NL-17-0429, ISFSI Decommissioning Funding Plan Triennial Update
| ML17089A520 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley, 07200042, 07200036, 07201039  |
| Issue date: | 03/30/2017 |
| From: | Hutto J Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| NL-17-0429 | |
| Download: ML17089A520 (35) | |
Text
~ Southern Nuclear J.J.Hutto Regulatory Affairs Director 40 Inverness Center Parkway Post Office Box 1295 Binnlngham, AL 35242 205 992 5872 tel 205 992 7601 fax llhutto@soulhemco.com March 30, 2017 Docket Nos.: 50-321 50-348 50-424 50-366 50-364 50-425 72-36 72-42 72-1039 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant-Units 1 and 2 Edwin I. Hatch Nuclear Plant-Units 1 and 2 Vogtle Electric Generating Plant-Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Ladies and Gentlemen:
NL-17-0429 In accordance with 10 CFR 72.30(b) and (c), Southern Nuclear Operating Company (SNC) hereby submits the enclosed Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost studies and funding plans for Joseph M. Farley Nuclear Plant (Farley),
Edwin I. Hatch Nuclear Plant (Hatch) and Vogtle Electric Generating Plant (Vogtle) Units 1 and
- 2.
This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.
Respectfully submitted, James J. Hutto Regulatory Affairs Director JJH/efbllac
Enclosures:
- 1. Farley ISFSI Decommissioning Funding Plan Triennial Update
- 2. Hatch ISFSI Decommissioning Funding Plan Triennial Update
- 3. Vogtle ISFSI Decommissioning Funding Plan Triennial Update
U.S. Nuclear Regulatory Commission NL-17-0429 Page 2 cc:
Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President-Farley Mr. D. R. Vineyard, Vice President-Hatch Mr. B. K. Taber, Vice President-Vogtle 1 & 2 Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. B. J. Adams, Vice President-Engineering Ms. B. L. Taylor, Regulatory Affairs Manager-Farley Mr. G. L. Johnson, Regulatory Affairs Manager-Hatch Mr. D. D. Sutton, Regulatory Affairs Manager-Vogtle 1 & 2 RTypes: GG1.004; CFA04.054; CHA02.004; CVC7000 Alabama Power Company Ms. A. Allcorn-Walker, Comptroller & V.P.
Mr. C. Blake, Assistant Treasurer Georgia Power Ms. A. P. Daiss, Comptroller, CAO, and Senior V. P.
Oglethorpe Power Ms. A. F. Appleby, Vice President, Teasurer Municipal Electric Authority of Georgia Mr. E. E. Easterlin, Sr., Senior V.P. and CFO City of Dalton Mr. Tom Bundros, CEO and President, Dalton Utilities U.S. Nuclear Regulatory Commission Mr. Michael Layton, Director-Division of Spent Fuel Management Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Senior Project Manager-Farley Mr. R. Hall, NRR Senior Project Manager - Hatch Mr. M. D. Orenak, NRR Senior Project Manager-Vogtle 1 &2 Mr. P. K. Niebaum, Senior Resident Inspector-Farley Mr. D. H. Hardage, Senior Resident Inspector-Hatch Mr. M. F. Endress, Senior Resident Inspector-Vogtle 1 & 2
Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Joseph M. Farley Nuclear Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update Joseph M. Farley Nuclear Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17,2011,111 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 Subpart 72.30(b) and (c) of the rule, this enclosure provides the required triennial update with adjustments as necessary to account for changes in costs and the extent of contamination, including a detailed cost estimate in an amount reflecting:
- 1. The work is performed by an independent contractor;
- 2. An adequate contingency factor;
- 3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402;
- 4. Identification of the key assumptions contained in the cost estimate; and
- 5. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.
Spent Fuel Management Strategy The operating licenses for Farley Units 1 & 2 are currently set to expire on June 25, 2037 and March 31, 2041 respectively. Approximately 5,520 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date. The ISFSI is operated under a Part 50 General License.
Assuming that the plant operates to the end of its currently licensed life, the spent fuel pools are expected to contain a total of approximately 2,221 spent fuel assemblies after the final core offloads. To facilitate immediate dismantling or safe-storage operations, the spent fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas or result in reduced operating expenses should the station be placed into a SAFSTOR dormancy configuration.
Completion of the ISFSI 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 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, 20 II E1-2 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update exceptions, in the order (the "queue") in which it was discharged from the reactor.[21 Southern Nuclear Company's current spent fuel management plan for the Farley spent fuel is based in general upon: 1) a 2032 start date for DOE initiating transfer of commercial spent fuel to a federal facility, and 2} completion of spent fuel receipt by year 2075. The completion date is based upon the DOE's generator allocation/receipt schedules which are based upon the oldest fuel receiving the highest priority. The end date assumes a maximum rate of transfer of 3,000 metric tons of uranium/yearP1 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) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria. 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.
ISFSI Description The Farley ISFSI uses a Holtec International (Holtec) HI-STORM 1 OOS, Version 8 dry storage system. The HI-STORM 1 OOS Version 8 is comprised of a multi-purpose canister (MPC) and storage overpack. The MPCs are assumed to be transferred directly to the DOE and not returned to the station. The storage overpacks remain onsite after transfer of the spent fuel to the DOE. The majority of the overpacks are assumed to be disposed of as "clean" material. The inner steel liners of the remaining overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.
