankee Atomic Power Station Environmental Repo11:, Supplement One, dated April 19, 1974 (MY APC to ABC)

5. NUREG/CR-5849, 11Manual for Conducting Radiological Surveys in Support ofLicense Termination"

6. AIF/NESP~036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates

7. Letter from (NRC) to (MYAPCO), Issuance of Amendment No. 167 to Facility Operating License No. DPR-36, dated July 30, 2002

8. Letter from D. Gillen (NRC) to J. Niles (MYAPCO), Issuance of Amendment No. 172 to Facility Operating License No. DPR Maine Yankee Atomic Powe1* Station (TAC No. M8000), dated September 30, 2005

9. Letter from C. Pizzella (MYAPCO) to U.S. Nuclear Regulatory Commission, OMY*l5*

053, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan," dated December 16, 2015 1O. Letter from Alston & Bird LLP to Federal Energy Regulatory Commission, "Maine Yankee Atomic Power Company Docket No. Jm.l.3.ER16-_-900," dated May+,

~eptember 30, 2016 Page 14of14 Revision43