ML22091A273
| ML22091A273 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/2022 |
| From: | Van Noordennen G TMI-2 Solutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| TMI2-RA-COR-2022-0004 | |
| Download: ML22091A273 (9) | |
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TMl-2 SOLUTIONS March 31, 2022 TM I2-RA-CO R-2022-0004 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 10 CFR 50.75 10 CFR 50.82
SUBJECT:
Decommissioning Fund Status Report - Three Mile Island, Unit 2 Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73 Docket No. 50-320 Pursuant to 10 CFR 50.75 and 10 CFR 50.82, TMl-2 Solutions is hereby submitting the following three reports to the Nuclear Regulatory Commission (NRC) for Three Mile Island Nuclear Station, Unit 2 for the year ending December 31, 2021. Attachment 1 provides a decommissioning funding status report based on the NRC formula described in 10 CFR 50.75(c). Attachment 2 provides a decommissioning funding status report based upon a site-specific decommissioning cost estimate (DCE). Attachment 3 contains a financial assurance status report as required by 10 CFR 50.82(a)(8)(v).
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact me at 860-462-9707.
Sincerely, Digitally signed by Gerard van Noordennen Ge ra rd Va n NO Ord en n en DN: rn=Gerard van Noordennen, o=EnergySolutions, ou=Regulatory Affairs, ema1l=gpvannoordennen@energysolut1ons.com, c=US Date: 2022.03.31 06:09:56 -04'00' Gerard van Noordennen Senior Vice President Regulatory Affairs TMl-2 Solutions, LLC Attachments:
- 1. Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report-NRC Formula
- 2. Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report -
Site-Specific Decommissioning Cost Estimate
- 3. Three Mile Island Nuclear Station, Unit 2 Financial Assurance Status Report cc: w/Attachments NRC Region I Administrator NRC Project Manager NRC Lead Inspector
TMl-2 Service List w/Attachments Ken Robuck President and CEO Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger President and Chief Nuclear Officer Reactor D&D Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Mike Lackey Senior Vice President D&D Operations Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Gerard van Noordennen Senior Vice President Regulatory Affairs Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Frank Helin Project Director TMl-2 Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Daniel F. Stenger Hogan Lovells US LLP 555 13th St NW Washington, D.C. 20004 Director, Bureau of Radiation Protection, Department of Environmental Protection, Commonwealth of Pennsylvania Rachael Carson State Office BLDG.
13TH Floor P.O. Box 8469 Harrisburg, PA 17105-8469 Chief, Division of Nuclear Safety, Bureau of Radiation Protection, Department of Environmental Protection,
Commonwealth of Pennsylvania Rachael Carson State Office BLDG.
13TH Floor P.O. BOX 8469 Harrisburg, PA 17105-8469 Chairman, Board of County Commissioners, Dauphin County 112 Market Street 7th Floor Harrisburg, PA 17101 Chairman, Board of Supervisors of Londonderry Township 783 S. Geyers Church Rd.
Middletown PA 17057 TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC Formula Page 1 of 2 This report reflects the TMl-2 Solutions ownership interests in the Three Mile Island Nuclear Station, Unit 2 as of December 31, 2021.
- 1. The minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(b) and (c) (see Schedule 1 ):
$524,500,027
- 2. The amount accumulated in external trust funds as of December 31, 2021:
- 3. There are no longer any funds being collected from the ratepayers.
After Tax
$902,074,154
- 4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:
Consolidated Ownership Interest in Unit Estimated Net Investment Rate Year of Site Restoration Completion 100%
2.00%
2054 Three Mile Island Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in mid-2022.
- 5. There are no contracts upon which the owners/licensees are relying upon pursuant to 10 CFR 50.75(e)(1 )(v).
- 6. There are no modifications to the licensee's current method of providing financial assurance.
- 7. The above-mentioned owner of Three Mile Island Nuclear Station, Unit 2, TMl-2 Solutions became the TMl-2 licensee on December 18, 2020, following the closing specified in the October 15, 2019 Asset Purchase and Sale Agreement. The trust agreement has not been amended since the closing.
- 8. Mathematical rounding was performed during the development of the supporting calculations.
ATTACHMENT 1 TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC Formula Page 2 of 2 Schedule 1 TM 1-2 Solutions, LLC.
Calculation of Minimum Financial Assurance Amount December 31, 2021 THREE MILE ISLAND NUCLEAR STATION, UNIT 2 Pennsylvania Regions Labor (L) = Northeast Energy (E) = National Waste Burial (B) = Generic For PWR Unit PWR Escalation Factor =
L=
E=
B=
Adjustment Factor 3.203 2.932 12.793 Ratio 0.65 0.13 0.22 Escalation Factor 1
2.082 0.381 2.814 5.277 Base Amount for PWR between 1200 MWt and 3400 MWt = ($75 + 0.0088P) million (P = power level in megawatts thermal= 2772)
($75 + 0.0088(2772)) million=
Escalated Amount for unit 1 = 99,393,600
=
$99,393,600
$524.500.027 Note 1: Mathematical rounding was performed during the development of the supporting calculations TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report -
Site-Specific Decommissioning Cost Estimate Page 1 of 4
- 1. Decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c) are based upon a site-specific Decommissioning Cost Estimate (DCE) as presented in PSDAR Revision 4, dated March 17, 2021. The DCE has been escalated 2.00% to present the decommissioning funds required in 2022 dollars.
