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| number = ML14314A070
| number = ML14314A070
| issue date = 11/06/2014
| issue date = 11/06/2014
| title = Quad Cities Nuclear Power Station, Units 1 and 2 & Proposed Independent Spent Fuel Storage Installation (ISFSI) - Decommissioning Funding Plan for Quad Cities Nuclear Power Station
| title = Proposed Independent Spent Fuel Storage Installation (ISFSI) - Decommissioning Funding Plan for Quad Cities Nuclear Power Station
| author name = Montgomery C R
| author name = Montgomery C
| author affiliation = MidAmerican Energy Co
| author affiliation = MidAmerican Energy Co
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter:MidAm erican MidAmerican Energy4299 N.W. Urbandale DriveENERGV Urbandale, Iowa 50322OBSESSIVELY, RELENTLESSLY AT YOUR SERVOCE. 515 281-2976 Telephone515 979-1201 Cellcrmontqomeryd.midamencan.comChuck MontgomeryManaging Senior Attorney10 CFR 72.30(b)November 6, 2014ATTN: Document Control DeskDirector -Division of Spent Fuel Storage and TransportationOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001Quad Cities Nuclear Power Station, Units 1 and 2Renewed Facility Operating License Nos. DPR-29 and DPR 30NRC Docket Nos. 50-254, 50-265, and 72-53
{{#Wiki_filter:MidAm erican                                                           MidAmerican Energy Drive 4299 N.W. Urbandale ENERGV                                                                Urbandale, Iowa 50322 OBSESSIVELY, RELENTLESSLY AT YOUR SERVOCE.                           515 281-2976 Telephone 515 979-1201 Cell crmontqomeryd.midamencan.com Chuck Montgomery Managing Senior Attorney 10 CFR 72.30(b)
November 6, 2014 ATTN: Document Control Desk Director - Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR 30 NRC Docket Nos. 50-254, 50-265, and 72-53


