ML20217C511

Forwards Info Re Management & Funding of Irradiated Fuel Notification,Per 10CFR50.54(bb),in Response to NRC Telcon Rai.Revs to Original 990811 Submittal Are Indicated by Redline/Strikeout Method

ML20217C511
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/30/1999
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9910130277
Download: ML20217C511 (8)

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. ConsumersEnergy A CMS Energy Company Big Rock Point Restoration Project M R hneers 10269 L&31 Ncnh Site General Manager Charlewix, MI 49720 September 30,1999 Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 - 0001 l

DOCKET 50-155 - LICENSE DPR- 6, BIG ROCK POINT PLANT - MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION.

The purpose of this letter is to provide additional information requested per telecon to the Commission. This information will assist the Commission in its review and preliminary approval of the program by which Consumers Energy Company intends to manage and provide funding for the management of all irradiated fuel at the Big Rock Point reactor site until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository.

The original submittal dated August 11,1999, has been revised to reflect the information requested. The revisions are indicated by the redline / strikeout method.

Kenneth P Powers Site General Manager cc: Administrator, Region III NRC Reactor Decommissioning Inspector - Region III J NRR Project Manager - OWFN, USNRC f Attachment y

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9910130277 990930 PDR ADOCK 05000155 0 W PDR

ATTACHMENT DOCKET 50-155 - LICENSE DPR- 6, BIG ROCK POINT PLANT - MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION.

Submitted September 30,1999

MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION l PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMAT!ON.

This attachment is divided into two sections that present the Big Rock Point Management and Funding Plan for Irradiated Fuel at the reactor following permanent cessation of operation as I required by 10 CFR Part 50.54(bb). These sections outline the strategy for management and funding of the irradiated fuel until the Secretary of Energy takes possession of the irradiated fuel for ultimate disposal in a repository.

I I. IRRADIATED FUEL MANAGEMENT PLAN

Background

Big Rock Point was expected to operate until the expiration of its operating license on May 31, 2000. However, Consumers Energy Company notified the Nuclear Regulatory Commission j

- (NRC) by letters dated June 18, and June 26,1997, of its intentions to permanently cease  !

, operations of the Big Rock Point Nuclear Plant by August 30,1997. On August 29,1997, the i I

plant was shutdown as certified. On September 22,1997, a letter pursuant to 10 CFR Part l 50.82(a)(1)(ii) was forwarded to the Commission, certifying that the fuel had been removed

from the reactor vessel and placed in the Irradiated Fuel Pool for storage. In accordance with j 10 CFR 50.82(a)(2), upon docketing of the certifications for permanent cessation of operations  ;'

l and permanent removal of fuel from the reactor vessel, the 10 CFR Part 50 license no longer l authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

In 1973, all Big Rock Point irradiated fuel was shipped to the Nuclear Fuel Services Corporation West Valley, New York facility for reprocessing. The Irradiated Fuel Pool was emptied of fuel to allow for lining of the concrete with stainless steel plate. The purpose for the liner was 1) to provide a leak-tight membrane for containment of the pool water and 2) to mitigate the potential for degradation of the Irradiated Fuel Pool concrete structure due to exposure to pool water. The original unlined Irradiated Fuel Pool was put in service in 1962.

The Irradiated Fuel Pool walls were coated with an epoxy paint.

The stainless steel liner and leak detection system were installed and placed in service during 1974. There have been no detected leaks through the Irradiated Fuel Pool stainless liner. A decommissioning worker checks the leak chase system for water periodically. Water was observed on several occasions, but through laboratory analysis, was found not to have originated from the Irradiated Fuel Pool.

During 1985, the NRC approved a license amendment increasing the Irradiated Fuel Pool capacity to 441 irradiated fuel assemblies, and this is the current number of irradiated fuel assemblies currently in residence in the irradiated fuel pool.

Based on Department of Energy shipment allocations approved under the Department's

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MANAGEMENT AND FUNDING OF 1RRADIATED FUEL NOTIFICATION PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION.

disposal contract with Consumers Energy Company, Big Rock Point irradiated fuel was

' scheduled to be delivered for shipment offsite between 1999 and 2007. Since a repository is not available to receive irradiated fuel, the irradiated fuel is to be temporarily stored onsite

- until it can be shipped to a licensed repository.

Options for Irradiated Fuel Disposition The preferred irradiated fuel disposition option for Consumers Energy Company would have been to have the Secretary of Energy take the irradiated fuel as scheduled. This option would have allowed the irradiated fuel to be removed from onsite storage and preclude irradiated fuel storage from posing a barrier to the decommissioning of Big Rock Point Nuclear Plant.

