View source for L-19-159, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI - Irradiated Fuel Management Plans

{{Adams
| number = ML19234A158
| issue date = 08/22/2019
| title = ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI - Irradiated Fuel Management Plans
| author name = Benyak D
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000334, 05000346, 05000412, 05000440, 07200014, 07200069, 07201043
| license number = DPR-066, NPF-003, NPF-058, NPF-073
| contact person = 
| case reference number = L-19-159
| document type = Letter type:L, Operating Plan
| page count = 27
}}

=Text=
{{#Wiki_filter:FENOC First Er,ergt fwclE'r @ing Canpry 341 White Pond Dive Akron, Ohio 44320 Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs August 22,2019 L-1 9-1 59                                                    10 cFR 50.54(bb) 10 cFR 72.218 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSI Docket No. 72-1043 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI Docket No. 72-14 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant, Unit No. 1 ISFSI Docket No. 72-69 lrradiated Fuel Manaqement Plans By letter dated April 25,2018 (Accession No. ML181154007) FirstEnergy Nuclear Operating Company (FENOC), acting as agent for FirstEnergy Nuclear Generation, LLC (FENGen), notified the Nuclear Regulatory Commission (NRC) of the intention of FirstEnergy Solution Corp. (FES, and parent of FENGen) to permanently cease operation of the four FENGen reactors over the next three years.
As a result, by letter dated March 15,2019 (Accession No. ML190744244),
FENOC submitted the lrradiated Fuel Management Plans (lFMPs) for the aforementioned FENGen facillties to the NRC for review and preliminary approval.

Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station lndependent Spent Fuel Storage Installation Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station lndependent Spent Fuel Storage lnstallation Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant lndependent Spent Fuel Storage lnstallation L-19-159 Page 2 By letter dated July 26,2019 (Accession No. ML192074097) the "Certification of Permanent Cessation of Power Operations" for the Ohio-located FENGen facilities of DBNPS and PNPP was withdrawn. As a result, the IFMPs for DBNPS and PNPP are no longer required. FENOC, acting on behalf of FENGen, hereby withdraws the IFMPs for those two units that were provided in the March 15, 2019 letter.
Since BVPS-1 and BVPS-2 remain scheduled to shutdown in 2021, the IFMPs for those two facilities are still required. As described in the March 15, 2019 letter, the funding plan of the IFMPs for the four FENGen facilities were consolidated.
Enclosed are revisions to the BVPS-1 and BVPS-2 IFMPs that eliminate funding associated with DBNPS and PNPP. Additionally, both IFMPs have been updated to reflect minor changes in the number of fuel assemblies to be disposed assumed in the site-specific decommissioning cost estimates, along with other minor changes.
Therefore, the attached BVPS-1 and BVPS-2 IFMPs supersede the BVPS-1 and BVPS-2 IFMPs contained in the March 15, 2019 letter.
There are no regulatory commitments contained in this letter. lf there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager, Nuclear Licensing and Regulatory Affairs, at (330) 315-6810.
Sincerely, h,\
Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs Attachments:
: 1. Beaver Valley Power Station, Unit No. 1 lrradiated Fuel Management Plan
: 2. Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management Plan

Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station Independent Spent Fuel Storage Installation Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station lndependent Spent Fuel Storage lnstallation Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant lndependent Spent Fuel Storage lnstallation L-19-159 Page 3 cc: NRC Region lAdministrator NRC Region lll Administrator NRC Project Manager - FENOC Fleet NRC Resident Inspector - Beaver Valley Power Station NRC Resident lnspector - Davis-Besse Nuclear Power Station NRC Resident Inspector - Perry Nuclear Power Plant Director BRP/DEP Site Representative BRP/DEP Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board

Attachment  1 L-19-159 Beaver Valley Power Station, Unit No. 1 lrradiated Fuel Management Plan (Eleven pages follow)

Attachment    1 L-19-159 Beaver Valley Power Station, Unit No.           1 Irradiated Fuel Management Plan Page1of11

===Background===
10 CFR Part 50.54(bb) requires licensees to establish a program to manage and provide funding for the management of spent fuel at the reactor site until title and possession of the fuel is transferred to the United States Department of Energy (DOE) for ultimate disposal. The Beaver Valley Power Station, Unit No. 1 lrradiated Fuel Management Plan (IFMP), described herein, is based, in part, on a decommissioning cost estimate (DCE) that was prepared in 2018 for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 , BVPS-2, or collectively, BVPS), which includes elements associated with spent fuel management. The DCE identifies the details, schedules, and costs associated with spent fuel management activities described in the BVPS-1 IFMP, along with license termination and site restoration activities and costs.
Pursuant to 10 CFR 50.75(f)(1) on March 15, 2019, FirstEnergy Nuclear Operating Company (FENOC) submitted its decommissioning trust financial status report for the four FENOC-operated nuclear facilities. Enclosure A of that report is a copy of the BVPS DCE. The DCE describes the bases for the assumptions regarding DOE acceptance of spent fuel from the industry and from BVPS.
