ML20267A285
| ML20267A285 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 11/23/2020 |
| From: | John Mckirgan Storage and Transportation Licensing Branch |
| To: | Jury K Entergy Services |
| White B | |
| References | |
| EPID L-2017-FPR-0005, EPID L-2017-FPR-0029, EPID L-2017-FPR-0060, EPID L-2017-FPR-0073 | |
| Download: ML20267A285 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 23, 2020 Mr. Keith Jury Vice President, Regulatory Assurance Entergy Services, Inc.
1340 Echelon Parkway M-ECH-61 Jackson, MS 39213
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION ANALYSIS OF ENTERGY SERVICES, INC.S INITIAL AND UPDATED DECOMMISSIONING FUNDING PLANS FOR ARKANSAS NUCLEAR ONE, UNITS 1 AND 2; GRAND GULF NUCLEAR STATION, UNIT 1; RIVER BEND STATION, UNIT 1; AND WATERFORD STEAM ELECTRIC STATION, UNIT 3 INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS
Dear Mr. Jury:
By letter dated December 17, 2012, Entergy Operations, Inc., currently Entergy Services, Inc.
(Entergy), submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, initial decommissioning funding plans (Initial DFPs) for the Independent Spent Fuel Storage Installations (ISFSIs) at Arkansas Nuclear One, Units 1 and 2 (ANO), Grand Gulf Nuclear Station, Unit 1 (Grand Gulf), River Bend Station, Unit 1 (River Bend), and Waterford Steam Electric Station, Unit 3 (Waterford) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12354A131). The NRC issued a Request for Additional Information (RAI) by letter dated April 30, 2014 (ADAMS Accession No. ML14120A273). Entergy responded to the NRCs RAI on July 24, 2014 (ADAMS Accession No. ML14205A483).
By letter dated December 17, 2015, Entergy Operations, Inc., submitted for NRC staff review and approval, updated decommissioning funding plans (updated DFPs) for the ISFSIs at ANO; Grand Gulf; River Bend; and Waterford (ADAMS Accession No. ML15351A523). The NRC issued an RAI by letter and enclosure dated February 23, 2018, regarding Entergys updated DFPs for the ANO, Grand Gulf, River Bend, and Waterford ISFSIs (ADAMS Accession Nos.
ML18058A056 and ML18058A057. Entergy provided RAI responses to the NRC on April 10, 2018 (ADAMS Accession No. ML18101A902).
In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Sections 72.30(b) and (c), and using NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance, the NRC staff reviewed the initial and updated DFPs submitted by Exelon, including the initial and updated 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
K. Jury 2 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 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 Entergy in its initial DFPs 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.
In its initial DFP, Entergy estimated the total costs to decommission the ISFSIs at ANO, Grand Gulf, River Bend, and Waterford for unrestricted use with a twenty-five percent contingency as
$3,758,000, $3,528,000, $3,151,000, and $3,015,000, respectively, in 2012 dollars. Based on its analysis of Entergys Initial DFPs and response to the RAIs, the NRC staff finds that the submitted DCEs: (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 criteria for unrestricted use; (4) and are based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2012 DCEs adequately estimated the cost, in 2012, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCEs are acceptable.
Entergy relied on excess funds from the decommissioning trust funds as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 50.75(e) and 10 CFR 72.30(e)(5).
This is allowed because the ANO, Grand Gulf, River Bend, and Waterford ISFSIs are Part 50 general licensed ISFSIs. The trust fund balances account for the 10 CFR Part 50 license expiration dates and the ISFSI DCEs assume all costs incurred following the year in which spent fuel has been fully removed from the ISFSI. The NRC staff finds that the aggregate dollar amount of the licensees financial instruments provided adequate financial assurance to cover its cost estimates, and therefore, that this financial instrument is acceptable.
Based on its financial analyses, the NRC staff finds that the initial DFPs contain the information required by 10 CFR 72.30(b) and that Entergy has provided reasonable assurance that funds will be available to decommission the ISFSIs at ANO, Grand Gulf, River Bend, and Waterford.
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. The updated DFP must update the information submitted with the original or prior-approved plan. In addition, the DFP must also specifically consider the effect of the following events on decommissioning costs, as required by 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.
