View source for NG-20-0078, Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)

{{Adams
| number = ML21014A455
| issue date = 01/13/2021
| title = Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)
| author name = Hansen P
| author affiliation = NextEra Energy Duane Arnold, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000331, 07200032
| license number = DPR-049
| contact person = 
| case reference number = NG-20-0078
| document type = Letter type:NG
| page count = 7
}}

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DUANE ARNOLD NG-20-0078 January 13, 2021                                                              10 CFR 50.54 Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket Nos. 50-331, 72-32 Renewed Facility Operating License No DPR-49 Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)

==References:==
: 1)             Letter, Curtland (NEDA) to U.S. NRC, "Certification of Permanent Cessation of Power Operations," NG-20-0074, dated August 27, 2020 (ML20240A067)
: 2)         Letter, Curtland (NEDA) to U.S. NRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center," NG-20-0090, dated October 12, 2020 (ML20286A317)
: 3)         Letter, Anderson (DAEC) to U. S. NRC, "Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate for Duane Arnold Energy Center," NG-09-0038, dated February 19, 2009 (M L090550968)
Pursuant to 10 CFR 50.54(bb), "Conditions of licenses," NextEra Energy Duane Arnold, LLC (NEDA) is submitting the Duane Arnold Energy Center (DAEC) Spent Fuel Management Plan (SFMP) on behalf of itself and the joint owners of DAEC, Central Iowa Power Cooperative (CIPCO) and Corn Belt Power Cooperative (Corn Belt). By {{letter dated|date=August 27, 2020|text=letter dated August 27, 2020}}, NEDA informed the U.S. Nuclear Regulatory Commission (NRC) that DAEC had permanently ceased power operations on August 10, 2020 (Reference 1). By {{letter dated|date=October 12, 2020|text=letter dated October 12, 2020}}, NEDA certified permanent defueling of the reactor at DAEC (Reference 2) . Therefore, as specified in 10 CFR 50 .82(a)(2), the 10 CFR Part 50 license for DAEC no longer authorizes operations of the reactor or emplacement or retention of fuel into the reactor vessel. In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), NEDA must submit a SFMP, Site-Specific Decommissioning Cost Estimate (DCE), and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations.
The SFMP is included as the Enclosure to this letter. An updated DCE was submitted to the NRC on February 25, 2020 (ML20056E054) . The DAEC PSDAR was submitted to the NRC on April 2, 2020 (ML20094F603) .
NextEra Energy Duane Arnold , LLC, 3277 DAEC Road , Palo, IA 52324

NG-20-0078 Page 2 of 2 As discussed in 10 CFR 50.54(bb), a licensee shall "within two (2) years following permanent cessation of operation of the reactor or 5 years before expiration of the reactor operating license, whichever occurs first, submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." NEDA is submitting the attached SFMP to fulfill the 10 CFR 50 .54(bb) requirement to submit a SFMP to the NRG within two years following permanent cessation of operation of the reactor for Commission review and preliminary approval of the program by which NEDA, CIPCO, and Corn Belt intend to manage and provide funding for the management of all irradiated fuel at the reactor facility until title and possession of the irradiated fuel is transferred to the U. S. Department of Energy for ultimate disposal.
Prior to the DAEC license being extended to 2034 (License Renewal), NEDA submitted a SFMP to the NRG February 19, 2009 (Reference 3) to fulfill the 10 CFR 50.54(bb) requirement to submit a SFMP to the NRG five (5) years before expiration of the operating license, which was set to expire in 2014. The SFMP in the Enclosure to this letter supersedes and replaces, in its entirety, the SFMP submitted in 2009.
In accordance with 10 CFR 50.54(bb), a copy of this notification will be maintained until the expiration of the DAEC operating license. Additionally, DAEC will notify the NRG of any other significant changes in the proposed Spent Fuel Management Plan described in the Enclosure pursuant to 10 CFR 50.54(bb). This letter contains no new commitments and no revisions to existing commitments.
Should there be any questions, please contact Mike Davis, Licensing Manager, at (319) 851-7032.
Paul Hansen Decommissioning Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure cc:    Administrator, Region Ill, USNRC Project Manager, DAEC, USNRC Inspector, DAEC, USNRC

Enclosure To NG-20-0078 Spent Fuel Management Plan for Duane Arnold Energy Center 4 pages follow