==Subject:==
==Subject:==
Proposed Independent Spent Fuel Storage Installation (ISFSI) DecommissioningFunding Plan for Quad Cities Nuclear Power StationMidAmerican Energy Company (MidAmerican) owns 25% of Quad Cities Nuclear PowerStation, Units 1 and 2 (QCNPS), and it provides financial assurance for the decommissioning ofits share of QCNPS. Exelon Generation Company, LLC (Exelon) owns the remaining 75% ofQCNPS, and it is the licensed operator for the facility. MidAmerican regrets to inform theNuclear Regulatory Commission of its failure to recognize the new filing requirement establishedby recent revisions to 10 CFR 72.30, and its consequent failure to make such a filing when dueon or before December 17, 2012. MidAmerican recently self-identified this omission and issubmitting the attached 10 CFR 72.30 report to fulfill this requirement. MidAmerican plans tofile an updated 10 CFR 72.30 report with MidAmerican's March 2015 10 CFR 50.75 biennialreport and each subsequent biennial report per 10 CFR 50.75. This will assure that the requiredinformation is provided to the NRC on a timely, ongoing basis.In accordance with 10 CFR 72.30, "Financial assurance and recordkeeping fordecommissioning," MidAmerican Energy Company is submitting the proposed ISFSIDecommissioning Funding Plan for QCNPS (Attachment 1). Exelon filed a 10 CFR 72.30(b)report for its 75% ownership interest in QCNPS on December 17, 2012, and MidAmerican reliesupon information provided in the Exelon report in the attached plan.The attached ISFSI Decommissioning Funding Plan includes ISFSI decommissioning costestimates excerpted from existing reactor decommissioning cost estimates. The QCNPSdecommissioning cost estimate assumes that the ISFSI, which has a Part 72 general license, willremain in service following the decommissioning and release of the other portions of the siteunder Part 50. As a result, the cost estimate assumes that the Part 50 license will be maintaineduntil the ISFSI is decommissioned and the license may be terminated. Decommissioning isdefined in 10 CFR 50.2 as the removal of a site from service and reduction of residualradioactivity to a level that permits the termination of the license, so the Part 50 license cannot beP4S52Y(p November 6, 2014U.S. Nuclear Regulatory CommissionPage 2terminated until the ISFSI meets residual radioactivity requirements. As a result, thedecommissioning of an ISFSI with a Part 72 general license is necessarily a Part 50decommissioning cost covered by 10 CFR 50.75.MidAmerican qualifies as an "electric utility" and recovers the costs of decommissioning,including ISFSI decommissioning, through cost of service rate recovery. As such, the attachedISFSI Decommissioning Funding Plan relies on "the methods of 10 CFR 50.75(b), (e), and (h), asapplicable" as allowed under new 10 CFR 72.30(e)(5), to demonstrate ISFSI decommissioningfinancial assurance and does not provide either a new ISFSI-specific decommissioning costestimate or new ISFSI-specific decommissioning financial assurance methods. Specifically, theDecommissioning Funding Plan relies on MidAmerican's decommissioning funding (10 CFR50.75) status update (as of September 30, 2014) submitted in the attached ISFSIDecommissioning Funding Plan (Attachment 1).Please refer any questions regarding the foregoing to the undersigned, Chuck Montgomery, at(515) 281-2976 or at CRMontgomerygmidamnerican.com.Sincerely,Cc: Regional Administrator- NRC Region IIINRC Project Manager -Quad Cities Nuclear Power StationNRC Senior Resident Inspector ATTACHMENT 1Proposed ISFSI Decommissioning Funding Plan1.0 SUMMARY DESCRIPTIONMidAmerican Energy Company (MidAmerican) is a minority owner, with a 25% ownershipshare, of Quad Cities Nuclear Power Station (QCNPS) Units I and 2. MidAmerican co-ownsQCNPS with Exelon Generation Company, LLC (Exelon). Exelon owns a 75% share of Units 1and 2 and operates both units as well. Exelon and MidAmerican maintain decommissioning costestimates for QCNPS, which are periodically updated. Imbedded in these decommissioning costestimates are the costs associated with decommissioning the Independent Spent Fuel StorageInstallation (ISFSI) located at QCNPS. The decommissioning cost estimate for the ISFSI havebeen extracted from the decommissioning cost estimate and are provided herein.As Exelon has noted in its own 10 CFR 72.30(b) filing, the radiological decommissioning costsfor an ISFSI typically consist of the costs associated with removing and disposing of smallvolumes of neutron-activated concrete and certain structural steel components. Exelon hasindicated that no impact is expected upon soil and groundwater at the QCNPS site during thestorage period contemplated in the decommissioning cost estimate for the site. Exelon has alsonoted that induced radioactivity at the QCNPS ISFSI is not expected to result in residualradioactivity in excess of 25 mRem/yr in an unrestricted release scenario, were no action to betaken to remediate the site.Finally, Exelon has noted that it anticipates small, but measurable amounts of inducedradioactivity to be present, and release of this material from the QCNPS site will require it to bedisposed of at a NRC-licensed radioactive waste disposal facility. Therefore, Exelon hasincluded the costs of this disposal in the decommissioning cost estimates.2.0 DETAILED DESCRIPTION2.1 Reasonable Assurance of Funds AvailabilityMidAmerican's trust fund balances for QCNPS Units I and 2 currently exceed the costsrequired for radiological decommissioning-see Tables I and 2, below. The excessassets will be used to decommission the on-site ISFSI. Table 1, below, shows the costsestimated for radiological decommissioning under 10 CFR 50.75(b) and (c), using theNRC Minimum formulas, and Table 2 shows MidAmerican's trust fund balances as ofSeptember 30, 2014. Both the radiological decommissioning costs and the trust fundbalances are stated in 2014 dollars and are adjusted for MidAmerican's 25% ownershipshare.1 2.2 Detailed Cost EstimateTable 3, below, which is based upon the November 2013 TLG decommissioning costestimate for QCNPS, details the costs of ISFSI decommissioning in 2014 dollars(MidAmerican escalated the 2011 dollar figures from the Nov. 2013 TLG study using a3.5% escalation rate). Table 3 shows the costs of performing this work (discussed furtherin the assumptions below), with an adequate contingency factor, to meet the 10 CFR20.1402 criteria for unrestricted use. The cost of performing this ISFSI decommissioningwork is approximately $486,000 per unit for MidAmerican's 25% share.2.3 AssumptionsConsistent with the assumptions made by Exelon in its own 10 CFR 72.30(b) filing,MidAmerican has made the following assumptions with respect to ISFSIdecommissioning:1. Decommissioning costs in Table 3 are escalated at 3.5% per annum into 2014dollars. (Exelon escalated costs into 2012 dollars since its 10 CFR 72.30(b)filing was made in late 2012.)2. All values in Tables 1 -4 are stated at MidAmerican's 25% ownership sharefor QCNPS. Costs for ISFSI decommissioning have been equally splitbetween the two (2) units at QCNPS.3. The costs for ISFSI decommissioning are expected to be incurred in the yearin which DOE has accepted all spent fuel from the QCNPS site for disposal.2.4 Method of AssuranceIn accordance with 10 CFR 72.30(b)(4), Tables 1 -3 demonstrate the method of assuringfunds for ISFSI decommissioning, from 10 CFR 72.30(e). Exelon and MidAmericanperiodically update the decommissioning cost estimate for QCNPS, and MidAmericanadjusts the funding levels, as necessary, in accordance with 10 CFR 50.75.(MidAmerican's annual Iowa jurisdictional decommissioning cost included in the cost ofservice is $1,595,964, per the Iowa Utilities Board's order in DocketNo. RPU-2013-0004. The Illinois Commerce Commission has not authorized anycurrent, ongoing collection from MidAmerican's Illinois ratepayers.)2.5 Volume of Subsurface Residual Radioactivity Requiring RemediationPer review of site-specific 10 CFR 50.75(g) logs, Exelon indicates it has not identifiedany onsite, subsurface material containing residual radioactivity at the ISFSI located atQCNPS.2 2.6 Certification of Financial AssuranceIn accordance with 10 CFR 72.30(b), financial assurance, for decommissioning, has beenprovided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b). Asdemonstrated in Tables 1-4, this provides the requisite financial assurance for the ISFSIdecommissioning costs.Table INRC Minimum as of9/30/14, in 2014 DollarsUnit 1 $166,138,985Unit 2 $166,138,985Totals $332,277,970Table 2External Trust FundBalance (Fair MarketValue) as of 9/30/14, in2014 DollarsUnit 1 $204,944,254Unit 2 $205,068,861Totals $410,013,115Table 3 (ISFSI Decommissioning Costs)MidAmerican's Burial/Ownership Share Unit 1 & U.RW Cu.FT Processed Utility andUnit 2 Removal Packaging Transport Disposal Other Total Total Class A Weight Craft Contractor(2014 Dollars w/3.5% Esc) Costs Costs Cost Costs Costs Contingency Costs LLRW (Ibs) Manhours Manhours.ISFSI License Termination 28 6 24 80 453 99 690 1,335 111,954 1,904 640Small Tool Allowance I --1 ----Property Taxes 91 9 100 -Security Staff Cost 65 10 75 1,245Utility Staff Cost --93 14 107 472Total 29 6 24 80 702 132 972 1,335 111,954 1,904 2,3563 Table 4 (Total Decommissioning Costs per NRC Minimum Formulas)(2014 Dollars)MidAmerican Energy CompanyQuad Cities, Units I & 2(2,957 MWt)As of 9/30/2014REACTOR TYPE: BWR$BASE COST 130,613,000($104 + 0.009P (in MWt))BaseEscalation Factors 9130/2014 Factor Base Year Source:Labor 120.0 2.08 2005 Bureau of Labor Statistics: Series CIU20100000002301EnergyPower 224.4 114.2 1986 Bureau of Labor Statistics: Series WPU0543Fuel 291.3 82.0 1986 Bureau of Labor Statistics: Series WPU0573Waste Burial 14.16 NUREG-1307, Rev 15, Table 2-1CalculationLabor Factor (L) 2.50 x 0.65 = 1.62 Labor Formula: CY Factor
Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for Quad Cities Nuclear Power Station MidAmerican Energy Company (MidAmerican) owns 25% of Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS), and it provides financial assurance for the decommissioning of its share of QCNPS. Exelon Generation Company, LLC (Exelon) owns the remaining 75% of QCNPS, and it is the licensed operator for the facility. MidAmerican regrets to inform the Nuclear Regulatory Commission of its failure to recognize the new filing requirement established by recent revisions to 10 CFR 72.30, and its consequent failure to make such a filing when due on or before December 17, 2012. MidAmerican recently self-identified this omission and is submitting the attached 10 CFR 72.30 report to fulfill this requirement. MidAmerican plans to file an updated 10 CFR 72.30 report with MidAmerican's March 2015 10 CFR 50.75 biennial report and each subsequent biennial report per 10 CFR 50.75. This will assure that the required information is provided to the NRC on a timely, ongoing basis.
* Base FactorEnergy Factor (E) 2.70 x 0.13 = 0.35 Energy Formula: E = 0.54P + 0.46FWaste Factor (B) 14.16 x 0.22 = 3.12Total Escalation Factor: 5.09 Total Escalation Formula: 0.65L + 0.13E + 0.22BTotal Minimum Assurance Unit I & 2(100%):MidAmericanMinimum Assurance (25%):$1,329,111,8821$ 332,277,9714}}
In accordance with 10 CFR 72.30, "Financial assurance and recordkeeping for decommissioning," MidAmerican Energy Company is submitting the proposed ISFSI Decommissioning Funding Plan for QCNPS (Attachment 1). Exelon filed a 10 CFR 72.30(b) report for its 75% ownership interest in QCNPS on December 17, 2012, and MidAmerican relies upon information provided in the Exelon report in the attached plan.
The attached ISFSI Decommissioning Funding Plan includes ISFSI decommissioning cost estimates excerpted from existing reactor decommissioning cost estimates. The QCNPS decommissioning cost estimate assumes that the ISFSI, which has a Part 72 general license, will remain in service following the decommissioning and release of the other portions of the site under Part 50. As a result, the cost estimate assumes that the Part 50 license will be maintained until the ISFSI is decommissioned and the license may be terminated. Decommissioning is defined in 10 CFR 50.2 as the removal of a site from service and reduction of residual radioactivity to a level that permits the termination of the license, so the Part 50 license cannot be P4S52Y(p
 
