3F0322-01, Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2021

Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2021

ML22089A163
Person / Time
Site:	Crystal River
Issue date:	03/30/2022
From:	State S ADP CR3
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
3F0322-01
Download: ML22089A163 (1)

Text

ADP CR3, LLC 17101 Preston Road, Suite 115 l Dallas, TX 75248 Scott E. State, P.E., Chief Nuclear Officer sstate@NorthStar.com l o.682.503.2240 l c.303.898.8035 10 CFR 50.82 10 CFR 50.75 March 30, 2022 3F0322-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River 3 - Annual Decommissioning and Irradiated Fuel Management Financial Status Report for 2021

References:

1. Letters, ADP CR3, LLC to USNRC, Crystal River Unit 3 Nuclear Generating Plant Notification of Revised Post-Shutdown Decommissioning Activities Report, dated June 26, 2019, and Supplemental Information in Support of Revised Post Shutdown Decommissioning Activities Report and Decommissioning Cost Estimate, dated December 26, 2019 (ML19177A232 and ML20006F022)

2. Letter, USNRC to Duke Energy Florida, LLC, Crystal River Unit 3 Nuclear Generating Plant Order Approving Transfer of Licensed Authority from Duke Energy Florida, LLC to ADP CR3, LLC and draft conforming administrative license amendment (EPID L-2019-LLA-0135), dated April 1, 2020 (ADAMS Accession Nos. ML20069A023, ML20069A024. ML20069A025, ML20069A026, ML20069A027, ML20101G582 and ML20101G583)

3. Letter, USNRC to Duke Energy Florida, LLC, Crystal River Unit 3 Nuclear Generating Plant - Issuance of Amendment No. 258 RE: Order Approving Transfer of Licensed Authority from Duke Energy Florida, LLC to ADP CR3, LLC and Conforming License Amendment (EPID L-2019-LLA-0135), dated October 1, 2020 (ML20253A343)

4. Letter, ADP CR3 to USNRC, Crystal River 3 ISFSI Decommissioning Trust, dated October 28, 2020 (ML20302A453)

U. S. Nuclear Regulatory Commission Page 2 of 3 March 30, 2022 3F0322-01

Dear Sir or Madam:

10 CFR 50.75(f)(1) requires each shutdown power reactor licensee to annually report to the NRC the status of their decommissioning financial assurance by March 31.

10 CFR 50.82(a)(8)(v) & (vii) require that after submitting its site-specific decommissioning cost estimate pursuant to 10 CFR 50.82(a)(4)(i), a licensee must annually submit to the NRC, by March 31, a report on the status of its decommissioning expenditures, remaining costs and funding assurance levels, as well as a report on the status of its funding for managing irradiated fuel.

A change to the spent fuel management strategy was described by Duke Energy Florida, LLC (DEF), ADP CR3, LLC (ADP CR3), and ADP SF1, LLC (ADP SF1) in the application for license transfer and was approved by the NRC in Reference 2. Under the terms of the license transfer, ADP CR3 became the NRC operator licensee responsible for all activities under the Crystal River Unit 3 Nuclear Plant (CR3) license. Under a Purchase and Sale Agreement (PSA) with DEF as part of the license transfer, ADP SF1 acquired the ISFSI, its associated equipment, the high-level radioactive and greater than Class C (GTCC) waste, and title to the spent nuclear fuel. DEF also assigned to ADP SF1 its Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste with the U.S. Department of Energy (DOE).

ADP SF1 entered into an operating agreement with ADP CR3, to possess and maintain the ISFSI, its associated equipment, and spent nuclear fuel.

As the NRC owner licensee, DEF continues to own the CR3 facility, with the exception of the assets described above, and its nuclear decommissioning trust (NDT). In addition to maintaining the NDT, DEF is responsible for disbursement of funds to pay for the costs of decommissioning as work is completed.

As a result of the PSA, after October 1, 2020, funding for spent fuel management costs for CR3 is no longer provided by the NDT. Funding for spent fuel management is provided by the ADP SF1 parent companies, NorthStar and Orano. The projected irradiated fuel management costs were submitted with the revised PSDAR in Reference 1, and an updated cash flow analysis was included in last years Annual Decommissioning and Irradiated Fuel Management Financial Status Report. A dedicated ISFSI Decommissioning Trust Fund has been established by ADP SF1 in accordance with the Order approving the license transfer as described in Reference 4.

