ML18102A531
| ML18102A531 | |
| Person / Time | |
|---|---|
| Site: | La Crosse, 07200006 File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/21/2018 |
| From: | Nick B Dairyland Power Cooperative |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LAC-14412 | |
| Download: ML18102A531 (6) | |
Text
BARBARA NICK President and CEO DAIRYLAND POWER COOPERATIVE March 21, 2018 In reply, please refer to LAC-14412 DOCKET NO. 72-46 10 CFR 72.30(b)&(c)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555~0001
SUBJECT:
REFERENCES:
Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)
Possession-Only License No. DPR-45 Response to Request for Additional Information by the Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards 2016 Decommissioning Funding Plan for La Crosse Boiling Water Reactor
- 1) Letter NRC Longmire to DPC dated March 8, 2018 Request for additional information regarding Dairyland Power Cooperative's Decommissioning Funding Plan Update for La Crosse Boiling Water Reactor Independent Spent Fuel Storage Installation (Agencywide Documents Access and Management System Accession Nos. ML18067A085 and ML18067A086)
- 2) Letter dated March 14, 2016, Dairyland Power Cooperative (DPC) submitted for U.S. Nuclear Regulatory Commission(NRC) staff review and approval, a decommissioning funding plan update (DFP Update) for the Independent Spent Fuel Storage Installations (ISFSI) at La Crosse Boiling Water Reactor (Agencywide Documents Access and Management System Accession No. ML16102A101). of this letter contains an update of the Decommissioning Funding Plan as required by the NRC's Request for Additional Information (RAI) of Reference 1 This letter and attachment identify no new commitments and no revisions to existing commitments.
If you have any questions concerning this matter, please contact Cheryl Olson of my staff at 608-689-4207.
Sincerely, BAN:CLO:tco A Touchstone Energy Cooperative ~
3200 East Ave. 5.
- PO Box 817
- La Crosse, WI 54602-0817
- 608-787-1258
- 608-787-1469 fax II www.dairynet.com
Document Control Desk LAC-14412 Page2 March 21, 2018 Attachments:
- 1) Decommissioning Fundi'ng Plan for the LACBWR Independent Spent Fuel Storage Installation (ISFSI) revised 3/20/2018 cc w/ Attachments:
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 c:J&-+,i.,
day of :1(4t.ei:1
. 2018, the above named, Barbara Nick, to me known to be the person who executed the foregoing instrument and acknowledged the same.
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Document Control Desk LAC-14412 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 assurance will be provided that funds will be available to decommission the ISFSI or MRS.
Information for Requirement 1:
Pursuant to 10 CFR 72.30{e)(S), because LACBWR was a power reactor licensed under 10 CFR 50, DPC utilizes the methods of 10 CFR 50.75(e)(l)(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:
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.
Information for Requirement 2:
Information contained in the LACBWR ISFSI Decommissioning Cost Estimate, derived from a study performed by Sargent & Lundy, LLC, is a decommissioning cost estimate (DCE) for the LACBWR ISFSI that provides an estimate for labor hours plus contingency.
The labor rate is obtained from the 2016 RSMeans Building Construction Cost Data. The costs for the license termination planning and execution are based on a cost estimate provided by industry and benchmarked against other similar types of ISFSI DCE.
Document Control Desk LAC-14412 ATTACHMENT 1 Page 2 Requirement 3:
10 CFR 72.30{b) (3)
Identification of and justification for using the key assumptions contained in the DCE.
Information for Requirement 3:
This information is included in the cost estimate.
Requirement 4:
10 CFR 72.30{b)(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.
Information for Requirement 4:
As indicated in the information for Requirement 1, DPC utilizes the methods of 10 CFR 50.75(e)
(l)(ii) to provide financial assurance for the LACBWR ISFSI. The DPC NOT 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 ISFSI NOT, 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 material containing residual radioactivity that will require remediation to meet the criteria for 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 that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning."
