ML19078A088

(Vcsns), Unit 1 - Independent Spent Fuel Storage Installation Decommissioning Funding Plan

ML19078A088
Person / Time
Site:	Summer, 07201038
Issue date:	03/18/2019
From:	Crosby M South Carolina Electric & Gas Co, South Carolina Public Service Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML19078A088 (14)

Text

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March 18, 2019 Michael R. Crosby Senior Vice President U. S. Nuclear Regulatory Commission Nuclear Energy Document Control Desk Director, Division of Spent Fuel Storage and Transportation (843) 761-4126 Office of Nuclear Material Safety and Safeguards fax: (843) 761-7037 Washington, D. C. 20555-0001 mrcrosby@santeecooper.com

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NOs. 50-395 and 72-1038 OPERATING LICENSE NO. NPF-12 INDEPENDENT SPENT FUEL STORAGE INSTALLATION DECOMMISSIONING FUNDING PLAN Ladies and Gentlemen:

The South Carolina Public Service Authority (Authority) and South Carolina Electric & Gas Company (SCE&G) have ownership interests of one-third and two-thirds, respectively, in the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS) Independent Spent Fuel Storage Installation (ISFSI). As provided in 10 CFR 72.30 (b), the Authority submitted a decommissioning funding plan by letter dated March 18, 2016. 10 CFR 72.30 (c) requires each holder of a license under Part 72 to resubmit the decommissioning funding plan at the time of license renewal and at intervals not to exceed three (3) years with adjustments as necessary to account for changes in costs and the extent of contamination. In accordance with 10 CFR 72.30 (c), the information below and the enclosed funding plan (please see Attachment) provide the Authority's periodic update to the VCSNS ISFSI decommissioning funding plan. SCE&G will file the required financial assurance information relative to its two-thirds ownership share in a separate submittal.

10 CFR 72.30 (c) requires the updated decommissioning funding plan to specifically consider the effect of the following events on decommissioning costs:

(1) Spills ofradioactive material producing additional residual radioactivity in onsite subsurface material.

There have been no reported spills at the ISFSI.

(2) Facility modifications.

There have been no facility modifications affecting the ISFSI decommissioning cost estimate.

(3) Changes in authorized possession limits.

There are no changes in authorized possession limits affecting the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate.

No actual remediation costs have been incurred.

The estimated cost to decommission the V.C. Summer, Unit 1 ISFSI and release it for unrestricted use is $6.9 million (please see Table 2 in the Attachment). The Authority's one-third share is $2.3 million. The Attachment contains cost estimate details, including key assumptions, a description of the method of assuring funds for decommissioning, and a certification that financial assurance has been provided in the amount of the cost estimate for decommissioning. ;4- b 0 ,.

f\JH S5 ° J tJ ,vi~s -z.i'° One Riverwood Drive I Moncks Corner, SC 29461-2901 I (843) 761-8000 I P.O. Box 2946101 I Moncks Corner, SC 29461-6101 tJ (l /2.

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Michael Crosby March 18, 2019 Page2 This letter contains no new regu_Iatory commitments. If there are any questions concerning this report, please contact me at (843) 761-4126.

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~~l el R. Crosby Senior Vice President Nuclear Energy MRC:trw Attachment cc: Catherine Haney Shawn A. Williams NRC Resident Inspector

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 1 of 12 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 ISFSI DOCKET 72-1038 SOUTH CAROLINA PUBLIC SERVICE AUTHORITY

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 2 of 12 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,(11 with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to deco.mmission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Virgil C. Summer Nuclear Station, Unit 1 (V.C.

Summer) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate;

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2. Spent Fuel Management Strategy The operating license for V.C. Summer is currently set to expire on August 6, 2042.

Approximately 2,757 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed with spent fuel planned to be transferred to the dry storage modules located at the ISFSI, to support continued plant operations. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2l).

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 3 of 12 Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactorPl In January 2013, the DOE issued the "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission on America's Nuclear Future and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fueI..."[ 4l The report stated,

"[W]ith the appropriate authorizations from Congress, the Administration currently plans.

to implement a program over the next 10 years that: ... [A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities."

Based upon DOE's latest strategy (and the potential for other, consent-based siting of consolidated interim storage facilities), South Carolina Electric & Gas (SCE&G) believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. SCE&G's current spent fuel management plan for the V.C. Summer spent fuel is based in general upon the spent fuel being fully removed from the V.C.

Summer site by 2095.

SCE&G's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above. No assumption made in this study should be interpreted to be inconsistent with this claim. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. lfDOE's failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shalJ issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "

4 "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S.

DOE, January 11, 2013

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 4 of 12 For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The V.C. Summer ISFSI is based upon Holtec Intemational's (Holtec) HI-STORM FW System for the dry storage of used nuclear fuel. The HI-STORM FW System consists of a sealed metallic multi-purpose canister (MPC) contained within an overpack constructed from a combination of steel and concrete. The MPC can accommodate up to 37 undamaged Zircaloy-clad pressurized water fuel assemblies. The overpack provides structural protection, cooling, and radiological shielding for the MPC.

