RA-18-053, Update to Spent Fuel Management Plan

Update to Spent Fuel Management Plan

ML18141A486
Person / Time
Site:	Oyster Creek
Issue date:	05/21/2018
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RA-18-053
Download: ML18141A486 (6)

Text

Michael P. Gallagher Exelon Nuclear Vice President License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.54(bb)

RA-18-053 May 21, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

Subject:

Update to Spent Fuel Management Plan for Oyster Creek Nuclear Generating Station

Reference:

1) Letter from Keith R. Jury, Exelon Generation Company, LLC to U.S.

Nuclear Regulatory Commission - "Permanent Cessation of Operations at Oyster Creek Nuclear Generating Station," dated January 7, 2011 (ML110070507)

2) Letter from James Barstow, Exelon Generation Company, LLC to U.S.

Nuclear Regulatory Commission - "Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan," dated December 30, 2014 (ML14365A067)

3) Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Certification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Power Station,"

dated February 14, 2018 (ML18045A084)

In accordance with 10 CFR 50.54(bb), Exelon Generation Company, LLC (Exelon) is hereby notifying the NRC of significant changes to the Oyster Creek Nuclear Generating Station (OCNGS) Spent Fuel Management Plan (SFMP).

By letter dated January 7, 2011, Exelon informed the U.S. Nuclear Regulatory Commission (NRC) that OCNGS will permanently cease power operations by December 31, 2019 (Reference 1).

Pursuant to 10 CFR 50.54(bb), Exelon submitted the SFMP and Preliminary Decommissioning Cost Estimate to the U.S. Nuclear Regulatory Commission (NRC) on December 30, 2014 (Reference 2).

On February 2, 2018, Exelon announced that it will retire OCNGS in 2018, at the end of the current two-year operating cycle. Exelon informed the NRC of this change in Reference 3. As

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Update Docket Nos. 50-219 and 72-15 May21,2018 Page2 a result of its decision to retire OCNGS one-year earlier, and related changes to the anticipated schedule of decommissioning activities, and spent fuel management activities Exelon is updating the OCNGS SFMP to reflect these changes.

As discussed in 10 CFR 50.54(bb), "Conditions of licenses," paragraph (bb), a licensee shall

"... The licensee shall notify the NRG of any significant changes in the proposed waste management program as described in the initial notification." Accordingly, the Attachment of this submittal includes the significant changes to the Spent Fuel Management Plan for NRC review and preliminary approval.

In accordance with 10 CFR 50.54(bb}, a copy of this notification will be maintained until the expiration of the OCNGS operating license. Additionally, OCNGS will notify the NRC of any other significant changes in the proposed Spent Fuel Management Plan described in the Attachment pursuant to 10 CFR 50.54(bb).

There are no new regulatory commitments contained in this letter.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.

Respectfully,

~*

Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC

Attachment:

Update to Spent Fuel Management Plan for Oyster Creek Nuclear Generating Station cc: w/ Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Update Docket Nos. 50-219 and 72-15 May 21, 2018 Page 3 bcc: w/o Attachment Senior Vice President Mid-Atlantic Operations Site Vice President - Oyster Creek Nuclear Generating Station Vice President - Licensing and Regulatory Affairs Plant Manager - Oyster Creek Nuclear Generating Station Director, Operations - Oyster Creek Nuclear Generating Station Director, Training - Oyster Creek Nuclear Generating Station w/ Attachment Senior Manager, Decommissioning - Cantera Site Decommissioning Director - Oyster Creek Nuclear Generating Station Regulatory Assurance Manager - Oyster Creek Nuclear Generating Station Manager, Licensing and Regulatory Affairs - KSA Licensing Records - KSA Commitment Tracking Coordinator - East

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Update Docket Nos. 50-219 and 72-15 May 21, 2018 Page A-1 of A-3 ATTACHMENT SPENT FUEL MANAGEMENT PLAN (SFMP)

FOR OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS)

1. BACKGROUND Exelon Generation Company, LLC (Exelon) provided notice of its intention to permanently terminate operations at Oyster Creek Nuclear Generating Station (OCNGS) no later than October 31, 2018 (Reference 1).

The decommissioning approach that has been selected by Exelon for OCNGS is the SAFSTOR method.

The decommissioning cost estimate (DCE) for OCNGS was previously provided to the NRC in Reference 2. This estimate assumes a December 31, 2019, permanent shutdown of OCNGS and provides costs in 2016 dollars. The costs herein have been adjusted consistent with the approach outlined in an attachment to the response to an NRC Request for Additional Information (RAI)

(Reference 3) and are quoted in December 31, 2017, dollars.

