ML19077A366
| ML19077A366 | |
| Person / Time | |
|---|---|
| Site: | 07201038 |
| Issue date: | 03/18/2019 |
| From: | Lippard G, Morris B SCANA Services, South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 19-134 | |
| Download: ML19077A366 (12) | |
Text
< scE&G A SCANA COMPANY March 18, 2019 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 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 Serial No.
LIC/SR Docket No.
License No.19-134 RO 72-1038 NPF-12 DECOMMISSIONING FUNDING PLAN FOR INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) 10 CFR 72.30 DECOMMISSIONING FUNDING PLAN Pursuant to 10 CFR 72.30(b), South Carolina Electric & Gas Company (SCE&G) submitted a decommissioning funding plan for the Independent Spent Fuel Storage Installation (ISFSI) located at Virgil C. Summer Nuclear Station Unit 1 (VCSNS) by letter dated March 15, 2016. 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 and funding plan attached provide SCE&G's periodic update to the VCSNS ISFSI decommissioning funding plan.
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 decommissioning cost estimate.
- 3. Changes in authorized possession limits.
There are no changes in authorized possession limits affecting the decommissioning cost estimate.
- 4. Actual remediation costs that exceed the previous cost estimate.
No actual remediation costs have been incurred.
V. C. Summer Nuclear Station, P. 0. Box 88, Jenkinsville, South Carolina, 29065, F (803) 941-9776, www.sceg.com
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSls Decommissioning Funding Plan Page 2 of 2 SCE&G and the South Carolina Public Service Authority (Santee Cooper) have undivided ownership interests of two-thirds and one-third respectively in VCSNS. Santee Cooper discloses the required financial assurance information relative to its one-third ownership share in a separate submittal.
This letter contains no new or modified regulatory commitments. Should you have any questions concerning the content of this letter, please contact Michael S. Moore at (803) 345-4752.
Very truly yours,
/~~~
George A. Lipppard Site Vice President V. C. Summer Nuclear Station Billie Kay Morris Assistant Controller, Nuclear SCANA Services, Inc.
Attachment - V. C. Summer Nuclear Station Decommissioning Funding Plan for ISFSI cc:
G. J. Lindamood C. Haney S. A. Williams NRC Resident Inspector
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page 1 of 10 Attachment I 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ISFSI DOCKET 72-1038 SOUTH CAROLINA ELECTRIC & GAS COMPANY
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page 2 of 10 10 CFR 72.30 ISFSI Decommissioning Funding Plan
- 1.
Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[11 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 the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS) in an amount reflecting:
- 1. The work is performed by an independent contractor;
- 2. An adequate contingency factor; and
- 3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:
- 1. Identification of the key assumptions contained in the cost estimate;
- 2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.
- 2.
Spent Fuel Management Strategy 2
The operating license for V.C. Summer expires on August 6, 2042. Approximately 2,757 spent fuel assemblies are currently projected to be generated over the life of the plant.
Because of the breach by the Department of Energy (DOE) of its contract to remove spent fuel from the site, an ISFSI has been constructed to provide long term on-site dry storage capability for spent fuel to support continued plant operations. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2J)
U.S. Code of Federal Regulations, Title l 0, 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, 2011 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page3of10 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 exceptions, in the order (the "queue") in which it was discharged from the reactor. r31 In January 2013, the DOE issued the "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission on America's Nuclear Future and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel... "[41 The report stated, "[W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:... [A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities."
Based upon DOE's latest strategy (and the potential for other, consent-based siting of consolidated interim storage facilities), South Carolina Electric & Gas (SCE&G) believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. SCE&G's current spent fuel management plan for the V.C. Summer spent fuel is based in general upon the spent fuel being fully removed from the V.C.
Summer site by 2095.
SCE&G's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above. No assumption made in this study should be interpreted to be inconsistent with this claim. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. If DOE's failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.
- 3.
ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DEGON alternative).
U.S. Code ofFederal Regulations, Title I 0, Part 96 l.l l, Atticle IV - Responsibilities of the Patties, 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... "
"Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S.
DOE, January 11, 2013
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page 4 of 10 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.
- 4.
