RA-12-043, Decommissioning Funding Plan for Interim Spent Fuel Storate Installations (Isfsls)

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Decommissioning Funding Plan for Interim Spent Fuel Storate Installations (Isfsls)
ML12353A033
Person / Time
Site: Oconee, Catawba, Robinson, McGuire, 07200006, 07200040, 07200003, 07200060  Duke Energy icon.png
Issue date: 12/13/2012
From: Waldrep B
Duke Energy Corp
To:
Document Control Desk, NRC/NMSS/SFST
References
RA-12-043
Download: ML12353A033 (24)
v • d • e


Text

Benjamin C Waldrep kDuke 10 CFR 72.30(b) Vice President CorporateGovernance &

OrEnergy OperationsSupport Duke Energy Corporation 526 South Church Street Charlotte,NC 28202 MailingAddress:

ECQ7H/P.0. Box 1006 Charlotte,NC 28201-1006 704 382 8162 704 382 6056 fax Benjamin. Waldrepljduke-energjVeem 10 CFR 72.30(b)

Serial: RA-12-043 December 13, 2012 Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 OCONEE NUCLEAR STATION H.B. ROBINSON STEAM ELECTRIC PLANT, INDEPENDENT SPENT FUEL STORAGE UNIT 2 INSTALLATION INDEPENDENT SPENT FUEL STORAGE DOCKET NO. 72-04 / LICENSE NUMBER INSTALLATION SNM-2503 DOCKET NO. 72-3 / LICENSE NUMBER SNM-2502 OCONEE NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE H.B. ROBINSON STEAM ELECTRIC PLANT, INSTALLATION UNIT 2 DOCKET NO. 72-40 INDEPENDENT SPENT FUEL STORAGE MCGUIRE NUCLEAR STATION INSTALLATION INDEPENDENT SPENT FUEL STORAGE DOCKET NO. 72-60 INSTALLATION DOCKET NO. 72-38 BRUNSWICK STEAM ELECTRIC PLANT INDEPENDENT SPENT FUEL STORAGE CATAWBA NUCLEAR STATION INSTALLATION INDEPENDENT SPENT FUEL STORAGE DOCKET NO. 72-6 INSTALLATION DOCKET NO. 72-45

SUBJECT:

DECOMMISSIONING FUNDING PLAN FOR INTERIM SPENT FUEL STORAGE INSTALLATIONS (ISFSls)

References:

1. 10 CFR Parts 20, 30, 40, et al. Decommissioning Planning;Final Rule, 76FR35512, Dated June 17, 2011
2. Letter, Benjamin C. Waldrep (Duke Energy) to USNRC,

Subject:

Decommissioning Financial Assurance Reports, Dated March 30, 2012, [ADAMS Accession No. ML110910058]

3. Letter, Donna Alexander (Progress Energy) to USNRC, RA-1 1-004, dated March 31, 2012,

Subject:

Biennial Decommissioning Funding Status Report, [ADAMS Accession No. ML110950366]

Pursuant to new 10 CFR 72.30(b), Duke Energy Carolinas, LLC (referred to hereinafter and in each of the enclosed attachments as "Duke") is submitting the enclosed decommissioning funding plans covering the ISFSIs for Oconee Nuclear Station, McGuire Nuclear Station and Catawba Nuclear Station and on behalf of Carolina Power & Light Company (referred to hereinafter and in each of the enclosed attachments as "CP&L") is submitting the enclosed decommissioning funding plans covering the ISFSIs for H.B.

Robinson Steam Electric Plant, Unit 2 and Brunswick Steam Electric Plant.

U.S. Nuclear Regulatory Commission December 13, 2012 RA-12-043 Page 2 New requirement 10 CFR 72.30(b) requires "each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan...." In accordance with 10 CFR 72.13(b) and 10 CFR 72.13(c), the new 10 CFR 72.30(b) is applicable to both specific and general licensed ISFSIs. The effective date for the referenced final rule is December 17, 2012.

As a convenience to the NRC, the enclosed report for the Catawba Nuclear Station ISFSI addresses North Carolina Electric Membership Corporation's 30.754 percent ownership, North Carolina Municipal Power Agency No. l's 37.5 percent ownership and Piedmont Municipal Power Agency's 12.5 percent ownership. As required by 10 CFR 72.30(b)(6), Duke and, in the case of Catawba Nuclear Station, North Carolina Electric Membership Corporation, North Carolina Eastern Municipal Power Agency No. 1 and Piedmont Municipal Power Agency have certified in the enclosed attachments that financial assurance for decommissioning has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance for ISFSI decommissioning cost.

