ML14073A068

Boiling Water Reactor, Annual Decommissioning Funding Status Report

ML14073A068
Person / Time
Site:	La Crosse  File:Dairyland Power Cooperative icon.png
Issue date:	03/10/2014
From:	Berg W Dairyland Power Cooperative
To:	Document Control Desk, NRC/FSME
References
LAC-14295
Download: ML14073A068 (6)

Text

WILLIAM L. BERG President and CEO DAIRYLAND POWER COOPERATIVE March 10, 2014 10 CFR 50.75(f)(2) 10 CFR 50.82(a)(8)

In reply, please refer to LAC-14295 DOCKET NO. 50-409 and 72-046 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)

Possession-Only License DPR-45 Annual Decommissioning Funding Status Report

REFERENCES:

1) 10 CFR 50.75(f)(2)

2) 10 CFR 50.82(a)(8)(v-vii)

In accordance with References 1 and 2, we are submitting our annual report on the status of decommissioning funding for the La Crosse Boiling Water Reactor.

If you have any questions concerning this information, please contact Don Egge, LACBWR Plant/ISFSI Manager at (608) 689-4207.

Sincerely, William L. Berg, President anCEO WLB:JBM:jkl

Attachment:

1) Decommissioning Funding Status Report for the La Crosse Boiling Water Reactor March 31, 2014 K

A Touchstone Energy Cooperative ____

3200 East Ave. S. e PO Box 817 e La Crosse, WI 54602-0817

• 608-787-1258 9 608-787-1469 fax

• www.dairynet.com

Document Control Desk LAC-14295 Page 2 March 10, 2014 cc w/

Attachment:

John Hickman Project Manager U.S. Nuclear Regulatory Commission Cynthia Pederson Regional Administrator, Region III U.S. Nuclear Regulatory Commission STATE OF WISCONSIN )

)

COUNTY OF LA CROSSE )

Personally came before me this /0 'k day of 2" tA,.* t", 2014, the above named, William L. Berg, to me known to be the person who executed the foregoing instrument and acknowledged the same.

Notary Public, La Crosse County My commission expires __ 5_- _ __/ _

LAURIE A. ENGEN Notary Public State of Wisconsin

Document Control Desk LAC-1 4295 ATTACHMENT 1 March 10, 2014 DECOMMISSIONING FUNDING STATUS REPORT FOR THE LA CROSSE BOILING WATER REACTOR MARCH 31, 2014 1.0 STATUS REPORTING IN ACCORDANCE WITH 10 CFR 50.75(f)(2) 1.1 The amount of funds estimated to be required for the LACBWR plant decommissioning as of 12/31/2013 pursuant to 10 CFR 50.75(b) and (c) was

$120,225,200.

This formula decommissioning cost value is derived using guidance from NUREG-1307, Revision 15, and a 1986 Base Cost of $22,472,000. As explained in the response to an NRC Request for Additional Information (RAI) dated 08/08/2012 (ADAMS Accession No. ML12235A299), based on a 1983 decommissioning cost estimate of $20,000,000, Dairyland Power Cooperative (DPC) submitted to the NRC a decommissioning funding report for LACBWR dated 07/25/1990 in which DPC concluded that decommissioning would cost

$90.9 million if decontamination and dismantling could begin in 2010.

Furthermore, DPC recognized that the funding plan contained in the Decommissioning Plan submitted to the NRC 12/21/1987 contemplated that total decommissioning costs for LACBWR would be below the levels set forth in 10 CFR 50.75(c)(1). To the extent that such an exemption was deemed necessary by the NRC, DPC requested exemption from funding the Decommissioning Trust at the minimum amount established in 10 CFR 50.75(c)(1) and requested that the NRC approve the continued funding of the Decommissioning Trust at the level set forth in the previously filed Decommissioning Plan.

The NRC approved a decommissioning cost of $92,000,000 in 2010 dollars in its Safety Evaluation of the Order to Authorize Decommissioning and Amendment No. 66 to Possession-Only License DPR-45 dated 08/07/1991 without exemption from 10 CFR 50.75(c)(1). The NRC cited the new decommissioning regulations as the basis for the approval (53 FR 24018, June 27, 1988, at page 24027, Column 1) stating that for reactors already shut down, "details concerning financial assurance ... would be decided on a case-by-case basis."

This formula decommissioning cost value does not reflect funds spent for substantial LACBWR plant decommissioning activities completed to date and discussed further in Section 2.0 of this report.

Based on a site specific decommissioning cost estimate revised March 2013, the amount of funds required for the LACBWR ISFSI decommissioning was

$1,435,626. This revised ISFSI Decommissioning Cost Estimate (DCE) reflects the MPC-LACBWR as-built vertical concrete cask (VCC) dimensions. These VCC dimensions differ from those previously used to establish the ISFSI DCE.

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Document Control Desk LAC-1 4295 ATTACHMENT 1 March 10, 2014 Use of the as-built VCC dimensions results in a reduction in the volume of concrete to be disposed of.

As of 12/31/2013, the cost of ISFSI decommissioning being carried on general ledger accounts was $1,741,226.

1.2 The amount of funds accumulated in the DPC Nuclear Decommissioning Trust (DPC NDT) for the LACBWR plant decommissioning as of 12/31/2013 was

$89,656,577.

