ML20307A533
| ML20307A533 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Nine Mile Point, Ginna, 07201036  |
| Issue date: | 11/20/2020 |
| From: | John Mckirgan Storage and Transportation Licensing Branch |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| White B | |
| References | |
| EPID L-2017-FPR-0013, EPID L-2017-FPR-0045, EPID L-2017-FPR-0058 | |
| Download: ML20307A533 (4) | |
Text
November 20, 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:
U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF EXELON GENERATION COMPANY, LLCS UPDATED DECOMMISSIONING FUNDING PLANS FOR THE CALVERT CLIFFS, NINE MILE POINT, AND R.E. GINNA INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS
Dear Mr. Hanson:
By letter dated March 31, 2015, Exelon1 submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, updated decommissioning funding plans (DFPs) for the ISFSIs at Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); Nine Mile Point Nuclear Station, Units 1 and 2 (Nine Mile Point); and R.E. Ginna Nuclear Power Plant (R.E. Ginna)
(ADAMS Accession No. ML15090A537). 2 The NRC issued a Request for Additional Information (RAI) by letter dated March 8, 2015 (ADAMS Accession No. ML18067A149). Exelon provided responses to the RAI on May 2, 2018 (ADAMS Accession No. 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 updated DFPs submitted by Exelon, including the updated decommissioning cost estimates (DCEs) and the method of assuring funds for decommissioning.
1 Exelon assumed the licenses for the operation of the facilities and associated ISFSIs from Calvert Cliffs Nuclear Power Plant, LLC; R.E. Ginna Nuclear Power Plant, LLC; and Nine Mile Point Nuclear Power Station, LLC, but the ownership of these facilities did not change (ADAMS Accession No. ML14063A125; ADAMS Accession No. ML14063A211; and ADAMS Accession No. ML14106A053, respectively).
2 The letter also provided financial information for Exelons ISFSIs at Braidwood Station, Units 1 and 2 (Braidwood); Byron Station, Units 1 and 2 (Byron); Clinton Power Station, Unit 1 (Clinton); Dresden Nuclear Power Station, Units 1, 2, and 3 (Dresden); LaSalle County Station, Units 1 and 2 (LaSalle);
Limerick Generating Station, Units 1 and 2 (Limerick); Oyster Creek Nuclear Generating Station (Oyster Creek); Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities); Peach Bottom Atomic Power Station, Units 1, 2 and 3 (Peach Bottom); and Salem Generating Station, Units 1 and 2 (Salem) (which shares an ISFSI with Hope Creek Generating Station, Unit 1 (Hope Creek)). The NRC staff provided its financial analyses of the DFPs for these ISFSIs in separate letters: Braidwood, Byron, Dresden, LaSalle, Limerick, Oyster Creek, Peach Bottom, Salem-Hope Creek, and Quad Cities (ADAMS Accession No. ML20279A501) and Clinton (ADAMS Accession No. ML20260H376).
By letter dated December 17, 2012, CENG submitted the initial DFPs for Calvert Cliffs, Nine Mile Point, and R.E. Ginna facilities. NRC provided its financial analyses of CENGs initial DFPs in a separate letter (ADAMS Accession No. ML20279A586).
B. Hanson Pursuant to 10 CFR 72.30(b), each holder of, or applicant for, a license 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 ISFSIs. 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.
Because CENG is co-licensee and, in 2012, operated the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna, CENG submitted initial DFPs for the ISFSIs in 2012, as required by 10 CFR 72.30(b). As discussed above, it did so by letter dated December 17, 2012. The NRC staff provided its financial analyses of the initial DFPs submitted by CENG for Calvert Cliffs; Nine Mile Point; and R.E. Ginna by separate letter (ADAMS Accession No. ML20279A586).
The financial analysis of CENGs initial DFP submission under 10 CFR 72.30(b) are not presented in this letter.
Pursuant to 10 CFR 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the initial DFP required by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination (updated DFP). The updated DFP must update the information submitted with the original or prior approved plan. In addition, the updated DFP must also specifically consider the effect of the following events on decommissioning costs, as required by 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.
Exelon estimated the total costs to decommission the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna for unrestricted use were $4.5 million (for each unit at Calvert Cliffs);
$6.1 million (for each unit at Nine Mile Point) 3; and $5.3 million, respectively, in 2014 dollars.