Information for Requirement 6:
Financial assurance for decommissioning the LACBWR ISFSI is provided in accordance with 10 CFR 50.75(e) (l)(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 is $994,103. We further certify that the funds accumulated for ISFSI decommissioning were $1,894,926 as of December 31, 2015.
Document Control Desk LAC-14412 ATIACHMENTl Page3 DPC provides the following information required by 10 CFR 72.30(c) At the time of license renewal and at intervals not to exceed 3 years, the decommissioning funding plan must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination. If the amount of financial assurance will be adjusted downward, this cannot be done until the updated decommissioning funding plan is approved. The decommissioning funding plan must update the information submitted with the original or prior approved plan and must specifically consider the effect of the following events on decommissioning costs:
Requirement 1:
10 CFR 72.30 (c) (1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.
Information for Requirement (1)
There have not been any spills of radioactive material in the Dairyland Power Cooperative's (DPC) La Crosse Boiling Water Reactor (LACBWR) Independent Spent Fuel Storage Installation (ISFSI) area that is surrounded by the ISFSI controlled area boundary fence. In addition, spills of radioactive material in the LACBWR ISFSI area are not expected to occur because radioactive material that could spill will not be brought into the ISFSI area.
Furthermore, the all welded construction of the multi-purpose containers (MPCs) in conjunction with the extensive inspections and testing performed during closing operations ensures that no release of radioactive effluents will occur.
The LACBWR ISFSI Final Safety Analysis Report (FSAR), Section 7A, The results of the structural analyses of the TSC for off-normal and accident events of storage, presented in Appendix 11.A, show that the TSC is not breached in any of the evaluated events. Consequently, based on the welded closure TSC confinement boundary and the leakage tests described in Section 9.A.2 of Appendix 9.A, the TSC has no credible leakage and, therefore, there is no release of radioactive material during off-normal or accident events of storage.
In the NRC Safety Evaluation Report (SER) dated October 2010, 7.2 Evaluation Findings The staff finds that the design of the confinement system of the MPC-LACBWR is in compliance with 10 CFR Part 72 and that the applicable design and acceptance criteria have been satisfied.
The evaluation of the confinement system design provides reasonable assurance that the MPC-LACBWR will allow safe storage of spent fuel. This finding is reached on the basis of a review that considered the regulation itself, appropriate regulatory guides, applicable codes and standards, the applicant's analysis and the staffs confirmatory analysis, and accepted engineering practices. The SER states, "The confinement design of the MPCs and the passive design of the storage system, minimize the potential for radioactive contamination to occur and to spread."
Document Control Desk LAC-14412 ATIACHMENTl Page4 Requirement (2) 10 CFR 72.30 (c) (2) Facility modifications:
Information for Requirement (2):
There have been no modifications to the LACBWR ISFSI design that could impact decommissioning costs, and no modifications are expected in the future. See response to item (3) below for more details.
Requirement (3):
10 CFR 72.30 (c) (3): Changes in authorized possession limits.
Information for Requirement 3:
The LACBWR ISFSI design consists of five storage casks containing spent fuel. The five spent fuel casks have been loaded and transferred to the ISFSI pad with spent fuel from the LACBWR.
LACBWR is currently being decommissioned and no more spent fuel will be generated. There is no GTCC waste on site and there will be no additional spent fuel casks placed in the LACBWR ISFSI beyond that of the original design.
Requirement ( 4):
10 CFR 72.30 (c) (4): Actual remediation costs that exceed the previous cost estimate.
Information for Requirement (4):
DPC will not begin to decommission the LACBWR ISFSI until after the U.S. Department of Energy takes possession of the spent fuel. Currently, this is estimated to begin in 2024.
Therefore, there have been no actual remediation costs that exceed previous cost estimates. Title 10 of the Code of Federal Regulations (10 CFR) 72.30(c) requires at the time oflicense renewal and at intervals not to exceed 3 years, the decommissioning funding plan (DFP) required to be submitted by 10 CFR 72.30(b) will be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination.