ML18361A577
| ML18361A577 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/17/2018 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Division of Spent Fuel Management |
| References | |
| 18-428 | |
| Download: ML18361A577 (7) | |
Text
',\\*'
'L VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 17, 2018 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Serial No.18-428 NRA/TJS Rev. 1 Docket Nos. 72-16, 72-56
NORTH ANNA POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS CISFSls) 10 CFR 72.30 DECOMMISSIONING FUNDING PLAN Pursuant to 10 CFR 72.30(b) and (c), Virginia Electric and Power Company (Dominion Energy Virginia) submits the attached decommissioning funding plan for the North Anna Power Station ISFSls.
Please contact Mr. Thomas J. Szymanski at (804) 273-3065 if you have any questions or require additional information.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering & Fleet Support Virginia Electric and Power Company
Attachment:
North Anna Power Station Decommissioning Funding Plan for ISFSls Commitments made by this letter: None cc:
Ms. Yen-Ju Chen Senior Project Manager U.S. Nuclear Regulatory Commission, Mail Stop 4834 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, VA 23060
1.-
North Anna Power Station Decommissioning Funding Plan for ISFSls North Anna Power Station - ISFSls Serial No.18-428 Docket Nos. 72-16, 72-56 Virginia Electric and Power Company (Dominion Energy Virginia)
'v Decommissioning Funding Plan for NAPS ISFSls Specific License No. SNM-2507, Docket No. 72-16 General License under 10 CFR 72.210, Docket No. 72-56 Serial No.18-428 Docket Nos. 72-16, 72-56 Page 1 of 5 Pursuant to 10 CFR 72:30(b), Virginia Electric and Power Company (Dominion Energy Virginia) submitted a decommissioning funding plan for the North Anna Power Station (NAPS) Independent Spent Fuel Storage Installations (ISFSls) on December 17, 2012 (Serial No.12-736, ADAMS Accession No. ML13002A036). Dominion responded to an NRC Request for Additional Information related to this submittal on September 30, 2013 (Serial No.13-434, ADAMS Accession No. ML13283A085). The latest NAPS Decommissioning Funding Plan for the NAPS I SF Sis was submitted on December 2, 2015 (Serial No.15-122, ADAMS Accession No. ML15342A039).
1 O 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 provides Dominion Energy Virginia's periodic update to the NAPS ISFSI decommissioning funding plan.
- Pursuant to 10 CFR 72.30(b), a decommissioning funding plan must contain:
- 1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.
Dominion Energy Virginia provides financial assurance for the decommissioning of NAPS using the external sinking fund method. Collections are based on site-specific cost estimates that include radiological decommissioning, spent fuel management (including ISFSI decommissioning) and site restoration.
Table 1 below shows the Total Funds and Allocated Radiological Funds accumulated as of December 31, 2017 and in future dollars for NAPS Units 1 and 2.
The table shows that the funds available for ISFSI Decommissioning, Spent Fuel Management and Site Restoration exceed the ISFSI Decommissioning Cost Estimate (OGE) amount.
\\
- ---- --- ~~--
Table 1 Allocated Radiological Total Funds in Total Funds in Funds in Unit External Trusts External Trusts External Trusts End of License Year (12/31/17 $)
(Future $)<1>
(12/31/17 $)
North Anna Unit 1
$541.02
$865.94
$371.84 2038 million million million North Anna Unit 2
$508.07
$853.04
$351.83 2040 million million million Allocated Radiological Funds in External Trusts (Future $)<2>
$595.15 million
$590.72 million Serial No.18-428 Docket Nos. 72-16, 72-56 Page 2 of 5 Funds Available ISF'Sls Decom, Spent Fuel Mgt &
ISF'Sls NRCMinimum Site Restoration DCE (Future $)131 112131111 s11*1 (12/31/17 $)(ij
$423.61
$169.18 million million
$1.45
$423.61
$156.24 million million million
- 1) Total Funds in External Trusts (Future$)= 2% Real Rate of Return applied to growth of funds in the External Trust to 3.5 years after Start of Decommissioning for each unit
- 2) Allocated Radiological Funds in External Trusts (Future$)= 2% Real Rate of Return applied to growth of funds in the External Trusts to 3.5 years after Start of Decommissioning for each unit.
- 3) NRC Minimum (Future$) = NRC Minimum amount reflects December 31, 2017 NRC Minimum Amount due to the application of a 2% Real Rate of Return to growth of funds in the External Trusts and keeping the NRC Minimum amount constant. The NAPS NRC Minimum Amounts are presented representing Dominion's 89.26% share of responsibility for NAPS decommissioning costs 1.
- 4) Funds Available for ISFSI Decommissioning, Spent Fuel Management and Site Restoration (12/31/17 $) is calculated as the difference between Total Funds in the External Trusts (2017 $) and the Allocated Radiological Funds in External Trusts (2017 $).
- 5) ISFSI DCE amount as reported in Table 2 of this filing.
As a regulated electric utility, Dominion Energy Virginia has the ability to recover its cost of service, including decommissioning funding, through rates. Dominion Energy Virginia maintains a site ISFSI DCE for NAPS, which it updates approximately every five years to determine whether there is any need to adjust rates collected from ratepayers and contributed to the external sinking fund.
1 North Anna Power Station is jointly owned by Virginia Electric and Power Company (88.4%)
and Old Dominion Electric Cooperative (11.6%). However, Dominion Energy Virginia is responsible for 89.26% of the decommissioning obligation.