NextEra Energy Duane Arnold, LLC (NEDA),
Central Iowa Power Cooperative (CIPCO), Corn Belt Power Cooperative (Corn Belt)
Spent Fuel Management Plan (SFMP) for Duane Arnold Energy Center I.      Background and Introduction By {{letter dated|date=August 27, 2020|text=letter dated August 27, 2020}}, and as required by 10 CFR 50.82(a)(1)(i), NextEra Energy Duane Arnold, LLC (NEDA) provided notice to the NRC that the Duane Arnold Energy Center (DAEC) permanently ceased operations on August 10, 2020. (Reference 1). By {{letter dated|date=October 12, 2020|text=letter dated October 12, 2020}}, NEDA certified permanent defueling of the reactor at DAEC (Reference 2). Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for DAEC no longer authorizes operations of the reactor or emplacement or retention of fuel into the reactor vessel.
The decommissioning approach that has been selected by NEDA for DAEC is the SAFSTOR method.
A Spent Fuel Management Plan (SFMP) for DAEC was previously provided to the NRC in 2009 (Reference 3). The SFMP in this Enclosure supersedes and replaces in entirety the SFMP submitted in Reference 3.
In order to estimate the costs associated with maintenance of the DAEC site in SAFSTOR and the eventual decommissioning of the site, NEDA assumed 2030 as the first year that the U.S. Department of Energy (DOE) will begin removing spent nuclear fuel from nuclear power reactor sites. Pursuant to the Nuclear Waste Policy Act (Reference 4), the Federal government has the responsibility to remove all spent fuel from DAEC and other commercial nuclear power reactor sites. However, the DOE spent fuel and high-level waste management program is currently stalled. Given the status of the DOE program, NEDA considered publicly available information to identify a reasonable date by which to expect DOE to begin accepting spent fuel. In January 2013, DOE released its "Strategy for Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste." (ML13011A138). The DOE Strategy contemplates building the capability to begin executing DOE's commitment to address waste disposal within the next ten years. Under this Strategy, by 2021, operation would begin of a "pilot storage facility" with an "initial focus on accepting spent fuel from shutdown reactor sites." By 2025, a "larger interim storage facility" would be available, and by 2048, a geologic repository would commence operations. For purposes of its DCE and this SFMP, DAEC has conservatively assumed that the larger interim storage facility is delayed five years and commences operations in 2030.
II. Spent Fuel Management Strategy 10 CFR 50.54(bb) requires that licensees establish a program "to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository."
Pending transfer of the fuel to the DOE, NEDA will store fuel on an interim basis in the

NextEra Energy Duane Arnold, LLC I Duane Arnold Energy Center Spent Fuel Management Plan Docket No. 50-331 NG-20-0078 Enclosure Page 2 of 4 spent fuel pool and/or the Independent Spent Fuel Storage Installation (ISFSI) located at DAEC.
DAEC currently has a licensed ISFSI. An ISFSI expansion will be constructed to support decommissioning operations. The expanded ISFSI facility will be able to accommodate the inventory of spent fuel remaining in the spent fuel pool. After the required cooling time, the spent fuel will be loaded in fuel storage canisters and moved to the ISFSI. Once the spent fuel pool is emptied of fuel, the facility will be placed in a SAFSTOR condition.
The ISFSI will continue to operate until the transfer of spent fuel to the DOE is complete.
Assuming the DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority and that the DOE begins removing spent fuel from commercial facilities in 2030, spent fuel is projected to remain at the DAEC site for approximately 39 years after the termination of operation (spent fuel is projected to be removed from the DAEC site by the end of 2059). 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.
Operation and maintenance costs for the storage facilities (ISFSI and spent fuel pool) are inputs to the DAEC Decommissioning Cost Estimate (DCE) submitted to the NRC on February 25, 2020 (Reference 5) and include the costs for staffing the facilities, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to the ISFSI and to decommission the ISFSI.
DAEC will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and ISFSI, as necessary. In addition, DAEC will also comply with applicable license termination requirements in accordance with 10 CFR 50.82, "Termination of license," with respect to plant shutdown and post-shutdown activities, including seeking NRC approvals as appropriate for the continued storage of irradiated fuel until transfer of the fuel to the DOE is complete.
Ill. Cost Estimate and Funding for Spent Fuel Management As stated in the DCE, total costs for spent fuel management under the SAFSTOR scenario will be approximately $259 million (2018 dollars). Of this, NEDA's 70% share is approximately $181 million; CIPCO's 20% share is approximately $52 million; and Corn Belt's 10% share is approximately $26 million. Further breakdown and analysis are discussed in the DCE.
NEDA This SFMP contemplates withdrawals from NEDA's nuclear decommissioning trust (NOT) for spent fuel management purposes, in accordance with the exemption granted

