NRC-14-0050, ISFSI Decommissioning Funding Plan

ISFSI Decommissioning Funding Plan

ML14183B584
Person / Time
Site:	Fermi
Issue date:	07/02/2014
From:	Conner J DTE Energy
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
NRC-14-0050
Download: ML14183B584 (12)

Text

Site'Vice President Te! 734.586.4849 Fa 734.586.5295 10 CFR 72.30 July 2, 2014 NRC-14-0050 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC Letter, "Clarification Regarding the Timing of Submittal of a Decommissioning Funding Plan per Title 10 of the Code of Federal Regulations Section 72.30(b) for Future Independent Spent Fuel Storage Installations," dated August 21, 2013, Accession No. ML13234A559

Subject:

Fermi 2 ISFSI Decommissioning Funding Plan DTE Electric Company has prepared a decommissioning funding plan and cost estimate for the Fermi 2 Independent Spent Fuel Storage Installation (ISFSI) pursuant to 10 CFR 72.30(b). Enclosure 1 provides the Fermi 2 ISFSI decommissioning funding plan.

Enc nsure 2 provides the decommissioning cost estimate for the Fermi 2 ISFSI. The enclosed funding plan and cost estimate contain the information required by 10 CFR 72.30 to provide reasonable assurance that funds will be available to decommission the Fermi 2 ISFSI. The funding plan is provided in advance of the date that the first spent fuel storage cask is used to store spent fuel per 10 CFR 72.212(a)(3), consistent with the clarification received in Reference 2. This letter constitutes certification that financial assurance is provided to cover the estimated costs of ISFSI decommissioning per 10 CFR 72.30(b)(6).

As discussed in Enclosure 1, DTE Electric Company submitted an application for license renewal in April 2014 (ML14121A532). As required by 10 CFR 72.30(c), the decommissioning funding plan will be updated after NRC approval of the license renewal application.

USNRC NRC-14-0050 Page 2 Should you have any questions or require additional information, please contact Lynne Goodman at 734-586-1205.

No new commitments are being made in this submittal.

Sincerely,

Enclosures:

1. Fermi 2 ISFSI Decommissioning Funding Plan

2. Fermi 2 ISFSI Decommissioning Cost Estimate cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

ENCLOSURE 1 TO NRC-14-0050 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2 ISFSI Decommissioning Funding Plan to NRC-14-0050 Page 1 Fermi 2 ISFSI Decommissioning Funding Plan Introduction An Independent Spent Fuel Storage Installation (ISFSI) is a facility that is designed and constructed for the interim storage of spent nuclear fuel. Solid reactor-related greater than Class C (GTCC) waste and other radioactive materials associated with spent fuel and reactor-related GTCC waste storage may also be stored at an ISFSI. The licensing requirements for ISFSI are specified in 10 Code of Federal Regulations (CFR) 72. Subpart 72.30 requires a decommissioning plan that provides reasonable assurance that the decontamination and decommissioning of the ISFSI at the end of its useful life will provide adequate protection to the health and safety of the public. This document provides the information required by 10 CFR 72.30.

DecommissioninQ Funding Plan for Fermi 2 ISFSI A decommissioning funding plan consisting of detailed information is required in 10 CFR 72.30(b). Each of the required items from 10 CFR 72.30(b) are discussed in detail below.

• Requirement 1: Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI A plant-specific decommissioning cost estimate has been prepared for the Fermi 2 ISFSI. The total estimated decommissioning cost is found in Table 2 of Enclosure 2 of this letter. The cost estimate assumes that Fermi 2 will be shut down by March 20, 2025 when the current license expires. The required funding per year is then calculated such that full funding will be available by the end of the current license. The result is approximately $710,000 per year. To achieve this required funding per year, monthly deposits will be made into a separate account for ISFSI decommissioning within the Nuclear Decommissioning Trust Fund (NDT) for Fermi 2. The amount deposited per month is based on electricity sales and will vary from month to month. The performance of the ISFSI account within the NDT Fund will be evaluated periodically and deposits adjusted as appropriate. A report will be submitted to the NRC at least once every three years to address the adequacy of the ISFSI decommissioning funding (see discussion of 10 CFR 72.30(c) below). In addition, in April 2014, DTE Electric Company submitted an application for renewing the Fermi 2 license (ML14121A532). The application is currently under review by the NRC staff. After the renewed license is granted, the ISFSI decommissioning funding plan will be reassessed. At that time, a revised ISFSI decommissioning funding plan will be submitted to the NRC (see discussion of 10 CFR 72.30(c) below).

