ML23090A170

Midamerican Nuclear Energy Co., Decommissioning Funding Status Report Pursuant to 10 CFR 50.75(f)(l), Including ISFSI Decommissioning Funding (10 CFR 72.30)

ML23090A170
Person / Time
Site:	Quad Cities
Issue date:	03/29/2023
From:	Kraemer G MidAmerican Nuclear Energy Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML23090A170 (1)

Text

~ Mid.Am.erican MidAmerican Energy 666 Grand Ave., Suite 2700

~ ENERGY Des Moines, Iowa 50309

~ OBSESSIVELY, RELENTLESSLY AT YOUR SERVICE,. 515 281-2990 Telephone 515 242-4398 Fax gretchen.kraemer@midamerican.com Gretchen Kraemer Senior Attorney VIA EXPRESS MAIL March 29, 2023 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Stop O-Pl-17 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Re : Decommissioning Funding Status Report Pursuant to 10 CFR

§50.75(f)(l), including ISFSI Decommissioning Funding (10 CFR §72.30)

Document Control Desk:

Enclosed is a signed original version of MidAmerican Energy Company's Decommissioning Funding Status Report (Report) for MidAmerican's twenty-five (25) percent share of the Quad Cities Nuclear Power Station, submitted pursuant to 10 CFR

§50.75(f)(l). The attached Report also includes the decommissioning funding plan for ISFSI, pursuant to 10 CFR §72.30.

If you have any questions regarding this submission, please contact the undersigned.

Respectfully submitted, Gretchen Kraemer Senior Attorney MidAmerican Energy Company 666 Grand Ave., Suite 2700 Des Moines, Iowa 50309 Phone: (515) 281-2990 Fax: (515) 242-4398 e-mail: gretchen.kraemer@midamerican.com

2023 DECOMMISSIONING FUNDING STATUS REPORT 10 CFR 50.75(f)(l)

(For The Year Ending December 31, 2022)

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 & 2 Submitted by MidAmerican Energy Company Dated March 29, 2023

OVERVIEW This Decommissioning Funding Status Report is being submitted pursuant to 10 CFR 50.75(f)(l) by MidAmerican Energy Company (MEC), a twenty-five percent owner of Quad Cities Nuclear Power Station, Units 1 & 2 (Quad Cities).

ADDITIONAL INFORMATION 1.) Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c).

Determined in accord with 10 CFR 50.75(b) and applicable formulas in 10 CFR 50.75(c) and reported in end of year 2022 dollars.

NRCMinimum Unit 1 $170,817,601 Unit2 $170,817,601 Totals $341,635,202 2.) Amount accumulated to the end of the calendar year preceding the date of the.

report.

As ofDecember 31, 2022, MEC had an accumulated after-tax balance of$663,720,846.

External Trust Fund Balance (Fair Market value)

Unit 1 $331,761,112 Unit2 $331,959,735 Totals $663,720,846 3.) Schedule of the annual amount remaining to be collected.

Within the meaning of 10 CFR 50.75(e)(l)(ii)(A), MEC collects the estimated total cost of decommissioning through rates established by "cost of service" or similar ratemaking regulation. Pursuant to the Iowa Utilities Board's rate case decision in Docket No. RPU-2013-0004, MidAmerican Energy Company's annual Iowa jurisdictional decommissioning cost included in the cost of service is $1,595,964 divided equally between the two Quad Cities Units. MidAmerican plans to continue customer collections at that same level through the operating license period of the plant. The Illinois Commerce Commission has not authorized any current, ongoing collections for decommissioningfrom MEC's Illinois ratepayers. On October 28, 2004 the NRC issued renewed facility operating licenses for Quad Cities Nuclear Power Station Unit 1 (License No. DPR-29) and Unit 2 (License No. DPR-30) effective as of the date of 2

issuance and which shall expire at midnight on December 14, 2032, in effect extending the licenses an additional twenty years.

4.) Assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

In filings with the IUB, MEC periodically utilizes appropriate assumptions for decommissioning cost escalations and earnings rates. Solely for purposes of meeting NRC's minimum requirements, MEC has calculated that the current fund balances and annual funding levels, together with earnings at a 2 percent annual real rate of return as permitted by 10 CFR 50.75(e)(l)(ii), satisfyNRC's minimum funding assurance requirements. Given the current fund balances, anticipated earnings on the funds, and planned future contributions, MEC expects that fully adequate funding will be available for each unit at the time of decommissioning.

