RA-21-0036, Duke Energy Carolinas, LLC - Decommissioning Funding Plan for Independent Spent Fuel Storage Installations (Isfsis)

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Duke Energy Carolinas, LLC - Decommissioning Funding Plan for Independent Spent Fuel Storage Installations (Isfsis)
ML21089A271
Person / Time
Site: Oconee, Catawba, McGuire, 07200006, 07200040, 07200003, 07200060
Issue date: 03/30/2021
From: Nolan M
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
RA-21-0036
Download: ML21089A271 (38)
v • d • e


Text

M. CHRISTOPHER NOLAN Vice President Nuclear Regulatory Affairs, Policy &

Emergency Preparedness 526 South Church Street, EC-07C Charlotte, NC 28202 980-382-7426 Chris.Nolan@duke-energy.com 10 CFR 72.30(b) 10 CFR 72.4 Serial: RA-21-0036 March 30, 2021 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-6 CATAWBA NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-45 MCGUIRE NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-38 OCONEE NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-04 OCONEE NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-40 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-3 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-60

SUBJECT:

DECOMMISSIONING FUNDING PLAN FOR INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS (ISFSIs)

REFERENCE:

1.

Duke Energy letter RA-21-0037, Biennial Decommissioning Financial Assurance Reports, dated March 30, 2021.

Ladies and Gentlemen:

Pursuant to 10 CFR 72.30(b), Duke Energy Progress, LLC and Duke Energy Carolinas, LLC, collectively referred to henceforth as Duke Energy, submit the required decommissioning funding plans covering the ISFSIs for the Brunswick Steam Electric Plant, Catawba Nuclear

U.S. Nuclear Regulatory Commission March 30, 2021 Page 2 Station, McGuire Nuclear Station, Oconee Nuclear Station, and the H.B. Robinson Steam Electric Plant, Unit 2. 10 CFR 72.30(b) requires that "each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan.... " In accordance with 10 CFR 72.13(b) and 10 CFR 72.13(c), the requirement in 10 CFR 72.30(b) is applicable to both specific and general licensed ISFSls. The required plans are attached.

As a convenience to the NRC, the attached decommissioning funding plan for the Catawba Nuclear Station ISFSI addresses North Carolina Electric Membership Corporation's 30.754 percent ownership, North Carolina Municipal Power Agency No. 1 's 37.5 percent ownership and Piedmont Municipal Power Agency's 12.5 percent ownership.

Because these 10 CFR 72.30(b) reports rely on information contained in the 10CFR 50.75(f)(1) decommissioning financial assurance reports (Reference 1 ), Duke Energy is submitting the reports under each regulation concurrently. Aligning the reporting cycle for decommissioning the ISFSls under 10 CFR 72.30(b) with the reporting cycle for plant radiological decommissioning under 1 O CFR 50. 75(f)(1) reduces the ongoing administrative burden of submitting these reports on separate schedules.

There are no regulatory commitments associated with this letter. If you have additional questions, please contact Art Zaremba, Director - Fleet Licensing at (980) 373-2062.

Sincerel

t

M. Christopher Nolan Vice President, Nuclear Regulatory Affairs, Policy & Emergency Preparedness Attachments:

1.

Brunswick Steam Electric Plant ISFSI Decommissioning Funding Plan 2.

Catawba Nuclear Station ISFSI Decommissioning Funding Plan 3.

McGuire Nuclear Station ISFSI Decommissioning Funding Plan 4.

Oconee Nuclear Station ISFSI Decommissioning Funding Plan 5.

H.B. Robinson Steam Electric Plant, Unit 2 ISFSI Decommissioning Funding Plan

U.S. Nuclear Regulatory Commission March 30, 2021 Page 3 xc (with enclosure):

Ms. L. Dudes, USNRC Regional Administrator, Region II Mr. G. Smith, USNRC Senior Resident Inspector - Brunswick Mr. A. Hon, NRR Project Manager - Brunswick Mr. J. Austin, USNRC Senior Resident Inspector - Catawba Ms. K. Cotton, NRR Project Manager - Catawba Mr. A Hutto, USNRC Senior Resident Inspector - McGuire Mr.

J. Klos, NRR Project Manager - McGuire, Robinson Mr. J. Nadel, USNRC Senior Resident Inspector - Oconee Mr.

S. Williams, NRR Project Manager - Oconee Mr. M. Fannon, USNRC Senior Resident Inspector - Robinson

Brunswick Steam Electric Plant ISFSI Decommissioning Funding Plan RA-21-0036 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Brunswick Steam Electric Plant, Docket No. 72-6 In accordance with 72.30(c), this decommissioning funding plan is being resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. This decommissioning funding plan updates the previous plan submitted on April 1, 2019 and specifically considers the effect of the following events on decommissioning costs:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Facility modifications.

Changes in authorized possession limits.

Actual remediation costs that exceed the previous cost estimate.

The following statements specifically address the above events defined in 10 CFR 72.30(c).

Since the submittal of the Decommissioning Funding Plan for the ISFSIs dated April 1, 2019:

1. No spills of radioactive materials producing additional residual activity in on-site subsurface material have occurred for Brunswick Steam Electric Plant.
2. No facility modifications have had an effect on ISFSI decommissioning costs.
3. There were no changes in authorized possession limits for any of the sites.
4. No active decommissioning has occurred, thus there have not been any actual remediation costs that exceed the previous cost estimate.

The requirements of a decommissioning funding plan in 10 CFR 72.30(b) are provided below.

1.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the Brunswick ISFSI.

2.

A detailed cost estimate for decommissioning, in an amount reflecting:

  • The cost of an independent contractor to perform all decommissioning activities;
  • An adequate contingency factor; and
  • The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of § 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.

RA-21-0036 The design and capacity of the Brunswick ISFSI is based upon the NUHOMS-61BTH spent fuel storage system. The system consists of a stainless steel Dry Shielded Canister (DSC), with a nominal capacity of 61 fuel assemblies, and a concrete Horizontal Storage Module (HSM) which houses the DSC during storage.

Assuming Brunswick operates until the expiration of the last of the current operating licenses in 2036, approximately 13,537 spent fuel assemblies are projected to be generated over the life of the plant, 4,397 of which have been shipped to DEPs Shearon Harris Nuclear Power Plant.1 Brunswick is also storing 304 spent fuel assemblies that have been shipped from DEPs H. B.