" Requirement 2: Detailed cost estimate for decommissioning A detailed plant-specific decommissioning cost estimate has been prepared for the Fermi 2 ISFSI. It includes cost of an independent contractor performing all decommissioning activities, an adequate contingency factor, and the cost of meeting 10 CFR 20.1402 for license termination for unrestricted use. The Fermi 2 ISFSI decommissioning cost estimate is provided in Enclosure 2 to this letter.

e Requirement 3: Identification of and justification for using the key assumptions contained in-h decommissioning cost estimate

Enclosure 1 to NRC-14-0050 Page 2 The decommissioning cost estimate key assumptions and their justifications are provided in the plant-specific decommissioning cost estimate for the Fermi 2 ISFSI. See Enclosure 2 to this letter.

" Requirement 4: Description of the method of assuring funds for decommissioning, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility DTE Electric Company is a licensee under 10 CFR 50 and a regulated electric utility.

Therefore, as allowed per 10 CFR 72.30(e)(5), the methods of 10 CFR 50.75(e) may be used. Specifically, the Fermi 2 ISFSI decommissioning funding plan utilizes an external sinking fund as described in 10 CFR 50.75(e)(1)(ii)(A) and (B). As approved by the Michigan Public Service Commission (MPSC), the Fermi 2 ISFSI decommissioning funding is collected from customers in rates and fees. The calculation for funding required per year assumes net earnings of 1%. This is consistent with assumptions used in DTE Electric Company's rate case submitted to the MPSC and is conservative compared to the 2% assumption allowed in 10 CFR 50.75. The funds for ISFSI decommissioning are being placed in a separate account in the Fermi 2 NDT Fund. The first deposit to the account was made in June 2014 based on decommissioning collections from May 2014. The State Street Bank and Trust Company is the current trustee.

" Requirement 5: Volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination The decommissioning cost estimate assumptions for material that will need to be remediated and the volume of waste are provided in the plant-specific decommissioning cost estimate for the Fermi 2 ISFSI (Enclosure 2 to this letter).

" Requirement 6: Certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning This signed letter provides certification that DTE Electric Company will provide financial assurance for decommissioning the Fermi 2 ISFSI in the amount indicated in Table 2 of Enclosure 2 of the letter. In addition, DTE Electric Company has already begun to make the monthly deposits as described above.

Updates to Decommissioning Funding Plan for Fermi 2 ISFSI Updates to the decommissioning funding plan are required per 10 CFR 72.30(c). The Fermi 2 ISFSI decommissioning funding plan will be updated and submitted at intervals not to exceed 3 years. The updates will consider the effect of potential events such as spills of radioactive material producing additional residual radioactivity in onsite subsurface material, facility modifications, changes in authorized possession limits, and actual remediation costs that exceed the previous cost estimate. In addition to these recurring updates, 10 CFR 72.30(c) also requires an update to be submitted at the time of license renewal. In April 2014, DTE Electric Company submitted an application for renewing the Fermi 2 license (ML14121A532) and the application is currently under review by the NRC staff. After the renewed license is granted, the ISFSI decommissioning funding plan will be reassessed to take into account the period of extended operation and will be resubmitted to the NRC.

ENCLOSURE 2 TO NRC-14-0050 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2 ISFSI Decommissioning Cost Estimate

DTE Energy D02-1687-14003; Attachment 1 Fermi 2 Nuclear Power Plant ISFSI - 2025 Shutdown Page 1 of 6 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

Subpart 72.30, Financial assurance and recordkeeping for decommissioning, requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Fermi 2 Nuclear Power Plant (Fermi 2) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2. Spent Fuel Management Strategy The operating license for Fermi 2 is currently set to expire on March 20, 2025. For planning purposes it is projected that up to 64 spent fuel storage casks are required to store approximately 4,352 assemblies. The ISFSI is operated under a Part 50 General License.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the 1

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

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DTE Energy D02-1687-14003; Attachment 1 Fermi 2 Nuclear Power Plant ISFSI - 2025 Shutdown Page 2 of 6 reactor.[2] DTE Energys current spent fuel management plan for the Fermi 2 spent fuel is based in general upon completion of spent fuel receipt by no later than year 2045.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The Fermi 2 ISFSI uses a Holtec International (Holtec) HI-STORM 100 dry storage system (nominal 68 assemblies per cask). The HI-STORM 100 is comprised of a multi-purpose canister (MPC) and storage overpack. The multi-purpose canisters are assumed to be transferred directly to the DOE and not returned to the station. The remaining overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRCs radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

In addition to the spent fuel casks located on the ISFSI pad after shutdown there may be additional casks used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

2 U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as TLG Services, Inc.

DTE Energy D02-1687-14003; Attachment 1 Fermi 2 Nuclear Power Plant ISFSI - 2025 Shutdown Page 3 of 6

5. Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the unit operating until the end of its current license, March 20, 2025, and the assumptions associated with DOEs spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is expected to be approximately 141 feet in width, and 141 feet in length.