ISFSI Description The V.C. Summer ISFSI is based upon Holtec lnternational's (Holtec) HI-STORM FW System for the dry storage of used nuclear fuel. The HI-STORM FW System consists of a sealed metallic multi-purpose canister (MPC) contained within an overpack constructed from a combination of steel and concrete. The MPC can accommodate up to 37 undamaged Zircaloy-clad pressurized water fuel assemblies. The overpack provides structural protection, cooling, and radiological shielding for the MPC.
The HI-STORM FW overpack is a rugged, heavy-walled cylindrical vessel. The main structural function of the storage overpack is provided by carbon steel, and the main shielding function is provided by plain concrete. The overpack plain concrete is enclosed by a steel weldment of cylindrical shells, a thick baseplate, and a top annular plate. A set of four equally spaced radial connectors join the inner and outer shells and define a fixed width annular space for placement of concrete. The overpack lid also has concrete to provide neutron and gamma shielding.
The on-site ISFSI at V.C. Summer is located west of the Fuel Handling Building (FHB) and northeast of Warehouses A and B in an expansion of the plant Protected Area. The ISFSI pad has been sized to store 98 HI-STORM FW storage casks with each cask capable of storing 37 Pressurized Water Reactor spent fuel assemblies, which will meet V.C. Summer's spent fuel storage needs over the 60-year licensed life of the plant.
The current spent fuel management plan for the V.C. Summer spent fuel would result in 75 spent fuel storage casks being placed on the ISFSI pad during plant operations. This conservatively assumes that no fuel is removed from the site by the DOE during plant operations or during the nine years of pool operations after the permanent cessation of operations.
The 75 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of 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.
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page 5 of 10
- 5.
Key Assumptions / Estimating Approach 6
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 station operating until the end of its current license (2042) and the DOE's spent fuel acceptance assumptions, as previously described.
The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small_[5l The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 5 of the 75 Holtec overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 157 offloaded assemblies, 37 assemblies per cask which results in 5 overpacks). It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.
The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[61 It would be 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. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.
There is no known subsurface material (soil contamination) in the immediate vicinity of the ISFSI pad that will require remediation to meet the criteria for license termination. As such, there is no allowance for soil remediation in the estimate.
Costs are reported in 2018 dollars and based upon a decommissioning analysis prepared for V.C. Summer in 2016.
Decommissioning is assumed to be performed by an independent contractor. As such, 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.
SCE&G, as licensee, will oversee the site activities.
HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev.2, at page 2-83 (Accession Number MLl3177A428)
HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev. 2, at page 2-84 (Accession Number ML13 l 77A428)
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page 6 of 10 Low-level radioactive waste disposal costs are based on SCE&G's currently negotiated rates with the Atlantic Compact and other waste handling service providers.
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.r7l The estimate is limited to costs necessary to terminate the ISFSl'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 Considerations 7
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 in which the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the remediation (overpack disposition) developed.
The remediation phase includes the cost for craft labor to demolish the activated overpacks, package the steel and concrete in certified waste containers, transportation to the Atlantic Compact Regional Waste site in Barnwell, South Carolina or a bulk waste processing site in Tennessee, for disposal, as well as the costs for the supporting equipment, materials and supplies.
The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.
The estimate also contains costs for the NRC (and NRC contractor) to perform the verification survey, SCE&G'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 2096, the year following all spent fuel removal.
"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.
Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NlJREG-1757, Volume 3, Revision 1, February 2012.
- 7.
Financial Assurance Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page7of10 SCE&G and the South Carolina Public Service Authority (Santee Cooper) have undivided ownership interests of two-thirds and one-third respectively in the V. C.
Summer Nuclear Station, Unit 1. The ISFSI decommissioning cost estimate in 2018 dollars is $6,856,000 based on a cost study prepared by TLG Services, Inc. in 2016.
SCE&G's portion is $4,570,667 and Santee Cooper's portion is $2,285,333. Santee Cooper discloses the required financial assurance information relative to its one-third ownership share in a separate submittal.
ISFSI operations at V.C. Summer are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract.
It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, SCE&G will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.
