ML20207L001

Transmits Tnp co-owners Annual Rept of Status of Decommissioning Funding for Tnp.Rept Is Based on Most Recent Analysis of Tnp Decommissioning Estimate & Funding Plan,Per Rev 6 to Pge, Tnp Decommissioning Plan

ML20207L001
Person / Time
Site:	Trojan  File:Portland General Electric icon.png
Issue date:	03/08/1999
From:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
VPN-008-99, VPN-8-99, NUDOCS 9903170331
Download: ML20207L001 (21)

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% Portland General Electric Company Trojan Nudear Plant n760 Columbia River Hay March 8,1999 Rainier OR 97048 cs03)sss an s VPN-008-99 Trojan Nuclear Plant Docket 50-344,72-017 License NPF-1 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Annual Report of the Status of Decommissioning Funding for the Trojan Nuclear Plant (TNP) in Accordance With 10 CFR 50.75(fV1)

In accordance with 10 CFR 50.75(f)(1), this letter transmits the TNP co-owners' annual report of the status of decommissioning funding for the TNP. This report, provided in Enclosure I to this letter, is based on the most recent analysis of the TNP decommissioning cost estimate and funding plan as incorporated into Revision 6 of PGE-1061, " Trojan Nuclear Plant Decommissioning Plan."

For convenience, a copy of Section 5, " Decommissioning Cost Estimate and Funding Plan," of the TNP Decommissioning Plan, Revision 6, is provided in Enclosure II. The decommissioning cost estimate and funding plan is updated to reflect actual expenditures and fund balances through December 31,1998. The cost estimate revision also incorporates the actual inflation rate for 1997, which had been estimated in the previous revision, and reflels updated projections associated with staffing, radiological waste burial costs, and work sche <lules.

Sincerely,

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f Stephen M. Quennoz Vice President, Nuclear huh and Thermal Operations Enclosures c: L. H. Thonus, NRC, NRR T. J Kobetz, NRC, NMSS R. A. Scarano, NRC Region IV David Stewart-Smith, OOE A. Bless, OOE 9903170331 990308~

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, . VPN-008-99 March 8,1999 Page 1 of 4 Annual Reoort of the Status of Decommasioning Funding for the Troian Nuclear Plant in Accordance With 10 CFR 50.75(fV1)

As required by 10 CFR 50.75(f)(1), this report constitutes Portland General Electric's (PGE's) annual report of the status of decommissioning funding for the Trojan Nuclear Plant (TNP). The information provided herein is based on the most recent analysis of the TNP decommissioning cost estimate and funding plan as dete.iled in Section 5 of PGE-1061, " Trojan Nuclear Plant

. Decommissioning Plan," Revision 6. For convenience, a copy of Section 5, " Decommissioning Cost Estimate and Funding Plan," of the TNP Decommissioning Plan, Revision 6, is provided in Enclosure II to VPN-008-P concurrently with this report.

10 CFR 50.75(f)(1) states,in part:

Eachpower reactor licensee shall report, on a calendar-year basis, to the NRC by March 31,1999,...on the status ofits decommissioningfundingfor each reactor orpart ofa r.* actor that it owns. The information in this report must include, at a minimum:

1. The amount ofdecominissioningfunds estimated to be requiredpursuant to 10 CFR 50.75(b) and(c);

2. The amount accumulated to the end ofthe calendaryearpreceding the date ofthe report:

3. A schedule ofthe annual amounts remaining to be collected;

4. The assumptions used regarding rates ofescalation in decommissioning costs, rates ofearnings on decommissioningfunds, and rates ofotherfactors used in fundingprojections;

5. Any contracts upon which the licensee is relyingpursuant to paragraph (e)(1)(v) l ofthis section:

6. Any modifications occurring to a licensee 's current method ofprovidingfinancial .

assurance since the last submitted report; and

7. Any material changes to trust agreements.

This report addresses the content and schedular requirements of 10 CFR 50.75(f)(1) as follows:

1. The amount ofdecommissioningfunds estimated to be requiredpursuant to i 10 CFR 50.75(b) and(c).

The amount of funds estimated to be required to decommission the TNP has been determined ,

based on a TNP-specific cost estimate prepared by PGE with assistance from TLG Services, Inc.

l (TLG). As indicated in the TNP Decommissioning Plan, Section 5.1 and Table 5.1-1, the total '

costs in 1997 dollars are estimated to be approximately $239,893,000 for radiological decommissioning activities, approximately $51,138,000 for nonradiological decommissioning <

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. . VPN-008-99 March 8,1999 Page 2 of t.

activities (site restoration), and approximately $132,527,000 for dry spent fuel storage. Costs associated with securing and maintaining decommissioning financial assurance and bridging funds are projected to total approximately $9,566,000. A detailed schedule of the TNP decommissioning and spent fuel management costs, totaling approximately $433,124,000 of decommissioning trust fund related expenditures, is provided in Section 5.1 and Table 5.1-2 of the TNP Decommissioning Plan.

