ML082520575

Letter Request for Additional Information to Support the Review of the Pilgrim Nuclear Power Station Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb) and the Preliminary Decommissioning (TACs MD9416 and MD8036)

ML082520575
Person / Time
Site:	Pilgrim
Issue date:	09/12/2008
From:	James Kim Plant Licensing Branch 1
To:	Entergy Nuclear Operations
kim J, NRR/ADRO/DORL, 415-4125
References
FOIA/PA-2009-0026, TAC MD8036, TAC MD9416, FOIA/PA-2013-0151
Download: ML082520575 (7)

Text

September 12, 2008

Vice President, Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION SPENT FUEL MANAGEMNT PLAN PURSUANT TO 10 CFR 50.54(bb) AND THE PRELIMINARY DECOMMISSIONING COST ESTIMATE PURSANT TO 10 CFR 50.75(f)(3) (TAC NOS. MD8036 AND MD9416)

Dear Sir or Madam:

By letters dated June 7, 2007, and July 31, 2008, Entergy Nuclear Operations, Inc. (the licensee) submitted the Pilgrim Nuclear Power Station spent fuel management plan and preliminary decommissioning cost estimate respectively for review.

The Nuclear Regulatory Commission staff has been reviewing the submittals and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). A response to this RAI is requested to be provided within 30 days.

Sincerely,

/RA/ James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

As stated cc w/encl: See next page

ML082520575 OFFICE LPLI-1/PM LPLI-1/LA LPLI-1/BC NAME JKim SLittle MKowal DATE 9/11/08 9/11/08 9/12/08 Enclosure REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE PILGRIM NUCLEAR POWER STATION SPENT FUEL MANAGEMENT PLAN AND PRELIMINARY DECOMMISSIONING COST ESTIMATE Spent Fuel Management Program (SFMP) and Preliminary Decommissioning Cost Estimate (PDCE)

RAI No. 1: Section 5 of the SFMP, Financial Assurance and Section 1.7.1 of the PDCE, Spent Fuel Disposition Pilgrim stated in both Section 5 of the SFMP and in Section 1.71. of the PDCE, the cost associated with the isolation and continued operation of the spent fuel pool, and the construction and operation of the Independent Spent Fuel Storage Installation (ISFSI) would be covered by the decommissioning trust funds. The costs are identified in Table 5 and included in the decommissioning cost estimate in Table 8 of PDCE.

Withdrawals from decommissioning trust funds under 10 CFR 50.82(a)(8)(i)(A) are limited to legitimate decommissioning activities consistent with the definition of decommissioning. In addition, withdrawals under 10 CFR 50.82(a)(8)(i)(C) are not permitted if they would inhibit the ability of the licensee to complete funding of any shortfalls in the decommissioning trust needed to ensure the availability of funds to ultimately release the site and terminate the license. For the scenario that was indentified in Pilgrim's submittal, Pilgrim did acknowledge in their discussion the necessity for an exemption in accordance with 10 CFR 50.12, from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for spent fuel management expenses. What is the source of funds to address the annual spent fuel costs identified in Table 5 of the PDCE?

Preliminary Decommissioning Cost Estimate (PDCE)

RAI No. 2: Section 2.2 Financial Assurance of the PDCE

In Section 2.2, Pilgrim stated that their analysis, whose results are shown in Table 8 of the July 31, 2008, submittal, was based on a 3-percent inflation rate. Was the 3-percent inflation rate based on the information identified in Section 2.1, "Escalation of the 2005 Costs to 2007 Dollars" or was it based on a different analysis? Based on the information provided in Section 2.1, the NRC staff could not reproduce the 3-percent inflation rate. Pilgrim should provide the supporting analysis that was used to develop the 3-percent escalation rate.

RAI No. 3: Section 2.2 Financial Assurance of the PDCE Section 2.2 stated that Pilgrim used a 1.47 percent real rate of return to produce the results listed in Table 8. The staff applied both the Pilgrim's 1.47 percent real rate of return as well as a 2 percent real rate of return. The staff analysis was based on a trust balance of $621.76 million and a license termination date of 2012 and deducted the expenses identified in Table 7, "Pilgrim Nuclear Power Station Schedule of Annual Expenditures, License Termination and Spent Fuel Management Allocations." The staff analysis did not support the conclusion that sufficient funds would be available to decommission Pilgrim starting in 2043 applying the licensee's real rate of return of 1.47 percent. In addition, the staff could not reconcile the differences between Pilgrim's and the staff's approaches for analyzing the decommissioning trust fund balance and projected expenditures. The licensee should provide the supporting analysis for values/cost identified in each of the columns listed in Table 8.

Pilgrim Nuclear Power Station cc: Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 MA Department of Public Health Radiation Control Program Schrafft Center, Suite 1M2A Massachusetts Emergency Management Agency Attn: John Giarrusso, Nuclear Preparedness Manager 400 Worcester Road Framingham, MA 01702-5399 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Site Vice President Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 General Manager, Plant Operations Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

Director, Nuclear Safety Assurance Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

Manager, Licensing Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 529 Main Street Charlestown, MA 02129

Pilgrim Nuclear Power Station cc: Senior Vice President Entergy Nuclear Operations, Inc.

P.O. Box 31955 Jackson, MS 39286-1995 Vice President, Oversight Entergy Nuclear Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

Vice President, Operations Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Michael Kansler President & CEO/CNO Entergy Nuclear Operations, Inc.

P.O. Box 31955 Jackson, MS 39268-1995 Mr. John F. McCann Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

Senior Manager, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. P.O. Box 31955 Jackson, MS 39268-1995 Assistant General Counsel Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306

Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348

Mr. John Doering P.O. Box 189 Parker Ford, PA 19457