SCE&G does not maintain separate trusts for funds designated to cover radiological decommissioning costs and funds designated to cover other decommissioning costs. Of the accumulated funds in the trust, approximately 88.69% are considered to be related to funding costs included in the NRC's definition of decommissioning pursuant to 10 CFR 50.75 (b) and (c), while the remaining 11.31% are considered to be related to other decommissioning costs. The 88.69% is the ratio of the total radiological decommissioning cost estimate in a 1991 site specific cost study prepared for V. C.
Summer to the total amount that served as the basis for collections through electric rates in an electric rate order issued by the Public Service Commission of South Carolina (SCPSC) in 1993.
In providing financial assurance pursuant to 10 CFR Part 72, SCE&G is relying on the 11.31 % portion of the accumulated trust fund balance considered to be related to decommissioning costs other than costs pursuant to 10 CFR Part 50. The total trust fund balance at December 31, 2018 was $190,330,017, after tax. Advances of $54,890,000 from SCE&G to fund premium payments have not been deducted in arriving at this amount. The 11.31 % portion of the trust fund balance at December 31, 2018 was
$21,526,325, after tax. As above, advances of $6,208,059 from SCE&G to fund premium payments that are considered to be applicable to this portion of the fund have not been deducted in arriving at this balance.
SCE&G's use of decommissioning funds does not require prior approval from the SCPSC. Moreover, SCE&G is unaware of any SCPSC requirement prohibiting the Company from using any portion of its decommissioning funds for radiological decommissioning costs. SCE&G will continue to assess the adequacy of annual collections and request rate relief as appropriate based upon results of models incorporating site specific cost study estimates.
Serial No.19-134 Docket No. 72-1038 VCSNS ISFSI Decommissioning Funding Plan Attachment I Page 8 of 10 SCE&G hereby certifies that financial assurance for decommissioning its share of the on-site ISFSI at V. C. Summer Unit 1 has been provided in the amount of the cost estimate for decommissioning using the methodology described in the previous paragraphs.
Table 1 Serial No.19-134 Docket No. 72-1038 Attachment I Page 9 of 10 Significant Quantities and Physical Dimensions ISFSIPad Residual Item Len!rth (ft)
Width (ft)
Radioactivity ISFSI Pad 251.5 129.0 No ISFSI Storage Overpack (Holtec FW)
Item Value Notes Overall Height (inches) 239.5 Dimensions are nominal Outside Diameter (inches) 139 Dimensions are nominal Inside Diameter (inches) 81 Dimensions are nominal Quantity 79 75 Spent fuel + 4 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 5 used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,705,088 Concrete and steel Other Low-Level Radioactive Waste (pounds) 1,766 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 30,414 Cubic feet Low-Level Radioactive Waste (packaged density) 56 Average weight density 0th P
er f ll I oten 1a 1y mpacte d It ems Item Value Notes Transfer Cask 1
No residual radioactivity Number of Overpacks used for GTCC storage 4
No residual radioactivity
~-~-----~
Table 2 Serial No.19-134 Docket No. 72-1038 Attachment I Page 10 of 10 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2018 dollars)
Decommissioning Contractor I Removal
! Packaging I Transport Disposal Planning (characterization.
specs and procedures)
Decontamination.Demolition 1
(activated cask disposition)
License Termination (radiological survevs)
Subtotal I Supporting Costs l\\RC and :--.JRC Contractor Fees and Costs Insurance Pro ertv Taxes 139 97 173 2.262 139 97 173 2,262
- i Other 301 31 1,373 1,705 423 124 0
Total Waste Volume I
Class A 1
[ (cubic feet) 1 I
301 :
2,702 30.414 1,373 Person-Hours I 0Yersight and I Craft Contractor 1,096
- I I
2.135 11,060 4,376 30,414 1
13,195 1,096 423 i
- I 776 124 0
54 54 Plant Energ~v_B_u_d~g~e_t ----+------+-------t-------t-------t-------t-------t---------,---------------,
- -Jon-Labor Overhead 12 12 Co orate A&G 27 27 Securitv ( industrial) 219 219 5,013 SCE&G Oversight Staff 250 250 3,803 Subtotal 1,109 '
1,109 9,592 Total (w/o contingenn) 139 97 173
- 2,262 2,814 5,485 30,414 i 13.195 10,688 Total (w/25% continaencv) 174 121 215 2,828 3,518 I 6,856