RS-10-034, Response to Request for Additional Information Regarding Decommissioning Financial Assurance Plans

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Response to Request for Additional Information Regarding Decommissioning Financial Assurance Plans
ML100480006
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 02/15/2010
From: Simpson P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-10-034
Download: ML100480006 (5)


Text

Exelon Nuclear 4300 Winfield Road Nuclear Warrenville, l L 60555 10 CFR 50.75(f)(I)

February 15,2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Response to Request for Additional Information Regarding Decommissioning Financial Assurance Plans

References:

1. Letter from Keith R. Jury (Exelon Generation Company, LLC) to U.S. NRC, "Decommissioning Funding Assurance Plan," dated July 29, 2009
2. Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional lnformation Regarding Decommissioning Financial Assurance Plans," dated October 27, 2009
3. Letter from Christopher Gratton (U.S. NRC) to Charles G. Pardee (Exelon Generation Company, LLC), "Request for Additional lnformation Re: Decommissioning Financial Assurance Plans,"

dated January 7,201 0 In Reference 3, the NRC requested additional information with respect to the decommissioning funding assurance plan, submitted by Exelon Generation Company, LLC (EGC) in Reference I,for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, and supplemented by the information submitted by EGC in Reference 2.

February 15, 2010 U.S. Nuclear Regulatory Commission Page 2 The requested information is contained in the Attachment to this letter.

There are no new regulatory commitments made in this letter.

If you have any questions about this letter, please contact me at (630) 657-2823.

R w e c f fully, i & ~ & ~ \0 Patrick R. Simpson Manager - ~icensing Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information cc: Regional Administrator, U.S. NRC Region Ill U.S. NRC Senior Resident Inspector, Braidwood Station U.S. NRC Senior Resident Inspector, Byron Station

ATTACHMENT RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Braidwood and Byron Question 1 In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.75(b)(2):

The NRC reserves the right to take the following steps in order to ensure a licensees adequate accumulation of decommissioning funds; and, either independently or in cooperation with the FERC and the licensees State PUC, take additional actions as appropriate on a case-by-case basis, including modification of a licensees schedule for the accumulation of decommissioning funds.

Provide balances for the respective decommissioning trust funds for Braidwood Unit 1 and Braidwood Unit 2 as of July 31, 2009, August 31, 2009, September 30, 2009 and October 31, 2009.

Provide balances for the respective decommissioning trust funds for Byron Unit 1 and Byron Unit 2 as of July 31, 2009, August 31, 2009, September 30, 2009 and October 31, 2009.

Response to Question 1 The decommissioning trust fund balances for Braidwood Station, Units 1 and 2 and Byron Station, Units 1 and 2 are provided below for the dates requested. Additional information is also provided for November 30, 2009, and December 31, 2009, to show the performance of the trust funds from the time of the submittal of EGCs decommissioning funding assurance plan through the end of 2009, the date EGC will use to calculate any required additional decommissioning funding assurance as described in the Reference.

Braidwood Braidwood Byron Byron Date Unit 1 Unit 2 Unit 1 Unit 2 July 31, 2009 $187.5M $207.1M $210.1M $203.6M August 31, 2009 $193.5M $213.4M $216.4M $209.9M September 30, 2009 $199.3M $219.5M $222.6M $216.0M October 31, 2009 $196.9M $216.9M $220.2M $213.6M November 30, 2009 $203.0M $223.3M $226.7M $219.9M December 31, 2009 $205.2M $225.3M $228.7M $221.9M Braidwood and Byron Question 2 As of November 30, 2009, Exelon has not resolved its shortfall in decommissioning funding assurance for Braidwood Units 1 and 2 and Byron Units 1 and 2 per NRC requirements. Provide additional financial assurance in an amount that will eliminate the decommissioning funding assurance shortfall for 1

Braidwood Units 1 and 2 and Byron Units 1 and 2 prior to December 31, 2009.

Response to Question 2 EGC intends to calculate any shortfall based on the decommissioning trust fund values and the estimated decommissioning costs as of December 31, 2009 as proposed in EGCs decommissioning funding assurance plan submitted in the Reference. Per this plan, EGC also intends to establish this additional financial guarantee by April 1, 2010, in accordance with NRC requirements. The dates set forth in the funding assurance plan were based on the time required to complete updated site-specific estimates for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, and the time required to obtain the required internal approvals for any required additional financial guarantees, including approval by the Exelon Board of Directors.

Byron and Braidwood Beginning in 1999, provide the year-end balances, dates, and amounts of contributions made by Exelon into each of the decommissioning trust funds associated with Braidwood Units 1 and 2 and Byron Units 1 and 2. The data should be aggregated to show total contributions made.

Response to Byron and Braidwood Request A summary of the year-end balances, and annual contributions made into each of the trust funds for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2 is given below.

Year-end Balances Braidwood Braidwood Byron Byron Year Unit 1 Unit 2 Unit 1 Unit 2 1999 $154.3M $154.5M $169.7M $156.6M 2000 $153.1M $160.2M $168.2M $161.1M 2001 $145.9M $153.3M $160.0M $153.9M 2002 $133.8M $141.5M $146.5M $141.3M 2003 $155.8M $165.6M $170.6M $164.8M 2004 $169.0M $180.6M $184.9M $179.0M 2005 $179.8M $192.8M $196.7M $190.7M 2006 $204.1M $219.7M $223.0M $216.6M 2007 $217.9M $234.9M $238.3M $231.4M 2008 $165.1M $183.2M $185.8M $180.0M 2009 $205.2M $225.3M $228.7M $221.9M 2

Annual Contributions Braidwood Braidwood Byron Byron Year Unit 1 Unit 2 Unit 1 Unit 2 1999 $474.9K $4,403.4K $2.5K $3,839.8K 2000 $474.9K $4,403.4K $2.5K $3,839.8K 2001 $64.1K $844.8K $9.9K $396.3K 2002 $64.1K $844.8K $9.9K $396.3K 2003 $64.1K $844.8K $9.9K $396.3K 2004 $64.1K $844.8K $9.9K $396.3K 2005 $64.1K $777.8K $9.9K $396.3K 2006 $58.8K $715.9K $9.1K $363.3K 2007 $0 $0 $0 $0 2008 $0 $0 $0 $0 2009 $0 $0 $0 $0

Reference:

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

NRC, "Decommissioning Funding Assurance Plan," dated July 29, 2009 3