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MONTHYEARML21060B4142021-04-12012 April 2021 U.S. Nuclear Regulatory Commission Analysis of Duke Energy Florida, Llc'S Initial Decommissioning Funding Plan for the Crystal River Independent Spent Fuel Storage Installation Project stage: Other 2021-04-12
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Category:Letter
MONTHYEARML23342A0942024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan ML23354A0632023-12-22022 December 2023 Cover Letter - Crystal River License Termination Plan Request for Additional Information ML23345A1882023-12-0606 December 2023 Fws to NRC Crystal River Species List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected by Your Proposed Project ML23320A2592023-11-17017 November 2023 STC-23 077 Notification of the Crystal River Unit 3 Generating Plant License Termination Plan Public Meeting and Federal Register Notice ML23313A1322023-11-15015 November 2023 Request for Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant ML23310A0712023-11-0707 November 2023 Audit Plan Cover Letter - Crystal River Unit 3 Nuclear Generating Plant LTP ML23187A1112023-07-25025 July 2023 Acceptance of Requested Licensing Action License Request to Add License Condition to Include License Termination Plan Requirements ML23107A2722023-06-13013 June 2023 Letter Transmitting NRC Survey Results for East Settling Pond ML23160A2962023-06-0909 June 2023 Response to Crystal River, Unit 3 Supplemental Information Needed for Acceptance on the Application for a License Amendment Regarding Approval of the License Termination Plan ML23107A2732023-06-0707 June 2023 Orise Independent Survey Report Dcn 5366-SR-01-0 IR 05000302/20220032023-05-25025 May 2023 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2022003 ML23103A1902023-04-19019 April 2023 Request for Supplemental Information Cover Letter ML23058A2532023-03-22022 March 2023 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River, Unit 3 - NRC Inspection Report No. 05000302/2022003 ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML22265A0192022-09-26026 September 2022 Nuclear Generating Plant - U.S. Nuclear Regulatory Commission'S Analysis of ADP CR3, Llc'S Decommissioning Funding Status Report (License No. DPR-72, Docket Nos. 50-302 and 72-1035) IR 05000302/20220022022-08-0909 August 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report 05000302/2022002 IR 05000302/20220012022-05-0303 May 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report 05000302/2022001 ML22116A1752022-04-27027 April 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3- Independent Spent Fuel Storage Installation Security Inspection Report 07201035/2022401 ML22105A3992022-04-18018 April 2022 Nuclear Generating Plant - Change in NRC Project Manager ML22011A1362022-01-31031 January 2022 Independent Spent Fuel Storage Installation Security Inspection Plan IR 05000302/20210042022-01-24024 January 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2021004 ML22024A2142022-01-24024 January 2022 Nuclear Generating Plant - NMFS NRC Letter - Crystal River Energy Complex Biological Opinion Status (License No. DPR-72, Docket Nos. 50-302 and 72-1035) ML21351A0052021-12-20020 December 2021 NRC Analysis of ADP CR3, LLC Decommissioning Funding Status Report for the Crystal River Unit 3 Nuclear Generating Plant (License No. DPR-72, Docket Nos. 50-302 and 72-1035) ML21322A2702021-11-24024 November 2021 Nuclear Generating Plant - Issuance of Amendment No. 260 Approving the Independent Spent Fuel Storage Installation Only Security Plan, Rev 3 IR 05000302/20210032021-11-0909 November 2021 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report Nos. 05000302/2021003 and 07201035/2021001 ML21288A4292021-10-18018 October 2021 Letter - Crystal River Unit 3 Nuclear Generating Plant - Correction to Safety Evaluation Related to the Issuance of Amendment No. 259 Approving the Independent Spent Fuel Storage Installation Only Emergency Plan ML21238A0952021-10-13013 October 2021 Issuance of Amendment No. 259 Approving the ISFSI-Only Emergency Plan, Revision Draft a IR 05000302/20210012021-08-12012 August 2021 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report Nos. 05000302/2021001 and 05000302/2021002 ML21182A1032021-07-0606 July 2021 Request for Additional Information (RAI) Related to the ISFSI-Only Emergency Plan ML21159A0422021-06-28028 June 2021 VY and CR Indirect License Transfer Package ML21060B4142021-04-12012 April 2021 U.S. Nuclear Regulatory Commission Analysis of Duke Energy Florida, Llc'S Initial Decommissioning Funding Plan for the Crystal River Independent Spent Fuel Storage Installation ML21028A5912021-03-0202 March 2021 Letter to Reid Forwarding Exemption from 10 CFR Part 20, Appendix G, Section Iii.E ML21055A7832021-02-25025 February 2021 Letter to Reid, Change in NRC Staff Project Management for Crystal River Unit 3 Nuclear Generating Plant ML21012A3142021-01-13013 January 2021 Independent Spent Fuel Storage Installation Security Inspection Plan IR 05000302/20200012020-11-19019 November 2020 NRC Inspection Report No. 05000302/2020001, Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3, Crystal River, Florida ML20269A2922020-10-0707 October 2020 NRC Form 311 QA Program Approval Revision 10 Related to Crystal River 3 ML20101G5822020-04-10010 April 2020 CR-3 License Transfer SE Corrected Cover Letter ML20069A0232020-04-0101 April 2020 Order Approving Transfer of Licensed Authority from Duke Energy Florida, LLC, to ADP CR3, LLC, and Draft Conforming Administrative License Amendment ML20050D0142020-02-19019 February 2020 NRC Independent Spent Fuel Storage Installation Inspection Report No. 07201035/2020001, Duke Energy Florida, LLC, Crystal River Unit 3, Crystal River, Florida ML20050F7702020-02-14014 February 2020 30-Day Notice of Payment from the City of Tallahassee Trust Fund Non-Qualified Nuclear Decommissioning Trust Fund for Crystal River Unit 3 ML20015A5672020-01-15015 January 