View source for L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007)

{{Adams
| number = ML23222A287
| issue date = 08/10/2023
| title = Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007)
| author name = Zawalick M
| author affiliation = Pacific Gas &amp; Electric Co
| addressee name = 
| addressee affiliation = NRC/NMSS/DFM, NRC/Document Control Desk
| docket = 07200026
| license number = 
| contact person = 
| case reference number = DIL-23-005, CAC 001028, EPID L02022-RNW-0007
| document type = Letter type:L
| page count = 1
| project = CAC:001028, EPID:001028, EPID:L02022
| stage = Other
}}

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{{#Wiki_filter:Pacific Gas anti Elecmc Company*
Maureen R. Zawalick Diablo Canyon Power Plant Vice President      P.O. Box 56 Business and        Avila Beach, CA 93424 Technical Services 805.545.4242 Maureen.Zawalick@pge.com PG&E Letter DIL-23-005 ATTN: Document Control Desk Director, Division of Fuel Management, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Diablo Canyon Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (CAC/EPID No. 001028/L-2022-RNW-0007)

==Reference:==
: 1. PG&E Letter DIL-22-003, License Renewal Application for the Diablo Canyon Independent Spent Fuel Storage Installation, dated March 9, 2022 (ML22068A189)

==Dear Commissioners and Staff:==

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted a License Renewal Application (LRA) for the Diablo Canyon (DC) Independent Spent Fuel Storage Installation (ISFSI). On September 2, 2022, the Governor of California signed Senate Bill No. 846 into law, which reversed the prior state decision approving the retirement of Diablo Canyon Power Plant (DCPP) by the expiration of the operating licenses in November 2024 and August 2025, for Units 1 and 2 respectively, and directed PG&E to pursue renewing the DCPP operating licenses. On July 10, 2023, the Governor of California signed Senate Bill No. 124 into law, which further clarified actions related to DCPP continued operations. In response, PG&E currently plans to submit a new DCPP LRA to the NRC by December 31, 2023, for up to 20 years of additional operation for DCPP Units 1 and 2 in accordance with NRC's standard review process.
Portions of the DC ISFSI LRA discuss DCPP ceasing operations in November 2024 and August 2025 for Units 1 and 2, respectively. The Enclosure to this letter provides the DC ISFSI LRA, Revision 1, Affected LRA Sections. These specific LRA Sections are revised to reflect the potential for DCPP continued operations beyond the current operating license expiration dates.
PG&E makes no new or revised regulatory commitments (as defined in NEI 99-04) in this letter.
If you have any questions or require additional information, please contact Mr. Philippe Soenen at (805) 459-3701.
A  member   of  the STARS   Alliance Callaway  Diablo Canyon  Palo Verde  Wolf Creek

Document Control Desk                                                  PG&E Letter DIL-23-005 Page 2 I state under penalty of perjury that the foregoing is true and correct.
Executed on August 10, 2023             .
Sincerely, Maureen R. Zawalick Vice President, Business and Technical Services Enclosure cc:        Diablo Distribution cc/enc: William C. Allen, NMSS Project Manager Brian Harris, NRC Senior Project Manager Mahdi O. Hayes, NRC Senior Resident Inspector Samson S. Lee, NRC Senior Project Manager Chris Markley, NMSS Project Manager John D. Monninger, NRC Region IV Administrator Anthony Chu, California Department of Public Health A  member   of  the STARS   Alliance Callaway  Diablo Canyon  Palo Verde  Wolf Creek

Enclosure PG&E Letter DIL-23-005 Page 1 of 9 Diablo Canyon (DC) Independent Spent Fuel Storage Installation (ISFSI)
Site-Specific License Renewal Application (LRA), Revision 1 Affected LRA Sections LRA Section                            Revision Summary 1.3.6        Updates the financial qualifications of PG&E to address the 1.6         source of funds for operating the DC ISFSI if Diablo Canyon Power Plant (DCPP) is approved to operate past November 2024 and August 2025 for Units 1 and 2, respectively.
F.1         Updates the Environmental Report Supplement to address the F.3         potential for DCPP license renewal and resulting deferral of F3.2        effects from decommissioning until later in the ISFSI license F3.3        renewal period.
G.3         Updates the spent fuel management strategy to account for the potential DCPP license renewal and clarifies PG&E has no plans to modify the DC ISFSI configuration due to potential continued DCPP operations.

