ML20260H376

ISFSI DFP Financial Closeout Letter

ML20260H376
Person / Time
Site:	Clinton
Issue date:	10/30/2020
From:	John Mckirgan Storage and Transportation Licensing Branch
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
White B
Shared Package
ML20212L744	List: ML20212L768 ML20212L769 ML20260H376
References
CAC 001028, EPID L-2017-FPR-0015
Download: ML20260H376 (3)

Text

October 30, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF EXELON GENERATION COMPANY, LLCS INITIAL DECOMMISSIONING FUNDING PLAN FOR CLINTON POWER STATION, UNIT 1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mr. Hanson:

By letter dated September 6, 2016, as supplemented by letters dated March 30, 2017, and May 2, 2018, Exelon Generation Company, LLC (EGC) submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, an initial decommissioning fund plan (DFP) for the independent spent fuel storage installation (ISFSI) at Clinton Power Station, Unit 1 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML16251A032, ML17089A681, and ML18124A197). In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Sections 72.30(b) and (c), and using NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance, the NRC staff reviewed the initial DFP submitted by Exelon, including the initial and updated decommissioning cost estimates (DCEs) and the method of assuring funds for decommissioning.

Pursuant to 10 CFR 72.30(b), each holder of, or applicant for, a licensee under Part 72 must submit for NRC review and approval a DFP containing information on how reasonable assurance will be provided that funds will be available to decommission its ISFSI. The DFP must contain a detailed decommissioning cost estimate (DCE), in an amount reflecting: (1) the cost of an independent contractor to perform all decommissioning activities, (2) an adequate contingency factor, and (3) the cost of meeting the 10 CFR 20.1402 unrestricted use criteria (or the cost of meeting the 10 CFR 20.1403 restricted use criteria, provided the licensee can demonstrate its ability to meet these criteria). The licensees DFP must also identify and justify using the key assumptions contained in the DCE. Further, the DFP must describe the method of assuring funds for ISFSI decommissioning, including means for adjusting cost estimates and associated funding levels periodically over the life of the ISFSI. Additionally, the DFP must specify the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination, and contain a certification that financial assurance for ISFSI decommissioning has been provided in the amount of the DCE.

The NRC staff reviewed and analyzed EGCs initial DFP submission to establish whether EGC provided reasonable assurance that funds will be available to decommission the ISFSI at Clinton Power Station, Unit 1, including the amount of the DCE and the method of assuring funds for decommissioning.

Exelon Generation Company, LLC estimates that the total cost to decommission the ISFSI at Clinton Power Station will be $5.5m in 2016 dollars. The NRC staff finds the DCE is based on the reasonable costs of a third-party contractor; properly includes an adequate contingency factor; and is based on reasonable and documented assumptions. Therefore, the NRC staff finds that the DCE adequately estimates the cost, at this time, to carry out required ISFSI decommissioning activities, prior to license termination.

EGC currently relies on excess funds from the 10 CFR 50.75 decommissioning trust fund as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 50.75(e) and 10 CFR 72.30(e)(5). This is allowed because EGCs ISFSI is a general licensed ISFSI under 10 CFR Part 50. The NRC staff finds that the aggregate dollar amount of the licensees financial instruments provide adequate financial assurance to cover its cost estimates, and therefore, that these financial instruments are acceptable.

Therefore, the NRC staff finds based on its review that the initial DFP contains the information required by 10 CFR 72.30(b) and that EGC has provided reasonable assurance that funds will be available to decommission the ISFSI at Clinton Power Station, Unit 1. In addition to its financial review of EGCs DFP, the NRC staff completed an environmental review. The NRC will publish a summary of the results of the environmental review in the Federal Register in November 2020.1 The environmental assessment and finding of no significant impacts for the Clinton ISFSI and related documents will be available at https://www.regulations.gov under the Docket ID: NRC-2020-0132. The NRC staff determined that there were no environmental impacts from the NRC staffs review and approval of EGCs DFP (ADAMS Accession Nos.

ML20212L769).

If you have any questions regarding this matter, please contact me at (301) 415-5722 or John.McKirgan@nrc.gov.

Sincerely, John McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1046 License No.: SFGL-62 CAC No.: 001028 EPID No: L-2017-FPR-0015 1 This Federal Register notice also summarizes the results of the EAs and FONSIs for the ISFSIs at Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Dresden Nuclear Power Station, Units 1, 2, and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Quad Cities Nuclear Power Station, Units 1 and 2; Clinton Power Station, Unit 1; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; R. E. Ginna Nuclear Power Plant; Peach Bottom Atomic Power Station, Units 1, 2, and 3; Hope Creek Generating Station shared with Salem Generating Station, Units 1 and 2; and Zion Nuclear Power Station, Units 1 and 2; Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; River Bend Station, Unit 1; and Waterford Steam Electric Station, Unit 3.

John B. McKirgan Digitally signed by John B. McKirgan Date: 2020.10.30 10:09:04 -04'00'

ML20260H376 *via email OFFICE NMSS/DFM OGC (NLO)

NMSS/DFM NMSS/DFM NAME RGladney*

PJehle*

WWheatley*

JMcKirgan*

DATE 09/09/2020 09/30/2020 10/06/2020 10/ /2020