RS-22-113, Updated ISFSI Decommissioning Funding Plan for Zion Nuclear Power Station

Updated ISFSI Decommissioning Funding Plan for Zion Nuclear Power Station

ML22299A153
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/26/2022
From:	Simpson P Constellation Energy Generation
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-22-113
Download: ML22299A153 (1)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-22-113 10 CFR 72.30(b)

October 26, 2022 ATTN: Document Control Desk Director - Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295, 50-304 and 72-1037

Subject:

Updated ISFSI Decommissioning Funding Plan for Zion Nuclear Power Station

Reference:

Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S.

NRC, "Response to Request for Additional Information Related to the Application for License Transfers and Conforming Administrative Amendments," dated February 8, 2019 (ADAMS Accession No. ML19043A673)

By letter dated February 8, 2019 (Reference) Exelon Generation Company, LLC (EGC) submitted an updated Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP) for Zion Nuclear Power Station (ZNPS). 10 CFR 72.30(c) requires resubmittal of the DFP every three years. Constellation Energy Generation, LLC (CEG) is submitting an updated ISFSI DFP for ZNPS in accordance with 10 CFR 72.30(c).

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mrs. Linda M. Palutsis at (630) 657-2821.

Respectfully, Patrick R. Simpson Sr. Manager Licensing Constellation Energy Generation, LLC

October 26, 2022 U.S. Nuclear Regulatory Commission Page 2 cc: NRC Regional Administrator, Region III Kim Conway, Project Manager, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION

1.0 BACKGROUND

By letter dated July 24, 2018 (Reference 1) ZionSolutions, LLC (ZS) and Exelon Generation Company, LLC (EGC) submitted for the U.S. Nuclear Regulatory Commission (NRC) review and approval an application requesting that the NRC consent to the transfer of ZS's Facility Operating Licenses Nos. DPR-39 and DPR-48 for Zion Nuclear Power Station (ZNPS), Unit 1 and Unit 2, and the transfer of the generally licensed Independent Spent Fuel Storage Installation (ISFSI) for ZNPS, Units 1 and 2, to EGC (subsequently renamed Constellation Energy Generation, LLC (CEG). 1 By letter dated November 26, 2019, the NRC approved the license transfer (Reference 2). Upon transfer of the license, CEG becomes responsible for managing the spent nuclear fuel and greater than class C (GTCC) waste (referred to collectively as "spent fuel management") and providing funding for spent fuel management costs at ZNPS after the removal of spent fuel, high-level radioactive waste, and/or reactor related GTCC waste from storage.

In 2010, at the time of transferring the ZNPS license to ZS, CEG retained $25 million in its Non-Qualified Decommissioning Trust Fund (referred to as the "ISFSI Trust Fund")

for maintenance and decommissioning of the ISFSI following site decommissioning completion and return of the license to CEG. The license transfer from ZS to CEG does not result in a change of ownership of the CEG ISFSI Trust Fund.

ZS and CEG anticipate the license transfer back to CEG to be completed in December 2022. The previous Decommissioning Funding Plan (DFP) and cost estimate for the ISFSI were submitted by CEG in 2019, (References 3 and 4). This submittal fulfills the 10 CFR 72.30(c) requirement for timely resubmittal of the DFP every three (3) years.

2.0

SUMMARY

DESCRIPTION CEG maintains a cost estimate for spent fuel management costs and decommissioning of the ZNPS ISFSI, which is periodically updated and adjusted as deemed appropriate by CEG and in compliance with applicable regulatory requirements.

This cost estimate includes the costs associated with decommissioning the ISFSI.

10 CFR 72.30, "Financial assurance and recordkeeping for decommissioning," requires that the funding plan for decommissioning the ISFSI be resubmitted periodically with adjustments as necessary to account for changes in costs and the extent of contamination. CEG has extracted from this cost estimate, and provides herein, information supporting this required response for ZNPS, Units 1 and 2.

CEG notes that radiological decommissioning costs for ISFSIs typically consist of the removal and disposal of small volumes of neutron-activated concrete and certain structural steel components. No impact is expected upon soil and groundwater at ZNPS during the storage periods contemplated in the cost estimate. CEG also notes that induced radioactivity at the ZNPS ISFSI is not expected to result in residual radioactivity in excess of 25 mRem/yr in an unrestricted release scenario, were no 1

Unless otherwise noted, future references to the "license" include the general license for the Zion Independent Spent Fuel Storage Installation.

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ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION action to be taken to remediate the site. However, since CEG anticipates that there may be small, but measurable, amounts of induced radioactivity present and release of this material from ZNPS will likely require it to be disposed of at an NRC licensed radioactive waste disposal facility, CEG has included these costs in its cost estimate.