The updated DCEs considered the requirements of 10 CFR 72.30(c)(1)-(4) and in its May 2, 2018, RAI response, the licensee provided a discussion of each requirement. In summary, the licensee explained that no changes in any of the factors listed in 10 CFR 72.30(c)(1)-(4) have occurred to warrant revision of the previously submitted decommissioning costs. Based on its review of ECGs submittal, the NRC staff finds that the updated DCEs: (1) are based on reasonable costs of a third-party contractor; (2) include an adequate contingency factor; (3) reflect the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and (4) are based on reasonable and documented assumptions. Therefore, the NRC staff finds that the DCEs 3 Value is based on the LIPA ownership share of Nine Mile Point Nuclear Station, Unit 2 of 18%. Since LIPAs DCE and DFP are included in the Exelon letter, the NRC included its assessment of LIPAs portion of the decommissioning costs in this letter. Total DCE for R.E. Ginna is $6.1 million with individual DCEs for Exelon of $5 million and $1.1 million for LIPA.
B. Hanson adequately estimated the cost, in 2015, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCEs are reasonable.
In the updated DFP, Exelon relied on a prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1). The NRC staff reviewed the licensees updated DFPs and finds that the aggregate dollar amount of the licensees financial instruments provided adequate financial assurance to cover its updated DCEs.
Based on its review, the NRC staff finds that the 2015 updated DFPs contained the information required by 10 CFR 72.30(c) and Exelon has provided reasonable assurance that funds will be available to decommission the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna. 4 In addition to the NRC staffs analyses of Exelons updated DFPs, the NRC staff completed environmental reviews of the DFPs for the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E.
Ginna. NRC staff determined there were no environmental impacts from the NRC staffs review and approval of CENGs initial and Exelons updated DFPs. The NRC staff will publish a summary of the results of these environmental reviews in the Federal Register in November 2020. 5 The environmental assessments and findings of no significant impacts and related documents for these ISFSIs will be available in https://www.regulations.gov under the Docket ID: NRC-2020-0132. The environmental assessments for Calvert Cliffs, R,E, Ginna, and Nine Mile Point are located at ADAMS Accession Nos. ML2022L589, ML20213C613, and ML20234A435, respectively.
If you have any questions regarding this matter, please contact me at (301) 415-5722 or John.McKirgan@nrc.gov Sincerely, John B. Digitally signed by John B.
McKirgan McKirgan Date: 2020.11.20 13:20:07 -05'00' John McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket Nos.: 72-08, 72-1036, and 72-67 License Nos.: SNM-2505, SFGL-47, and SFGL-45 CAC No.: 001028 EPID Nos.: L-2017-FPR-0013, L-2017-FPR-0045, and L-2017-FPR-0058 4 The NRC staff provided its financial analyses of the DFPs for Exelons other licensed ISFSIs in separate letters (ADAMS Accession No. ML20279A501; ADAMS Accession No. ML20279A586; ADAMS Accession No. ML20260H376).
5 This Federal Register Notice also includes a summary of the results of the environmental reviews for the ISFSIs at Arkansas Nuclear One, Units 1 and 2; Braidwood Station; Byron Station; Clinton Power Station; Dresden; Grand Gulf Nuclear Station, Unit 1; Hope Creek Generating Station; LaSalle; Limerick; Oyster Creek; Quad Cities; Clinton; Peach Bottom; River Bend Station, Unit 1; Salem; Waterford Steam Electric Station, Unit 3; and Zion Nuclear Power Station, Units 1 and 2.
B. Hanson
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF CONSTELLATION ENERGY NUCLEAR GROUP, LLCS INITIAL DECOMMISSIONING FUNDING PLANS AND EXELON GENERATION COMPANY, LLCS DECOMMISSIONING FUND PLAN UPDATES FOR THE CALVERT CLIFFS, NINE MILE POINT, AND R.E. GINNA INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS DOCUMENT DATED: November 20, 2020 DISTRIBUTION:
PUBLIC DFM r/f RidsNmssRefsFab KLois, NMSS SHarwell, NMSS FMiller, NMSS MHenderson, NMSS BWhite, NMSS DHabib, NMSS JMaltese, OGC PJehle, OGC JMcKirgan, NMSS BVaidya, NRR BPurnell, NRR RGladney, NMSS RidsNMSSResource RidsNrrPMCalvertCliffs Resource RidsNrrPMNineMilePoint Resource RidsNrrPMREGinna Resource ADAMS Package Accession No.: ML20212L881 *via email OFFICE NMSS/DFM NMSS/DFM NMSS/REFS/FAB OGC (NLO) NMSS/DFM/STLB NAME RGladney* WWheatley* FMiller* PJehle* JMcKirgan*
DATE 10/01/2020 10/26/2020 11/4/2020 11/ 17/2020 11/20/2020 OFFICIAL RECORD COPY