Robinson Steam Electric Plant Unit 2. Based on a 2056 DOE start date for Brunswick, the current ISFSI is assumed to be expanded to accommodate the 158 HSMs remaining after cessation of operations. The cost estimate reflects the cost to decommission the assumed expanded ISFSI. Brunswick spent fuel is projected to be fully removed from the site in 2072.

The 158 HSMs include 150 for spent fuel and 8 for GTCC storage.

Details of the NUHOMS spent fuel storage system, including physical dimensions, can be found in the proprietary version of the Final Safety Analysis Report for the Transnuclear NUHOMS, Docket Number 72-1004.

The methodology used to develop this detailed cost estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates."2 The methodology includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal and removal of components. Undistributed costs are typically time-dependent costs such as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology also uses a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In this detailed cost estimate, contingency fulfills this role.

Specifically, contingency is added to all costs at a constant 25% rate, consistent with the contingency evaluation criteria referenced by the NRC in NUREG-17573.

1 Ownership of the 4,397 spent fuel assemblies have been transferred to the Shearon Harris Nuclear Power Plant and are included in its decommissioning spent fuel inventory and strategy.

2 Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. This document is referenced in NRCs NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

RA-21-0036 The detailed cost estimate assumes a spent fuel management strategy, which determines the estimated number of casks of canisters that may be installed at the Brunswick ISFSI and the estimated date for ISFSI decommissioning. The current spent fuel management strategy is based in general upon: (1) an industry and site-specific start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), (2) DOE's generator allocation/receipt schedules, which are based upon the oldest fuel receiving the highest priority, and (3) a maximum rate of transfer of 3,000 metric tons of uranium/year.

Assumptions regarding the removal of spent fuel by the DOE will continue to be assessed and revised, as necessary, with updates to be reflected in future ISFSI decommissioning plans that are submitted to the NRC pursuant to 10 CFR 72.30(c).

In addition, the detailed cost estimate is based on or includes the following:

  • the plant operating until the end of its current license;
  • the expected ISFSI configuration after all spent fuel and Greater-than-Class-C (GTCC) material has been removed from the site;
  • the ISFSI pads not being contaminated, with only verification surveys to be performed;
  • the ISFSI being promptly decommissioned (similar to the power reactor DECON alternative) after all spent fuel and GTCC has been removed from the ISFSI, irrespective of the decommissioning alternative identified for the nuclear power plant;
  • the costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use;
  • no remediation of contaminated (radiological) soil being required in order to terminate the site operating license;
  • no expected interior or exterior radioactive surface contamination of the HSMs; and
  • an allowance, equal to the number of HSMs required for final core offload, of HSMs (including heat shield, canister support structure, and miscellaneous steel components within the HSMs) assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel or GTCC. Controlled disposal costs are included for this allowance of concrete and steel.

The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, forms the basis of this cost estimate. Disposition of released material and structures is assumed to be outside the scope of this cost estimate.

RA-21-0036 A detailed breakdown of the cost to decommission the Brunswick ISFSI is provided in the table below. These costs were developed in conjunction with the 2019 Decommissioning Cost Analysis for the Brunswick Nuclear Station prepared by TLG Service, Inc. Costs were escalated from the 2019 TLG Services study using the 2020 Consumer Price Index inflation factor 2.3%.

Activity costs for ISFSI decommissioning are divided into 3 phases. The first phase covers initial planning during which the empty casks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination are developed.

The next phase includes the cost of removal, packaging, transportation and disposal of the activated components, including supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, the verification survey, and the associated equipment and laboratory support. The cost estimate also includes costs for the NRC and NRC contractor reviews, Duke's oversight staff, site security (industrial), and other site operating costs. The activities are estimated to begin in 2072 following the removal of all spent fuel from the ISFSI, and are estimated to occur in 123 days.

The methodology employed by TLG Services, Inc., does not assume that all decommissioning activities will be performed by an independent contractor. Because it would be impractical to identify the activities in the cost estimate that are assumed to be performed by an independent contractor, Duke has, as a conservative measure, applied a 20% markup to all costs in the estimate in order to determine the cost of an independent contractor to perform all decommissioning activities. This markup accounts for profit margin (15%) and risk premium (5%) in amounts consistent with what is applied in Duke Energys Asset Retirement Obligation.

This markup can be seen in the table below and is deemed appropriate because it is conservatively applied to all activity costs even though certain costs already account for performance by an independent contractor or are not activity costs (e.g., property taxes, insurance).

3.

Identification of and justification for using the key assumptions contained in the DCE.

The assumptions and justification for those assumptions included in the Brunswick ISFSI decommissioning cost estimate are presented in the Section 2 above.

4. A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

Funds from Part 50 external sinking funds are to be used for Part 72 decommissioning.

Concurrently with this report and pursuant to 10 CFR 50.75(f)(1), Duke Energy has filed Biennial Decommissioning Financial Assurance Reports (the 2021 DFAs) (Reference 1) and reported in the 2021 DFAs for Brunswick Unit 1 that the amounts accumulated and the annual amounts remaining to be collected, together with future earnings on such amounts, includes funding for both estimated reactor and Brunswick ISFSI decommissioning costs. When the methodology described in LIC-205, Revision 6 is used to determine whether Duke Energys decommissioning RA-21-0036 funding assurance for Brunswick Unit 1 exceeds the minimum financial assurance, the amount of surplus in the Part 50 external sinking funds is more than sufficient to fund the estimated Brunswick ISFSI decommissioning cost.

5. The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

6. A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke hereby certifies that financial assurance for decommissioning the Brunswick ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described in Part 4 above.