2. The amount accumulated to the end ofthe calendaryearpreceding the date ofthe report.

The table below reflects the amount of decommissioning funds accumulated by the TNP co-owners through December 31,1998. Each of the TNP co-owners separately collect and maintain funds for the decommissioning of the TNP. These funds are collected through rates and deposited to external trust funds in accordance with 10 CFR 50.75. Additional details of the TNP decommissioning funding plans and schedules for each of the TNP co-owners are provided in Section 5.3 of the TNP Decommissioning Plan.

Status of Decommissioning Trust Funds As of December 31.1998 TNP Co-Owner Fund Balance as of12/31/98*

Portland General Electric $62,858,000 Eugene Water & Electric Board (EWEB)/

$14,207'000 Bonneville Power Administration (BPA) l Pacific Power & Light (PP&L) $3,387,000 I i

Total $80,452,000

• The 1998 end-of-year trust fund balances include an adjustment for trust expenditures incurred in November and December 1998 that were not paid out of the trusts in 1998.

3. A schedule ofthe annual amounts remaining to be collected.

The decommissioning trust fund cash flow fc each of the TNP co-owners is described in Section 5.3 and quantified in Tables 5.3-2 through 5.3-4 of the TNP Decommissioning Plan.

As detailed in Section 5.3.2 of the TNP Decommissioning Plan, each TNP co-owner maintains a i decommissioning fund collection schedule which ensures that each co-owner's portion of the decommissioning activity expenditures will be fully funded. These trust fund contribution I

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. schedules are based on fm ading requirements for both radiological and nonradiological decommissioning costs, as well as financing costs and specific spent fuel management costs including planning, design, construction, operation and maintenance (O&M), and {

decommissioning of an independent spent fuel storage installation (ISFSI). The collection

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schedules do not include funding for spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning tmst funds.

4. The assumptions used regarding rates ofescalation in decommissioning costs, rates of earnings on decommissioningfunds, andrates ofotherfactors usedinfunding projections.

The following table provides the TNP co-owners' assumptions regarding escalation, earnings, and interest rates used to project the TNP decommissioning cost and funding schedules as 1 l reflected in Section 5 of the TNP Decommissioning Plan.

Assumptions Regarding

! Escalation, Earnings, and Interest Rates l

Trust Fund Bridge Loan Escalation Earnings Interest Rate

• Line of Credit j 6

TNP Co-Owner Factor * (%) Rate (%) (%)

d Fees (%) j

'5.27 l PGE 2.37 85.55 0.35 '

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'4.14 ,

i BPA/EWEB 2.37 5 N/A N/A l I

L PP&L 2.37 4.5 N/A 0.5 l

• ne escalation rate assumption of 2.37% represents the average of WEFA projected inflation rates for l 1999 through 2023.

b l Each TNP co-owner assumed a trust fund earnings rate based on recent fund earning performance with consideration for projected near-term growth and conservatism.

• Bridge loans for BPA and PP&L are not projected to be necessary.

d BPA plans to use a letter ofintent, rather than a lir e of credit, to provide financial assurance in i accordance with 10 CFR 50.75(cXIXiv).

• This rate is applied to the qualified portion of PGE's trust fund.

Inis rate is applied to the non-qualified portion of PGE's trust fund.

8 The yield spread portion of this value is the average of the WEFA forecasted 5-year note for 2000 and 2001 (the years in which it is projected that the largest bridge loans may be secured) less projected inflation.

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Enclosure I

. VPN-008-99 March 8,1999 Page 4 'of 4 i 5 Any contracts upon which the licensee is relyingpursuant toparagraph (e)(1)(v) ofthis section.

