L-2018-068, Florida Power and Light Co. - Response to Request for Additional Information Re Decommissioning Funding Plan Updates for Independent Spent Fuel Storage Installations

Florida Power and Light Co. - Response to Request for Additional Information Re Decommissioning Funding Plan Updates for Independent Spent Fuel Storage Installations

ML18095A057
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold, 07200061, 07200062
Issue date:	04/03/2018
From:	Larry Nicholson Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
L-2018-068
Download: ML18095A057 (5)

Text

April 3, 2018 L-2018-068 10 CFR 50.75(f)(1) 10 CFR 72.30(b)(c)(1) (4)

Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Docket No. 72-61 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Docket No. 72-62 NextEra Energy Seabrook, LLC Seabrook Station Docket No. 50-443 Docket No. 72-63 NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center Docket No. 50-331 Docket No 72-32 NextEra Energy Point Beach, LLC Point Beach Units 1 and 2 Docket Nos. 50-266, 50-301 Docket No. 72-05

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References:

1. Florida Power & Light Company letter L-2015-064, Decommissioning Funding Status Reports/Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update, March 27, 2015 (ADAMS Accession No. ML15090A114)

2. NRC Letter, Request for Additional Information Regarding Florida Power and Light/NextEra Decommissioning Funding Plan Updates for St. Lucie, Units 1 and 2; Seabrook Station; Duane Arnold Energy Center; and Point Beach, Units 1 And 2 Independent Spent Fuel Storage Installations, dated February 27, 2018 (ADAMS Accession No. ML18058A053)

3. Florida Power & Light Company letter L-2017-040, Decommissioning Funding Status Reports/Independent Spent Fu!31 Storage Installation (ISFSI) Financial Assurance Update, March 30, 2017 (ADAMS Accession No. ML17130A921) jt-/JD I Florida Power & Light Company ;vfv/5SZ~

700 Universe Boulevard, Juno Beach, FL 33408

L-2018-068 Page 12 of2 By letter dated March 27, 2015 (L-2015-064), Florida Power and Light Company (FPL) submitted Reference 1, the Decommissioning Funding Status Reports/Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update cost estimates for its reactors, and as agent for NextEra Energy Seabrook, LLC, NextEra Energy Duane Arnold, LLC, and NextEra Energy Point Beach, LLC.

On February 27, 2018, the NRC staff issued Reference 2, requesting additional information in order to complete its review. The response to Reference 2 is provided in the enclosure to this letter.

The enclosure to this letter contains responses to the NRC requests for additional information for each of the below referenced stations. Please note that the enclosed information is also applicable to the most recently submitted ISFSI decommissioning cost estimates in Reference 3.

In reference to this request, CAC No. 001028, the EPID numbers are as listed below for each ISFSI:

ISFSI EPID St. Lucie Units 1 and 2 L-2017-FPR-0061 Turkev Point Units 3 and 4 L-2017-FPR-0070 Seabrook Station L-2017-FPR-0063 Duane Arnold Enerav Center L-2017-FPR-0023 Point Beach Units 1 and 2 1,.-2017-FPR-0055 This letter contains no new commitments and no revisions to existing commitments.

Should there be any questions, please contact Steve Catron at (561) 304-6206.

iV--

Larry Jicholson Nuclear Licensing and Regulatory Compliance Director Enclosure (1)

L-2018-068 Enclosure

• ' Page I1 Enclosure Regulatory Requirement Pursuant to Title 1O of the Code of Federal Regulations (1 O CFR) 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the decommissioning funding plan (DFP) required to be submitted by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. The DFP must update the information submitted with the original or prior approved plan. In addition, the DFP must also specifically consider the effect of the following events on decommissioning costs, as required by 10 CFR 72.30(c)(1 )-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.

Background

By letter dated March 27, 2015, Florida Power and Light/NextEra Energy submitted for U.S.

Nuclear Regulatory Commission (NRG) staff review and approval, DFP updates for the independent spent fuel storage installations at St. Lucie Units 1 and 2; Seabrook Station; Duane Arnold Energy Center; and Point Beach Units 1 and 2 (Agencywide Documents Access and Management System Accession No. ML15090A114). The NRG staff reviewed Florida Power and Light/NextEra's DFP updates for each ISFSI and believes Florida Power and Light/NextEra's submittal was not sufficient to meet the intent of the requirement in 72.30(c).