RA-21-0036 Activity Description Removal Costs Packaging Costs Transport Costs Disposal Costs Other Costs Total Costs Waste Volume (cubic feet)

Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Planning (characterization, specs and procedures) 304.9 304.9 1,240 Decontamination (activated HSM disposition) 139.1 475.7 4,430.6 5,284.8 10,330.3 53,601 845 License Termination (radiological surveys) 1,928.4 1,928.4 17,068 Subtotal 139.1 475.7 4,430.6 5,284.8 2,233.2 12,563.5 53,601 17,913 1,240 Supporting Costs NRC and NRC Contractor Fees and Costs 448.1 448.1 1,153 Insurance 79.8 79.8 Property taxes 1.5 1.5 Plant energy budget 20.5 20.5 Non-Labor Overhead 4.1 4.1 Corporate A&G Cost 26.6 26.6 Security Staff Cost 315.1 315.1 5,082 Utility Staff Cost 277.2 277.2 3,855 Subtotal 1,172.9 1,172.9 10,090.0 Total (w/o contingency) 139.1 475.7 4,430.6 5,284.8 3,406.1 13,736.3 53,601 17,913 11,330 Total (w/25% contingency) 173.9 594.6 5,538.3 6,606.0 4,257.6 17,170.4 Total (w/20% 3rd party markup) 208.7 713.5 6,645.9 7,927.2 5,109.1 20,604.5 Brunswick Nuclear Plant ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

Catawba Nuclear Station ISFSI Decommissioning Funding Plan RA-21-0036 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Catawba Nuclear Station, Docket No. 72-45 In accordance with 72.30(c), this decommissioning funding plan is being resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. This decommissioning funding plan updates the previous plan submitted on April 1, 2019 and specifically considers the effect of the following events on decommissioning costs:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Facility modifications.

Changes in authorized possession limits.

Actual remediation costs that exceed the previous cost estimate.

The following statements specifically address the above events defined in 10 CFR 72.30(c).

Since the submittal of the Decommissioning Funding Plan for the ISFSIs dated April 1, 2019:

1. No spills of radioactive materials producing additional residual activity in on-site subsurface material have occurred for Catawba Nuclear Station.
2. No facility modifications have had an effect on ISFSI decommissioning costs.
3. There were no changes in authorized possession limits for any of the sites.
4. No active decommissioning has occurred, thus there have not been any actual remediation costs that exceed the previous cost estimate.

The requirements of a decommissioning funding plan in 10 CFR 72.30(b) are provided below.

1.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the Catawba ISFSI.

2.

A detailed cost estimate for decommissioning, in an amount reflecting:

  • The cost of an independent contractor to perform all decommissioning activities;
  • An adequate contingency factor; and
  • The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of § 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.

RA-21-0036 The design and capacity of the Catawba ISFSI is based upon the UMS-24 and MAGNASTOR-37 spent fuel storage systems. The systems consist of a stainless steel Transportable Storage Canister (TSC), with a nominal capacity of 24 and 37 fuel assemblies, respectively, and a steel-lined Vertical Concrete Cask (VCC) which houses the TSC during storage.

Assuming Catawba operates until the expiration of the last of the current operating licenses in 2043, approximately 6361 spent fuel assemblies are projected to be generated over the life of the plant. Based on a 2042 DOE start date for Catawba and 123 casks remaining after cessation of operations, all Catawba spent fuel is projected to be fully removed from the site in 2077.

The 123 casks include 109 for spent fuel and 14 for GTCC storage.

Details of the UMS-24 spent fuel storage system, including physical dimensions, can be found in the Final Safety Analysis Report for the NAC-UMS Universal Storage System, Docket Number 72-1015. The Docket Number for the MAGNASTOR-37 System is 72-1031.

The methodology used to develop this detailed cost estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates."1 The methodology includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal and removal of components. Undistributed costs are typically time-dependent costs such as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology also uses a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In this detailed cost estimate, contingency fulfills this role.

Specifically, contingency is added to all costs at a constant 25% rate, consistent with the contingency evaluation criteria referenced by the NRC in NUREG-17572.

The detailed cost estimate assumes a spent fuel management strategy, which determines the estimated number of casks of canisters that may be installed at the Catawba ISFSI and the estimated date for ISFSI decommissioning. The current spent fuel management strategy is based in general upon: (1) an industry and site-specific start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), (2) DOE's 1 Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. This document is referenced in NRCs NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors.

2 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

RA-21-0036 generator allocation/receipt schedules, which are based upon the oldest fuel receiving the highest priority, (3) a maximum rate of transfer of 3,000 metric tons of uranium/year, and (4) any fuel residing in the spent pool at the time of shutdown or license expiration remaining in the pool until transfer to the DOE. Assumptions regarding the removal of spent fuel by the DOE will continue to be assessed and revised, as necessary, with updates to be reflected in future ISFSI decommissioning plans that are submitted to the NRC pursuant to 10 CFR 72.30(c).

In addition, the detailed cost estimate is based on or includes the following:

  • the plant operating until the end of its current license;
  • the expected ISFSI configuration after all spent fuel and Greater-than-Class-C (GTCC) material has been removed from the site;
  • the ISFSI pads not being contaminated, with only verification surveys to be performed;
  • the ISFSI being promptly decommissioned (similar to the power reactor DECON alternative) after all spent fuel and GTCC has been removed from the ISFSI, irrespective of the decommissioning alternative identified for the nuclear power plant;
  • the costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use;
  • no remediation of contaminated (radiological) soil being required in order to terminate the site operating license;
  • no expected interior or exterior radioactive surface contamination of the VCCs;
  • an allowance, equal to the number of VCCs required for final core offload, of VCCs (including steel liner and concrete) assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel or GTCC. Controlled disposal costs are included for this allowance of concrete and steel.

The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, forms the basis of this cost estimate. Disposition of released material and structures is assumed to be outside the scope of this cost estimate.

A detailed breakdown of the cost to decommission the Catawba ISFSI is provided in the table below. These costs were developed in conjunction with the 2018 Decommissioning Cost Analysis for the Catawba Nuclear Station prepared by TLG services, Inc. Costs were escalated from the 2018 TLG Services study using the 2019 and 2020 Consumer Price Index inflation factors of 1.9% and 2.3%, respectively. Activity costs for ISFSI decommissioning are divided into RA-21-0036 3 phases. The first phase covers initial planning during which the empty casks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination are developed. The next phase includes the cost of removal, packaging, transportation and disposal of the activated components, including supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, the verification survey, and the associated equipment and laboratory support. The cost estimate also includes costs for the NRC and NRC contractor reviews, Duke's oversight staff, site security (industrial), and other site operating costs. The activities are estimated to begin in 2077 following the removal of all spent fuel from the ISFSI, and are estimated to occur in 123 days.