Enclosure                                 Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-23-005                                                           Installation Page 2 of 9                                     Site-Specific License Renewal Application 1.3.6  Financial Qualifications of PG&E PG&E will remain financially qualified to carry out the operation and decommissioning of the ISFSI during the period of the renewed material license as required by 10 CFR 72.22(e). The source of funds to operate the DC ISFSI until the expiration of the current DCPP Unit 1 operating license in November 2024 is the General Rate Case process regulated by the CPUC to set customer rates.
The most-recent General Rate Case application to the CPUC was submitted in June 2021 and includes an ISFSI funding request into 2025 (Reference 1.6.4). As shown in Reference 1.6.5 (see page WP 3-50, item 5040889), estimated operating and maintenance costs are approximately $12.1 million for 2024 and $8.3 million for 2025.
On September 2, 2022, the Governor of California signed Senate Bill No. (SB) 846 into law, which reversed the prior CPUC decision approving the retirement of DCPP by the expiration of the operating licenses and directed PG&E to pursue renewing the operating licenses. PG&E currently plans to submit a new DCPP LRA to the Nuclear Regulatory Commission (NRC) by December 31, 2023 for up to 20 years of additional operation in accordance with NRC's standard review process. If PG&E continues operating DCPP beyond the Unit 1 and 2 current operating license expiration dates in November 2024 and August 2025, respectively, PG&Eas a rate regulated utilitywill seek recovery of funds to operate DCPP and the DC ISFSI through a ratemaking process established by the CPUC consistent with California Public Utilities Code 712.8(h)(1) (Reference 1.6.11).
The source of funds to operate and decommission the DC ISFSI after DCPP operations have ceased is the PG&E Nuclear Decommissioning Trust Fund, which is regulated by the CPUC and NRC. On a nominal three-year frequency, PG&E submits an updated funding request (termed the Nuclear Decommissioning Cost Triennial Proceeding) to the CPUC for the PG&E Nuclear Decommissioning Trust Fund. The most-recent CPUC funding request was submitted in December 2021 (Reference 1.6.6). The Irradiated Fuel Management Plan was submitted to the NRC in 2019 (Reference 1.6.7) and is conservative compared to PG&E's current plans to pursue DCPP license renewal because it assumes funding is required from the PG&E Nuclear Decommissioning Trust Fund earlier (i.e., starting in 2024 versus a later date). As shown in the Irradiated Fuel Management Plan, Table 1, estimated operating and maintenance costs for November 2024 through August 2067 are $1.13 billion or approximately $26.2 million annually (in 2019 dollars).
The Irradiated Fuel Management Plan assumes the Department of Energy (DOE) will complete transfer of spent fuel from the DC ISFSI in 2067. PG&E will continue to request additional funding through the CPUC Nuclear Decommissioning Cost Triennial Proceeding process if the DOE transfer date is delayed.
1.6    Section 1.0 References 1.6.11 California Public Utilities Code 712.8 (h)(1). Available online at https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PUC&se ctionNum=712.8.
Section 1, General Information

Enclosure                               Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-23-005                                                            Installation Page 3 of 9                                    Site-Specific License Renewal Application F.1   Introduction Independent Spent Fuel Storage Installations (ISFSIs) for storing spent nuclear fuel and associated radioactive materials are licensed by the U.S. Nuclear Regulatory Commission (NRC). ISFSIs are licensed in accordance with the Atomic Energy Act of 1954 (42 United States Code [USC] 2011, et. seq.) and NRC implementing regulations.
Pacific Gas and Electric Company (PG&E) owns and operates the Diablo Canyon (DC) ISFSI in San Luis Obispo County, California. The DC ISFSI consists of the HI-STORM 100 System, transporter, cask transfer facility (CTF), storage pads, and ancillary equipment. The DC ISFSI operates pursuant to its own site-specific NRC License (SNM-2511), which was issued in March 2004 (Reference F8.1). The DC ISFSI was constructed to store the spent fuel associated with DC Power Plant (DCPP)
Units 1 and 2, two pressurized water reactors that were planned for permanent cessation of operations at the expiration of the current operating licenses in 2024 and 2025, respectively. NRC License SNM-2511 currently allows PG&E to store up to 4,400 spent fuel assemblies in up to 140 HI-STORM 100SA casks (138 plus two spare locations) at the DC ISFSI. The current site-specific DC ISFSI license will expire on March 22, 2024.
On September 2, 2022, the Governor of California signed Senate Bill No. 846 into law, which reversed the prior state decision approving the retirement of DCPP by the expiration of the operating licenses and directed PG&E to pursue renewing the operating licenses. PG&E currently plans to submit a new license renewal application (LRA) to the NRC by December 31, 2023 for up to 20 years of additional operation in accordance with NRC's standard review process. If DCPP operates beyond the current license expiration dates, additional spent fuel will be generated from continued DCPP operations; however, a change to the licensed capacity of the DC ISFSI is not required. Spent fuel in excess of the DC ISFSI licensed capacity will be stored in the DCPP spent fuel pools. The need to expand the DC ISFSI storage capacity after DCPP permanent shutdown is not reasonably foreseeable because at some point during the 40-year DC ISFSI renewal period, either a consolidated interim storage facility or a permanent repository may become available. However, if an ISFSI expansion is required to support decommissioning, it would be subject to a separate licensing action and is not part of this LRA.
F.3   Affected Environment As discussed in Section F1.4, the environmental impacts of the DC ISFSI were first presented in the ER for the DC ISFSI license application (Reference F8.4) and NRC issued an EA related to the construction and operation of the DC ISFSI (Reference F8.5). Because these documents have previously defined the impacts of the DC ISFSI, PG&E adopts relevant material from these documents by reference.
PG&E planned to permanently cease DCPP Units 1 and 2 power operations at the end of the existing operating licenses in November 2024 and August 2025, respectively. Under that scenario, PG&E planned to employ the DECON method and begin active decommissioning soon after Unit 2 shutdown (Reference F8.15). DCPP 10 CFR Part 50 license termination would be targeted for approximately 9 years after Unit 2 shutdown. As described in Section F1.1, the ISFSI LR period would be from Appendix F, Environmental Report Supplement

