ML082910039
| ML082910039 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/14/2008 |
| From: | Bethay S Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.08.052, FOIA/PA-2009-0026, TAC MD8036, TAC MD9416, FOIA/PA-2013-0151 | |
| Download: ML082910039 (8) | |
Text
EnteW Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay Director, Nuclear Assessment October 14, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Response to 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS. MD8036 and MD9416)
REFERENCE:
- 1. NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS. MD8036 and MD9416)", dated September 12, 2008
- 2. Entergy Letter, "Spent Fuel Management Plan Submittal in accordance with10 CFR 50.54(bb)", dated June 7, 2007
- 3. Entergy Letter, "PNPS Report Pursuant to 10 CFR 50.75(f)(3)",
dated July 31, 2008
- 4. Entergy Letter, "Annual Report of Proof of Financial Protection", dated March 26, 2008 LETTER NUMBER: 2.08.052
Dear Sir or Madam:
This letter provides the response to the NRC Request for Additional Information (Reference 1) regarding Entergy Nuclear Operations, Inc. (ENO), Pilgrim Nuclear Power Station's (PNPS) following documents: "Spent Fuel Management Plan Submittal in accordance with10 CFR 50.54(bb)", dated June 7, 2007 (Reference 2) and "PNPS Report Pursuant to 10 CFR 50.75(f)(3)", dated July 31, 2008 (Reference 3). The additional information is provided in Attachment 1 to this letter.
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Entergy Nuclear Operations, Inc. Letter Number 2.08.052 Pilgrim Nuclear Power Station Page 2 If you have any questions or require additional information, please contact Mr. Joseph R. Lynch, Licensing Manager, at (508) 830-8403.
This letter contains no commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the ______of_____ 2008.
Sincerely, Ate en J ethay urance Director, Nuclear Safet MJG/dI
Attachment:
- 1. Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3)
(TAC NOS. MD8036 and MD9416) cc: Mr. James S. Kim, Project Manager Regional Administrator, Region 1 Plant Licensing Branch I-1 U.S. Nuclear Regulator Commission Division of Operator Reactor Licensing 475 Allendale Road Office of Nuclear Reactor Regulation King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission One White Flint North O-8C2 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector Pilgrim Nuclear Power Station
Attachment 1 to Letter 2.08.052 Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS. MD8036 and MD9416)
(5 Pages) 208052
Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS. MD8036 and MD9416)
/
Spent Fuel Management Program (SFMP) and Preliminary Decommissioning Cost Estimate (PDCE)
NRC RAI No. 1: Section 5 of the SFMP, Financial Assurance and Section 1.7.1 of the PDCE, Spent FuelDisposition 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?
Entergy Response:
Pilgrim Nuclear Power Station (PNPS) Spent Fuel Management plan assumes withdrawals from the decommissioning trust for spent fuel management purposes.
Entergy will make appropriate submittals 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.
Entergy will also monitor the decommissioning fund to ensure that spent fuel management withdrawals will not inhibit the ability of Entergy to complete'radiological decommissioning.
It should be noted that the projected expenditures for spent fuel management identified in the preliminary decommissioning cost analysis do not include any credit or offset for costs that may be incurred by the licensee, Entergy Nuclear Operations, Inc. (ENO), as a result of the Department of Energy's (DOE) failure in the timely removal of spent fuel from the site pursuant to the DOE contractual obligations (Nuclear Waste Policy Act).
ENO believes that the extended spent fuel management costs are compensable damages incurred by ENO that should be paid by DOE because DOE failed to comply with the contractual obligations for the disposal of spent fuel for the site. This would provide an alternate source of funds for spent fuel management, and as such, the results of litigation or potential changes in future government policy could reduce or eliminate the need to make withdrawals from the trust fund for spent fuel management. However, the analysis for the Spent Fuel Management Program conservatively assumes that these costs are not recovered from DOE.
280052 Page 1of 5
Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS. MD8036 and MD9416)
Preliminary Decommissioning Cost Estimate (PDCE)
NRC 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.
Entergy Response:
A 3% inflation rate (along with a 5% earnings rate) has been used by the licensee in the past to escalate the estimated decommissioning cost in the 10 CFR 50.75(f)(1) reports on the status of the decommissioning funding for the Pilgrim Nuclear Power Station (Reference 4). It was used in the Table 8 analyses for consistency with the assumptions in the 50.75(f)(1) reports for future escalation of decommissioning costs.
280052 Page 2 of 5
Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS. MD8036 and MD9416)
NRC 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.
Entergy Response:
The original Table 8 displays the results of a present value method which solved for the required rate of return necessary to end up with a net zero balance for the trust fund at the completion of decommissioning. The analysis showed a real rate of return less than 2% would be required for this scenario.