The TNP co-owners do not rely on contractual obligations from customers to satisfy the financial assurance stipu'.ations of 10 CFR 50.75(e)(1). For PGE and PP&L, the financial assurance I mechanism will consist of the decommissioning trust fund balance together with a letter of credit  ;

in accordance with 10 CFR 50.75(eXIXii) and (iii). As allowed by 10 CFR 50.75(eX1Xiv), l BPA, as a Federal government entity fulfilling the decommissioning funding obligations of i EWEB, a licensee, will provide financial assurance in the form of a statement ofintent. 1

6. Any modifications occurring to a licensee 's current method ofprovidingfinancial assurance since the last submitted report.

As of December 31,1998, no modifications have occurred since the last funding plan submittal to the TNP co-owners' planned methods of providing financial assurance that adequate funds will be available to complete radiological decommissioning of the TNP site. A description of the current method each of the TNP co-owners will use to provide financial assurance is provided m l Section 5.3.2 of the TNP Decommissioning Plan. As stated above, for PGE and PP&L, the J financial assurance mechanism will consist of the decommissioning trust fund balance together with a letter of credit. The methodology used to determine the size of the letter of credit is described in Section 5.3.2.1 of the TNP Decommissioning Plan. BPA, as a Federal government et.tity fulfilling the decommissioning funding obligations of EWEB, a licensee, will provide financial assurance in the form of a statement ofintent in accordance with 10 CFR 50.75(eXIXiv).

7. Any material changes to trust agreements. <

The TNP co-owners have not made any material changes to the decommissioning trust l agreements since the last funding plan submittal. i l

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Enclosure II to VPN-008-99 Section 5," Decommissioning Cost Estimate and Funding Plan" of PGE-1061, " Trojan Nuclear Plant Decommissioning Plan," Revision 6 j

'O TRO.lAN DECOMMISSIONING PLAN

5. DECOMMISSIONING COST ESTIMATE AND FUNDING PLAN In accordance with 10 CFR 50.82(a)(4), the TNP-specific cost estimate and funding plan as I incorporated into this section provide: 1 I

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1. An updated estimate of total and remaining TNP decommissioning costs; I I I i

2. A comparison of the estimated costs with present funds set aside for I decommissioning; and l l l

3. The plan for assuring the availability of adequate funds for completion of i ,

decommissioning and release of the TNP site for unrestricted use. l l

l 5.1 DECOMMISSIONING COST ESTIMATE l This section provides the results of and basis for a cost estimate prepared by PGE with I assistance from TLG Services, Inc. (TLG) for the decommissioning of TNP. Incorporated into this cost estimate are costs of activities involved in radiological decommissioning necessary for '

termination of TNP's Part 50 license, as well as expenditures necessary to complete nonradiological site restoration activities. The costs of removal and disposal of nonradioactive structures and materials beyond that necessary for license termination have been identified separately from radiological decommissioning costs.

Also separately identified are cost projections and funding requirements for the onsite management ofirradiated fuel until possession and title of the irradiated fuel is transferred to DOE for ultimate disposal. The description of the spent fuel management costs and associated funding plan provided in this section, together with the description of the spent fuel management program in Section 3.3.1, fulfill the requirements of 10 CFR 50.54(bb). I 5.1.1 COST ESTIMATE RESULTS Summarizing the results of the TNP cost estimate, Table 5.1-1 provides estimates of total I decommissioning costs as well as decommissioning costs that remain as of January 1,1999. As l l indicated in Table 5.1-1, the costs (in 1997 dollars) for the selected decommissioning I 4 alternative are estimated to total approximately $239,893,000 for radiological decommissioning i activities, approximately $51,138,000 for nonradiological decommissioning activities (site 1 l restoration), and approximately $132,527,000 for dry spent fuel storage. Costs associated with I securing and maintaining decommissioning financial assurance and bridging funds are projected to total approximately $9,566,000. A detailed schedule of TNP's decommissioning i and spent fuel management costs, totaling approximately $433,124,000 of decommissioning i trust fund-related expenditures, is provided in Table 5.1-2 and described in Section 5.1.2. I 5-1 Revision 6

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TROJAN DECOMMISSIONING PLAN 5.l.2 COST ESTIMATE DESCRIPTION The initial Decommissioning Plan deconunissioning cost estimate was based largely on the TNP-specific cost estimate perfor ned for PGE by TLG Services, Inc. in May 1994. The  !

methodology used to develop the cost estimate followed the approach presented in 1 AIF/NESP-036," Guidelines to Producing Decommissioning Cost Estimates," and the DOE l

" Decommissioning Handbook." These guidance documents utilize a unit cost factor method  !

for estimating decommissioning activity costs. Unit cost factors incorporate site-specific considerations whenever practicable. Using plant drawings and inventory documents,

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quantities and volumes of the equipment and material to be removed during decommissioning  ;

were estimated. Unit cost factors were applied to the volumes and quantities to estimate the l

" activity dependent" costs. " Period dependent" costs were determined from a critical path schedule based on the removal activity duration.