As stated in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), this IFMP is based on the assumption that BVPS-1 shuts down by May 31,2021. This IFMP presumes the DOE will commence acceptance of BVPS-1 spent fuel in 2029 and complete removal of spent fuel from the site by 2060 consistent with the most recent DOE spent fuel management and acceptance strategyl described below.
1 DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.
However, for these purposes, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance is assumed to commence in 2029 from BVPS-1 and in accordance with spent fue! shipment schedules that are based upon published historic acceptance priority rankings by DOE. Nothing herein should be interpreted as a concession or admission of any kind for purposes other than for this submission. Such other purposes would include, but are not limited to, disputes regarding DOE's legal or contractual acceptance obligations, or damages claims for recovery of incurred costs.
L-19-159 Page2of11 Spent Fuel Manaqement Strateqv FENOC assumes that, as stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting spent fuel for storage from the nation's commercial nuclear plants beginning in 2025 for placement in a consolidated interim storage facility (CISF) that starts operation in 2025. The DCE assumes that BVPS-1 will shutdown and cease operations in 2021 and that BVPS-1 spent fuel will be accepted for placement in the CISF. Using the rankings for spent fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987, and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2044, BVPS-1 fuel would be accepted atthe DOE storage facility starting in 2029.
The spent fuel pool will contain discharged fuel from the previous refueling cycles, as well as the final reactor core at shutdown. lmmediately after shutdown, spent fuel will be located in the spent fuel pool and in canisters located on an independent spent fuel storage installation (lSFSl). During the five-year period after the shutdown, the spent fuel from the spent fuel pool would be packaged into canisters and transferred to the ISFSI for interim storage. This period provides the necessary cooling time for the spent fuel to meet the decay heat requirements for placement in dry storage.
The current BVPS dry fuel storage system consists of a Transnuclear Standardized NUHOMS multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSM). There are ten modules currently on the ISFS! pad with 37-assembly capacity DSCs. A Holtec HI-STORM FW system, with a 37-fuel assembly capacity Multi-Purpose Canister (MPC) and concrete shield overpack is expected to be used following shutdown.
The DSCs and MPCs are assumed to be transferred directly to the DOE.
FENOC has constructed an ISFSI at BVPS to support BVPS-1 and BVPS-2 operations. The ISFSI operates under a general license pursuant to 10 CFR 72.210. The current size of the ISFSI pad is approximately 300 feet by 90 feet. The ISFSI will require expansion once plant operations cease in order to support spent fuel management activities. The pad expansion will be 120 feet by 90 feet. Total capacity of the consolidated pad is expected to be 88 DSCs and MPCs holding spent fuel and 6 MPCs holding greater than CIass C waste. The ISFS! will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. The DCE assumes that the BVPS spent fuel will be transferred to the DOE by 2060.
Table 1 provides a listing of the location of the spent fuel from 2019 until the spent fuel has been accepted by the DOE.
L-1 9-1 59 Page3of11 Table 1 - Spent Fuel Management Schedule (BVPS-1 Fuel Assembly Location)1 Year                 BVPS-1            BVPS.1         DOE Acceptance Pool lnventory     ISFSI lnventory    of BVPS-1 Fuel 2019                  1,252              370                  0 2020                  1,252              370                  0 2021                  1,409              370                  0 2022                  1,409               370                 0 2023                  1,409              370                  0 2424                  1,409              370                  0 2025                   706              1,073                 0 2026                    0               1,779                 0 2027                    0               1,779                 0 2028                    0               1,779                 0 2029                    0               1 ,763               16 2030                    0               1 ,710               s3 2031                    0               1,657                53 2032                    0               1,512               145 2033                    0               1,439                73 2034                    0               1,369                70 203s                    0               1,369                 0 2036                    0               1,324                45 2037                    0               1,263                61 2038                    0               1 ,190               73 2039                    0               1 ,117               73 2040                    0               1,054                63 2041                    0               1,054                 0 2042                    0                 985                69 2043                    0                 924                61 2044                    0                 846                78 2045                    0                789                 57 2046                    0                728                 61 2047                    0                659                 69 2048                    0                659                  0 2049                    0                 554               105 2050                    0                 534                20 205  1                  0                469                 65 2052                    0                 412                57 2053                    0                 355                57 2054                    0                 298                57 2055                    0                 241                57 L-19-1 59 Page 4 of    11 Table 1 (continued)
Year                         BVPS.1                BVPS-1           DOE Acceptance Pool lnventory       ISFSI lnventory       of BVPS-1 Fuel 2056                             0                   184                   57 2057                             0                   127                   57 2058                             0                    70                   57 2059                             0                    13                   57 2060                             0                     0                    13 Total                                                                     1,779 Note:
1 . Fuel location is as of the date of the submittal. lt is assumed that no fuel is transferred from the spent fuel pool to the ISFSI until 2025.
