ZS-2012-0109, Report on Status of Decommissioning Funding for Shutdown Reactors

Report on Status of Decommissioning Funding for Shutdown Reactors

ML12090A005
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/26/2012
From:	Daly P ZionSolutions
To:	Document Control Desk, NRC/FSME
References
ZS-2012-0109
Download: ML12090A005 (5)

Text

ZIONSOLUTIONSLC An EneWySolut~msComp"ny 10 CFR 50.75(f)(1) ZS-2012-0109 March 26, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 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 and 50-304

References:

1. Exelon Generation Corporation (EGC) Letter RS-08-009, "Application for License Transfers and Conforming'Administrative License Amendments,"

dated January 25, 2008

2. Nuclear Regulatory Commission (NRC) Letter, Hickman to Daly, ZionSolutions, LLC, "Order Approving Transfer of Licenses and Conforming Amendments Relating to Zion Nuclear Power Station, Units 1 and 2," dated May 4, 2009

3. ZionSolutions, LLC Letter, Daly to NRC, "Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Zion Nuclear Power Station, Units I and 2," dated March 18, 2008

4. ZionSolutions, LLC Letter, Beckman to Hickman, "Notification of a Significant Schedule Change from that provided in the Amended Post-Shutdown Decommissioning Activity Report," dated November 23, 2010

Subject:

Report on Status of Decommissioning Funding for Shutdown Reactors In accordance with 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning," paragraph (f)(1), ZionSolutions, LLC (ZS) is submitting a report on the status of decommissioning funding for the Zion Nuclear Power Station (ZNPS), Units 1 and 2. The annual radiological decommissioning funding assurance report for ZNPS is provided in the attachment to this letter for the period ending December 31, 2011.

The minimum required decommissioning funding assurance amount is based on a site-specific decommissioning cost estimate determined in accordance with 10 CFR 50.82(a). A change to the spent fuel management strategy was described in the application for license transfer (Reference 1),

accepted by the NRC via Reference 2, and further described in the amended PSDAR (Reference 3).

Reference 4 provided the decommissioning schedule that included adjustments resulting from

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ZionSolutions, LLC ZS-2012-0109 Page 2 of 3 incorporation of the actual calendar date of the asset and NRC license transfers as well as refinement of individual activity sequencing as the project planning achieved more detail.

Each of those references addressed the project's planning and scheduling basis, the associated estimated costs and the available funds for decommissioning, decontamination, dismantlement, and spent fuel management of both ZNPS units as an integrated project. As described in those references, radiological decommissioning as represented by the ZNPS integrated plan includes removal of the fuel to a dry storage facility and the decontamination and dismantlement of the radiologically involved systems, structures, and components. The attached decommissioning cost estimate does not include the costs of dismantling non-radiological systems and structures and other non-radiological site restoration.

ZS agreements with EGC include rights that will enable ZS to return the decontaminated site and transfer the Independent Fuel Storage Installation, spent fuel, remaining Greater than Class C (GTCC) waste, and associated NRC licenses to EGC by about calendar year 2020. Once these transfers are accomplished, EGC would maintain the irradiated fuel, including ongoing financial responsibility, until title to and possession of the irradiated fuel is transferred to the Department of Energy for its ultimate disposition. These latter, ongoing costs are not included in the estimates herein.

NRC review of this decommissioning management strategy and the associated funding and cost estimate was accomplished as part of the NRC approval of the transfer of the ZNPS operating licenses to ZS (Reference 2). For purposes of consistency with references 1, 2 and 3, the results of the end of year 2011 funding and cost estimate shown in the Attachment are aggregated for the entire project since Unit 1 and Unit 2 are being decommissioned concurrently as a single integrated project. This is consistent with the licensing basis and integrated plans for sequencing radiological decommissioning and fuel management reflected in the references. Since the time of the last estimate provided in Reference 3, the cost and funding estimate have been adjusted for market value changes in the decommissioning trust fund (DTF), refinement of the cost and schedule estimate reflecting more mature knowledge gained from the new cost-significant contracts for various decommissioning and fuel management activities, and more developed cost allocations among the activities for radiological and non-radiological work. (While this report excludes costs and discussion of non-radiological site restoration, it is ZS plan to additionally complete that work as part of the contract scope with EGC.)