November 6, 2014 U.S. Nuclear Regulatory Commission Page 2 terminated until the ISFSI meets residual radioactivity requirements. As a result, the decommissioning of an ISFSI with a Part 72 general license is necessarily a Part 50 decommissioning cost covered by 10 CFR 50.75.
MidAmerican qualifies as an "electric utility" and recovers the costs of decommissioning, including ISFSI decommissioning, through cost of service rate recovery. As such, the attached ISFSI Decommissioning Funding Plan relies on "the methods of 10 CFR 50.75(b), (e), and (h), as applicable" as allowed under new 10 CFR 72.30(e)(5), to demonstrate ISFSI decommissioning financial assurance and does not provide either a new ISFSI-specific decommissioning cost estimate or new ISFSI-specific decommissioning financial assurance methods. Specifically, the Decommissioning Funding Plan relies on MidAmerican's decommissioning funding (10 CFR 50.75) status update (as of September 30, 2014) submitted in the attached ISFSI Decommissioning Funding Plan (Attachment 1).
Please refer any questions regarding the foregoing to the undersigned, Chuck Montgomery, at (515) 281-2976 or at CRMontgomerygmidamnerican.com.
Sincerely, Cc:     Regional Administrator- NRC Region III NRC Project Manager - Quad Cities Nuclear Power Station NRC Senior Resident Inspector
 