At the end of each year, PGE updates the decommissioning cost estimate based on actual I decommissioning progress and with an estimate of remaining costs based on the best available I information about the remaining scope of the decommissioning effon. The update generally l l results in changes to the timing of fund expenditures, and may reflect changes to the scope of I major projects. The cost estimate reflects updated staffing requirements, remaining scheduled I decommissioning equipment removal efforts, adjustments for current radioactive waste disposal i volumes and costs, and an update of the estimate to disposition non-radiological hazards. I The results of PGE's decommissioning cost estimate have been incorporated into Table 5.1-2, which provides a comprehensive expen 'iture schedule for the decommissioning of TNP. This table incorporates an annual breakdown of projected costs associated with radiological and nonradiological decommissioning, spent fuel management, and decommissioning expenditure financing activities. The decommissioning cost estimate expenditure schedule contained in Table 5.1-2 is described in the remainder of this section.

5.1.2.1 Radiological Decommissioning Costs l The cost schedule for radiological decommissioning activities is incorporated into Table 5.1-2, I i which reflects the results of the decommissioning cost estimate for TNP. Consistent with

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current NRC policy, the TNP decommissioning cost estimate considers radiological I decommissioning costs to be only those costs associated with normal decommissioning activities necessary for termination of the Pan 50 license and release of the site for unrestricted use. The decommissioning cost estimate does not include in radiological decommissioning I costs those costs associated with spent fuel management or the disposal of nonradioactive structures and materials beyond that necessary to terminate TNP's Part 50 license.

5-2 Revision 6

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TRO.lAN DECO *))11SSIONING Pl Rndiological decommissioning activity costs are separately identified in Table 5.1-2 as  !

"DECON/ License Termination." Burial costs were derived from PGE modeling and analysis I oflow-level radioactive waste disposal costs as updated in early 1999, which more l I

conservatively reflect projected burial rates. Contingencies were applied to each area of the I cost estimate (i.e., decontamination and dismantlement, waste disposal, fmal survey, etc.) at I appropriate rates. No credit was taken for equipment salvage value. I Standard ongoing financial controls have been established and executed to ensure funds are i expended consistent with the provisions of 10 CFR 50.82(a)(8). Throughout the budgetary I i process and budget year, costs associated with new projects or activities are evaluated to determine their correct cost classification, i.e., fuel management, radiological, nonradiological I decommissioning, etc. As a result, only costs which meet the intent of the TNP l Decommissioning Plan and TNP License Termination Plan, upon approval, are submitted for i reimbursement from the decommissioning trust. Periodically, variances between the estimate and actual costs will be reviewed as they relate to the total cost estimate to provide assurance ,

that the cost estimate centinues to be reasonable. This complies with 10 CFR 50.82(a)(8)(iXA). i In addition, PGE corporate fincance personnel review the TNP co-owners' trust fund activity I and balance periodically. Any significant activity which is inconsistent with the  !

Decommissioning Plan and License Termination Plan. upon approval, would be brought to the I attention of TNP management.

The decommissioning cost estimate reflects costs in 1997 dollars, and has been updated to I account for work performed through 1998 where TNP expended funds for decommissioning I activities. The decommissioning cost estimate reflects updated staffing requirements, I remaining scheduled decommissioning equipment removal efforts, and adjustments for I radioactive waste disposal volumes and costs to reflect the latest burial cost projections. I Costs required to maintain spent fuel in a safe storage condition are not funded by the trust fund while the spent fuel remains in wet storage. Once the spent fuel is transferred to dry storage, there are sufficient trust fund annual contributions to cover annual costs. This is described in i Sections 5.2 and 5.3.2 and Table 5.1-2. This complies with 10 CFR 50.82(a)(8)(i)(B).

