ML19165A009
| ML19165A009 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  (DPR-080, DPR-082) |
| Issue date: | 06/14/2019 |
| From: | Soenen P Pacific Gas & Electric Co |
| To: | Division of Operating Reactor Licensing |
| Singal B, 301-415-3016 | |
| References | |
| EPID L-2019-LRM-0034 | |
| Download: ML19165A009 (24) | |
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Diablo Canyon Power Plant Post-Shutdown Decommissioning Activities Report, Site-Specific Decommissioning Cost Estimate, and Irradiated Fuel Management Plan Pre-Application Meeting Presented by:
Brian Ketelsen - Decommissioning Manager, Business Analysis Philippe Soenen - Decommissioning Environmental and Licensing Manager June 19, 2019
Meeting Purpose / Goals
- Provide background information to the NRC staff on the current status of Diablo Canyon Power Plant (DCPP) decommissioning planning.
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Provide preliminary information regarding the Post-Shutdown Decommissioning Activities Report (PSDAR), Site-Specific Decommissioning Cost Estimate (SSDCE), and Irradiated Fuel Management Plan (IFMP).
10 CFR 50.82(a)(4)(i) requires a PSDAR be submitted prior to or within two years after permanent cessation of operations. The PSDAR is required to include a description of planned decommissioning activities, schedule, a review of environmental impacts, and an SSDCE, including the costs of managing irradiated fuel.
10 CFR 50.75(f)(3) requires licensees at or about five years prior to the projected end of operations to submit a preliminary decommissioning cost estimate.
10 CFR 50.54(bb) requires an IFMP be submitted five years before expiration of the reactor operating license.
Meeting Purpose / Goals 3
DCPP Decommissioning Planning On November 27, 2018, PG&E notified the NRC of the intent to permanently cease operations at DCPP Units 1 and 2 upon expiration of the operating licenses.
DCPP Unit 1 license expires November 2, 2024 DCPP Unit 2 license expires August 26, 2025 PG&E is currently working on decommissioning planning activities necessary to support direct transition to decommissioning upon permanent cessation of operations.
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Licensing Activities and Schedule Decommissioning specific submittals currently planned through December 2020 Description Current Scheduled Submittal Date Permanent Cessation of Operations (ML18331A553)
November 27, 2018 Exemption Request to Access Nuclear Decommissioning Trust Fund (ML18347B552)
December 13, 2018 DCPP Decommissioning Funding Report (ML19094B780)
March 26, 2019 Post-Shutdown Decommissioning Activities Report August 2019 Site-Specific Decommissioning Cost Estimate August 2019 Irradiated Fuel Management Plan August 2019 DCPP Decommissioning Funding Report (Annually)
March 2020 Permanently Defueled Technical Specification License Amendment Request December 2020 License Amendment Request for Commitments (if required)
December 2020 5
PSDAR, SSDCE, and IFMP The PSDAR, SSDCE, and IFMP are being submitted concurrently under separate cover letters. The technical, schedule, and cost information provided is consistent among these submittals.
PSDAR includes summary information related to the SSDCE and cost of managing irradiated fuel.
10 CFR 50.82(a)(4)(i) requires a PSDAR be submitted prior to or within two years after permanent cessation of operations.
10 CFR 50.75(f)(3) requires licensees at or about five years prior to the projected end of operations to submit a preliminary decommissioning cost estimate.
10 CFR 50.54(bb) requires an IFMP be submitted five years before expiration of the reactor operating license.
Consistent with the Decommissioning Cost Estimate submitted to the California Public Utilities Commission (CPUC) in Dec. 2018.
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Post-Shutdown Decommissioning Activities Report PSDAR is required to be submitted before or within 2 years following permanent cessation of operations In accordance with 10 CFR 50.82(a)(4)(i) the PSDAR contains:
A description of planned decommissioning activities and schedule A discussion of the reasons for concluding the environmental impacts associated with decommissioning will be bounded by previously issued environmental impact statements An SSDCE, including the projected cost for managing irradiated fuel Regulatory Guidance Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Revision 1, dated June 2013 7
PSDAR - Planned Activities and Schedule Period Title Start Finish General Description
- 1) Pre-Shutdown Planning Dec. 2010 Oct. 2024 Consists of detailed planning, engineering, licensing, and permitting efforts, the bulk of which will take place 2017 - 2024.