SNC's current spent fuel management plan for Farley spent fuel would result in 89 spent fuel storage casks (nominal 32 assemblies per cask) and 56 spent fuel storage casks (nominal 24 assemblies per cask) being placed on a storage pad at the site after all spent fuel has been removed from the spent fuel pool. This represents approximately 75% of the total spent fuel projected to be generated during the currently licensed operating period.
In addition to the spent fuel casks located on the ISFSI pad after shutdown there are projected to be additional casks that are expected to be used for Greater-than-Ciass-C (GTCC) storage.
The storage overpacks used for the GTCC canisters (estimated quantity of 8) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.
U.S. Code of Federal Regulations, Title l 0, 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... "
"Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004.
E1 -3 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.
Key Assumptions I 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 unit operating until the end of its current license, (Unit 1 - June 25, 2037; Unit 2 -
March 31, 2041 ), and the assumptions associated with DOE's spent fuel acceptance, as previously described.
The nominal size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is expected to be approximately 40,000 square feet in surface area.
It is not expected that the overpacks will have any interior or exterior radioactive surface contamination. It is 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. Any neutron activation of the steel and concrete is expected to be extremely small.
To validate this assumption, the estimate accounts for characterization of 10% of the overpacks; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.
The decommissioning estimate conservatively assumes that 14 overpacks, excluding those used for GTCC, will contain low levels of neutron-induced residual radioactivity on its inner steel liner that would necessitate remediation at the time of decommissioning. For purposes of this estimate, the overpack inner steel liners are designated for controlled disposal as low-level radioactive waste. It is not expected that there will be any residual contamination left on the concrete ISFSI pad, or other facilities at the Farley ISFSI. It is 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. Therefore, it is assumed for this analysis that these facilities will not be contaminated. As such, only verification surveys are included for the facilities in the decommissioning estimate.
There is no expected subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.
To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the concrete overpack surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad, and the other ISFSI structures.
Decommissioning is assumed to be performed by an independent contractor. As such, essentially all 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. Those craft labor positions that are expected to be provided locally. SNC will oversee the site activities; and, therefore the estimate includes SNC's labor and overhead costs.
Low-level radioactive waste disposal costs are based on Southern Nuclear Company's current cost of disposal at the Energy Solutions Clive, Utah disposal site.
E1-4 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update Costs are reported in 2015 dollars.
Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.141 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meets the
§20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.
Cost Estimate 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 - empty overpacks are characterized and the specifications and work procedures for the decontamination (liner removal) developed.
The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.
The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.
In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), SNC'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 2076, the year following all spent fuel removal.
Financial Assurance Summary SNC operates the Farley ISFSI in accordance with the general license provisions of the 10 CFR 72, Subpart K. The Farley ISFSI is a shared facility for storage of spent fuel from both Unit 1 and Unit 2. Accordingly, the cost associated with operation and decommissioning the ISFSI is not unit-specific and may be funded from the existing decommissioning trust fund established in accordance with 10 CFR 50.75 for either unit.
The Farley ISFSI decommissioning cost estimate is derived from a site-specific decommissioning cost study prepared every three years. The scope of the decommissioning cost study includes decommissioning of the reactor facility to permit license termination, management of the spent fuel in accordance with 10 CFR 50.54(bb), and decommissioning the ISFSI following removal of the spent fuel. The estimated costs are adjusted periodically to reflect the current assumptions such as cost of energy, labor, burial cost, projected capacity, and schedule for removal of fuel from the site. Incorporation of the cost to decommission the "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.
Nuclear Regulatory Commission's Office of Federal and State Materials and Environmental Management Programs, NUREG-1757, Volume 3, Revision 1, February 2012.
E1-5 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update ISFSI into the scope of the Farley decommissioning cost study and use for cost-of-service ratemaking, provides assurance that adequate funding will be available as required by 10 CFR 72.30 (b), (c), and (d).
Financial assurance that adequate funds are available to decommission the ISFSI is based on the following:
- Site specific cost studies have historically included the cost to decommissioning the ISFSI as part of the scope of activities necessary to decommission the Part 50 facility and terminate the Part 50 specific license in accordance with 10 CFR 50.82, Termination of License.
- SNC previously collected funds to demonstrate compliance with the NRC minimum decommissioning funding requirement based on the NRC formula amount described in 10 CFR 50.75 based on the original operating license period of 40 years. Upon issuance of the renewed operating license, these same funds will accumulate interest over an additional 20 year period.
As a result, the decommissioning trust fund balances will exceed the NRC minimum decommissioning funding formula amount described in 10 CFR 50.75 at the time of Part 50 license expiration and provide additional assurance that adequate funds will be available to decommission the Farley ISFSI.
- The most recent Farley decommissioning cost study update estimates the amount necessary for ISFSI decommissioning to be $5,297,000 (2015$) shared by both operating units. The estimates are included in Table 3.
- In accordance with 10 CFR 72.30(b), financial assurance for decommissioning has been provided in an amount separate from the requirements of 10 CFR 50.75(b). The amount allocated for ISFSI decommissioning is held in the same financial instrument as the reactor decommissioning funds required by 10 CFR 50.75. As shown in Table 3, these funds are in excess of the amount required for decommissioning the Part 50 facility and provide adequate assurance that funding for decommissioning the ISFSI will be available upon expiration of the Part 50 operating licenses for Farley Units 1 and 2.