In a similar manner, the enclosed report for the Brunswick Steam Electric Plant ISFSI addresses North Carolina Eastern Municipal Power Agency's 18.33 percent ownership. As required by 10 CFR 72.30(b)(6), CP&L and, in the case of Brunswick Steam Electric Plant, North Carolina Eastern Municipal Power Agency have certified in the enclosed attachments that financial assurance for decommissioning has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance for ISFSI decommissioning cost.

There are no regulatory commitments associated with this letter.

Please address any questions regarding this matter to Paul Guill at (704) 382-4753.

Sincerely, Benjamin C. Waldre$

Vice President - Corporate Governance &

Operations Support Attachments:

1. Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Oconee Nuclear Station
2. Decommissioning Funding Plan for Independent Spent Fuel Storage Installation McGuire Nuclear Station
3. Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Catawba Nuclear Station
4. Decommissioning Funding Plan for Independent Spent Fuel Storage Installation H. B. Robinson Steam Electric Plant, Unit 2
5. Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Brunswick Steam Electric Plant

U.S. Nuclear Regulatory Commission December 13, 2012 RA-12-043 Page 3 xc (with attachment):

V. M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 J. P. Boska, Senior Project Manager (ONS)

U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 C2 Rockville, MD 20852-2738 J. H. Thompson, Project Manager (CNS & MNS)

U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 F. E. Saba, NRR Project Manager (BSEP)

U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 A. T. Billoch-Colon, NRR Project Manager (HBRSEP, Unit 2)

U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 D15 Rockville, MD 20852-2738 E. L. Crowe, NRC Senior Resident Inspector Oconee Nuclear Station J. Zeiler, NRC Senior Resident Inspector McGuire Nuclear Station P. K. Niebaum, Senior Resident Inspector Brunswick Steam Electric Plant, Unit Nos. 1 and 2 J. A. Hickey, Senior Resident Inspector H. B. Robinson Steam Electric Plant, Unit No. 2 G. A. Hutto, III, NRC Senior Resident Inspector Catawba Nuclear Station M. D. Waters Chief - Licensing Branch Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop E3 D2M Rockville, MD 20852-2738

U.S. Nuclear Regulatory Commission December 13, 2012 RA-1 2-043 Page 4 xc Continued (with attachment):

S. E. Jenkins, Manager Radioactive & Infectious Waste Management SC Dept. of Health and Env. Control 2600 Bull St.

Columbia, SC 29201 W. L. Cox, 111, Section Chief Div. of Environmental Health, RP Section NC Dept. of Env. &Natural Resources 1645 Mail Service Center Raleigh, NC 27699

Attachment I Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Oconee Nuclear Station

U.S. Nuclear Regulatory Commission Page 1 of 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Oconee Nuclear Station, Docket No. 72-04/License SNM-2503 Oconee Nuclear Station, Docket No. 72-40 10 CFR 72.30(b) Each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that must contain:

(1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the ISFSI.

(2) A detailed cost estimate for decommissioning, in an amount reflecting (i) The cost of an independent contractor to perform all decommissioning activities; (ii) An adequate contingency factor; and (iii) The cost of meeting the §20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of

§20.1403 of this chapter, the cost estimate may be based on meeting the §20.1403 criteria.

Duke's most recent detailed cost estimate for decommissioning the ISFSI is included in the 2008 Decommissioning Cost Analysis for the Oconee Nuclear Station prepared by TLG Services, Inc.

(hereinafter referred to as the "2008 Decommissioning Cost Analysis"). The 2008 Decommissioning Cost Analysis uses, and relies on, the basic approach presented in "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, developed by the Atomic Industrial Forum (now Nuclear Energy Institute), which describes a unit factor method for determining decommissioning activity costs. The unit factor approach used in the 2008 Decommissioning Cost Analysis incorporates site-specific costs and the latest available information on worker productivity in decommissioning. The 2008 Decommissioning Cost Analysis also reflects insights regarding regulatory aspects and technical challenges of decommissioning commercial nuclear units such as Rancho Seco, Trojan, Yankee Rowe, Main Yankee, San Onofre-1 and others.

