ML20198M378

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Trojan Independent Spent Fuel Storage Installation'S (ISFSI) - Radiological Decommissioning Cost Estimate and Funding Plans Additional Documentation
ML20198M378
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 07/08/2020
From: Jenkins B
Portland General Electric Co
To:
Document Control Desk, Division of Fuel Management
References
VPN-007-2020
Download: ML20198M378 (11)
v • d • e


Text

Portland General Electric Company Trojan ISFSI 71760 Columbia River Hwy Rainier, Oregon 97048 July 8, 2020 VPN-007-2020 Trojan ISFSI Docket No. 72-17 License No. SNM-2509 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Trojan Independent Spent Fuel Storage Installation's {ISFSI)

Radiological Decommissioning Cost Estimate and Funding Plans Additional Documentation Pursuant to 10 CFR 72.30(b), Portland General Electric (PGE) submitted for Nuclear Regulatory Commission (NRC) review and approval the proposed Trojan ISFSI Preliminary Radiological Decommissioning Plan (PGE-1082), Revision 2 via letter VPN-004-2020, dated March 23, 2020.

PGE's, Pacificorp's and Eugene Water and Electric Board's (EWEB), Trojan Nuclear Plant and Trojan ISFSI co-owners, Certifications of Financial Assurance were not included due to personnel unavailability associated with COVID-19/Coronavirus workplace restrictions as required or requested to meet the 10 CFR 72.30 Sections of the Decommissioning Planning Rule and the guidance in NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance, Financial Assurance, Record keeping, and Timeliness.

These documents are now provided in this mailing for insertion as Appendix 7-1, 7-2, and 7-3 in PGE-1082 Revision 2 as attached in Enclosure I.

If there are any questions regarding *this letter, please contact Mr. Mark E. Tursa of my staff at (503) 556-7030.

Sincerely, Bradley Y. Jenkins Vice President, Utility Operations Enclosures c: Director, NRC Region IV, DNMS (without Enclosures)

Todd Cornett, ODOE (with Enclosure I)

Deborah Hart, EWEB (with Enclosure I)

Mike Johanson, PacifiCorp (with Enclosure I)

Dana Sandlin, BPA (with Enclosure I)

ENCLOSURE I to VPN-007-2020 TROJAN ISFSI CO-OWNERS (PGE, PACIFICORP AND EWEB) CERTIFICATES OF FINANCIAL ASSURANCE FOR INSERTION AS RADIOLOGICAL DECOMMISSIONING PLAN (PGE-1082), REVISION 2 10 CFR 72.30 requires specific information and several documents, related to Trojan's Radiological Decommissioning Cost Estimate and associated Co-Owner Funding Plans, to be submitted to the NRC for review and approval. This information and the supporting documents have been put into this Topical Report titled: "Trojan ISFSI Preliminary Radiological Decommissioning Plan (PGE-1082)."

PGE's, Pacificorp's and Eugene Water and Electric Board's (EWEB), Trojan Nuclear Plant and Trojan ISFSI co-owners, Certifications of Financial Assurance were not included in the March 23, 2020 submission to the NRC due to personnel unavailability associated with COVID-19/Coronavirus workplace restrictions as required or requested to meet the 10 CFR 72.30 Sections of the Decommissioning Planning Rule and the guidance in NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness.

These documents are now provided for insertion as Appendix 7-1, 7-2 and 7-3 in PGE-1082 Revision 2 in this Enclosure I.

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN APPENDIX 7-1 Certification of Financial Assurance from Portland General Electric Company for 67.5% Ownership

  • Revision 2

CERTIFICATION OF FINANCIAL ASSURANCE Principal: Portland General Electric Company, 121 SW Salmon Street, Portland, Oregon 97204-2901 NRC license number, name and address of facility: SNM-2509, Trojan Independent Spent Fuel Storage Installation (ISFSI), 71760 Columbia River Highway, Rainier, Oregon 97048 Issued to: U.S. Nuclear Regulatory Commission I certify that Portland General Electric Company, as a co-owner of the Trojan site and Trojan ISFSI facilities with Eugene Water and Electric Board and PacifiCorp, is licensed to possess spent nuclear fuel, licensed under 10 CFR Part 72 in the following amounts:

Type of Material Spent fuel from Trojan Nuclear Plant and associated radioactive materials related to receipt, storage, and

  • transfer of the fuel assemblies. Chemical and/or Physical Form: Spent fuel assemblies and damaged fuel assemblies as UO2 clad with Zircaloy-4. Fuel debris as UO2 contained in Failed Fuel Cans or Damaged Fuel Containers.

Amount of Material 344.5 MTU of intact spent fuel assemblies, damaged fuel assemblies, and fuel debris.

I also certify that financial assurance for Portland General Electric Company's 67.5 percent ownership share of the

  • Trojan site and Trojan ISFSI facilities in the amount of $7,032,000 ( of the total site-specific ISFSI radiological decommissioning cost estimate of $10,417,000), in nominal US dollars will be obtained, as described below for the purpose ofISFSI radiological decommissioning as prescribed by 10 CFR Part 72.

