ML13100A127
| ML13100A127 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/12/2013 |
| From: | Berg W Dairyland Power Cooperative |
| To: | Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards |
| References | |
| LAC-14270 | |
| Download: ML13100A127 (10) | |
Text
WILLIAM L. BERG President and CEO DAIRYIAND POWER COO 0 E RATIVE March 12, 2013 10 CFR 72.30(b)
In reply, please refer to LAC- 14270 DOCKET NO. 50-409 and 72-046 ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)
Possession-Only License DPR-45 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation
REFERENCES:
Dairyland Power Cooperative is submitting to the NRC for review and approval the enclosed Decommissioning Funding Plan for the LACBWR Independent Spent Fuel Storage Installation (ISFSI) in accordance with 10 CFR 72.30(b). Attachment 1 addresses each of the six criteria contained in 10 CFR 72.30(b) and references Attachment 2 which provides details concerning the LACBWR ISFSI decommissioning cost estimate that is derived from a study performed by Sargent & Lundy, LLC.
This letter identifies no new commitments and revises no existing commitments.
If you have any questions concerning this Decommissioning Funding Plan for the LACBWR ISFSI, please contact Don Egge, LACBWR Plant/ISFSI Manager at (608) 689-4207.
Sincerely, William L. Berg, President and EO WLB:JBM-jkl JýýE;Lý A Touchstone EnergyP Cooperative 4'
3200 East Ave. S.
- PO Box 817 . La Crosse, WI 54602-0817
- 608-787-1258 e 608-787-1469 fax . www.dairynet.com
Document Control Desk LAC- 14270 Page 2 March 12,2013 Attachments: 1) Decommissioning Funding Plan for the LACBWR Independent Spent Fuel Storage Installation (ISFSI)
- 2) LACBWR ISFSI Decommissioning Cost Estimate, Revision 1, March 2013 cc w/Attachments: John Hickman Project Manager U.S. Nuclear Regulatory Commission Charles Casto Regional Administrator, Region III U.S. Nuclear Regulatory Commission STATE OF WISCONSIN )
)
COUNTY OF LA CROSSE )
Personally came before me this / day of , 2013, the above named, William L. Berg, to me known to be the person who executed the foregoing instrument and acknowledged the same.
N blic, La Crosse County Wisconsin My commission expires 6> '- A 17V LAURIE A. ENGEN Notary State Public of Wisconsin
Document Control Desk LAC- 14270 ATTACHMENT 1 Page 1 Decommissioning Funding Plan for the LACBWR Independent Spent Fuel Storage Installations (ISFSI)
Dairyland Power Cooperative (DPC) is the holder of a general license under 10 CFR 72, Subpart K for the LACBWR ISFSI in which five NAC-MPC dry cask storage systems containing all LACBWR spent fuel and fuel debris are located. Cask loading and transport operations were completed September 19, 2012. No additional spent fuel shall be stored at the LACBWR ISFSI.
DPC provides the following information required by 10 CFR 72.30(b) included in the Decommissioning Funding Plan for the LACBWR ISFSI:
Requirement 1:
10 CFR 72.30(b)(1) Information on how reasonable assurancewill be provided thatfinds will be available to decommission the ISFSI or MRS.
Information for Requirement 1:
Pursuant to 10 CFR 72.30(e)(5), because LACBWR was a power reactor licensed under 10 CFR 50, DPC utilizes the methods of 10 CFR 50.75(e)(1)(ii) to provide financial assurance for the LACBWR ISFSI.
The DPC Nuclear Decommissioning Trust (DPC NDT) is established with a separate sub-account for the accumulation of ISFSI decommissioning funds.
Requirement 2:
10 CFR 72.30(b)(2) A detailedcost estimatefor decommissioning, in an amount reflecting.
('i) The cost of an independent contractorto perform all decommissioning activities; (ii) An adequate contingencyfactor; and (iii) The cost of meeting the § 20.1402 of this chapter criteriafor unrestricted use, provided that, if the applicantor licensee can demonstrateits ability U to meet the provisionsof§ 20.1403 of this chapter, the cost estimate may be based on meeting the § 20.1403 criteria.
Information for Requirement 2:
Information contained in the LACBWR ISFSI Decommissioning Cost Estimate, derived from a study performed by Sargent & Lundy, LLC, provides the recently revised decommissioning cost estimate (DCE) for the LACBWR ISFSI and is included as Attachment 2. The DCE for the LACBWR ISFSI was
$1,675,129 as of January 31, 2013. The DCE uses a contract labor rate, applies adequate contingency factors, and assumes unrestricted use criteria.
Requirement 3:
10 CFR 72.30(b)(3) Identification of andjustificationfor using the key assumptions contained in the DCE.
Document Control Desk LAC-14270 ATTACHMENT 1 Page 2 Information for Requirement 3:
Information contained in the LACBWR ISFSI Decommissioning Cost Estimate, derived from a study performed by Sargent & Lundy, LLC, provides the DCE for the LACBWR ISFSI and is included as . Identification of and justification for using the key assumptions contained in the DCE are provided in Attachment 2.
