ML11136A185

ME5494; ME5501 and 02; ME5506 and 07; ME5540 and 42 - 2011 Decommissioning Funding Status (DFS) Report - Request for Additional Information (RAI) - Final Version

ML11136A185
Person / Time
Site:	Millstone, Kewaunee, Surry, North Anna
Issue date:	05/16/2011
From:	Feintuch K Division of Operating Reactor Licensing
To:	Sommers D
References
Download: ML11136A185 (5)

Text

NRR-PMDAPEm Resource From: Feintuch, Karl Sent: Monday, May 16, 2011 12:04 PM To: david.sommers@dom.com; tom.szymanski@tom.com Cc: Simpson, JoAnn; Purdie, Michael; Dusaniwskyj, Michael

Subject:

ME5494; ME5501 and 02; ME5506 and 07; ME5540 and 42 - 2011 Decommissioning Funding Status (DFS) report - Request for Additional Information (RAI) - final version Attachments: ME5494 et al Dominion DFS RAIs rev 1.docx In a letter dated March 29, 2011, Agencywide Document and Management System (ADAMS) Accession No.

ML110900375, Dominion Resources Services (Dominion), on behalf of the below-listed plants, submitted to the Nuclear Regulatory Commission (NRC) the 2011 Decommissioning Funding Status (DFS) Report for:

Surry Power Station Units 1 and 2, North Anna Power Station Units 1 and 2, Millstone Power Station Units 1, 2, and 3, and Kewaunee Power Station, as required under Title 10 of the Code of Federal Regulations (10 CFR) Part 50.75(f)(1)

In an email dated May 5, 2011, the NRC send a draft set of RAI items to Dominion (ADAMS Accession No.

ML11129A007). This set of RAI items was the agenda of a clarification conference call on May 12, 2011, with the following attendance:

NRC Attendance:

Feintuch, Karl, (LPL3-1) - NRC point of contact (Joel Wiebe is backup point of contact)

Purdie, Michael (PFIB)

Simpson, JoAnn (PFIB)

Dusaniwskyj, Michael (PFIB)

Mizuno, Beth (OGC)

Dominion Attendance:

Richard Anderson (Finance)

Dave Sommers (Lic. Supervisor) Backup point of contact Lee Thomasson (Corp. RP)

Tom Szymanski (Corp. Lic. and ReadyTalk host) Dominion point of contact The May 12, 2011 discussion resulted in changes to the draft set of RAI items. The resulting final set of RAI items is attached. As before, these RAI items originate with the NRCs Financial Analysis and International Projects Branch, Division of Policy and Rulemaking, Office of Nuclear Reactor Regulation. The cognizant reviewers are JoAnn Simpson and Michael Purdie.

A response to these items is requested within 30 days (that is, on or before June 15, 2011).

As before, if there are any questions, please contact me.

Karl Feintuch Project Manager for Kewaunee Power Station and Dominion Fleet Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-3079 1

Hearing Identifier: NRR_PMDA Email Number: 28 Mail Envelope Properties (Karl.Feintuch@nrc.gov20110516120400)

Subject:

ME5494; ME5501 and 02; ME5506 and 07; ME5540 and 42 - 2011 Decommissioning Funding Status (DFS) report - Request for Additional Information (RAI) - final version Sent Date: 5/16/2011 12:04:00 PM Received Date: 5/16/2011 12:04:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients:

