ML25254A223
| ML25254A223 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/11/2025 |
| From: | James Holloway Dominion Energy Nuclear Connecticut |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 25-058A | |
| Download: ML25254A223 (1) | |
Text
Dominion Energy Nuclear Connecticut, Inc.
5000 Dominion Boulevard, Glen Allen, VA, 23060 DominionEnergy.com United States Nuclear Regulatory Commission Serial No.: 25-058A Attention: Document Control Desk NRA/JHH:
R0 Washington, D. C. 20555-0001 Docket No.: 50-245 License No.: DPR-21 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE SUBMITTAL AND REQUEST FOR APPROVAL OF DECOMMISSIONING FUNDING STATUS REPORT REVIEW In Reference 1, Dominion Energy Nuclear Connecticut, Inc. (DENC) provided a report on the status of decommissioning funding for Millstone Power Station Unit 1 (MPS1),
pursuant to 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)-(vii).
In Reference 2, the Nuclear Regulatory Commission (NRC) provided a Request for Additional Information (RAI) on the subject submittal (Reference 1), via email dated August 12, 2025. The NRC staff reviewed the information provided and determined that additional information is required to complete its review. A response is expected by the NRC within 30 days from the date of the email, September 11, 2025. The NRC RAI and the associated DENC response are provided in the attachment.
Please contact Julie Hough at (804) 273-3586 if you have any questions or require additional information.
Sincerely, James E. Holloway Vice President - Nuclear Engineering and Fleet Support Dominion Energy Nuclear Connecticut, Inc.
References:
- 1.
Letter from J. Holloway (DENC) to U.S. Nuclear Regulatory Commission (NRC), Dominion Energy Nuclear Connecticut, Inc, Millstone Power Station Unit 1 Decommissioning Funding Status Report, dated March 26, 2025. (ADAMS Accession No. ML25093A222)
Serial No.: 25-058A Docket No.: 50-245 Page 2 of 2 2.
Email from T. Hood (NRC) to J. Holloway (DENC), Millstone Unit 1 - Annual Decommissioning Funding Report Requested Additional Information, dated August 12, 2025.
Attachment:
Response for Additional Information Related to Submittal and Request for Approval of Decommissioning Funding Status Report Review, Millstone Power Station Unit 1.
Commitments made in this letter: None cc: U. S. Nuclear Regulatory Commission Region I Tanya Hood NRC Project Manager - Millstone Power Station, Unit 1
Serial No.: 25-058A Docket No.: 50-245 Attachment Response to NRC Request for Additional Information Related to Submittal and Request for Approval of Decommissioning Funding Status Report Review Millstone Power Station - Unit 1 Dominion Energy Nuclear Connecticut, Inc. (DENC)
Serial No.: 25-058A Docket No.: 50-245 Attachment, page 1 of 3 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Decommissioning Funding Status Report Review Millstone Power Station Unit 1 By letter dated March 26, 2025 (Agencywide Documents Access and Management System Accession No. ML25093A222), Dominion Energy Nuclear Connecticut, Inc.
(licensee), submitted its annual report on the status of decommissioning funding for Millstone Power Station Unit 1 (Millstone Unit 1). The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information submitted and determined that additional information is required to complete its review. The NRC RAI and the associated DENC response are provided in the attachment.
RAI 1: Decommissioning Cost Increases Basis:
The regulations at 10 CFR 50.82(a)(7) require, in part, that licensees, prior to making any significant changes from those actions and schedules described in the post-shutdown decommissioning activities report (PSDAR), shall notify the NRC in writing, with a copy sent to the affected States(s), including changes that significantly increase the decommissioning cost.
Issue:
The March 2025 report presented license termination cost estimates that are 46% higher than those reflected in the 2024 report (ML24088A235). The 2025 report also presented spent fuel management cost estimates that are 94.7% higher than those reflected in the 2024 report.
Request:
Based on information presented in the 2025 Decommissioning Trust Fund Status Report, has the licensee notified the NRC, in writing, and notified the affected State(s), before making any significant schedule change from, the actions and schedules described in the current PSDAR, including the changes that significantly increased the decommissioning cost?