The methodology employed by TLG Services, Inc., does not assume that all decommissioning activities will be performed by an independent contractor. Because it would be impractical to identify the activities in the cost estimate that are assumed to be performed by an independent contractor, Duke has, as a conservative measure, applied a 20% markup to all costs in the estimate in order to determine the cost of an independent contractor to perform all decommissioning activities. This markup accounts for profit margin (15%) and risk premium (5%) in amounts consistent with what is applied in Duke Energys Asset Retirement Obligation.

This markup can be seen in Table 1 and is deemed appropriate because it is conservatively applied to all activity costs even though certain costs already account for performance by an independent contractor or are not activity costs (e.g., property taxes, insurance).

3.

Identification of and justification for using the key assumptions contained in the DCE.

The assumptions and justification for those assumptions included in the Catawba ISFSI decommissioning cost estimate are presented in the Section 2 above.

4. A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

Funds from Part 50 external sinking funds are to be used for Part 72 decommissioning.

Concurrently with this report and pursuant to 10 CFR 50.75(f)(1), Duke Energy has filed on behalf of itself and the co-owners of Catawba the Biennial Decommissioning Financial Assurance Reports (the 2021 DFAs) (Reference 1) and reported in the 2021 DFAs for Catawba Unit 2 that the amounts accumulated and the annual amounts remaining to be collected, together with future earnings on such amounts, includes funding for both estimated reactor and Catawba ISFSI decommissioning costs. When the methodology described in LIC-205, Revision 6 is used to determine whether Duke Energys decommissioning funding assurance for Catawba Unit 2 exceeds the minimum financial assurance, the amount of surplus in the Part 50 external sinking funds is more than sufficient to fund the estimated Catawba ISFSI decommissioning cost.

In addition, Duke Energy and the co-owners of Catawba are electric utilities and, as such, can rely solely on the external sinking fund in accordance with 10 CFR 72.30(e)(5). Cost estimates RA-21-0036 will be adjusted at least every three years and plans submitted to NRC as required by 10 CFR 72.30(b). Funding levels can be periodically adjusted through rate recovery.

5. The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

6. A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke and the co-owners of Catawba hereby certify that financial assurance for decommissioning the Catawba ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described in Part 4 above.

RA-21-0036 Activity Description Removal Costs Packaging Costs Transport Costs Disposal Costs Other Costs Total Costs Waste Volume (cubic feet)

Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Planning (characterization, specs and procedures) 333.6 333.6 1,120 Decontamination (activated VCC disposition) 106.3 204.3 363.8 3,519.3 4,193.7 48,454 1,253 License Termination (radiological surveys) 1,727.3 1,727.3 13,755 Subtotal 106.3 204.3 363.8 3,519.3 2,060.9 6,254.6 48,454 15,008 1,120 Supporting Costs NRC and NRC Contractor Fees and Costs 505.6 505.6 1,153 Barnwell Annual Access Fee 184.5 184.5 Insurance 81.3 81.3 Property taxes 22.9 22.9 Plant energy budget 24.0 24.0 Corporate A&G 27.1 27.1 Site O&M 3.1 3.1 Security Staff Cost 264.8 264.8 5,082 Oversight Staff Cost 274.2 274.2 3,855 Subtotal 184.5 1,203.0 1,387.5 10,090 Total (w/o contingency) 106.3 204.3 363.8 3,703.8 3,263.9 7,642.1 48,454 15,008 11,210 Total (w/25% contingency) 132.9 255.4 454.8 4,629.7 4,079.8 9,552.6 Total (w/20% 3rd party markup) 159.5 306.5 545.7 5,555.7 4,895.8 11,463.2 Catawba Nuclear Station ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

McGuire Nuclear Station ISFSI Decommissioning Funding Plan RA-21-0036 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation McGuire Nuclear Station, Docket No. 72-38 In accordance with 72.30(c), this decommissioning funding plan is being resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. This decommissioning funding plan updates the previous plan submitted on April 1, 2019 and specifically considers the effect of the following events on decommissioning costs:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Facility modifications.

Changes in authorized possession limits.

Actual remediation costs that exceed the previous cost estimate.

The following statements specifically address the above events defined in 10 CFR 72.30(c).

Since the submittal of the Decommissioning Funding Plan for the ISFSIs dated April 1, 2019:

1. No spills of radioactive materials producing additional residual activity in on-site subsurface material have occurred for McGuire Nuclear Station.
2. No facility modifications have had an effect on ISFSI decommissioning costs.
3. There were no changes in authorized possession limits for any of the sites.
4. No active decommissioning has occurred, thus there have not been any actual remediation costs that exceed the previous cost estimate.

The requirements of a decommissioning funding plan in 10 CFR 72.30(b) are provided below.

1.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the McGuire ISFSI.

2.

A detailed cost estimate for decommissioning, in an amount reflecting:

  • The cost of an independent contractor to perform all decommissioning activities;
  • An adequate contingency factor; and
  • The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of § 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.

RA-21-0036 The design and capacity of the McGuire ISFSI is based upon the UMS-24, MAGNASTOR-37 and TN-32 spent fuel storage systems. The UMS-24 and MAGNASTOR-37 systems consist of a stainless steel Transportable Storage Canister (TSC), with a nominal capacity of 24 and 37 fuel assemblies, respectively, and a steel-lined Vertical Concrete Cask (VCC) which houses the TSC during storage. The TN-32 system consists of a bolted lid steel canister design with a nominal capacity of 32 fuel assemblies.

Assuming McGuire operates until the expiration of the last of the current operating licenses in 2043, approximately 6499 spent fuel assemblies are projected to be generated over the life of the plant. McGuire is also storing 300 spent fuel assemblies that have been shipped from DECs Oconee Nuclear Station.1 Based on a 2042 DOE start date for McGuire and 135 casks remaining after cessation of operations, all McGuire spent fuel is projected to be fully removed from the site in 2078. The 135 casks include 121 for spent fuel and 14 for GTCC storage.

Details of the UMS-24 spent fuel storage system, including physical dimensions, can be found in the Final Safety Analysis Report for the NAC-UMS Universal Storage System, Docket Number 72-1015. The Docket Numbers for the MAGNASTOR-37 and TN-32 systems are 72-1031 and 72-1021, respectively.

The methodology used to develop this detailed cost estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates."2 The methodology includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal and removal of components. Undistributed costs are typically time-dependent costs such as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology also uses a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In this detailed cost estimate, contingency fulfills this role.

Specifically, contingency is added to all costs at a constant 25% rate, consistent with the contingency evaluation criteria referenced by the NRC in NUREG-17573.

