ML19003A146

Independent Spent Fuel Storage Installations (Isfsis) - Submittal of 10 CFR 72.30 Decommissioning Funding Plan

ML19003A146
Person / Time
Site:	North Anna
Issue date:	12/31/2018
From:	Huddle K Old Dominion Electric Cooperative
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML19003A146 (9)

Text

ODEC Old Dominion Electric CooperativesM December 31, 2018 ATTN: Document Control Desk Director, Division of Spent Fuel Management

• Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission License No. SNM-2507, 2501 Washington, D. C. 20555-0001 Docket No. 72-16, 72-56 OLD DOMINION ELECTRIC COOPERATIVE NORTH ANNA POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS (ISFSls) 10 CFR 72.30 DECOMMISSIONING FUNDING PLAN Pursuant to 10 CFR 72.30(b) and (c), Old Dominion Electric Cooperative submits the attached decommissioning funding plan for the North Anna Power Station ISFSls.

Please contact me at (804) 968-7151 if you have any questions or require additional information.

Sincerely,

. Karen E. Huddle Manager of Treasury Services Old Dominion Electric Cooperative

Attachment:

North Anna Power Station Decommissioning Funds Plan for ISFSls Commitments made by this letter: None cc: Ms. Yen-Ju Chen Senior Project Manager U.S. Nuclear Regulatory Commission, Mail Stop 4834 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738

Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Virginia Electric and Power Company 120 Tredegar Street Richmond, Virginia 23219 Frederick D. Gerloff Decommissioning Project Manager Dominion Energy Services, Inc.

5000 Dominion Blvd, 2SE Glen Allen, VA 23060 9 4201 Dominion Boulevard ~ 804-747-0592 Jbt 804-747-3742 @) www.odec.com Glen Allen, Virginia 23060

Docket Nos. 72-16, 72-56 Attachment 1 Page 1 of 7 Attachment 1 OLD DOMINION ELECTRIC COOPERATIVE

. North Anna Power Station Decommissioning Funding Plan for ISFSls Old Dominion Electric Cooperative North Anna Power Station - ISFSls

Docket Nos. 72-16, 72-56 Attachment 1 Page 2 of7 Attachment 1 Decommissioning Funding Plan for NAPS ISFSls Specific License No. SNM-2507, 2501, Docket NQ. 72-16 General License under 10 CFR 72.210, Docket N~. 72-56 Pursuant to 10 CFR 72.30(b), Old Dominion Electric Cooperative (ODEC) submitted a decommissioning funding plan for the North Anna Power Station (NAPS) Independent*

Spent Fuel Storage Installations (ISFSls) on December 13, 2012 (ADAMS Accession No. ML12353A032). ODEC responded to an NRG Request for Additional Information related to this submittal on September 30, 2013 (ADAMS Accession No. ML13295A329). ODEC further submitted a-Correction Notice on October 21, 2013, correcting (ADAMS Accession No. ML13296A023). The latest NAPS Decommissioning Funding Plan for the NAPS ISFSls was submitted on December 15, 2015 (ADAMS Accession No. ML16020A001 ).

10 CFR 72.30(c) requires each holder of a license under Part 72 'to* resubmit the decommissioning funding plan at the time of license renewal and at intervals not to exceed three (3) 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 ODEC's periodic update to the NAPS 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.

ODEC provides financial assurance for the decommissioning of NAPS using the external sinking fund method. Collections are based on site-specific cost estimates that include radiological decommissioning, spent fuel management (including ISFSI decommissioning) and site restoration.

Table 1 below shows the Total Funds and Allocated Radiological Funds accumulated as of December 31, 2017 and in future dollars for NAPS Units 1 and 2.

The table shows that the fun9s available for ISFSI Decommissioning, Spent Fuel Management and Site Restoration exceed the ISFSI Decommissioning Cost Estimate (DCE) amount.

Docket Nos. 72-16, 72-56 Attachment 1 Page 3 of7 Table 1 Allocated Allocated Radiological Radiological Funds Available Total Funds in Total Funds in Funds in Funds in ISFSls Decom.

External External External External Spent Fuel Mgt & ISFSls Unit Trusts Trusts Trusts Trusts NRC Minimum Site Restoration DCE End of License Year /12/31/17 $) /Future$)(') /12/31/17 $) /Future $)(2l /Future $)(3) (12/31/17 $)(4) /12/31/17 $)(5)

North Anna Unit 1 . $90.67 $145.12 .$62.56 $100.12 $50.97 $28.11 2038 million million million million million million $174,500 North Anna Unit 2 $93.14 $149.07 $64.26 $107.83 $50.97 $28.88 2040 million million million million million million

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

2

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

3

<> 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 Trusts and keeping the NRC Minimum amount constant. The NAPS NRG Minimum Amounts are presented representing ODEC's

10. 74% share of responsibility for NAPS decommissioning costs 1 .

