ML16096A389

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Boiling Water Reactor - Annual Decommissioning Funding Status Report
ML16096A389
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 03/16/2016
From: Nick B
Dairyland Power Cooperative
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LAC-14376
Download: ML16096A389 (6)
v • d • e


Text

BARBARA A. NICK President and CEO DAIRYLAND POWER COOPERATIVE March 16, 2016 In reply, please refer to LAC-14376 10 CFR 50.75(f)(2) 10 CFR 50.82(a)(8)

DOCKET NO. 50-409 and 72-046 ATIN: 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 Robert Palmberg, Vice President, Generation, of my staff at 608-787-1483.

Sincerely, Barbara A. Nick, President and CEO BAN :CLO:tco

Attachment:

1) Decommissioning Funding Status Report for the La Crosse Boiling Water Reactor March 2, 2016

~~

A Touchstone Energy" Cooperative 3200 East Ave. S. *PO Box 817 *La Crosse, WI 54602-0817 fi08-787-1?S8

  • fi08-787-14fig fax* www.rl;:iirvrn'!t.mm

Document Control Desk LAC-14376 Page 2 March 16, 2016 cc w/

Attachment:

Marlayna Vaaler Project Manager U.S. Nuclear Regulatory Commission Cynthia Pederson Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission STATE OF WISCONSIN)

COUNTY OF LA CROSSE Personally came before me this /~-I-It day of !Jt~ 2016, the above named, Barbara A. Nick, to me known to be the person who executed the foregoing instrument and acknowledged the same.

Notary Public, La Crosse County Wisconsin s-- ~ 5" - 18' My commission e x p i r e s - - - - - - - - - -

LAURIE A ENGEN Notary Public State of Wisconsin

~~

A Touchstone Energy'" Cooperative 3200 East Ave. S. *PO Box 817 *La Crosse, WI 54602-0817 n08-787-1?S8

  • n08-787-14fiq fax* www.rl;:iirvnP.t.mm

Document Control Desk LAC-14376 AlTACHMENT 1 March 16, 2016 DECOMMISSIONING FUNDING STATUS REPORT FOR THE LA CROSSE BOILING WATER REACTOR MARCH 2, 2016 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 12/31/2015 pursuant to 10 CFR 50.75(b) and (c) was

$128,315,120.

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 NRG 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 12/2111987 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 NRG approve the continued funding of the Decommissioning Trust at the level set forth in the previously filed Decommissioning Plan.

The NRG approved a decommissioning cost of $92,000,000 in 201 O 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 NRG 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.

1.2 The amount of funds accumulated in the DPC Nuclear Decommissioning Trust (DPC NOT) forthe LACBWR Plant decommissioning as of 12/31/2015 was

$92,780,744.

Page 1 of4

Document Control Desk LAC-14376 ATTACHMENT 1 March 16, 2016 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 fixed rate of return is 1.55% for Money Market and Fixed Income Investments 1.4.3 The current Board approved DPC NDT asset allocation goal is 0% to 30% 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.

Page 2 of 4

Document Control Desk LAC-14376 AITACHMENTl March 16, 2016 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 $55,443,429 (from total below) in year 2015 dollars. Table 1 provides information related to the cost of completed decommissioning activities.

TABLE 1 ACTIVITY YEAR COST 2015 COST1 Limited Dismantlement 1996 199,262 419,816 Limited Dismantlement 1997 81,780 165,671 Limited Dismantlement 1998 287,942 560,882 Limited Dismantlement 1999 288,244 539,875 Limited Dismantlement 2000 238,296 432,533 Limited Dismantlement 2001 559, 116 968,207 Limited Dismantlement 2002 415,290 691,489 Limited Dismantlement 2003 565,579 905,510 Limited Dismantlement 2004 379,328 583,958 RPV and B/C Waste Removal 2005 3,729,985 5,521,289 RPV and B/C Waste Removal 2006 11,866,247 16,889,369 RPV and B/C Waste Removal 2007 8,531,106 11,675,407 Fuel Storage Rack Removal 2012 1,553,282 1,747,231 Post-Fuel Planning 2012 1,170,017 1,316, 111 Metal Removal 2013 2,722,838 2,945,022 Metal Removal/LTP Development 2014 5,997,090 6,236,974 Resin Removal/LTP Development 2015 3,844,085 3,844,085 Cost of Decommissioning Completed as of 12/31/20151 55,443,429 12015 Cost based on original cost realized escalated annually by 4%.

The amount of funds accumulated in the DPC NDT as of 12/31/2015 for decommissioning of the LACBWR Plant was $92, 780, 744.

The amount of funds estimated to be required for the LACBWR Plant decommissioning as of 12/31/2015 pursuant to 10 CFR 50.75(b) and (c) was

$128,315, 120. Subtracting funds spent as of 12/31/2015 from the formula amount leaves the remainder .of $72,871.,691. Funds accumulated in the DPC NOT as of 12/31/2015 exceeded the remainder of the required formula amount.

2.2 As of 12/31/2015, the site specific cost estimate to complete decommissioning of the LACBWR Plant was $84,672,474. This value is based upon the LACBWR Page 3 of 4

Document Control Desk LAC-14376 ATTACHMENT 1 March 16, 2016 Decommissioning & Decontamination Cost Study Update that was petiormed in March 2013 and adjusted for work completed in 2013 thru 2015. As of 12/31/2015, the cost of LACBWR Plant decommissioning being carried on general ledger accounts was $86,479,475.

During 2015, resin and sludge was removed from components remaining on-site and the license termination plan was completed. The actual cost of these decommissioning activities was $3,844,085, approximately the estimated cost.

Removal of the resin was not specifically called out in the LACBWR Decommissioning & Decontamination Cost Study Update as this was embedded in the costs associated with the waste treatment system removal.

As of 12/3112015, 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 $2,200,000 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-13815 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 March, 2014, ADAMS Accession No. ML14079A352).

Page 4 of 4

BARBARA A. NICK President and CEO DAIRYLAND POWER COOPERATIVE March 16, 2016 In reply, please refer to LAC-14376 10 CFR 50.75(f)(2) 10 CFR 50.82(a)(8)

DOCKET NO. 50-409 and 72-046 ATIN: 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 Robert Palmberg, Vice President, Generation, of my staff at 608-787-1483.

Sincerely, Barbara A. Nick, President and CEO BAN :CLO:tco

Attachment:

1) Decommissioning Funding Status Report for the La Crosse Boiling Water Reactor March 2, 2016

~~

A Touchstone Energy" Cooperative 3200 East Ave. S. *PO Box 817 *La Crosse, WI 54602-0817 fi08-787-1?S8

  • fi08-787-14fig fax* www.rl;:iirvrn'!t.mm

Document Control Desk LAC-14376 Page 2 March 16, 2016 cc w/

Attachment:

Marlayna Vaaler Project Manager U.S. Nuclear Regulatory Commission Cynthia Pederson Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission STATE OF WISCONSIN)

COUNTY OF LA CROSSE Personally came before me this /~-I-It day of !Jt~ 2016, the above named, Barbara A. Nick, to me known to be the person who executed the foregoing instrument and acknowledged the same.

Notary Public, La Crosse County Wisconsin s-- ~ 5" - 18' My commission e x p i r e s - - - - - - - - - -

LAURIE A ENGEN Notary Public State of Wisconsin

~~

A Touchstone Energy'" Cooperative 3200 East Ave. S. *PO Box 817 *La Crosse, WI 54602-0817 n08-787-1?S8

  • n08-787-14fiq fax* www.rl;:iirvnP.t.mm

Document Control Desk LAC-14376 AlTACHMENT 1 March 16, 2016 DECOMMISSIONING FUNDING STATUS REPORT FOR THE LA CROSSE BOILING WATER REACTOR MARCH 2, 2016 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 12/31/2015 pursuant to 10 CFR 50.75(b) and (c) was

$128,315,120.

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 NRG 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 12/2111987 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 NRG approve the continued funding of the Decommissioning Trust at the level set forth in the previously filed Decommissioning Plan.

The NRG approved a decommissioning cost of $92,000,000 in 201 O 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 NRG 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.

1.2 The amount of funds accumulated in the DPC Nuclear Decommissioning Trust (DPC NOT) forthe LACBWR Plant decommissioning as of 12/31/2015 was

$92,780,744.

Page 1 of4

Document Control Desk LAC-14376 ATTACHMENT 1 March 16, 2016 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 fixed rate of return is 1.55% for Money Market and Fixed Income Investments 1.4.3 The current Board approved DPC NDT asset allocation goal is 0% to 30% 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.

Page 2 of 4

Document Control Desk LAC-14376 AITACHMENTl March 16, 2016 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 $55,443,429 (from total below) in year 2015 dollars. Table 1 provides information related to the cost of completed decommissioning activities.

TABLE 1 ACTIVITY YEAR COST 2015 COST1 Limited Dismantlement 1996 199,262 419,816 Limited Dismantlement 1997 81,780 165,671 Limited Dismantlement 1998 287,942 560,882 Limited Dismantlement 1999 288,244 539,875 Limited Dismantlement 2000 238,296 432,533 Limited Dismantlement 2001 559, 116 968,207 Limited Dismantlement 2002 415,290 691,489 Limited Dismantlement 2003 565,579 905,510 Limited Dismantlement 2004 379,328 583,958 RPV and B/C Waste Removal 2005 3,729,985 5,521,289 RPV and B/C Waste Removal 2006 11,866,247 16,889,369 RPV and B/C Waste Removal 2007 8,531,106 11,675,407 Fuel Storage Rack Removal 2012 1,553,282 1,747,231 Post-Fuel Planning 2012 1,170,017 1,316, 111 Metal Removal 2013 2,722,838 2,945,022 Metal Removal/LTP Development 2014 5,997,090 6,236,974 Resin Removal/LTP Development 2015 3,844,085 3,844,085 Cost of Decommissioning Completed as of 12/31/20151 55,443,429 12015 Cost based on original cost realized escalated annually by 4%.

The amount of funds accumulated in the DPC NDT as of 12/31/2015 for decommissioning of the LACBWR Plant was $92, 780, 744.

The amount of funds estimated to be required for the LACBWR Plant decommissioning as of 12/31/2015 pursuant to 10 CFR 50.75(b) and (c) was

$128,315, 120. Subtracting funds spent as of 12/31/2015 from the formula amount leaves the remainder .of $72,871.,691. Funds accumulated in the DPC NOT as of 12/31/2015 exceeded the remainder of the required formula amount.

2.2 As of 12/31/2015, the site specific cost estimate to complete decommissioning of the LACBWR Plant was $84,672,474. This value is based upon the LACBWR Page 3 of 4

Document Control Desk LAC-14376 ATTACHMENT 1 March 16, 2016 Decommissioning & Decontamination Cost Study Update that was petiormed in March 2013 and adjusted for work completed in 2013 thru 2015. As of 12/31/2015, the cost of LACBWR Plant decommissioning being carried on general ledger accounts was $86,479,475.

During 2015, resin and sludge was removed from components remaining on-site and the license termination plan was completed. The actual cost of these decommissioning activities was $3,844,085, approximately the estimated cost.

Removal of the resin was not specifically called out in the LACBWR Decommissioning & Decontamination Cost Study Update as this was embedded in the costs associated with the waste treatment system removal.

As of 12/3112015, 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 $2,200,000 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-13815 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 March, 2014, ADAMS Accession No. ML14079A352).

Page 4 of 4

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