The amount of funds accumulated in the DPC NDT for the LACBWR ISFSI decommissioning as of 12/31/2013 was $1,741,385.

1.3 A schedule of the annual amounts remaining to be collected for the LACBWR plant decommissioning is not included because no further amounts are scheduled to be collected.

1.4 The assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in the funding projections are as follows:

1.4.1 The average escalation rates applied in the decommissioning cost estimate are:

• Labor 4.0%

• Indirect 4.0%

• Shipping 3.0%

• Reprocessing 5.0%

• Material 4.0%

• Burial - Radwaste 5.0%

1.4.2 The DPC NDT investment earnings projections are:

• Equity Investments: 7.5%

• Money Market and Fixed Income Investments: 2.0% to 5.0%

1.4.3 The current Board approved DPC NDT asset allocation goal is 30% to 60% in equity investments and the balance in fixed income investments.

1.5 There are no contracts upon which DPC is relying pursuant to paragraph (e)(1)(v) of 10 CFR 50.75.

1.6 There have been no modifications to DPC's method of providing financial assurance since the last submitted report.

1.7 There have been no changes to DPC's Nuclear Decommissioning Trust Agreement since the last submitted report.

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Document Control Desk LAC-1 4295 ATTACHMENT 1 March 10, 2014 2.0 STATUS REPORTING IN ACCORDANCE WITH 10 CFR 50.82(a)(8)(v-vii) 2.1 Funds spent to date for decommissioning the LACBWR plant are $41,940,059 in year 2013 dollars. Table 1 provides information related to the cost of completed decommissioning activities.

TABLE 1 ACTIVITY YEAR COST 2013 COST1 Limited Dismantlement 1996 199,262 388,143 Limited Dismantlement 1997 81,780 153,172 Limited Dismantlement 1998 287,942 518,567 Limited Dismantlement 1999 288,244 499,145 Limited Dismantlement 2000 238,296 399,901 Limited Dismantlement 2001 559,116 895,162 Limited Dismantlement 2002 415,290 639,320 Limited Dismantlement 2003 565,579 837,195 Limited Dismantlement 2004 379,328 539,902 RPV and B/C Waste Removal 2005 3,729,985 5,104,742 RPV and B/C Waste Removal 2006 11,866,247 15,615,171 RPV and B/C Waste Removal 2007 8,531,106 10,794,570 Fuel Storage Rack Removal 2012 1,553,282 1,615,413 Post-Fuel Planning 2012 1,170,017 1,216,818 Metal Removal 2013 2,722,838 2,722,838 Cost of Decommissioning Completed as of 12131/2013 $41,940,059 12013 Cost based on original cost realized escalated annually by 4%.

The amount of funds accumulated in the DPC NDT as of 12/31/2013 for decommissioning of the LACBWR plant was $89,656,577.

The amount of funds estimated to be required for the LACBWR plant decommissioning as of 12/31/2013 pursuant to 10 CFR 50.75(b) and (c) was

$120,225,200. Subtracting funds spent as of 12/31/2013 from the formula amount leaves the remainder of $78,285,141. Funds accumulated in the DPC NDT as of 12/31/2013 exceeded the remainder of the required formula amount.

2.2 As of 12/31/2013, the site specific cost estimate to complete decommissioning of the LACBWR plant was $88,726,629. This value is based upon a revision to the LACBWR Decommissioning & Decontamination Cost Study Update that was performed in March 2013. During the revision to the cost study, some structures previously assumed to be decontaminated and left intact were evaluated for complete demolition and disposal. This change in decommissioning methodology to demolition and disposal of structures, in lieu of decontamination of structures, resulted in an increase in the LACBWR plant decommissioning cost Page 3 of 4

Document Control Desk LAC-1 4295 ATTACHMENT 1 March 10, 2014 estimate in the range of $20 million over the previous November 2010 decommissioning cost estimate of $67.8 million.

During 2013, components of the steam turbine, main generator, component cooling water system, and other systems were removed and disposed of. The actual cost of decommissioning activities during 2013 was $2,722,838. This actual cost was the same as the estimated cost because the estimated liability was revised to $88,726,629 at year end to accommodate the expected increase in decommissioning cost as noted above.

As of 12/31/2013, decommissioning criteria for the LACBWR site have been assumed to be in accordance with 10 CFR 20.1402 for unrestricted use.

2.3 There have been no modifications to DPC's method of providing financial assurance since the last submitted report.

2.4 There have been no changes to DPC's Nuclear Decommissioning Trust Agreement since the last submitted report.

2.5 DPC's established 10 CFR 50.54(bb) spent fuel management funding plan is that ISFSI operating costs are funded from DPC's Operations & Maintenance (O&M) budget.

2.6 DPC has not projected the cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Secretary of Energy because this cost is indeterminate. ISFSI operating costs are estimated to be $2,000,000 per year and are funded from the O&M budget.

2.7 DPC has an established 10 CFR 50.54(bb) spent fuel management funding plan that was submitted to the NRC by letter LAC-1 3815 dated 09/26/2003 (ADAMS Accession No. ML032881008).

The DPC spent fuel management funding plan is described in Section 3.2, "Dry Cask Storage Cost Funding," of the LACBWR Decommissioning Plan/PSDAR (Revised August, 2013, ADAMS Accession No. ML13220A750).

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