Accordingly, the funds set aside to cover the ISFSI decommissioning costs for Farley are not the same funds credited for compliance with the decommissioning funding requirements of 10 CFR 50.75. Table 3 provides a summary to demonstrate decommissioning funding in the amounts required by 10 CFR 50.75 and 10 CFR 72.30 will be available when required to decommission the Part 50 reactor plants and the Part 72 ISFSI, respectively.
E1-6 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Area (ft2)
Residual Radioactivity ISFSI Pad 40,000 No residual radioactivity __
ISFSI Overpack (HI-STORM 1 OOS Version B)
Item Value Notes (all dimensions are nominal)
Overall Height (inches) 218.5 I
Outside Diameter (inches) 132.5 Main cylindrical body of overpack Inside Diameter (inches) 73.5 Inner Liner Thickness (inches) 1.0 Quantity (total) 153 Spent Fuel 145 + GTCC 8 Quantity (with residual radioactivity) 14 Equivalent to the number of overpacks used to store last complete core offloads Total Surface Area of Overpack Inner Liner with Residual 4,485 Radioactivity (square feet)
Low-Level Radioactive Waste (cubic feet) 3,131 Low-Level Radioactive Waste (packaged dens_i!y--_!Qs./cu.ft.)
59 Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 8
No residual radioactivity Transfer Cask 1
No residual radioactivity E1 -7 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste thousands, 2015 dollars Volume Person-Hours NRC/NRC Removal Packaging Trans_Q_ort Disposal Other Total (ft3)
Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 422 422 1,288 Remediation (activated liner removal) 253 13 58 196 57 577 3,131 963 License Termination (radiological surveys) 2,150 2,150 17,246 Subtotal 253 13 58 196 2,629 3,148 3,131 19,497 Supporting Costs NRC and NRC Contractor Fees and Costs 425 425 776 Insurance 142 142 Property Tax 2
2 Site Overheads 66 66 Corporate Overheads 57 57 Security (Industrial) 101 101 4,978 Farley Oversight Staff 297 297 3,771 Subtotal 1,090 1,090 4,978 3,771 776 Total (w/o contingency) 253 13 58 196 3,718 4,238 3,131 24,475 3,771 776 Total (with 25% contingency) -
5,297 Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2076.
E1 -8 to NL-17-0429 Farley ISFSI Decommissioning Funding Plan Triennial Update Table 3 - Financial Assurance (Alabama Power Company-100% ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to
$421,872,000 10 CFR 50.75(b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of
$402,098,838 2016 (2016$)
3 Assumptions regarding:
(a) Rates of escalation in decommissioning costs 4.5%
(b) Rates of earnings on de commissioning funds 7.0%
2.5%
(c) Real rate of return 4
Projected NRC minimum requirements pursuant to 1 0 CFR
$1,063,219,177 50.75(b) and (c) (U1-year 2037, U2-year 2041) 5 Projected ending fund balance (U1 -year 2037, U2 year 1,685,739,447 2041) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration
$622,520,270 (U1 -year 2037, U2-year 2041) Row 5-Row 4 7
ISFSI decommissioning cost estimate from TLG Services
$2,648,500 Inc cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$6,975,227 Services Inc cost study (U 1 - year 2037, U2 - year 2041)
E1-9 Unit2
$421,872,000
$388,100,905 4.5%
7.0%
2.5%
$1,267,908,645 2,131,415,883
$863,507,238
$2,648,500
$8,318,088
Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant-Units 1 and 2 Vogtle Electric Generating Plant-Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Edwin I. Hatch Nuclear Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Edwin I. Hatch Nuclear Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, 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 Subpart 72.30(b) and (c) of the rule, this enclosure provides the required triennial update with adjustments as necessary to account for changes in costs and the extent of contamination, including a detailed cost estimate in an amount reflecting:
- 1. The work is performed by an independent contractor;
- 2. An adequate contingency factor;
- 3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402;
- 4. Identification of the key assumptions contained in the cost estimate; and
- 5. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.
Spent Fuel Management Strategy The operating licenses for Hatch Units 1 & 2 are currently set to expire on August 6, 2034 and June 13, 2038 respectively. Approximately 14,823 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date. The ISFSI is licensed and operated under 10 CFR Part 72 in accordance with the general license provisions of 10 CFR 72.210.
Assuming that the plant operates to the end of currently licensed life the spent fuel pools are expected to contain a total of approximately 3,337 spent fuel assemblies after the final core offloads. To facilitate immediate dismantling or safe-storage operations, the spent fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and allow termination of the Part 50 license using the DECON method described in NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities:
Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, " (GElS).
Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to meet its contractual obligation 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 (the "queue") in which it was discharged from the reactor. SNC's current spent fuel management plan for the Hatch spent fuel is based in general upon: 1) a 2032 start date for DOE initiating transfer of commercial spent fuel to a federal E2-2 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update facility, and 2) completion of spent fuel receipt in 2074. The completion date is based upon the DOE's generator allocation/receipt schedules which are based upon the oldest fuel receiving the highest priority. The end date assumes a maximum rate of transfer of 3,000 metric tons of uranium/year.
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) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria. 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.
