ML24345A166
| ML24345A166 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/12/2025 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | |
| Shared Package | |
| ML24345A164 | List: |
| References | |
| EPID L-2024-DFA-0000 | |
| Download: ML24345A166 (1) | |
Text
Enclosure 1 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AMENDED SAFETY EVALUATION REPORT Docket No. 70-1257 License No. SNM-1227 Framatome, Inc.
Triennial Update to Decommissioning Funding Plan
1.0 BACKGROUND
Nuclear facilities licensed under Title 10 of the Code of Federal Regulations (10 CFR),
Part 70, are required to provide adequate financial assurance for decommissioning, decontamination and reclamation pursuant to 10 CFR Section 70.25, Financial Assurance and Recordkeeping for Decommissioning. Framatome, Inc. (Framatome or the licensee) is the holder of Special Nuclear Material License Number SNM-1227. Pursuant to 10 CFR Paragraph 70.25(e)(2), Framatome is required to submit a Decommissioning Funding Plan (DFP) and financial assurance at least every 3 years for the U.S. Nuclear Regulatory Commissions (NRC) review and approval.
By letter dated January 23, 2024, Framatome submitted a triennial update to its DFP for the Framatome Inc. Richland Nuclear Fuel Fabrication facility for the period ending December 31, 2023 (Agencywide Documents Access Management System Accession No. ML24031A543; Cover Letter) and (ML24031A545; 2023 DFP, non-public enclosure). The DFP submittal included a 2023 decommissioning cost estimate (DCE) for the Richland Facility. Subsequently, Framatome identified an internal accounting error and amended its 2023 DFP (ML24250A201),
noting the error to the DCE, on page 5, table 1 (ML24250A202, non-public). The error resulted in Framatome revising the Low-level Radiological Waste (LLRW) Inventory Disposal amount, which reduced the DCE from $11,944,000 to $3,929,000. Accordingly, the Decommissioning Cost Estimate Summary total was also revised with a reduction from $100,928,000 to
$90,908,000 as the result of the revised Low-level Radiological Waste Inventory Disposal Amount and other revised figures included in the Decommissioning Cost Estimate. Prior to reviewing the amended DFP and the revised DCE, the NRC had approved the Framatome 2023 DFP for the Richland Nuclear Fuel Fabrication facility by letter dated November 6, 2024 (ML24297A304).
2.0 REGULATORY REQUIREMENTS As required by 10 CFR 70.25(e)(2), Framatome must continue to submit an updated cost estimate for decommissioning for the NRCs review at intervals not to exceed three years. After resolution of any NRC comments on the estimate, Framatome must submit a signed original of the financial instrument reflecting an amount sufficient to cover the approved cost estimate.
Framatome remains responsible for the decommissioning of the licensed site and facility; will abide by all commitments and representations previously made to the NRC; and abide by all constraints, conditions, requirements, representations, and commitments identified in the license.
2 3.0 REGULATORY GUIDANCE The NRC utilizes NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance Financial Assurance, Recordkeeping, and Timeliness as guidance to evaluate the DFPs submitted by 10 CFR Part 70 licensees.
4.0 NRC STAFF EVALUATION Framatomes previous triennial update DFP for the Richland Nuclear Fuel Fabrication Facility for the period ending December 31, 2020, was submitted on January 28, 2021 (ML21028A752, ML21028A753) and supplemented on June 8, 2021, with a response to a request for additional information (ML21159A159). The NRC staff approved Framatomes 2020 DCE in the amount of
$81,580,000, by letter dated August 12, 2021 (ML21166A200, ML21166A201).
Framatome revised the 2023 DCE in its amended 2023 DFP, dated September 06, 2024 (ML24250A201; ML24250A202, non-public). The revised 2023 DCE is $90,908,000, which is a
$9,328,000 increase over the 2020 DCE. As mentioned in section 1.0 of this safety evaluation report (SER), the amended DFP and the revised DCE were submitted by Framatome due to an accounting error in the 2023 DFP submitted on January 23, 2024 (ML24031A542, ML24031A543). This Amended SER evaluates the corrected information submitted in Framatomes amended 2023 DFP. In its amended 2023 submittal, Framatome stated that the amended DFP and associated DCE had been prepared in accordance with the requirements of 10 CFR 70.25 and the guidance provided in NUREG-1757, Consolidated NMSS Decommissioning Guidance, Volume 3, Rev. 1, February 2012.