However, since the Secretary of Energy is unable to accept the fuel as scheduled, onsite storage will be required. The most desirable onsite storage option, since it allows maximum dismantlement flexibility, is the use of a dry transportable canister system.

Irradiated Fuel Management Strategy During Safe Storage l l

l As previously stated,' the preferred onsite storage alternative for irradiated fuel is in a dry l transportable canister system such as the Wesflex

• Storage System, which will be used at the l Big Rock' Point site. NRC approval of this system is expected prior to scheduled j

commencement of fuel load in 2002. The irradiated fuel will be then be transferred to seven i approved casks and stored in the Independent Spent Fuel Storage Installation. Until that time, l irradiated fuel will be stored in the Irradiated Fuel Pool. ]

L Irradiated Fuel Pool Operations

! l The Irradiated Fuel Pool will remain operational for as long as irradiated fuel is stored in the !

. pool, approximately 5 % years after cessation of plant power operations. After fuel and high level waste have been removed from the Irradiated Fuel Pool, the pool will no longer be needed or maintained. Operation of the pool will require that the water be purified, cooled, and replenished with make-up water. In addition, the Reactor Building will continue to be heated.

l Purification and cooling of the water in the Irradiated Fuel Pool will be accomplished by the recently installed Irradiated Fuel Cooling System. Normal Irradiated Fuel Pool water make-up is supplied from the treated radwaste or demineralized water system. A secondary backup supply of water is available from the fire protection synem hose station.

Irradiated Fuel Pool chemistry, temperature, and level will be monitored on a routine basis.

Water level'and cooling shall be maintained during storage of irradiated fuel. The water functions as a heat sink for the irradiated fuel decay heat and provides radiation shielding of

MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION.

the irradiated fuel. The water quality helps minimize age-related degradation of the components in the Irradiated Fuel Pool and, therefore, helps to ensure the continued integrity of the Irradiated Fuel Pool stainless steel liner and irradiated fuel racks. These actions are responsive to NRC concerns expressed in NRC Bulletin 94-01 [ Reference A].

The irradiated fuel storage racks and Irradiated Fuel Pool concrete structure and stainless liner have been evaluated for structural integrity during the planned storage period. The evaluations support continued operation throughout that storage period [ References B and C]. i There are two types of irradiated fuel storage racks in the Irradiated Fuel Pool, aluminum and stainless steel. The potential for galvanic corrosion at the interface between the aluminum racks and the stainless liner is mitigated by a bimetallic pad. The bottom of the pad, which )

I lies directly upon the stainless steel liner is composed of stainless steel. The top of the pad is composed of an aluminum plate and the aluminum irradiated fuel rack is placed on top. This

. configuration is used under all the aluminum racks in the Irradiated Fuel Pool.

An annual inspection of surveillance coupons to monitor potential degradation at the stainless steel and aluminum plate interface has been conducted since the installation of the plates in the Irradiated Fuel Pool. Minor pitting has been observed in the surveillance coupons. No degradation of the actual aluminum racks has been observed. Consumers Energy Company has determined that if the pitting found in the coupons were present in the actual racks, the structural integrity of the racks would not be affected during the service period of the racks.

The aluminum and stainless steel racks will be acceptable for use during the proposed storage

- period [ Reference B].

The stainless steel liner will have been in service for 26 years at the end of Big Rock Point's operating license. After approximately 25 years (1974-1999) of service, no leakage through the liner has been detected. The Irradiated Fuel Pool stainless steel liner and the irradiated fuel storage racks will be acceptable for use throughout the wet fuel dormancy phase of the DECON period. This is the conclusion of a study performed to specifically address the aging of the Irradiated Fuel Pool liner and existing irradiated fuel racks [ Reference B].

The Irradiated Fuel Pool concrete structure was built during the two years of plant construction (1960 to 1962). The epoxy coated Irradiated Fuel Pool was in service from 1962 to 1973, or approximately 11 years. Portions of the concrete were exposed to Irradiated Fuel Pool water during this in-service period due to the blistering and spalling of the epoxy paint.

The Irradiated Fuel Pool concrete has essentially been dry since 1974, when the liner was installed.

. The concrete of the Isradiated Fuel Pool is not subjected to a freeze-thaw environment. The Reactor Building will remain heated to the extent needed to eliminate freezing of the Irradiated

MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION.

Fuel Pool during the period of use for irradiated fuel storage. The concrete is essentially in a dry service environment.

