ML22300A221
| ML22300A221 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/02/2023 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Wiebe J | |
| References | |
| EPID L-2022-LLL-0008 | |
| Download: ML22300A221 (11) | |
Text
November 2, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CLINTON POWER STATION, UNIT 1 - PRELIMINARY DECOMMISSIONING COST ESTIMATE AND FUEL MANAGEMENT PROGRAM (EPID L-2022-LLL-0008)
Dear Mr. Rhoades:
By letter dated April 18, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22108A263), Constellation Energy Generation, LLC (CEG),
submitted its Spent Fuel Management Plan for Clinton Power Station, Unit 1 (CPS). CEG also submitted a preliminary decommissioning cost estimate for CPS in Attachment 1 of the letter dated April 18, 2022. By letter dated March 31, 2023 (ML23082A312), CEG provided an updated decommissioning funding status report.
The U.S. Nuclear Regulatory Commission (NRC) staff finds that CEGs program for the long-term storage of spent fuel and the preliminary cost estimate for radiological decommissioning of CPS are adequate and provide sufficient details associated with the funding mechanisms. The NRC staff, therefore, concludes that the licensees spent fuel management program for CPS complies with Title 10 of the Code of Federal Regulations (10 CFR) 50.54(bb) and approves the program on a preliminary basis. In addition, the NRC staff finds that the preliminary cost estimate for CPS is reasonable and complies with the requirements of 10 CFR 50.75(f)(3).
If you have any questions, please contact me at 301-415-6606 or via e-mail at Joel.Wiebe@nrc.gov.
Sincerely,
/RA/
Joel S. Wiebe, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461
Enclosure:
Safety Evaluation cc: Listserv
Enclosure SAFETY EVALUATION RELATED TO THE PRELIMINARY DECOMMISSIONING COST ESTIMATE AND SPENT FUEL MANAGEMENT PROGRAM CONSTELLATION ENERGY GENERATION, LLC CLINTON POWER STATION, UNIT NO. 1 DOCKET NO. 50-461
1.0 INTRODUCTION
By letter dated April 18, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22108A263), Constellation Generation Company, LLC (CEG),
submitted its spent fuel management program (SFMP) for Clinton Power Station, Unit 1 (CPS) and a preliminary decommissioning cost estimate (preliminary cost estimate). By letter dated March 31, 2023 (ML23082A312), CEG provided an updated decommissioning funding status report.
Title 10 of the Code of Federal Regulations (10 CFR), section 50.54(bb), requires nuclear power plants that are within 5 years of expiration of their operating license to submit a spent fuel management (SFM) and funding program to the U.S. Nuclear Regulatory Commission (NRC) for review and preliminary approval. The program should discuss the means by which the licensee intends to manage and provide funding for the management of spent fuel until the fuel is transferred to the U.S. Department of Energy (DOE) for permanent disposal. In the same time period, the licensee is also required by 10 CFR 50.75(f)(3) to submit a preliminary decommissioning cost estimate, which includes an up-to-date assessment of the major factors that could affect the cost to decommission the reactor.
2.0 BACKGROUND
CPS is a 3,473 MWt (megawatt thermal), boiling-water reactor owned by CEG and is located in east central Illinois, approximately 6 miles east of the city of Clinton and approximately 60 miles northeast of Springfield. The CPS operating license was issued on April 17, 1987, and is set to expire on April 17, 2027.
CEG states that it has not made a final determination of the specific decommissioning approach for CPS. However, for the purposes of this submittal, the SAFSTOR option has been selected.
CEG further states that it reserves the right to choose an alternative option at the actual time of decommissioning, recognizing that the chosen option needs to meet NRC requirements for decommissioning funding.
3.0 REGULATORY REQUIREMENTS AND CRITERIA 3.1 Regulatory Requirement (10 CFR 50.54(bb))
The regulatory requirement in 10 CFR 50.54(bb) states, in part:
For nuclear power reactors licensed by the NRC, the licensee shall, within 2 years following permanent cessation of operation of the reactor or 5 years before expiration of the reactor operating license, whichever occurs first, submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of the operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository.