In section 2 of the amended 2023 DFP, Framatome provided justification for the key assumptions used in the preparation of the DFP and cost estimate for the decommissioning of their Richland Facility. In table 7 of its revised 2023 DCE, Framatome provided detailed costs for the decommissioning activities of its facility and these costs are based on the billing rates (wages, benefits, overheads, and profits) from third-party contractors based out of the State of Washington. The revised DCE is based on unrestricted use and Framatome used a contingency factor to estimate the total decommissioning costs.
The revision information conformed to the Decommissioning Planning Rule requirement for licensees to consider the effect of eight events, outlined in 10 CFR70.25(e)(2), on DCEs. The NRC staff finds that, in its amended submittal, Framatome considered the effect of these events as follows:
a.
Spills of radioactive material.
Framatome stated, No spills that will impact decommissioning costs have occurred.
The few very minor unplanned contamination events since the last update, but each was cleaned up to release limits and any contaminated soil or asphalt was packaged into waste drums and is accounted for in section 5.3.2.
b.
Waste inventory increases.
Framatome, having indicated there has been an increase in the inventory of waste volume since 2020, increased the DCE from $200,000 to $207,000.
3 c.
Waste disposal costs increase.
Framatome has updated its disposal costs since the 2020 DCE update to reflect recent quotes. The estimated disposal costs are primarily due to increased disposal and labor costs. The waste volume estimates for decommissioning are unchanged.
d.
Facility modifications.
Framatome stated that, since the 2020 DFP update, the Scrap Uranium Recovery Facility Building was constructed to house a replacement of the Gadolinia Scrap Uranium Recovery facility (fuel scrap dissolution and solvent extraction activities) that was previously located in the Engineering Laboratory Operations (ELO) Building. The volume of contaminated piping, duct work and other equipment has not changed since 2020. Sources of significant cost increase include the accumulation of combustible waste since the Solid Waste Uranium Recovery incinerator has not run for several years and the accumulation of noncombustible waste due to repurposing portions of the ELO and Specialty Fuels Buildings. In addition, Framatome indicates significant increases in the cost of Lab samples.
e.
Changes in authorized possession limits.
Framatome stated that there have not been any changes in the authorized possession limits since the last update.
f.
Actual remediation costs that exceed the previous cost estimate.
Framatome stated that some remediation costs have occurred since the last update and as appropriate have been considered.
g.
Onsite disposal.
Framatome stated no onsite disposal has occurred.
h.
Use of a settling pond.
Framatome stated no use of settling ponds has occurred since the last update Framatome also stated that additional soil remediation to meet the NRC radiological decommissioning criteria is not anticipated to be necessary. Based on the information discussed above, the NRC staff finds that Framatomes updated DFP meets the regulatory requirements of 10 CFR 70.25(e). Specifically, Framatome submitted a detailed cost estimate for decommissioning within 3 years of its last approved estimate. In addition, the NRC staff finds that Framatomes DCE provides justification for key assumptions, reflects the cost of an independent contractor to perform decommissioning activities, is based on unrestricted use, and includes an adequate contingency factor. As such, the NRC staff finds Framatomes triennial DFP update acceptable and should be approved.
4 5.0 ENVIRONMENTAL REVIEW This action involves a change to surety requirements. The NRC staff has determined that this action is subject to a categorical exclusion pursuant to 10 CFR § 51.22(c)(10)(i). Therefore, neither an environmental assessment nor an environmental impact statement is required for this action.
6.0 CONCLUSION
Therefore, the NRC concludes that Framatomes revised 2023 DCE of $90,908,000 is reasonable. Framatome must appropriately revise its financial assurance mechanisms and Certification of Financial Assurance and submit them for NRC review within 60 days from the staffs approval date of the 2023 DCE.
The 2023 DCE of $90,908,000 is an increase from the 2020 amount which was $81,580,00.
Based on the above, NRC staff amends the SER to conform with the revisions identified by the licensee.