PLA-7761, Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan, Updated (PLA-7761)

Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan, Updated (PLA-7761)

ML18347B515
Person / Time
Site:	Susquehanna
Issue date:	12/13/2018
From:	Cimorelli K Susquehanna, Talen Energy
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
PLA-7761
Download: ML18347B515 (13)

Text

Kevin Cimorelli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 TALEN~

ENERGY Tel. 570.542.3795 Fax 570.542.1504 Kevin.Cimorelli@TalenEnergy.com DEC 1 3 2018 U. S. Nuclear Regulatory Commission 10 CFR 50.75 Attn: Document Control Desk 10 CFR 72.30 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) DECOMMISSIONING FUNDING PLAN, UPDATED Docket No. 50-387, 50-388 PLA-7761 and 72-28 Susquehanna Nuclear, LLC is submitting the enclosed updated Decommissioning Funding Plan for the Independent Spent Fuel Storage Installation (ISFSI) in accordance with 10 CFR 72.30(b). Enclosure 1 addresses each ofthe six criteria contained in 10 CFR 72.30(b) and references Enclosure 2, which provides details concerning the ISFSI decommissioning cost estimate that was prepared by TLG Services, Inc. This update is required under 10 CFR 72.30(c) for the ISFSI Decommissioning Cost Estimate.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Jason Jennings, Manager- Nuclear Regulatory Affairs at (570) 542-3155.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: : Decommissioning Funding Plan : 10 CFR 72.30 ISFSI Decommissioning Cost Estimate Copy: NRC Region I Ms. T. E. Hood, NRC Project Manager Ms. L. H. Micewski, NRC Sr. Resident Inspector Mr. M. Shields, PA DEP/BRP

Enclosure 1 to PLA-7761 Decommissioning Funding Plan

Susquehanna Nuclear, LLC PLA-7761; Enclosure 1 Susquehanna Steam Electric Station ISFSI Page 1 of2 Decommissioning Funding Plan 10 CFR 72.30(b) requires each holder of, or applicant for, a license under Part 72 to submit for NRC review and approval a decommissioning funding plan (DFP). Susquehanna Nuclear, LLC provides the following information required by 10 CFR 72.30(b) to be included in the DFP:

Requirement 1:

"(1) Information on how reasonable assurance will be provided thatfimds will be available to decommission the ISFSI or MRS. "

Information for Requirement 1:

Pursuant to 10 CFR 72.30(e)(5), Susquehanna Steam Electric Station is a power reactor licensee under 10 CFR 50, the methods of 10 CFR 50.75(b), (e), and (h) are utilized to provide financial assurance associated with its 90 percent ownership of the Independent Spent Fuel Storage Installation (ISFSI). As shown below, the prepaid funds in the decommissioning trusts for Susquehanna Units 1 and 2 exceed, with credited earnings, the amount required by the NRC for radiological decommissioning of the Units and the ISFSI decommissioning cost estimate combined.

Requirement 2:

(2) A detailed cost estimate for decommissioning, in an amount reflecting:

(i) The cost of an independent contractor to perform all decommissioning activities; (ii) An adequate contingency factor; and.

(iii) The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of§ 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.

Information for Requirement 2:

This information is included in the report in Enclosure 2.

Requirement 3:

(3) Identification of and justification for using the key assumptions contained in the DCE.

Information for Requirement 3:

This information is included in the report in Enclosure 2.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 1 Susquehanna Steam Electric Station ISFSI Page 2 of2 Requirement 4:

(4) A description of the method of assuringfimdsfor decommissioningfi*om paragraph (e) of this section, including means for adjusting cost estimates and associated fimding levels periodically over the life of the facility.

Information for Requirement 4:

Susquehanna Nuclear, LLC uses the prepayment method of assuring funds for decommissioning.

As reported in the most recent Decommissioning Funding Status Report (PLA-7584 dated March 30, 2017), the market value of the decommissioning trusts as of December 31, 2016, were

$488,857,613 and $544,458,258 for Susquehanna Units 1 and 2 respectively. When 2 percent real earnings are credited up to the times of permanent termination of operations, along with a pro-rata credit during a dismantlement period, as permitted by 10 CFR § 50.75(e)(l)(i), these amounts have a credited value of$962,238,726 and $1,109,557,525 respectively. The amount of surplus in these trusts ($871 ,619,251 combined) is more than sufficient to fund the estimated ISFSI decommissioning cost ($21.696 million). The decommissioning cost estimate will be adjusted as necessary every three years, as required by 10 CFR 72.30(c). Susquehanna Nuclear, LLC annually adjusts its 90 percent share of the amount of financial assurance required by 10 CFR 50.75(b) in accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50.75(£)(3) and (5) at or about five years prior to the projected end of reactor operations.