Requirement 4:
10 CFR 72.30(b)(4) A descriptionof the method of assuringfundsfor decommissioningfrom paragraph(e) of this section, includingmeans for adjusting cost estimates and associatedfunding levels periodically over the life of thefacility.
Information for Requirement 4:
As indicated in the information for Requirement 1, DPC utilizes the methods of 10 CFR 50.75(e)(1 )(ii) to provide financial assurance for the LACBWR ISFSI. The DPC NDT is established with a separate sub-account for the accumulation of ISFSI decommissioning funds. The DCE for the LACBWR ISFSI will be adjusted every three years as required by 10 CFR 72.30(c). DPC will adjust the amount of financial assurance required by the ISFSI DCE by assessing whether changes in the DCE or investment earnings performance necessitate additional collections. DPC Board policy is to provide additional funding, as necessary, through rates charged to its members or through transfers from reserve funds to ensure that the DPC NDT, with future investment earnings, will be sufficient to cover final decommissioning expenses.
Requirement 5:
10 CFR 72.30(b)(5) The volume of onsite subsurface materialcontaining residualradioactivitythat will require remediation to meet the criteriafor license termination.
Information for Requirement 5:
There is no known subsurface material containing residual radioactivity in the proximity of the LACBWR ISFSI that will require remediation to meet the criteria for license termination.
Requirement 6:
10 CFR 72.30(b)(6) A certification thatfinancialassurancefor decommissioninghas been provided in the amount of the cost estimatefor decommissioning."
Information for Requirement 6:
Financial assurance for decommissioning the LACBWR ISFSI is provided in accordance with 10 CFR 50.75(e)(1)(ii) which pursuant to 10 CFR 72.30(e)(5) provides the requisite financial assurance for the ISFSI decommissioning cost. Dairyland Power Cooperative, the licensee for the La Crosse Boiling Water Reactor and ISFSI, hereby certifies that the decommissioning cost estimate for the ISFSI was $1,675,129 as of January 31, 2013, and that it was revised on March 11, 2013, as indicated in Attachment 2 to be
$1,435,626. We further certify that the funds accumulated for ISFSI decommissioning were $1,669,124 as of January 31, 2013.
Document Control Desk LAC-14270 ATTACHMENT 2 LACBV'-. ISFSI DECOPMBSCDIGG COST ESTIMATE PI&RCH 2MS PREPARED B ,nrvs DA C, afityMa~~nacqSupervisor REVIEWED BY DA I Support Engineer, Licensing TE 3//'Z1/3 APPROVED BY DA P1tnISFSI Maf'gar
Document Control Desk LAC-14270 ATTACHMENT 2 RECORD OF REVISIONS Revision 0 ISFSI Decommissioning Cost Estimate is established within the 2010 LACBWR Decommissioning & Decontamination Cost Study Update (November 2010) as System Identification No. 1100.
Revision 1 ISFSI Decommissioning Cost Estimate (DCE) is established as a unique document separate from the LACBWR Decommissioning & Decontamination Cost Study Update. The ISFSI DCE uses the same assumptions for rates, costs, weight conversions, and contingency factors as applied in the LACBWR Decommissioning & Decontamination Cost Study Update. The volume of concrete to be disposed of is revised to reflect the MPC-LACBWR as-built vertical concrete cask (VCC) dimensions. These VCC dimensions differ from those documented in Reference 1 previously used to establish the ISFSI DCE.
Use of the as-built VCC dimensions results in a reduction in the volume of concrete to be disposed of. Other changes include:
o All costs have been adjusted, based on 2013 dollars.
o Labor costs for 2013 will be based on a DPC labor cost (administrative and union averages) for metal removal. Specialty contractor rate for concrete removal will be used where concrete or soil removal is required.
This represents an approximate 4.92% increase over the 2010 rates based on DPC's labor cost increase.
- DPC labor cost $71.66/hr
- Contractor labor cost $87.29/hr
- Contractor labor and equipment cost $152.76/hr
- Blended rate (DPC and Contractor with equipment) $112.21/hr o All costs for reprocessing and burial of radioactive material are based on Reference 3.
Document Control Desk LAC-14270 ATTACHMENT 2 Introduction Dairyland Power Cooperative (DPC) is the holder of a general license under 10 CFR 72, Subpart K for the LACBWR ISFSI in which five NAC-MPC dry cask storage systems containing all LACBWR spent fuel and fuel debris are located. Cask loading and transport operations were completed September 19, 2012. No additional spent fuel shall be stored at the LACBWR ISFSI.
The ISFSI was developed as an interim spent fuel storage option until a long term solution is available. This document represents the decommissioning cost estimate (DCE) for the LACBWR ISFSI after title to the fuel and possession of the fuel is transferred to the Secretary of Energy.
Assumptions
- 1) The concrete pad and equipment are not radioactively contaminated.
- 2) The concrete pad (48' x 32' x 3') and ramp (30' x 16' x 3') will be left in place.
- 3) The five vertical concrete casks (VCCs, 10'-8" diameter, 22" thick walls, 13'-4" tall) and lids (6'-6" diameter, 8.25" thick) will be disposed of as radioactive waste.
