ML21062A253

Federal Register Notice for Environmental Assessments and Findings of No Significant Impact of Independent Spent Fuel Storage Facilities Decommissioning Funding Plans Related to Donald C. Cook Nuclear Plant; Closeout Letter

ML21062A253
Person / Time
Site:	Cook, 07200072
Issue date:	04/07/2021
From:	John Mckirgan Storage and Transportation Licensing Branch
To:	Lies Q Indiana Michigan Power Co
CTMarkley - NMSS/DFM/STL - 301.415.6293
Shared Package
ML21062A251	List: ML21062A253 ML21062A254 ML21062A255
References
CAC 001028, EPID L-2017-FPR-0020
Download: ML21062A253 (4)

Text

April 7, 2021 Mr. Q. Shane Lies Site Vice President Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, MI 49106

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION ANALYSIS OF INDIANA MICHIGAN POWER COMPANYS INITIAL AND UPDATED DECOMMISSIONING FUNDING PLANS FOR THE DONALD C. COOK INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS

Dear Mr. Lies:

By letter dated December 17, 2012, Indiana Michigan Power Company (IMP), submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, an Initial decommissioning funding plan (Initial DFP) for the Independent Spent Fuel Storage Installation (ISFSI) at Donald C. Cook Nuclear Plant Units 1 and 2 (DCNP), (Agencywide Documents Access and Management System Accession No. ML123630254).

By letter dated December 14, 2015, IMP, submitted, for NRC staff review and approval, an updated DFP for the ISFSI at Donald C. Cook Nuclear Plant, Units 1 and 2 (ADAMS Accession No. ML15351A007). The NRC issued Requests for Additional Information (RAIs) dated February 28, 2018, regarding IMPs DFP Update for the Cook ISFSI (ADAMS Accession No. ML18060A022). IMP provided RAI responses to the NRC on April 11, 2018, supplementing the 2015 DFP update. IMPs update supplement can be found in ADAMS at Accession No. ML18103A035.

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 IMPs initial and updated DFPs, including the initial and updated decommissioning cost estimates (DCEs) and the method of assuring funds for decommissioning.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 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 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

Q. Lies 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 IMP on how reasonable assurance will be provided that funds will be available to decommission the ISFSI, including the amount of the DCE and the method of assuring funds for decommissioning.

In its 2012 Initial DFP, IMP estimated that the total cost to decommission the ISFSI at DCNP for unrestricted use is $4,611,447, in 2012 dollars.

Based on its analysis of IMPs Initial DFP, the staff finds that the submitted DCE: (1) is based on reasonable costs of a third-party contractor; (2) includes an adequate contingency factor; (3) reflect 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 2012 DCE adequately estimates the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCE is acceptable.

In the Initial DFP, IMP relied on an external trust fund as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 50.75(e)(1)(ii)(A) which is allowed under 10 CFR 72.30(e)(5). This is allowed because the IMP ISFSI belongs to a licensee with a power reactor license under part 50. The NRC staff finds that the aggregate dollar amount of the licensees financial instrument provides adequate financial assurance to cover its cost estimates, and therefore, that these financial instruments are 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 IMP has provided reasonable assurance that funds will be available to decommission the ISFSI at DCNP.

Pursuant to 10 CFR 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the DFP required to be submitted by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. The updated DFP must update the information submitted with the original or prior approved plan. In addition, the 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.

In its 2015 updated DFP, IMP estimated that the total cost to decommission the Donald C. Cook ISFSI at for unrestricted use ranges from $21.7 million to $44.3 million, in 2015 dollars. IMP provided five decommissioning scenarios, including four DECON scenarios and one SAFSTOR scenario. The updated range of the decommissioning cost estimates (DCE) considered the requirements of 10 CFR 72.30(c)(1)-(4) and in its April 11, 2018 RAI response, the licensee provided a narrative on each requirement. In sum, 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 IMPs submittals, the staff finds that the updated range of the DCE: is based on reasonable costs of a third-party contractor; includes an adequate contingency factor; and is based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2015 updated DCE

Q. Lies adequately estimates the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCE is reasonable In the updated DFP submittals, MP relied on an external trust fund as financial assurance for its ISFSI decommissioning, a method authorized by 10 CFR 50.75(e)(1)(ii)(A), which is allowed under 10 CFR 72.30(e)(5). This is allowed because the Donald C. Cook ISFSI belongs to a licensee with a power reactor license under part 50. The NRC staff reviewed the licensees 2015 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments provides adequate financial assurance to cover its DCE range. Therefore, the NRC staff finds these financial instruments are acceptable.

The NRC staff reviewed the DFP Update submitted by IMP, including the updated DCE range and the method of assuring funds for decommissioning, in accordance with 10 CFR 72.30(c) and NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance. Based on its review, the NRC staff finds that the DFP Update contains the information required by 10 CFR 72.30(c) and IMP has provided reasonable assurance that funds will be available to decommission the Donald C. Cook ISFSI.

In addition to the NRC staffs review of IMPs initial and updated DFPs, 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 ISFSIs at the Donald C. Cook Nuclear Plant. The environmental assessments and findings of no significant impact for these ISFSIs are available in https://www.regulations.gov under the Docket ID: NRC-2021-0064. The NRC staff determined there were no environmental impacts from the NRC staffs review and approval of IMPs initial and updated DFPs.

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: 2021.04.07 14:13:59

-04'00' John McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No(s).: 72-72 License No.: SFGL-52 CAC No.: 001028 EPID No(s): L-2017-FPR-0020

ML21062A251

• By email OFFICE NMSS/DFM NMSS/DFM OGC/HLW NMSS/STLB PJehle* NLO NAME CMarkley SFigueroa* JMcKirgan*

w/OGC edits DATE 2/25/2021 3/3/2021 3/25/2021 4/7/2021