• 5.) Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(l)(v).

MEC is not relying upon any contract for purposes of providing decommissioning funding within the meaning of 10 CFR 50.75(e)(l)(v).

6.) Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

MEC continues to use the external sinking fund method of providing decommissioning funding assurance.

7.) Any material changes to trust agreements.

No material changes were made to the trust agreements since MidAmerican's last Decommissioning Funding Status Report, in 2021, and no additional material changes were needed for compliance with 10 CFR 50.75(h)(2). The following table identifies the current Trustee and Investment Manager for each fund.

Trust Trustee InvestmentMana2er Unit 1, Qualified The Ba,nk of New York NISA Investment Advisors Mellon Unit 1, Non-Qualified The Bank of New York NISA Investment Advisors.

Mellon 3

Unit 2, Qualified The Bank of New York NISA Investment Advisors Mellon Unit 2, Non-Qualified The Bank of New York NISA Investment Advisors Mellon 8.) ISFSI Decommissioning Funding Plan.

See Attachment No. 1.

MID AMERICAN ENERGY COMPANY

~~~

By:

Gretchen Kraemer, Senior attorney MidAmerican Energy Company 666 Grand Avenue, Suite 2700 Des Moines, Iowa 50309 Phone: (515) 281-2990 Email: gretchen.kraemer@midamerican.com 4

ATTACHMENT No. 1 ISFSI Decommissioning Funding Plan 1.0

SUMMARY

DESCRIPTION MidAmerican Energy Company (MidAmerican) is a minority owner, with a 25%

ownership share, of Quad Cities Nuclear Power Station (QCNPS) Units 1 and 2.

MidAmerican co-owns QCNPS with Exelon Generation Company, LLC (Exelon).

- Exelon owns a 75% share of Units 1 and 2 and operates both units as well. Exelon and MidAmerican maintain decommissioning cost estimates for QCNPS, which are periodically updated. Imbedded in these decommissioning cost estimates are the costs associated with decommissioning the Independent Spent Fuel Storage Installation (ISFSI) located at QCNPS. The decommissioning cost estimate for the ISFSI has been extracted from the decommissioning cost estimate and is provided herein.

As Exelon has noted in its own 10 CPR 72.30(b) filing, the radiological decommissioning costs for an ISFSI typically consist of the costs associated with removing and disposing of small volumes of neutron-activated concrete and certain structural steel components.

Exelon has indicated that no impact is expected upon soil and groundwater at the QCNPS site during the storage period contemplated in the decommissioning cost estimate for the site. Exelon has also noted that induced radioactivity at the QCNPS ISFSI is not expected to result in residual radioactivity in excess of 25 mRem/yr in an unrestricted release scenario, were no action to be taken to remediate the site.

Finally, Exelon has noted that it anticipates small, but measurable amounts of induced radioactivity to be present, and release of this material from the QCNPS site will require it to be disposed of at a NRC-licensed radioactive waste disposal facility. Therefore, Exelon has included the costs of this disposal in the decommissioning cost estimates.

2.0 DETAILED DESCRIPTION 2.1 Reasonable Assurance of Funds Availability MidAmerican's trust fund balances for QCNPS Units 1 and 2 currently exceed the costs required for radiological decommissioning-see Tables 1 and 2, below. The excess assets will be used to decommission the on-site ISFSI. Table 1, below, shows the costs estimated for radiological decommissioning under 10 CPR 50.75(b) and (c), using the NRC Minimum formulas, and Table 2 shows MidAmerican' s trust fund balances as of December 31, 2022. Both the radiological decommissioning costs and the trust fund balances are stated in 2022 dollars and are adjusted for MidAmerican's 25% ownership share.

