3F0323-02, Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2022

Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2022

ML23088A387
Person / Time
Site:	Crystal River
Issue date:	03/29/2023
From:	State S ADP CR3
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
3F0323-02
Download: ML23088A387 (1)

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U. S. Nuclear Regulatory Commission Page 2 of 3 3F0323-02

Dear Sir or Madam:

10 CFR 50.75(f)(1) requires each shutdown power reactor licensee to annually report to the NRC the status of their decommissioning financial assurance by March 31.

10 CFR 50.82(a)(8)(v) & (vii) require that after submitting its site-specific decommissioning cost estimate pursuant to 10 CFR 50.82(a)(4)(i), a licensee must annually submit to the NRC, by March 31, a report on the status of its decommissioning expenditures, remaining costs and funding assurance levels, as well as a report on the status of its funding for managing irradiated fuel.

A change to the spent fuel management strategy was described by Duke Energy Florida, LLC (DEF), ADP CR3, LLC (ADP CR3), and ADP SF1, LLC (ADP SF1) in the application for license transfer and was approved by the NRC in Reference 2. Under the terms of the license transfer, ADP CR3 became the NRC operator licensee responsible for all activities under the Crystal River Unit 3 Nuclear Plant (CR3) license. Under a Purchase and Sale Agreement (PSA) with DEF as part of the license transfer, ADP SF1 acquired the ISFSI, its associated equipment, the high-level radioactive and greater than Class C (GTCC) waste, and title to the spent nuclear fuel. DEF also assigned to ADP SF1 its Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste with the U.S. Department of Energy (DOE).

ADP SF1 entered into an operating agreement with ADP CR3, to possess and maintain the ISFSI, its associated equipment, and spent nuclear fuel.

As the NRC owner licensee, DEF continues to own the CR3 facility, with the exception of the assets described above, and its nuclear decommissioning trust (NDT). In addition to maintaining the NDT, DEF is responsible for disbursement of funds to pay for the costs of decommissioning as work is completed.

As a result of the PSA, after October 1, 2020, funding for spent fuel management costs for CR3 is no longer provided by the NDT. Funding for spent fuel management is provided by the ADP SF1 parent companies, NorthStar and Orano. The projected irradiated fuel management costs were submitted with the revised PSDAR in Reference 1, and an updated cash flow analysis was included in last years Annual Decommissioning and Irradiated Fuel Management Financial Status Report. In addition, ADP updated the Decommissioning Cost Estimate (DCE) in May 2022 - Reference 5. A dedicated ISFSI Decommissioning Trust Fund has been established by ADP SF1 in accordance with the Order approving the license transfer as described in Reference 4.

U. S. Nuclear Regulatory Commission Page 3 of 3 3F0323-02

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ADP CR3, LLC DOCKET NUMBERS 50-302 / 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 1 CR3 ANNUAL DECOMMISSIONING FINANCIAL STATUS REPORT FOR 2022

U. S. Nuclear Regulatory Commission Attachment 1 3F0323-02 Page 1 of 2 ADP CR3, LLC Status of Decommissioning Funding Crystal River Nuclear Plant As of December 31, 2022 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) 10 CFR 50.75(f)(1) (Thousands of Dollars)

1. Minimum Financial Assurance (MFA) $254,684 [Note 1]

2. ISFSI Obligation as of 12/31/2022 $4,587 [Note 2]

3. Decommissioning Trust Fund Balance as of

$458,126 [Note 3]

12/31/2022

4. A schedule of the annual amounts remaining to be

$14,026 [Note 4]

collected

5. Assumptions used in determining rates of escalation in decommissioning costs, rates of 2% annual real rate of return per earnings on decommissioning funds, and rates of 10 CFR 50.75(e)(1)(i) other factors used in funding projections.

6. Any contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v)

7. Modifications occurring to a licensee's current method of providing financial None assurance since the last submitted report

8. Any material changes to trust agreements None Note 1: This amount is based upon total DECON expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and PROMPT DECON analysis provided in Attachment 2. This is the amount of decommissioning funds estimated to be required for remaining License Termination Costs.

Note 2: ISFSI Obligation is funded by the ISFSI Decommissioning Trust Account (See Table 3.1) and based on the ISFSI demolition site-specific cost estimate dated March 30, 2022.

Note 3: NDT Balance - $424,308 plus Provisional Trust Balance $33,818.

Note 4: Reflects ADP contributions pursuant to the terms of the Decommissioning Services Agreement (DSA) dated May 8, 2019, and as amended October 1, 2020.

