ML18109A069

Summary of April 10, 2018, Meeting with Indiana Michigan Power Company Regarding Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2

ML18109A069
Person / Time
Site:	Cook
Issue date:	04/26/2018
From:	Dietrich A Plant Licensing Branch III
To:	Gebbie J Indiana Michigan Power Co
Dietrich A
References
Download: ML18109A069 (5)

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• • • ... April 26, 2018 LICENSEE: Indiana Michigan Power Company, LLC FACILITY: Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2

SUMMARY

OF APRIL 10, 2018, MEETING WITH INDIANA MICHIGAN POWER COMPANY REGARDING DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND2 On April 10, 2018, a Category I public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Indiana Michigan Power Company (l&M, the licensee) via teleconference. This meeting was open to members of the public. No regulatory decisions were made at this meeting.

The purpose of the meeting was to discuss the decommissioning trust funds for Donald C. Cook Nuclear Plant (CNP), Unit Nos. 1 and 2. The licensee submitted its Decommissioning Funding Status Report to the NRC via letter dated March 21, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17081A443). The meeting notice and agenda, dated March 26, 2018, are available in ADAMS at Accession No. ML18085A008. A list of attendees is included as Enclosure 1 to this memorandum.

The NRC staff began the teleconference by providing background information and discussing the reason for the meeting. The NRC staff stated that in l&M's 2017 submittal of the CNP Decommissioning Funding Status Reports, required by Title 10 of the Code of Federal Regulations ( 10 CFR) Section 50. 75(f)( 1), l&M reported the amount of funds allocated for radiological decommissioning for items included in 10 CFR, Sections 50.75(b) and 50.75(c), to be $877,702,748, collectively, for both CNP Unit 1 and Unit 2. During the NRC staff review of this submittal, the staff observed that the amount of funds that had been reported by l&M in 2015 as allocated for radiological decommissioning was $1,027,257,392, collectively, for both CNP Unit 1 and Unit 2. The NRC staff calculated that the amount allocated for radiological decommissioning had decreased by $149,554,644, collectively, for both CNP Unit 1 and Unit 2, or $78,470,927 and $71,083,717 for CNP, Units 1 and 2, respectively, from 2015 to 2017.

Thus, the public teleconference was requested in order for the NRC staff to obtain clarification from the licensee regarding the reason for the decrease in funds.

The NRC staff asked the licensee whether there had been a withdrawal of funds from the decommissioning trust fund, and if not, to explain the decrease in funds allocated for radiological decommissioning. In response to the staff's question, the licensee affirmed that there had been no withdrawals. The licensee stated that the total value of the account had increased, in alignment with overall market conditions, but that the amount specifically allocated

toward radiological decommissioning had decreased. The licensee explained that the decrease was due to a 2017 site-specific cost study at CNP, which determined that additional funding would be required in the future for spent fuel management. Therefore, the licensee had reallocated a percentage of the funds in the trust account, previously allocated for radiological decommissioning, to be used for future maintenance of CNP's independent spent fuel storage installation (ISFSI), pursuant to 10 CFR 50.54(bb). The licensee stated that in crafting its biennial submittal to the NRC, it had followed the guidance provided in Regulatory Issue Summary (RIS) 2001-07, Revision 1, "10 CFR 50.75 Reporting and Recordkeeping for Decommissioning Planning," dated January 8, 2009 (ADAMS Accession No. ML083440158).

RIS 2001-07, Revision 1, discusses "the need to preserve the distinction between funds accumulated for radiological decommissioning which licensees are required to report, and funds accumulated for other purposes."

The NRC staff stated that funds that have previously been reported as dedicated for radiological decommissioning cannot be repurposed. Thus, the amount of funds reported biennially is generally expected to increase over time unless adversely affected by market conditions. The NRC staff referenced 10 CFR 50. 75(h)(2), which states, "Disbursements or payments from the trust, escrow account, Government fund, or other account used to segregate and manage the funds, [ ... ]are restricted to decommissioning expenses." In response to this statement, the licensee declared that it had not made a disbursement from the account, only reallocated the funds in the account for future ISFSI (spent fuel management) expenses.

The NRC staff concluded the meeting by informing the licensee that if additional written explanation were required, the licensee would be informed by future correspondence.

Members of the public were not in attendance. Public Meeting Feedback forms were not received. Please direct any inquiries to me at 301-415-3826, or Allison.Dietrich@nrc.gov.

f/AI tit Allison W. Dietrich, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

1. List of Attendees Cc: Listserv

LIST OF ATTENDEES APRIL 10, 2018, PUBLIC MEETING WITH l&M, LLC DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 DECOMMISSIONING FUNDING STATUS REPORT Name Organization Allison Dietrich NRC Richard Turtil NRC Anita Ghosh NRC Kosmas Lois NRC Jennivine Rankin NRC Anthony Bowers NRC Helen Levendosky* l&M Ginger Hartman* l&M Bud Haemer* l&M Randy Arnold* l&M Daniel Hunt* l&M Laura Fletcher* l&M

• Participated by telephone Enclosure

ML18109A069 OFFICE DORL/LPL3-1 /PM DORL/LPL3-1/LA DLP/PFPB/BC DORL/LPL3-1 /BC DORL/LPL3-1 /PM NAME ADietrich SRohrer ABowers DWrona ADietrich DATE 4/23/18 4/23/18 4/23/18 4/26/18 4/26/18