ATTACHMENT 1 Proposed ISFSI Decommissioning Funding Plan 1.0    
 
==SUMMARY==
DESCRIPTION MidAmerican Energy Company (MidAmerican) is a minority owner, with a 25% ownership share, of Quad Cities Nuclear Power Station (QCNPS) Units I and 2. MidAmerican co-owns QCNPS with Exelon Generation Company, LLC (Exelon). Exelon owns a 75% share of Units 1 and 2 and operates both units as well. Exelon and MidAmerican maintain decommissioning cost estimates for QCNPS, which are periodically updated. Imbedded in these decommissioning cost estimates are the costs associated with decommissioning the Independent Spent Fuel Storage Installation (ISFSI) located at QCNPS. The decommissioning cost estimate for the ISFSI have been extracted from the decommissioning cost estimate and are provided herein.
As Exelon has noted in its own 10 CFR 72.30(b) filing, the radiological decommissioning costs for an ISFSI typically consist of the costs associated with removing and disposing of small volumes of neutron-activated concrete and certain structural steel components. Exelon has indicated that no impact is expected upon soil and groundwater at the QCNPS site during the storage period contemplated in the decommissioning cost estimate for the site. Exelon has also noted that induced radioactivity at the QCNPS ISFSI is not expected to result in residual radioactivity in excess of 25 mRem/yr in an unrestricted release scenario, were no action to be taken to remediate the site.
Finally, Exelon has noted that it anticipates small, but measurable amounts of induced radioactivity to be present, and release of this material from the QCNPS site will require it to be disposed of at a NRC-licensed radioactive waste disposal facility. Therefore, Exelon has included the costs of this disposal in the decommissioning cost estimates.
2.0     DETAILED DESCRIPTION 2.1     Reasonable Assurance of Funds Availability MidAmerican's trust fund balances for QCNPS Units I and 2 currently exceed the costs required for radiological decommissioning-see Tables I and 2, below. The excess assets will be used to decommission the on-site ISFSI. Table 1, below, shows the costs estimated for radiological decommissioning under 10 CFR 50.75(b) and (c), using the NRC Minimum formulas, and Table 2 shows MidAmerican's trust fund balances as of September 30, 2014. Both the radiological decommissioning costs and the trust fund balances are stated in 2014 dollars and are adjusted for MidAmerican's 25% ownership share.
1
 