NRC License Termination
$1,033,204,628
- 2. The amount accumulated in external trust funds as of December 31, 2021 :
- 3. There are no longer any funds being collected from the ratepayers.
After Tax
$902,074,154
- 4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:
Consolidated Ownership Interest in Unit Estimated Rate of Escalation in Decommissioning Costs Estimated After-Tax Rate of Return Year of Site Restoration Completion 100%
0.00%
2.00%
2054 Three Mile Island Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in mid-2022.
All costs are based on a site-specific decommissioning cost study, Decommissioning Cost Estimate (DCE) as presented in PSDAR Revision 4, dated March 17, 2021. The DCE has been escalated 2.00% to present the decommissioning funds required in 2022 dollars.
- 5. There are no contracts upon which the owners/licensees are relying pursuant to 10 CFR 50.75(e)(1 )(v).
- 6. There are no modifications to the licensee's current method of providing financial assurance.
- 7. The above-mentioned owner of the Three Mile Island Nuclear Station Unit 2; TMl-2 Solutions became the TMl-2 licensee on December 18, 2020, following the closing specified in the October 15, 2019 Asset Purchase and Sale Agreement. The trust agreement has not been amended since the closing.
- 8. Site Specific Cost Analysis Assumptions 10 CFR 50.75(e)(1)(i), states, in part, that:
TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report -
Site-Specific Decommissioning Cost Estimate Page 2 of 4 A licensee that has prepaid funds based on a site-specific estimate under 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate.
In accordance with Regulatory Guide 1.159, Revision 2, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, a facility specific analysis may be used to demonstrate the adequacy of decommissioning funds, provided that:
NRG-required cost estimate for decommissioning costs, as defined in 10 CFR 50.2, is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2).
The site-specific radiological decommissioning cost estimate is $1,033,204,628 which is greater than the 10 CFR 50.75(c) cost estimate of $524,500,027. The analysis assumes a 2 percent yearly rate of return. The cash flows were contained in a decommissioning cost estimate that was prepared for Three Mile Island Nuclear Station, Unit 2. The cash flow analysis assumes the yearly expenses are incurred at mid-year.
Schedule 1 provides the site-specific analysis. The analysis values are in 2022 dollars.
The analysis is based on TMl-2 transitioning from Post-Defueling Monitored Storage status to decommissioning in mid-2022 and includes expenditures for license termination costs only.
- 9. Mathematical rounding was performed during the development of the supporting calculations.
- 10.
References:
A. Letter from USN RC to Halnon, G.H. (GPU Nuclear, Inc.), "Three Mile Island Nuclear Station, Unit No. 2 - Order Approving Transfer of License from the FirstEnergy Companies to TMl-2 Solutions, LLC and Draft Conforming Administrative License Amendment (EPID L-2019-LLA-0257)," dated December 2, 2020.
B. Notification of "Amended Post-Shutdown Decommissioning Activities Report" (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7),
Revision 4, dated March 17, 2021.
TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report-Site-Specific Decommissioning Cost Estimate Page 3 of 4 Schedule 1 TMl-2 SOLUTIONS, LLC.
Funding Analysis December 31, 2021 THREE MILE ISLAND NUCLEAR STATION, UNIT 2 Estimated Net Investment Rate Estimated Escalation Rate Estimated After-Tax Rate of Return Qualified Trust Balance on December 31, 2021 Non-Qualified Trust Balance on December 31, 2021 Total Beginning Year Balance Deposits 2022 902,074,154 $
2023 868,580,787 $
2024 815,299,938 $
2025 759,402,991 $
2026 700,976,730 $
2027 640,203,881 $
2028 594,434,615 $
2029 556,749,437 $
2030 539,152,828 $
2031 519,695,586 $
2032 485,276,494 $
2033 438,552,143 $
2034 383,491,036 $
2035 285,096,541 $
2036 182,225,114 $
2037 103,666,362 $
2020 - 2037 902,074,154 2038-2055 95,357,313 Total Earnings 17,531,237 $
16,672,086 $
15,591,118 $
14,459,205 13,279,016 $
12,224,144 $
11,397,862 $
10,850,517 $
10,483,648 $
9,950,219 $
9,146,818 $
8,139,041 $
6,619,679 $
4,626,947 $
2,830,609 $
1,970,531 $
165,772,678 $
29,734,478 $
195,507,156 $
After-Tax 2.00%
0.00%
2.00%
892,074,154 After-Tax 10,000,000 902,074,154 Ending Withdrawals Balance 51,024,604 $
868,580,787 69,952,936 $
815,299,938 71,488,066 $
759,402,991 72,885,466 $
700,976,730 74,051,865 $
640,203,881 57,993,410 $
594,434,615 49,083,040 $
556,749,437 28,447,126 $
539,152,828 29,940,890 $
519,695,586 44,369,311 485,276,494 55,871,169 $
438,552,143 63,200,148 $
383,491,036 105,014,174 $
285,096,541 107,498,374 $
182,225,114 81,389,360 $
103,666,362 10,279,581 $
95,357,313 I"
972,489,519 $
95,357,313 60,715,109 64,376,683 1,033,204,628 TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report -
Site-Specific Decommissioning Cost Estimate Vear 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2038 - 2055 Notes:
Page 4 of 4 TMl-2 SOLUTIONS, LLC.