3.1.1 Criteria to Support the 10 CFR 50.54(bb) Review Similar to reviews of other SFMPs,1 the NRC staff reviewed the following information submitted in support of CEGs SFMP to evaluate and provide preliminary approval of the SFM and funding program:
Estimated cost to isolate the spent fuel pool and fuel handling systems. For the SAFSTOR option, the cost to manage and to provide funding for the management of irradiated fuel and fuel handling systems may be considered part of the preparation for transfer of the irradiated fuel to the DOE; Estimated cost to maintain and, if needed, expand an independent spent fuel storage installation (ISFSI) or a combination of wet/dry storage; Estimated annual cost for the operation of the selected option (wet or dry storage or a combination of the two) until the DOE takes possession of the fuel; Estimated cost for the preparation, packaging, and shipping of the fuel to the DOE; Estimated cost to decommission the spent fuel storage facility; Brief discussion of the selected storage method or methods, and the estimated time for these activities; Information identifying the source of funds for managing spent fuel.
3.2 Regulatory Requirement (10 CFR 50.75(f)(3) and (f)(5))
Regulation 10 CFR 50.75(f)(3) states:
1 Recent reviews include safety evaluations by the Office of Nuclear Reactor Regulation related to the SFMPs for the Duane Arnold Energy Center (ML22089A049); Oyster Creek Nuclear Generating Station (ML18226A330), and the Fort Calhoun Station, Unit 1 (ML18017B005).
Each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate [herein referred to as the preliminary cost estimate] which includes an up-to-date assessment of the major factors that could affect the cost to decommission.
Section 50.75(f)(5) requires, if necessary, a licensee to include plans with the preliminary cost estimate, to adjust decommissioning funding levels to demonstrate a reasonable level of assurance that funds will be available when needed to cover the cost of decommissioning.
The guidance in NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors, dated December 2004, section C1.4 (NUREG-1713) (ML043510113),
provides that the NRC staff should compare the preliminary cost estimate to the minimum decommissioning funding amount based on the formulas in 10 CFR 50.75(c), and perform an assessment of the major factors that could affect the preliminary cost estimate.
3.2.1 Criteria to Support the 10 CFR 50.75(f)(3) Review NUREG-1713, provides additional guidance on the information that is to be addressed in the preliminary cost estimate. The principal factors to be addressed are:
Decommissioning option/method anticipated; Potential for known or suspected contamination of the facility or site; Low-level radioactive waste (LLW) disposition plan; Preliminary schedule of decommissioning activities; and Any other factors that could significantly affect the cost to decommission.
The cost estimate should provide costs for each of the following:
Pre-decommissioning engineering and planning - decommissioning engineering and planning prior to completion of reactor defueling; Reactor deactivation - deactivation and radiological decontamination of plant systems to place the reactor into a safe, permanent shutdown condition; Safe storage - safe storage monitoring of the facility until dismantlement begins (if storage or monitoring of spent fuel is included in the cost estimate, it should be shown separately);
Dismantlement - radiological decontamination and dismantlement of systems and structures required for license termination (if demolition of uncontaminated structures and site restoration activities are included in the cost estimate, they should be shown separately); and LLW disposition - LLW packaging, transportation, vendor processing, and disposal.
4.0 TECHNICAL EVALUATION
4.1 Evaluation of the Spent Fuel Management Estimated Costs As required by 10 CFR 50.54(bb), CEG estimated the cost associated with the long-term management of spent fuel at $209.7 million (in 2021 dollars). The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to the ISFSI and to decommission the ISFSI. CEG assumes, for the purposes of this estimate, that the spent fuel will be packaged into multi-purpose containers (MPCs) over the first 3 to 5 years after shutdown. It is assumed that this period provides the necessary cooling for the spent fuel from the final core to meet the transport and/or storage requirements for decay heat. The estimates include the cost for the labor and equipment to transfer and load each MPC and relocate it to the ISFSI. Pending transfer of the fuel to the DOE, CEG will store fuel on an interim basis in the spent fuel pool and/or the ISFSI located at the CPS site. The ISFSI facility will be expanded to accommodate the inventory of spent fuel in the spent fuel pool following the final reactor defueling. After the required cooling time, the spent fuel will be loaded in fuel storage canisters and moved to the ISFSI. The ISFSI will continue to operate until the transfer of spent fuel to the DOE is complete.