The 2008 Decommissioning Cost Analysis was used to establish the following cost components that are associated with radiological decontamination and license termination of the ISFSI:

U.S. Nuclear Regulatory Commission Page 2 of 3 Oconee Nuclear Station - ISFSI Radiological and License Termination Decommissioning Costs 2008 Costs Total 2008 Costs Total 2010 Costs

($ Thousands) Contingency ($ Thousands) ($ Thousands)

ISFSI License Termination $ 5,647 $ 1,208 $ 6,855 $ 7,414 Small tool allowance $ 37 $ 5 $ 42 $ 45 Period Dependent Costs $ 989 $ 133 $ 1,122 $ 1,214 Total Oconee ISFSI Radiological and License Termination Decommissioning Costs $ 6,673 $ 1,346 $ 8,019 $ 8,673 Totals mray not foot due to rounding Escalation rate - 4.0%

Period dependent costs include costs such as insurance, taxes, equipment rental, energy, NRC fees, staff and overhead.

Based on the detailed cost estimate for decommissioning the ISFSI that is included in the 2008 Decommissioning Cost Analysis, the table above sets forth amounts reflecting:

(i) the cost of an independent contractor to perform all decommissioning activities, which is based on the applicable costs from the 2008 Decommissioning Cost Analysis, plus a commercially reasonable markup to applicable charges; (ii) an adequate contingency factor; and (iii) the cost to remediate the Oconee Nuclear Station site to a residual level consistent with 10 CFR 20.1402.

(3) Identification of and justification for using the key assumptions contained in the DCE.

The cost components shown in the table in Part 2 above are based on the following assumptions:

  • DOE will accept spent fuel by 2017 and will accept responsibility for all storage canisters.
  • All costs associated with non-radiological decommissioning of the ISFSI are outside the scope of this submittal.

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

As a licensee who is issued a power reactor license for Oconee Nuclear Station under Part 50, Duke provides financial assurance for decommissioning of the site by the method described in 10 CFR 72.30(e)(5) by complying with the methods of 10 CFR 50.75(b), (e) and (h). As evidenced by Duke's March 30, 2011 (Reference 2), Decommissioning Financial Assurance Report, filed pursuant to 10 CFR 50.75(f)(1), Duke has provided financial assurance for decommissioning of the site in an amount at least equal to that required by 10 CFR 50.75(b). The amount of financial assurance required by 10 CFR 50.75(b) is subject to annual adjustment in accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50.75(f)(3) and (5) at or about five years prior to the projected end of reactor operations.

U.S. Nuclear Regulatory Commission Page 3 of 3 The North Carolina Utilities Commission (NCUC) and the Public Service Commission of South Carolina (PSCSC) require that Duke update its cost estimate for decommissioning its nuclear plants every five years. Such update is based on the site-specific nuclear decommissioning cost study prepared by an independent third party. As noted in Part 2 above, the 2008 Decommissioning Cost Analysis is the most recent cost study. Both the NCUC and the PSCSC have allowed Duke to recover estimated decommissioning costs, including those related to ISFSI decommissioning, through retail rates over the expected remaining service periods of Duke's nuclear stations. Accordingly, Duke is funding its decommissioning trust funds such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (f)(1). Therefore, as described in Part 1 above, funds will be available for the cost of ISFSI decommissioning.

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke hereby certifies that, as evidenced by Duke's March 30, 2011, Decommissioning Financial Assurance Report (Reference 2), filed pursuant to 10 CFR 50.75(f)(1), financial assurance for decommissioning the Oconee Nuclear Station has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance of the ISFSI decommissioning cost.

Attachment 2 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation McGuire Nuclear Station

U.S. Nuclear Regulatory Commission Page 1 of 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation McGuire Nuclear Station, Docket No. 72-38 10 CFR 72.30(b) Each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that must contain:

(1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the ISFSl.

(2) A detailed cost estimate for decommissioning, in an amount reflecting (i) The cost of an independent contractor to perform all decommissioning activities; (ii) An adequate contingency factor; and (iii) The cost of meeting the §20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of

§20.1403 of this chapter, the cost estimate may be based on meeting the §20.1403 criteria.

Duke's most recent detailed cost estimate for decommissioning the ISFSI is included in the 2008 Decommissioning Cost Analysis for the McGuire Nuclear Station prepared by TLG Services, Inc.