ISFSI Description The Hatch ISFSI uses a Holtec International (Holtec) HI-STORM 100 Version B dry storage system. The HI-STORM 100 is comprised of a multi-purpose canister (MPC) and storage overpack. The multi-purpose canisters are assumed to be transferred directly to the DOE and not returned to the station. The storage overpacks remain onsite after transfer of the spent fuel to the DOE. The majority of the overpacks are assumed to be disposed of as "clean" material.
The inner steel liners of the remaining overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.
SNC's current spent fuel management plan for the Hatch spent fuel would result in 138 spent fuel storage casks (nominal 68 assemblies per cask) and 38 spent fuel storage casks (nominal 52 assemblies per cask) being located on a storage pad after all spent fuel has been removed from the spent fuel pool. This represents approximately 77% of the total spent fuel projected to be generated during the currently licensed operating period.
In addition to the spent fuel casks located on the ISFSI pad after shutdown there are projected to be additional casks that are expected to be used for Greater-than-Ciass-C (GTCC) storage.
The storage overpacks used for the GTCC canisters (estimated quantity of 8) are not expected to have any interior contamination or 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.
Key Assumptions I 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 unit operating until the end of its current license, (Unit 1 -August 6, 2034; Unit 2 -
June 13, 2038), and the assumptions associated with DOE's spent fuel acceptance, as previously described.
E2-3 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update The nominal size of the ISFSI pad and adjacent concrete sufficient to store the projected amount of spent fuel is expected to be approximately 67,000 square feet in surface area.
It is not expected that the overpacks will have any interior or exterior radioactive surface contamination. It is 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. Any neutron activation of the steel and concrete is expected to be extremely small.
To validate this assumption, the estimate accounts for characterization of 10% of the overpacks; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.
The decommissioning estimate conservatively assumes that 22 overpacks, excluding those used for GTCC, will contain low levels of neutron-induced residual radioactivity of its inner steel liner that would necessitate remediation at the time of decommissioning. For purposes of this estimate, the overpack inner steel liners are designated for controlled disposal as low-level radioactive waste.
It is not expected that there will be any residual contamination left on the concrete ISFSI pad, or other facilities at the Hatch ISFSI. It is 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. Therefore, it is assumed for this analysis that these facilities will not be contaminated. As such, only verification surveys are included for the facilities in the decommissioning estimate.
There is no expected subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.
To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 1 00% survey of the concrete overpack surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad, and the other ISFSI structures.
Decommissioning is assumed to be performed by an independent contractor. As such, essentially all 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. Southern Nuclear Company, as licensee, will oversee the site activities; the estimate includes Southern Nuclear Company's labor and overhead costs.
Low-level radioactive waste disposal costs are based on Southern Nuclear Company's current cost of disposal at the Energy Solutions Clive, Utah disposal site.
Costs are reported in 2015 dollars.
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.
E2-4 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update 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 Estimate 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 - empty overpacks are characterized and the specifications and work procedures for the decontamination (liner removal) developed.
The remediation phase-residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.
The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.
In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), Southern Nuclear Company's oversight staff, site security (industrial), and other site operating costs.
For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2075, the year following all spent fuel removal.
Financial Assurance Summary SNC operates the Hatch ISFSI in accordance with the general license provisions of the 10 CFR 72, Subpart K. The Hatch ISFSI is a shared facility for storage of spent fuel from both Unit 1 and Unit 2. Accordingly, the cost associated with operation and decommissioning the ISFSI is not unit-specific and may be funded from the existing decommissioning trust fund established in accordance with 10 CFR 50.75 for either unit.
The Hatch ISFSI decommissioning cost estimate is derived from a site-specific decommissioning cost study prepared every three years. The scope of the decommissioning cost study includes decommissioning of the reactor facility to permit license termination, management of the spent fuel in accordance with 10 CFR 50.54(bb), and decommissioning the ISFSI following removal of the spent fuel. The estimated costs are adjusted periodically to reflect the current assumptions such as cost of energy, labor, burial cost, projected capacity, and schedule for removal of fuel from the site. Incorporation of the cost to decommission the ISFSI into the scope of the Hatch decommissioning cost study and use for cost-of-service ratemaking, provides assurance that adequate funding will be available as required by 1 0 CFR 72.30 (b), (c), and (d).
Financial assurance that adequate funds are available to decommission the ISFSI is based on the following:
- Site specific cost studies have historically included the cost to decommissioning the ISFSI as part of the scope of activities necessary to decommission the Part 50 facility and terminate the Part 50 specific license in accordance with 10 CFR 50.82, Termination of License.
E2-5 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update
- SNC previously collected funds to demonstrate compliance with the NRC minimum decommissioning funding requirement based on the NRC formula amount described in 10 CFR 50.75 based on the original operating license period of 40 years. Upon issuance of the renewed operating license, these same funds will accumulate interest over an additional 20 year period.
As a result, the decommissioning trust fund balances will exceed the NRC minimum decommissioning funding formula amount described in 10 CFR 50.75 at the time of Part 50 license expiration and provide additional assurance that adequate funds will be available to decommission the Hatch ISFSI.
- The most recent Hatch decommissioning cost study update estimates the amount necessary for ISFSI decommissioning to be $6,252,000 (2015$) shared by both operating units. The estimates are included in Tables 3-6.