3.0 DETAILED DESCRIPTION 3.1 Reasonable Assurance of Funds Availability In Reference 5, CEG described certain terms of the sale agreement of ZNPS to ZS which required ZS to construct an ISFSI, transfer the spent nuclear fuel and GTCC waste to the ISFSI, and decommission the ZNPS Units except for the ISFSI.

Subsequently, the NRC approved the corresponding license transfer, (Reference 6).

Following the completion of the sale, CEG transferred the funds in the ZNPS Units Qualified and Non-Qualified Decommissioning Trust Funds (DTF) into Qualified and Non-Qualified DTFs established by ZS. As part of the transfer of funds to ZS, CEG segregated $25 million to be retained in CEGs Non-Qualified DTF (the ISFSI Trust Fund) for the purpose of funding the maintenance and decommissioning of the ISFSI after ZS completes the decommissioning of the rest of the ZNPS site and the License transfers back to CEG. Table 1 shows the ISFSI Trust Fund assets, and the costs estimated for ISFSI decommissioning as required under 10 CFR 72.30(b), as of August 31, 2022.

3.2 Detailed Cost Estimate and Adjustments In 2021, an updated detailed cost estimate was developed to estimate the costs (in 2021 dollars) to manage the spent nuclear fuel in the ISFSI on the ZNPS site and decommission the ISFSI. The estimate relies upon site-specific information reflecting the design of the spent fuel dry storage facilities and current assumptions pertaining to the disposition of the spent fuel. The cost estimate assumes that once decommissioning and demolition of ZNPS are complete, the site license and responsibility for ISFSI spent fuel management and decommissioning are to be transferred back to CEG from ZS.

CEG currently intends to use an independent contractor to perform all activities associated with the decommissioning of the ISFSI. Table 2 shows the cost for an independent contractor to perform all radiological decommissioning activities, with an adequate contingency to meet the 10 CFR 20.1402 criteria for unrestricted use. All costs have a 25% contingency factor applied consistent with the evaluation criteria referenced in NUREG-1757, "Consolidated Decommissioning Guidance," (Reference 7).

The cost estimate provided herein has been escalated to August 31, 2022 dollars. The method used to escalate was performed in two steps. The first step increased the cost estimate to June 30, 2022 dollars using the Employment Cost Index, Total Compensation Private Industry Workers. The second step increased the cost estimate to August 31, 2022 dollars using a forecasted average annual escalation rate of 3.078%.

This rate is based on past performance of the Employment Cost Index, Total Compensation Private Industry Workers.

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ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION 3.3 Assumptions CEG has made the following assumptions within the ZNPS cost estimate with respect to the site ISFSI decommissioning:

1. ZNPSs site license is to be transferred back to CEG in January 2022. This date is conservative since the license transfer is anticipated to occur in December 2022.

2. All values in Table 2 are at ownership share. The ownership share for CEG of ZNPS is 100%.

3. All ISFSI decommissioning costs are expected to be incurred in the year following the year all spent fuel has been removed from the site.

4. For the purposes of the cost estimate, the transfer of all ZNPS spent fuel to the DOE is assumed to be completed in 2044. This date assumes the DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority, the DOE will give priority to removing fuel from shutdown sites, and that the DOE begins removing spent fuel from commercial facilities in 2035 with an annual capacity of 3,000 metric tons of uranium. 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. As part of the periodic updates to the cost estimate, the assumptions regarding DOE fuel removal from the site are reviewed and adjusted based on new information or considerations.

5. The trust fund assets allocated for ISFSI decommissioning earn a 2% annual real rate of return, consistent with 10 CFR 50.75I(1)(i).

3.4 Method of Assurance In accordance with 10 CFR 72.30(b)(4), Table 1 describes the method from 10 CFR 72.30(e) selected by CEG for assuring funds for ISFSI decommissioning.

CEG periodically updates the cost estimate associated with the site-specific assurance method and adjusts the funding levels, as necessary, in accordance with 10 CFR 50.75. The cost estimate will be periodically updated and adjusted as deemed appropriate by CEG and in compliance with applicable regulatory requirements.

Currently, CEG performs a comprehensive update to cost estimates at least once every 5 years in accordance with Regulatory Guide 1.159, Revision 2, Section C.1.4.3, "Frequency of Adjustment," (Reference 8). In addition, the cost estimate is adjusted to account for inflation on an annual basis.

3.5 Volume of Subsurface Residual Radioactivity Requiring Remediation CEG has not identified any onsite, subsurface material containing residual radioactivity at the ISFSI.

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ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION 3.6 Effects of Events Listed in 10 CFR 72.30(c)

The 2021 update to the detailed cost estimate for managing the spent nuclear fuel in the ISFSI on the ZNPS site and decommissioning the ISFSI is relied upon in this DFP. Each of the items listed in 10 CFR 72.30(c)(1) through (4) was considered in preparation of the 2021 updated cost estimate. Therefore, the effects, if any, since 2021 of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning costs provided in Table 2:

1. Spills of radioactive material producing additional residual radioactivity in onsite subsurface material

• No impact. There have been no spills of radioactive material producing additional residual radioactivity in onsite subsurface material from 2021 to August 31, 2022 at the ZNPS ISFSI.