- 2) Power Block Modifications Nov. 2024 Apr. 2027 Transitions the plant to a decommissioning configuration to support safe and efficient decommissioning.
- 3) Wet Storage May 2027 Jun. 2032 Designates the timeframe where spent nuclear fuel (SNF) is cooling in the spent fuel pools (SFPs) and/or is being transferred to the DC ISFSI. Concurrently, preparations are being made for major decontamination and dismantlement (D&D) in period 4.
- 4) Building Demolition Jul. 2032 Apr. 2035 Consists of D&D of radiological systems, structures, and components. Also includes removal of several ancillary (non-radiological) structures.
- 5) Site Restoration May 2035 Dec. 2038 Includes demolition of non-radiological structures, conduct of final radiological surveys to support license termination, and restoration of non-Independent Spent Fuel Storage Installation (ISFSI) areas. Period ends with 10 CFR 50 license termination.
- 6) ISFSI Operations Jan. 2039 Aug. 2067 Designates the timeframe after 10 CFR 50 license termination where SNF and greater than Class C (GTCC) waste are stored only at the DC ISFSI and transferred to the Department of Energy (DOE) for storage at a permanent off-site repository. This period also includes biological monitoring of the plant site restoration.
- 7) ISFSI Restoration Sep. 2067 Jan. 2076 Consists of removal of ISFSI structures, conduct of final radiological surveys for ISFSI license termination, restoration of affected areas, and biological monitoring of ISFSI restoration.
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PSDAR - Environmental Review PG&E reviewed the environmental effects associated with planned decommissioning activities. The following previously issued National Environmental Policy Act (NEPA) reviews were relied upon:
NUREG-0586, Final Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear Facilities, Supplement 1 (Nov. 2002)
NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for Release License Termination of NRC-Licensed Nuclear Facilities (Jul. 1997)
Atomic Energy Commission, Final Environmental Statement Related to the Nuclear Generating Station Diablo Canyon Units 1 & 2 (May 1973) 9
PSDAR - Operational Area 10
PSDAR - Environmental Review Evaluation of DCPP decommissioning activities within the operational area indicates that the impacts are bounded by the NRC Decommissioning GEISs conclusions and the Final Environmental Statement for the site.
Site-specific assessments were completed as required by the NRC Decommissioning GEIS PG&E concluded moderate impacts to threatened and endangered species due to the potential for threatened and endangered species to be adversely impacted by demolition of the discharge structure 11
PSDAR - Environmental Review Decommissioning activities to support current plans with impacts outside the operational area include:
Offsite Power Supply Modifications Environmental impacts reviewed and determined to be bounded by the Final Environmental Statement for the site.
Offsite Pismo Beach Rail Yard Improvements (not included in the environmental review)
As required, PG&E will verify that the decommissioning activities for the Pismo Beach Rail Yard improvements meet the requirements of 10 CFR 50.82(a)(6)(i) - (iii) or seek appropriate NRC approval if needed.
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Site-Specific Decommissioning Cost Estimate 10 CFR 50.75(f)(3) requires licensees at or about five years prior to the projected end of operations to submit a preliminary decommissioning cost estimate.
PG&E created a decommissioning cost estimate that was submitted to the CPUC in 2018 and was provided to the NRC in the DCPP Decommissioning Funding Report in 2019.
PG&E used a team of nuclear, decommissioning, and DCPP experts to form the detailed decommissioning plan, schedule, and associated cost estimate.
Using the previously-submitted decommissioning cost estimate, PG&E prepared the SSDCE to meet NRC guidance and industry precedent for SSDCE format and content.