In accordance with 10 CFR 50.82(a)(8)(i)(C) and 10 CFR 50.75(e), the TNP co-owners I periodically assess the financial assurance amount required to complete radiological decommissioning. The established financial assurance mechanisms (i.e., letter of credit) are I adjusted as necessary to ensure that the sum of trust fund balances and letter of credit amounts I equals the amount needed to complete radiological decommissioning. " Bridge" funds are i described in Section 5.3. I l

5-3 Revision 6

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l l TROJAN DECOMMISSIONING PLAN 5cl.2.2 Nonradiological Decommissioning costs -

Although not required by NRC regulations, the decommissioning cost estimate for TNP l incorporates nonradiological decommissioning costs, as indicated in Table 5.1-2. The TNP decommissioning cost estimate considers nonradiological decommissioning costs to be those

. costs associated with site remediation and demolition and removal of uncontaminated structures. The decommissioning cost estimate does not include in nonradiological decommissioning costs those costs associated with spent fuel management or radiological I  ;

decommissioning activities.  !

I ~l 5.1.2.3 Spent Fuel Management Costs  !

Implementation costs associated with spent fuel management are reflected in the projected cost I schedule for the onsite management ofirradiated fuel detailed in Table 5.1-2. Spent fuel management costs begin with ongoing spent fuel pool operation, surveillance, and maintenance activity costs, and continue through ISFSI planning, construction, and operation until possession and title of the irradiated fuel is transferred to the DOE for ultimate disposal (assumed in this estimate to be completed in 2018). As indicated in Table 5.1-2, spent fuel pool operation expenditures are projected to end in early 2000 as e result of the transfer of the I spent fuel pool contents to the ISFSI. Costs associated with onsi.e management of the spent fuel will then involve ISFSI operation, maintenance, and surveillance expenditures. Finally, l upon transfer of the ISFST contents to an offsite repository, spent fuel management costs end in 1 2018 with final expenditures necessary for ISFSI decommissioning activities. I PGE has analyzed spent fuel operations and maintenance costs related to storage in both the spent fuel pool and the ISFSI. The methodology used in this analysis considered plant-specific values, as applicable, for labor, material, and outside professional services requirements as well 1 as for other distributed items such as overheads, property and liability insurance, regulatory j fees, fire protection activities, and power usage. The results of this analysis were then '

l incorporated into the decommissioning cost study. i 5.1.2.4 Financial Activity Costs '

l Additional costs may be incurred by each TNP co-owner as necessary during decommissioning I j to secure and maintain assurance that adequate funds will be available to complete radiological

decommissioning of the TNP site, and to secure loans or other " bridging" mechanisms to augment existing funds to cover near-term decommissioning costs. The financial assurance costs (e.g., letter of credit and loan interest fees) indicated in Table 5.1-2 are based on the basis I m

points and projected amount of required financial assurance appropriate for each co-owner as described in Section 5.3," Decommissioning Funding Plan." The loan costs in Table 5.1-2 are based on the interest rate and loan amount appropriate for each TNP co-owner requiring 5-4 Revision 6

4 TROJAN DECOMMISSIONING PLAN financial bridging as described in Section 5.3. The method which each co-owner will use to provide the required financial assurance mechanisns and bridging funds is described in detail i i Section 5.3. I 1

5.2 SPENT FUEL MANAGEMENT FUNDING PLAN Spent fuel management costs are segregated in Table 5.1-2 into spent fuel pool operation costs and dry storage (ISFSI) costs. Ongoing costs associated with the storage of spent fuel and other high-level radioactive waste in the spent fuel pool are currently incorporated into the TNP O&M budget, and are expected to continue to be funded in this manner until the contents of the spent fuel pool are transferred to the ISFSI. Costs associated with dry storage activities, including ISFSI planning, construction, O&M, and decommissioning, as reflected under the column heading " Dry Storage" in Table 5.1-2, will be funded with decommissioning trust funds collected for that purpose. Additional details on the l

decommissioning trust fund collections for each TNP co-owner are provided in Section 5.3. l