Schedule Table 2 provides a summary of the spent fuel management activities described in the DCE. The table provides the decommissioning period associated with the spent fuel management activity, its cost, and the approximate duration of the activity. The table does not consider ISFSI decommissioning, as this is an activity undertaken after spent fuel has been accepted by the DOE and removed from the site.
L-19-159 Page5of11 Table 2 - Spent Fuel Management Activities Decommissioning       Costs             Start Date       Stop Date          Approximate Period                (thousands,                                           Duration 201  I                                                (years) dollars)1 1 - Preparations           3,848        May 2021         December 2022           1.5 2a - Dormancy            128,369        December         August 2026             3.7 with Wet Fuel                           2022 Storage 2b - Dormancy            1 06,1 25      August 2026      January 2061           34.4 with Dry Fuel Storage Total                    238,341 Notes:
1 . The values were updated to reflect minor changes in the number of fuel assemblies to be disposed. The values were reported in 2014 dollars. A composite escalation factor was applied to convert the values into 2018 dollars. These values differ from those in Table 3 due to the way the values in both tables were escalated.
Decommissioning Period 1 - Preparations During this period, the facility is placed in a condition that allows the spent fue! to be safely stored and the facility to be maintained in a condition to be subsequently decontaminated to levels that permit release for unrestricted use.
The facility is left essentially intact with structures maintained in a sound condition. The process of placing the plant in safe-storage includes, but is not limited to, isolating the spent fuel storage services and fuel handling systems so that the spent fuel can be safely transferred from the spent fuel storage pool to the ISFSI for interim storage.
Decommissioning Period 2a - Dormancy with Wet Fuel Storage During this period, the facility is in the dormancy period of SAFSTOR decommissioning. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. FENOC expects to construct an ISFSI pad expansion during this period. FENOC plans to begin transferring the remaining BVPS-1 spent fuel from the spent fuel pool to dry storage in 2025 and to complete the transfer of fuel to the consolidated ISFSI in 2026.
L-19-159 Page6of11 Decommissioning Period 2b      - Dormancy with Dry Fuel Storage During this period, spent fuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the BVPS DCE, the IFMP assumes that the DOE will begin removing fuel from BVPS-1 in 2029 and will complete the removal of spent fuel from the site in 2060, according to the schedule set fofth in Table 1. During this period, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Maintenance, monitoring, and inspection of equipment, including fuel handling and shipping equipment, will be performed as required. BVPS-1 will also maintain a security force, which will safeguard the spent fuel for as long as it remains on site. Security barriers, sensors, alarms, and other surueillance equipment will be maintained as required to provide security for the ISFSI and spent fuel.
Cost Estimate The BVPS DCE provides the basis for the costs associated with spent fuel management.
The DCE includes the cost of operating and maintaining the spent fuel pool and the lSFSl. Pool operations are expected to continue approximately five years after the cessation of plant operations. ISFSI operating costs are based upon an approximately 39-year period of operation following plant shutdown. The cost for the labor and equipment to load and transfer each spent fuel canister to the ISFS! from the spent fuel pool is also included. Costs for transferring the fuel from the ISFSI into the DOE transport cask are also included in the DCE.
Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for statfing the facility, as well as security, insurance, and licenslng fees. Costs are also provided withln the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFSI is complete.
L-19-159 Page 7 of 11 Table 3 provides an expenditure summaryforthe BVPS-1 IFMP in 2018 dollars.
Table 3 - IFMP Expenditure Summaryl Expenditure Year                       (thousands, 201 I dollars) 2021                       1,838 2022                       4,788 2023                       33,479 2024                       33,57 1 2025                       33,479 2026                       21,422 2027                       2,497 2028                       7,110 2A29                       2,788 2030                       3,389 2031                       3,389 2032                       3,696 2033                       3,088 2034                       2,487 2035                       3,088 2036                       3,095 2037                       3,088 2038                       3,088 2039                       3,389 2040                       2,794 2041                       3,088 2042                       3,088 2443                       2,788 2044                       2,794 2045                       2,788 2046                       2,788 2047                       2,788 2048                       2,794 2049                       2,799 2050                       2,788 2051                       2,788 2052                       2,794 2053                       2,788 2054                       2,788 2055                       2,788 2056                       2,794 2457                       2,799 L-19-159 Page8of11 Table 3 (continued)
Expenditure Year                            (thousands, 201  I dollars) 2058                            3,088 2059                            2,799 2060                            3,095 Total                           232,539 Note:
1   The values were updated to reflect the minor changes in the number of fuel assemblies to be disposed.
Fundins The BVPS funding mechanisms take into account the need to fund spent fuel management for both BVPS-1 and BVPS-2.