Requirement 5:

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

Information for Requirement 5:

This infmmation is included in the report in Enclosure 2.

Requirement 6:

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Information for Requirement 6:

Susquehanna Nuclear, LLC, hereby certifies that financial assurance for the estimated cost of decommissioning the Susquehanna ISFSI has been provided as discussed above.

Enclosure 2 to PLA-7761 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 1 of 8 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,Pl 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 Susquehanna Steam Electric Station (Susquehanna) 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 CPR 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 licenses for the two Susquehanna units are currently set to expire on July 17, 2042 and March 23, 2044, respectively. Approximately 18,656 spent fuel assemblies are curr-ently projected to be generated as a result of plant operations through the license expiration dates. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and spent fuel transferr-ed to dry storage modules located on the ISFSI, to support continued plant operations. It is likely, based upon the curr-ent projection of the DOE's ability to remove spent fuel fi:om the site, that the cunent ISFSI will be expanded to suppmt continued 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 TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 2 of8 operations and decommissioning. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2l).

All spent fuel for the entire operating life of the plant is expected to be packaged in dry storage containers (DSCs ), including spent fuel assemblies in the spent fuel pool at the time of final shutdown. Transferring the spent fuel from the pools to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas or result in reduced operating expenses should the station be placed into a SAFSTOR dormancy configuration.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. However, with no progress by DOE in the removal of spent fuel from commercial generating sites, Susquehanna Nuclear's cunent spent fuel management plan, for purposes of this analysis, assumes "just-in-time" acceptance, i.e.,

the DOE will be able to complete the transfer of spent fuel so as not to impede a deferred decommissioning scenario (SAFSTOR) and the tmmination of the operating licenses within the required 60 year period (from the cessation of operations). To achieve this objective, based upon the oldest fuel receiving the highest priority,[3l and an annual maximum rate oftransfer of3,000 metric tons ofuranium/year,[4l DOE would commence pickup of spent fuel from Susquehanna by 2075, with the completion of spent fuel receipt by year 2094.

Susquehanna Nuclear's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process to DOE the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative). In this estimate the ISFSI decommissioning is considered an independent project, regardless ofthe decommissioning alternative identified for the nuclear power plant.

2 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

U.S. Code of Federal Regulations, Title 10, Patt 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 HL W at the DOE repository. This priority ranking shall be based on the age of SNF and/or HL W 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 ... "

4 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004.

TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 3 of8

4. ISFSI Description The design and capacity of the Susquehanna ISFSI is based upon a NUHOMS dry storage system. The NUHOMS system is comprised of a dry storage canister (DSC),

with either a 52 or 61 spent fuel assembly capacity, and a horizontal storage module (HSM), Model 102. The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-induced activation of steel components as a result ofthe long-term storage of the spent fuel. The cost to dispose of material with residual radioactivity, and verify that the remaining facility and su11'ounding environs meet the NRC's radiological limits established for umestricted use, form the basis of the ISFSI decommissioning estimate.

Susquehanna Nuclear's current spent fuel management plan for the Susquehanna spent fuel would result in approximately 310 HSMs (27 DSCs containing 52 assemblies each and 283 DSCs containing a nominal 61 assemblies per DSC) being in position on the storage pad at the site after all spent fuel has been removed from the spent fuel pools.

This represents 100% of the total spent fuel projected to be generated during the currently licensed operating period.

In addition to the spent fuel HSMs located on the ISFSI pad after shutdown there are projected to be additional HSMs that are expected to be used for Greater-than-Class-C (GTCC) storage. The HSMs used for the GTCC canisters (estimated quantity of 6 per unit) are not expected to have any interior contamination or residual activation ~nd 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.

5. Key Assumptions I 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 Susquehanna units operating until the end of their current licenses, July 17, 2042 and March 23, 2044, respectively, and the assumptions associated with DOE's spent fuel acceptance, as previously described.

For purposes of this analysis the cu11'ent pad (221 feet by 224 feet) will be expanded to accommodate the 322 modules (including the 12 modules for storing GTCC).