However, a more basic method that the licensee believes is acceptable to the Staff is to escalate the trust fund balance of $621.74 million assuming a 2% rate of return and compare the earnings against the costs shown in Table 7 for license termination and spent fuel. As shown in the attached Revised Table 8; this results in a positive balance at the conclusion of decommissioning, confirming that there/ are more than sufficient funds for both activities (radiological and spent fuel). The licensee requests that the Staff substitute the Revised Table 8 in the licensee's plan for the original Table 8. The calculation methodology for Revised Table 8 is shown at the end of the table.
(Using the values of 3% inflation and 4.47% in the attached table, the decommissioning trust fund would net to $0 at the conclusion of the decommissioning process, consistent with the analysis previously provided in the original Table 8.)
280052 Page 3 of 5
Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS.
MD8036 and MD9416)
Pilgrim Nuclear Station Decommissioning Funding Plan (thousands of 2007 dollars)
Table 8 (Revised)
Basis Year 2007 Fund Balance $621.740 (millions)
Annual Escalation 0.00%
Annual Earninngs 2.00%
A B C D E Total License 50.75 50.54(bb) Termination Decommissioning License Spent Fuel and Spent Fuel Trust Fund Termination Management Management Total Cost Escalated at 2%
Cost Cost Cost Escalated at 0% (minus expenses)
Year (millions) (millions) (millions) (millions) (millions) .
2007 - 621.740 2008 - 634.175 2009 - 646.858 2010 - 659.795 2011 - 672.991 2012 28.119 7.203 35.322 35.322 651.129 2013 75.178 12.725 87.903 87.903 576.249 2014 0.655 35.706 36.361 36.361 551.413 2015 0.655 35.706 36.361 36.361 526.080 2016 0.657 35.804 36.461 36.461 500.141 2017 0.655 33.783 34.438 34.438 475.705 2018 0.655 6.456 7.111 7.111 478.109 2019 0.655 6.456 7.111 7.111 480.560 2020 0.657 6.474 7.131 7.131 483.040 2021 0.655 6.456 7.111 7.111 485.590 2022 0.655 6.456 7.111 7.111 488.190 2023 0.655 6.456 7.111 7.111 490.843 2024 0.657 6.474 7.131 7.131 493.529 2025 0.655 6.456 7.111 7.111 496.289 2026 0.655 6.456 7.111 7.111 499.104 2027 0.655 6.456 7.111 7.111 501.975 2028 0.657 6.474 7.131 7.131 504.883 2029 0.655 6.456 7.111 7.111 507.870 2030 0.655 6.456 7.111 7.111 510.916 2031 0.655 6.456 7.111 7.111 514.023 2032 0.657 6.474 7.131 7.131 517.173 2033 0.655 6.456 7.111 7.111 520.405]
28(X)52 Page 4 of 5
Entergy Response to NRC 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 Cost Estimate Pursuant to 10 CFR 50.75(f)(3) (TAC NOS.
MD8036 and MD9416)
Pilgrim Nuclear Station Decommissioning Funding Plan (thousands of 2007 dollars)
Table 8 (Revised)
Basis Year 2007 Fund Balance $621.740 (millions)
Annual Escalation 0.00%
Annual Earnings 2.00% ..............
A B C D E Total License 50.54(bb) Termination Decommissioning 50.75 Spent Fuel and Spent Fuel Trust Fund License Management Management Total Cost Escalated at 2%
Termination Cost Cost Escalated at 0% (minus expenses)
Year Cost (millions) (millions) (millions) (millions) (millions) 2034 0.655 6.456 7.111 7.111 523.703 2035 0.655 6.456 7.111 7.111 527.066 2036 0.657 6.474 7.131 7.131 530.476 2037 0.655 6.456 7.111 7.111 533.974 2038 0.655 6.456 7.111 7.111 537.543 2039 0.655 6.456 7.111 7.111 541.183 2040 0.657 6.474 7.131 7.131 544.875 2041 0.655 6.456 7.111 7.111 548.662 2042 0.767 6.438 7.205 7.205 552.430 2043 41.452 - 41.452 41.452 522.027 2044 102.047 - 102.047 102.047 430.420 2045 95.513 1.246 96.759 96.759 342.270 2046 74.110 1.684 75.794 75.794 273.321 2047 74.110 1.684 75.794 75.794 202.993 2048 39.177 0.426 39.603 39.603 167.450 2049 0.798 1.013 1.811 1.811 168.988 2050 0.182 0.230 0.412 0.412 171.956 549.81 328.70 878.51 878.51 Calculations:
Column C = A + B Column D = (C)*(1 +0%)A(current year - 2007) or for 0%, D = C Column E = (Previous year's fund balance) * (1 + .02) - D (current year's decommissioning expenditures) 280052 Page 5 of 5