In order to estimate the costs associated with maintenance of the OCNGS site in SAFSTOR and the eventual decommissioning of the site, at the time of the estimate, Exelon assumed 2025 as the first year that the U.S. Department of Energy (DOE) will begin removing spent nuclear fuel from nuclear power reactor sites. Pursuant to the Nuclear Waste Policy Act (Reference 4), the Federal government has the responsibility to remove all spent fuel from OCNGS and other commercial nuclear power reactor sites. However, the DOE spent fuel and high-level waste management program is currently stalled. Given the status of the DOE program, Exelon considered information made publicly available by DOE, the Government Accountability Office (GAO), the Blue Ribbon Commission on America's Nuclear Future, and the political environment surrounding this issue, and concluded that 2025 was the most likely timeframe for DOE to initiate removal of commercial nuclear fuel from reactor sites.

2. SPENT FUEL MANAGEMENT STRATEGY The NRC requires (as discussed in 10 CFR 50.54(bb)) that licensees establish a program "to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." Pending transfer of the fuel to the DOE [Secretary of Energy], Exelon will store fuel on an interim basis in the spent fuel pool and/or the ISFSI located at the OCNGS site.

A licensed Independent Spent Fuel Storage Installation (ISFSI) is currently operating under a NRC general license at OCNGS. The ISFSI facility will be expanded to accommodate the inventory of spent fuel remaining in the spent fuel pool at the time of permanent shutdown. After the required cooling time, the spent fuel will be loaded in fuel storage canisters and moved to the ISFSI. Once the spent fuel pool is emptied of fuel, the facility will be placed in a SAFSTOR

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Update Docket Nos. 50-219 and 72-15 May 21, 2018 Page A-2 of A-3 condition. The existing ISFSI will continue to operate until the transfer of spent fuel to the DOE is complete.

Assuming the DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority and that the DOE begins removing spent fuel from commercial facilities in 2025 with an annual capacity of 3,000 metric tons of uranium, spent fuel is projected to remain at the OCNGS site for approximately 16 years after the termination of operation (spent fuel is projected to be removed from the OCNGS site by the end of 2034). Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in spent fuel remaining at the site longer than anticipated.

Operation and maintenance costs for the storage facilities (ISFSI and spent fuel pool) are reflected in the OCNGS DCE (Reference 2) and include the costs for staffing the facilities, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to the ISFSI and to decommission the ISFSI.

A discussion of site-specific considerations for the management of spent fuel at OCNGS may be found in Section 3.4.1 of the DCE Report (Reference 2).

When OCNGS terminates operations in 2018, OCNGS will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the OCNGS spent fuel pool and ISFSI, as necessary.

In addition, OCNGS will also comply with applicable license termination requirements in accordance with 10 CFR 50.82, "Termination of license," with respect to plant shutdown and post-shutdown activities, including seeking NRC approvals as appropriate for the continued storage of irradiated fuel until transfer of the fuel to the DOE is complete.

3. COST ESTIMATE AND FUNDING FOR SPENT FUEL MANAGEMENT Annual costs for spent fuel management under the SAFSTOR scenario range from approximately

$5.6 million to $45.0 million with a total cost of $290.1 million (December 31, 2017, dollars).

As of December 31, 2017, the OCNGS decommissioning trust fund balance was $982.1 million.

At this time, there are no annual contributions to the fund and none are anticipated through the decommissioning period. To the extent that the trust fund balance exceeds costs required for radiological decommissioning, trust fund monies (subject to receipt of an exemption), in conjunction with Exelon operating revenues, will be used to pay for spent fuel management costs.

An additional potential source of funding for OCNGS spent fuel management costs is the Settlement Agreement between Exelon and the DOE, under which the United States Government has agreed to reimburse Exelon for costs incurred attributable to DOEs failure to meet its contractual obligations for the transfer of spent fuel from OCNGS and other Exelon nuclear plants (Reference 5).

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Update Docket Nos. 50-219 and 72-15 May 21, 2018 Page A-3 of A-3

4. NRC APPROVALS This SFMP contemplates potential withdrawals from the decommissioning trust for spent fuel management purposes. Prior to any such withdrawals, Exelon will await the granting of the exemption from the requirements of 10 CFR 50.82(a)(8)(i)(A) requested in Reference 6. Exelon will monitor the funding level of the decommissioning fund to ensure that spent fuel management withdrawals will not inhibit the ability of Exelon to complete radiological decommissioning.

5. REFERENCES

1. Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Certification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Power Station," dated February 14, 2018 (ADAMS Accession No. ML18045A084)

2. Letter from James Barstow, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Submittal of Updated Decommissioning Cost Analysis for Oyster Creek Nuclear Generation Station," dated March 30, 2016 (ADAMS Accession No. ML16090A067)

3. Letter from David T. Gudger, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information Regarding Preliminary Decommissioning Cost Estimate," dated April 5, 2016 (ADAMS Accession No. ML16096A397)

4. United States of America Public Law 97-425, "Nuclear Waste Policy Act of 1982," dated January 7, 1983.

5. Settlement Agreement between the U.S. Department of Energy and Exelon Generation Company, LLC (including Commonwealth Edison Company and AmerGen Energy Company), signed and executed August 5, 2004, as amended by the Addendum to the Settlement Agreement signed May 4, 2009.

6. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)," dated March 22, 2018 (ADAMS Accession No. ML18081A201)