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Site-Specific Decommissioning Cost Estimate SSDCE provides projected costs of managing irradiated fuel, as well as radiological decommissioning and site restoration costs.
Regulatory Guidance Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Plants (Feb.
2005)
NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors (Dec. 2004) 14
Site-Specific Decommissioning Cost Estimate Project management plans and studies were prepared to establish the site-specific baseline for decommissioning activities, costs, and an executable schedule.
All schedules and cost estimates were consolidated into a single cost estimate and total project schedule.
The cost estimate was subsequently broken down into 19 major scope items.
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Site-Specific Decommissioning Cost Estimate PG&E developed contingency percentages for each line item cost category with an overall contingency level of 20.6%.
Decommissioning costs are escalated using a blending of:
PG&E union contract and non-represented employee CPUC Rate Case forecast Weighted Gross Domestic Product implicit price deflator Employment Cost Index for Total Private Compensation Average growth rate of Pressurized Water Reactor burial costs from NUREG-1307 Decommissioning trust earnings are projected using Russells 20-year return forecast for equity and fixed income.
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TotalEstimate (Thousands,$2019)
License Termination SpentFuel Management Site Restoration GRANDTOTAL
$5,143,867
$3,159,685
$1,245,867
$738,315 Site-Specific Decommissioning Cost Estimate Costs were divided into the three NRC-defined cost categories (license termination, spent fuel management, and site restoration) 17
Site-Specific Decommissioning Cost Estimate PG&E currently has more funds in the nuclear decommissioning trust (NDT) for DCPP Units 1 and 2 than required to meet the minimum NRC decommissioning amount ($670.2 million [$2019] per unit) calculated pursuant to the requirements of 10 CFR 50.75(c).
DCPP Unit 1 trust account balance end of first quarter 2019 -
$1,414.6 million DCPP Unit 2 trust account balance end of first quarter 2019 -
$1,850.4 million PG&E submitted an exemption request to allow PG&E to withdraw $187.8 million ($2017) from the Diablo Canyon NDT for decommissioning planning prior to permanent cessation of operations.
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Irradiated Fuel Management Plan 10 CFR 50.54(bb) requires an IFMP be submitted five years before expiration of the reactor operating license Results in DCPP IFMP required date of November 2, 2019 The IFMP must include how the licensee intends to manage and provide funding for all irradiated fuel 19
SSDCE and IFMP are based on the assumption that the DOE would commence picking up SNF at DCPP in 2038 with all SNF and GTCC waste transferred by 2067.
For the SNF not already placed at the DC ISFSI, initial interim storage would be the SFPs Approximately 18 months after shutdown, PG&E will implement a spent fuel pool island.
All SNF will be transferred to the DC ISFSI Irradiated Fuel Management Plan 20
Irradiated Fuel Management Plan Current dry cask storage system is comprised of the following:
HI-STORM 100 System A storage multiple purpose canister (MPC) for SNF capable of storing up to 32 SNF assemblies A storage overpack dry cask for SNF, referred to as a HISTORM 100SA A transfer cask, referred to as a HITRAC A low-profile transporter A vertical cask transporter Cask transfer facility 21
The DC ISFSI with use of the current dry cask storage system has adequate capacity for all fuel-related storage The current dry cask storage system licensing basis is limited to a minimum cooling of 10 years Costs assume all SNF will be transferred to the DC ISFSI seven years after permanent cessation of operations for Unit 2 PG&E is planning to implement an alternate dry cask storage design, including required licensing Irradiated Fuel Management Plan 22
Irradiated Fuel Management Plan Estimated cost for spent fuel management after permanent cessation of operations is $1,245.9 million ($2019).
A portion of the funds requested in the exemption request will be used for pre-shutdown planning activities associated with spent fuel management (if approved).
PG&E will annually submit to the NRC by March 31st a report on the status of the funding for managing spent fuel.
In accordance with 10 CFR 50.54(bb), PG&E will notify the NRC of any significant changes in the proposed waste management program.
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Thank You 24