5.3 DECOMMISSIONING FUNDING

PLAN , I 5.3.1 CURRENT DECOMMISSIONING FUNDING CAPABILITIES Each of the TNP co-owners separately collect and maintain funds for the decommissioning of-TNP. These funds are collected through rates and deposited to external trust funds in accordance with 10 CFR 50.75. Because the TNP was shutdown prematurely, the external trust I funds established by the TNP co-owners currently contain only a portion of the total amotmt needed for site radiological decommissioning. Table 5.3-1 summarizes the status of the TNP co-owners' decommissioning trust funds as of December 31,1998. I The NRC's general policy requires, prior to the start of the Decontamination and Dismantlement Period, either funds needed for decommissioning (as the term " decommission" is defined in 10 CFR 50.2," Definitions") to be available or an appropriate financial vehicle to be secured and maintained that will assure the availability of adequate funds for completion of i radiological decommissioning. As indicated above, the trusts established by the TNP l i

co-owners for decommissioning; will not :ontain the funds necessary for completion of radiological decommissioning prior to the start of the Decontamination and Dismantlement l Period. Thus prior to commencing this period, each TNP co-owTier is required to secure a financial assurance mechanism allowed by 10.CFR 50.75(e). This financial assurance must be I

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maintained until terminatior. of TNP's Part 50 license. Furthermore, during the Decontamination and Disn nie.nent Period, a co-owner's decommissioning trust fund balance I may be reduced to a point where it will be necessary in certain instances to borrow or otherwise I provide " bridging" funds to complete decontamination activities and allow scheduled collections to restore the decommissioning, trust fund balance.

5-5 Revision 6

TROJAN DECOMMISSIONING PLAN 5;3.2 TNP CO-OWNERS' DECOMMISSIONING FUNDING PLANS I

Each of the TNP co-owners has established a program in conjunction with specified goals for l the collection of funds for the decommissioning of TNP. Each TNP co-owner maintains a  !

decommissioning fund collection schedule which ensures that each co-owner's portion of the decommissioning activity expenditures will be fully funded. These trust fund contribution schedules are based on funding requirements for both radiological and nonradiological decommissioning costs, as well as financing costs and specific spent fuel management costs including planning, design, construction, O&M, and decommissioning of an ISFSI. These collection schedules do not include funding for spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning trust funds. The decommissioning trust fund cash flow for each of the TNP co-owners, based on the expenditure schedule in Table 5.1-2 and the co-owner contribution schedules, is described below.

5.3.2.1 PGE Fundino Table 5.3-2 provides PGE's decommissioning trust fund cash flow in nominal dollars (2.37% escalation) during deconunissioning. The trust fund expenditures described in this table I are PGE's share (67.5%) of the expenditures described in Table 5.1-2, with the exception of spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning trust funds. The trust fund contributions listed in Table 5.3-2 are based upon PGE's decommissioning trust fund contribution schedule which ensures that PGE's portion of the decommissioning activity expenditures will be fully funded.

Projected requirements for bridging funds have been incorporated into PGE's decommissioning l trust fund cash flow. As previously discussed, PGE's external trust fund currently contains only a portion of the total amount needed for PGE's share of site radiological decommissioning costs. Based on the decommissioning trust fund cash flow analysis presented in Table 5.3-2, bridging funds are anticipated to be required in the year 2000 to complete decontamination I activities and allow scheduled collections to restore the decommissioning trust fund balance.

Projected interest on bridging funds has been incorporated into PGE's trust fund cash flow as I j indicated in Table 5.3-2. j In addition, because the trusts established by the TNP co-owners for decommissioning I will not contain the funds necessary for completion of radiological decommissioning prior i to the start of the Decontamination and Dismantlement Period, each TNP co-owner must secure i a financial assurance mechanism allowed by 10 CFR 50.75, and maintain this assurance until termination of TNP's Part 50 license. PGE's financial assurance mechanism will consist of the decommissioning trust fund balance together with a letter of credit. Because financial assurance will be maintained only for radiological decommissioning activities, the I methodology used to determine the size of the letter of credit ensures that if a given amount of 5-6 Revision 6

4 TROJAN DECOMMISSIONING PLAN the decommissioning trust fund is used for purposes other than radiological decommissioning i activities during a current year, the portion of the financial assurance provided by the letter of credit must be increased by the same amount. This methodology can be summarized as follows:

La = Ti - T2 + T3 where l 1

La = Letter of Credit Portion of Financial Assurance Needed for Current Year j T i= Total costs of remaining radiological decommissioning activities I T 2= Current decommissioning trust fund balance T 3= Portion of trust balance planned for non-radiological costs during current year I i Financial assurance for remaining radiological decommissioning activities will be calculated at I i the beginning of each year and will be periodically reviewed during each year to ensi:re that an adequate level of financial assurance is maintained.