(hereinafter referred to as the "2008 Decommissioning Cost Analysis"). The 2008 Decommissioning Cost Analysis uses, and relies on, the basic approach presented in "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, developed by the Atomic Industrial Forum (now Nuclear Energy Institute), which describes a unit factor method for determining decommissioning activity costs. The unit factor approach used in the 2008 Decommissioning Cost Analysis incorporates site-specific costs and the latest available information on worker productivity in decommissioning. The 2008 Decommissioning Cost Analysis also reflects insights regarding regulatory aspects and technical challenges of decommissioning commercial nuclear units such as Rancho Seco, Trojan, Yankee Rowe, Main Yankee, San Onofre-1 and others.

The 2008 Decommissioning Cost Analysis was used to establish the following cost components that are associated with radiological decontamination and license termination of the ISFSI:

U.S. Nuclear Regulatory Commission Page 2 of 3 1 McGuire Nuclear Station - ISFSl Radiological and License Termination Decommissioning Costs 2008 Costs Total 2008 Costs Total 2010 Costs

($ Thousands) Contingency ($ Thousands) ($ Thousands)

ISFSI License Termination $ 2,786 $ 510 $ 3,296 $ 3,565 Small tool allowance $ 8 $ 1 $ 9 $ 10 Period Dependent Costs $ 1,051 $ 139 $ 1,190 $ 1,287 Total McGuire ISFSI Radiological and License Termination Decommissioning Costs $ 3,845 $ 650 $ 4,495 $ 4,862 Totals may not foot due to rounding Escalation rate - 4.0%

Period dependent costs include costs such as insurance, taxes, equipment rental, energy, NRC fees, staff and overhead.

Based on the detailed cost estimate for decommissioning the ISFSI that is included in the 2008 Decommissioning Cost Analysis, the table above sets forth amounts reflecting:

(i) the cost of an independent contractor to perform all decommissioning activities, which is based on the applicable costs from the 2008 Decommissioning Cost Analysis, plus a commercially reasonable markup to applicable charges; (ii) an adequate contingency factor; and (iii) the cost to remediate the McGuire Nuclear Station site to a residual level consistent with 10 CFR 20.1402.

(3) Identification of and justification for using the key assumptions contained in the DCE.

The cost components shown in the table in Part 2 above are based on the following assumptions:

  • DOE will accept spent fuel by 2017 and will accept responsibility for all storage canisters.
  • All costs associated with non-radiological decommissioning of the ISFSI are outside the scope of this submittal.

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

As a licensee who is issued a power reactor license for McGuire Nuclear Station under Part 50, Duke provides financial assurance for decommissioning of the site by the method described in 10 CFR 72.30(e)(5) by complying with the methods of 10 CFR 50.75(b), (e) and (h). As evidenced by Duke's March 30, 2011 (Reference 2), Decommissioning Financial Assurance Report, filed pursuant to 10 CFR 50.75(f)(1), Duke has provided financial assurance for decommissioning of the site in an amount at least equal to that required by 10 CFR 50.75(b). The amount of financial assurance required by 10 CFR 50.75(b) is subject to annual adjustment in accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50.75(f)(3) and (5) at or about five years prior to the projected end of reactor operations.

U.S. Nuclear Regulatory Commission Page 3 of 3 The North Carolina Utilities Commission (NCUC) and the Public Service Commission of South Carolina (PSCSC) require that Duke update its cost estimate for decommissioning its nuclear plants every five years. Such update is based on the site-specific nuclear decommissioning cost study prepared by an independent third party. As noted in Part 2 above, the 2008 Decommissioning Cost Analysis is the most recent cost study. Both the NCUC and the PSCSC have allowed Duke to recover estimated decommissioning costs, including those related to ISFSI decommissioning, through retail rates over the expected remaining service periods of Duke's nuclear stations. Accordingly, Duke is funding its decommissioning trust funds such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (0(1). Therefore, as described in Part.1 above, funds will be available for the cost of ISFSI decommissioning.

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Duke hereby certifies that, as evidenced by Duke's March 30, 2011, Decommissioning Financial Assurance Report (Reference 2), filed pursuant to 10 CFR 50.75(f)(1), financial assurance for decommissioning the McGuire Nuclear Station has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance of the ISFSI decommissioning cost.

Attachment 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Catawba Nuclear Station

U.S. Nuclear Regulatory Commission Page 1 of 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Catawba Nuclear Station, Docket No. 72-45 10 CFR 72.30(b) Each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that must contain:

(1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the ISFSI.