2.2     Detailed Cost Estimate Table 3, below, which is based upon the November 2013 TLG decommissioning cost estimate for QCNPS, details the costs of ISFSI decommissioning in 2014 dollars (MidAmerican escalated the 2011 dollar figures from the Nov. 2013 TLG study using a 3.5% escalation rate). Table 3 shows the costs of performing this work (discussed further in the assumptions below), with an adequate contingency factor, to meet the 10 CFR 20.1402 criteria for unrestricted use. The cost of performing this ISFSI decommissioning work is approximately $486,000 per unit for MidAmerican's 25% share.
2.3     Assumptions Consistent with the assumptions made by Exelon in its own 10 CFR 72.30(b) filing, MidAmerican has made the following assumptions with respect to ISFSI decommissioning:
: 1. Decommissioning costs in Table 3 are escalated at 3.5% per annum into 2014 dollars. (Exelon escalated costs into 2012 dollars since its 10 CFR 72.30(b) filing was made in late 2012.)
: 2. All values in Tables 1 - 4 are stated at MidAmerican's 25% ownership share for QCNPS. Costs for ISFSI decommissioning have been equally split between the two (2) units at QCNPS.
: 3. The costs for ISFSI decommissioning are expected to be incurred in the year in which DOE has accepted all spent fuel from the QCNPS site for disposal.
2.4     Method of Assurance In accordance with 10 CFR 72.30(b)(4), Tables 1 -3 demonstrate the method of assuring funds for ISFSI decommissioning, from 10 CFR 72.30(e). Exelon and MidAmerican periodically update the decommissioning cost estimate for QCNPS, and MidAmerican adjusts the funding levels, as necessary, in accordance with 10 CFR 50.75.
(MidAmerican's annual Iowa jurisdictional decommissioning cost included in the cost of service is $1,595,964, per the Iowa Utilities Board's order in Docket No. RPU-2013-0004. The Illinois Commerce Commission has not authorized any current, ongoing collection from MidAmerican's Illinois ratepayers.)
2.5     Volume of Subsurface Residual Radioactivity Requiring Remediation Per review of site-specific 10 CFR 50.75(g) logs, Exelon indicates it has not identified any onsite, subsurface material containing residual radioactivity at the ISFSI located at QCNPS.
2
 
2.6       Certification of Financial Assurance In accordance with 10 CFR 72.30(b), financial assurance, for decommissioning, has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b). As demonstrated in Tables 1-4, this provides the requisite financial assurance for the ISFSI decommissioning costs.
Table I NRC Minimum as of 9/30/14, in 2014 Dollars Unit 1                   $166,138,985 Unit 2                   $166,138,985 Totals                    $332,277,970 Table 2 External Trust Fund Balance (Fair Market Value) as of 9/30/14, in 2014 Dollars Unit 1                   $204,944,254 Unit 2                   $205,068,861 Totals                    $410,013,115 Table 3 (ISFSI Decommissioning Costs)
MidAmerican's                                                                                             Burial/
Ownership Share Unit 1 &                                 U.RW                                 Cu.FT     Processed             Utility and Unit 2                     Removal   Packaging Transport Disposal Other     Total     Total   Class A   Weight       Craft Contractor (2014 Dollars w/3.5% Esc)     Costs   Costs     Cost   Costs   Costs Contingency   Costs   LLRW         (Ibs) Manhours   Manhours.
ISFSILicense Termination   28       6         24       80       453   99         690     1,335     111,954     1,904   640 Small Tool Allowance       I       -                       -                       1       -         -           -         -
Property Taxes                                                   91     9           100                                     -
Security Staff Cost                                               65     10         75                                     1,245 Utility Staff Cost         -       -                             93     14         107                                     472 Total                      29       6         24       80       702   132         972     1,335     111,954   1,904     2,356 3
 