Accordingly, ADP CR3, LLC, hereby submits the status of its decommissioning financial assurance (Attachment 1), the estimated costs to complete decommissioning and financial assurance demonstration (Attachment 2), and the projected cash flow analysis for irradiated fuel management (Attachment 3) for Crystal River Nuclear Plant. All or most of the spent fuel management costs are a liability of the U.S. Government as a result of its breach of the spent fuel disposal contract.

U. S. Nuclear Regulatory Commission Page 3 of 3 March 30, 2022 3F0322-01 This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Mr. Mark Van Sicklen, ADP CR3, LLC Licensing Manager, at (352) 436-5572.

Sincerely, ADP CR3, LLC Scott E. State, P.E.

Chief Nuclear Officer Attachments:

Attachment 1 - CR3 Annual Decommissioning Financial Status Report for 2021 Attachment 2 - CR3 Estimate of Costs to Complete Decommissioning and Financial Assurance Demonstration Attachment 3 - CR3 Projected Cash Flow Analysis for Irradiated Fuel Management cc: NMSS Project Manager Regional Administrator, Region I

ADP CR3, LLC DOCKET NUMBERS 50-302 / 72-035 LICENSE NUMBER DPR - 72 ATTACHMENT 1 CR3 ANNUAL DECOMMISSIONING FINANCIAL STATUS REPORT FOR 2021

U. S. Nuclear Regulatory Commission Attachment 1 March 30, 2022 Page 1 of 2 3F0322-01 ADP CR3, LLC Status of Decommissioning Funding Crystal River Nuclear Plant As of December 31, 2021 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) 10 CFR 50.75(f)(1) (Thousands of Dollars)

1. Minimum Financial Assurance (MFA) $348,123 [Note 1]

2. ISFSI Obligation as of 12/31/2021 $4,587 [Note 2]

3. Decommissioning Trust Fund Balance as of

$559,359 [Note 3]

12/31/2021

4. A schedule of the annual amounts remaining to be

$20,928 [Note 4]

collected

5. Assumptions used in determining rates of escalation in decommissioning costs, rates of 2% annual real rate of return per earnings on decommissioning funds, and rates of 10 CFR 50.75(e)(1)(i) other factors used in funding projections.

6. Any contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v)

7. Modifications occurring to a licensee's current method of providing financial None assurance since the last submitted report

8. Any material changes to trust agreements None Note 1: This amount is based upon total DECON expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and PROMPT DECON analysis provided in Attachment 2. This is the amount of decommissioning funds estimated to be required for remaining License Termination Costs.

Note 2: ISFSI Obligation is funded by the ISFSI Demolition Trust Account (See Table 3.1) and based on the ISFSI demolition site-specific cost estimate dated March 30, 2022.

Note 3: NDT Balance - $530,279 plus Provisional Trust Balance $29,080.

Note 4: Reflects ADP contributions pursuant to the terms of the Decommissioning Services Agreement (DSA) dated May 8, 2019, and as amended October 1, 2020.

U. S. Nuclear Regulatory Commission Attachment 1 March 30, 2022 Page 2 of 2 3F0322-01 ADP CR3, LLC Status of Decommissioning Funding Crystal River Nuclear Plant As of December 31, 2021 - 10 CFR 50.75(f(1) and 10 CFR 50.82(a)(8)(v) 10 CFR 50.82(a)(8)(v) & (vi) (Thousands of Dollars)

1. Cumulative decommissioning spending through

$295,596 [Note 1]

12/31/2021

2. 2021 decommissioning spending $104,891 [Note 2]

3. Decommissioning Trust Fund & Provisional Trust

$559,359 [Note 3]

Fund Total as of 12/31/2021

4. Additional planned contributions to the Provisional

$20,928 [Note 4]

Trust Account

5. Estimated costs to complete from the latest $348,123 estimate. (See #1 above in 10 75 CFR 50.75 information)

ADP CR3 has projected the cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Department of Energy based on the assumption that DOE pickup of fuel no later than 2037. The cost analysis is provided in Attachment 3.