Enclosure                                Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-23-005                                                            Installation Page 4 of 9                                    Site-Specific License Renewal Application March 2024 through March 2064; therefore, a portion of the ISFSI LR period would occur during active DCPP decommissioning.
If DCPP continues to operate past November 2024 and August 2025 (see Section F.1), PG&E's decommissioning plans for DCPP would likely remain the same, just deferred by the additional DCPP operation period for up to 20 years.
F3.2  Land Use This section updates information previously presented in the ER (Reference F8.4; Section 2.2.2). Information regarding land use of the area outside of the DC owner-controlled area that is not discussed below has not changed from the information presented in the ER or the NRCs EA (Reference F8.5; Section 4.2); therefore, PG&E adopts this information by reference.
Farming is a significant land use in San Luis Obispo County; the principal agricultural industries/crops are wine grapes, vegetables, cattle, nurseries, fruits, nuts, and grains (Reference F8.16). The total land acreage of San Luis Obispo County is 2,111,084 acres. In 2017, farm acreage in the county was approximately 931,291 acres. There are several vineyards and wineries in the county. Wine grapes account for approximately 26 percent of the top ten value crops in the county (Reference F8.16).
The fruit and nut crop industries had an estimated value of $603 million in 2020, with wine grapes accounting for $218 million (Reference F8.16).
In the immediate vicinity of the DCPP and the ISFSI site, most agricultural activities conducted take place on lands leased from PG&E. These activities consist of cattle grazing on much of the area surrounding the site, and dry farming of hay for cattle, which takes place on a single farm in the east-southeast sector of the PG&E-controlled property. The farm is located along the site access road on the coastal plateau, approximately 3.5 miles south from the plant and extends for 1 mile south. In addition, there are two household gardens greater than 500 square feet within 5 miles of the ISFSI site. One garden is approximately 0.25 acres and is located 4.42 miles north-northeast of the ISFSI. The second garden is approximately 500 square feet and is located 4.63 miles east of the ISFSI. The only dairy farm operation is located 12 miles northeast of the site at California Polytechnic State University in San Luis Obispo.
The land use within the DC owner-controlled area will change significantly during the ISFSI license renewal period due to DCPP's decommissioning activities (i.e.,
dismantlement, decontamination, and final site restoration). Final DCPP site restoration will be conducted to conclude DCPP decommissioning activities, including transitioning the site to unrestricted use. As decommissioning progresses, the owner-controlled area will be collapsed to support ISFSI operations, security, and transmission operations via the 230 and 500 kV switchyards. A DCPP final site restoration plan, including land uses, will be developed, reviewed, and approved by applicable state and local agencies as DCPP decommissioning progresses. If DCPP continues to operate past November 2024 and August 2025 (see Section F.1), the described land use effects from DCPP decommissioning activities would remain the same, just deferred by the additional DCPP operation period for up to 20 years.
Appendix F, Environmental Report Supplement