1 McGuire has taken ownership of the 300 Oconee Nuclear Station spent fuel assemblies and has included them in the decommissioning spent fuel inventory and strategy which serve as an input to the costs provided in the below table.

2 Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. This document is referenced in NRCs NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

RA-21-0036 The detailed cost estimate assumes a spent fuel management strategy, which determines the estimated number of casks of canisters that may be installed at the McGuire ISFSI and the estimated date for ISFSI decommissioning. The current spent fuel management strategy is based in general upon: (1) an industry and site-specific start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), (2) DOE's generator allocation/receipt schedules, which are based upon the oldest fuel receiving the highest priority, (3) a maximum rate of transfer of 3,000 metric tons of uranium/year, and (4) any fuel residing in the spent pool at the time of shutdown or license expiration remaining in the pool until transfer to the DOE. Assumptions regarding the removal of spent fuel by the DOE will continue to be assessed and revised, as necessary, with updates to be reflected in future ISFSI decommissioning plans that are submitted to the NRC pursuant to 10 CFR 72.30(c).

In addition, the detailed cost estimate is based on or includes the following:

  • the plant operating until the end of its current license;
  • the expected ISFSI configuration after all spent fuel and Greater-than-Class-C (GTCC) material has been removed from the site;
  • the ISFSI pads not being contaminated, with only verification surveys to be performed;
  • the ISFSI being promptly decommissioned (similar to the power reactor DECON alternative) after all spent fuel and GTCC has been removed from the ISFSI, irrespective of the decommissioning alternative identified for the nuclear power plant;
  • the costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use;
  • no remediation of contaminated (radiological) soil being required in order to terminate the site operating license;
  • no expected interior or exterior radioactive surface contamination of the VCCs;
  • an allowance, equal to the number of VCCs required for final core offload, of VCCs (including steel liner and concrete) assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel or GTCC. Controlled disposal costs are included for this allowance of concrete and steel.

The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, forms the basis of this cost estimate. Disposition of released material and structures is assumed to be outside the scope of this cost estimate.

RA-21-0036 A detailed breakdown of the cost to decommission the McGuire ISFSI is provided in the table below. These costs were developed in conjunction with the 2018 Decommissioning Cost Analysis for the McGuire Nuclear Station prepared by TLG Services, Inc. Costs were escalated from the 2018 TLG Services study using the 2019 and 2020 Consumer Price Index inflation factors of 1.9% and 2.3%, respectively. Activity costs for ISFSI decommissioning are divided into 3 phases. The first phase covers initial planning during which the empty casks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination are developed. The next phase includes the cost of removal, packaging, transportation and disposal of the activated components, including supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, the verification survey, and the associated equipment and laboratory support. The cost estimate also includes costs for the NRC and NRC contractor reviews, Duke's oversight staff, site security (industrial), and other site operating costs. The activities are estimated to begin in 2078 following the removal of all spent fuel from the ISFSI, and are estimated to occur in 123 days.

The methodology employed by TLG Services, Inc., does not assume that all decommissioning activities will be performed by an independent contractor. Because it would be impractical to identify the activities in the cost estimate that are assumed to be performed by an independent contractor, Duke has, as a conservative measure, applied a 20% markup to all costs in the estimate in order to determine the cost of an independent contractor to perform all decommissioning activities. This markup accounts for profit margin (15%) and risk premium (5%) in amounts consistent with what is applied in Duke Energys Asset Retirement Obligation.

This markup can be seen in the table below and is deemed appropriate because it is conservatively applied to all activity costs even though certain costs already account for performance by an independent contractor or are not activity costs (e.g., property taxes, insurance).

3.

Identification of and justification for using the key assumptions contained in the DCE.

The assumptions and justification for those assumptions included in the McGuire ISFSI decommissioning cost estimate are presented in the Section 2 above.

4. A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

Funds from Part 50 external sinking funds are to be used for Part 72 decommissioning.

Concurrently with this report and pursuant to 10 CFR 50.75(f)(1), Duke Energy has filed Biennial Decommissioning Financial Assurance Reports (the 2021 DFAs) (Reference 1) and reported in the 2021 DFAs for McGuire Unit 2 that the amounts accumulated, together with future earnings on such amounts, includes funding for both estimated reactor and McGuire ISFSI decommissioning costs. When the methodology described in LIC-205, Revision 6 is used to determine whether Duke Energys decommissioning funding assurance for McGuire Unit 2 RA-21-0036 exceeds the minimum financial assurance, the amount of surplus in the Part 50 external sinking funds is more than sufficient to fund the estimated McGuire ISFSI decommissioning cost.

In addition, Duke Energy is an electric utility and, as such, can rely solely on the external sinking fund in accordance with 10 CFR 72.30(e)(5). Cost estimates will be adjusted at least every three years and plans submitted to NRC as required by 10 CFR 72.30(b). Funding levels can be periodically adjusted through rate recovery.

5. The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

6. A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke hereby certifies that financial assurance for decommissioning the McGuire ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described in Part 4 above.

RA-21-0036 Activity Description Removal Costs Packaging Costs Transport Costs Disposal Costs Other Costs Total Costs Waste Volume (cubic feet)

Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Planning (characterization, specs and procedures) 390.9 390.9 1,192 Decontamination (activated VCC disposition) 98.0 185.6 1,512.6 2,344.4 4,140.6 48,454 1,248 License Termination (radiological surveys) 1,812.8 1,812.8 14,277 Subtotal 98.0 185.6 1,512.6 2,344.4 2,203.7 6,344.3 48,454 15,525 1,192 Supporting Costs NRC and NRC Contractor Fees and Costs 511.8 511.8 1,153 Insurance 81.3 81.3 Property taxes 1.0 1.0 Plant energy budget 24.0 24.0 Corporate A&G 27.1 27.1 Site O&M 4.2 4.2 Security Staff Cost 263.7 263.7 5,082 Oversight Staff Cost 274.2 274.2 3,855 Subtotal 1,187.3 1,187.3 10,090 Total (w/o contingency) 98.0 185.6 1,512.6 2,344.4 3,391.0 7,531.6 48,454 15,525 11,282 Total (w/25% contingency) 122.5 231.9 1,890.7 2,930.6 4,238.8 9,414.5 Total (w/20% 3rd party markup) 147.0 278.3 2,268.9 3,516.7 5,086.6 11,297.4 McGuire Nuclear Station ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

Oconee Nuclear Station ISFSI Decommissioning Funding Plan RA-21-0036 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Oconee Nuclear Station, Docket No. 72-04/License SNM-2503 Oconee Nuclear Station, Docket No. 72-40 In accordance with 72.30(c), this decommissioning funding plan is being resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. This decommissioning funding plan updates the previous plan submitted on April 1, 2019 and specifically considers the effect of the following events on decommissioning costs:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Facility modifications.

