ML24260A219
ML24260A219 | |
Person / Time | |
---|---|
Site: | Millstone ![]() |
Issue date: | 09/16/2024 |
From: | James Holloway Dominion Energy, Dominion Energy Nuclear Connecticut |
To: | Office of Nuclear Reactor Regulation, Document Control Desk |
References | |
24-281 | |
Download: ML24260A219 (1) | |
Text
Dominion Energy Nuclear Connecticut. Inc.
5000 Dominion Boulevard, Glen Allen. VA 23060 DominionEnergy.com September 16, 2024 Director of the Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 1 DECOMMISSIONING TRUST FUND DISBURSEMENT Dominion
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Energy*
Serial No.24-281 NRA/NDM Rev. 0 Docket No.
50-245 License No. DPR-21 REVISION TO PREVIOUS THIRTY-DAY WRITTEN NOTIFICATION Pursuant to License Condition 2.C(6)(c) of the Millstone Power Station Unit 1 (MPS1)
Facility Operating License, the Decommissioning Trust Agreements for MPS1 include requirements for written notice to the Nuclear Regulatory Commission (NRC) related to payments or disbursements from the decommissioning trust fund. Specifically, written notice must be made to the Director of the Office of Nuclear Reactor Regulation at least 30 days before the Trustee makes payments or disbursements, other than for ordinary administrative expenses from the decommissioning trust fund. The Decommissioning Trust Agreements further require that no payments or disbursements be made from the decommissioning trust fund if prior written notice of objection is received from the NRC.
On November 30, 2020, Dominion Energy Nuclear Connecticut, Inc. (DENG) submitted a written trust fund disbursement notification (ML20336A104) intended to cover expected, non-administrative expenses for MPS1 for the period from 2021 through 2025. In that submittal, DENC discussed projected annual costs for modified SAFSTOR, spent fuel management and additional activities of "approximately $5.9 million in 2021, $5.3 million in 2022, $6.3 million in 2023, $5.3 million in 2024, and $5.3 million in 2025 (in 2020 dollars)." The higher costs in 2021 were explained as "attributable predominantly to the Turbine Building Crane Main Hook maintenance project" The higher costs in 2023 were attributable predominantly to "BADGER testing and removal of the deenergized 345kv transmission line."
On September 29, 2022, DENG submitted a follow-up written trust fund disbursement notification (ML22272A549) intended to revise expected, non-administrative expenses for MPS1 for the period from 2022 through 2025. In that submittal, DENC reported that exposure to weather is causing hazardous conditions both inside and on the roofs. The frequency at which roof repairs are required have been increasing over recent years.
Therefore, DENC updated the projected spending (in 2022 dollars) to approximately $6.5 million in 2022, $8.8 million in 2023, and $5.7 million in 2024 and 2025. To summarize, the projected values were assumed to escalate by approximately 3.65% per year (representing the average expected Consumer Price Index rate during the 2022 - 2025
Serial No.: 24-281 Docket No. 50-245 Page 2 of 3 period).
The increase in expenditures for 2022 and 2023 was attributable to the replacement of the Maintenance Garage roof ($0.7 million in 2022) and replacement of the Reactor Building roof ($1.9 million in 2023).
In 2024, an analysis of security costs associated with MPS1 determined that existing expenditures do not accurately reflect the actual level of security support required. To properly reflect actual security costs, DENC is providing notice that additional funding is necessary to correct the funding shortage associated with security protection of MPS1.
An additional annual amount of $2.3M in 2024 dollars is estimated based on the level of security support required for a total annual amount of $3.6M spent on security.
As reported in DENC's most recent decommissioning funding status report, dated March 26, 2024 (Serial No.24-100, ML24088A235), the costs for modified SAFSTOR, spent fuel management, roof repair, and additional activities will be approximately $8.5 million in 2024. The revised amounts include the additional amount of $2.3M in security funding which are $10.BM for 2024 and $8.4M for 2025 (in 2024 dollars). Costs in 2025 are expected to escalate at a rate of 2.50%, which is the forecasted Consumer Price Index (CPI).
The MPS1 decommissioning funding analysis, which was provided in Attachment 1 of the decommissioning funding status report submitted on March 26, 2024, demonstrated that the MPS1 decommissioning trust fund is adequate to complete decommissioning (with over $425 million in 2024 dollars remaining in the fund upon completion of decommissioning). The MPS1 decommissioning funding analysis includes spent fuel storage costs, which are included in the site-specific cost estimate on which the analysis is based. The proposed disbursements are greater than the expenditures estimated in the 2024 MPS 1 decommissioning funding analysis, but the variance is very small compared to the projected excess and does not have a material effect on the decommissioning funding analysis. The proposed disbursements will not reduce the decommissioning trust fund below levels required for completion of decommissioning.
This letter provides the required written notice pursuant to License Condition 2.C(6)(c) of the MPS1 Facility Operating License and by Section 4.01 of the MPS1 Decommissioning Trust Agreements, for the period from the date of this submittal through the end of 2025.
DENG intends to provide written direction to the Trustee with respect to the disbursement of funds no sooner than 30 days from the date of this letter, unless DENC or the Trustee receives written notice of objection from the NRC. Such prior written notice should be directed to:
James E. Holloway Vice President - Nuclear Engineering &
Fleet Support Dominion Energy Nuclear Connecticut, Inc.
5000 Dominion Boulevard Glen Allen, VA. 23060
Serial No.: 24-281 Docket No. 50-245 Page 3 of 3 If you have any questions or require additional information, please contact Mr. Shayan Sinha at (804) 273-4687.
Sincerely, James E. Holloway Vice President - Nuclear Engineering and Fleet Support Dominion Energy Nuclear Connecticut, Inc.
Commitments made in this letter: None.
cc:
Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road, Suite 102 King of Prussia, PA 19406-1415 T. E. Hood Decommissioning Project Manager (MPS Unit 1)
U.S. Nuclear Regulatory Commission Two White Flint North, Mail Stop A 1 OM 11545 Rockville Pike Rockville, MD 20852-2738 NRG Senior Resident Inspector U.S. Nuclear Regulatory Commission, Region I 475 Allendale Road, Suite 102 King of Prussia, PA 19406-1415 Stephen Gordo Stephen. Cordo@bnymellon.com Service Director Team Lead Asset Servicing Client Experience BNY Mellon 135 Santilli Highway Everett, MA 02149