ML18361A575

Independent Spent Fuel Storage Installation (Sfsi) - 10 CFR 72.30 Decommissioning Funding Plan

ML18361A575
Person / Time
Site:	Millstone
Issue date:	12/19/2018
From:	Mark D. Sartain Dominion Energy Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
18-427
Download: ML18361A575 (7)

Text

Dominion Energy Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 DominionEnergy.com December 19, 2018 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 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

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Domin_ ion

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Energy Serial No.18-427 NRA/T JS Rev. 1 Docket No.

72-47 MILLSTONE POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) 10 CFR 72.30 DECOMMISSIONING FUNDING PLAN Pursuant to 10 CFR 72.30(b) and (c), Dominion Energy Nuclear Connecticut, Inc.

(DENG) submits the attached decommissioning funding plan for the Millstone Power Station (MPS) ISFSI.

Please contact Mr. Thomas J. Szymanski at (804) 273-3065 if you have any questions or require additional information.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering & Fleet Support Dominion Energy Nuclear Connecticut, Inc.

Attachment:

Millstone Power Station Decommissioning Funding Plan for ISFSI Commitments made in this letter: None cc:

Mr. J. N. Nguyen NRC Senior Project Manager U. S. Nuclear Regulatory Commission, Mail Stop 4834 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Millstone Power Station Decommissioning Funding Plan for ISFSI Mil.lstone Power Station - ISFSI Dominion Energy Nuclear Connecticut, Inc. (DENC)

Serial No.18-427 Docket No. 72-47 Decommissioning Funding Plan for MPS ISFSI Serial No.18-427 Docket No. 72-47 Page 1 of 5 General License under 10 CFR 72.210, Docket No. 72-47 Pursuant to 10 CFR 72.30 (b), Dominion Energy Nuclear Connecticut, Inc. (DENC) submitted a decommissioning funding plan for the Millstone Power Station (MPS)

Independent Spent Fuel Storage Installation (ISFSI) on December 17, 2012 (Serial No.12-736, ADAMS Accession No. 13002A036). DENC responded to NRC Request for Additional Information related to this submittal on September 30, 2013 (Serial No.13-434, ADAMS Accession No. ML13283A085). The last DENC decommissioning funding plan update was submitted on December 2, 2015 (Serial No.15-123, ADAMS Accession No. ML15342A064).

10 CFR 72.30(c) requires each holder of a license under Part 72 to resubmit the decommissioning funding plan at intervals not to exceed three years with adjustments as necessary to account for changes in costs and the extent of contamination.

In accordance with 10 CFR 72.30(c), the information below provides DEN C's periodic update to the MPS ISFSI decommissioning funding plan.

Pursuant to 10 CFR 72.30(b), a decommissioning funding plan must contain:

1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

Millstone Power Station Unit 1 (MPS1) is currently maintaining its spent fuel in wet storage and is not relying on an ISFSI. DENC and the MPS3 co-owners 1 provide financial assurance for decommissioning MPS2 and MPS3 through the prepayment method. The nuclear decommissioning trusts for MPS2 and MPS3 are allocated to radiological decommissioning.

Table 1 below shows crediting 2% real earnings on the prepaid funds through 3.5 years after license expiration as permitted by 10 CFR 50.75(e)(1)(i). The amounts accumulated in the nuclear decommissioning trusts for MPS2 and MPS3 as of December 31, 2017 exceed that required to meet the Nuclear Regulatory Commission (NRC) minimum.and the ISFSI radiological decommissioning cost estimate (DCE) combined. The amounts reported in Table 1 reflect the total amount of funds in the MPS Trusts including those of the MPS3 co-owners. The NRC Minimum and ISFSI DCE amounts are also reported at the 100% level.

1 MPS3 is jointly owned by Dominion Energy Nuclear Connecticut, Inc. (93.4707%), Green Mountain Power Corporation (1.7303%) and Massachusetts Municipal Wholesale Electric Company (4.7990%).

L Table 1 Total Funds in Total Funds in Unit External Trusts External Trusts NRCMinimum End of License Year (12/31/17 $)

(Future $)111 (Future $)121 Millstone Unit2

$700.08

$1,084.12

$450.86 2035 million million million Millstone Unit 3

$729.98

$1,359.94

$479.35 2045 million million million Funds in Excess of NRC Minimum (Future $)1'112l

$633.26 million

$880.59 million Serial No.18-427 Docket No. 72-47 Page 2 of 5 Funds in Excess ISFSI of NRC Minimum DCE (12/31/17 $)131 (12/31/17 $)141

$408.94 million

$1.47

$472.70 million million

1) Total Funds in External Trusts (Future$)= 2% Real Rate of Return applied to growth of funds in the External Trust to 3.5 years after Start of Decommissioning for each unit.

2) NRC Minimum (Future $) = NRC Minimum amount reflects December 31, 2017, NRC Minimum Amount due to the application of a 2% Real Rate of Return to growth of funds in the External Trust and keeping the NRC Minimum amount constant. The MPS NRC Minimum amounts are presented representing 100% responsibility of decommissioning costs.

3) Funds in Excess of NRC Minimum (12/31/17 $) are calculated by applying a 2% discount rate to the Funds in Excess of NRC Minimum (Future $).

4) ISFSI DCE amount as reported in Table 2 of this filing.

2) A detailed cost estimate for decommissioning, in an amount reflecting:

(i) The cost of an independent contractor to perform all decommissioning

• activities; (ii) An adequate contingency factor; and (iii) The cost of meeting the §20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of §20.1403 of this chapter, the cost estimate may be based on meeting the §20.1403 criteria.