Funding Analysis December 31, 2021 THREE MILE ISLAND NUCLEAR STATION, UNIT 2 Beginning Balance Deposits Earnings Withdrawals 95,357,313 1,884,436 $
2,271,001 94,970,749 1,875,590 $
2,382,520 94,463,819 1,864,312 $
2,496,408 93,831,723 1,850,507 2,612,717 93,069,514 $
1,834,075 2,731,497 92,172,093 1,814,914 $
2,852,801 91,134,206 1,792,917 2,976,683 89,950,440 1,767,977 3,103,197 88,615,220 1,739,980 $
3,232,400 87,122,801 1,708,813 3,364,348 85,467,265 1,674,434 $
3,491,174 83,650,524 $
1,636,805 3,620,536 81,666,793 1,589,517 $
4,381,848 78,874,462 $
1,513,459 $
6,403,033 73,984,889 $
1,417,365 6,233,316 69,168,937 $
1,317,088 $
6,629,035 63,856,990 $
1,223,571 5,356,831 59,723,731 $
1,228,717 $
(3,424,235) 29,734,478 60,715,109 (1)
Withdrawals reflect the project remaining in the PDMS condition until mid-2022 (2)
Withdrawals reflect the project in Decommissioning starting mid-2022 to mid-2037 Ending Balance 94,970,749 94,463,819 93,831,723 93,069,514 92,172,093 91,134,206 89,950,440 88,615,220 87,122,801 85,467,265 83,650,524 81,666,793 78,874,462 73,984,889 69,168,937 63,856,990 59,723,731 64,376,683 (3)
Withdrawals reflect the project in Fuel Debris Storage Management starting mid-2037 through 2053 (4)
Withdrawals reflect the ISFSI decommissioning and License Termination by the end of 2054 (5)
Withdrawal amounts are net cost including allowed DOE reimbursements for Fuel Debris Management (6)
Withdrawal negative amount in 2055 represents final DOE reimbursement (7)
Withdrawals are estimated based upon a site-specific Decommissioning Cost Estimate (DCE) as presented in PSDAR Revision 4, dated March 17, 2021. The DCE has been escalated 2.00% to present the decommissioning funds required in 2022 dollars.
(8)
Earnings are based on a 2.00% rate of return on the average of Beginning Balance and Beginning Balance plus Deposits less Withdrawals.
TMl2-RA-COR-2022-0004 Three Mile Island Nuclear Station, Unit 2 Financial Assurance Status Report Page 1 of 1
- 1. Formal decommissioning has not started at Three Mile Island Nuclear Station, Unit 2. A disbursement of decommissioning trust funds occurred in December 2020 in the amount of $8,059,381 for planning and licensing cost incurred by TMl2 Solutions prior to project closing. Disbursements of decommissioning trust funds in calendar year 2021 were
$48,454,385. The cumulative disbursement of decommissioning trust funds is
$56,513,766 through December 31, 2021 Amount Spent on Decommissioning:
Cumulative (December 2020)
Calendar Year 2021 Cumulative (December 2020 - December 31, 2021)
$ 8.1M
$48.4M
$56.5M
- 2. Decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c) are based upon a site-specific Decommissioning Cost Estimate (DCE) as presented in PSDAR Revision 4, dated March 17, 2021. The DCE has been escalated 2.00% to present the decommissioning funds required in 2022 dollars.
NRC License Termination
$1,033,204,628
- 3. The amount accumulated in external trust funds as of December 31, 2021:
- 4. There are no longer any funds being collected from the ratepayers.
After Tax
$902,074,154
- 5. There are no modifications to the licensee's current method of providing financial assurance.
- 6. There were no amendments to the trust agreements for the above-mentioned owner of Three Mile Island Nuclear Station, Unit 2.
- 7. Mathematical rounding was performed during the development of the supporting calculations.
- 8.
References:
A. Letter from USN RC to Halnon, G.H. (GPU Nuclear, Inc.), "Three Mile Island Nuclear Station, Unit No. 2 - Order Approving Transfer of License from the FirstEnergy Companies to TMl-2 Solutions, LLC and Draft Conforming Administrative License Amendment (EPID L-2019-LLA-0257)," dated December 2, 2020.
B. Notification of "Amended Post-Shutdown Decommissioning Activities Report" (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7),
Revision 4, dated March 17, 2021.