ML20206P092

Responds to Discussing Impact That Delays to Wesflex Sys Approval Would Have on Big Rock Point Decommissioning Cost & Schedule

ML20206P092
Person / Time
Site:	Big Rock Point, 07201026  File:Consumers Energy icon.png
Issue date:	05/07/1999
From:	Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Withrow G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9905180144
Download: ML20206P092 (1)

Text

1 May 7, 1999

' Mr. Gregory C. Withrow

' Acting Site General Manager Consumers Energy Big Rock Point Nuclear Plant 10269 US-31 North Charlevoix, Michigan 49720

SUBJECT:

RESPONSE TO FEBRUARY 26,1999, LETTER

Dear Mr. Withrow:

I am responding to your February 26,1999, letter. In your letter, you discussed the impact that delays to the Wesfiex System (Wesfiex) approval would have on Big Rock Point's decommissioning cost and schedule. You explained that dry fuel storage is a critical path for decommissioning Big Rock Point and any delay in loading fuel into casks beyond summer 2002 places in question the adequacy of existing funding to complete the project.

We appreciate Consumer Energy's economic need for approval of Wesfiex by the year 2001.

The current storage review schedule for Wesfiex anticipates issuance of a preliminary safety evaluation report and initiation of rulemaking by March 2000. Based on this schedule, the final certificate of compliance would be issued by February 2001. Please note that when this schedule was developed, the needs of Consumers Energy's Big Rock Point and Palisades plants were taken into consideration.

Your letter referred to our February 10,1999, conference call during which we discussed Big Rock Point's need to store mixed-oxide (MOX) and damaged fuel in the Wesflex System. We understand that Westinghouse Electric Company plans to submit an application for storage of MOX and damaged fuel in Wesfiex in July 1999. We will schedule our review of this application when we receive it.' We will determine the review schedule based on our existing work and available resources and, to the extent that we can, your needs.

If you have any questions on this matter, please contact Marissa Bailey at (301) 415-8531.

Sincerely, ORIGINAL SIGNED BY :s; I

Susan F. Shankman, Deputy Director Licensing and Inspection Directorate 9905180144 990507 Spent Fuel Project Office g5 Office of Nuclear Material Safety DR ADOCK 0 and Safeguards

/, 0 Docket Nos.: 72-1026,50-155

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g nezy Washington, DC 20555-0001 DOCKET 50155 - UCENSE DPR BIG ROCK FOINT PLANT - CObT/5CHEDULE IMPACT FROM DELAYS IN APPROVAL OF WESFLEX DRY FUEL STORAGE SYSTEM.

The purpose of this letter is to provide infonnation pertaining to the cost and schedule impact on Big Rock Point's deceiTTiissioning and restoration initiative from delays in approval of the Wesflex Dry Fuel Storage System. The information is provided in response to a staff request during a conference call on February 10,1998 involving representatives froen NRC's Spent Fuel Project Of5ce (SFPO) and Dry Fuel Storage Teams from Consumers Energy's Big Rock Point and P L Ay Plants.

Summary of Big Rock Point's Position Big Rock Point's position is that any delay in loadmg fuelinto casks beyond the current schedule of summer, 2002 would place in question the =Agi y of existing funding to complete the project.

Description of Current Schedule The current Big Rock Point Restoration Project calls for removal of fuel from the spent fuel pool and conunencement of dry cask storage activities dunng the period June.

i November, 2002. Big Rock Point is preparing, and in fact would much prefer, to perform

.h g fuel loadmg in the summer of 2001, and a contingency plan has been prepared to l,

accelerate the schedule should licensure and manufacture of spent fbel storage casks be complete. Northern Michigan's weather conditions limit fuelloading and stotwe 7f activities to the wanner weather months.

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Dry fuel loading and storage is a pivotal evolution in Big Rock Point's integrated schedule. Currently, we are on track to complete dismantlemem of systems and structures not required to support spent fuel pool operanon by mid.2001, and are underway on the planning phase of major component removal. Actual removal oflarge 10nnn<

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BIG ROCK POINT PLANT - COST / SCHEDULE IMPALT FROM DELAYS IN APPROVAL OF WESFLEX DRY FUEL STORAGE SYSTEM.

components is scheduled to commence in late 2000 and continue through 2004. As currently scheduled, site restoration sliould occur early in 2005, after which ISFSI maintenance will be the only ongoing activity.

l Discussion i

Because of the closely coupled contractual commitments necessary to suppon Big Rock Point's integrated schedule, delays in loading and stonng spent fuel beyond the year 2002 would be expected to add at least $20 million annually to total project costs. This conservative estimate assumes schedule flexibility and avadability among the various vendors who have contractually committed to perform key activities based on our current published schedule. There would cenamly be costly delays in developing alternatives, such as removal of the reactor vessel with spent fuel remaining in the pool.

The current integrated schedule makes efGcient use of management personnel, planning and construction supervision, contractor expens, radwaste and radiation protection professionals, operators, and security staff through 2005. We would consider the loss of institutional knowledge and Big Rock Point site-specific dismantlement experience in any of these disciplines to have a serious adverse impact on our ability to complete the restoration safely and efficiently. Delays would resultin higher total fixed costs in these categories.

Delays beyond 2002 would increase Big Rock Point's vulnerability to unforeseeable changes in waste acceptance charges and practices. As a minimum, we would anticipate additional charges from our waste removal contractor. Our current schedule appropriately emphasizes the urgency of shipping all available radioactive waste to the existing waste site before burial charges escalate funher. Untimely closure of the Barnwell facility would seriously impair our ability to complete site restoration.

Cutrent spending levels are appmpriate to suppon the existing schedule, and interest earned on the declining fund balance will supplement available funding for approximately two more years. However, by 2002, on our current schedule, available funding will have been drawn down to a level that will be inadequate to accommodate additional delays.

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I BIG ROCK POINT PLANT - COST / SCHEDULE BiPACT FROM DELAYS IN APPROVAL OF WESFLEX DRY FUEL STORAGE SYSTEM.

Conclusion Big Rock Point has exanuned the integrated nature of the restoration schedule, the rate of spending to support the schedule, available funding, contractual specifications, and the significance of unloading the spent fuel pool to the project's critical path. After careful consideration, we have determined that any delay in spent fuelloading beyond the year 2002 presents a high potential to place in jeopardy the timely completion of the restoration project. Specifically, we have concluded that fuel loading delays beyond 2002 would cause the sufficiency of decommissioning funds to be in question.

For additional information, please contact Mr. Stephen Guthrie of my staff at (616) 547 8254.

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Grego

. Withrow Acting Site General Manager CC:

Administrator, Region m - USNRC NRC Reactor Decommissioning Inspector - Big Rock Point NRR Pmject Manager-OWFN, USNRC 8

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