General Methodology Used to Develop ISFSI Decommissioning Cost Estimates

{DCE)

A site-specific ISFSI DCE based on 10 CFR 72.30 requirements was prepared for the MPS ISFSI in 2014. The ISFSI DCE was based on the assumption that a third party contractor would perform decommissioning. To determine the cost of using a third party contractor, fully burdened labor rates (labor costs plus employee benefits and

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Serial No.18-427 Docket No. 72-47 Page 3 of 5 taxes) were used as a basis, and a premium was added to represent a third party contractor's profit margin.

The site-specific ISFSI DCE includes undistributed costs (for support activities and costs such as staff, security, insurance, energy, materials and services) allocated to the ISFSI decommissioning period.

The site-specific ISFSI DCE includes 25%

contingency in accordance with NUREG-1757, Volume 3, Revision 1. Table 2 below shows the contingency as one line item.

The site-specific ISFSI DCE is based on remediating the site to a residual radioactivity level consistent with 10 CFR 20:1402 (i.e., unrestricted use). As shown in Table 2 below, the estimated cost to decommission the ISFSI at MPS is $1.471 million in 2017 dollars (100% decommissioning responsibility). Applying a CPl2 based annual escalation rate to the 2014 dollars shown in Table 2, the total cost to decommission the MPS ISFSI is $1.471 million in 2017 dollars.

Table 2 Millstone Power Station Site Specific Cost Estimates Applicable to ISFSI Decommissioning Costs - 10 CFR 72.30 (In thousands of dollars) 25%

Total Total ISFSI Decommissioning Activity Description Labor Equipment Disposal Other Contingency 2014$

2017$

Distributed (Direct) Cost Preparation and NRC Review of License Termination Plan 98 $

152 $

251 $

Verification Survey of Horizontal Storage Modules

-178 $

52 $

230 $

• Preparation of Final Report on Decommissioning and NRC Review 98 $

152 $

251 $

Total Distributed (Direct) Cost 375 $

52 $

305 732 s Undistributed (Allocatedl Cost Total Undistributed (Allocated) Cost 401 $

401 $

Total Millstone ISFSI Decommissioning Cost 776 $

52 $

305 $

1,133 $

25% Contlngencv Aoolled to Total Millstone ISFSI Decommissioning Cost Estimate 283 $

283 $

Total Millstone ISFSI Decommissioning Cost Estimate with Contingency 1,416 $

Annual Escalation Rate 12014$ to 2017$)(

1.27%

Escalation Rate based on average of CPI-U Indices for period shown Decommissioning Cost shown at 100.00%

Information Required by 10 CFR 72.30(c) 10 CFR 72.30(c) requires the updated decommissioning funding plan to specifically consider the effect of the following events on decommissioning costs:

(1) Spills of radioactive material producing additional residual radioactivity in onsi.te subsurface material.

There have been no reported spills affecting the ISFSI.

2 The mnemonic for CPI-U is shown under Item 4.

261 239 261 760 417 1,176 294 1,471

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(2) Facility modifications.

There have been no facility modifications affecting the ISFSI DCE.

(3) Changes in authorized possession limits.

Serial No.18-427 Docket No. 72-4 7 Page 4 of 5 As stated below,- the ISFSI DCE is based on an ISFSI sized, when used in conjunction with the spent fuel pools, to accommodate the spent fuel generated over the life of the station. There are no changes in authorized possession limits affecting the DCE.

(4) Actual remediation costs that exceed the previous cost estimate.

No actual remediation costs have been incurred.

3) Identification of and justification for using the key assumptions contained in the DCE.

The DCE for the MPS ISFSI assumes:

i.

An ISFSI that is sized, when used in conjunction with the spent fuel pools, to accommodate the spent fuel generated over the life of MPS2 and MPS3.

ii.

Decommissioning will be performed by an independent contractor as required.

iii.

Storage canisters will be used to ship the contained spent fuel to the Department of Energy.

iv.

A dry transfer facility will not be necessary.

v.

The ISFSI pad and support modules are assumed to be free of contamination and left in place.

4) A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

DENG (for MPS2 and MPS3) and the MPS3 co-owners use the prepayment method of assuring funds for decommissioning MPS2 and MPS3. As shown above, the prepaid funds in the MPS2 and MPS3 decommissioning trusts exceed, with credited earnings, the amount required by the NRC for radiological decommissioning and the ISFSI DCE combined. The MPS decommissioning cost study and the ISFSI DCE are updated approximately every five years.

The ISFSI decommissioning funding plan periodically submitted pursuant to 10 CFR 72.30(c) will further adjust the most recent site-specific ISFSI DCE using a CPI indice based annual escalation rate and

Serial No.18-427 Docket No. 72-4 7 Page 5 of 5 will consider the need for any further adjustment based on the factors in 10 CFR 72.30(c)(1 )-(4).

The CPI indice annual escalation rate mnemonic is as follows:

CPI - U: Urban Consumer - All Items, (Index 1982-84=100, SA), U.S. Bureau of Labor Statistics (BLS); Moody's Analytics (ECCA) Forecast, Quarterly, United States.

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5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

Onsite subsurface material is assumed to have no residual radioactivity that will require remediation to meet the criteria for license termination.

The spent fuel storage casks are sealed and contain no liquid.

6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

DENG certifies that financial assurance for the estimated cost of decommissioning the MPS ISFSI has been provided as discussed above.