(2) A detailed cost estimate for decommissioning, in an amount reflecting (i) The cost of an independent contractor to perform all decommissioning activities; (ii) An adequate contingency factor; and (iii) The cost of meeting the §20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of

§20.1403 of this chapter, the cost estimate may be based on meeting the §20.1403 criteria.

Duke's most recent detailed cost estimate for decommissioning the ISFSI is included in the 2008 Decommissioning Cost Analysis for the Catawba Nuclear Station prepared by TLG Services, Inc.

(hereinafter referred to as the "2008 Decommissioning Cost Analysis"). The 2008 Decommissioning Cost Analysis uses, and relies on, the basic approach presented in "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, developed by the Atomic Industrial Forum (now Nuclear Energy Institute), which describes a unit factor method for determining decommissioning activity costs. The unit factor approach used in the 2008 Decommissioning Cost Analysis incorporates site-specific costs and the latest available information on worker productivity in decommissioning. The 2008 Decommissioning Cost Analysis also reflects insights regarding regulatory aspects and technical challenges of decommissioning commercial nuclear units such as Rancho Seco, Trojan, Yankee Rowe, Main Yankee, San Onofre-1 and others.

The 2008 Decommissioning Cost Analysis was used to establish the following cost components that are associated with radiological decontamination and license termination of the ISFSI:

U.S. Nuclear Regulatory Commission Page 2 of 3 Catawba Nuclear Station - ISFSI Radiological and License Termination Decommissioning Costs 2008 Costs Total 2008 Costs Total 2010 Costs

($ Thousands) Contingency ($ Thousands) ($ Thousands)

ISFSI License Termination $ 2,401 $ 430 $ 2,831 $ 3,062 Small tool allowance $ 6 $ 1 $ 7 $ 8 Period Dependent Costs $ 1,080 $ 142 $ 1,222 $ 1,322 Total Catawba ISFSI Radiological and License Termination Decommissioning Costs $ 3,488 $ 573 $ 4,061 $ 4,392 Duke Energy Share (19.246%) $ 845 North Carolina Electric Membership Corporation Share (30.754%)/o _ $ 1,351 North Carolina Municipal Power Agency No. 1 Share (37.5%) s$ 1,647 Piedmont Municipal Power Agency Share (12.5%) s$ 549 Totals maynotfootdue to rounding Escalation rate - 4.0%

Period dependent costs include costs such as insurance, taxes, equipment rental, energy, NRC fees, staff and overhead.

Based on the detailed cost estimate for decommissioning the ISFSI that is included in the 2008 Decommissioning Cost Analysis, the table above sets forth amounts reflecting:

(i) the cost of an independent contractor to perform all decommissioning activities, which is based on the applicable costs from the 2008 Decommissioning Cost Analysis, plus a commercially reasonable markup to applicable charges; (ii) an adequate contingency factor; and (iii) the cost to remediate the Catawba Nuclear Station site to a residual level consistent with 10 CFR 20.1402.

(3) Identification of and justification for using the key assumptions contained in the DCE.

The cost components shown in the table in Part 2 above are based on the following assumptions:

a Catawba Nuclear Station will operate through its license renewal period.

0 DOE will accept spent fuel by 2017 and will accept responsibility for all storage canisters.

0 All costs associated with non-radiological decommissioning of the ISFSI are outside the scope of this submittal.

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

As a licensee who is issued a power reactor license under Part 50, each owner of the Catawba Nuclear Station provides financial assurance for decommissioning of the site by the method described in 10 CFR 72.30(e)(5) by complying with the methods of 10 CFR 50.75(b), (e) and (h). As evidenced by Duke's March 30, 2011 (Reference 2), Decommissioning Financial Assurance Report, filed pursuant to 10 CFR 50.75(f)(1), each owner has, with respect to its applicable ownership percentage, provided financial assurance for decommissioning in an amount at least equal to that required by 10 CFR 50.75(b). The amount of financial assurance required by 10 CFR 50.75(b) is subject to annual adjustment in

U.S. Nuclear Regulatory Commission Page 3 of 3 accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50.75(f)(3) and (5) at or about five years prior to the projected end of reactor operations.