\

I also certify that Portland General Electric Company is qualified to use the assurance method of 10 CFR Part 72.30(e)(5) and 10 CFR Part 50.75(e)(l)(ii), and Portland General Electric Company recovers the total cost of its share of Trojan decommissioning costs through rates established by "cost of service" or similar ratemaking regulation which will provide funds needed for its share ofISJ:SI radiological decommissioning costs. As of December 31, 2019, $5,420,379 has been collected in Portland General Electric Company's Nuclear Decommissioning Trust ISFSI Radiological Decommissioning Sub-Account for its share ofISFSI radiological decommissioning costs. Portland General Electric Company uses a 2 percent annual real rate of return, per 10 CFR 50.75(e)(l)(ii), on invested Radiological Decommissioning Sub-Account dollars and this results in a projected Radiological Decommissioning Sub-Account balance of$10.9 million for December 31, 2056, the projected start date of radiological decommissioning is in 2057. In the future, if additional funds are needed for ISFSI radiological decommissioning, the funds will be transferred from one of the other Trojan decommissioning trust accounts into the ISFSI Radiological Decommissioning Sub-Account.

Contact information for this certification of financial assurance by Portland General Electric Company is as follows:

Licensee Name: Portland General Electric Company License Number: SNM-2509 Docket Number: 72-017

  • Issuer: Portland General Electric Company 121 SW Salmon Street Portland, Oregon 97204-2901 James Lobdell, Senior Vice President Finance, CFO and Treasurer Phone: 503-464-2723 Trustee: The Northern Trust Company 333 South Wabash Avenue, WB-42, Chicago, Illinois 60604 USA Andrea Law, Senior Vice President Phone: 312-630-6801 Date: April 21, 2020 Portland General Electric Company e *or
  • e resident Finance, Chief Financial Officer and Treasurer

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN

  • APPENDIX 7-2 Certification of Financial Assurance from Eugene Water and Electric Board (EWEB) for 30% Ownership - Enclosed
  • Revision 2

CERTIFICATION OF FINANCIAL ASSURANCE

  • Principal: Eugene Water & Electric Board NRC license number, name and address of facility: SNM-2509, Trojan Independent Spent Fuel Storage Installation (ISFSI), 71760 Columbia River Highway, Rainier, Oregon 97048 Issued to: U.S. Nuclear Regulatory Commission I certify that Eugene Water & Electric Board, with Portland General Electric Company and PacifiCorp are licensed to possess spent nuclear fuel, licensed'.under 10 CFR Part 72 in the following amounts:

Type of Material Spent fuel from Trojan Nuclear Plant and associated radioactive materials related to receipt, storage, and transfer of the fuel assemblies. Chemical and/or Physical Form: Spent fuel assemblies and damaged fuel assemblies as UO2clad with Zircaloy-4. Fuel debris as UO2 contained in Failed Fuel Cans or Dama~ed Fuel Containers.

Amount of Material 344.5 MTU of intact spent fuel assemblies, damaged fuel assemblies, and fuel debris.

I also certify that financial assurance for Eugene Water &Electric Board's 30 percent Trojan ownership share in the amount of $3,125,000 of the total site-specific ISFSI radiological decommissioning cost estimate of $10,417,000, in nomi.nal US dollars has been obtained for the purpose of ISFSI radiological decommissioning as prescribed by 10 CFRPart 72.

I also certify that the Eugene Water & Electric Board maintains Net Billing Agreements with the Bonneville Power

  • Administration (Bonneville). The Net Billing Agreements contractually obligate Bonneville to pay costs associated with Eugene Water & Electric Board's 30 percent ownership share of Trojan, including spent fuel management, ISFSI radiological decommissioning, and non-radiological decommissioning costs. Bonneville's confirmation of its contractual obligation is attached to this Certification. Pursuant to 10 CFR Part 72.30(e)(4), Eugene Water &

Electric Board, a government agency, uses a Statement of Intent to provide financial assurance for Eugene Water &

Electric Board's 30 percent of the costs of Trojan decommissioning, including ISFSI radiological decommissioning.

Contact information for this certification of financial assurance by Eugene Water & Electric Board is the following:

Licensee name: Eugene Water & Electric Board License number: SNM-2509 Docket number: 72-017 Licensee: Eugene Water & Electric Board 500 East 4 th Avenue Eugene, Oregon 97401 Frank Lawson, General Manager Phone: 541-685-7000 Signature and V

Frank Lawson

Title:

General Manager

Department of Energy Bonneville Power Administration Mail Drop 1399 P.O. Box968 Richland, Washington 99352-096.8 POWER BUSINESS LINE March 27, 2020 In reply refer to: PGAC/Richland AT1N: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Trojan ISFSI Docket No.72-017 License No. SNM-2509

Dear Sir or Madam:

The Bonneville Power Administration (BPA) entered into a contract in 1970 with the Eugene Water and Electric Board (EWEB) regarding EWEB's thirty percent ownership share of the Trojan Nuclear Power Plant (Trojan). Under this contract, BPA provides the funding for EWEB's share of Trojan costs and in tum receivedEWEB's share of Trojan's power. This contract remains in place until its termination at the end of all clecommissioning activities.