l 5.3.2.2 EWEB/BPA Funding BPA is obligated through Net Billing Agreements to pay costs associated with EWEB's share of TNP, including decommissioning and spent fuel management costs. BPA will fulfill the l

decommissioning funding obligations of EWEB. including providing financial assurance for EWEB's portion of decommissioning costs in a manner stipulated in 10 CFR 50.75(e)(1)(iv) l for Federal government licensees. Table 5.3-3 provides BPA/EWEB's decommissioning trust fund cash flow in nominal dollars (2.37% escalation) during decommissioning. The trust fund I expenditures described in this table are BPA/EWEB's share (30%) of the expenditures described in Table 5.1-2, with the exception of spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning trust funds. The trust fund contributions listed in Table 5.3-3 are based upon BPA/EWEB's decommissioning trust fund contribution schedule which ensures that BPA/EWEB's portion of the decommissioning activity expenditures will be fully funded.  !

i Projected requirements for bridging funds have been incorporated into BPA/EWEB's {

decommissioning trust fund cash flow. As previously discussed, BPA/EWEB's extemal trust l fund currently contains only a portion of the total amount needed for l BPA/EWEB's share of site radiological decommissioning costs. Based on the I decommissioning trust fund cash flow analysis presented in Table 5.3-3, bridging funds will be required to complete decontamination activities and allow scheduled collections to restore the decommissioning trust fund balance. These bridging funds are not expected to incur interest costs since BPA, as a government entity, will provide the additional decommissioning funding wnen necessary according to the schedule listed in Table 5.3-3.

5-7 Revision 6 l

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TRO.1AN DECOMMISSIONING PLAN i

As allowed by 10 CFR 50.75(e)(1)(iv), BPA, as a Federal government entity fulfilling the I i decommissioning funding obligations of EWEB, a licensee, will provide financial assurance in l the form of a statement ofintent. The statement ofintent will contain a reference to the TNP l decommissioning cost estimate described in Section 5.1, indicating that funds for radiological I decommissioning will be obtained when necessary.

1 5.3.2.3 PP&L Fundino Table 5.3-4 provides PP&L's decommissioning trust fund cash flow in nominal dollars (2.37% escalation) during decommissioning. The trust fund expenditures described in this table I are PP&L's share (2.5%) of the expenditures described in Table 5.1-2, with the exception of spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than -j decommissioning trust funds. The trust fund contributions listed in Table 5.3-4 are based upon i PP&L's decommissioning trust fund contribution schedule which ensures that PP&L's portion of the decommissioning activity expenditures will be fully funded.

Based on the decommissioning trust fund cash flow analysis presented in Table 5.3-4, PP&L's decommissioning trust balance will remain adequately funded during decommissioning such that bridging funds will not be required. However, because the trusts established by the TNP i co-owners for decommissioning will not contain the funds necessary for completion of radiological decommissioning prior to the start of the Decontamination and Dismantlement .

Period, PP&L must secure a financial assurance mechanism allowed by 10 CFR 50.75 and I

maintain this assurance until termination of TNP's Part 50 license. PP&L's financial assurance mechanism will consist of the decommissioning trust fund balance together with a letter of credit. The methodology for determining the size of the letter of credit is as described in Section 5.3.2.1,"PGE Funding."

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5-8 Revision 6

TROJAN DECOMMISSIONING PLAM Table 5.1-1 Estimate of " Trust Fund" Decommissioning Costs l (1997 dollars)

Total Total Costs l l (Start-to-Finish) Remaining as of 1 I

, Costs January 1,1999 l l

Radiological (NRC) Decommissioning Costs l I 1 l Reactor Vessel and Internals Removal and Disposal 25,898,000 14,386,000 1 !

Dismantlement, Decontamination, and Remediation 157,200,000 97,853,000 l Waste Disposal 38,233,000 23,888,000 l l 1

Final Survey 18,562,000 17,802,000 1 Total 239,893,000 153,929,000 l l

I Nonradiological Decommissioning Costs i j 1 '

Site Restoration 51,138,000 50,517,000 1 Total 51,138,000 50,517,000 l l

i i

i Dry Spent Fuel Management Costs I ISFSI Constniction and Deconunissioning 62,925,000 41,109,000 l ISFSI Operation and Maintenance 69,602,000 69,496,000 i Total 132,527,000 110,605,000 l I