With respect to Duke, the North Carolina Utilities Commission (NCUC) and the Public Service Commission of South Carolina (PSCSC) require that Duke update its cost estimate for decommissioning its nuclear plants every five years. Such update is based on a site-specific nuclear decommissioning cost study prepared by an independent third party. As noted in Part 2 above, the 2008 Decommissioning Cost Analysis is the most recent cost study. Both the NCUC and the PSCSC have allowed Duke to recover estimated decommissioning costs, including those related to ISFSI decommissioning, through retail rates over the expected remaining service periods of Duke's nuclear stations. Accordingly, Duke is funding its decommissioning trust funds, such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (f)(1). Therefore, as described in Part 1 above, funds will be available for the cost of ISFSI decommissioning.

With respect to North Carolina Electric Membership Corporation (NCEMC), North Carolina Municipal Power Agency No. 1 (NCMPA1) and Piedmont Municipal Power Agency (PMPA), Duke provides each with a copy of the site-specific nuclear decommissioning cost analyses for the Catawba Nuclear Station.

Based on such studies, among other things, each of NCEMC, NCMPA1 and PMPA establishes its own rates and is able to recover its cost of service allocable to decommissioning. Accordingly, each of NCEMC, NCMPA1 and PMPA is funding its decommissioning trust funds such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (f)(1).

Therefore, as described in Part 1 above, funds will be available for the cost of ISFSI decommissioning.

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Each of Duke, NCEMC, NCMPA1 and PMPA hereby certifies that, as evidenced by Duke's March 30, 2011 (Reference 2), Decommissioning Financial Assurance Report, filed pursuant to 10 CFR 50.75(f)(1),

financial assurance for decommissioning the Catawba Nuclear Station has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance for each owner's share of the ISFSI decommissioning cost.

U.S. Nuclear Regulatory Commission RA-1 2-043 Attachment 4 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation H. B. Robinson Steam Electric Plant, Unit 2

U.S. Nuclear Regulatory Commission RA-1 2-043, Attachment 4 Page 1 of 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation H. B. Robinson Steam Electric Plant, Unit 2, Docket No. 72-03/License SNM-2502 H. B. Robinson Steam Electric Plant, Unit 2, Docket No. 72-60 10 CFR 72.30(b) Each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that must contain:

(1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the ISFSI.

(2) A detailed cost estimate for decommissioning, in an amount reflecting (i) The cost of an independent contractor to perform all decommissioning activities; (ii) An adequate contingency factor; and (iii) The cost of meeting the §20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of

§20.1403 of this chapter, the cost estimate may be based on meeting the §20.1403 criteria.

CP&L's most recent detailed cost estimate for decommissioning the ISFSI is included in the 2009 Decommissioning Cost Update of the H. B. Robinson Nuclear Power Plant prepared by EnergySolutions, LLC (hereinafter referred to as the "2009 Decommissioning Cost Update"). The 2009 Decommissioning Cost Update uses, and relies on, the basic approach presented in "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors approach used in the 2009 Decommissioning Cost Update incorporates site-specific costs and work activities.

The 2009 Decommissioning Cost Update was used to establish the following cost components that are associated with radiological decontamination and license termination of the ISFSI:

U.S. Nuclear Regulatory Commission RA-12-043, Attachment 4 Page 2 of 3 Robinson Nuclear Plant - ISFSI Radiological and License Termination Decommissioning Costs 2009 Costs Total 2009 Costs Total 2010 Costs

($ Thousands) Contingency ($ Thousands) ($ Thousands)

Costs associated with NUHOMS 7P ISFSI:

Preparation and NRC Review of License Termination Plan $ 201 $ 26 $ 227 $ 236 Verification Survey of Horizontal Storage Modules $ 24 $ 3 $ 27 $ 28 Preparation of Final Report on Decommissioning and NRC Review $ 111 $ 14 $ 125 $ 130 Costs associated with NUHOMS 24PTH ISFSI:

Preparation and NRC Review of License Termination Plan $ 201 $ 26 $ 227 $ 236 Verification Survey of Horizontal Storage Modules $ 60 $ 8 $ 68 $ 71 Preparation of Final Report on Decommissioning and NRC Review $ 111 $ 14 $ 125 $ 130 Undistributed Costs (Equivalent to costs associated with ISFSl with no fuel) $ 3,240 $ 453 $ 3,693 $ 3,841 Total Robinson ISFSI Radiological and License Termination Decommissioning Costs $ 3,948 $ 544 $ 4,492 $ 4,672 Totals may not foot due to rounding Escalation rate - 4.0%

Undistributed costs include costs such as insurance, taxes, energy, and staff.