U. S. Nuclear Regulatory Commission Attachment 1 3F0323-02 Page 2 of 2 ADP CR3, LLC Status of Decommissioning Funding Crystal River Nuclear Plant As of December 31, 2022 - 10 CFR 50.75(f(1) and 10 CFR 50.82(a)(8)(v) 10 CFR 50.82(a)(8)(v) & (vi) (Thousands of Dollars)

1. Cumulative decommissioning spending through

$390,498 [Note 1]

12/31/2022

2. 2022 decommissioning spending $94,902 [Note 2]

3. Decommissioning Trust Fund & Provisional Trust

$458,126 [Note 3]

Fund Total as of 12/31/2022

4. Additional planned contributions to the Provisional

$14,026 [Note 4]

Trust Account

5. Estimated costs to complete from the latest $254,684 estimate. (See #1 above in 10 CFR 50.75 information)

ADP CR3 has projected the cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Department of Energy based on the assumption that DOE pickup of fuel no later than 2037. The cost analysis is provided in Attachment 3.

6. Estimate based on unrestricted release of the site See Attachment 2 per 10 CFR 20.1402

7. Modifications to Financial Assurance Since Last Report None

8. Any material changes to trust agreements None Note 1: Cumulative Spending ($295,596) per report, dated March 30, 2022 (3F0322-01) plus 2022 decommissioning spending $94,902).

Note 2: Represents the amount actually disbursed from the fund for calendar year 2022.

Note 3: NDT Balance - $424,308 plus Provisional Trust Balance $33,818.

Note 4: Reflects ADP contributions and distributions pursuant to the terms of the Decommissioning Services Agreement (DSA) dated May 8, 2019, and as amended October 1, 2020.

ADP CR3, LLC DOCKET NUMBERS 50-302 / 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 2 CR3 ESTIMATE OF COSTS TO COMPLETE DECOMMISSIONING AND FINANCIAL ASSURANCE DEMONSTRATION

U. S. Nuclear Regulatory Commission Attachment 2 3F0323-02 Page 1 of 2 CR3 ESTIMATE OF COSTS TO COMPLETE DECOMMISSIONING AND FINANCIAL ASSURANCE DEMONSTRATION Table 2.1 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - Total License Termination and Site Restoration - TABLE 2.1 (Thousands of 2023 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 License License Beginning of Net Incremental Site End-Of-Year Termination Termination Total Period Funded NDT Contributions & Annual Earnings Year Restoration Fund Cost Cost Expenses Balance Withdrawals (Distributions) on Fund Cost Balance (ADP-Contractor) (DEF-Owner) (NDF + PT) Provisional Trust 2023 $92,803 $1,541 $1,055 $95,399 $458,126 $95,399 $5,631 $7,255 $375,613 2024 $91,627 $1,572 $1,693 $94,892 $375,613 $94,892 $5,599 $5,614 $291,935 2025 $44,574 $1,603 $5,988 $52,165 $291,935 $52,165 $2,796 $4,795 $247,362 2026 $10,205 $1,635 $25,836 $37,676 $247,362 $37,676 $0 $4,194 $213,879 2027 $0 $680 $0 $680 $213,879 $4,623 -$50,000 $4,185 $163,441 2028 $0 $694 $0 $694 $163,441 $694 $0 $3,255 $166,002 2029 $0 $708 $0 $708 $166,002 $708 $0 $3,306 $168,601 2030 $0 $722 $0 $722 $168,601 $722 $0 $3,358 $171,236 2031 $0 $736 $0 $736 $171,236 $736 $0 $3,410 $173,910 2032 $0 $751 $0 $751 $173,910 $751 $0 $3,463 $176,622 2033 $0 $766 $0 $766 $176,622 $766 $0 $3,517 $179,373 2034 $0 $781 $0 $781 $179,373 $781 $0 $3,572 $182,164 2035 $0 $797 $0 $797 $182,164 $797 $0 $3,627 $184,994 2036 $0 $813 $0 $813 $184,994 $813 $0 $3,684 $187,865 2037 $0 $829 $0 $829 $187,865 $829 $0 $3,741 $190,776 2038 $0 $846 $0 $846 $190,776 $846 $0 $3,799 $193,729 TOTAL $239,210 $15,474 $34,572 $280,812 $458,126 $293,198 -$35,973 $64,774 $193,729

U. S. Nuclear Regulatory Commission Attachment 2 3F0323-02 Page 2 of 2 Table 2.1 Definitions: (Thousands of Dollars)

Column 1: License Termination Cost - (ADP-Contractor)

Reflects the Total Annual License Termination Plan cost for ADP (Contractor) in 2023 dollars at a 2% escalation rate.