2. Facility modifications

• No impact. There have been no modifications to the ZNPS ISFSI from 2021 to August 31, 2022 that would materially change the latest decommissioning cost estimate.

3. Changes in authorized possession limits

• No impact. There have been no changes in authorized possession limits at the ZNPS ISFSI from 2021 to August 31, 2022.

4. Actual remediation costs that exceed the previous cost estimate

• No impact. No actual remediation costs have been incurred at the ZNPS ISFSI, therefore no actual remediation costs exceed the previous cost estimate.

3.7 Certification of Financial Assurance In accordance with 10 CFR 72.30(b), financial assurance for decommissioning the ISFSI has been provided in an amount that equals or exceeds the cost estimate for ISFSI decommissioning, as demonstrated in Table 1.

4.0 REFERENCES

1. Letter from Ken Robuck (ZionSolutions, LLC) and J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. NRC, "Application for License Transfers and Conforming Administrative License Amendments," dated July 24, 2018 (ADAMS Accession No. ML18211A303)

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ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION

2. Letter from J. B. Hickman (U.S. NRC) to J. Sauger (Energy Solutions, LLC),

"Zion Nuclear Power Station, Units 1 and 2 - Order Approving Transfer of Licenses from ZionSolutions, LLC to Exelon Generation Company, LLC and Conforming Administrative License Amendments (EPID L-2018-LLA-0217),"

dated November 26, 2019 (ADAMS Accession No. ML19228A129)

3. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Independent Spent Fuel Storage Installation Decommissioning Funding Plan for Zion," dated September 18, 2019 (ADAMS Accession No. ML19261B478)

4. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to the Application for License Transfers and Conforming Administrative Amendments," dated February 8, 2019 (ADAMS Accession No. ML19043A673)

5. Letter from T. S. O'Neill (Exelon Generation Corporation) and J. Christian (ZionSolutions, LLC) to U.S. NRC, "Application for License Transfers and Conforming Administrative License Amendments," dated January 25, 2008 (ADAMS Accession No. ML080310521)

6. Letter from J. B. Hickman (U.S. NRC) to J. A. Christian (ZionSolutions, LLC),

"Order Approving Transfer of Licenses and Conforming Amendments Relating to Zion Nuclear Power Station, Units 1 and 2 JAC Nos. J00341 and J00342)," dated May 4, 2009 (ADAMS Accession No. ML082840443)

7. NUREG-1757, "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. NRCs Office of Nuclear Material Safety and Safeguards, Vol. 3, Rev 1, dated February 2012

8. Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Office of Nuclear Regulatory Research, Revision 2, dated October 2011 Page 5 of 7

ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION TABLE 1 - Zion Nuclear Power Station - ISFSI Only - Decommissioning Financial Assurance Summary Trust Fund Total Trust Fund Part 72.30 Site Assets Allocated Assets as of Parent Specific for ISFSI Annual Method of August 31, 2022 Company Decommissioning Cost, Decommissioning Contributions Assurance (2022 dollars) Guarantee (2022 dollars)

(2022 dollars)

(Thousands $) (Thousands $)

(Thousands $)

$11,141

$61,909 $13,199 $0 $0 10 CFR 72.30(e)(1)

(in 2045)

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ATTACHMENT UPDATED ISFSI DECOMMISSIONING FUNDING PLAN FOR ZION NUCLEAR POWER STATION TABLE 2 - ISFSI Decommissioning Funding Estimate for Zion Nuclear Power Station (August 31, 2022 Dollars, Thousands)

Burial Transportati LLRW Removal Packaging Other Volume Activity Description on Disposal Total Costs Costs Costs Costs Class A Costs Costs (cubic feet)

Decommissioning Contractor Decontamination (activated disposition) $758 $148 $403 $1,384 $2,693 40,426 Characterization and Licensing Surveys $2,634 $2,634 Subtotal* $758 $148 $403 $1,384 $2,634 $5,327 40,426 Supporting Costs Utility Staff Cost $575 $575 Security Staff Cost $673 $673 Insurance and NRC Fees $1,352 $1,352 Property Taxes $901 $901 Plant Energy Budget $38 $38 Equipment and Supplies $47 $47 Subtotal* $47 $0 $0 $0 $3,539 $3,586 Total w/o contingency* $805 $148 $403 $1,384 $6,173 $8,912 40,426 Total with 25% contingency* $1,006 $185 $503 $1,730 $7,716 $11,141

• Total Costs may not add due to rounding Page 7 of 7