Changes in authorized possession limits.

Actual remediation costs that exceed the previous cost estimate.

The following statements specifically address the above events defined in 10 CFR 72.30(c).

Since the submittal of the Decommissioning Funding Plan for the ISFSIs dated April 1, 2019:

1. No spills of radioactive materials producing additional residual activity in on-site subsurface material have occurred for Oconee Nuclear Station.
2. No facility modifications have had an effect on ISFSI decommissioning costs.
3. There were no changes in authorized possession limits for any of the sites.
4. No active decommissioning has occurred, thus there have not been any actual remediation costs that exceed the previous cost estimate.

The requirements of a decommissioning funding plan in 10 CFR 72.30(b) are provided below.

1.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the Oconee ISFSI.

2.

A detailed cost estimate for decommissioning, in an amount reflecting:

  • The cost of an independent contractor to perform all decommissioning activities;
  • An adequate contingency factor; and
  • The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of § 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.

RA-21-0036 The design and capacity of the Oconee ISFSI is based upon the NUHOMS-24 spent fuel storage system. The system consists of a stainless steel Dry Shielded Canister (DSC), with a nominal capacity of 24 fuel assemblies, and a concrete Horizontal Storage Module (HSM) which houses the DSC during storage.

Assuming Oconee operates until the expiration of the last of the current operating licenses in 2034, approximately 7523 spent fuel assemblies are projected to be generated over the life of the plant, 300 of which have been shipped to DECs McGuire Nuclear Station.1 Based on a 2039 DOE start date for Oconee and 234 HSMs remaining after cessation of operations, all Oconee spent fuel is projected to be fully removed from the site in 2063. The 234 HSMs include 219 for spent fuel and 15 for GTCC storage.

Details of the NUHOMS spent fuel storage system, including physical dimensions, can be found in the proprietary version of the Final Safety Analysis Report for the Transnuclear NUHOMS, Docket Number 72-1004.

The methodology used to develop this detailed cost estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates."2 The methodology includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal and removal of components. Undistributed costs are typically time-dependent costs such as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology also uses a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In this detailed cost estimate, contingency fulfills this role.

Specifically, contingency is added to all costs at a constant 25% rate, consistent with the contingency evaluation criteria referenced by the NRC in NUREG-17573.

The detailed cost estimate assumes a spent fuel management strategy, which determines the estimated number of casks of canisters that may be installed at the Oconee ISFSI and the 1 Ownership of the 300 spent fuel assemblies have been transferred to the McGuire Nuclear Station and are included in its decommissioning spent fuel inventory and strategy.

2 Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. This document is referenced in NRCs NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

RA-21-0036 estimated date for ISFSI decommissioning. The current spent fuel management strategy is based in general upon: (1) an industry and site-specific start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), (2) DOE's generator allocation/receipt schedules, which are based upon the oldest fuel receiving the highest priority, (3) a maximum rate of transfer of 3,000 metric tons of uranium/year, and (4) any fuel residing in the spent pool at the time of shutdown or license expiration being remaining in the pool until transfer to the DOE. Assumptions regarding the removal of spent fuel by the DOE will continue to be assessed and revised, as necessary, with updates to be reflected in future ISFSI decommissioning plans that are submitted to the NRC pursuant to 10 CFR 72.30(c).

In addition, the detailed cost estimate is based on or includes the following:

  • the plant operating until the end of its current license;
  • the expected ISFSI configuration after all spent fuel and Greater-than-Class-C (GTCC) material has been removed from the site;
  • the ISFSI pads not being contaminated, with only verification surveys to be performed;
  • the ISFSI being promptly decommissioned (similar to the power reactor DECON alternative) after all spent fuel and GTCC has been removed from the ISFSI, irrespective of the decommissioning alternative identified for the nuclear power plant;
  • the costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use;
  • no remediation of contaminated (radiological) soil being required in order to terminate the site operating license;
  • no expected interior or exterior radioactive surface contamination of the HSMs; and
  • an allowance, equal to the number of HSMs required for final core offload, of HSMs (including heat shield, canister support structure, and miscellaneous steel components within the HSMs) assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel or GTCC. Controlled disposal costs are included for this allowance of concrete and steel.

The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, forms the basis of this cost estimate. Disposition of released material and structures is assumed to be outside the scope of this cost estimate.

RA-21-0036 A detailed breakdown of the cost to decommission the Oconee ISFSI is provided in the table below. These costs were developed in conjunction with the 2018 Decommissioning Cost Analysis for the Oconee Nuclear Station prepared by TLG Services, Inc. Costs were escalated from the 2018 TLG Services study using the 2019 and 2020 Consumer Price Index inflation factors of 1.9% and 2.3%, respectively. Activity costs for ISFSI decommissioning are divided into 3 phases. The first phase covers initial planning during which the empty casks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination are developed. The next phase includes the cost of removal, packaging, transportation and disposal of the activated components, including supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, the verification survey, and the associated equipment and laboratory support. The cost estimate also includes costs for the NRC and NRC contractor reviews, Duke's oversight staff, site security (industrial), and other site operating costs. The activities are estimated to begin in 2063 following the removal of all spent fuel from the ISFSI, and are estimated to occur in 123 days.

The methodology employed by TLG Services, Inc., does not assume that all decommissioning activities will be performed by an independent contractor. Because it would be impractical to identify the activities in the cost estimate that are assumed to be performed by an independent contractor, Duke has, as a conservative measure, applied a 20% markup to all costs in the estimate in order to determine the cost of an independent contractor to perform all decommissioning activities. This markup accounts for profit margin (15%) and risk premium (5%) in amounts consistent with what is applied in Duke Energys Asset Retirement Obligation.

This markup can be seen in the table below and is deemed appropriate because it is conservatively applied to all activity costs even though certain costs already account for performance by an independent contractor or are not activity costs (e.g., property taxes, insurance).