- In accordance with 10 CFR 72.30(b), financial assurance for decommissioning has been provided in an amount separate from the requirements of 10 CFR 50.75(b). The amount allocated for ISFSI decommissioning is held in the same financial instrument as the reactor decommissioning funds required by 10 CFR 50.75. As shown in Tables 3-6, these funds are in excess of the amount required for decommissioning the Part 50 facility and provide adequate assurance that funding for decommissioning the ISFSI will be available upon expiration of the Part 50 operating licenses for Hatch Units 1 and 2.
Accordingly, the funds set aside to cover the ISFSI decommissioning costs for Hatch are not the same funds credited for compliance with the decommissioning funding requirements of 10 CFR 50.75. Tables 3-6 provide a summary to demonstrate decommissioning funding in the amounts required by 10 CFR 50.75 and 10 CFR 72.30 will be available when required to decommission the Part 50 reactor plants and the Part 72 ISFSI, respectively.
E2-6 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Area (ft2)
Residual Radioactivity ISFSI Pad 67,000 No residual radioactivity ISFSI Overpack (HI-STORM 1 OOS Version B)
Item Value Notes (all dimensions are nominal)
Overall Height (inches) 229.5 Outside Diameter (inches) 132.5 Main cylindrical body of overpack Inside Diameter (inches) 73.5 Inner Liner Thickness (inches) 1.0 Quantity (total}
184 Spent Fuel 145 + GTCC 8 Quantity (with residual radioactivity) 22 Equivalent to the number of overpacks used to store last complete core offloads Total Surface Area of Overpack Inner Liner with Residual 8,316 Radioactivity (square feet}
Low-Level Radioactive Waste (cubic feet) 5,754 Low-Level Radioactive Waste (packaged density-lbs./cu.ftJ 59 Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 8
No residual radioactivitY Transfer Cask 1
No residual radioactivity Cask Transfer Facility 1
No residual radioactivity E2 -7 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste thousands, 2015 dollars Volume Person-Hours NRC/NRC Removal PackaQinQ Transport Disposal Other Total (ft3)
Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, 455 455 1,200 specs and procedures)
Remediation 86 19 110 1,390 40 1,645 5,754 1,341 (activated liner removal)
License Termination 1,889 1,889 14,962 (radiological surveys)
Subtotal 86 19 110 1,390 2,384 3,989 5,754 17,503 Supporting Costs NRC and NRC Contractor 430 430 776 Fees and Costs Insurance 148 148 Property Tax 0
0 Security (Industrial) 118 118 3,448 Hatch Oversight Staff 317 317 3,792 Subtotal 1,013 1,013 3,448 3,792 776 Total (w/o contingency) 86 19 110 1,390 3,397 5,002 5,754 20,950 3,792 776 6,252 I
Total (with 25% contingency)
I Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2075.
E2-8 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Table 3 - Financial Assurance (Georgia Power Company 50.1% Ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to 10
$290,887,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$256,846,668 (2016$)
3 Assumptions regarding:
(a) Rates of escalation in decommissioning costs 2.49%
(b) Rates of earnings on de commissioning funds 4.49%
2.00%
(c) Real rate of return 4
Projected NRC minimum requirements pursuant to 10 CFR
$452,888,392 50.75 (b) and (c) (U1 -year 2034, U2-year 2038) 5 Projected ending fund balance (U1 -year 2034, U2 year
$555,426,000 2038) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1 -
$102,537,608 year 2034, U2 - year 2038) Row 5 - Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$1,566,126 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$2,499,051 Services Inc cost study (U1 -year 2034, U2-year 2038)
E2-9 Unit2
$290,887,000
$237,524,936 2.49%
4.49%
2.00%
$499,708,989
$612,294,000
$112,585,011
$1,566,126
$2,757,408 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Table 4-Financial Assurance (Oglethorpe Power Company 30% Ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to 1 0
$174,184,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$135,393,000 (2016$)
3 Assumptions regarding:
(a) Rates of escalation in decommissioning costs 2.49%
(b) Rates of earnings on de commissioning funds 5.00%
(c) Real rate of return 2.51%
4 Projected NRC minimum requirements pursuant to 10 CFR
$277,944,000 50.75 (b) and (c) (U1 -year 2034, U2-year 2038) 5 Projected ending fund balance (U1 -year 2034, U2 year
$325,838,941 2038) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1 -
$47,894,941 year 2034, U2 - year 2038) Row 5 - Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$937,800 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$1,496,438 Services Inc cost study (U1 -year 2034, U2-year 2038)
E2 -10 Unit2
$174,184,000
$106,443,000 2.49%
5.00%
2.51%
$306,678,000
$311,372,737
$4,694,737
$937,800
$1,651,143 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Table 5 - Financial Assurance (Municipal Electric Authority of Georgia 17.7% Ownership)
Unit 1 Unit2 1
The NRC minimum decommissioning estimate, pursuant to 10
$102,769,000
$102,769,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$11 0,640,440
$110,172,122 (2016$)
3 Assumptions regarding:
(a) Rates of escalation in decommissioning costs 2.49%
2.49%
(b) Rates of earnings on de commissioning funds 4.15%
4.15%
1.66%
1.66%
(c) Real rate of return 4
Projected NRC minimum requirements pursuant to 10 CFR
$160,003,325
$176,544,820 50.75 (b) and (c) (U1 - year 2034, U2 - year 2038}
5 Projected ending fund balance (U1 -year 2034, U2 year
$221,017,000
$255,730,000 2038) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30} and Site Restoration (U1 -
$61,013,675
$79,185,180 year 2034, U2 - year 2038) Row 5 - Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$553,302
$553,302 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$882,898
$974,174 Services Inc cost study (U1 -year 2034, U2-year 2038}
E2-11 to NL-17-0429 Hatch ISFSI Decommissioning Funding Plan Triennial Update Table 6 - Financial Assurance (Dalton Utilities 2.2% Ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to 10
$12,773,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$19,694,062 (2016$)
3 Assumptions regarding:
(d) Rates of escalation in decommissioning costs 2.49%