The funding for BVPS-1 spent fuel management follows the schedule described above. Funding for Periods 1 and 2a extends from 2021 to 2026. This correlates with preparation activities and transferring the spent fuel to the ISFSI pad. Period 2b funding covers the period from 2027 to 2060. This correlates to long-term storage of spent fuel on the ISFSI pad until the fuel is transferred to the DOE.
Periods 1 and 2a Funding The total FENGen obligation for Periods 1 and 2a funding, which includes ISFSI activities and the transfer of spent fuel from the spent fuel pools to the lSFSl, for BVPS-1 is approximately $128.5 million dollars. FENGen intends to fund this obligation through a cash deposit of $267 million paid into a provisional trust.
FENGen expects to recover the majority of its costs for Periods 1 and 2a by making claims for damages resulting from the DOE's breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (Standard Contract) for BVPS-1. lt also expects that by no later than January 1,2A27, it will be able to obtain a settlement agreement to recover Period 2b costs annually. Therefore, FENGen has focused on planning to fund the expected costs through 2026 (that is, Periods 1 and 2a).
L-19-159 Page9of11 Upon emergence from bankruptcy, New Holdco2 and subsidiaries are projected to have approximately $2 billion of current assets, including cash and cash equivalents. FENGen anticipates that such assets would be able to fund Periods 1 and 2a spent fuel management activities for FENGen's two units by placement of
$267 million into a provisional trust by the end ol 2021. The provisional trust will enable use of the funds for spent fuel management activities occurring during Periods 1 and 2a. Upon the completion of the spent fuel activities in Periods 1 and 2a, the terms of the provisional trust will provide that it can be terminated, and its balance released back to FENGen.
FENGen will withdraw money from the $267 million provisional trust to pay the BVPS-1 Periods 1 and 2a spent fuel expenditures. Table 4 provides a summary of the FENGen use of the $267 million provisional trust. The expenditures came from the BVPS site-specific DCE that was developed in 2018.
rabre 4 - Periods                              Expenditures lffit':;r:t"xl[J:i Year               BVPS.1          BVPS.2          Total              Trust Value Payments        Payments         FENGen Payments lnitial Value                                                           267,000 2021             1,838            530              2,368           264,632 2022             4,788           2,943             7,631           257,001 2023            33,479           ?4,672           58,1 51           198,850 2024            33,571           36,556           70,127            129,723 2025            33,479           36,456           69,935            58,788 2026            21,422           36,456           57,878              910 Totals          128,577         137,513          266,090              910 Therefore, BVPS-1 Periods 1 and 2a costs will be fully paid for by funds withdrawn from the $267 million provisional trust.
2 March  31,2018, FirstEnergy Solutions Corp. (FES), togetherwith FENOC, FirstEnergy Nuclear Generation, LLC (FENGen), and FES's other subsidiaries, filed voluntary petitions for bankruptcy protection under Chapter 11 of the United States Bankruptcy Code.
Under the Plan of Reorganization, if confirmed, at emergence from bankruptGy, a new privately-held holding company will be formed with shares initially held by certain current creditors of one or more of FES, FENOC, FENGen, or FirstEnergy Generation, LLC (FG) (a sister company of FENGen holding fossi! fuel generation assets), and management of the new holding company. The name of the new holding company is yet to be determined, therefore, it will be described using the generic name, "New HoldCo." Both reorganized FENOC and reorganized FENGen will become wholly-owned subsidiaries of New HoldCo.
L-19-159 Page10of11 Period 2b Funding As described in the BVPS DCE, it is anticipated that the spent fuel will be entirely located on the ISFSI pad by 2026. The spent fuel is assumed to remain on the ISFSI pad between 2A27 and 2060, when the last of the spent fuel is transferred to the DOE. There are annual costs associated with maintaining the spent fuel on the ISFSI pad during this period. FENGen generally expects to recover those costs for spent fuel management during Period 2b, through reimbursements from the DOE due to its partial breach of the DOE Standard Contract.
FENGen has an existing settlement agreement with the DOE to recover spent fuel expenditures for its four facilities. Between 2012 and 2017, FENGen has recovered more than $193 million from the DOE. However, this settlement expires December 31 ,2019, and FENGen may need to litigate with the DOE in order to obtain reimbursement of Period 1 and 2a spent fuel expenditures after that date if the current settlement agreement is not extended. Other licensees with plants in premature shutdown have litigated with DOE to obtain recovery of Period 2b dry fuel storage costs and then obtained a settlement agreement. Thus, FENGen expects to obtain a settlement agreement for the Period 2b expenses and potentially some of the Periods 1 and 2a expenses.
As FENGen recovers its damages from the DOE, adequate funds will be retained in a segregated account to fund future annual expenses. Depending upon when litigation is resolved or a settlement is reached, this may include funding for parts of Periods 1 and 2a. Once the provisional trust is terminated, FENGen will rely upon the funds set aside in the segregated account.