3.

Identification of and justification for using the key assumptions contained in the DCE.

The assumptions and justification for those assumptions included in the Oconee ISFSI decommissioning cost estimate are presented in the Section 2 above.

4. A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

Funds from Part 50 external sinking funds are to be used for Part 72 decommissioning.

Concurrently with this report and pursuant to 10 CFR 50.75(f)(1), Duke Energy has filed Biennial Decommissioning Financial Assurance Reports (the 2021 DFAs) (Reference 1) and reported in the 2021 DFAs for Oconee Unit 3 that amounts accumulated, together with future earnings on such amounts, includes funding for both estimated reactor and Oconee ISFSI decommissioning costs. When the methodology described in LIC-205, Revision 6 is used to determine whether Duke Energys decommissioning funding assurance for Oconee Unit 3 exceeds the minimum RA-21-0036 financial assurance, the amount of surplus in the Part 50 external sinking funds is more than sufficient to fund the estimated Oconee ISFSI decommissioning cost.

In addition, Duke Energy is an electric utility and, as such, can rely solely on the external sinking fund in accordance with 10 CFR 72.30(e)(5). Cost estimates will be adjusted at least every three years and plans submitted to NRC as required by 10 CFR 72.30(b). Funding levels can be periodically adjusted through rate recovery.

5. The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

6. A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke hereby certifies that financial assurance for decommissioning the Oconee ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described in Part 4 above.

RA-21-0036 Activity Description Removal Costs Packaging Costs Transport Costs Disposal Costs Other Costs Total Costs Waste Volume (cubic feet)

Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Planning (characterization, specs and procedures) 455.5 455.5 1,408 Decontamination (activated HSM disposition) 143.9 495.2 3,495.3 5,215.3 9,349.6 54,395 872 License Termination (radiological surveys) 2,410.1 2,410.1 19,894 Subtotal 143.9 495.2 3,495.3 5,215.3 2,865.7 12,215.3 54,395 20,766 1,408 Supporting Costs NRC and NRC Contractor Fees and Costs 513.9 513.9 1,153 Barnwell Annual Access Fee 184.5 184.5 Insurance 51.1 51.1 Property taxes 2.1 2.1 Plant energy budget 19.8 19.8 Corporate A&G 27.1 27.1 Site O&M 2.1 2.1 Security Staff Cost 262.7 262.7 5,082 Oversight Staff Cost 274.2 274.2 3,855 Subtotal 184.5 1,152.9 1,337.4 10,090 Total (w/o contingency) 143.9 495.2 3,495.3 5,399.8 4,018.6 13,552.7 54,395 20,766 11,498 Total (w/25% contingency) 179.8 618.9 4,369.1 6,749.8 5,023.2 16,940.9 Total (w/20% 3rd party markup) 215.8 742.7 5,242.9 8,099.7 6,027.9 20,329.1 Oconee Nuclear Station ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

H.B. Robinson Steam Electric Plant, Unit 2 ISFSI Decommissioning Funding Plan RA-21-0036 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation H. B. Robinson Steam Electric Plant Unit 2, Docket No. 72-03/License SNM-2502 H. B. Robinson Steam Electric Plant Unit 2, Docket No. 72-60 In accordance with 72.30(c), this decommissioning funding plan is being resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. This decommissioning funding plan updates the previous plan submitted on April 1, 2019 and specifically considers the effect of the following events on decommissioning costs:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

Facility modifications.

Changes in authorized possession limits.

Actual remediation costs that exceed the previous cost estimate.

The following statements specifically address the above events defined in 10 CFR 72.30(c).

Since the submittal of the Decommissioning Funding Plan for the ISFSIs dated April 1, 2019:

1. No spills of radioactive materials producing additional residual activity in on-site subsurface material have occurred for H.B. Robinson Steam Electric Plant.
2. No facility modifications have had an effect on ISFSI decommissioning costs.
3. There were no changes in authorized possession limits for any of the sites.
4. No active decommissioning has occurred, thus there have not been any actual remediation costs that exceed the previous cost estimate.

The requirements of a decommissioning funding plan in 10 CFR 72.30(b) are provided below.

1.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the Robinson ISFSI.

2.

A detailed cost estimate for decommissioning, in an amount reflecting:

  • The cost of an independent contractor to perform all decommissioning activities;
  • An adequate contingency factor; and
  • The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of § 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.

RA-21-0036 The design and capacity of the Robinson ISFSI is based upon the NUHOMS-24P and NUHOMS-7P spent fuel storage systems. The systems consist of a stainless steel Dry Shielded Canister (DSC), and a concrete Horizontal Storage Module (HSM) which houses the DSC during storage.

The 7P ISFSI consists of site-specific license HSMs with NUHOMS-7P DSCs that house 7 spent fuel assemblies each. The 24P ISFSI consists of general license HSMs with NUHOMS-24P DSCs that house 24 spent fuel assemblies each.

Assuming Robinson operates until the expiration of the last of the current operating licenses in 2030, approximately 2295 spent fuel assemblies are projected to be generated over the life of the plant, 504 of which have been shipped to DEPs Shearon Harris Nuclear Power Plant and 304 of which have been shipped to DEPs Brunswick Steam Electric Plant.1 Based on a 2049 DOE start date for Robinson, 73 HSMs are projected to be on site after cessation of operations, all Robinson spent fuel is projected to be fully removed from the site in 2056. The 73 HSMs include 68 for spent fuel (60 in the 24P ISFSI and 8 in the 7P ISFSI) and 5 for GTCC storage.

Details of the NUHOMS spent fuel storage system, including physical dimensions, can be found in the proprietary version of the Final Safety Analysis Report for the Transnuclear NUHOMS, Docket Number 72-1004.

The methodology used to develop this detailed cost estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates."2 The methodology includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal and removal of components. Undistributed costs are typically time-dependent costs such as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology also uses a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In this detailed cost estimate, contingency fulfills this role.

Specifically, contingency is added to all costs at a constant 25% rate, consistent with the contingency evaluation criteria referenced by the NRC in NUREG-17573.

1 Ownership of the 504 and 304 spent fuel assemblies have been transferred to the Shearon Harris Nuclear Power Plant and Brunswick Steam Electric Plant, respectively, and are included in each respective decommissioning spent fuel inventory and strategy.