K. Jury 3 In its 2015 updated DFPs, Entergy estimated the total costs to decommission the ISFSIs at ANO, Grand Gulf, River Bend, and Waterford for unrestricted use as $9.1 million, $9.9 million,
$7 million, and $7 million, respectively, in 2015 dollars. The updated DCEs considered the requirements of 10 CFR 72.30(c)(1)-(4). Entergy also provided a narrative on each requirement in its April 10, 2018 RAI response. In sum, the licensee explained that no changes in any of the factors listed in 10 CFR 72.30(c)(1)-(4) have occurred. Based on its review of Entergys submittal, the NRC staff finds that the updated DCEs: are based on reasonable costs of a third-party contractor; include an adequate contingency factor; reflect the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and are based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2015 updated DCEs adequately estimated the cost to carry out required ISFSI decommissioning activities prior to license termination, and that the DCEs are reasonable.
In the updated DFPs, Entergy relied on excess funds from the decommissioning trust funds as financial assurance for its ISFSI decommissioning, a method authorized by 10 CFR 50.75(e) and 10 CFR 72.30(e)(5). This is allowed because the ANO, Grand Gulf, River Bend, and Waterford ISFSIs are Part 50 general licensed ISFSIs. The trust fund balances account for the 10 CFR Part 50 license expiration dates and the ISFSI DCEs assume all costs incurred following the year in which spent fuel has been fully removed from the ISFSI. The NRC staff reviewed the licensees 2015 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments provides adequate financial assurance to cover its updated DCEs.
Based on its review, the NRC staff finds that the updated DFPs contain the information required by 10 CFR 72.30(c). The staff finds that Entergy has provided reasonable assurance that funds will be available to decommission the ANO, Grand Gulf, River Bend, and Waterford ISFSIs.
In addition to the NRC staffs review of Entergys initial and updated DFPs, the NRC staff completed an environmental review. The NRC staff determined there were no environmental impacts from the NRC staffs review and approval of Entergys initial and updated DFPs. The NRC staff will publish a summary of the results of the environmental review in the Federal Register in November 2020 1 for ANO; Grand Gulf; River Bend; and Waterford. The environmental assessments and findings of no significant impact for these ISFSIs will be available in https://www.regulations.gov under the Docket ID: NRC-2020-0132.
1 This Federal Register Notice also includes summaries of results for the ISFSIs at the Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Dresden Nuclear Power Station, Units 1, 2, and 3; 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; Clinton Power Station, Unit 1; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; R. E. Ginna Nuclear Power Plant; Zion Nuclear Power Station, Units 1 and 2; Hope Creek Generating Station, Unit 1; Salem Generating Station, Units 1 and 2; and Peach Bottom Atomic Power Station Units 2 and 3.
K. Jury 4 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: 2020.11.23 07:42:09
-05'00' John McKirgan, Chief Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No(s).: 72-13, 72-50, 72-49, and 72-75 License No.: SFGL-02, SFGL-29, SFGL-23, and SFGL-49 CAC No.: 001028 EPID No(s): L-2017-FPR-0005, L-2017-FPR-0029, L-2017-FPR-0060, and L-2017-FPR-0073
K. Jury 5
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION ANALYSIS OF ENTERGY SERVICES, INC.S INITIAL AND UPDATED DECOMMISSIONING FUNDING PLANS FOR ARKANSAS NUCLEAR ONE, UNITS 1 AND 2; GRAND GULF NUCLEAR STATION, UNIT 1; RIVER BEND STATION, UNIT 1; AND WATERFORD STEAM ELECTRIC STATION, UNIT 3 INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS DOCUMENT DATED: November 23, 2020 DISTRIBUTION:
PUBLIC DFM R/F RidsNmssRefsFab KLois, NMSS SHarwell, NMSS FMiller, NMSS MHenderson, NMSS BWhite, NMSS DHabib, NMSS JMaltese, OGC PJehle, OGC TWengert, NRR WAllen, NMSS SLingam, NRR AKlett, NRR JMcKirgan, NMSS RidsNMSSResource RidsNrrPMANO Resource RidsNrrPMGrandGulf Resource RidsNrrPMRiverBend Resource RidsNrrPMWaterford Resource ADAMS Package Accession No.: ML20267A285
- via email OFFICE NMSS/DFM: PM NMSS/DFM: LA OGC (NLO) NMSS/REF/FAB NMSS/STLB: BC NAME RGladney* WWheatley* PJehle* FMiller JMcKirgan*
DATE 09/15/2020 10/20/2020 11/17/2020 11/2/2020 11/23/2020 OFFICIAL RECORD COPY