ML20279A586

U.S. Nuclear Regulatory Commission'S Analysis of Constellation Energy Nuclear Group, Llc'S Initial Decommissioning Funding Plans for the Calvert Cliffs, Nine Mile Point, and R.E. Ginna Independent Spent Fuel Storage Installation

ML20279A586
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna, 07200087
Issue date:	11/20/2020
From:	John Mckirgan Storage and Transportation Licensing Branch
To:	Shawn Smith Constellation Energy Group
White B
References
CAC 001028, EPID L-2017-FPR-0013, EPID L-2017-FPR-0045, EPID L-2017-FPR-0058
Download: ML20279A586 (4)

Text

November 20, 2020 Shane Smith, Vice President Finance Constellation Energy 1310 Point Street Baltimore, MD 21231

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF CONSTELLATION ENERGY NUCLEAR GROUP, LLCS INITIAL DECOMMISSIONING FUNDING PLANS FOR THE CALVERT CLIFFS, NINE MILE POINT, AND R.E. GINNA INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS

Dear Mr. Smith:

By letter dated December 17, 2012, Constellation Energy Nuclear Group, LLC (CENG) submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, the initial decommissioning funding plans (DFPs) for the Independent Spent Fuel Storage Installations (ISFSIs) at Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); Nine Mile Point Nuclear Station, Units 1 and 2 (Nine Mile Point); and R.E. Ginna Nuclear Power Plant (R.E.

Ginna) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML123550040). The NRC staff notes that Exelon Generating Company, LLC (Exelon) now holds the licenses for these facilities. 1 In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Sections 72.30(b),

and using NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance, the NRC staff reviewed the initial DFPs submitted by CENG, including the initial decommissioning cost estimates (DCEs) and the method of assuring funds for decommissioning.

Pursuant to 10 CFR 72.30(b), each holder of, or applicant for, a license under Part 72 must submit for NRC review and approval a DFP containing information on how reasonable assurance will be provided that funds will be available to decommission its ISFSIs. The DFP must contain a detailed DCE, in an amount reflecting: (1) the cost of an independent contractor to perform all decommissioning activities, (2) an adequate contingency factor, and (3) the cost of meeting the 10 CFR 20.1402 unrestricted use criteria (or the cost of meeting the 10 CFR 20.1403 restricted use criteria, provided the licensee can demonstrate its ability to meet these criteria). The licensees DFP must also identify and justify using the key assumptions 1 Exelon is an intermediate parent company and also is the co-licensee and the operator of Calvert Cliffs, R.E. Ginna, and Nine Mile Point nuclear power plants (NPPs). Exelon assumed the licenses for the operation of the facilities and associated ISFSIs, but the ownership of these facilities did not change (ADAMS Accession No. ML14063A125; ADAMS Accession No. ML14063A211; and ADAMS Accession No. ML14106A053).

By letter dated March 31, 2015, Exelon submitted updated DFPs for the ISFSIs at Calvert Cliffs; Nine Mile Point; and R.E. Ginna (ADAMS Accession No. ML15090A537). Included in the 2015 submission was information on other Exelon-licensed ISFSIs. Exelon provided RAI responses addressing the 2015 DFPs to the NRC staff on May 2, 2018 (ADAMS Accession No. ML18124A197).

S. Smith contained in the DCE. Further, the DFP must describe the method of assuring funds for ISFSI decommissioning, including means for adjusting cost estimates and associated funding levels periodically over the life of the ISFSI. Additionally, the DFP must specify the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination and contain a certification that financial assurance for ISFSI decommissioning has been provided in the amount of the DCE.

The NRC staff reviewed and analyzed the information submitted by CENG on how reasonable assurance will be provided that funds will be available to decommission the ISFSIs, including the amount of the DCE and the method of assuring funds for decommissioning.

CENG estimated the total costs to decommission the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna for unrestricted use were $2,059,000, $2,163,000 2, and $2,232,000, respectively, in 2012 dollars. Based on its analysis of CENGs submittals, the staff finds that the submitted DCEs for 2012: 1) are based on reasonable costs of a third-party contractor;

2) include an adequate contingency factor; 3) reflect the cost of meeting the 10 CFR 20.1402 unrestricted use criteria; and 4) are based on reasonable and documented assumptions.

Therefore, the NRC staff finds that the DCEs adequately estimate the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCEs are acceptable.

CENG relied on prepayment, as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 72.30(e)(1). The NRC staff finds that the 2012 aggregate dollar amount of the licensees financial instruments provided adequate financial assurance to cover its cost estimates, and therefore, that these financial instruments are acceptable.