The plan for BVPS-1 Period 2b funding process is to retain approximately $9.3 million in the segregated account for BVPS-1. The intent is to pay for the annual ISFSI activities, then apply for recovery of the expenses from the DOE, as needed lf FENGen is unable to obtain a settlement with DOE by the end of 2026, FENGen will obtain a performance bond for approximately $9.3 million (approximately 1.3 times the highest one-year value of ISFSI maintenance expenses). lf needed, the bond will be in place by the end of 2026. The bond will be renewed annually and remain in-place until such time that a settlement with the DOE is obtained.
ISFSI Decommissioninq Fundinq Once the ISFSI pad is no longer needed, ISFSI decommissioning can occur. The ISFSI decommissioning is expected to be completed by 2083. ISFSI decommissioning costs will be paid from an existing provisional ISFSI trust that was established for that purpose. FENOC letter to the NRC dated December 17,2018 (Accession No. ML18351A161) states that sufficient funding is available for ISFS!
L-1 9-1 59 Page11of11 decommissioning. Due to the changes in the assumptions in the BVPS DCE regarding the disposal of additional fuel assemblies for BVPS-1 and BVPS-2, the BVPS ISFS! was reviewed. lt was determined that there was no significant impact upon the BVPS ISFSI DCE.
Adiustments to Fundins Pursuant to 10 CFR 50.75(0(1), and 10 CFR 50.82(aXBXv) and (vi), FENOC is currently required to annually report to the NRC the status of the FENGen facility NDTs. Pursuantto 10 CFR 50.54(bb), FENOC is required to reporttothe NRC any significant changes to the IFMP. Since this IFMP includes a description of funding mechanisms and values, significant changes to the funding mechanisms and values will be reported. FENOC will make any adjustments, as needed, to ensure the adequacy of the facility NDT orthe FENGen provisional trust used to support the IFMP.

Attachment 2 L-19-159 Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management Plan (Eleven pages follow)

Attachment 2 L-1 9-1 59 Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management Plan Page1of11

===Background===
10 CFR Part 50.54(bb) requires licensees to establish a program to manage and provide funding for the management of spent fuel at the reactor site until title and possession of the fuel is transferred to the United States Department of Energy (DOE) for ultimate disposal. The Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management Plan (IFMP), described herein, is based, in pail, on a decommissioning cost estimate (DCE) that was prepared in 2018 for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1, BVPS-2, or collectively, BVPS), which includes elements associated with spent fuel management. The DCE identifies the details, schedules, and costs associated with spent fuel management activities described in the BVPS-2 IFMP, along with license termination and site restoration activities and costs.
Pursuant to 10 CFR 50.75(f)(1) on March 15, 2019, FirstEnergy Nuclear Operating Company (FENOC) submitted its decommissioning trust financial status report for the four FENOC-operated nuclear facilities. Enclosure A of that report is a copy of the BVPS DCE. The DCE describes the bases for the assumptions regarding DOE acceptance of spent fuel from the industry and from BVPS.
As stated in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), the IFMP is based on the assumption that BVPS-2 shuts down by October 31 ,2021. This IFMP presumes the DOE will commence acceptance of BVPS-2's spent fuel in 2034 and completes removal of spent fuel from the site by 2060 consistent with the most recent DOE spent fuel management and acceptance strategyl described below.
1 DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.
However, for these purposes, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance is assumed to commence in 2034 from BVPS-2 and in accordance with spent fuel shipment schedules that are based upon published historic acceptance priority rankings by DOE. Nothing herein should be interpreted as a concession or admission of any kind for purposes other than for this submission. Such other purposes would include, but are not limited to, disputes regarding DOE's legal or contractual acceptance obligations, or damages claims for recovery of incurred costs.
L-1 9-159 Page 2 of 11 Spent Fuel Manaqement Strategy FENOC assumes that, as stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting spent fuel for storage from the nation's commercial nuclear plants beginning in 2025 for placement in a consolidated interim storage facility (CISF) that starts operation in 2025. The DCE assumes that BVPS-2 will shutdown and cease operations in 2021 and that BVPS-2 spent fuel will be accepted for placement in the CISF. Using the rankings for spent fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987, and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004, BVPS-2 fuel would be accepted at the DOE storage facility starting in 2034.
The spent fuel pool will contain discharged fuel from the previous refueling cycles, as well as the final reactor core at shutdown. lmmediately after shutdown, spent fuel will be located in the spent fuel pool and in canisters located on an independent spent fuel storage installation (lSFSl). During the five-year period after the shutdown, the spent fuel from the spent fuel pool would be packaged into canisters and transferred to the ISFS! for interim storage. This period provides the necessary cooling time for the spent fuel to meet the decay heat requirements for placement in dry storage.