NextEra Energy Duane Arnold, LLC I Duane Arnold Energy Center Spent Fuel Management Plan Docket No. 50-331 NG-20-0078 Enclosure Page 3 of 4 by NRC on August 12, 2020 (Reference 6). At this time, there are no annual contributions made to the NOT and none are anticipated through the decommissioning period.
In addition to the costs identified in the DCE for spent fuel management, additional post-shutdown costs were incurred for those aspects of the spent fuel pool-to-ISFSI pad campaign that was underway on August 10, 2020, when Duane Arnold experienced an unplanned shutdown and permanently ceased operations. This campaign, though originally planned as an operational activity, became a decommissioning campaign for the purpose of spent fuel management funding as the plant permanently ceased operations while the campaign was ongoing. These post-shutdown spent fuel management costs, amounting to approximately $26.5 million, will also be paid from NEDA's NOT under the authority granted by the NRC exemption, in addition to those costs previously identified in the DCE (NEDA's $181 million share). NEDA has evaluated the funding level of the decommissioning fund to ensure that this additional withdrawal for spent fuel management will not inhibit the ability of NEDA to complete radiological decommissioning. The additional withdrawal of these funds will not materially affect the NOT cashflow analysis presented in NEDA's exemption request. Using the same analysis methodology used for the exemption request, NEDA has determined that the withdrawal of these additional funds under the authorization granted by the NRC exemption would result in a remaining NEDA balance in excess of $150 million at the end of decommissioning in 2080.
NEDA will continue monitoring the funding level to ensure that future withdrawals for spent fuel management do not inhibit the ability of NEDA to complete radiological decommissioning.
C/PCO CIPCO did not seek an exemption to allow use of its NOT for spent fuel management activities. CIPCO is a not-for-profit electric cooperative. CIPCO maintains reserve funds, outside of its NOT, for asset retirement and other purposes. These funds are available to pay for spent fuel management, together with operational income, if necessary.
Corn Belt Corn Belt did not seek an exemption to allow use of its NOT for spent fuel management activities. Corn Belt is a not-for-profit electric cooperative. Corn Belt maintains reserve funds, outside of its NOT, for asset retirement and other purposes. These funds are available to pay spent fuel management, together with operational income, if necessary.
An additional potential source of supplemental funding for spent fuel management costs for all Joint Owners is the Settlement Agreement, under which the United States Government has agreed to reimburse Duane Arnold for costs incurred attributable to DOE's failure to meet its contractual obligations for the transfer of spent fuel from DAEC.

NextEra Energy Duane Arnold, LLC I Duane Arnold Energy Center Spent Fuel Management Plan Docket No. 50-331 NG-20-0078 Enclosure Page 4 of 4 IV. References
: 1)     Letter, Curtland (NEDA) to U.S. NRC, "Certification of Permanent Cessation of Power Operations," NG-20-0074, dated August 27, 2020 (ML20240A067)
: 2)     Letter, Curtland (NEDA) to U.S. NRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center," NG-20-0090, dated October 12, 2020 (ML20286A317)
: 3)     Letter, Anderson (DAEC) to U.S. NRC, "Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate for Duane Arnold Energy Center," NG-09-0038, dated February 19, 2009 (ML090550968)
: 4)     United States of America Public Law 97-425, "Nuclear Waste Policy Act of 1982,"
dated January 7, 1983
: 5)     Letter, Curtland (NEDA) to U.S. NRC, "Request for Exemption from 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv), NG-20-0007, dated February 25, 2020 (ML20056E054)
: 6)     Letter, Wall (NRC) to D. Moul (NEDA), "Duane Arnold Energy Center- Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and Section 75(h)(1)(iv)," dated August 12, 2020 (ML20171A627, ML20171A626)}}