Serial No.18-428 Docket Nos. 72-16, 72-56 Page 3 of 5
- 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.
General Methodology Used to Develop ISFSI Decommissioning Cost Estimates A site-specific ISFSI DCE based on 10 CFR 72.30 requirements was prepared for the NAPS ISFSI in 2014. The ISFSI DCE was based on the assumption that a third party contractor would perform decommissioning. To determine the cost of using a third party contractor, fully burdened labor rates (labor costs plus employee benefits and taxes) were used as a basis and a premium was added to represent a third party contractor's profit margin.
The site-specific ISFSI DCE includes undistributed costs (for support activities and costs such as staff, security, insurance, energy, materials and services) allocated to the ISFSI decommissioning period. The site-specific ISFSI DCE includes 25%
contingency in accordance with NUREG-1757, Volume 3, Revision 1. Table 2 below shows the contingency as one line item.
The site-specific ISFSI DCE is based on remediating the site to a residual radioactivity level consistent with 10 CFR 20.1402 (i.e., unrestricted use). As shown in Table 2 below, the estimated cost to Dominion to decommission the ISFSls at NAPS is $1.396 million in 2014 dollars (89.26% decommissioning responsibility). Applying a CPl2 based annual escalation rate to-the 2014 dollars shown in Table 2, the total cost to decommission the NAPS ISFSls is $1.450 million in 2017 dollars.
2 The mnemonic for CPI-U is shown under Item 4.
Table 2 North Anna Power Station Serial No.18-428 Docket Nos. 72-16, 72-56 Page 4 of 5 Site Specific Cost Estimates Applicable to ISFSI Decommissioning Costs - 10 CFR 72.30 (in thousands of dollars) 25%
Total Total ISFSI Decommissioning Actlvltv Description Labor Equipment Disposal Other Contingency 2014$
2017$
Distributed (Direct) Cost Preparation and NRC Review of License Termination Plan 87 $
137 $
225 $
Verification Survey of Horizontal Storage Modules 117 $
56 $
173 $
Preoaration of Final Re Port on Decommissioning and NRC Review 87 $
137 $
225 $
Total Distributed (Direct) Cost 292 $
56 275 623 Total Undistributed (Allocated) Cost 323 13 $
157 $
494 $
Total North Anna ISFSI Decommissioning Cost 615 $
70 $
432 1,117 $
25% Contingency Applied to Total North Anna ISFSI Decommissioning Cost Estimate 279 279 Total North Anna ISFSI Decommissioning Cost Estimate with Contingency 1,396 Annual Escalation Rate (2014$ to 2017$)
1.27%
Escalation Rate based on avera2e of CPI-U Indices for Period shown Decommissioning Cost shown at 89.26%
Dominion Energy Virginia Decommissioning Responsibility Percentage Information Required by 10 CFR 72.30(c}
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 of radioactive 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 DCE.
(3) Changes in authorized possession limits.
As stated below, the ISFSI DCE is based on ISFSls that are sized, when used in conjunction with the spent fuel pool, to accommodate the spent fuei generated over the life of the station. There are no changes in authorized possession limits affecting the DCE.
(4) Actual remediation costs that exceed the previous cost estimate.
No actual remediation costs have been incurred..
- 3) Identification of and justification for using the key assumptions contained in the DCE The DCE for the NAPS ISFSls assumes:
- i.
ISFSls that are sized, when used in conjunction with the spent fuel pool, to accommodate the spent fuel generated over the life of the station.
234 180 234 647 513 1,160 290 1,450
Serial No.18-428 Docket Nos. 72-16, 72-56 Page 5 of 5 ii.
Decommissioning will be performed by an independent contractor as required.
iii.
Storage canisters will be used to ship the contained spent fuel to the Department of Energy. Single purpose canisters will be qualified for shipment or transported in licensed transportation overpacks to avoid the need for repackaging and will maintain occupational exposures as low as reasonably achievable.
iv.
A dry transfer facility will not be necessary.
- v.
The ISFSI pads and support modules are assumed to be free of contamination and left in place.
- 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.
Dominion Energy Virginia uses an external sinking fund method for NAPS. The external sinking fund is based on site-specific cost estimates that include estimated ISFSI decommissioning costs. Dominion Energy Virginia updates these cost estimates approximately every five years to determine whether there is any need to adjust rates collected from ratepayers and contributed to the external sinking fund.
The ISFSI decommissioning funding plan periodically submitted pursuant to 10 CFR 72.30 (c) will further adjust the most recent site-specific ISFSI DCE using a CPI indice based escalation rate and will consider the need for any further adjustment based on the factors in 10 CFR 72.30(c)(1) - (4).
The CPI indice annual escalation rate mnemonic is as follows:
CPI - U: Urban Consumer -All Items, (Index 1982-84=100, SA), U.S. Bureau of Labor Statistics (BLS); Moody's Analytics (ECCA) Forecast, Quarterly, United States.
- 5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.
Onsite subsurface material associated with the NAPS ISFSls is assumed to have no residual radioactivity that will require remediation to meet the criteria for license termination. The spent fuel storage casks are sealed and contain no liquid.
- 6) A certification that financial assurance for decommissioning has been provided in the amount of the_ cost estimate for decommissioning.
Dominion Energy Virginia certifies that financial assurance for the estimated cost of decommissioning the NAPS ISFSls has been provided as discussed above.