The current BVPS dry fuel storage system consists of a Transnuclear Standardized NUHOMS multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSM). There are ten modules currently on the ISFSI pad with 37-assembly capacity DSCs. A Holtec HI-STORM FW system, with a 37-fuel assembly capacity Multi-Purpose Canister (MPC) and concrete shield overpack, is expected to be used following shutdown.
The DSCs and MPCs are assumed to be transferred directly to the DOE.
FENOC has constructed an ISFSI at BVPS to support BVPS-1 and BVPS-2 operations. The ISFSI operates under a general license pursuant to 10 CFR 72.210. The current size of the ISFSI pad is approximately 300 feet by 90 feet. The ISFSI will require expansion once plant operations cease in order to support spent fuel management activities. The pad expansion will be 120 feet by 90 feet. Total capacity of the consolidated pad is expected to be 88 DSCs and MPCs holding spent fuel and 6 MPCs holding greater than CIass C waste. The ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. The DCE assumes that the BVPS spent fuel will be transferred to the DOE by 2060.
Table 1 provides a Iisting of the location of the spent fuel from 2019 until the spent fuel has been accepted by the DOE.
L-1 9-1 59 Page3of11 Table 1 - Spent Fuel Management Schedule (BVPS-2 Fuel Assembly Location)1, 2 Year                 BVPS.2            BVPS-2         DOE Acceptance Pool lnventory     ISFSI lnventory    of BVPS-2 Fuel 201  I                1,257                0                 0 2020                  1,321                0                  0 2021                  1,478                0                  0 2022                  1,478                0                  0 2423                  1,478                0                  0 2024                  1,478                0                  0 2025                  1 ,108              370                 0 2026                     0              1,478                 0 2027                     0              1,478                 0 2028                     0              1,478                 0 2029                     0              1,478                 0 2030                     0              1,478                 0 203  1                   0              1,478                 0 2032                     0              1,478                 0 2033                     0              1,478                 0 2034                     0              1,425                53 2035                     0              1,356                6g 2036                     0              1,291                65 2037                     0              1,224                71 2038                     0              1 ,151               69 2039                     0               1,089               62 2040                     0               1,089                0 2041                     0               1,025               64 2042                     0                964                61 2043                     0                899                65 2044                     0                838                61 2045                     0                838                 0 2046                     0                777                61 2047                     0                717                60 2048                     0                659                58 2049                     0                598                61 2050                     0                533                65 2051                     0                476                57 2052                     0                419                57 2053                     0                362                57 2454                     0                305                57 2055                     0                248                57 2056                     0                191                57 L-1 9-1 59 Page 4 of    11 Table 1 (continued)
Year                         BVPS-2                BVPS-2           DOE Acceptance Pool lnventory       ISFSI lnventory       of BVPS- Fuel 2057                             0                   134                   57 2058                             0                    77                   57 2059                             0                    20                   57 2060                             0                    20                   20 Total                                                                     1,478 Notes:
: 1. Fuel location is as of the date of the submittal. lt is assumed that no fuel is transferred from the spent fuel pool to the ISFSI until 2025.
: 2. The values were updated to reflect minor changes in the number of fuel assemblies to be disposed.
Schedule Table 2 provides a summary of the spent fuel management activities described in the DCE. The table provides the decommissioning period associated with the spent fuel program activity, its cost, and the approximate duration of the activity.
The table does not consider ISFSI decommissioning, as this is an activity undertaken after spent fuel has been accepted by the DOE and removed from the site.
L-1 g-1 59 Page5of11 Table 2   - Spent Fuel Management    Activities Decommissioning       Costs           Start Date         Stop Date          Approximate Period                (thousands,                                           Duration 201  I                                                (years) dollars)l'2 1 - Preparations           3,846      October 2021       Mav 2023                1.5 2a - Dormancy            139,932      May 2023           January 2027            3.7 with Wet Fuel Storage 2b - Dormancy            1 00,1 57    January 20?7       January 2061            34 with Dry Fuel Storage Total                    243,935 Notes:
: 1. The values    were obtained from the BVPS DCE, which were reported in 2014 dollars. A composite escalation factor was applied to convert the values into 2018 dollars. These values differ from those in Table 3 due to the way the values in both tables were escalated.
: 2. The change in the number of fuel assemblies to be disposed was determined not to affect the costs.
Decommissioning Period 1 - Preparations Durlng this period, the facility is placed in a condition that allows the spent fuel to be safely stored and the facility to be maintained in a condition to be subsequently decontaminated to levels that permit release for unrestricted use.
The facility is left essentially intact with structures maintained in a sound condition. The process of placing the plant in safe-storage includes, but is not limited to, isolating the spent fuel storage services and fuel handling systems so that the spent fuel can be safely transferred from the spent fuel storage pool to the ISFSI for interim storage.
