ML22340A475
| ML22340A475 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 02/24/2023 |
| From: | Yoira Diaz-Sanabria Storage and Transportation Licensing Branch |
| To: | Conry T Yankee Atomic Electric Co |
| References | |
| EPID L-2017-FPR-0074 | |
| Download: ML22340A475 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 24, 2023 Timothy Conry Treasurer Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF YANKEE ATOMIC ELECTRIC COMPANYS 2018 AND 2021 UPDATED DECOMMISSIONING FUNDING PLANS FOR THE YANKEE NUCLEAR POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION
Dear Timothy Conry:
By letters dated December 10, 2018 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML18354A738), December 10, 2021 (ML22010A012), as supplemented by letter dated August 3, 2022 (ML22237A063), Yankee Atomic Electric Company (YAEC) submitted updated decommissioning funding plans (DFPs) for the Independent Spent Fuel Storage Installation (ISFSI) located at the former Yankee Nuclear Power Station (YNPS) located in Rowe, Massachusetts, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval.1 Previously, by letter dated December 17, 2012 (ML123630169), YAEC submitted the initial DFP for the YNPS ISFSI for NRCs review and approval. By letter dated December 14, 2015 (ML16020A016), YAEC submitted an updated DFP, also for NRC staff review and approval.
The NRC staff reviewed these DFP submittals (i.e., the initial and the 2015 triennial update),
and documented the findings in its letter dated April 7, 2021 (ML21062A247). In support of the approvals of the initial and the updated 2015 DFPs, the NRC staff published the results of these reviews in an environmental assessment and findings of no significant impact in the Federal Register (86 FR 19644) on April 14, 2021. The NRC staff determined that there were no environmental impacts from the NRC staffs review and approval of YAECs initial and updated DFPs.
Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Sections 72.30(b), each holder of, or applicant for, a license under 10 CFR 72 must submit for NRC review and approval a DFP containing information on how reasonable assurance will be provided that funds will be available to decommission its ISFSIs. The DFP must contain a detailed decommissioning cost estimate (DCE) in an amount reflecting: (1) the cost of an independent contractor to perform all decommissioning activities, (2) an adequate contingency factor, and (3) the cost of meeting the 10 CFR 20.1402 unrestricted use criteria (or the cost of meeting the 10 CFR 20.1403 restricted 1 Yankee Rowe was successfully decommissioned between 1992 and 2007. During decommissioning all 533 spent fuel assemblies were transferred from the spent fuel pool to 15 spent fuel storage casks. In addition, one greater-than-Class C (GTCC) cask containing segmented sections of the reactor internals are stored on the spent fuel storage pad. The ISFSI is operated under a Part 50 General License.
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use criteria, provided the licensee can demonstrate its ability to meet these criteria). The licensees DFP must also identify and justify using the key assumptions contained in the DCE.
Further, the DFP must describe the method of assuring funds for ISFSI decommissioning, including means for adjusting cost estimates and associated funding levels periodically over the life of the ISFSI. Additionally, the DFP must specify the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination, and contain a certification that financial assurance for ISFSI decommissioning has been provided in the amount of the DCE.
Pursuant to 10 CFR 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the initial DFP required to be submitted by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination in an updated DFP. The updated DFP must update the information submitted with the original or prior approved plan. In addition, the updated DFP must also specifically consider the effect of the following events on decommissioning costs, as required by 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.
In accordance with 10 CFR 72.30(c), and using NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance, dated February 2012, the NRC staff reviewed the following updated DFPs submitted by YAEC, including the updated decommissioning cost estimates (DCEs) and the method of assuring funds for decommissioning.
2018 Updated DFP In its 2018 updated DFP, YAEC estimated the total cost to decommission the YNPS ISFSI, for unrestricted use, to be $8.01 million in 2018 dollars.
For its 2018 updated DFP, YAEC relied on prepayment in the YNPS decommissioning trust fund as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(1). The NRC staff reviewed the licensees 2018 updated DFP and finds that the aggregate dollar amount of the licensees financial instrument provides adequate financial assurance to cover its cost estimate. Therefore, the NRC staff finds this financial instrument is acceptable.
2021 Updated DFP In its 2021 updated DFP, YAEC estimated that the total cost to decommission the YNPS ISFSI, for unrestricted use, to be $5.9 million in 2021 dollars. According to YAEC, the decrease in cost estimate from the 2018 updated DCE was based, in part, on a modified assumption regarding the amount of material that would be shipped offsite as low-level radioactive waste (modified to align with other industry precedent). The NRC staff reviewed YAECs basis for the decrease in the cost estimate and found that the rationale is reasonable based on adjustments for changes in costs and industry precedent related to the quantity of waste assumed to low-level radioactive waste, while increasing the contingency factor from 10% to 25%.
For its 2021 updated DFP, YAEC relied on prepayment in the YNPS decommissioning trust fund as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(1). The NRC staff reviewed the licensees 2021 updated DFP and finds that the aggregate dollar amount of the licensees financial instrument
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provides adequate financial assurance to cover its DCE. Therefore, the NRC staff finds this financial instrument is acceptable.
Conclusion Based on its review of the above YAECs submittals, the NRC staff finds that the updated DCEs for 2018 and 2021: (1) are based on reasonable costs of a third-party contractor, (2) include an adequate contingency factor, (3) reflect the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use, and (4) are based on reasonable and documented assumptions. Therefore, the NRC staff finds that the updated DCEs adequately estimate the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCEs are acceptable.
The NRC staff reviewed YAECs 2018 and 2021 updated DFP submissions, including the updated DCEs and the method of assuring funds for decommissioning, in accordance with 10 CFR 72.30(c) and NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance.
Based on its review, the NRC staff finds that the updated DFPs contain the information required by 10 CFR 72.30(c) and that YAEC has provided reasonable assurance by which funds will be available to decommission the YNPS ISFSI. Therefore, the NRC staff finds that the DCEs adequately estimated the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCEs are reasonable.
In addition to the NRC staffs review of the above updated DFPs, the NRC staff completed an environmental review. The NRC staff published a summary of the results of the environmental review in the Federal Register (88 FR 7469) on February 3, 2023, for the YNPS ISFSI. The environmental assessment and findings of no significant impact for YNPS ISFSI is available in https://www.regulations.gov under the Docket ID: NRC-2023-0022. The NRC staff determined that there was no environmental impact from the NRC staffs review and approval of YAECs updated DFPs.
If you have any questions regarding this matter, please contact me at (301) 415-8064 or yoira.diaz-sanabria@nrc.gov.
Sincerely, Yoira K. Diaz-Sanabria Digitally signed by Yoira K. Diaz-Sanabria Date: 2023.02.24 08:40:29 -05'00' Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-31 License No.: DPR-03 EPID No.: L-2017-FPR-0074
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SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF YANKEE ATOMIC ELECTRIC COMPANYS 2018 AND 2021 UPDATED DECOMMISSIONING FUNDING PLANS FOR THE YANKEE NUCLEAR POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCUMENT DATED: February 24, 2023 DISTRIBUTION:
FMiller, NMSS SMcCarthy, NMSS SHarwell, NMSS DHabib, NMSS PJehle, OGC RidsNmssRefsFab ADAMS Accession Number: ML22340A475
- by email OFFICE DFM/STLB:PM DFM/STLB:LA OGC/NLO NMSS/STLB:BC NAME TLiu ELee for WWheatley PJehle*
YDiaz-Sanabria DATE 12/6/2022 12/7/2022 1/12/2023 2/23/2023 OFFICIAL RECORD COPY