<4> Funds Available for ISFSI Decommissioning, Spent Fuel Management and Site Restoration (12/31/17 $) is calculated as the difference between Total Funds in the External Trusts (2017 $) and the Allocated Radiological Funds in External Trusts (2017 $).

5

<> ISFSI DCE amount as reported in Table 2 of this filing.

As a regulated electric utility, ODEC has the ability to recover its cost of service, including decommissioning funding, through rates. ODEC obtains a site specific ISFSI DCE for NAPS from Dominion Energy approximately every five years to determine whether there is any need to adjust wholesale power rates and contributions to the external sinking fund. The decommissioning cost is a fixed number in ODEC's formulary rate that requires Federal Energy Regulatory Commission approval prior to any adjustment.

1 North Anna Power Station is jointly owned by Virginia Electric and Power Company (88.4%)

and Old Dominion Electric Cooperative (11.6%). However, ODEC is responsible for 10.74%

of the decommissioning obligation.

Docket Nos. 72-16, 72-56 Attachment 1 Page 4 of7

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 1th is chapter, the cost estimate may be based on meeting the §20.1403 criteria.

General Methodology Used to Develop ISFSI Decommissioning Cost Estimates A site-specific ISFSI DCE based on 10 CFR 72.30 requirements was prepared for the NAPS 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 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 CFR20.1402 (i.e., unrestricted use). As shown in Table 2 below, the estimated cost to ODEC to decommission the ISFSls at NAPS is $168,000 in 2014 dollars (10.74% decommissioning responsibility). Applying a CPl 2 based annual escalation rate to the 2014 dollars shown in Table 2, the total cost to decommission the NAPS ISFSls is $174,500 in 2017 dollars.

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

Docket Nos. 72-16, 72-56 Attachment 1 Page 5 of7 Table 2 North Anna 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 Precaration and NRC Review of License Termination Plan $10.5 $ - $ - $16.6 $ - $27.1 $28.1 Verification Survey of Horizontal Storage Modules $14.1 $6.8 $ - $ - $ - $20.9 $ 21.7 Precaralion of Final Recort on Decommissionina and NRC Review $10.5 $ - $ - $16.5 $ - $27.0 $28.1 Total Distributed (Direct) Cost $35.1 $6.8 $ - $33.1 $ - $75.0 $77.9 Total Undistributed (Allocated) Cost $38.9 $1.6 $ - $18.9 $ - $59.4 $ 61.7 Total North Anna ISFSI Decommissionin11 Cost $74.0 $8.4 $ - $52.0 $ - $134.4 $139.6 25% Contin11encv Applied to Total North Anna ISFSI Decommissionin11 Cost Estimate ' $33.6 $33.6 $ 34.9 Total North Anna ISFSI Decommissionin11 Cost Estimate with Contingency $168.0 $174.5 Annual Escalation Rate (2014$ to 2017$) 1.27% Escalation Rate based on average of CPI-U indices for period shown Decommissioning Cost shown at 10.74% ODEC Decommissioning Responsibilitv Percentaae 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 onsite subsurface material.

There have been no reported spills at the ISFSI.

(2) Facility modifications.

There have been no facility modifications affecting the ISFSI DCE.

(3) Changes in authorized possession limits.

As stated below, the ISFSI DCE is based on ISFSls that are sized, when used in conjunction with the spent fuel pool, 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.

• Docket Nos. 72-16, 72-56 Attachment 1 Page 6 of7

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

The DCE for the NAPS ISFSls assumes:

i. ISFSls that are sized, when used in conjunction with the spent fuel pool, to accommodate the spent fuel generated over the life of the station.

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. Single purpose canisters will be qualified for shipment or transported in licensed transportation overpacks to avoid the need for repackaging and will maintain occupational exposures as low as reasonably achievable.

iv. A dry transfer facility will not be necessary.

v. The ISFSI pads and support modules are assumed to be_ free of contamin.ation 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.

ODEC uses an external sinking fund method for NAPS. The external sinking fund is based on site-specific cost estimates that include estimated ISFSI decommissioning costs. ODEC obtains these *cost estimates from Dominion Energy approximately every five years to determine whether there is any need to adjust wholesale power rates and contributions to the external sinking fund. 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*cp1 indice based escalation rate and 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.

Docket Nos. 72-16, 72-56 Attachment 1 Page 7 of7

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

Onsite subsurface material associated with the NAPS ISFSls 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 ar:id contain no liquid.

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

ODEC certifies that financial assurance for the estimated cost of decommissioning the NAPS ISFSls has been provided as discussed above.