When CPS terminates operations in 2027, CPS will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the CPS spent fuel pool and ISFSI. Based upon the assumptions in the decommissioning cost estimate regarding the DOEs receipt schedules, spent fuel is projected to remain at the CPS site for approximately 17 years after the termination of operation (spent fuel is projected to be removed from the CPS site by the end of 2044). Any delay in transfer of fuel to the DOE or decrease in the rate of acceptance will result in spent fuel remaining at the site longer.
With regard to the cost estimate for the SFMP and related activities at CPS, the NRC staff evaluated the $209.7 million (in 2021 dollars) estimated cost for reasonableness. In doing so, the NRC staff considered cost information from independent sources and compared data against information provided by other licensees. One such study, Blue Ribbon Commission on Americas Nuclear Future (Blue Ribbon Commission report), dated January 2012, provided to the DOE, cost, and cost considerations for the operation and maintenance of spent fuel storage at shutdown sites. Costs cited in that report range from $4.5 million to $8 million per year (in 2012 dollars) for SFM at shutdown sites. These costs adjusted for inflation (in 2021 dollars) are
$5.6 million and $10.1 million, respectively. Accounting for inflation and considering the SFMP operational period with the CPS site-specific costs, the NRC staff determined that the cost estimate provided by CEG, on the average (approximately $12.4 million per year), exceeds the higher range of costs cited in the study. In addition, the NRC staff determined that the CEG cost estimate was comparable with a range of other licensee SFMP cost estimates previously reviewed by the NRC staff. The NRC staff acknowledges that potential site-specific variances may exist among individual SFMPs. Based on the foregoing, the NRC staff finds CEGs $209.7 million cost estimate for SFM at CPS to be reasonable.
The NRC staff reviewed the provided information on spent fuel activities for CPS including the bases for the costs associated with spent fuel management and the detailed cost analysis for CPS and compared the information to the criteria to support the 10 CFR 50.54(bb) review. As a result of its evaluation of estimated costs, the NRC staff concludes that CEGs SFMP is comprehensive, contains sufficient detail regarding activities and identified costs for managing spent fuel, and includes a reasonable timeline for SFM activities. Based on its review, the staff finds that information required to evaluate and provide preliminary approval of the SFM funding program was provided and appears reasonable.
4.2 Evaluation of the Program to Manage and Provide Funding of all Irradiated Fuel As noted above, CEG estimated the cost associated with the long-term management of spent fuel at $209.7 million (in 2021 dollars). According to its April 18, 2022, letter, CEG intends to pay for the irradiated fuel expenditures for CPS using a combination of operating revenue and excess decommissioning trust funds (subject to receipt of NRC approval of an exemption).
Based on the NRC staffs independent cash flow analysis, approximately $76.7 M (in 2021 dollars) will remain in the decommissioning trust funds upon completion of the radiological decommissioning. CEG has also identified an additional potential source of funding for CPS SFM costs from the settlement agreement between CEG and the DOE. Under the DOE Standard Contract No. DE-CR01-84RW00008, the United States Government has agreed to reimburse CEG for costs incurred attributable to the DOEs failure to meet its contractual obligations for the transfer of spent fuel from CPS and other CEG nuclear plants.2 The NRC staff finds the SFMP estimates to be reasonable, based on a cost comparison with decommissioning reactors that are similar to CPS, while acknowledging that there are large uncertainties and potential site-specific variances. In addition, based on its review of CEGs plan to fund irradiated fuel expenditures using a combination of operating revenue and excess decommissioning trust funds, as well as the DOE reimbursements pursuant to the settlement agreement between CEG and the DOE, the NRC staff finds that there is reasonable assurance that adequate funds will be available for the management of irradiated fuel.