2020 Independent Spent Fuel Storage Installation Security Inspection Plan ML20009D0432020-01-10010 January 2020 Letter to Hobbs, Crystal River Unit 3 Nuclear Generating Plant - Corrected Safety Evaluation for Approval of Partial Site Release for Facility Operating License No. DPR-72 ML19339G5092020-01-0202 January 2020 Letter to Hobbs, Crystal River Unit 3 Nuclear Generating Plant - Approval of Partial Site Release for Facility Operating License No. DPR-72 ML19343A8252019-12-0606 December 2019 Letter from Erika Bailey, Oak Ridge Institute for Science and Education, to John Hickman, NRC, Forwarding Independent Confirmatory Survey Summary and Results for the 3,854-Acre Area Partial Site Release at the Crystal River Energy Complex IR 05000302/20190022019-11-20020 November 2019 NRC Inspection Report No. 05000302/2019002 and Independent Spent Fuel Storage Installation Inspection Report No. 07201035/2019002, Duke Energy Florida, LLC, Crystal River Unit 3, Crystal River, Florida ML19317D0932019-10-25025 October 2019 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance - Engine Systems, Inc. Report No. 10 CFR21-0127, Rev. 0, Emd Fuel Injectors - Seized Plunger and Bushing ML19261A0702019-09-19019 September 2019 VEGP U3 Proficiency Watches Prior to Fuel Load ML19177A0802019-06-26026 June 2019 Nuclear Generating Plant (CR-3) - Notification of Revised Post-Shutdown Decommissioning Activities Report (Revised PSDAR) ML19170A1942019-06-14014 June 2019 Application for Order Consenting to Direct Transfer of Control of Licenses and Approving Conforming License Amendment ML19129A1402019-05-15015 May 2019 Letter to Hobbs, Correction to Amendment No. 257 Approving Independent Spent Fuel Storage Installation (ISFSI)-Only Emergency Plan, Revision 1 2024-01-09
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April 12, 2021 Terry Hobbs General Manager, Decommissioning 15760 W. Power Line Street, SAB2 Crystal River, FL 34428
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION ANALYSIS OF DUKE ENERGY FLORIDA, LLCS INITIAL DECOMMISSIONING FUNDING PLAN FOR THE CRYSTAL RIVER INDEPENDENT SPENT FUEL STORAGE INSTALLATION
Dear Mr. Hobbs:
By letter dated May 15, 2017, Duke Energy Florida, LLC (DEF) 1 submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, an initial decommissioning funding plan (DFP) for the independent spent fuel storage installation (ISFSI) at Crystal River Unit 3 Nuclear Generating Plant (CR-3) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17135A230).
In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 72.30(b), and using NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance, the NRC staff reviewed DEFs initial DFP, including the initial decommissioning cost estimate (DCE) and the method of assuring funds for decommissioning.
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 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 the information submitted by DEF on how reasonable assurance will be provided that funds will be available to decommission the ISFSI at CR-3, including the amount of the DCE and the method of assuring funds for decommissioning.
1 As ordered on April 1, 2020 (ADAMS Accession No. ML20069A024) and effected in the license transfer amendment on October 1, 2020 (ADAMS Accession No. ML20253A343), the NRC authorized the transfer of CR-3 ISFSI from DEF to ADP CR3, LLC (ADP CR3). DEF retained ownership of the Decommissioning Trust Fund.
T. Hobbs In its 2017 initial DFP, DEF estimated the total costs to decommission the CR-3 ISFSI to unrestricted use is $4,995,800 in 2017 dollars. Based on its financial analysis of DEFs submittals, the NRC staff finds that the DCE submitted for 2017: (1) is based on reasonable costs of a third-party contractor, (2) includes an adequate contingency factor, (3) reflects the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use, and (4) is based on reasonable and documented assumptions. Therefore, the NRC finds that the 2017 DCE adequately estimates the cost, to carry out required ISFSI decommissioning activities prior to license termination, and that the 2017 DCE is acceptable.
In the initial DFP, DEF relied on an external sinking fund in the form of excess funds from its reactor 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). DEF, a public utility, is authorized to rely solely on the external sinking fund in accordance with 10 CFR 72.30(e)(5).
This is allowed because the Crystal River ISFSI belongs to a licensee with a power reactor license under part 50. The NRC staff reviewed the DEFs 2017 Decommissioning Funding Report for CR-3, dated March 28, 2017 (ADAMS Accession No. ML17087A256), and finds that the aggregate dollar amount of the licensees financial instrument provides adequate financial assurance to cover its cost estimates, and therefore, that this financial instrument is acceptable.
Based on its financial analyses, the NRC staff finds that the initial DFP contains the information required by 10 CFR 72.30(b) and that DEF has provided reasonable assurance that funds will be available to decommission the ISFSIs at CR-3.
In addition to the NRC staffs review of DEFs initial DFP, the NRC staff completed an environmental review. The NRC staff published a summary of the results of the environmental review in the Federal Register in April 2021 for the ISFSI at CR-3. The environmental assessment and finding of no significant impact for the CR-3 ISFSI is available in https://www.regulations.gov under the Docket ID: NRC-2021-0073. The NRC staff determined there was no environmental impact from the NRC staffs review and approval of DEFs initial DFP.
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: 2021.04.12 13:50:01
-04'00' John McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1035 License No.: SFGL-64 EPID No: L-2017-FPR-0078 cc: Billy Reid, ADP CF3, LLC
ML21060B414
- concurrence via email OFFICE DFM DFM OGC/NLO DFM NAME YChen* WWheatley* PJehle* JMcKirgan*
DATE 3/2/2021 3/4/2021 3/30/2021 4/12/2021