Financing Costs l l

Financial Assurance 461,000 461,000 1 Decommissioning Bridge Loans 9,105,000 9,105,000 1 Total 9,566,000 9,566,000 l l

l Total Trust Fund Expenditures $433,124,000 $324,617,000 i Revision 6 t

F Table 5.19 Decommissioning Cost Estimate:

Itemized Decommissioning EQ (1997 $ x 100 Radiological Total Trust Expenditures Decommissioning Total Total Total Total Total Radiological Nonrediological Spent Fuel Financing Combined DECON/

C+:- ,,,, c,, Decommissioning Management Adnnty Trust License Year Expenditures Expenditures Expenditures E*Wures Expenditures Termmation 1993 0 0 0 0 0 1994 7,992 0 0 0 7,992 7,992 1995 15,837 0 1,102 0 16,939 15,837 1996 8,529 492 3,144 0 12,165 8,529 1997 19,309 45 7,974 0 27,328 19,309 1998 34,297 86 9,703 0 44,086 34,297 1999 55,029 8,286 26,354 0 89,669 55,029 2000 43,324 5,059 12,272 637 61,292 43,324 2001 39,168 3,083 3,739 1,462 47,452 39,168 2002 14,672 1,719 3,736 1,930 22,057 14,672

.2003 1,736 335 3,729 1.977 7,777 1,736 2004 0 304 3,718 1,569 5,591 2005 0 364 3,703 1,114 5,121 2006 0 305 3,681 660 4,646 2007 0 304 3,655 205 4,164 2008 0 304 3,621 11 3,936 l 2009 0 305 3,580 1 3,886 l 2010 0 304; 3,533 0 3,837 l 2011 0 304 3,476 0 3,780 l 2012 0 304 3,476 0 3,780 1 2013 0 304 3,476 0 3,780 2014 0 304 3,476 0 3,780 1 2015 0 304 3,476 0 3.780 2016 0 304 3,476 0 3,780 2017 0 304 3,476 0 3,780 l 2018 0 10,033 10,951 0 21,884 2019 0 14,105 0 0 14,105 2020 0 304 0 0 304 2021 0 304 0 0 304 2022 0 304 0 0 304 1 2023 0 1,825 0 0 1,825 1 1

Toto,l. 239,893 51.138 132,527 9,566 433,124 239,893 l

c- i

. a--

TROJANDECOMMISSIONINGQ

r. ,

3r Trojan Nuclear Plant APERturrk l

>enditure Schedule

))

CARD l Also Availabla on  !

-knradiological Spent Fuel Management Financin'g~ "" l I Decommissioning Activities SFP Dry Storage l

[

Remediation Spent Costs for l ActMties / Fuel ISFSI Maintaining i Site Pool Construction & iSFSI Financial Costs of I Restoration O&M Decomrnissioning O&M Assurance Loans  !

I o 0 I 0

l 0 1,102 0 1 492 3,144 0 1 45 7,974 0 I 86 9,596 107 8,286 10,279 24,644 1,710 l

5,059 7,709 8,612 3,660 238 399 1 3,083 0 3,739 153 1,309 1 1,719 0 3,736 55 1,875 335 0 3,729 15 1,962 g 304 0 3,718 1,569 1 304 0 3,703 t,114 I l 305 0 3,681 660 l 304 0 3,655 205 l

g 304 0 3,621 11 l 305 0 3,580 1 1 304 0 3,533 I 304 0 3,476 304 0 3,476 l

l 304 0 3,476 l

304 0 3,476 l l 304 0 3,476 l 304 0 3.476 g

l 304 0 3,476 l

! 10,933 7,853 3.098 l l 14,105 I 304 '

! 304 I l

l 304 l

l 1,825 I l l 51,138 17.988 62,925 69.602 461 9,105 I Revision 6

~~~~

_- - C9031 l033\ - l__ _

1 TROJANDECOAfAflSSIONING PLAN l

. . Table 5.3-1 Status of Decommissioning Trust Funds as of December 31,1998 I Trojan Co-Owner Fund Balance as of 12/31/98' l l

l Portland General Electric (PGE) $62,858,000 1 Eugene Water & Electric (EWEB)/ $14,207,000 i Bonneville Power Administration (BPA) l Pacific Power & Light (PP&L) $3,387,000 I I ,

1 Total $80,452,000 1 The 1998 end-of-year trust fund balances include an adjustment for tmst expenditures I incurred in November and December 1998 that were not paid out of the trust in 1998. I Revision 6 1

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