It is not expected that the overpacks will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for characterization of 10% of the overpacks; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate conservatively assumes that 12 overpacks (equivalent to the number of casks to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. For purposes of this estimate, the overpacks are designated for controlled disposal as low-level radioactive waste.

It is assumed that a small amount of residual contamination will be present at the in-ground cask transfer facility and the lifting cable assemblies of the HI-TRAC vertical cask transporter at the time of decommissioning. It is not expected that there will be any residual contamination left on the concrete ISFSI pad, or other facilities at the Fermi 2 ISFSI, including the ISFSI fabrication pad. It is expected that these assumptions would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that only the in-ground cask transfer facility and certain components of the HI-TRAC transporter will be contaminated. As such, only verification surveys are included for the other facilities in the decommissioning estimate.

There is no known [3] subsurface material (soil contamination) in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the concrete 3

Email Lynne Goodman to Francis Seymore, April 30, 2014.

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DTE Energy D02-1687-14003; Attachment 1 Fermi 2 Nuclear Power Plant ISFSI - 2025 Shutdown Page 4 of 6 overpack surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad, and the other ISFSI structures.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions are expected to be provided locally. DTE Energy, as licensee, will oversee the site activities; the estimate includes DTE Energys labor and overhead costs.

Low-level radioactive waste packaging and transport costs are based on industry data.

Disposal costs are based on DTE Energys existing contracted disposal rates.

Costs are reported in 2014 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[4]

The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

An initial planning phase - empty overpacks are characterized and the specifications and work procedures for the decontamination (liner removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of as low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), DTE Energys oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2045, the year following all spent fuel removal.

4 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S.

Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

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DTE Energy D02-1687-14003; Attachment 1 Fermi 2 Nuclear Power Plant ISFSI - 2025 Shutdown Page 5 of 6 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft) Width (ft) Radioactivity ISFSI Pad (dimensions are for current pad) 141 141 No ISFSI Pad Expansion (dimensions are for expansion)

ISFSI Overpack Item Value Notes (all dimensions are nominal)

Overall Height (inches) 224 Dimensions are nominal Outside Diameter (inches) 133.90 Main cylindrical body of overpack Inside Diameter (inches) 73.50 Dimensions are nominal Inner Liner Thickness (inches) 1.25 Dimensions are nominal Quantity (total) 64 Quantity (with residual radioactivity) 12 Equivalent to the number of overpacks used to store last complete core offload Total Surface Area of Overpack Inner Liner with Residual Radioactivity (square feet) 4,467 Low-Level Radioactive Waste (cubic feet) 25,078 Low-Level Radioactive Waste (packaged density) 82 Other Potentially Impacted Items Item Value Notes In-Ground Cask Transfer Facility 1 Small amount of residual activity HI-TRAC Vertical Cask Transporter 1 Small amount of residual activity ISFSI Equipment Storage Building 1 No residual radioactivity Number of Overpacks used for GTCC storage 4 No residual radioactivity TLG Services, Inc.

DTE Energy D02-1687-14003; Attachment 1 Fermi 2 Nuclear Power Plant ISFSI - 2025 Shutdown Page 6 of 6 Table 2 ISFSI Decommissioning Costs1 and Waste Volumes (Thousands, 2014 dollars) Person-Hours Waste Oversight Volume and Decon Removal Packaging Transport Disposal Other Total (ft3) Craft Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 272.6 272.6 1,072.0 Remediation (activated liner removal) 262.0 314.4 549.8 2,505.1 17.1 3,648.4 25,051.0 2,807.6 Remediation (Cask Transfer Facility / HI-TRAC Vertical Transporter) 9.5 19.2 5.0 21.7 21.7 1.9 79.0 217.0 441.5 License Termination (radiological surveys) 1,299.2 1,299.2 10,598.0 Subtotal 9.5 281.2 319.4 571.5 2,526.8 1,590.8 5,299.2 25,268.0 13,847.1 1,072.0 Supporting Costs NRC and NRC Contractor Fees and Costs 383.7 383.7 776.0 Insurance 103.0 103.0 Energy Budget 63.0 63.0 Corporate A&G 204.2 204.2 Security (industrial) 161.1 161.1 4,252.7 DTE Energy Oversight Staff 176.7 176.7 3,226.2 Subtotal 1,091.6 1,091.6 8,254.8 Total (w/o contingency) 9.5 281.2 319.4 571.5 2,526.8 2,682.4 6,390.8 25,268.0 13,847.1 9,326.8 Total (w/25% contingency) 11.9 351.5 399.3 714.4 3,158.5 3,353.0 7,988.5 Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2045 TLG Services, Inc.