6. Estimate based on unrestricted release of the site See Attachment 2 per 10 CFR 20.1402

7. Modifications to Financial Assurance Since Last Report None

8. Any material changes to trust agreements None Note 1: Cumulative Spending ($190,705) per report, dated March 29, 2021 (3F0321-06) plus 2021 decommissioning spending ($104,891)

Note 2: Represents the amount actually disbursed from the fund for calendar year 2021 Note 3: NDT Balance - $530,279 plus Provisional Trust Balance $29,080.

Note 4: Reflects ADP contributions and distributions pursuant to the terms of the Decommissioning Services Agreement (DSA) dated May 8, 2019, and as amended October 1, 2020.

ADP CR3, LLC DOCKET NUMBERS 50-302 / 72-035 LICENSE NUMBER DPR - 72 ATTACHMENT 2 CR3 ESTIMATE OF COSTS TO COMPLETE DECOMMISSIONING AND FINANCIAL ASSURANCE DEMONSTRATION

U. S. Nuclear Regulatory Commission Attachment 2 March 30, 2022 Page 1 of 2 3F0322-01 CR3 ESTIMATE OF COSTS TO COMPLETE DECOMMISSIONING AND FINANCIAL ASSURANCE DEMONSTRATION Table 2.1 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - Total License Termination and Site Restoration - TABLE 2.1 (Thousands of 2022 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 License License Beginning of Net Incremental Site End-Of-Year Termination Termination Total Period Funded NDT Contributions & Annual Earnings Year Restoration Fund Cost Cost Expenses Balance Withdrawals (Distributions) on Fund Cost Balance (ADP-Contractor) (DEF-Owner) (NDF + PT) Provisional Trust 2022 $105,470 $1,511 $5,220 $112,200 $559,359 $112,200 $7,713 $8,943 $463,815 2023 $104,332 $1,541 $1,055 $106,928 $463,815 $106,928 $6,323 $7,138 $370,349 2024 $65,077 $1,572 $1,693 $68,342 $370,349 $68,342 $4,006 $6,040 $312,053 2025 $45,056 $1,603 $5,988 $52,647 $312,053 $52,647 $2,885 $5,188 $267,479 2026 $11,205 $1,635 $25,836 $38,675 $267,479 $38,675 $0 $4,576 $233,380 2027 $0 $680 $0 $680 $233,380 $19,035 -$50,006 $4,287 $168,626 2028 $0 $694 $0 $694 $168,626 $694 $0 $3,359 $171,291 2029 $0 $708 $0 $708 $171,291 $708 $0 $3,412 $173,995 2030 $0 $722 $0 $722 $173,995 $722 $0 $3,465 $176,739 2031 $0 $736 $0 $736 $176,739 $736 $0 $3,520 $179,522 2032 $0 $751 $0 $751 $179,522 $751 $0 $3,575 $182,347 2033 $0 $766 $0 $766 $182,347 $766 $0 $3,632 $185,212 2034 $0 $781 $0 $781 $185,212 $781 $0 $3,689 $188,120 2035 $0 $797 $0 $797 $188,120 $797 $0 $3,746 $191,069 2036 $0 $813 $0 $813 $191,069 $813 $0 $3,805 $194,061 2037 $0 $829 $0 $829 $194,061 $829 $0 $3,865 $197,097 2038 $0 $846 $0 $846 $197,097 $846 $0 $3,925 $200,176 TOTAL $331,139 $16,984 $39,792 $379,472 $559,359 $406,270 -$29,078 $76,165 $200,176

U. S. Nuclear Regulatory Commission Attachment 2 March 30, 2022 Page 2 of 2 3F0322-01 Table 2.1 Definitions: (Thousands of Dollars)

Column 1: License Termination Cost - (ADP-Contractor)

Reflects the Total Annual License Termination Plan cost for ADP (Contractor) in 2022 dollars at a 2% escalation rate.

Column 2: License Termination Cost - (DEF-Owner)

Reflects the Total Annual License Termination Plan cost for DEF (Owner) in 2022 dollars at a 2% escalation rate.

Column 3: Site Restoration Cost:

Reflects the Annual Site Restoration Plan cost in 2022 dollars at a 2% escalation rate.