- 4) All fencing, lighting, security systems, and building will be left as is.
- 5) Costs are based on the current LACBWR Decommissioning and Decontamination Cost Study Update.
- 6) All material removed will be disposed of at an approved disposal site.
Reference Materials
- 1) Sargent & Lundy Report, "Independent Review of Decommissioning Cost Study for LACBWR," SL-010039, April 15, 2010
- 2) 2013 LACBWR Decommissioning and Dismantlement Cost Study Update
- 3) Energy Solutions Schedule of Charges, Effective Date January 1, 2011, through December 31, 2016 System Classification In keeping with LACBWR contamination criteria, all material removed from the ISFSI for disposal will be considered "Potentially Clean" having <0.1 mRem/hr general dose rate.
Labor Labor rates and contingencies are as determined in the current LACBWR Decommissioning and Decontamination Cost Study Update:
- 2) Contracted labor rate to DPC = $87.29/hr
- 3) Contracted labor rate with required equipment to DPC = $152.76/hr
- 4) Blended rate (DPC and Contractor with equipment) = $112.2"1/hr LACBWR ISFSI DCE 1 of 4 REVISION 1
Document Control Desk LAC-14270 ATTACHMENT 2 The following contingency estimates will be applied to the labor costs:
- 1) Clean component removal - 15%
An annual escalation rate of 4% per year will be applied to the labor costs.
ShiD*ina Transportation of material from the LACBWR ISFSI will be made by either truck or rail based on expense and availabilities.
The following contingency estimates will be applied to the shipping cost:
- 1) Conventional radioactive waste shipping, both truck and rail -- 15%
An annual escalation rate of 3% per year will be applied to the shipping cost for all material.
Burial All concrete disposed of during the decommissioning of the LACBWR ISFSI will be sent to Energy Solutions for direct burial.
Pricing used will be as per Reference 3. A 5.263% tax will be added to the burial fee for all material sent to direct burial at Clive, UT.
The following contingency rate estimate will be applied to the burial cost:
- 1) Soil and concrete radwaste burial - 50%
An annual escalation rate of 5% per year will be applied to the burial costs.
Materials The cost of materials/consumables has remained relatively constant.
A contingency rate estimate of 25% will be applied to the material cost.
An annual escalation rate of 4% per year will be applied to the material costs.
LACBWR ISFSI DCE 2 of 4 REVISION 1
Document Control Desk LAC-14270 ATTACHMENT 2 System/Project: ISFS I 2013 Rates Used to Determine Cost A Reprocessing Rates: = N/A B Burial Rates: = Concrete to Clive, UT 3
$65/ft3 + $5.263% tax = $68.42/ft C Transportation Cost: = $5,547/load of 40,000 lbs of waste material to Oak Ridge, TN
= $7,521/railcar of 180,000 lbs of waste to Energy Solutions D Unit Removal Rate: = 0.006 man hours/lb E Labor Rate: = Contract labor $87.29/hr F Weights Used for Conversion:
Dirt Weight = 150 Ibs/ft3 7.66 lbs/ft of 3" piping schedule 80 Normal concrete weight = 150 Ibs/ft3 40 lbs/ft2 of 1" plate steel High density concrete weight = 230 Ibs/ft3 800 lbs for 8" valves 58 lbs/ft of 8" piping schedule 80 500 lbs for 3" - 8' valves G Larger ComDonent Weiahts are obtained from technical manuals when available MATERIAL REMOVED Piping < 2.5" Linear feet = lbs Piping > 2.5" Linear feet = lbs Valves > 8" = lbs Valves 2.5" - 8" = lbs Plate steel from tanks or components lbs Others: lbs lbs lbs Total weight = lbs NOTES: 5 VCCs with lids - 3,530 ft 3 concrete to dispose of.
(1 VCC = 678 ftW, 1 lid = 27.65 ft')
Cost includes final release survey of ISFSI site.
ISFSI cost is not added to the LACBWR plant decommissioning cost.
ISFSI DCE is used for separate funding of ISFSI decommissioning.
COSTS Assigned labor hours: 3,177 hrs Assigned ManRem: N/A Rem Final release labor hours: 5,407 hrs Rate 2013 Cost % Contingency 2013 with Contingencies Labor $87.29/hr $749,297 15 $861,692 Shipping $5,547/load $73,428 15 $84,443 Reprocessing Burial $68.42/ft 3 $241,523 50 $362,285 Material $115,642 10 $127,206
$1,179,890 = TOTAL = $1,435,626 LACBWR ISFSI DCE 3 of 4 REVISION 1
Document Control Desk LAC-14270 ATTACHMENT 2 TABLE 1 2013 Cost Study Contingency Estimates LABOR Clean component removal 5%
SHIPPING Contaminated material shipments 15%
RADIOACTIVE WASTE BURIAL Soil and concrete radwaste burial 50%
MATERIAL 25%
TABLE 2 2013 Cost Study Annual Escalator Rates LABOR 4%
SHIPPING Contaminated material shipments 3%
RADIOACTIVE WASTE BURIAL Energy Solutions (All soil and concrete) 5%
MATERIAL 4%