Based on its review, the NRC staff finds that the Initial DFPs contained the information required by 10 CFR 72.30(b) and that CENG provided reasonable assurance that funds will be available to decommission the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna.

Pursuant to 10 CFR 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the DFP required to be submitted by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination.

Because Exelon is co-licensee and operator of the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna, Exelon submitted updated DFPs for the ISFSIs in 2015, as required by 10 CFR 72.30(c). As discussed above, it did so by letter dated March 31, 2015 (ADAMS Accession No. ML15090A537). The NRC staff provided its financial analyses of the updated DFPs submitted by Exelon for Calvert Cliffs; Nine Mile Point; and R.E. Ginna by separate letter (ADAMS Accession No. ML20279A501). The financial analyses of Exelons 2015 DFP submission under 10 CFR 72.30(c) are not presented in this letter. 3 2 Value is based on the Long Island Power Authority (LIPA) ownership share of Nine Mile Point Nuclear Station, Unit 2 of 18%. Since LIPAs DCE and DFP are included in the CENG letter, the NRC included its assessment of LIPAs portion of the decommissioning costs in this letter. Total DCE for R.E. Ginna is

$2,163,000 with individual DCEs for CENG of $1,821,000 and $342,000 for LIPA.

3 The NRC staff provided its financial analyses of the DFPs for Exelons other licensed ISFSIs in separate letters (ADAMS Accession No. ML20279A501; ADAMS Accession No. ML20307A533; ADAMS Accession No. ML20260H376).

S. Smith In addition to the NRC staffs analyses of CENGs initial DFPs, the NRC staff completed environmental reviews of the DFPs submitted for the ISFSIs at Calvert Cliffs, Nine Mile Point, and R.E. Ginna. The NRC staff determined there were no environmental impacts from the NRC staffs review and approval of CENGs initial DFPs and Exelons updated DFPs. The NRC staff will publish a summary of the results of these environmental reviews in the Federal Register in November 2020. 4 The environmental assessments and findings of no significant impacts and related documents for these ISFSIs will be available in https://www.regulations.gov under the Docket ID: NRC-2020-0132. The environmental assessments for Calvert Cliffs, R.E. Ginna, and Nine Mile Point are located at ADAMS Accession Nos. ML20212L589, ML20213C613, and ML20234A435, respectively.

If you have any questions regarding this matter, please contact me at (301) 415-5722 or John.McKirgan@nrc.gov Sincerely, John B. Digitally signed by John B.

McKirgan McKirgan Date: 2020.11.20 14:29:52

-05'00' John McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket Nos.: 72-08, 72-1036, and 72-67 License Nos.: SNM-2505, SFGL-47, and SFGL-45 CAC No.: 001028 EPID Nos.: L-2017-FPR-0013, L-2017-FPR-0045, and L-2017-FPR-0058 cc: B. Hanson, Exelon 4 This Federal Register Notice also includes a summary of the results of the environmental reviews for the ISFSIs at Arkansas Nuclear One, Units 1 and 2; Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Clinton Power Station, Unit 1; Dresden Nuclear Power Station, Units 1, 2, and 3; Grand Gulf Nuclear Station, Unit 1; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Quad Cities Nuclear Power Station, Units 1 and 2; River Bend Station, Unit 1; Waterford Steam Electric Station, Unit 3; and Zion Nuclear Power Station, Units 1 and 2.

S. Smith

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF CONSTELLATION ENERGY NUCLEAR GROUP, LLCS INITIAL DECOMMISSIONING FUNDING PLANS FOR THE CALVERT CLIFFS, NINE MILE POINT, AND R.E. GINNA INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS DOCUMENT DATED: November 20, 2020 DISTRIBUTION:

PUBLIC DFM r/f RidsNmssRefsFab KLois, NMSS SHarwell, NMSS FMiller, NMSS MHenderson, NMSS BWhite, NMSS DHabib, NMSS JMaltese, OGC PJehle, OGC JMcKirgan, NMSS BVaidya, NRR BPurnell, NRR RGladney, NMSS RidsNMSSResource RidsNrrPMCalvertCliffs Resource RidsNrrPMNineMilePoint Resource RidsNrrPMREGinna Resource ADAMS Package Accession No.: ML20212L881 *via email OFFICE NMSS/DFM NMSS/DFM NMSS/REFS/FAB OGC (NLO) NMSS/DFM/STLB NAME RGladney* WWheatley* FMiller PJehle* JMcKirgan*

DATE 10/01/2020 10/26/2020 11/4/2020 11/17/2020 11/20/2020 OFFICIAL RECORD COPY