ML18324A594

Letter to J. Welsch Nuclear Regulatory Commissions Analysis of Pacific Gas and Electric Companys Initial Decommissioning Funding Plan and Updated Decommissioning Funding Plan for Diablo Canyons Independent Spent Fuel Storage Installation

ML18324A594
Person / Time
Site:	Diablo Canyon
Issue date:	11/19/2018
From:	John Mckirgan Spent Fuel Licensing Branch
To:	Welsch J Pacific Gas & Electric Co
Longmire P
Shared Package
ML18324A593	List: ML18324A594
References
CAC 001028, EPID L-2017-FPR-0021
Download: ML18324A594 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 19, 2018 James Welsch, Vice President Nuclear Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424

SUBJECT:

NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF PACIFIC GAS AND ELECTRIC COMPANYS INITIAL DECOMMISSIONING FUNDING PLAN AND UPDATED DECOMMISSIONING FUNDING PLAN FOR DIABLO CANYONS INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mr. Welsch:

By letter dated December 17, 2012, Pacific Gas and Electric Company (PG&E) submitted, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval, an initial decommissioning funding plan (initial DFP) for the independent spent fuel storage installation (ISFSI) at Diablo Canyon Power Plant (DCPP) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12353A315). By letter dated December 17, 2015, PG&E submitted, also for NRC staff review and approval, an updated decommissioning funding plan (updated DFP) for the ISFSl at DCPP (ADAMS Accession No. ML15351A502).

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 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 ISFSI. The DFP must contain a detailed decommissioning cost estimate (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 PG&E in its initial DFP on how reasonable assurance will be provided that funds will be available to decommission the ISFSI, including the amount of the DCE and the method of assuring funds for decommissioning.

In the initial DFP, PG&E estimated that the total cost to decommission the ISFSI at DCPP for unrestricted use is $5,180,500, in 2012 dollars. Based on its analysis of PG&Es initial DFP, the

NRC staff finds that the submitted DCE is based on reasonable costs of a third party contractor; includes an adequate contingency factor; and is based on reasonable and documented assumptions. Therefore, the NRC staff finds that the DCE adequately estimates the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCE is acceptable.

PG&E relied on an external sinking fund as financial assurance for ISFSI decommissioning, a method authorized by 10 CFR 72.30(e). The NRC staff finds that the aggregate dollar amount of the licensees financial instruments provides adequate financial assurance to cover its cost estimates, and therefore, that these financial instruments are acceptable.

Pursuant to 10 CFR 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the initial 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 (updated DFP). The updated DFP must update the information submitted with the original or prior approved plan. In addition, the updated DFP must 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.

In the updated DFP, PG&E estimates that the total cost to decommission the ISFSI at DCPP for unrestricted use is $6,031,600, in 2015 dollars. The updated decommissioning cost estimate (updated DCE) considered the requirements of 10 CFR 72.30(c)(1)-(4) and the licensee provided a narrative on each requirement. The licensee stated:

There have not been any spills of radioactive material in the Diablo Canyon ISFSI storage site and cask transfer facility (CTF).

There are no radioactive systems at the ISFSI storage pads other than the overpacks containing multi-purpose canisters (MPCs). The fuel is stored dry inside the MPC, so that no radioactive liquid is available for leakage. The MPCs are loaded, welded, and the upper lid decontaminated in the Diablo Canyon Power Plant fuel handling building/auxiliary building before being moved to the CTF located near the ISFSI storage pads. The overpacks are loaded and the lids installed prior to movement from the CTF to the ISFSI pads. Fuel is not removed from the MPCs at either the ISFSI storage pads or the CTF. Unloading of the fuel from the MPC, if necessary, would only occur in the SFP in the FHB/AB.

There have been no modifications to the Diablo Canyon ISFSI design that could impact decommissioning costs, and no modifications are expected in the future that would increase decommissioning costs.

No changes to this limit are planned during the plant operating period.

Based on its review of PG&Es submittal, the NRC staff finds that the updated DCE: is based on reasonable costs of a third party contractor; includes an adequate contingency factor; and is based on reasonable and documented assumptions. Therefore, the NRC staff finds that the updated DCE adequately estimates the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCE is acceptable.

PG&E currently relies on an external sinking fund as financial assurance for the ISFSI decommissioning, a method authorized by 10 CFR 72.30(e). The NRC staff reviewed the licensees updated DFP for DCPP, Units 1 and 2, and finds that the aggregate dollar amount of the licensees financial instruments provides adequate financial assurance to cover its updated DCE.

The NRC staff reviewed the initial and updated DFP submitted by PG&E, including the initial and updated DCEs and the method of assuring funds for decommissioning, in accordance with 10 CFR 72.30(b) & (c) and NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance. Based on its review, the NRC staff finds that the initial and updated DFPs contain the information required by 10 CFR 72.30(b) and (c) and PG&E has provided reasonable assurance that funds will be available to decommission the DCPP ISFSI.

In addition to the NRC staffs review of PG&Es initial and updated DFP, the NRC staff completed an environmental review. On June 7, 2018, the NRC staff published the results of that review in an environmental assessment (EA) and finding of no significant impact (FONSI) in the Federal Register (83 FR 26501). The NRC staff determined there were no environmental impacts from the NRC staffs review and approval of PG&Es DFP.

If you have any questions regarding this matter, please contact me or Pamela Longmire, Ph.D.

of my staff at (301) 415-7465.

Sincerely,

/RA/

John McKirgan, Branch Chief Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-26 CAC No.: 001028 EPID No.: L-2017-FPR-0021

SUBJECT:

NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF PACIFIC GAS AND ELECTRIC COMPANYS INITIAL DECOMMISSIONING FUNDING PLAN AND UPDATED DECOMMISSIONING FUNDING PLAN FOR DIABLO CANYONS INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCUMENT DATE: November 19, 2018 DISTRIBUTION:

SFM R/F JMcKirgan, NMSS ABowers, NRR KLois, NRR SHarwell, NRR MHenderson, NRR BSingal, NRR G:/SFST/72.30 Decommissioning Funding Plans/Closeout/Diablo Canyon/DC closeout letter (OGCHLWreview_NLO).docx Final EA: ML18131A047 ADAMS Package No.: ML18324A593 Memo: ML18324A594 OFC NMSS/DSFM NMSS/DSFM OGC NMSS/DSFM NAME PLongmire WWheatley via email NNoelliste via email JMcKirgan DATE 10/29/2018 10/31/2018 10/29/2018 11/19/2018 OFFICIAL RECORD COPY