Decommissioning Period 2a         - Dormancy with Wet Fuel Storage During this period, the facility is in the dormancy period of SAFSTOR decommissioning. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. FENOC expects to construct an ISFSI pad expansion during this period. FENOC plans to begin transferring the BVPS-2 spent fuel from the spent fuel pool to dry storage in 2025 and to complete the transfer of fuel to the consolidated ISFSI in 2026, L-1 9-1 59 Page6of11 Decommissioning Period 2b - Dormancy with Dry Fuel Storage During this period, spent fue! will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the BVPS DCE, the IFMP assumes that the DOE will begin removing fuel from BVPS-2 in 2034 and will complete the removal of spent fuel from the site in 2060, according to the schedule set forth in Table 1. During this period, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Maintenance, monitoring, and inspection of equipment, including fuel handling and shipping equipment, will be performed as required. BVPS-2 will also maintain a security force, which will safeguard the spent fuel for as long as it remains on site. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the ISFS! and spent fuel.
Cost Estimate The BVPS DCE provides the basis for the costs associated with spent fuel management.
The DCE includes the cost of operating and maintaining the spent fuel pool and the lSFSl. Pool operations are expected to continue approximately five years after the cessation of plant operations. ISFSI operating costs are based upon an approximately 39-year period of operation following plant shutdown. The cost for the labor and equipment to load and transfer each spent fuel canister to the ISFSI from the spent fuel pool is also included. Costs for transferring the fuel from the ISFSI into the DOE transport cask are also included in the DCE.
Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided within the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFSI is complete.
L-19-159 Page 7 of 11 Table 3 provides an expenditure summaryforthe BVPS-2 IFMP in 2018 dollars.
Table 3 - IFMP Expenditure Summaryl Expenditure Year                         (thousands, 2018 dollars) 2021                                        530 2022                                      2,843 2023                                      24,672 2024                                      36,556 2025                                      36,456 2026                                      36,456 2027                                       3,592 2028                                       2,578 2029                                       2,571 2030                                       2,571 2031                                       2,571 2032                                       ?,579 2033                                       2,571 2034                                       2,872 2035                                       3,172 2036                                       3,1 79 2037                                       3,172 2038                                       3,172 2039                                       3,172 2040                                       2,578 2041                                       3,172 2042                                       3,172 2043                                       3,172 2044                                       3,1 79
          ?045                                       2,972 2046                                       2,872 2047                                       2,872 2048                                       2,879 2049                                       2,872 2050                                       2,872 2051                                       2,872 2052                                       3,1 79 2053                                       2,872 2054                                       3j72 2055                                       2,872 2056                                       3,1 79 L-19-159 Page8of11 Table 3 (continued)
Expenditure Year                             (thousands, 201   I dollars) 2057                                            2,872 2058                                            3,172 2059                                            2,872 2060                                            3,1 79 Total                                          238,037 Fundinq The BVPS funding mechanisms take into account the need to fund spent fuel management for the BVPS-1 and BVPS-2.
The funding for BVPS-2 spent fuel management follows the schedule described above. Funding for Periods 1 and 2a extends from 2021 to 2026. This correlates with preparation activities and transferring the spent fuel to the ISFSI pad. Period 2b funding covers the period from 2027 to 2060. This correlates to long-term storage of spent fuel on the ISFSI pad until the fuel is transferred to the DOE.
Periods 1 and 2a Funding The total FENGen obligation for Periods 1 and 2a funding, which includes ISFSI activities and the transfer of spentfuel from the spent fuel pools to the lSFSl, for BVPS-2 is approximately $137.5 million dollars. FENGen intends to fund this obligation through a cash deposit of $267 million paid into a provisional trust.
FENGen expects to recover the majority of its costs for Periods 1 and 2a by making claims for damages resulting from the DOE's breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (Standard Contract) for BVPS-2. lt also expects that by no later than January 1,2027, it will be able to obtain a settlement agreement to recover Period 2b costs annually.
Therefore, FENGen has focused on planning to fund the expected costs through 2026 (that is, Periods 1 and 2a).
L-19-159 Page9of11 Upon emergence from bankruptcy, New Holdco2 and subsidiarles are projected to have approximately $2 billion of current assets, including cash and cash equivalents.
FENGen anticipates that such assets would be able to fund Periods 1 and 2a spent fuel management activities for FENGen's two units by placement of $267 million into a provisional trust by the end of 2021. The provisional trust will enable use of the funds for spent fuel management activities occurring during Periods 1 and 2a. Upon the completion of the spent fuel activities in Periods 1 and 2a, the terms of the provisional trust will provide that it can be terminated, and its balance released back to FENGen.
FENGen will withdraw money from the $267 million provisional trust to pay the BVPS-2 Periods 1 and 2a spent fuel expenditures. Table 4 provides a summary of the FENGen use of the $267 million provisional trust. The expenditures came from the BVPS site-specific DCE that was developed in 2018.