(e) Rates of earnings on de commissioning funds 2.269%
-0.221%
(f) Real rate of return 4
Projected NRC minimum requirements pursuant to 10 CFR
$19,886,566 50.75 (b) and (c) (U1 - year 2034, U2 - year 2038) 5 Projected ending fund balance (U1 -year 2034, U2 year
$29,493,579 2038) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1 -
$9,607,013 year 2034, U2 - year 2038) Row 5 - Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$68,772 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$109,739 Services Inc cost study (U1 -year 2034, U2-year 2038)
E2-12 Unit2
$12,773,000
$19,577,284 2.49%
2.269%
-0.221%
$21,942,483
$32,262,908
$1 0,320,425
$68,772
$121,084
Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant-Units 1 and 2 Vogtle Electric Generating Plant-Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Vogtle Electric Generating Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Vogtle Electric Generating Plant-Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, 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 Subpart 72.30(b) and (c) of the rule, this enclosure provides the required triennial update with adjustments as necessary to account for changes in costs and the extent of contamination, including a detailed cost estimate in an amount reflecting:
- 1. The work is performed by an independent contractor;
- 2. An adequate contingency factor;
- 3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402;
- 4. Identification of the key assumptions contained in the cost estimate; and
- 5. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for lice11se termination.
Spent Fuel Management Strategy The operating licenses for Vogtle Nuclear Plant Units 1 & 2 are currently set to expire on January 16, 204 7 and February 9, 2049 respectively.
Approximately 7,156 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date. The ISFSI currently has sixteen loaded casks on the pad and is licensed and operated under 10 CFR Part 72 in accordance with the general license provisions of 10 CFR 72.210.
Assuming that the plant operates to the end of currently licensed life the spent fuel pools are expected to contain a total of approximately 2,409 spent fuel assemblies after the final core offloads. To facilitate immediate dismantling or safe-storage operations, the spent fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and allow termination of the Part 50 license using the DECON method described in NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities:
Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, " (GElS).
Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to meet its contractual obligation 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 (the "queue") in which it was discharged from the reactor. SNC's current spent fuel management plan for the Vogtle spent fuel is based in general E3-2 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update upon: 1) a 2032 start date for DOE initiating transfer of commercial spent fuel to a federal facility, and 2) completion of spent fuel receipt by year 2078. The completion date is based upon the DOE's generator allocation/receipt schedules which are based upon the oldest fuel receiving the highest priority. The end date assumes a maximum rate of transfer of 3,000 metric tons of uranium/year.
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) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria. 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.
ISFSI Description The Vogtle ISFSI uses a Holtec International (Holtec) HI-STORM 1 OOS, Version B dry storage system. The HI-STORM 1 OOS Version B is comprised of a multi-purpose canister (MPC) and storage overpack. The multi-purpose canisters are assumed to be transferred directly to the DOE and not returned to the station. The storage overpacks remain onsite after transfer of the spent fuel to the DOE. The majority of the overpacks are assumed to be disposed of as "clean" material. The inner steel liners of the remaining overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.
SNC's current spent fuel management plan for the Vogtle spent fuel would result in 93 spent fuel storage casks (nominal 32 assemblies per cask) and 77 spent fuel storage casks (nominal 24 assemblies per cask) being located on a storage pad after all spent fuel has been removed from the spent fuel pool. This represents approximately 67% of the total spent fuel projected to be generated during the currently licensed operating period.
In addition to the spent fuel casks located on the ISFSI pad after shutdown there are projected to be additional casks that are expected to be used for Greater-than-Ciass-C (GTCC) storage.
The storage overpacks used for the GTCC canisters (estimated quantity of 1 0) are not expected to have any interior contamination or 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.
Key Assumptions I 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 unit operating until the end of its current license, (Unit 1 -January 16, 2047; Unit 2 E3-3 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update
- February 9, 2049), and the assumptions associated with DOE's spent fuel acceptance, as previously described.
The nominal size of the ISFSI pad and adjacent concrete sufficient to store the projected amount of spent fuel is expected to be approximately 49,000 square feet in surface area.
It is not expected that the overpacks will have any interior or exterior radioactive surface contamination. It is 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. Any neutron activation of the steel and concrete is expected to be extremely small.
To validate this assumption, the estimate accounts for characterization of 10% of the overpacks; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.
The decommissioning estimate conservatively assumes that 18 overpacks, excluding those used for GTCC, will contain low levels of neutron-induced residual radioactivity of its inner steel liner that would necessitate remediation at the time of decommissioning. For purposes of this estimate, the overpack inner steel liners are designated for controlled disposal as low-level radioactive waste.