The Attachment provides the aggregated, minimum estimated cost (funds needed) for concurrent radiological decommissioning of both nuclear units and for all used fuel management for the ten year contract period (corresponding to Item A in the Attachment), as defined by the prior submittals, planned decommissioning sequences, and work breakdown structure. This estimate has been developed from the site aggregate decommissioning schedule and provides the cost and funding allocation necessary to optimally decommission the radiologically involved systems, structures and components consistent with the Commission accepted decommissioning strategy. For completeness, the funding amount from the trust for both Unit 1 and Unit 2 is shown as components of the total DTF value as of December 31,2011 (Item B).

ZionSolutions, LLC ZS-2012-0109 Page 3 of 3 Disbursements from the trust fund have been made in accordance with the conditions of the ZNPS licenses, including the required advance notifications to the Office of Nuclear Reactor Regulation.

There are no regulatory commitments contained within this letter.

If you have any questions about this letter, please contact me at (224) 789-4020.

Patrick T. Daly Senior Vice President cc: John Hickman, U.S. NRC Senior Project Manager Service List

Attachment:

Annual Radiological Decommissioning Funding Assurance Report for Zion Nuclear Power Station, Station Aggregate

ZionSolutions, LLC ZS-2012-0109: Attachment Attachment Annual Radiological Decommissioning Funding Assurance Report for Zion Nuclear Power Station, Aggregate Costs December 31, 2011 (2011 dollars, thousands)

Required Minimum at December 31, 2011 (A) $641,286 Trust Fund Amount at December 31, 2011 (B) $650,957 Difference - Surplus/(Shortfall) (C) = (B) - (A) $9,671

1. The required minimum funding assurance amount is based on the decommissioning scenario from the site-specific decommissioning cost estimate provided in Reference 3. The cost estimate reflects actual experience to date, as well as, refinements made through the date of this filing.

2. The trust fund amount is the amount allocated for Radiological Decommissioning only, and does not include the allocation for dismantling non-radiological systems and structures and other non-radiological site restoration based on the decommissioning cost estimate.

3. There are no additional funds to be collected.

4. A 2% annual real rate of return is assumed in these calculations.

5. There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).

6. Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(l)(i).

7. There are no material changes to the trust fund agreements as described at the time of transfer of the licenses.

Zion Nuclear Power Station, Unit I and 2 License Transfer Service List cc:

Mr. Patrick T. Daly Mr. Kent McKenzie Senior VP and General Manager Emergency Management Coordinator ZionSolutions, LLC Lake County Emergency Management Agency 101 Shiloh Boulevard 1303 N. Milwaukee Avenue Zion, IL 60099 Libertyville, IL 60048-1308 Patrick Thurman, Esq. Regional Administrator VP Regulatory Affairs, Licensing and U.S. NRC, Region III Document Control 2443 Warrenville Road ZionSolutions, LLC Lisle, IL 60532-4352 101 Shiloh Boulevard Zion, IL 60099 John E. Matthews Morgan, Lewis & Bockius LLP Gary Bouchard .1111 Pennsylvania Avenue, NW VP Engineering, Ops & Nuclear Security Washington, DC 20004 and Decommissioning Plant Manager ZionSolutions, LLC 101 Shiloh Boulevard Zion, IL 60099 Alan Parker President Government Group EnergySolutions 800 Oak Ridge Turnpike, Ste. A-402 Oak Ridge, TN 37830 Thomas Magette Senior VP Nuclear Regulatory Strategy EnergySolutions 6350 Stevens Forest Road, Ste. 2000 Columbia, MD 21046 Russ Workman Deputy General Counsel EnergySolutions 423 West 300 South, Ste. 200 Salt Lake City, UT 84101 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, IL 62704