Column 4: Total Expenses Reflects Total Expenses (Column 1 plus Column 2 plus Column 3)

Column 5: Beginning of Period Funded Balance Reflects the Funded Balance as of January 1 of each year thereafter. The Funded Balance includes the Nuclear Decommissioning Trust (NDT), plus the Provisional Trust (PT))

• January 1, 2022, Beginning of Period Funded Balances equal $530,279 NDT Balance plus $29,080 PT Balance Column 5: NDT Withdrawals Reflects the annual expenditures from the NDT in 2022 dollars at a 2% escalation rate.

• $19,035 estimated withdrawal on January 1, 2027, reflects Total Expenses ($680) plus final payment for achievement of the ISFSI-Only Interim End-State Conditions ($18,355) pursuant to Section 9.3.4 of the Decommissioning Services Agreement (DSA) dated May 29, 2019, and Amended October 1, 2020.

Column 6: ADP Net Incremental Contributions (Distributions) - Provisional Trust Reflects ADP incremental contributions and (distributions) pursuant to the terms of the DSA.

Column 7: Annual Earnings on Funds Reflects earnings on funds remaining in the trust. A 2% Earnings rate is used over a 0% cost escalation rate. The annual 2% earnings are calculated on the Beginning Balance (Column 4) minus 100% of withdrawals (Column5) plus 100%

of contributions (Columns 6) multiplied by the 2% annual earnings rate.

Column 8: End of Year Fund Balance Reflects the End-of-Year Trust Fund Balance.

- (Column 5 minus Column 6 plus Column 7 plus Column 8)

ADP CR3, LLC DOCKET NUMBERS 50-302 / 72-035 LICENSE NUMBER DPR - 72 ATTACHMENT 3 CR3 PROJECTED CASH FLOW ANALYSIS FOR IRRADIATED FUEL MANAGEMENT

U. S. Nuclear Regulatory Commission Attachment 3 March 30, 2022 Page 1 of 2 3F0322-01 CR3 PROJECTED CASH FLOW ANALYSIS FOR IRRADIATED FUEL MANAGEMENT Table 3.1 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - ISFSI Decommissioning - TABLE 3.1 (Thousands of 2022 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Spent Fuel Beginning of End-Of-Year ADP ADP Annual Earnings Year Management Period Fund Fund Withdrawals Distributions on Fund

- ISFSI Demo Balance Balance 2022 $0 $3,951 $0 $0 $79 $4,030 2023 $0 $4,030 $0 $0 $81 $4,111 2024 $0 $4,111 $0 $0 $82 $4,193 2025 $0 $4,193 $0 $0 $84 $4,277 2026 $0 $4,277 $0 $0 $86 $4,363 2027 $0 $4,363 $0 $0 $87 $4,450 2028 $0 $4,450 $0 $0 $89 $4,539 2029 $0 $4,539 $0 $0 $91 $4,630 2030 $0 $4,630 $0 $0 $93 $4,722 2031 $0 $4,722 $0 $0 $94 $4,817 2032 $0 $4,817 $0 $0 $96 $4,913 2033 $0 $4,913 $0 $0 $98 $5,011 2034 $0 $5,011 $0 $0 $100 $5,111 2035 $0 $5,111 $0 $0 $102 $5,214 2036 $0 $5,214 $0 $0 $104 $5,318 2037 $4,587 $5,318 $4,587 -$731 $0 $0 TOTAL $4,587 $3,951 $4,587 -$731 $1,367 $0

U. S. Nuclear Regulatory Commission Attachment 3 March 30, 2022 Page 2 of 2 3F0322-01 Table 3.1 Definitions:

Column 1: License Termination Cost Reflects the Total ISFSI Decommissioning cost in 2022 dollars at a 2% escalation rate.

Column 2: Beginning of Period Funded Balance Reflects the Funded Balance as of January 1 of each year.

Column 3: ADP NDT Withdrawals Reflects the annual expenditures from the NDT in 2022 dollars at a 2% escalation rate.

Column 4: ADP Distributions Reflects distribution of residual ISFI Decommissioning funds upon completion of the ISFSI decommissioning.

Column 5: Annual Earnings on Funds Reflects earnings on funds remaining in the trust. A 2% Earnings rate is used over a 0% cost escalation rate. The annual 2% earnings are calculated on the Beginning Balance (Column 2) minus 100% of withdrawals (Columns 3) minus 100% of distributions (Columns 5) multiplied by the 2% annual earnings rate.