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2.2 Detailed Cost Estimate Table 3, below, which is based upon the Constellation decommissioning cost estimate for QCNPS, details the costs of ISFSI decommissioning in 2022 dollars (i.e., July 2022 dollars escalated at an aggregate rate of 1.53% to December 2022). Table 3 shows the costs of performing this work (discussed further in the assumptions below), with an adequate contingency factor, to meet the 10 CFR 20.1402 criteria for unrestricted use. The cost of performing this ISFSI decommissioning work is approximately $2,122,500 ($4,245,000 x 1/2 =

$2,122,500 per Table 3, see the "Total Costs" column) per unit for MidAmerican's 25% share.

2.3 Assumptions MidAmerican has made the following assumptions with respect to ISFSI decommissioning:

1. Decommissioning costs in Table 3 are in 2022 dollars (i.e., July 2022 dollars escalated at an aggregate rate of 1.53% to December 2022).

2. All values in Tables 1 - 4 are stated at MidAmerican's 25% ownership share for QCNPS.

3. The costs for ISFSI decommissioning are expected to be incurred in the year in which DOE has accepted all spent fuel from the QCNPS site for disposal.

2.4 Method of Assurance In accordance with 10 CFR 72.30(b)(4), Tables 1 - 3 demonstrate the method of assuring funds for ISFSI decommissioning, from 10 CFR 72.30(e). Exelon and MidAmerican periodically update the decommissioning cost estimate for QCNPS, and MidAmerican adjusts the funding levels, as necessary, in accordance with 10 CFR 50.75. (MidAmerican's annual Iowa jurisdictional decommissioning cost included in the cost of service is $1,595,964 per the Iowa Utilities Board's rate case decision in Docket No. RPU-2013-0004. The Illinois Commerce Commission has not authorized any current, ongoing collection from MidAmerican's Illinois ratepayers.)

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2.5 Volume of Subsurface Residual Radioactivity Requiring Remediation Per review of site-specific 10 CFR 50.75(g) logs, Exelon indicates it has not identified any onsite, subsurface material containing residual radioactivity at the ISFSI located at QCNPS.

2.6 Certification of Financial Assurance In accordance with 10 CFR 72.30(b), financial assurance, for decommissioning, has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b). As demonstrated in Tables 1 - 4, this provides the requisite financial assurance for the ISFSI decommissioning costs.

Table 1 NRC Minimum Unit 1 $170,817,601 Unit2 $170,817,601 Totals $341,635,202 Table 2 External Trust Fund Balance (Fair Market Value)

Unit 1 $331,761,112 Unit2 $331,959,735 Totals $663,720,846 Table 3 (ISFSI Decommissioning Costs)

(2022 Dollars)

MidAmerican's . Equipment Ownership Share labor & Materials Energy Burial Other Total Costs Unit 1 924,177 407,897 4,569 385,560 400,536 2,122,738 Unit2 924,075 407,871 4,556 385,542 400,569 2,122,614 Total 1,848,252 815,768 9,125 771,103 801,105 4,245,353 7

Table 4 (Total Decommissioning Costs per NRC Minimum Formulas)

(2022 Dollars)

MidAmerican Energy Company Quad Cities, Units 1 & 2 2,957 MWt As of 12/31/2022 REACTOR TYPE: BWR BASE COST (1986 Cost) $ 130,613,000

($104 + 0.009P (in MW!))

Escalation Factors 12/31/2022 Base Factor Base Year Source:

labor 152.8 2.08 2005 Bureau of labor Statistics: Series CIU2010000000230!

Energy Po'Mir(P) 280.0 114.2 1986 Bureau of labor Statistics: Series WPU0543 Fuel (F) 395.1 82.0 1986 Bureau of labor Statistics: Series WPU0573 Waste Burial {B) 12.296 NUREG-1307, Rev 19, Table 2-1 Calculation Labor Formula: l=Labor_CurrentYear Factor*

labor Factor (L) 3.18 X 0.65 = 2.07 labor Base Factor Energy Formula: E =

0.54*(Power_ CurrentY earFactor/Power_BaseYear)+

Energy Factor (E) 3.54 X 0.13 = 0.46 0.46*(Fuel_CurrentY earFactor/Fuel BaseY ear Waste Factor (B) 12.296 X 0.22 = 2.71 Total Escalation Factor: 5.23 Total Escalation Formula: 0.65L + 0.13E + 0.228 Total Minimum Assurance Unit 1 & 2 (100%): 1$1,3ss,s40,a11 I MidAmerican Minimum Assurance (25%): $ 341,635,202 8