It is not expected that there will be any residual contamination left on the concrete ISFSI pad, or other facilities at the Vogtle Nuclear Plant ISFSI. It is 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. Therefore, it is assumed for this analysis that these facilities will not be contaminated. As such, only verification surveys are included for the facilities in the decommissioning estimate.
There is no expected subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.
To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the concrete overpack surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad, and the other ISFSI structures.
Decommissioning is assumed to be performed by an independent contractor. As such, essentially all 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. Southern Nuclear Company, as licensee, will oversee the site activities; the estimate includes Southern Nuclear Company's labor and overhead costs.
Low-level radioactive waste disposal costs are based on Southern Nuclear Company's current cost of disposal at the Energy Solutions Clive, Utah disposal site.
Costs are reported in 2015 dollars.
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.
E3 - 4 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update 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 Estimate 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 - empty overpacks are characterized and the specifications and work procedures for the decontamination (liner removal) developed.
The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.
The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.
In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), SNC's oversight staff, site security (industrial), and other site operating costs.
For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2079, the year following all spent fuel removal.
Financial Assurance Summary SNC operates the Vogtle ISFSI in accordance with the general license provisions of the 10 CFR 72, Subpart K. The Vogtle ISFSI is a shared facility for storage of spent fuel from both Unit 1 and Unit 2. Accordingly, the cost associated with operation and decommissioning the ISFSI is not unit-specific and may be funded from the existing decommissioning trust fund established in accordance with 10 CFR 50.75 for either unit.
The Vogtle ISFSI decommissioning cost estimate is derived from a site-specific decommissioning cost study prepared every three years. The scope of the decommissioning cost study includes decommissioning of the reactor facility to permit license termination, management of the spent fuel in accordance with 10 CFR 50.54(bb), and decommissioning the ISFSI following removal of the spent fuel. The estimated costs are adjusted periodically to reflect the current assumptions such as cost of energy, labor, burial cost, projected capacity, and schedule for removal of fuel from the site. Incorporation of the cost to decommission the ISFSI into the scope of the Vogtle decommissioning cost study and use for cost-of-service ratemaking, provides assurance that adequate funding will be available as required by 10 CFR 72.30 (b), (c), and (d).
Financial assurance that adequate funds are available to decommission the ISFSI is based on the following:
- Site specific cost studies have historically included the cost to decommissioning the ISFSI as part of the scope of activities necessary to decommission the Part 50 facility and terminate the Part 50 specific license in accordance with 10 CFR 50.82, Termination of License.
E3-5 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update
- SNC previously collected funds to demonstrate compliance with the NRC minimum decommissioning funding requirement based on the NRC formula amount described in 10 CFR 50.75 based on the original operating license period of 40 years. Upon issuance of the renewed operating license, these same funds will accumulate interest over an additional 20 year period.
As a result, the decommissioning trust fund balances will exceed the NRC minimum decommissioning funding formula amount described in 10 CFR 50.75 at the time of Part 50 license expiration and provide additional assurance that adequate funds will be available to decommission the Vogtle ISFSI.
- The most recent Vogtle decommissioning cost study update estimates the amount necessary for ISFSI decommissioning to be $5,545,000 (2015$) shared by both operating units. The estimates are included in Tables 3-6.
- In accordance with 10 CFR 72.30(b), financial assurance for decommissioning has been provided in an amount separate from the requirements of 10 CFR 50.75(b). The amount allocated for ISFSI decommissioning is held in the same financial instrument as the reactor decommissioning funds required by 10 CFR 50.75. As shown in Tables 3-6, these funds are in excess of the amount required for decommissioning the Part 50 facility and provide adequate assurance that funding for decommissioning the ISFSI will be available upon expiration of the Part 50 operating licenses for Vogtle Units 1 and 2.
Accordingly, the funds set aside to cover the ISFSI decommissioning costs for Vogtle are not the same funds credited for compliance with the decommissioning funding requirements of 1 0 CFR 50.75. Tables 3-6 provide a summary to demonstrate decommissioning funding in the amounts required by 10 CFR 50.75 and 10 CFR 72.30 will be available when required to decommission the Part 50 reactor plants and the Part 72 ISFSI, respectively.
E3-6 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Area (ft2)
Residual Radioactivity ISFSI Pad 49,000 No residual radioactivity ISFSI Overpack (HI-STORM 1 OOS Version B)
Item Value Notes (all dimensions are nominal)
Overall Height (inches) 218 -1/2 Outside Diameter (inches) 132-1/2 Main cylindrical body of overpack Inside Diameter (inches) 73-1/2 Inner Liner Thickness (inches) 1.0 Quantity (total) 180 Spent Fuel 145 + GTCC 8 Quantity (with residual radioactivity) 18 Equivalent to the number of overpacks used to store last complete core offloads Total Surface Area of Overpack Inner Liner with Residual 5,767 Radioactivity (square feet)
Low-Level Radioactive Waste _(cubic feet) 4,011 Low-Level Radioactive Waste (packaged density-lbs./cu.ft.)
