ML19095A010

Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

ML19095A010
Person / Time
Site:	Three Mile Island
Issue date:	04/05/2019
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TM-19-024
Download: ML19095A010 (49)

Text

Exelon TM-19-024 April 5, 2019 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR 50 NRG Docket No. 50 289 Michael P. Gallagher Exelon Nuclear Vice President License Renewal and Decommiss1onmg 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.82(a)(4)(i)

Subject:

Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

References:

1) Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (ML17171A151)

2) Letter from Patrick Simpson, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission

-"Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," dated April 1, 2019 (ML 19091A140)

Pursuant to 1 O CFR 50.82(a)(4)(i), Exelon Generation Company, LLC (Exelon) is submitting the site-specific decommissioning cost estimate (DCE) for Three Mile Island Nuclear Station, Unit 1 (TMl-1). On June 20, 2017, in accordance with 10 CFR 50.82(a)(1)(i), Exelon informed the U.S. Nuclear Regulatory Commission (NRG) that TMl-1 will permanently cease power operations on or about September 30, 2019 (Reference 1 ). In accordance with 10 CFR 50.54(bb) and 1 O CFR 50.82(a)(4)(i), Exelon is required to submit a Spent Fuel Management Plan (SFMP), Site Specific Decommissioning Cost Estimate (DCE), and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations.

The TMl-1 PSDAR and SFMP are being submitted under separate cover letters. Attachment 1 to this letter provides the TMl-1 DCE. The latest Decommissioning Funding Report for TMI was submitted in Reference 2, Attachment

30. The minimum formula cost amount using the formula in 1OCFR50.75(c) has been calculated assuming the labor, energy, and burial factors described in Attachment 1 of Reference

2. The site-specific cost amount reported in the DCE is greater than the minimum formula cost amount, as required by 1 O CFR 50.75(b)(1

). Attachment 2 to this letter contains the projected annual cash flow from the Nuclear Decommissioning Trust Fund (NDTF) for TMl-1 radiological decommissioning.

The cost in U.S. Nuclear Regulatory Commission Site-Specific Decommissioning Cost Estimate Docket Nos. 50-289 April 5, 2019 Page2 Attachment 2 for radiological decommissioning (including decommissioning for the proposed Independent Spent Fuel Storage Installation (ISFSI)) are from Attachment 1, Table 6-2, which have been escalated from June 2018 dollars in Attachment 1, to December 31, 2018 dollars using an escalation rate of 1.42% (which corresponds to an APR of 2.8638%).

The NDTF balance as of December 31, 2018 was $669,617,225.

The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention).

Attachment 2 demonstrates that adequate funding is available in the NDTF to complete radiological decommissioning.

Pursuant to 10 CFR 50.75(f)(1) and 1 O CFR 50.82(8)(v) the financial assurance summary report will be updated and submitted to the NRC annually.

The cost estimates and financial levels will be adjusted in accordance with Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (applicable revision at the time) and will be used to demonstrate funding assurance.

If the funding assurance demonstration shows the decommissioning trust fund is not sufficient, then an alternate funding mechanism allowed by 1 o CFR 50.75(e) and the guidance provided in the Regulatory Guide, will be put in place at an appropriate time. The DCE (Attachment

1) and the Decommissioning Annual Cash Flows (Attachment

2) were inputs to the PSDAR, with the PSDAR providing summaries of the conclusions.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264. Respectfully, Attachment 1: Three Mile Island Nuclear Station -Unit 1 -Site-Specific Decommissioning Cost Estimate Attachment 2: Three Mile Island Nuclear Station -Unit 1 -Annual Decommissioning Fund Cash Flow cc: w/Attachment Regional Administrator

-NRC Region I NRC Senior Resident Inspector-Three Mile Island Nuclear Station -Unit 1 NRC Project Manager, NRR -Three Mile Island Nuclear Station -Unit 1 NRC Project Manager, NMSS/DUWP/RDB

