ML18093A432

Lacrossesolutions, LLC - Report on Status of Decommissioning Funding for Shutdown Reactor

ML18093A432
Person / Time
Site:	La Crosse  File:Dairyland Power Cooperative icon.png
Issue date:	03/29/2018
From:	Gerard van Noordennen LaCrosseSolutions
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LC-2018-0027
Download: ML18093A432 (6)

Text

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LACROSSESOLUTIONS 10 CPR 50.75(+/-)(1) 10 CPR 50.82(a)(8)

March 29, 2018 LC-2018-0027 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 La Crosse Boiling Water Reactor Facility Operating License No. DPR-45 NRC Docket Nos. 50-409 and 72-046

Subject:

Report on Status of Decommissioning Funding for Shutdown Reactor

References:

1) Barbara Nick, Dairyland Power Cooperative, Letter to U.S. Nuclear Regulatory Commission, "Application for Order Approving License Transfer and Conforming Administrative License Amendments," dated October 8, 2015

2) Marlayna Vaaler, U.S. Nuclear Regulatory Commission, Letter to Barbara Nick, Dairyland Power Cooperative, "Order Approving Transfer of License for the La Crosse Boiling Viater Reactor from the Dairyland Power Cooperative to LaCrosseSolutions, LLC and Conforming Administrative License Amendment" dated May 20, 2016

3)

• Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Notification of Amended Decommissioning Plan and Post-Shutdown Decommissioning Activities Report for La Crosse Boiling Water Reactor," dated June 27, 2016 In accordance with 10 CPR 50.75, "Reporting and recordkeeping for decommissioning planning," paragraph (f)(l), and 10 CPR 50.82, "Termination of license," paragraph (a)(8),

LaCrosseSolutions, LLC (LS) is submitting a report on the status of funding for decommissioning the La Crosse Boiling Water Reactor (LACBWR) facility, and managing the associated irradiated fuel.' The annual radiological decommissioning and irradiated fuel management funding assurance report for LACBWR is provided in the Attachment to this letter for the period ending December 31, 201 7.

The minimum required decommissioning funding assurance amount is based on a site-specific decommissioning cost estimate determined in accordance.with 10 CPR 50.82(a). A change to the spent fuel management strategy was described in the application for license transfer (Reference 1), accepted by the NRC via Reference 2, and further described in the amended PSDAR (Reference 3).

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LaCrosseSolutions LC-2018-0027 Page 2 of3 Each of those references addressed the project's planning and scheduling basis, the associated estimated costs and the available funds for decommissioning, decontamination, dismantlement, and spent fuel management of the LACBWR facility. As described in those references, radiological decommissioning as represented by the LACBWR plan includes decontamination and dismantlement of the radiologically involved systems, structures, and components. The attached decommissioning cost estimate does not include the costs of dismantling non-radiological systems and structures and other non-radiological site restoration.

Under the terms of the license transfer, LS became the lead NRC liqensee responsible for all activities under the LACBWR License. LS will complete all activities necessary to terminate the License and release the LACBWR Site for unrestricted use as an industrial site, except for a small area surrounding the Independent Spent Fuel Storage Installation (ISFSI) containing the spent nuclear fuel until its final disposition. Dairyland Power Cooperative (DPC) will remain the owner licensee and will retain title to the spent nuclear fuel. Upon issuance of a license amendment providing for termination of the License, except for the ISFSI site, and upon receipt of a future NRC license transfer approval, LS will transfer responsibility for the License back to DPC. Thereafter, DPC will maintain the ISFSI, and the ultimate disposition of the spent nuclear fuel will be provided for under the terms of DPC's Standard Contract for Disposal of Spent Nuclear Fuel and/or High Level Waste with the U.S. Department of Energy. These latter, ongoing costs are not included in the estimates herein.

NRC review of this decommissioning management strategy and the associated funding and cost estimate was accomplished as part of the NRC approval of the transfer of the LACBWR operating licenses to LS (Reference 2). Since the time of the last estimate provided in Reference 3, the cost and funding estimates have been adjusted for market value changes in the decommissioning trust fund (DTF), refinement of the cost and schedule estimate reflecting more mature knowledge gained from the new cost-significant contracts for various decommissioning activities, and more developed cost allocations among the activities for radiological and non-radiological work. While this report excludes costs and discussion of non-radiological site restoration, it is LS plan to additionally complete that work as part of the contract scope with DPC.

All spent nuclear fuel elements from LACBWR have been transferred to dry cask storage in the ISFSI. LS has entered into a "Company Services Agreement" with DPC, pursuant to which DPC will provide operations, maintenance, access control, and security services to and for the ISFSI site. DPC is responsible for the costs relating to the ISFSI.

The Attachment provides the aggregated, minimum estimated cost (funds n:eeded) for radiological decommissioning. This estimate has been developed from the site aggregate decommissioning schedule and provides the cost and funding allocation necessary to optimally decommission the radiologically involved systems, structures and components consistent with the Commission accepted decommissioning strategy.

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LaCrosseSolutions LC-2018-0027 Page 3 of3 There are no regulatory commitments contained within this letter.

If you have any questions about this letter, please contact me at (860) 462-9707.