2 Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. This document is referenced in NRCs NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

RA-21-0036 The detailed cost estimate assumes a spent fuel management strategy, which determines the estimated number of casks of canisters that may be installed at the Robinson ISFSI and the estimated date for ISFSI decommissioning. The current spent fuel management strategy is based in general upon: (1) an industry and site-specific start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), (2) DOE's generator allocation/receipt schedules, which are based upon the oldest fuel receiving the highest priority, and (3) a maximum rate of transfer of 3,000 metric tons of uranium/year.

Assumptions regarding the removal of spent fuel by the DOE will continue to be assessed and revised, as necessary, with updates to be reflected in future ISFSI decommissioning plans that are submitted to the NRC pursuant to 10 CFR 72.30(c).

In addition, the detailed cost estimate is based on or includes the following:

the plant operating until the end of its current license; the expected ISFSI configuration after all spent fuel and Greater-than-Class-C (GTCC) material has been removed from the site; the ISFSI pads not being contaminated, with only verification surveys to be performed; the ISFSI being promptly decommissioned (similar to the power reactor DECON alternative) after all spent fuel and GTCC has been removed from the ISFSI, irrespective of the decommissioning alternative identified for the nuclear power plant; the costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use; no remediation of contaminated (radiological) soil being required in order to terminate the site operating license; no expected interior or exterior radioactive surface contamination of the HSMs; and an allowance, equal to the number of HSMs required for final core offload, of HSMs (including heat shield, canister support structure, and miscellaneous steel components within the HSMs) assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel or GTCC. Controlled disposal costs are included for this allowance of concrete and steel.

The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, forms the basis of this cost estimate. Disposition of released material and structures is assumed to be outside the scope of this cost estimate.

RA-21-0036 A detailed breakdown of the cost to decommission the Robinson ISFSI is provided in the table below. These costs were developed in conjunction with the 2019 Decommissioning Cost Analysis for the Robinson Nuclear Station prepared by TLG Service, Inc. Costs were escalated from the 2019 TLG Services study using the 2020 Consumer Price Index inflation factor 2.3%.

Activity costs for ISFSI decommissioning are divided into 3 phases. The first phase covers initial planning during which the empty casks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination are developed.

The next phase includes the cost of removal, packaging, transportation and disposal of the activated components, including supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, the verification survey, and the associated equipment and laboratory support. The cost estimate also includes costs for the NRC and NRC contractor reviews, Duke's oversight staff, site security (industrial), and other site operating costs. The activities are estimated to begin in 2058 following the removal of all spent fuel from the ISFSI, and are estimated to occur in 123 days.

The methodology employed by TLG Services, Inc., does not assume that all decommissioning activities will be performed by an independent contractor. Because it would be impractical to identify the activities in the cost estimate that are assumed to be performed by an independent contractor, Duke has, as a conservative measure, applied a 20% markup to all costs in the estimate in order to determine the cost of an independent contractor to perform all decommissioning activities. This markup accounts for profit margin (15%) and risk premium (5%) in amounts consistent with what is applied in Duke Energys Asset Retirement Obligation.

This markup can be seen in the table below and is deemed appropriate because it is conservatively applied to all activity costs even though certain costs already account for performance by an independent contractor or are not activity costs (e.g., property taxes, insurance).

3.

Identification of and justification for using the key assumptions contained in the DCE.

The assumptions and justification for those assumptions included in the Robinson ISFSI decommissioning cost estimate are presented in the Section 2 above.

4. A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

Funds from Part 50 external sinking funds are to be used for Part 72 decommissioning.

Concurrently with this report and pursuant to 10 CFR 50.75(f)(1), Duke Energy has filed Biennial Decommissioning Financial Assurance Reports (the 2021 DFAs) (Reference 1) and reported in the 2021 DFAs for Robinson Unit 2 that the amounts accumulated and the annual amounts remaining to be collected, together with future earnings on such amounts, includes funding for both estimated reactor and Robinson ISFSI decommissioning costs. When the methodology described in LIC-205, Revision 6 is used to determine whether Duke Energys decommissioning RA-21-0036 funding assurance for Robinson Unit 2 exceeds the minimum financial assurance, the amount of surplus in the Part 50 external sinking funds is more than sufficient to fund the estimated Robinson ISFSI decommissioning cost.

In addition, Duke Energy is an electric utility and, as such, can rely solely on the external sinking fund in accordance with 10 CFR 72.30(e)(5). Cost estimates will be adjusted at least every three years and plans submitted to NRC as required by 10 CFR 72.30(b). Funding levels can be periodically adjusted through rate recovery.

5. The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

6. A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke hereby certifies that financial assurance for decommissioning the Robinson ISFSI has been provided in the amount of the cost estimate for decommissioning using the methodology described in Part 4 above.

RA-21-0036

[1] Includes costs for both the 7P and 24P ISFSIs Activity Description Removal Costs Packaging Costs Transport Costs Disposal Costs Other Costs Total Costs Waste Volume (cubic feet)

Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Planning (characterization, specs and procedures) 230.2 230.2 1,072 Decontamination (activated HSM disposition) 51.2 200.5 1,486.4 1,944.7 3,682.8 19,175 291 License Termination (radiological surveys) 908.4 908.4 6,727 Subtotal 51.2 200.5 1,486.4 1,944.7 1,138.6 4,821.4 19,175 7,018 1,072 Supporting Costs NRC and NRC Contractor Fees and Costs 443.0 443.0 1,153 Insurance 92.1 92.1 Property taxes 18.4 18.4 Plant energy budget 17.4 17.4 Non-Labor Overhead 16.4 16.4 Corporate A&G Cost 18.4 18.4 Security Staff Cost 307.9 307.9 5,082 Utility Staff Cost 277.2 277.2 3,855 Subtotal 1,190.8 1,190.8 10,090 Total (w/o contingency) 51.2 200.5 1,486.4 1,944.7 2,329.4 6,012.2 19,175 7,018 11,162 Total (w/25% contingency) 63.9 250.6 1,858.0 2,430.9 2,911.7 7,515.2 Total (w/20% 3rd party markup) 76.7 300.8 2,229.6 2,917.1 3,494.1 9,018.3 Robinson Nuclear Plant ISFSI Decommissioning Cost Estimate[1]

(thousands of 2020 dollars)

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