.An evaluation of the concrete structure has determined that the concrete is not exceeding the acceptable stress limits while it is bearing the weight of the filled Irradiated Fuel Pool and the weight of the irradiated fuel stored within it. This analysis has determined the concrete condition, existing flaws or damage, and structural integrity. The study shows that the Irradiated Fuel Pool concrete structure is able to perform its intended service for irradiated fuel storage during the wet dormancy phase of the DECON period [ Reference C].

In conclusion, the Irradiated Fuel Pool concrete structure, stainless steel liner and irradiated fuel storage racks will perform their intended service, that of irradiated fuel storage, for the intended period of use.

II. DECOMMISSIONING COST ESTIMATE AND FUNDING A site-specific decommissioning cost estimate for Big Rock Point was prepared by TLG Services, Inc. (TLG) (Reference D]. The results of the study, summarized below in Table II.1, represent a cooperative effort between TLG and Consumers Energy Company to capture the expenditures associated with the termination of Big Rock Point's 10 CFR Part 50 license as well as for the management of irradiated fuel and ultimate restoration of the site to a greenfield condition.

Big Rock Point Decommissioning Cost Estimate Summary ($ 1997) (January 1,1999 $) i Table II.1 Staffing 25,208,000 130,985,885 D-Plan, Preparation, Modifications 14,491,000 14,491,000 Decontamination 5,320,000 5,540,033 Removal 39,938,000 41,589,817

. Packaging, Shipping, LLW Recycling 13,592,000 14,154,159 Burial 17,063,000 17,768,718 License Termination Survey & Final Report G,709,000 6,986,481 ISFSI Start-up Expenses 11,572,000 12,050,612 ISFSI D&D Miscellaneous Costs 1,791,000 1,865,075 Insurance, Taxes, Fees, Energy 16,743,000 17,440,689 Contingency 41.429.000 43.142.484 TOTAL 293,851,000 306,014,953-

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1 MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION l

PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION.

The TLG study provides this estimate for decommissioning Big Rock Point under current requirements, based upon present day costs and available technology. The methodology used to develop the estimate follows the basic approach originally presented in the AIF/NESP-036 study report, " Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates" [ Reference E] and the U.S. Department of Energy " Decommissioning Ilandbook" [ Reference F]. These references utilize a unit cost factor methodology for estimating decommissioning activity costs to simplify the estimating calculations. Detailed inventory of the Big Rock Point systems, structures, and components was compiled as input to i the decommissioning cost estimate.

TLG supplemented the published guidelines with experience gained from other l decommissioning programs and with decommissioning related field activities. This experience was relied upon in determining the assumptions and bases which produce estimates associated with costs, personnel requirements, radioactive waste volumes and service requirements.

The alternative evaluated in the decommissioning study is DECt N. This alternative was selected due to the availability of a low level waste disposal site L J the advantages associated with utilizing site experienced personnel.

This study includes costs for the storage ofirradiated fuel generated over the operating life of 1 Big Rock Point in the Irradiated Fuel Pool for up to approximately five and one half years post l shutdown, capital costs for the dry transportable canister system and ISFSI construction, the transfer of irradiated fuel into the dry transportable canister system and ISFSI, and the operational costs of the ISFSI for approximately nine years until ultimate transfer of fuel to the Secretary of Energy, assumed for purposes of this study to be 2012. Costs for eventual decontamination and dismantlement of the ISFSI are also included in the study.

Funding for the management of all irradiated fuel at Big Rock Point is provided through the use of a decommissioning external sinking fund, funded by rates that are established by cost of service rulemaking regulation. The status and financial assurance of the decommissioning fund is documented in a submittal forwarded to the NRC by letter dated March 29,1999 entitled " Certification of Financial Assurance for Decommissioning Pursuant to 10 CFR 50.75(f)(1)".

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MANAGEMENT AND FUNDING OF IRRADIATED FUEL NOTIFICATION PURSUANT TO 10 CFR 50.54(bb); RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION. i l

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REFERENCES l l

A. NRC Bulletin 94-01, " Potential Fuel Pool Draindown Caused by Inadequate l Maintenance at Dresden 1", Nuclear Regulatory Commission, April 14, 1994.

B. W.R. Pavlichko, " Fuel Pool Liner / Fuel Rack Corrosion Evaluation", December 1994.

C. T.R. Thiruvengadam, " Integrity of the Concrete Spent Fuel Pool for Long Term Storage of Spent Fuel during Safe Storage Period", December 1994. .

I D. "1997 Decommissioning Cost Study for the Big Rock Point Nuclear Plant", TLG Services, Inc., April 1998 <

E. - AIF/NESP-036, " Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates", TLG Services, Inc., May 1986 F. U.S. Department of Energy " Decommissioning Handbook", William J. Manion and Thomas S. LaGuardia, November 1980 u