Respectfully,

~rG~~

Vice President Regulatory Affairs

Attachment:

1) Annual Radiological Decommissioning and Irradiated Fuel Management Funding Assurance Report for La Crosse Boiling Water Reactor, Aggregate Costs cc: Marlayna Vaaler, U.S. NRC Project Manager Service List

LaCrosseSolutions LC-2018-0027: Attachment Page 1 of2 Annual Radiological Decommissioning and Irradiated Fuel Management Funding Assurance Report for La Crosse Boiling Water Reactor, Aggregate Costs December 31, 2017 (2017 dollars, millions)

Trust Fund Amount at December 31, 2017 (A)

NRC Required Minimum Funding Assurance Amount at December 31, 2017 (B)

Difference in Trust Fund Amount versus Required Minimum Funding at December 31, 2017 - Surplus/(Shortfall) (C) = (A) - (B) $0.7 Projected End of Project Surplus at December 31, 2017 (D) $1.12 Estimated Costs to Complete Decommissioning at December 31, 2017 (E) $16.0 Projected Costs to Manage Irradiated Fuel at December 31, 2017 (F) $03 Amount Spent on Decommissioning4 (G):

Cumulative (June 2016-December 31, 2016)5 Calendar Year 201 7 Cumulative (June 2016-December 31, 2017) 6 1

This NDT position, together with the $17 million Surety Bond payable to the NDT, provides for s~fficient funding and financial assurance for completion ofradiological decommissioning of the LACBWR Project. Additionally, EnergySolutions resources and the $15 million performance guarantee agreed to with DPC in the LACBWR Disposal Services Agreement, are available but are not relied upon here.

2 The surplus is based on the trust fund amount as ofDecember 31, 2017, less the estimate of costs to complete decommissioning, plus annual earnings and less taxes through the end of the project.

3 A separate account in the trust holds the funds necessary for the ultimate decommissioning of the ISFSI site and final license termination. DPC currently funds and will continue to fund the operation and maintenance of the ISFSI through its annual operating revenue.

4 The amounts spent on decommissioning represents withdrawals made from the trust fund reported for radiological decommissioning.

5 This time period reflects the transfer oflicense to LS in June 2016 as documented in Reference 2.

6 This time period reflects the transfer of license to LS in June 2016 as documented in Reference 2.

LaCrosseSolutions LC-2018-0027: Attachment Page 2 of2 a) The required minimum funding assurance amount is based on the decommissioning scenario from the site-specific decommissioning cost estimate provided in Reference 3. The cost estimate reflects actual experience to date, as well as forecast refinements made through the date of this filing.

b) The trust fund amount is the actual trust fund balance less outstanding disbursements for decommissioning costs incurred through the same date.

c) There are no additional funds to be collected.

d) A 2% annual real rate of return is assumed in these calculations.

e) There are no contracts relied upon pursuant to 10 CFR 50.75(e)(l)(v).

f) Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(l)(i). There are no modifications to the current method of providing financial assurance since the last submitted report.

g) There are no material changes to the trust fund agreements or financial assurance contracts as described at the time of transfer of the licenses.

h) LS has entered into a "Company Services Agreement" with DPC, pursuant to which DPC will provide operations, maintenance, access control, and security services to and for the ISFSI site. DPC is responsible for the costs relating to the ISFSI and those costs are not included in this decommissioning estimate.

i) DPC has funds sufficient to meet its obligations to manage spent fuel safely as requisite to the current cost estimates for the project and pursuant to 10 CFR 50.82(a)(8)(vii). A separate account in the trust holds the funds necessary for the ultimate decommissioning of the ISFSI site and final license termination. DPC's established spent fuel management funding plan is that it currently funds and will continue to fund the operation and maintenance of the ISFSI through its annual operating revenue.

j) DPC has not projected the cost of managing irradiated 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 $2.5 million per year and are funded from the operations and maintenance budget.

k) Inquiries regarding the management of spent nuclear fuel beyond completion of the decommissioning project should be directed to DPC.

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• La Crosse Boiling Water Reactor Service List cc:

Ken Robuck Regional Administrator Group President Disposal and U.S. NRC, Region III Decommissioning 2443 Warrenville Road EnergySolutions Lisle, IL 60532-4352 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Paul Schmidt, Manager Radiation Protection Section John Sauger Bureau of Environmental and Occupational Health Executive VP and Chief Nuclear Officer Division of Public Health ReactorD&D Wisconsin Department of Health Services EnergySolutions P.O. Box 2659 121 W. Trade Street, Suite 2700 Madison, WI 53701-2659 Charlotte, NC 28202 Barbara Nick Joseph Nowak President and CEO General Manager Dairyland Power Cooperative LaCrosseSolutions 3200 East Avenue South, S4601 State Highway 3 5 La Crosse, WI 54602-081 7 Genoa, WI54632-8846 Cheryl*Olson, ISFSI Manager Gerard van Noordennen La Crosse Boiling Water Reactor VP Regulatory Affairs Dairyland Power Cooperative EnergySolutions S4601 State Highway 3 5 121 W. Trade Street, Suite 2700 P.O. Box 817 Charlotte, NC 28202 Genoa, WI54632-8846 Russ Workman Lane Peters General Counsel La Crosse Boiling Water Reactor EnergySolutions Dairyland Power Cooperative 299 South Main Street, Suite 1700 S4601 State Highway 3 5 Salt Lake City, UT 84111 Genoa, WI54632-8846 Jerome Pedretti, Clerk Thomas Zaremba Town of Genoa Wheeler, Van Sickle and Anderson, S.C.

E860 Mundsack Road 44 East Mifflin Street, Suite 1000 Genoa, WI 54632 Madison, WI 53 703 Jeffery Kitsembel John E. Matthews Division of Energy Regulation Morgan, Lewis & Bockius LLP Wisconsin Public Service Commission 1111 Pennsylvania Avenue, NW P.O. Box 7854 Washington, DC 20004 Madison, WI 53707-7854