ML18019A213

Northern Trust - Notice of Disbursement from Exelon Generation Company, LLC Zion Decommissioning Trusts

ML18019A213
Person / Time
Site:	Zion, 07200104  File:ZionSolutions icon.png
Issue date:	01/17/2018
From:	Thomas D Northern Trust Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML18019A213 (4)

Text

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January l1' , 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Notice of Disbursement from Exelon Generation Company, LLC Zion Decommissioning Trusts

Reference:

1) Letter from Thomas O'Neill (Exelon Generation Company, LLC) and John Christian (ZionSolutions, LLC), to U.S. NRC, "Application for License Transfers and Conforming Administrative License Amendments," dated January 25, 2008, submitted by Exelon Generation Company, LLC and ZionSolutions, LLC to the Nuclear Regulatory Commission

2) Letter from Patrick R. Simpson (EGC) to U.S. Nuclear Regulatory Commission, "Independent Spent Fuel Storage Installation (ISFSI)

Decommissioning Funding Plan for Zion," dated October 17, 2016, (ADAMS Accession No. ML16291A50)

The purpose of this letter is to provide notice of the disbursement of funds from the Exelon Generation Company, LLC (EGC) Zion Unit 1 and Unit 2 decommissioning trust funds. The Master Terms for Trust Agreements Applicable to Second Amended and Restated Nonqualified Nuclear Decommissioning Master Trust Agreement dated as of July 1, 2013 among the NQF Companies identified therein and The Northern Trust Company, as Trustee (the "Master

• Terms"), require that the Trustee provide thirty (30) days written notice to the NRC, Director of the Office of Nuclear Reactor Regulation, prior to disbursing any funds from the decommissioning trust funds to reimburse EGC for Decommissioning Costs. The Master Terms further provide that no reimbursements from the trust funds will be made for any costs to which the NRC Director Office of Nuclear Reactor Regulation provides written objection within the thirty (30) day review period. The NRC's regulations at 10 C.F.R. 50.75(h)(l)(iv) require notice of thirty (30) worldng days. To address this discrepancy, Northern Trust will not make any disbursements from the funds until after thirty (30) working days from the date of this written notice to the NRC. Furthermore, Northern Trust will not make any disbursements for any Decommissioning Costs to which the NRC objects within the 30 working day period. Barring any objection from the NRC, Northern Trust will make the disbursements noted below for Decommissioning Costs.

The transfer of funds will reimburse EGC for Decommissioning Costs incurred from 2011 through 2016 for oversight of ZionSolutions 's removal of fuel from the spent fuel pool and NTAC:2SE-18

$ NORTHERN TRUST transfer to the ISFSI in conjunction with its decommissioning of Zion Units 1 and 2 and for Exelon Generation's cost estimates for decommissioning the ISFSI.

The amount of decommissioning costs to be disbursed from each unit trust fund is specified in the table that appears below.

Unit Total Zion Station ISFSI Decommissioning Decommissioning Decommissioning Costs (fuel to ISFSI)

Zion Unit 1 $290,206.73 $222,414.36 $67,792.37 Zion Unit 2 $290,207.14 $222,414.36 $67,792.78 Total Disbursement $580,413.87 $444,828.72 $135,585.155 Request Even though the Decommissioning Costs for which EGC seeks reimbursement were incurred while ZionSolutions is the licensee for Zion Station, the expenses are legitimate Decommissioning Costs and can be reimbursed from the Zion Unit 1 and Unit 2 Non-Tax Qualified Decommissioning Trust Funds held by Exelon Generation for spent fuel management and ISFSI decommissioning. As explained in the License Transfer Application (Reference 1),

ZionSolutions assumed responsibility for decommissioning Zion Station, including construction of an ISFSI and transfer of the spent fuel to the ISFSI. (Reference 1, Attachment 1, p. 5.)

Following completion of its decommissioning activities, ZionSolutions will take such actions as are required to transfer the license to Exelon Generation. As part of this transaction, Exelon Generation retained $25 million and segregated that amount in its Zion Units 1 and 2 Non-Tax Qualified Decommissioning Trust Funds "for the purpose of funding the maintenance and decommissioning of the ISFSI" and other potential activities following transfer of the Licenses to Exelon Generation. (Reference 1, Attachment 1, pp. 10 and 11.) The NRC approved the license transfer application on May 4, 2009. The expenses for which Exelon Generation seeks reimbursement are associated with the decommissioning of Zion Station and decommissioning of the ISFSI.

To the extent EGC's trust funds for Zion are to be used for maintenance and decommissioning of the ISFSI, only a portion of the EGC Zion decommissioning trust funds are reserved for funding the ISFSI decommissioning. (Reference 2.) After reimbursement of these costs from the trust fund, sufficient funds remain to provide funding assurance for decommissioning the ISFSI per 10 CFR 72.30.

If you have any questions about this letter, please contact me at (312) 444-2247.

NTAC:2SE-18

$ NORTHERN TRUST 6::

Danu Thomas

~----.::o Vice President cc: John Hickman, NRC Project Manager (via email atjohn.hickman@nrc.gov)

Marc Dapas, NRC Director NMSS (via email at marc.dapas@nrc.gov)

Doug Brown (Exelon)

Brian Andersen (Exelon)

Patrick Simpson (Exelon) (via email at patrick.simpson@exeloncorp.com)

NTAC:2SE-18 L __

Dann Thomas Vice President

~ Northern Trust The Northern Trust Company Direct (312) 444-2247 50 South La Salle Street Facsimile (312) 630-6062 Chicago, Illinois 60603 dt2@ntrs.com (312) 630-6000