Specifically, the DFP updates do not provide sufficient information to allow the NRG to determine that the events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered.

RA11 For each ISFSI, provide a revised DFP that includes information on the occurrence, and the effect on decommissioning costs, of each of the events listed in 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.

NextEra Response Florida Power & Light Company, NextEra Energy Seabrook, LLC, NextEra Energy Duane Arnold, LLC, and NextEra Energy Point Beach, LLC Uointly referred to as "NextEra") submitted initial ISFSI decommissioning funding plans on December 17, 2012 (Reference 1). On May 23, 2014, the NRG requested additional information from NextEra (Reference 2), and on August 12, 2014, NextEra responded to the RAI (Reference 3). This response included entirely new ISFSI decommissioning funding cost estimates for each fleet ISFSI.

In March 2015, NextEra submitted a biennial reactor decommissioning funding report required by 10 CFR 50.75 (Reference 4). NextEra also submitted its triennial 10 CFR 72.30 ISFSI decommissioning funding plans at that time. Because NextEra had recently submitted new ISFSI decommissioning funding plans, it did not commission entirely new ISFSI decommissioning cost estimates in March 2015.

Instead, following the guidance in Regulatory Guide 1.159, section 1.F "Adjustments to Cost Estimates," NextEra escalated its existing ISFSI decommissioning cost estimates to account for inflation.

L-2018-068 Enclosure Page 12 Enclosure The following tables supplement the 2015 ISFSI decommissioning funding plan to address new information that may affect the previously submitted reports in accordance with 10 CFR 72.30(c)(1-4).

T urkey Pom . t (Flon"da Power & L",ght Companv Spills of radioactive material producing additional residual None radioactivity in onsite subsurface material Facility modifications None Changes in authorized possession limits None Actual remediation costs that exceed the previous cost estimate None St. Lucie (Florida Power & Light Company)

Spills of radioactive material producing additional residual None radioactivity in onsite subsurface material Facility modifications None Changes in authorized possession limits None Actual remediation costs that exceed the previous cost estimate None Seabrook (NextEra Enerav Seabrook, LLC)

Spills of radioactive material producing additional residual None radioactivity in onsite subsurface material Facility modifications None Changes in authorized possession limits None Actual remediation costs that exceed the previous cost estimate None Duane Arnold (NextEra Energy Duane Arnold, LLC)

Spills of radioactive material producing additional residual None radioactivity in onsite subsurface material Facility modifications None Changes in authorized possession limits None Actual remediation costs that exceed the previous cost estimate None

. L-2018-068 Enclosure Page 13 Enclosure Point Beach (NextEra Energy Point Beach, LLC)

Spills of radioactive material producing additional residual None radioactivity in onsite subsurface material Facility modifications None Changes in authorized possession limits None Actual remediation costs that exceed the previous cost estimate None On March 30, 2017, NextEra again submitted decommissioning funding status reports and new ISFSI decommissioning cost estimates (Reference 5). NextEra affirms that the above tables indicating no changes for the criteria found in 10 CFR 72.30(c)(1-4) remain applicable for the 2017 cost estimates.

References

1. FPL Letter L-2012-442, "ISFSI Decommissioning Funding Plans," dated Dec. 17, 2012 (ADAMS Accession No. ML12354A134).

2. NRC Letter, "Request for Additional Information for Review of the Decommissioning Funding Plans for Florida Power and Light and NextEra Energy Independent Spent Fuel Storage Installations," dated May 23, 2014 (ADAMS Accession No. ML14143A141).

3. FPL Letter L-2014-214, "Reply to Request for Additional Information for Review of the Decommissioning Funding Plans Regarding the Independent Spent Fuel Storage Installations," dated Aug. 12, 2014 (ADAMS Accession No. ML14225A655).

4. FPL Letter L-2015-064, "Decommissioning Funding Status Reports/ Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update," dated Mar. 27, 2015 (ADAMS Accession No. ML15090A114).

5. FPL Letter L-2017-040, "Decommissioning Funding Status Reports/ Independent Spent Fuel Storage-lnstallation*11sFSI) Financial Assurance Update," dated Mar. 30, 2017 (ADAMS Accession- No.

ML17093A722).