Enclosure                              Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-23-005                                                           Installation Page 5 of 9                                   Site-Specific License Renewal Application F3.3  Transportation Except for updated traffic volumes presented below, information regarding transportation in the DC ISFSI area has not changed from the information presented in the ER (Reference F8.4; Section 2.8.2) or the NRCs EA (Reference F8.5; Section 4.8); therefore, PG&E adopts this information by reference.
As of 2021, approximately 1,400 full-time personnel commute to DCPP and the DC ISFSI each workday. These employees travel predominantly on the highways serving the DC ISFSI area. During the ISFSI LR period, the number of full-time commuting personnel is expected to significantly decrease due to the permanent shutdown of DCPP. The number of full-time commuting personnel will continue to decrease until the DCPP licenses are terminated after DCPP decommissioning is complete. If DCPP continues to operate past November 2024 and August 2025 (see Section F.1), the described transportation effects due to DCPP decommissioning would remain the same, just deferred by the additional DCPP operation period for up to 20 years.
Table F3.3-1 presents the existing traffic volumes for the major highways and roads serving the DC ISFSI site.
Table F3.3-1 Annual Average Daily Traffic Volume (Two-Way)
Road/Highway                        Daily Traffic Volume U.S. Highway 101 (at San Luis Bay Drive)           67,000 vehicles/day State Highway 1 (at North Highway 101)          22,000 vehicles/day Avila Beach Drive (West of San Luis Bay Drive)       12,578 vehicles/day San Luis Bay Drive (West of Ontario Road)           8,359 vehicles/day Source: References F8.17 and F8.18 Appendix F, Environmental Report Supplement

Enclosure                                         Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-22-005                                                                               Installation Page 6 of 9                                              Site-Specific License Renewal Application G.3       10 CFR 72.30 Diablo Canyon Independent Spent Fuel Storage Installation Decommissioning Cost Estimate
: 2. Spent Fuel Management Strategy The operating licenses for DCPP Units 1 and 2 are currently set to expire on November 2, 2024, and August 26, 2025, respectively. Approximately 4,398 spent fuel assemblies are projected to be generated as a result of plant operations through these license expiration dates. The ISFSI is operated under a Part 72 site-specific license.
Assuming that the plant operates to the end of currently licensed life, the spent fuel pools are expected to contain up to 2,542 spent fuel assemblies after the final core offloads (1,261 and 1,281 spent fuel assemblies stored in the Unit 1 and 2 spent fuel pools, respectively). To facilitate immediate dismantling, the spent fuel that cannot be transferred directly to the DOE from the pools is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pools to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas.
Assuming that the plant operates beyond the current Unit 1 and 2 operating license expiration dates in November 2024 and August 2025, respectively, additional spent fuel generated from continued DCPP operations may be stored in the spent fuel pools. PG&E currently has no plans to expand the DC ISFSI or develop a new ISFSI at the DCPP site for continued plant operations because there is sufficient spent fuel storage capacity between the DC ISFSI and spent fuel pools for 60 total years of DCPP operation. Furthermore, a possibility remains that, at some point during the 40-year DC ISFSI renewal period, either a consolidated interim storage facility or a permanent repository may become available, thus creating space at the DC ISFSI for the additional spent fuel transfer from the spent fuel pools.
Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.7 PG&E's current spent fuel management plan for the DCPP spent fuel is based in general upon: (1) a 2038 start date for DOE initiating transfer of commercial spent fuel to a federal facility, and (2) completion of spent fuel and GTCC waste receipt by year 2067.8 The completion date is based upon the DOE's generator allocation/receipt schedules which are based upon the oldest 7
U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) " ... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such material from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "
8 "Application of Pacific Gas and Electric Company in the 2018 Nuclear Decommissioning Cost Triennial Proceeding." Pacific Gas and Electric Company filed with the California Public Utilities Commission on December 13, 2018.
Appendix G, Decommissioning Funding Plan