Table 4 (Total Decommissioning Costs per NRC Minimum Formulas)
(2014 Dollars)
MidAmerican Energy Company Quad Cities, Units I & 2 (2,957 MWt)
As of 9/30/2014 REACTOR TYPE:                     BWR BASE COST                   130,613,000
($104 + 0.009P (in MWt))
Base Escalation Factors             9130/2014     Factor       Base Year       Source:
Labor                     120.0             2.08           2005       Bureau of Labor Statistics: Series CIU20100000002301 Energy Power                  224.4             114.2           1986       Bureau of Labor Statistics: Series WPU0543 Fuel                    291.3             82.0           1986       Bureau of Labor Statistics: Series WPU0573 Waste Burial             14.16                                         NUREG-1307, Rev 15, Table 2-1 Calculation Labor Factor (L)                     2.50 x 0.65 =               1.62 Labor Formula: CY Factor
* Base Factor Energy Factor (E)                   2.70 x 0.13 =               0.35   Energy Formula: E = 0.54P + 0.46F Waste Factor (B)         14.16           x 0.22 =               3.12 Total Escalation Factor:                                         5.09   Total Escalation Formula: 0.65L + 0.13E + 0.22B Total Minimum Assurance Unit I & 2 (100%):                                                 $1,329,111,8821 MidAmerican Minimum Assurance (25%):                                $ 332,277,971 4}}

Latest revision as of 16:44, 5 February 2020

Proposed Independent Spent Fuel Storage Installation (ISFSI) - Decommissioning Funding Plan for Quad Cities Nuclear Power Station
ML14314A070
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 11/06/2014
From: Cindy Montgomery
MidAmerican Energy Co
To:
Document Control Desk, NRC/NMSS/SFST
References
Download: ML14314A070 (6)
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Text

MidAm erican MidAmerican Energy Drive 4299 N.W. Urbandale ENERGV Urbandale, Iowa 50322 OBSESSIVELY, RELENTLESSLY AT YOUR SERVOCE. 515 281-2976 Telephone 515 979-1201 Cell crmontqomeryd.midamencan.com Chuck Montgomery Managing Senior Attorney 10 CFR 72.30(b)

November 6, 2014 ATTN: Document Control Desk Director - Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR 30 NRC Docket Nos. 50-254, 50-265, and 72-53

Subject:

Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for Quad Cities Nuclear Power Station MidAmerican Energy Company (MidAmerican) owns 25% of Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS), and it provides financial assurance for the decommissioning of its share of QCNPS. Exelon Generation Company, LLC (Exelon) owns the remaining 75% of QCNPS, and it is the licensed operator for the facility. MidAmerican regrets to inform the Nuclear Regulatory Commission of its failure to recognize the new filing requirement established by recent revisions to 10 CFR 72.30, and its consequent failure to make such a filing when due on or before December 17, 2012. MidAmerican recently self-identified this omission and is submitting the attached 10 CFR 72.30 report to fulfill this requirement. MidAmerican plans to file an updated 10 CFR 72.30 report with MidAmerican's March 2015 10 CFR 50.75 biennial report and each subsequent biennial report per 10 CFR 50.75. This will assure that the required information is provided to the NRC on a timely, ongoing basis.

In accordance with 10 CFR 72.30, "Financial assurance and recordkeeping for decommissioning," MidAmerican Energy Company is submitting the proposed ISFSI Decommissioning Funding Plan for QCNPS (Attachment 1). Exelon filed a 10 CFR 72.30(b) report for its 75% ownership interest in QCNPS on December 17, 2012, and MidAmerican relies upon information provided in the Exelon report in the attached plan.

The attached ISFSI Decommissioning Funding Plan includes ISFSI decommissioning cost estimates excerpted from existing reactor decommissioning cost estimates. The QCNPS decommissioning cost estimate assumes that the ISFSI, which has a Part 72 general license, will remain in service following the decommissioning and release of the other portions of the site under Part 50. As a result, the cost estimate assumes that the Part 50 license will be maintained until the ISFSI is decommissioned and the license may be terminated. Decommissioning is defined in 10 CFR 50.2 as the removal of a site from service and reduction of residual radioactivity to a level that permits the termination of the license, so the Part 50 license cannot be P4S52Y(p

November 6, 2014 U.S. Nuclear Regulatory Commission Page 2 terminated until the ISFSI meets residual radioactivity requirements. As a result, the decommissioning of an ISFSI with a Part 72 general license is necessarily a Part 50 decommissioning cost covered by 10 CFR 50.75.