4.3 Evaluation of the Preliminary Decommissioning Cost Estimate CEG estimated the total decommissioning cost of CPS to be approximately $1.5 billion (in 2021 dollars). This cost includes $1.180 billion for license termination expenditures, $209.7 million for SFM expenditures, and $98.53 million for site restoration expenditures. CEG has not made a final determination of the decommissioning approach for CPS. For the purposes of this submittal, the SAFSTOR option has been selected with radiological decommissioning completed and 10 CFR, part 50, license termination in 2087. The NRC staff notes that 10 CFR, part 50, license termination cannot occur until all spent fuel is transferred to the DOE.
The licensee has divided the estimated total cost of $1.5 billion into the following principal categories/activities: decontamination costs; support systems/component removal; packaging; transportation; waste disposal; waste processing; program management; security; spent fuel storage; insurance and regulatory fees; energy; characterization and licensing surveys; property taxes; and miscellaneous equipment and supply costs. The licensee included a timeline and an annual cost projection that identifies when these activities will take place, and the costs associated with each of these items. In addition, the licensee identified the contingency factors for major activities ranging from 10 to 75 percent. The NRC staff reviewed the contingency factors and the work difficulty factors used in the cost estimate and finds them to be reasonable.
Decommission is defined in 10 CFR 50.2 as removal of a facility or site safely from service and reduce residual radioactivity to a level that permits: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. Decommissioning costs, as defined in the regulation, are included in the licensees $1.5 billion estimate. The licensees costs for radiological decommissioning is presented in Attachment 3 of its April 18, 2022, letter. The licensees decommissioning funding analysis in its April 18, 2022, letter, was based on a decommissioning trust fund (DTF) balance 2ML21057A273.
for radiological decommissioning of $719.0 million as of December 31, 2021. On March 31, 2023, CEG provided a decommissioning funding status report that was based on a DTF balance of $634 million as of December 31, 2022. The NRC staff performed an independent cash flow analysis of the DTF assuming a 2 percent real rate of return and estimated that about $76.7 M will remain in the trust fund following completion of decommissioning in 2087.
Additionally, in accordance with NUREG-1713, the NRC staff compared the preliminary cost estimate of $1.5 billion to the minimum decommissioning funding amount of $700 million based on the formulas in 10 CFR 50.75(c) and determined the CEG amount is greater than the NRC minimum decommissioning funding amount. Based on the above, the NRC staff concludes that the DTF has sufficient funds to pay for radiological decommissioning.
The NRC staff evaluated the preliminary cost estimate with respect to the factors and costs identified in section 3.2.1 of this safety evaluation (SE). The cost estimate provided the following principal factors:
Decommissioning option/method anticipated: CEG has not made a final determination of the decommissioning approach for CPS; however, for purposes of this submittal, the licensee noted that the SAFSTOR option has been selected.
Potential for known or suspected contamination of the facility or site: CEG provided an allowance for soil and groundwater remediation costs in the cost estimate. The required soil remediation is based on evaluation of 10 CFR 50.75(g)(1) reports.
Low-level radioactive waste (LLW) disposition plan: The preliminary decommissioning cost estimate (DCE) provides a description of CEGs LLW disposal plans and table 4-1 provides a breakdown of waste volumes by regulatory disposal classification.
Preliminary schedule of decommissioning activities: CEG provided a preliminary schedule of activities related to the SAFSTOR method of decommissioning for CPS.
Although the detailed decommissioning activities listed within the preliminary DCE are titled differently than the major decommissioning phases cited in NUREG-1713, they achieve the same result. The major milestones identified in the DCE include the following six periods of license termination and site restoration activities:
(1) Decommissioning Planning - This phase begins 2 years prior to shutdown to perform planning and licensing activities and ends at plant shutdown.
(2) Shutdown through Permanent Defuel - A short phase (< 1 month) where the plant staff defuels the reactor.