Column 6: End of Year Fund Balance Reflects the End-of-Year Trust Fund Balance.

- (Column 2 minus Column 3 plus Column 4 plus Column 5)

U. S. Nuclear Regulatory Commission Attachment 3 March 30, 2022 Page 3 of 2 3F0322-01 CR3 PROJECTED CASH FLOW ANALYSIS FOR IRRADIATED FUEL MANAGEMENT Table 3.2 Crystal River Unit 3 Nuclear Power Station - PROMPT DECON Methodology Annual Cash Flow Analysis - Irradiated Fuel Management - Table 3.2 (Thousands of 2022 Dollars) - See column definitions below Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Spent Fuel Beginning of ADP Incremental End-Of-Year ADP DOE Cost Annual Earnings Year Management Period Fund Contributions Fund Withdrawals Recovery on Fund Costs Balance (Distributions) Balance 2022 $11,746 $0 $11,746 $12,297 $0 $3 $554 2023 $7,292 $554 $7,292 -$4,728 $16,861 $27 $5,421 2024 $7,518 $5,421 $7,518 $0 $12,006 $50 $9,958 2025 $7,669 $9,958 $7,669 $0 $7,292 $48 $9,630 2026 $7,822 $9,630 $7,822 $0 $15,469 $86 $17,363 2027 $11,298 $17,363 $11,298 $0 $7,822 $69 $13,956 2028 $11,524 $13,956 $11,524 $0 $11,597 $70 $14,099 2029 $11,755 $14,099 $11,755 $0 $11,524 $69 $13,938 2030 $11,990 $13,938 $11,990 $0 $11,755 $69 $13,771 2031 $12,230 $13,771 $12,230 $0 $12,307 $69 $13,918 2032 $12,474 $13,918 $12,474 $0 $12,230 $68 $13,741 2033 $12,724 $13,741 $12,724 $0 $12,474 $67 $13,559 2034 $12,978 $13,559 $12,978 $0 $13,060 $68 $13,710 2035 $13,238 $13,710 $13,238 $0 $12,978 $67 $13,517 2036 $13,503 $13,517 $13,503 $0 $13,238 $66 $13,319 2037 $77,171 $13,319 $77,171 $0 $64,671 $4 $824 TOTAL $242,932 $0 $242,932 $7,569 $235,285 $902 $824

U. S. Nuclear Regulatory Commission Attachment 3 March 30, 2022 Page 4 of 2 3F0322-01 Table 3.2 Definitions: (Thousands of Dollars)

Column 1: Spent Fuel Management Costs Reflects the Total Annual Spent Fuel Management cost in 2022 dollars at a 2%

escalation rate.

Column 2: Beginning of Period Funded Balance Reflects the Funded Balance as of January 1 of each year.

Column 3: ADP Withdrawals Reflects the annual expenditures from the Irradiated Fuel Management Account in 2022 dollars at a 2% escalation rate paid by ADP SF1 pursuant to the SNF Services Agreement dated October 1, 2020.

Column 4: ADP Incremental Contributions (Distributions)

Reflects ADP incremental contributions and (distributions).

Column 5: DOE Cost Recovery Reflects Cost Recovery from DOE for breach of the Standard Contract in 2022 dollars at a 2% escalation rate.

• Conservatively assumes recovery of approximately 91% of costs, net of legal costs and disallowed costs

• Year 2023: $16,861 recovery reflects initial NorthStar DOE settlement for costs incurred from 2020 thru 2021

• Year 2037: $64,671 reflects NorthStar DOE settlement for costs incurred in 2036 and 2037. (excludes recovery DOE Fuel Loading Costs - $21,415 incurred in 2037)

Column 7: Annual Earnings on Funds Reflects earnings on funds remaining in the account. A 2% Earnings rate is used over a 0% cost escalation rate. The annual 2% earnings are calculated on the Beginning Balance (Column 4) minus 100% of withdrawals (Column5) plus 100%

of contributions (Columns 6) multiplied by the 2% annual earnings rate.

Column 8: End of Year Fund Balance Reflects the End-of-Year Trust Fund Balance.

- (Column 2 minus Column 3 plus Column 4 plus Column 5 plus Column 6)