-Three Mile Island -Unit 2 Director, Bureau of Radiation Protection

-PA Department of Environmental Resources Attachment 1 : Three Mile Island Nuclear Station -Unit 1 Site-Specific Decommissioning Cost Estimate Exelon TM-19-024 April 5, 2019 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR 50 NRG Docket No. 50 289 Michael P. Gallagher Exelon Nuclear Vice President License Renewal and Decommiss1onmg 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.82(a)(4)(i)

Subject:

Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

References:

1) Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (ML17171A151)

2) Letter from Patrick Simpson, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission

-"Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," dated April 1, 2019 (ML 19091A140)

Pursuant to 1 O CFR 50.82(a)(4)(i), Exelon Generation Company, LLC (Exelon) is submitting the site-specific decommissioning cost estimate (DCE) for Three Mile Island Nuclear Station, Unit 1 (TMl-1). On June 20, 2017, in accordance with 10 CFR 50.82(a)(1)(i), Exelon informed the U.S. Nuclear Regulatory Commission (NRG) that TMl-1 will permanently cease power operations on or about September 30, 2019 (Reference 1 ). In accordance with 10 CFR 50.54(bb) and 1 O CFR 50.82(a)(4)(i), Exelon is required to submit a Spent Fuel Management Plan (SFMP), Site Specific Decommissioning Cost Estimate (DCE), and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations.

The TMl-1 PSDAR and SFMP are being submitted under separate cover letters. Attachment 1 to this letter provides the TMl-1 DCE. The latest Decommissioning Funding Report for TMI was submitted in Reference 2, Attachment

30. The minimum formula cost amount using the formula in 1OCFR50.75(c) has been calculated assuming the labor, energy, and burial factors described in Attachment 1 of Reference

2. The site-specific cost amount reported in the DCE is greater than the minimum formula cost amount, as required by 1 O CFR 50.75(b)(1

). Attachment 2 to this letter contains the projected annual cash flow from the Nuclear Decommissioning Trust Fund (NDTF) for TMl-1 radiological decommissioning.

The cost in U.S. Nuclear Regulatory Commission Site-Specific Decommissioning Cost Estimate Docket Nos. 50-289 April 5, 2019 Page2 Attachment 2 for radiological decommissioning (including decommissioning for the proposed Independent Spent Fuel Storage Installation (ISFSI)) are from Attachment 1, Table 6-2, which have been escalated from June 2018 dollars in Attachment 1, to December 31, 2018 dollars using an escalation rate of 1.42% (which corresponds to an APR of 2.8638%).

The NDTF balance as of December 31, 2018 was $669,617,225.

The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention).

Attachment 2 demonstrates that adequate funding is available in the NDTF to complete radiological decommissioning.

Pursuant to 10 CFR 50.75(f)(1) and 1 O CFR 50.82(8)(v) the financial assurance summary report will be updated and submitted to the NRC annually.

The cost estimates and financial levels will be adjusted in accordance with Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (applicable revision at the time) and will be used to demonstrate funding assurance.

If the funding assurance demonstration shows the decommissioning trust fund is not sufficient, then an alternate funding mechanism allowed by 1 o CFR 50.75(e) and the guidance provided in the Regulatory Guide, will be put in place at an appropriate time. The DCE (Attachment

1) and the Decommissioning Annual Cash Flows (Attachment

2) were inputs to the PSDAR, with the PSDAR providing summaries of the conclusions.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264. Respectfully, Attachment 1: Three Mile Island Nuclear Station -Unit 1 -Site-Specific Decommissioning Cost Estimate Attachment 2: Three Mile Island Nuclear Station -Unit 1 -Annual Decommissioning Fund Cash Flow cc: w/Attachment Regional Administrator

-NRC Region I NRC Senior Resident Inspector-Three Mile Island Nuclear Station -Unit 1 NRC Project Manager, NRR -Three Mile Island Nuclear Station -Unit 1 NRC Project Manager, NMSS/DUWP/RDB

-Three Mile Island -Unit 2 Director, Bureau of Radiation Protection

-PA Department of Environmental Resources Attachment 1 : Three Mile Island Nuclear Station -Unit 1 Site-Specific Decommissioning Cost Estimate