The HI-STORM FW overpack is a rugged, heavy-walled cylindrical vessel. The main structural function of the storage overpack is provided by carbon steel, and the main shielding function is provided by plain concrete. The overpack plain concrete is enclosed by a steel weldment of cylindrical shells, a thick baseplate, and a top annular plate. A set of four equally spaced radial connectors join the inner and outer shells and define a fixed width annular space for placement of concrete. The overpack lid also has concrete to provide neutron and gamma shielding.

The on-site ISFSI at V.C. Summer is located west of the Fuel Handling Building (FHB) and northeast of Warehouses A and Bin an expansion of the plant Protected Area. The ISFSI pad has been sized to store 98 HI-STORM FW storage casks with each cask capable of storing 37 Pressurized Water Reactor spent fuel assemblies, which will meet V.C. Summer's spent fuel storage needs over the 60-year licensed life of the plant.

The current spent fuel management plan for the V.C. Summer spent fuel would result in 75 spent fuel storage casks being placed on the ISFSI pad during plant operations. This conservatively assumes that no fuel is removed from the site by the DOE during plant operations or during the nine years of pool operations after the permanent cessation of operations.

The 75 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 5 of 12

5. Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2042) and the DOE's spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. [5l The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 5 of the 75 Holtec overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 157 offloaded assemblies, 37 assemblies per cask which results in 5 overpacks). It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad. [61 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

There is no known subsurface material (soil contamination) in the immediate vicinity of the ISFSI pad that will require remediation to meet the criteria for license termination. As such, there is no allowance for soil remediation in the estimate.

Costs are reported in 2018 dollars and based upon a decommissioning analysis prepared for V.C. Summer in 2016.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. SCE&G, as licensee, will oversee the site activities.

HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev.2, at page 2-83 (Accession Number ML13177A428) 6 HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev. 2, at page 2-84 (Accession Number ML13177A428)

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 6 of 12 Low-level radioactive waste disposal costs are based on SCE&G's currently negotiated rates with the Atlantic Compact and other waste handling service providers.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-l 757Pl The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6. Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

• An initial planning phase in which the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the remediation (overpack disposition) developed.

• The remediation phase includes the cost for craft labor to demolish the activated overpacks, package the steel and concrete in certified waste containers, transportation to the Atlantic Compact Regional Waste site in Barnwell, South Carolina or a bulk waste processing site in Tennessee, for disposal, as well as the costs for the supporting equipment, materials and supplies.

• The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor) to perform the verification survey, SCE&G's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2096, the year following all spent fuel removal.

7. Financial Assurance The ISFSI decommissioning cost estimate in 2018 dollars is $6,856,000 (please see Table

2) based on a cost study prepared by TLG Services, Inc. in 2016. The Authority's portion is $2,285,333 and SCE&G's portion is $4,570,667. SCE&G discloses the required 7

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 7 of 12 financial assurance information relative to its two-thirds ownership share in a separate submittal.

ISFSI operations at V.C. Summer are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract.

It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, the Authority will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

• Although the decommissioning trust fund is for radiological decommissioning (i.e., post-shutdown) costs only, the ISFSI decommissioning is a radiological cost.

Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by the Authority, including ISFSI decommissioning costs.

• The projected minimum certification amount, calculated pursuant to 10 CFR

50. 75( c) required to demonstrate reasonable assurance of funds for decommissioning V.C. Summer is $459,074,840 (2018 dollars), based upon the NRC's latest figures for calculating that value. The Authority's one-third share is

$153,024,947.

• Based upon the Authority's V.C. Summer decommissioning trust fund balance as of December 31, 2018 as reported in the Authority's March 2019 biennial Decommissioning Funding Report and considering an average real rate of return of 0.7 percent on the fund between December 31, 2018 and 2049 when plant decommissioning activities are completed, the trust fund is projected to contain a

$6,088,263 surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10 CFR 50.75(c). This surplus is sufficient to complete the future decommissioning of the ISFSI.

• The Authority will continue to assess the decommissioning trust fund status in accordance with NRC requirements (e.g. 10 CFR 50.75(b)(2), 10 CFR 50.75(+/-)(1), 10 CFR 72.30(c)) and projected surplus, to account for the continued assurance of adequate funds for ISFSI decommissioning. Any adjustments to the cost estimate and funding levels will be made in connection with the triennial filing required pursuant to 10 CFR 72.30(c). To the extent any specific regulatory actions are necessary at the time of withdrawal from the trust fund of the amount .

necessary for ISFSI decommissioning, the Authority will pursue such actions.

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 8 of 12 The Authority hereby certifies that financial assurance for decommissioning its one-third share of the on-site ISFSI at V. C. Summer Unit 1 has been provided in the amount of the cost estimate for decommissioning using the methodology described in the previous paragraphs.