"Simpson, JoAnn" <JoAnn.Simpson@nrc.gov>

Tracking Status: None "Purdie, Michael" <Michael.Purdie@nrc.gov>

Tracking Status: None "Dusaniwskyj, Michael" <Michael.Dusaniwskyj@nrc.gov>

Tracking Status: None "david.sommers@dom.com" <david.sommers@dom.com>

Tracking Status: None "tom.szymanski@tom.com" <tom.szymanski@tom.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 2111 5/16/2011 12:04:00 PM ME5494 et al Dominion DFS RAIs rev 1.docx 25042 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR NORTH ANNA POWER STATION, UNITS 1 AND 2; SURRY POWER STATION, UNITS 1 AND 2; KEWAUNEE POWER STATION; AND MILLSTONE POWER STATION, UNITS 2 AND 3 The Request for Additional Information (RAI) provided is in response to the Virginia Electric and Power Company (Dominion), Dominion Nuclear Connecticut Inc. (DNC), and Dominion Energy Kewaunee Inc.s (DEK), (collectively the licensees), 2011 Decommissioning Funding Status (DFS) report. On March 29, 2011, Dominion submitted to the Nuclear Regulatory Commission (NRC) the 2011 Decommissioning Funding Status (DFS) report for North Anna Power Station, Units 1 and 2 (North Anna 1 and 2), Surry Power Station, Units 1 and 2 (Surry 1 and 2),

Kewaunee Power Station (Kewaunee), and Millstone Power Station, Units 2 and 3 (Millstone 2 and 3) as required under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.75(f)(1) (Agencywide Documents Access Management System (ADAMS) Accession No.

ML110900375). Dominion should provide a response within 30 days from receipt of these RAI items (On or before June 15, 2011).

RAI #1: Basis for real rate of returns:

DEK:

Provide the basis for the assumptions used regarding rates of escalation in decommissioning costs, rates earnings on decommissioning funds, and rates of other factors assumed in the DFS report.

On March 29, 2011, DEK reported a 2 percent real rate of return on its decommissioning trust fund for Kewaunee.

Dominion and DNC:

Provide the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

Also, provide the citation (e.g., an Order by the rate-regulatory authority) by the regulatory entities that allows for the assumptions used. If necessary, please submit a corrected submittal.

On March 29, 2011, Dominion reported a 2 percent real rate of return on its decommissioning trust funds for its share in North Anna 1 and 2 and for Surry 1 and 2. DNC reported a 2 percent real rate of return on its decommissioning trust funds for Millstone 2 and 3. However, Dominion and DNC did not provide their assumptions for escalation in decommissioning costs, rates of

earnings on decommissioning funds, and rates of other factors used in funding projections, or their citations (e.g., an Order) by the regulatory entities that allows for their assumptions.

As stated in 10 CFR 50.75(f)(1):

[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . .

RAI #2: Reporting requirements:

Indicate if there are contracts upon which the licensees are relying under paragraph 10 CFR 50.75(e)(1)(v) and if there were any modifications to the licensees current method of providing financial assurance since the last submitted report.

In the DFS report submitted on March 29, 2011, the licensees provided information required under 10 CFR 50.75(f)(1), but did not indicate if there are any contracts upon which they are relying upon or if there were any modifications occurring to the licensees current method of providing financial assurance since the last submitted report.

As stated under 10 CFR 50.75(f)(1):

[T]he information in [the DFS] report must include [. . .] any contracts upon which the licensee is relying under paragraph (e)(1)(v) of this section; any modifications occurring to a licensees current method of providing financial assurance since the last submitted report. . .

RAI #3: Annual Contributions:

Dominion:

Indicate whether the current annual contributions identified in the DFS report for North Anna 1 and 2 and Surry 1 and 2 are the annual decommissioning contributions for radiological decommissioning. If not, provide a breakdown of the annual decommissioning contributions that will be accumulated for only radiological decommissioning costs. Also, provide a schedule of the annual decommissioning contributions remaining to be collected.

Within the DFS report, Dominion included the annual funding levels, but did not indicate if the annual funding levels include contributions towards non-radiological decommissioning costs, or provide a schedule of the annual amounts remaining to be collected.

As stated under 10 CFR 50.75(f)(1):

[T]he information in [the DFS] report must include [. . .] a schedule of the annual amounts remaining to be collected. . .

RAI #4: After-tax decommissioning funds as of December 31, 2010:

Indicate if the amounts of decommissioning funds that are identified within the DFS report are the after-tax amount of funds accumulated through December 31, 2010. If not, provide the after-tax amount of decommissioning funds accumulated through December 31, 2010.

Within the DFS report, the licensees provided the amounts of funds in the trust as of 12/31/2010, but did not indicated if the amounts stated were the before or after-tax balances.

The provisions of 10 CFR 50.75(f)(1) and (2) require the licensee to report the amount of funds accumulated to the end of the calendar year preceding the report.