The dry storage vendor, Transnuclear, Inc., does not expect the horizontal storage 3 modules to have any interior or exterior radioactive surface contamination. [S] Any neutron 5

Updated Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Transnuclear Inc., NUH-003, Rev. 14, at page 3.5-1 TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 4 of8 activation ofthe steel and concrete is expected to be extremely small.[61 This assumption is adopted for this analysis.

The decommissioning estimate is based on the premise that some of the DSC support stmcture within some of the HSMs will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 26 of the 310 HSMs are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number ofDSCs required for the final core off-load (i.e., 764 of:floaded assemblies/unit, 61 assemblies per DSC) which results in a total of 13 HSMs/unit or 26 total that contain residual radioactivity. It is assumed that these are the final HSMs of:floaded; consequently they have the least time for radioactive decay of the neutron activation products.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad. Therefore, it is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

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

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 Constmction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions that are expected to be provided locally, are consistent with fully burdened contractor labor rates used in the most recently developed Susquehanna decommissioning cost estimate, escalated to 2018 dollars. Susquehanna Nuclear, as licensee, will oversee the site activities; the estimate includes Susquehanna Nuclear's labor and overhead costs.

Low-level radioactive waste packaging, transpmi and disposal costs are based on rates consistent with the most recently developed decommissioning cost estimate (year 2017 dollars), escalated to 2018 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.[81 6

Ibid. at page 9.6-1 Susquehanna Radiation Protection Manager "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office ofNuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision I, February 2012 TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 5 of8 Costs are repmied in 2018 dollars and based upon a decommissioning analysis prepared for Susquehanna in 2017. Activity costs originally repmied in 2017 dollars have been escalated to 2018 dollars using the Consumer Price Index, Services. [91 The estimate is limited to costs necessary to terminate the ISFSI' s NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30 (c) (1)- (4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications in the past three years that affect the decommissioning cost estimate.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost 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 HSMs are characterized and the specifications and work procedures for the decontamination developed.

• The remediation phase - material with residual radioactivity is removed, packaged in cetiified waste containers, transpmied to the low-level waste site, and disposed of at 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 to perform the verification survey), Susquehanna Nuclear's oversight staff, site security (industrial),

and other site operating costs.

9 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUROOOOSAS TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-77 61; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 6 of8 For estimating purposes it is conservatively assumed that all expenditures will be incuned in the year 2095, the year following all spent fuel removal.

TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 7 of8 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft) Residual Radioactivity Current ISFSI Paci (nominal dimensions) 221 224 No ISFSI Horizontal Storage Module -Model 202 Item Value Notes (all dimensions are nominal)

Outside Height (inches) 222 Without vent cover Outside Length (inches) 248 Without shield walls Outside Width (inches) 116 Without shield walls Quantity (total) 322 Spent Fuel (31 0) + GTCC (12)

Equivalent to the number ofHSMs used Quantity (with residual radioactivity) 26 to store last complete core offload)

Low-Level Radioactive Waste 68,878 cubic feet Low-Level Radioactive Waste (packaged density) 119 Average weight density (lbs/cf)

Other Potentially Impacted Items Item Value Notes Number ofHSMs used for GTCC storage 12 No residual radioactivity TLG Services, Inc.

Susquehanna Nuclear, LLC PLA-7761; Enclosure 2 Susquehanna Steam Electric Station ISFSI Page 8 of8 Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Burial Volume (thousands, 2018 dollars) (Class A) Person-Hours Oversight and Removal Packaging Transport Disposal Other Total Cubic Feet Craft Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 529 529 - - 1,624 Decontamination (activated disposition) 160 474 4,378 7,307 12,319 68,878 1,064 -

License Termination (radiological surveys) - - - - 2,770 2,770 - 23,113 -

Subtotal 160 474 4,378 7,307 3,299 15,617 68,878 24,178 1,624 Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 393 393 - - 776 Insurance - - - - 97 97 - - -

Property Tax - - - - 249 249 - - -

Corporate Overhead and Shared Services - - - - 284 284 - - -

Non Labor Overhead - - - - 76 76 - - -

Security (industrial) - - - - 135 135 - - 7,437 Susquehanna Nuclear Oversight Staff - - - - 506 506 - 5,642 Subtotal - - - - 1,740 1,740 - 13,854 Total (w/o contingency) 160 474 4,378 7,307 5,038 17,357 68,878 24,178 15,478 Total (w/25% contingency) 200 593 5,473 9,133 6,298 21,696 Note 1: for funding planning purposes decommissioning costs can be assumed to be incurred in year 2095 TLG Services, Inc.