South Carolina Public Service Authority Virgil C. Summer Nuclear Statio.n, Unit 1 Attachment Page 9 of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft) Width (ft) Radioactivity ISFSI Pad 251.5 129.0 No ISFSI Storage Overpack (Holtec FW)

Item Value Notes Overall Height (inches) 239.5 Dimensions are nominal Outside Diameter (inches) .139 Dimensions are nominal Inside Diameter (inches) 81 Dimensions are nominal Quantity 79 75 Spent fuel+ 4 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 5 used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,705,088 Concrete and steel Other Low-Level Radioactive Waste (pounds) 1,766 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 30,414 Cubic feet Low-Level Radioactive Waste (packaged density) 56 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1 No residual radioactivity Number of Overpacks used for GTCC storage 4 No residual radioactivity

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 10 of 12 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2018 dollars) Volume Person-Hours Class A Oversight and Removal Packa!!in!! Transport Disoosal Other Total (cubic feet) Craft Contractor Decommissioning Contractor Planning (characterization, specs and procedures)

- - - - 301 301 - - 1,096 Decontamination/Demolition 139 97 173 2,262 31 2,702 30,414 2,135 -

(activated cask disposition)

License Termination (radiologicalsurvevs)

- - - - 1,373 1,373 - 11,060 -

Subtotal 139 97 173 2,262 1,705 4,376 30,414 13,195 1,096 Suooorting Costs NRC and NRC Contractor Fees and Costs

- - - - 423 423 - - 776 Insurance - - - - 124 124 - - -

Property Taxes - - - - 0 0 - - -

Plant Energy Budget - - - - 54 54 - - -

Non-Labor Overhead - - - - 12 12 - - -

Corporate A&G - - - - 27 27 - - -

Security (industrial) - - - - 219 219 - - 5,013 SCE&G Oversight Staff - - - - 250 250 - - 3,803 Subtotal - - - - 1,109 1,109 - - 9,592 Total (w/o contingency) 139 97 173 2,262 2,814 5,485 30,414 13,195 10,688 Total (w/25% contingency) 174 121 215 2,828 3,518 6,856 - - -

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 11 of 12 Table 3 Financial Assurance 10 CFR 50.75(b) & (c) Decommissioning Estimate (2018 Dollars): $459,074,840 Authority's One-Third Share of Decommissioning Estimate (2018 Dollars): $153,024,947 Market value of the external trust fund at December 31, 2018: $130,713,506 Schedule of annual amounts remaining to be collected 2018 Dollars i Real Beginning Decommissioning Annual Ending Rates Year Balance

• Expenditures . Deposits. Earnings Balance of Return 2019 130,713,506 0 1,151,433 131,864,939 0.0088 2020 131,864,939 115,260 1,146,632 133,126,831 0.0087 2021 133, 126,831 115,260 1,163,657 134,405,748 0.0087 2022 134,405,748 115,260 1,086,344 135,607,351 0.0081 2023 135,607,351 115,260 1,083,797 136,806,408 0.0080 2024 136,806,408 115,260 1,016,705 137,938,373 0.0074 2025 137,938,373 115,260 994,358 139,047,991 0.0072 2026 139,047,991 115,260 1,006,760 140,170,011 0.0072.

2027 140,170,011 115,260 985,280 141,270,551 0.0070 2028 141,270,551 115,260 894,903 142,280,714 0.0063 2029 142,280,714 115,260 901,302 143,297,275 0.0063 2030 143,297,275 115,260 907,741 144,320,276 0.0063 2031 144,320,276 115,260 899,790 145,335,326 0.0062 2032 145,335,326 115,260 906,118 146,356,704 0.0062 2033 146,356,704 115,260 912,486 147,384,450 0.0062 2034 147,384,450 115,260 918,894 148,418,604 0.0062 2035 148,418,604 115,260 910,499 149,444,363 0.0061 2036 149,444,363 115,260 916,792 150,476,415 0.0061 2037 150,476,415 115,260 923,123 151,514,799 0.0061 2038 151,514,799 115,260 914,342 152,544,401 0.0060 2039 152,544,401 115,260 920,555 153,580,216 0.0060

South Carolina Public Service Authority Virgil C. Summer Nuclear Station, Unit 1 Attachment Page 12 of 12 i 2018 Doll~rs.

' Real I.

• Beginning, : Decommi'ssioning Annual . Ending Rates i Year 13alance Experiditures Deposits Earnings Balance of Return 2040 153,580,216 115,260 926,806 154,622,282 0.0060 2041 154,622,282 115,260 917,633 155,655,175 0.0059 2042 155,655,175 9,108,627 869,706 147,416,254 0.0059 2043 147,416,254 21,860,707 745,131 126,300,677 0.0059 2044 126,300,677 21,860,707 619,817 105,059,787 0.0059 2045 105,059,787 21,860,707 485,439 83,684,520 0.0058 2046 83,684,520 21,860,707 360,722 62,184,534 0.0058 2047 62,184,534 21,860,707 235,276 40,559,104 0.0058 2048 40,559,104 21,860,707 107,229 18,805,626 0.0057 2049 18,805,626 12,752,078 34,715 6,088,263 0.0057 Total 130,713,506 153,024,947 2,535,720 25,863,984 6,088,263 The preceding table is excerpted from the Authority's March 2019 Decommissioning Funding Status Report for V.C. Summer Nuclear Station, Unit 1 in accordance with 10 CFR 50.75(f)(1) Reporting and Recordkeeping for Decommissioning Planning and is provided for illustrative purposes.