MidAmerican qualifies as an "electric utility" and recovers the costs of decommissioning, including ISFSI decommissioning, through cost of service rate recovery. As such, the attached ISFSI Decommissioning Funding Plan relies on "the methods of 10 CFR 50.75(b), (e), and (h), as applicable" as allowed under new 10 CFR 72.30(e)(5), to demonstrate ISFSI decommissioning financial assurance and does not provide either a new ISFSI-specific decommissioning cost estimate or new ISFSI-specific decommissioning financial assurance methods. Specifically, the Decommissioning Funding Plan relies on MidAmerican's decommissioning funding (10 CFR 50.75) status update (as of September 30, 2014) submitted in the attached ISFSI Decommissioning Funding Plan (Attachment 1).

Please refer any questions regarding the foregoing to the undersigned, Chuck Montgomery, at (515) 281-2976 or at CRMontgomerygmidamnerican.com.

Sincerely, Cc: Regional Administrator- NRC Region III NRC Project Manager - Quad Cities Nuclear Power Station NRC Senior Resident Inspector

ATTACHMENT 1 Proposed ISFSI Decommissioning Funding Plan 1.0

SUMMARY

DESCRIPTION MidAmerican Energy Company (MidAmerican) is a minority owner, with a 25% ownership share, of Quad Cities Nuclear Power Station (QCNPS) Units I and 2. MidAmerican co-owns QCNPS with Exelon Generation Company, LLC (Exelon). Exelon owns a 75% share of Units 1 and 2 and operates both units as well. Exelon and MidAmerican maintain decommissioning cost estimates for QCNPS, which are periodically updated. Imbedded in these decommissioning cost estimates are the costs associated with decommissioning the Independent Spent Fuel Storage Installation (ISFSI) located at QCNPS. The decommissioning cost estimate for the ISFSI have been extracted from the decommissioning cost estimate and are provided herein.

As Exelon has noted in its own 10 CFR 72.30(b) filing, the radiological decommissioning costs for an ISFSI typically consist of the costs associated with removing and disposing of small volumes of neutron-activated concrete and certain structural steel components. Exelon has indicated that no impact is expected upon soil and groundwater at the QCNPS site during the storage period contemplated in the decommissioning cost estimate for the site. Exelon has also noted that induced radioactivity at the QCNPS ISFSI is not expected to result in residual radioactivity in excess of 25 mRem/yr in an unrestricted release scenario, were no action to be taken to remediate the site.

Finally, Exelon has noted that it anticipates small, but measurable amounts of induced radioactivity to be present, and release of this material from the QCNPS site will require it to be disposed of at a NRC-licensed radioactive waste disposal facility. Therefore, Exelon has included the costs of this disposal in the decommissioning cost estimates.

2.0 DETAILED DESCRIPTION 2.1 Reasonable Assurance of Funds Availability MidAmerican's trust fund balances for QCNPS Units I and 2 currently exceed the costs required for radiological decommissioning-see Tables I and 2, below. The excess assets will be used to decommission the on-site ISFSI. Table 1, below, shows the costs estimated for radiological decommissioning under 10 CFR 50.75(b) and (c), using the NRC Minimum formulas, and Table 2 shows MidAmerican's trust fund balances as of September 30, 2014. Both the radiological decommissioning costs and the trust fund balances are stated in 2014 dollars and are adjusted for MidAmerican's 25% ownership share.

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2.2 Detailed Cost Estimate Table 3, below, which is based upon the November 2013 TLG decommissioning cost estimate for QCNPS, details the costs of ISFSI decommissioning in 2014 dollars (MidAmerican escalated the 2011 dollar figures from the Nov. 2013 TLG study using a 3.5% escalation rate). Table 3 shows the costs of performing this work (discussed further in the assumptions below), with an adequate contingency factor, to meet the 10 CFR 20.1402 criteria for unrestricted use. The cost of performing this ISFSI decommissioning work is approximately $486,000 per unit for MidAmerican's 25% share.