Table 4  -  Periods 1 and 2a Spent Fuel Expenditures (thousands, 2018 dollars)
Year               BVPS.1          BVPS.2            Total             Trust Value Payments        Payments          FENGen Payments lnitial Value                                                             267,000 2021               1 ,838                530             2,368            264,632 2022               4,788                2,843            7,631            257,001 2023               33,479              24,672           58,151            198,850 2024               33,571              36,556           70,127            128,723 2025               33,479              36,456           69,935             58,788 2026               21,422              36,456           57,878              910 Totals             128,577            137,513          266,090              910 Therefore, BVPS-2 Periods 1 and 2a costs will be fully paid for by funds withdrawn from the $267 million provisional trust.
2 March 31, 2018, FirstEnergy Solutions Corp. (FES), togetherwith FENOC, FirstEnergy Nuclear Generation, LLC (FENGen), and FES's other subsidiaries, filed voluntary petitions for bankruptcy protection under Chapter 11 of the United States Bankruptcy Code.
Under the Plan of Reorganization, if confirmed, at emergence from bankruptcy, a new privately-held holding company will be formed with shares initially held by certain current creditors of one or more of FES, FENOC, FENGen, or FirstEnergy Generation, LLC (FG) (a sister company of FENGen holding fossil fuel generation assets), and management of the new holding company. The name of the new holding company is yet to be determined, therefore, it will be described using the generic name, "New HoldGo." Both reorganized FENOC and reorganized FENGen will become wholly-owned subsidiaries of New HoldCo.
L-1 g-1 59 Page10of11 Period 2b Funding As described in the BVPS DCE, it is anticipated that the spent fuel will be entirely located on the ISFSI pad by 2026. The spent fuel is assumed to remain on the ISFSI pad between 2027 and 2060, when the last of the spent fuel is transferred to the DOE. There are annual costs associated with maintaining the spent fuel on the ISFSI pad during this period. FENGen generally expects to recover those costs for spent fuel management during Period 2b, through reimbursements from the DOE due to its partial breach of the DOE Standard Contract.
FENGen has an existing settlement agreement with the DOE to recover spent fuel expenditures for its four facilities. Between 2012 and 2017, FENGen has recovered more than $193 million from the DOE. However, this settlement expires December 31 ,2019, and FENGen may need to litigate with the DOE in order to obtain reimbursement of Period 1 and 2a spent fuel expenditures after that date if the current settlement agreement is not extended. Other licensees with plants in premature shutdown have litigated with DOE to obtain recovery of Period 2b dry fuel storage costs and then obtained a settlement agreement. Thus, FENGen expects to obtain a settlement agreement for the Period 2b expenses and potentially some of the Period 1 and 2a expenses.
As FENGen recovers its damages from the DOE, adequate funds will be retained in a segregated account to fund future annual expenses. Depending upon when litigation is resolved or a settlement is reached, this may include funding for parts of Periods 1 and 2a. Once the provisional trust is terminated, FENGen will rely upon the funds set aside in the segregated account.
The plan for BVPS-2 Period 2b funding process is to retain approximately $4.7 million in the segregated account for BVPS-2. The intent is to pay for the annual ISFSI activities, then apply for recovery of the expenses from the DOE, as needed. lf FENGen is unable to obtain a settlement with DOE by the end of 2026, FENGen will obtain a performance bond for approximately $+.2 million (approxlmately 1.3 times the highest one-year value of ISFSI maintenance expenses). lf needed, the bond will be in place by the end of 2026. The bond will be renewed annually and remain in-place until such time that a settlement with the DOE is obtained.
ISFSI Decommissioninq Fundinq Once the ISFSI pad is no longer needed, ISFSI decommissioning can occur. The ISFSI decommissioning is expected to be completed by 2083. ISFSI decommissioning costs will be paid from an existing provisional ISFSI trust that was established for that purpose. FENOC letter to the NRC dated December 17,2018 (Accession No. ML18351A161) states that sufficient funding is available for ISFSI L-1 9-1 59 Page11of11 decommissioning. Due to the changes in the assumptions in the BVPS DCE regarding the disposal of additional fuel assemblies for BVPS-13 and BVPS-2, the BVPS ISFSI was reviewed. lt was determined that there was no significant impact upon the BVPS ISFSI DCE Adiustments to Fundinq Pursuantto 10 CFR 50.75(f)(1), and 10 CFR 50.82(aXBXv) and (vi), FENOC is currently required to annually report to the NRC the status of the FENGen facility NDTs. Pursuantto 10 CFR 50.54(bb), FENOC is required to reporttothe NRC any significant changes to the IFMP. Since this IFMP includes a description of funding mechanisms and values, significant changes to the funding mechanisms and values will be reported. FENOC will make any adjustments, as needed, to ensure the adequacy of the facility NDT or the FENGen provisional trust used to support the IFMP.
3A change to an assumption in the BVPS DCE added an additional four fuel assemblies to BVPS-1 that require disposal.}}