Column 2: License Termination Cost - (DEF-Owner)

Reflects the Total Annual License Termination Plan cost for DEF (Owner) in 2023 dollars at a 2% escalation rate.

Column 3: Site Restoration Cost:

Reflects the Annual Site Restoration Plan cost in 2023 dollars at a 2% escalation rate.

Column 4: Total Expenses Reflects Total Expenses (Column 1 plus Column 2 plus Column 3)

Column 5: Beginning of Period Funded Balance Reflects the Funded Balance as of January 1 of each year thereafter. The Funded Balance includes the Nuclear Decommissioning Trust (NDT), plus the Provisional Trust (PT)

• January 1, 2023, Beginning of Period Funded Balance equals $458,126, which includes $424,308 NDT Balance plus $33,818 PT Balance Column 6: NDT Withdrawals Reflects the annual expenditures from the NDT in 2023 dollars at a 2% escalation rate.

• $4,623 estimated withdrawal on January 1, 2027, reflects Total Expenses

($680) plus final payment for achievement of the ISFSI-Only Interim End-State Conditions ($3,943) pursuant to Section 9.3.4 of the Decommissioning Services Agreement (DSA) dated May 29, 2019, and Amended October 1, 2020.

Column 7: ADP Net Incremental Contributions (Distributions) - Provisional Trust Reflects ADP incremental contributions and (distributions) pursuant to the terms of the DSA.

Column 8: Annual Earnings on Funds Reflects earnings on funds remaining in the trust. A 2% Earnings rate is used over a 0% cost escalation rate. The annual 2% earnings are calculated on the Beginning Balance (Column 5) minus 100% of withdrawals (Column6) plus 100%

of contributions (Columns 7) multiplied by the 2% annual earnings rate.

Column 9: End of Year Fund Balance Reflects the End-of-Year Trust Fund Balance.

- (Column 5 minus Column 6 plus Column 7 plus Column 8)

ADP CR3, LLC DOCKET NUMBERS 50-302 / 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 3 CR3 PROJECTED CASH FLOW ANALYSIS FOR IRRADIATED FUEL MANAGEMENT

U. S. Nuclear Regulatory Commission Attachment 3 3F0323-02 Page 1 of 4 CR3 PROJECTED CASH FLOW ANALYSIS FOR IRRADIATED FUEL MANAGEMENT Table 3.1 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - ISFSI Decommissioning - TABLE 3.1 (Thousands of 2023 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Spent Fuel Beginning of End-Of-Year ADP ADP Annual Earnings Year Management Period Fund Fund Withdrawals Distributions on Fund

- ISFSI Demo Balance Balance 2023 $0 $3,886 $0 $0 $78 $3,964 2024 $0 $3,964 $0 $0 $79 $4,043 2025 $0 $4,043 $0 $0 $81 $4,124 2026 $0 $4,124 $0 $0 $82 $4,206 2027 $0 $4,206 $0 $0 $84 $4,290 2028 $0 $4,290 $0 $0 $86 $4,376 2029 $0 $4,376 $0 $0 $88 $4,464 2030 $0 $4,464 $0 $0 $89 $4,553 2031 $0 $4,553 $0 $0 $91 $4,644 2032 $0 $4,644 $0 $0 $93 $4,737 2033 $0 $4,737 $0 $0 $95 $4,832 2034 $0 $4,832 $0 $0 $97 $4,928 2035 $0 $4,928 $0 $0 $99 $5,027 2036 $0 $5,027 $0 $0 $101 $5,127 2037 $4,587 $5,127 $4,587 -$540 $0 $0 TOTAL $4,587 $3,886 $4,587 -$540 $1,241 $0

U. S. Nuclear Regulatory Commission Attachment 3 3F0323-02 Page 2 of 4 Table 3.1 Definitions:

Column 1: Spent Fuel Management - ISFSI Demo Reflects the Total ISFSI Decommissioning cost in 2023 dollars at a 2% escalation rate.

Column 2: Beginning of Period Funded Balance Reflects the Funded Balance as of January 1 of each year.

Column 3: ADP NDT Withdrawals Reflects the annual expenditures from the NDT in 2023 dollars at a 2% escalation rate.

Column 4: ADP Distributions Reflects distribution of residual ISFI Decommissioning funds upon completion of the ISFSI decommissioning.