2.3 Assumptions Consistent with the assumptions made by Exelon in its own 10 CFR 72.30(b) filing, MidAmerican has made the following assumptions with respect to ISFSI decommissioning:

1. Decommissioning costs in Table 3 are escalated at 3.5% per annum into 2014 dollars. (Exelon escalated costs into 2012 dollars since its 10 CFR 72.30(b) filing was made in late 2012.)
2. All values in Tables 1 - 4 are stated at MidAmerican's 25% ownership share for QCNPS. Costs for ISFSI decommissioning have been equally split between the two (2) units at QCNPS.
3. The costs for ISFSI decommissioning are expected to be incurred in the year in which DOE has accepted all spent fuel from the QCNPS site for disposal.

2.4 Method of Assurance In accordance with 10 CFR 72.30(b)(4), Tables 1 -3 demonstrate the method of assuring funds for ISFSI decommissioning, from 10 CFR 72.30(e). Exelon and MidAmerican periodically update the decommissioning cost estimate for QCNPS, and MidAmerican adjusts the funding levels, as necessary, in accordance with 10 CFR 50.75.

(MidAmerican's annual Iowa jurisdictional decommissioning cost included in the cost of service is $1,595,964, per the Iowa Utilities Board's order in Docket No. RPU-2013-0004. The Illinois Commerce Commission has not authorized any current, ongoing collection from MidAmerican's Illinois ratepayers.)

2.5 Volume of Subsurface Residual Radioactivity Requiring Remediation Per review of site-specific 10 CFR 50.75(g) logs, Exelon indicates it has not identified any onsite, subsurface material containing residual radioactivity at the ISFSI located at QCNPS.

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2.6 Certification of Financial Assurance In accordance with 10 CFR 72.30(b), financial assurance, for decommissioning, has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b). As demonstrated in Tables 1-4, this provides the requisite financial assurance for the ISFSI decommissioning costs.

Table I NRC Minimum as of 9/30/14, in 2014 Dollars Unit 1 $166,138,985 Unit 2 $166,138,985 Totals $332,277,970 Table 2 External Trust Fund Balance (Fair Market Value) as of 9/30/14, in 2014 Dollars Unit 1 $204,944,254 Unit 2 $205,068,861 Totals $410,013,115 Table 3 (ISFSI Decommissioning Costs)

MidAmerican's Burial/

Ownership Share Unit 1 & U.RW Cu.FT Processed Utility and Unit 2 Removal Packaging Transport Disposal Other Total Total Class A Weight Craft Contractor (2014 Dollars w/3.5% Esc) Costs Costs Cost Costs Costs Contingency Costs LLRW (Ibs) Manhours Manhours.

ISFSILicense Termination 28 6 24 80 453 99 690 1,335 111,954 1,904 640 Small Tool Allowance I - - 1 - - - -

Property Taxes 91 9 100 -

Security Staff Cost 65 10 75 1,245 Utility Staff Cost - - 93 14 107 472 Total 29 6 24 80 702 132 972 1,335 111,954 1,904 2,356 3

Table 4 (Total Decommissioning Costs per NRC Minimum Formulas)

(2014 Dollars)

MidAmerican Energy Company Quad Cities, Units I & 2 (2,957 MWt)

As of 9/30/2014 REACTOR TYPE: BWR BASE COST 130,613,000

($104 + 0.009P (in MWt))

Base Escalation Factors 9130/2014 Factor Base Year Source:

Labor 120.0 2.08 2005 Bureau of Labor Statistics: Series CIU20100000002301 Energy Power 224.4 114.2 1986 Bureau of Labor Statistics: Series WPU0543 Fuel 291.3 82.0 1986 Bureau of Labor Statistics: Series WPU0573 Waste Burial 14.16 NUREG-1307, Rev 15, Table 2-1 Calculation Labor Factor (L) 2.50 x 0.65 = 1.62 Labor Formula: CY Factor

  • Base Factor Energy Factor (E) 2.70 x 0.13 = 0.35 Energy Formula: E = 0.54P + 0.46F Waste Factor (B) 14.16 x 0.22 = 3.12 Total Escalation Factor: 5.09 Total Escalation Formula: 0.65L + 0.13E + 0.22B Total Minimum Assurance Unit I & 2 (100%): $1,329,111,8821 MidAmerican Minimum Assurance (25%): $ 332,277,971 4
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