ML22340A492

Closeout Letter to Connecticut Yankee Regarding 2018 and 2021 Updated DFPs for Haddam Neck Plant ISFSI

ML22340A492
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/24/2023
From:	Yoira Diaz-Sanabria Storage and Transportation Licensing Branch
To:	Conry T Connecticut Yankee Atomic Power Co
References
EPID L-2017-FPR-0031
Download: ML22340A492 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 24, 2023 Timothy Conry Treasurer Connecticut Yankee Atomic Power Company 362 Injun Hollow Road East Hampton, CT 06424-3099

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF CONNECTICUT YANKEE ATOMIC POWER COMPANYS 2018 AND 2021 UPDATED DECOMMISSIONING FUNDING PLANS FOR THE HADDAM NECK PLANT INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Timothy Conry,

By letters dated December 10, 2018 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML18354A741), and December 10, 2021 (ML21362A132), as supplemented by the letter dated August 3, 2022 (ML22237A077), Connecticut Yankee Atomic Power Company (CYAPCO) submitted updated decommissioning funding plans (DFP) for the Independent Spent Fuel Storage Installation (ISFSI) located on the site of Haddam Neck Plant (Haddam Neck) in East Hampton, Connecticut, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval.1 Previously, by letter dated December 17, 2012 (ML12363A024), CYAPCO submitted the initial DFP for the Haddam Neck ISFSI to the NRC for review and approval. By letter dated December 14, 2015 (ML16020A209), CYAPCO submitted an updated DFP for the Haddam Neck ISFSI to the NRC staff for review and approval. The NRC staff reviewed these DFP submittals (i.e., the initial and the triennial update) and documented its findings in a letter dated February 20, 2019 (ML19070A033). In support of its approvals of the initial and the updated DFPs, the NRC staff published the results of these reviews in an environmental assessment and findings of no significant impact in the Federal Register (84 FR 8122) on March 6, 2019.

The NRC staff determined that there were no environmental impacts from the NRC staffs review and approval of CYAPCOs initial and 2015 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 1 Haddam Neck was successfully decommissioned between 1998 and 2007. During decommissioning all 1,019 spent fuel assemblies were transferred from the spent fuel pool to 40 spent fuel storage casks. In addition, three greater-than-Class C (GTCC) casks containing segmented sections of the reactor internals are stored on the spent fuel storage pad. There are also two spent fuel transfer casks stored on the pad.

The fuel transfer casks are assumed to remain on-site until decommissioning and the disposition of which is included in this estimate. The ISFSI is operated under a Part 50 General License.

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decommissioning activities, (2) an adequate contingency factor, and (3) the cost of meeting the 10 CFR 20.1402 unrestricted use criteria (or the cost of meeting the 10 CFR 20.1403 restricted use criteria, provided the licensee can demonstrate its ability to meet these criteria). The licensees DFP must also identify and justify using the key assumptions contained in the DCE.

Further, the DFP must describe the method of assuring funds for ISFSI decommissioning, including means for adjusting cost estimates and associated funding levels periodically over the 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 CYAPCO, including the updated decommissioning cost estimates (DCEs) and the method of assuring funds for decommissioning.

2018 Updated DFP In its 2018 updated DFP, CYAPCO estimated the total cost to decommission the Haddam Neck ISFSI, for unrestricted use, to be $16.22 million in 2018 dollars.

For its 2018 updated DFP, CYAPCO relied on prepayment in the Haddam Neck 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 DCE. Therefore, the NRC staff finds this financial instrument is acceptable.

2021 Updated DFP In its 2021 updated DFP, CYAPCO estimated that the total cost to decommission the Haddam Neck ISFSI for unrestricted use to be $6.9 million in 2021 dollars. According to CYAPCO, 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 CYAPCOs 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%.

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For its 2021 updated DFP, CYAPCO relied on prepayment in the Haddam Neck 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 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 CYAPCOs 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 CYAPCOs 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 CYAPCO has provided reasonable assurance by which funds will be available to decommission the Haddam Neck 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 Haddam Neck ISFSI.

The environmental assessment and findings of no significant impact for Haddam Neck 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 CYAPCOs 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 08:42:09 -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.: 72-39 License No.: SFGL-21 EPID No.: L-2017-FPR-0031

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SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF CONNECTICUT YANKEE ATOMIC POWER COMPANYS 2018 AND 2021 UPDATED DECOMMISSIONING FUNDING PLANS FOR THE HADDAM NECK PLANT 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: ML22340A492

• 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