59 Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storaqe 10 No residual radioactivity Transfer Cask 1
No residual radioactivity Cask Transfer Facility 1
No residual r~dioactivity E3 -7 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste thousands, 2015 dollars Volume Person-Hours NRC/NRC Removal Packaging Transport Disposal Other Total (ft3)
Contractor Licensee Contractor Decommissionil!g_ Contractor Planning (characterization, specs and procedures) 421 421 1,176 Remediation (activated liner removal) 68 13 74 966 39 1,160 4,011 928 License Termination (radiological surveys) 1,835 1,835 15,485 Subtotal 68 13 74 966 2,295 3,416 4,011 17,590 Supporting Costs NRC and NRC Contractor Fees and Costs 427 427 776 Insurance I
148 148 I
Property Tax 0
0 i
Security (Industrial) 120 120 3,476 Vogtle Oversight Staff 3,824 326 326 i
3,824 I
Subtotal 1,020 1,020 3,476 776 Total (w/o contingency) 3,824 68 13 74 966 3,315 4,436 4,011 21,066 776 Total (with 25% contingency) 5,545 Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2079.
E3-8 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Table 3 - Financial Assurance Vogtle Unit 1 and 2 (Georgia Power Company 45.7% Ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to 10
$203,616,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$127,774,550 (2016$)
3 Assumptions regarding:
(a) Rates of escalation in decommissioning costs 2.49%
(b) Rates of earnings on decommissioning funds 4.49%
2.00%
(c) Real rate of return 4
Projected NRC minimum requirements pursuant to 10 CFR
$436,453,709 50.75 (b) and (c) (U1 -year 2047, U2-year 2049) 5 Projected ending fund balance (U1 -year 2047, U2 year
$521,070,000 2049) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1 -
$84,616,291 year 2047, U2-year 2049) Row 5-Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$1,267,032 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$2,783,527 Services Inc cost study (U1 -year 2047, U2-year 2049)
E3-9 Unit2
$203,616,000
$137,930,256 2.49%
4.49%
2.00%
$458,459,710 I
$576,411,000
$117,951,290
$1,267,032
$2,923,872 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Table 4-Financial Assurance Vogtle Units 1 and 2 (Oglethorpe Power Company 30% Ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to 10
$133,665,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$78,988,000 (2016$)
3 Assumptions regarding:
a)Rates of escalation in decommissioning costs 2.49%
b)Rates of earnings on de commissioning funds 5.00%
2.51%
c) Real rate of return 4
Projected NRC minimum requirements pursuant to 10 CFR
$293,647,000 50.75 (b) and (c) (U1 -year 2047, U2-year 2049) 5 Projected ending fund balance (U1 -year 2047, U2 year
$358,448,476 2049) 6 Additional funds available for Spent Fuel Management (10 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1 -
$64,801,476 year 2047, U2-year 2049) Row 5-Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$831,750 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$1,827,261 Services Inc cost study (U1 -year 2047, U2-year 2049)
E3-10 Unit2 I
$133,665,000
$71,549,000 I
I 2.49%
5.00%
2.51%
$308,453,000
$357,974,453
$49,521,453
$831,750
$1,919,392 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Table 5 - Financial Assurance (Municipal Electric Authority of Georgia 22.7% Ownership)
Unit 1 Unit2 1
The NRC minimum decommissioning estimate, pursuant to 1 0
$101 '140,000
$101 '140,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$111,947,589
$1 07,008,868 (2016$)
3 Assumptions regarding:
a)Rates of escalation in decommissioning costs 2.49%
2.49%
b)Rates of earnings on decommissioning fund 4.15%
4.15%
1.66%
1.66%
c)Real rate of return 4
Projected NRC minimum requirements pursuant to 10 CFR
$216,794,987
$227 '725, 793 50.75 (b) and (c) (U1 -year 2047, U2-year 2049) 5 Projected ending fund balance (U1 -year 2047, U2 year
$363,553,000
$377,053,000 2049) 6 Additional funds available for Spent Fuel Management (1 0
$146,758,013
$149,327,207 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1 -
year 2047, U2-year 2049) Row 5-Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$629,358
$629,358 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$1,382,629
$1,452,341 Services Inc cost study (U1 -year 2047, U2-year 2049)
E3-11 to NL-17-0429 Vogtle ISFSI Decommissioning Funding Plan Triennial Update Table 6 - Financial Assurance (Dalton Utilities 1.6% Ownership)
Unit 1 1
The NRC minimum decommissioning estimate, pursuant to 1 0
$7,129,000 CFR 50.75 (b) and (c) (Dec 2016$)
2 Total amount accumulated in the trust fund at the end of 2016
$10,577,080 (2016$)
3 Assumptions regarding:
a)Rates of escalation in decommissioning costs 2.49%
b)Rates of earnings on de commissioning funds 2.269%
c) Real rate of return
-0.221%
4 Projected NRC minimum requirements pursuant to 10 CFR
$15,281,11 0 50.75 (b) and (c) (U1 -year 2047, U2-year 2049) 5 Projected ending fund balance (U1 -year 2047, U2 year
$21,204,600 2049) 6 Additional funds available for Spent Fuel Management (1 0 CFR 50.54 (bb) and 10 CFR 72.30) and Site Restoration (U1-
$5,923,490 year 2047, U2-year 2049) Row 5-Row 4 7
ISFSI decommissioning cost estimate from TLG Services Inc
$44,360 cost study (2015$)
8 Projected ISFSI decommissioning cost estimate from TLG
$97,454 Services Inc cost study (U1 -year 2047, U2-year 2049)
E3 -12 Unit2
$7,129,000
$10,127,249 2.49%
2.269%
-0.221%
$16,051,584
$21,234,586
$5,183,002
$44,360
$102,368
---