Under this contract, BPA has a contractual commitment to pay any decommissioning costs attributable to EWEB for both the Trojan Nuclear Plant and the Independent Spent Fuel Storage Installation. The Trojan costs are included in BP A's costs which ate required by law to be recovered by BPA from its ratepayers. The funding is through the BPA Fund.

If you have any questions concerning this correspondence, please contact Ms. Dana Sandlin at (509) 372-5756.

Sincerely, Cherie Sonoda, Nuclear Supervisor Contract Generating Resources ecc:

Ms.Deborah Hart, EWEB Mr. Todd Cornett, Oregon Dept of Energy Mr. Mark Tursa, PGE Mr. Mike Johanson, PacifiCorp

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN

  • APPENDIX 7-3 Certification of Financial Assurance from PacifiCorp for 2.5% Ownership - Enclosed
  • Revision 2
  • . CERTIFICATION OF FINANCiAL ASSlJRANCE NRC license ~umbe~.= name and address of facility: SNM-2509, Trojan Independent Spent Fuel Storage Installation (ISFSI), 71760 Columbia River Highway, Rainier, Oregon 97048 Issued to: U.S. Nuclear Regulatory Commission I certify that PacifiCorp, as a co-owner of the Trojan site and Trojan ISFSI facilities with Portland General Electrip Company and Eugene Water and Electric Board, is licensed to possess spent nudear,fuel., E~ensed under JO CFR P~rt 72 in th, following amounts:

Type of Material Spent fuel from Trojan Nuclear Plant and associated radioactive materials related to receipt, storage, and transfer of the fuel assemblies. Chemical and/or Physical Form: Spent fuel assemblies and damaged fuel assemblies as UO2 clad with Zircaloy-4. Fuel debris as UO2 contained ,in Failed Fuel Can.s or Damaged Fuel Containers.

, ' ' J "

Amount of Material'

  • - : ~44r~ fy!TU .of intact *~l?el}t ft1e, ::is~t!rri-bJ,ies, dam~gyq fl1el ass~IT,1Pfo~s, anq fu_el .debris.
  • ! **. -**' ' ' ** , . *-' , / ,,.*. ,. - .* ' : .,,. ' ***
  • _;** < : .:: '* "*: ,., '. . ,.., ", ** , **
  • _ _'.. . . . . .

I also certify that financial assurance for PacifiCorp's 2.5 percent ownership share of the Trojan site and Trojan ISFSifacilities in the amount of $260,000 (of the total site-specific ISFSI radiological decommissioning cost estimate of$10,417,000), in nominal US dollars, will be obtained, as described below for the purpose ofISFSI radiological decommissioning as prescribed by 10 CFR Part 72.

I also certify that PacifiCorp is qualified to use the assurance method of 10 CFR Part 72.30(e)(5) and 10 CFR Part 50.75(e)(l)(ii), and PacifiCorp recovers the total cost of its share of decommissioning costs through rates established by "cost of service" or similar ratemaking regulation, which will provide funds needed.for PacifiCoi:p's share_ofISFS1 radioJqgical decommissioning costs. As of December 31, 20i9, $1,953,937 has been collected in PacifiCorp's Trojan Nuclear Decommissioning Trust for PacifiCorp's share of Trojan decommissioning costs, including ISFSI radiological decommissioning costs. As of December 31, 2019, $155,449 was deposited into the ISFSI Radiological Decommissioning Fund of PacifiCorp's Trojan Nuclear Decommissioning Trust. Pacificorp uses a 2 percent annual real rate of return, per 10 CPR S0.75(e)(l)(ii), on invested Radiological Decommissioning Sub-Account dollars and this results in a projected Radiological Decommissioning Sub-Account balance of $308,000 for December 31, 2056, the projected start date of radiological decommissioning is in 2057. In the future, if additional funds are needed for ISFSI radiological decommissioning, the funds will be transferred from one of the other Trojan decommissioning trust accounts into the ISFSI Radiological Decommissioning Sub-Account.

  • Contact information for this Ce1tification of Financial Assurance by PacifiCorp is as follows:

I

  • Licensee Name:

License Number:

Docket Number:

PacifiCorp SNM-2509 72-017 Issuer: PacifiCorp 825 NE Multnomah Street Portland, Oregon 97232 Attn: Ryan Weems, VP, Controller and Asst. Treasurer Phone: 503-813-5401 Trustee: State Street Bank and Trust Company T~afayette Corp0r:i.te Center 2 A venue de Lafayette, LCC 2 Boston, Massachusetts 02111 Attn: Ms. Laura Scully, Vice President Phone: 617-786-3000 Date: June 16, 2020 PACIFICORP

, Controller and Asst. Treasurer

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