Based on the detailed cost estimate for decommissioning the ISFSI that is included in the 2009 Decommissioning Cost Update, the table above sets forth amounts reflecting:

(i) the cost of an independent contractor to perform all decommissioning activities, which is based on applicable costs from the 2009 Decommissioning Cost Update, plus a commercially reasonable markup to applicable charges; (ii) an adequate contingency factor; and (iii) the cost to remediate the H. B. Robinson Steam Electric Plant, Unit 2 site to a residual level consistent with 10 CFR 20.1402.

(3) Identification of and justification for using the key assumptions contained in the DCE.

The cost components shown in the table above are based on the following assumptions:

  • H. B. Robinson Steam Electric Plant, Unit 2 will operate through its license renewal period.
  • DOE will accept spent fuel by 2020 and will accept responsibility for all storage canisters.
  • All costs associated with non-radiological decommissioning of the ISFSI are outside the scope of this submittal.

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

As a licensee who is issued a power reactor license for H. B. Robinson Steam Electric Plant, Unit 2 under Part 50, CP&L provides financial assurance for decommissioning of the site by the method described in 10 CFR 72.30(e)(5) by complying with the methods of 10 CFR 50.75(b), (e) and (h). As evidenced by CP&L's March 31, 2011 (Reference 3), Biennial Decommissioning Funding Status Report, filed pursuant to 10 CFR 50.75(f)(1), CP&L has provided financial assurance for decommissioning of the site in an amount at least equal to that required by 10 CFR 50.75(b). The amount of financial assurance required by 10 CFR 50.75(b) is subject to annual adjustment in accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50.75(f)(3) and (5) at or about five years prior to the projected end of reactor operations.

U.S. Nuclear Regulatory Commission RA-12-043, Attachment 4 Page 3 of 3 The North Carolina Utilities Commission (NCUC) requires that CP&L update its cost estimate for decommissioning its nuclear plants every five years. Such update is based on the site-specific nuclear decommissioning cost study prepared by an independent third party. As noted in Part 2 above, the 2009 Decommissioning Cost Update is the most recent cost study. The NCUC has allowed CP&L to recover estimated decommissioning costs, including those related to ISFSI decommissioning, through retail rates over the expected remaining service periods of its nuclear stations. Accordingly, CP&L is funding their decommissioning trust funds such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (f)(1). Therefore, as described in Part 1 above, funds will be available for the cost of ISFSI decommissioning.

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

CP&L hereby certifies that, as evidenced by CP&L's March 31, 2011, Biennial Decommissioning Funding Status Report (Reference 3), filed pursuant to 10 CFR 50.75(f)(1), financial assurance for decommissioning the H. B. Robinson Steam Electric Plant, Unit 2 has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance of the ISFSI decommissioning cost.

U.S. Nuclear Regulatory Commission RA-12-043 Attachment 5 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Brunswick Steam Electric Plant

U.S. Nuclear Regulatory Commission RA-1 2-043, Attachment 5 Page 1 of 3 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation Brunswick Steam Electric Plant, Docket No. 72-6 10 CFR 72.30(b) Each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that must contain:

(1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

10 CFR 72.30(c) requires a decommissioning funding plan be provided at least every three years and at the time of license renewal. Compliance with this part, together with the method of assuring funds described in Part 4 below, will provide reasonable assurance that funds will be available to decommission the ISFSI.

(2) A detailed cost estimate for decommissioning, in an amount reflecting (i) The cost of an independent contractor to perform all decommissioning activities; (ii) An adequate contingency factor; and (iii) The cost of meeting the §20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of

§20.1403 of this chapter, the cost estimate may be based on meeting the §20.1403 criteria.

CP&L's most recent detailed cost estimate for decommissioning the ISFSI is included in the 2009 Decommissioning Cost Update of the Brunswick Nuclear Power Plant prepared by EnergySolutions, LLC (hereinafter referred to as the "2009 Decommissioning Cost Update"). The 2009 Decommissioning Cost Update uses, and relies on, the basic approach presented in "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors approach used in the 2009 Decommissioning Cost Update incorporates site-specific costs and work activities.