(3) Permanent Defuel through Zirconium Fire Window - This phase runs from permanent defuel until the end of the Zirconium fire window. Activities to deactivate plant systems and is also performed during this phase.
(4) End of Zirconium Fire Window through All Fuel on Pad - This phase includes the removal of all spent fuel from the pool to the ISFSI pad. Emergency planning and insurance requirements are reduced due to the end of the Zirconium fire window.
(5) All Fuel on the Pad through License Termination - This phase includes further reductions of emergency planning and security requirements and continues until NRC license termination.
(6) Site Restoration - This phase occurs after license termination and includes the final demolition of any non-radiological structures, site grading, and preparation of reuse of land.
Any other factors that could significantly affect the cost to decommission: The licensee considered other potential factors that could significantly affect the cost of decommissioning. In section 4 of the preliminary DCE, CEG provides a discussion of assumptions used in developing the various costs elements and considerations; including the cost associated with decontamination and component removal, waste disposal, and labor. These assumptions serve as the foundation in the development of the anticipated cost to decommission CPS. The cost estimate also includes contingency values for all major activities examined (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal). The licensee assumes that the ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed and notes that any delay in removing the fuel from the reactor site may affect the cost of decommissioning.
The cost estimate provided the following costs:
Pre-decommissioning engineering and planning costs, including utility staff, NRC fees, and contracted engineering analyses Reactor deactivation costs, including utility staff, security staff, structure decontamination, insurance, heavy equipment, health physics supplies, maintenance supplies, spent fuel pool O&M supplies, plant energy, hazardous liquid remediation, NRC fees, emergency planning fees, modifications, process decommissioning water waste, site upkeep, disposal of dry active waste, and severance.
Safe storage costs, including utility staff, security staff, insurance, health physics supplies, maintenance supplies, plant energy, NRC fees, process decommissioning water waste, site upkeep, disposal of dry active waste.
Dismantlement costs, including utility staff, security staff, decommissioning operations contractor staff, structure removal, system removal, insurance, reactor pressure vessel, reactor pressure vessel internals, greater than Class C waste disposal, heavy equipment, health physics supplies, maintenance supplies, plant preparation and temporary services, plant energy, hazardous liquid remediation, lead remediation, NRC fees, asbestos, condenser, turbine generator, retired turbine generator, recirc pumps/reactor coolant pumps, site excavation, scaffolding, process decommissioning water waste, site upkeep, spent fuel rack removal, disposal of dry active waste, decommissioning operations contractor relocation, decommissioning waste, cofferdams, site grading and landscaping, remove rubble/backfill site, radiation Surveys and, severance.
LLW disposition - LLW packaging, transportation, vendor processing, and disposal is included above under Dismantlement costs. Waste disposal and waste processing is included in Attachment 1, table 6-1.
Based on its review of the factors and costs outlined in the preliminary cost estimate, the NRC staff finds that the licensee has adequately addressed the factors and costs specified by the guidance in NUREG-1713, as described in section 3.2.1 of this SE. Based on the above, the
NRC staff finds the preliminary cost estimate for radiological decommissioning of CPS is reasonable, and that the DTF balance, as of December 31, 2022, will be sufficient to fund the radiological decommissioning.
5.0 CONCLUSION
The NRC staff finds that CEGs program for the long-term storage of spent fuel and the preliminary cost estimate for radiological decommissioning of CPS are adequate and provide sufficient details associated with the funding mechanisms. The NRC staff, therefore, concludes that the licensees spent fuel management program for CPS complies with 10 CFR 50.54(bb) and approves the program on a preliminary basis. In addition, the NRC staff finds that the preliminary cost estimate for CPS is reasonable and complies with the requirements of 10 CFR 50.75(f)(3).
Principal Contributor: Mable A. Henderson Date: November 2, 2023
ML22300A221 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NMSS/REFS/FAB/BC NAME JWiebe SRohrer FMiller DATE 10/30/2023 10/31/2023 10/30/2023 OFFICE OGC NLO NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME AGhosh-Naber JWhited JWiebe DATE 10/30/2023 11/02/2023 11/02/2023