Enclosure                                       Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-22-005                                                                             Installation Page 7 of 9                                             Site-Specific License Renewal Application fuel receiving the highest priority. In accordance with the 10 CFR 961 standard contract,9 PG&E will be able to load a maximum of five full MPCs into five DOE-supplied transportation casks each year. Thus, the spent fuel and GTCC waste is projected to be removed from the DC ISFSI in 2067.
: 4. Independent Spent Fuel Storage Installation Description The DC ISFSI uses a Holtec International (Holtec) HI-STORM 100 System. The HI-STORM 100 System is comprised of an MPC, the HI-STORM 100SA storage overpack, and the HI-TRAC transfer cask. The MPCs are assumed to be transferred directly to the DOE and not returned to the station. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.
PG&E's current spent fuel management plan for the DCPP spent fuel would result in up to 138 SFSCs (nominal 32 assemblies per cask) at a time being placed on storage pads.
In addition to the spent fuel casks located on the ISFSI pad, there are projected to be additional casks that are expected to be used for GTCC waste storage on a separate GTCC waste pad. The storage overpacks used for the GTCC waste canisters (estimated quantity of 10) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey. It should be noted that the present ISFSI is not sized nor licensed for GTCC waste. A new license amendment would need to be submitted in the future for constructing an additional storage pad onsite that accommodates GTCC waste as approved stored contents.10 PG&E may elect to implement a different storage system that will work within the existing estimated pad footprint.
Table G-1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.
: 5. Key Assumptions/Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC waste material have been removed from the site. Configuration of the ISFSI is based on the licensed capacity, and the assumptions associated with DOE's spent fuel acceptance, as previously described. As discussed above, if DCPP operates beyond the Unit 1 and 2 operating license expiration dates in November 2024 and August 2025, respectively, PG&E currently has no plans to expand the DC ISFSI or develop a new ISFSI at the DCPP site because there is sufficient spent fuel storage capacity between the DC ISFSI and spent fuel pools for 60 total years of DCPP operation.
9 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004.
10 Future licensing activities for a separate GTCC waste storage facility are not included in the LRA. Impacts to the LRA (or renewed ISFSI license, as applicable) will be addressed as part of the GTCC waste licensing actions.
Appendix G, Decommissioning Funding Plan

Enclosure                                        Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-22-005                                                                                Installation Page 8 of 9                                               Site-Specific License Renewal Application The current size of the ISFSI pad is sufficient to store the projected amount of spent fuel for 40 years of DCPP operation and is approximately 105 feet in width and 476 feet in length. The DCPP spent fuel pools have the capacity to store any spent fuel generated for up to 20 years beyond the Unit 1 and 2 operating license expiration dates in November 2024 and August 2025, respectively.
If a new pad is added onsite as a separate facility to accommodate GTCC waste, the total GTCC waste concrete dimensions are expected to be approximately 105 feet in width and 34 feet in length.11 It is not expected that the overpacks will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of the good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. This is addressed in the Holtec Final Safety Analysis Report supporting General License 72-1014. To validate this assumption, it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.
It is not expected that there will be any residual contamination left on the concrete ISFSI pad or in the CTF area. It is expected that this assumption would be confirmed as a result of the good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that the ISFSI pad and transfer facility area will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.
There is no known subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.
However, the site-specific detailed cost estimate assumes radiological remediation of surficial soil in a limited area of approximately 1.2 acres (containing approximately 500 cubic yards) adjacent to the footprint of the ISFSI/GTCC waste pads. Impacts to soil beneath the ISFSI/GTCC waste pads are not anticipated given the limited pathways for contamination from the canisters, as well as the 7-foot thick concrete base of the pad.
To support an application for ISFSI license termination, the estimate assumes that a final status survey will be performed; this will include a 100 percent survey of the concrete overpack surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad.
As per 10 CFR 72.30(b)(2)(i), decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material 11 Future licensing activities for a separate GTCC waste storage facility are not included in the license renewal application. Impacts to the license renewal application (or renewed ISFSI license, as applicable) will be addressed as part of the GTCC waste licensing actions.
Appendix G, Decommissioning Funding Plan

Enclosure                                    Diablo Canyon Independent Spent Fuel Storage PG&E Letter DIL-22-005                                                                    Installation Page 9 of 9                                         Site-Specific License Renewal Application costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations),
and laboratory service costs are based on vendor price lists. Those craft labor positions that are expected to be provided locally, are consistent with fully burdened contractor labor rates used in the most recently developed site-specific DCPP decommissioning cost estimate in 2017 dollars and escalated to 2021 dollars.
PG&E, as licensee, will oversee the site activities; the estimate includes PG&E's labor and overhead costs.
Low-level radioactive waste packaging, transport, and disposal costs are based on rates consistent with the most recently developed site-specific decommissioning cost estimate in 2021 dollars.
Costs are reported in 2021 dollars.
An overall contingency of 18.5 percent has been added. As provided for in NUREG-1757, because the DCPP decommissioning cost estimate is site-specific with a high degree of certainty, the contingency of 18.5 percent is less than the contingency referenced in NUREG-1757.[12]
12 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S.
Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012 Appendix G, Decommissioning Funding Plan}}