The 2009 Decommissioning Cost Update was used to establish the following cost components that are associated with radiological decontamination and license termination of the ISFSI:

U.S. Nuclear Regulatory Commission RA-12-043, Attachment 5 Page 2 of 3 Brunswick Nuclear Plant - ISFSI Radiological and License Termination Decommissioning Costs 2009 Costs Total 2009 Costs Total 2010 Costs

($ Thousands) Contingency ($ Thousands) ($ Thousands)

Preparation and NRC Review of License Termination Plan $ 201 $ 26 $ 227 $ 236 Verification Survey of Horizontal Storage Modules $ 107 $ 14 $ 121 $ 126 Preparation of Final Report on Decommissioning and NRC Review $ 111 $ 14 $ 125 $ 130 Undistributed Costs (Equivalent to costs associated with ISFSI with no fuel) $ 1,365 $ 180 $ 1,545 $ 1,607 Total Brunswick ISFSI Radiological and License Termination Decommissioning Costs $ 1,784 $ 234 $ 2,018 $ 2,099 Duke Energy Share (81.67%) $ 1,714 North Carolina Eastern Municipal Power Agency Share (18.33%) $ 385 Totals may not foot due to rounding Escalation rate - 4.0%

Undistributed costs include costs such as insurance, taxes, energy, and staff.

Based on the detailed cost estimate for decommissioning the ISFSI that is included in the 2009 Decommissioning Cost Update, the table above sets forth amounts reflecting:

(i) the cost of an independent contractor to perform all decommissioning activities, which is based on applicable costs from the 2009 Decommissioning Cost Update, plus a commercially reasonable markup to applicable charges; (ii) an adequate contingency factor; and (iii) the cost to remediate the Brunswick Steam Electric Plant site to a residual level consistent with 10 CFR 20.1402.

(3) Identification of and justification for using the key assumptions contained in the DCE.

The cost components shown in the table above are based on the following assumptions:

  • Brunswick Steam Electric Plant will operate through its license renewal period.
  • DOE will accept spent fuel by 2020 and will accept responsibility for all storage canisters.

a All costs associated with non-radiological decommissioning of the ISFSI are outside the scope of this submittal.

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of this section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

As a licensee who is issued a power reactor license under Part 50, each owner of the Brunswick Steam Electric Plant provides financial assurance for decommissioning of the site by the method described in 10 CFR 72.30(e)(5) by complying with the methods of 10 CFR 50.75(b), (e) and (h). As evidenced by CP&L's March 31, 2011 (Reference 3), Biennial Decommissioning Funding Status Report, filed pursuant to 10 CFR 50.75(f)(1), each owner has, with respect to its applicable ownership percentage, provided financial assurance for decommissioning of the site in an amount at least equal to that required by 10 CFR 50.75(b). The amount of financial assurance required by 10 CFR 50.75(b) is subject to annual adjustment in accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50.75(f)(3) and (5) at or about five years prior to the projected end of reactor operations.

U.S. Nuclear Regulatory Commission RA-12-043, Attachment 5 Page 3 of 3 With respect to CP&L, The North Carolina Utilities Commission (NCUC) requires that CP&L update its cost estimate for decommissioning its nuclear plants every five years. Such update is based on the site-specific nuclear decommissioning cost study prepared by an independent third party. As noted in Part 2 above, the 2009 Decommissioning Cost Update is the most recent cost study. The NCUC has allowed CP&L to recover estimated decommissioning costs, including those related to ISFSI decommissioning, through retail rates over the expected remaining service periods of its nuclear stations. Accordingly, CP&L is funding its decommissioning trust funds such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (f)(1). Therefore, as described in Part 1 above, funds will be available for the cost of ISFSI decommissioning.

With respect to North Carolina Eastern Municipal Power Agency (NCEMPA), CP&L provides them with a copy of the site-specific nuclear decommissioning cost updates for the Brunswick Steam Electric Plant.

Based on such studies, among other things, NCEMPA establishes its own rates and is able to recover its cost of service allocable to decommissioning. Accordingly, NCEMPA is funding its decommissioning trust funds such that decommissioning costs being recovered through rates, when coupled with the existing fund balance and expected fund earnings are in compliance with 10 CFR 50.75(c), as reported pursuant to 10 CFR 50.75(b) and (f)(1). Therefore, as described in Part 1 above, funds will be available for the cost of ISFSI decommissioning.

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

There is currently no known subsurface material containing residual radioactivity that will require remediation at decommissioning.

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning.

Both CP&L and NCEMPA hereby certify that, as evidenced by CP&L's March 31, 2011, Biennial Decommissioning Funding Status Report (Reference 3), filed pursuant to 10 CFR 50.75(f)(1), financial assurance for decommissioning the Brunswick Steam Electric Plant has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b), which pursuant to 10 CFR 72.30(e)(5) provides

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