DENC Response to RAI Question No. 1:
There have been no significant changes from the actions and schedules outlined in the MPS1 PSDAR since submittal of the 2024 filing (Reference 1). The 2024 filing assumed that MPS1 would be decommissioned concurrent with MPS2 and MPS3. However, DENC notified the NRC of their intent to submit subsequent license renewal applications for MPS2 and MPS3 in Reference 2. The extension of commercial operations for MPS2
Serial No.: 25-058A Docket No.: 50-245, Page 2 of 3 and MPS3 would delay their decommissioning, resulting in lost license termination cost efficiencies and an overall increase in decommissioning costs for MPS1. These cost impacts are reflected in the 2025 filing (Reference 3) but are due to changes to the MPS2 and MPS3 decommissioning schedules versus changes to the MPS1 decommissioning cost and schedule.
The increase in spent fuel management costs is attributed to increased cost for security guards and an extended fuel campaign duration. As detailed in Reference 4, DENC notified the NRC of the increase in security guard costs. The assumed duration of the fuel campaign was increased from 3.5 years in the 2024 filing to 7.5 years in the 2025 filing due to a changed assumption for Department of Energy (DOE) spent fuel pickup from 2035 to 2040, which resulted in a corresponding cost increase.
RAI 2: Decommissioning Beyond 60 years Basis:
The regulations in 10 CFR 50.82(a)(7) require the licensee to notify the NRC, in writing with a copy to the affected States, before it performs any significant decommissioning activity that could be considered inconsistent with, or a significant schedule change from, the planned decommissioning activities or schedules described in the PSDAR. The regulation at 10 CFR 50.82(a)(3) requires power reactor licensees to complete decommissioning within 60 years of permanent cessation of operations.
Issue:
The March 2025 report presented a final year end of decommissioning date of 2099, 41 years beyond the final year license termination date of 2058.
Request:
Based on the 2025 Decommissioning Trust Fund Status Report, has the licensee requested an exemption for an extension, or does the licensee anticipate requesting an exemption for an extension, from the NRC, of the 60-year decommissioning completion requirement found in 10 CFR 50.82(a)(3)?
DENC Response to RAI Question No. 2:
The decommissioning funding cash flow analysis provided in Reference 3 does not assume that DENC will request an exemption from the 60-year decommissioning requirement found in 10 CFR 50.82(a)(3) or take any credit for such an exemption. The analysis anticipates that the unit will be fully decommissioned in 2058 and thus released from the 10 CFR 50.82(a)(3) license. Following completion of MPS1 decommissioning in 2058, DENC will maintain an ISFSI license under 10 CFR Part 72. The costs shown in Reference 3, Table II, Column 3 for the year 2099 are for anticipated pickup of Greater-Than-Class C waste by the DOE.
Serial No.: 25-058A Docket No.: 50-245, Page 3 of 3
References:
- 1. Letter from J. Holloway to NRC, Dominion Energy Nuclear Connecticut, Inc.,
Millstone Power Station Unit 1, Decommissioning Funding Status Report, dated March 26, 2024 (ADAMS Accession No. ML24088A235).
- 2. Letter from J. Holloway to NRC, Dominion Energy Nuclear Connecticut, Inc.,
Millstone Power Station Units 2 and 3, Intent to Pursue Subsequent License Renewal, dated December 20, 2023 (ADAMS Accession No. ML23361A031).
- 3. Letter from J. Holloway to NRC, Dominion Energy Nuclear Connecticut, Inc.,
Millstone Power Station Unit 1, Decommissioning Funding Status Report, dated March 26, 2025 (ADAMS Accession No. ML25093A222).
- 4. Letter from J. Holloway to NRC, Dominion Energy Nuclear Connecticut, Inc.,
Millstone Power Station Unit 1, Decommissioning Trust Fund Disbursement, Revision to Previous Thirty-Day Written Notification dated September 16, 2024 (ADAMS Accession No. ML24260A219).