Column 5: Annual Earnings on Funds Reflects earnings on funds remaining in the trust. A 2% Earnings rate is used over a 0% cost escalation rate. The annual 2% earnings are calculated on the Beginning Balance (Column 2) minus 100% of withdrawals (Columns 3) minus 100% of distributions (Columns 5) multiplied by the 2% annual earnings rate.

Column 6: End of Year Fund Balance Reflects the End-of-Year Trust Fund Balance.

- (Column 2 minus Column 3 plus Column 4 plus Column 5)

U. S. Nuclear Regulatory Commission Attachment 3 3F0323-02 Page 3 of 4 CR3 PROJECTED CASH FLOW ANALYSIS FOR IRRADIATED FUEL MANAGEMENT Table 3.2 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - Irradiated Fuel Management - Table 3.2 (Thousands of 2023 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Spent Fuel Beginning of ADP Incremental End-Of-Year ADP DOE Cost Annual Earnings Year Management Period Fund Contributions Fund Withdrawals Recovery on Fund Costs Balance (Distributions) Balance 2023 $10,531 $417 $10,531 $10,675 $0 $3 $564 2024 $7,518 $564 $7,518 $0 $16,861 $50 $9,956 2025 $7,669 $9,956 $7,669 -$10,850 $19,361 $54 $10,853 2026 $7,822 $10,853 $7,822 $0 $15,187 $91 $18,309 2027 $11,298 $18,309 $11,298 $0 $7,822 $74 $14,907 2028 $11,524 $14,907 $11,524 $0 $11,298 $73 $14,754 2029 $11,755 $14,754 $11,755 $0 $11,524 $73 $14,596 2030 $11,990 $14,596 $11,990 $0 $11,755 $72 $14,433 2031 $12,230 $14,433 $12,230 $0 $11,990 $71 $14,264 2032 $12,474 $14,264 $12,474 $0 $12,230 $70 $14,090 2033 $12,724 $14,090 $12,724 $0 $12,474 $69 $13,909 2034 $12,978 $13,909 $12,978 $0 $12,724 $68 $13,723 2035 $13,238 $13,723 $13,238 $0 $12,978 $67 $13,531 2036 $13,503 $13,531 $13,503 $0 $13,238 $66 $13,333 2037 $77,171 $13,333 $77,171 $0 $64,671 $4 $837 TOTAL $234,425 $417 $234,425 -$175 $234,114 $906 $837

U. S. Nuclear Regulatory Commission Attachment 3 3F0323-02 Page 4 of 4 Table 3.2 Definitions: (Thousands of Dollars)

Column 1: Spent Fuel Management Costs Reflects the Total Annual Spent Fuel Management cost in 2023 dollars at a 2%

escalation rate.

Column 2: Beginning of Period Funded Balance Reflects the Funded Balance as of January 1 of each year.

Column 3: ADP Withdrawals Reflects the annual expenditures from the Irradiated Fuel Management Account in 2023 dollars at a 2% escalation rate paid by ADP SF1 pursuant to the SNF Services Agreement dated October 1, 2020.

Column 4: ADP Incremental Contributions (Distributions)

Reflects ADP incremental contributions and (distributions).

Column 5: DOE Cost Recovery Reflects Cost Recovery from DOE for breach of the Standard Contract in 2023 dollars at a 2% escalation rate.

• Conservatively assumes recovery of approximately 91% of costs, net of legal costs and disallowed costs

• Year 2024: $16,861 recovery reflects initial NorthStar DOE settlement for costs incurred from 2020 thru 2021

• Year 2025: $19,361 recovery reflects initial NorthStar DOE settlement for costs incurred from 2022 thru 2023

• Year 2026: $15,187 recovery reflects initial NorthStar DOE settlement for costs incurred from 2024 thru 2025

• Year 2037: $64,671 reflects NorthStar DOE settlement for costs incurred in 2036 and 2037. (excludes recovery DOE Fuel Loading Costs - $21,415 incurred in 2037)

Column 6: Annual Earnings on Funds Reflects earnings on funds remaining in the account. A 2% Earnings rate is used over a 0% cost escalation rate. The annual 2% earnings are calculated on the Beginning Balance (Column 4) minus 100% of withdrawals (Column5) plus 100%

of contributions (Columns 6) multiplied by the 2% annual earnings rate.

Column 7: End of Year Fund Balance Reflects the End-of-Year Trust Fund Balance.

- (Column 2 minus Column 3 plus Column 4 plus Column 5 plus Column 6)