ML19091A049

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Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR) Possession-Only License DPR-45 10 CFR 72.30(b) Decommissioning Funding Plan for Independent Spent Fuel Storage Installation
ML19091A049
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 03/11/2019
From: Nick B
Dairyland Power Cooperative
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LAC-14430
Download: ML19091A049 (14)
v • d • e


Text

BARBARA A. NICK President and CEO DAIRYlAND POWER COOPERATIVE March 11, 2019 In reply, please refer to LAC-14430 10 CFR 72.30(b)

DOCKET NO. 50-409 and 72-046 ATIN: 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:

1) 10 CFR 72.30(b) 2) 10 CFR 72.30(c)

Dairyland Power Cooperative is submitting to the NRG 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). On March 8, 2018, the NRC requested additional information to demonstrate the events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered and the responses for these items, which were submitted in LAC-14412 dated March 21, 2018, have been included. provides details concerning the updated LACBWR ISFSI decommissioning cost estimate.

Sincerely,

~

Barbara Nick, President and CEO BAN:CLO;tco Attachments: 1) Decommissioning Funding Plan for the LACBWR Independent Spent Fuel Storage Installation (ISFSI)

2) Record of Revisions of the Decommissioning Funding
3) WI-QA-07, Preparing the Triennial ISFSI Decommissioning Fund Status Report

~~

A Touchstone Energy'" Cooperative 3200 East Ave. S.

  • PO Box 817
  • La Crosse, WI 54602-0817
  • 608-787-1258
  • 608-787-1420 fax* www.dairylandpower.com Dairyland Power Cooperative is an equal opportunity provider and employer.

Document Control Desk LAC-14430 Page 2 March 15, 2019 cc:

Ken Robuck Group President Disposal and Jeffery Kitsembel Decommissioning Division .of Energy Regulation Energy Solutions Wisconsin Public Service Commission 299 South Main Street, Suite 1700 PO Box 7854 Salt Lake City, UT 84111 Madison, WI 53707-7854 John Sauger* Paul Schmidt, Manager Executive VP and Chief Nuclear Officer Radiation Protection Section Reactor D & D Bureau of Environmental & Occupational EnergySolutions Health 2701 Deborah Avenue Division of Public Health Zion, IL 60099 Wisconsin Department of Health Services Gerard van Noordennen PO Box2659 VP Regulator Affairs Madison, WI 53701-2659 EnergySqlutions 2701 Deborah Avenue Barbara Nick Zion, IL 60099 President and CEO Dairyland Power Cooperative Joseph Nowak 3200 East Avenue South General Manager La Crosse, WI 54602-0817 LaCrosseSolutions S4601 State Highway 35 Cheryl Olson, ISFSI Manager Genoa, WI 54632-846 La Crosse Boiling Water Reactor Dairyland Power Cooperative Dan Shrum S4601 State Highway 35 Senior VP Regulator Affairs Genoa, WI 54632-8846 EnergySolutions 299 South Main $treet, Suite 1700 Lane Peters, Genoa Site Manager Salt Lake City, UT 84111 La Crosse Boiling Water Reactor Dairyland Power Cooperative Russ Workman S4601 State Highway 35 General Counsel Genoa, WI 54632-8846 EnergySolutions 299 South Main Street, Suite 1700 Thomas Zaremba

. Salt Lake City, UT 84111 Wheeler, Van Sickle and Anderson, S.C.

44 East Mifflin Street, Suite 1000 Jerome Pedretti, Clerk Madison, WI 53703 Town of Genoa E860 Mundsack Road John E. Matthews C3enoa, WI 54632 Morgan, Lewis and Beckius LLP t 111 Pennsylvania Avenue, NW Regional Administrator Washington, DC 20004 U.S. NRC, Region Ill 2443 Warrenville Road Lisle, IL 60532-4352

Document Control Desk LAC-14430 Page 3 March 15, 2019 STATE OF WISCONSIN )

)

COUNTY OF LA CROSSE )

Personally, came before me this //f/,L day of ~ , 2019, the above named, Barbara Nick, to me known to be the person who executed the foregoing instrument and acknowledged the same.

Notary Public, La Crosse County Wisconsin 5"- 2.-.2- ~O:L 2-My commission expires _ _ _ _ _ _ _ _ __

LAURIE A. ENGEN Notary Public State of Wisconsin

Document Control Desk LAC-14430 ATTACHMENT 1 Page 1 March 15, 2019 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. The loading of the casks and associated transport operations were completed on September 19, 2012. No additional spent fuel has been 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)(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 NOT) is established with a separate sub-account for the accumulation of ISFSI decommissioning funds.

Requirement 2:

10 CFR 72.30(b)(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 2019 RS Means 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.

Requirement 3:

10 CfR 72.30(b)(3) Identification of and justification for using the key assumptions contained in the OGE.

Information for Requirement 3:

This information is included in the cost estimate.

Document Control Desk LAC-14430 ATIACHMENTl Page 2 March 15, 2019 Requirem~nt 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)(1)(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 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 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)(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 is $1,143,162. We further certify that the funds accumulated for ISFSI decommissioning were $1,941,457 as of December 31, 2018.

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:

Document Control Desk LAC-14430 ATTACHMENT 1 Page 3 March 15, 2019 Requirement (c)(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 indicates that the structural analyses of the TSC for off-normal and accident events of storage, presented in Appendix 11.A, demonstrates 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 determined that the design of the confinement system of the MPC-LACBWR complies 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 based on a review that considered the regulation itself, appropriate regulatory guides, applicable codes and standards, the applicant's analysis and the staff's 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."

Requirement (c)(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 (c)(3):

10 CFR 72.30 (c) (3): Changes in authorized possession limits.

Document Control Desk LAC-14430 ATIACHMENT1 Page4 March 15, 2019 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 all spent fuel including assemblies and pieces 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 (c)(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 of license 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.

Document Control Desk LAC-14430 ATIACHMENT2 Page 1 March 15, 2019 RECORD OF REVISIONS OF THE DECOMMISSIONING FUNDING Revision O ISFSI Decommissioning Cost Estimate is established within the 2010 LACBWR Decommissioning & Decontamination Cost Study Update (November 2010) as System Identification No. 1100.

Revision 1 In 2013, the 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:

  • All costs have been adjusted, based on 2013 dollars.
  • 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.

1. All costs for reprocessing and burial of radioactive material are based on Energy Solutions Schedule of Charges, Effective Date January 1, 2011, through December 31, 2016 Revision 2 In 2016, the estimate was revised assuming that the waste can be disposed of as industrial waste. The burial and transportation costs associated with the removal of radioactively contaminate waste (estimated in 2013 to be approximately $446,728) were replaced with a cost to move the waste to a local landfill (estimated in 2016 to be approximately $113,444). This results in a savings of over $333,284. Additionally, the cost of release of the concrete casks using the MARSAME process along with the license termination planning and execution were included using an estimate from a contractor who is doing this work for the LACBWR plant ($560,000) vs a labor estimate used in the 2013 report (approximately 472,000 in 2013 dollars). Using an escalation rate of 4%/yr. for the 2013 estimate, the 2013 estimate in 2016 dollars is $530,936.

Therefore, the change in the manner in which the estimate was done resulted in a net gain of $19,000 for the estimate.

Revision 3 It is now assumed that DPC labor will not be involved in cask demolition and disposal.

Between 2016 and 2019, there was a reduction in the crew costs used from RS Means Contractor Labor and Equipment Cost from $179.75/hr. to $168.36/hr. This resulted in the lowering of costs to move waste to a local landfill to $106,225, which is a reduction of $7,219. Demolition costs reported in 2016 were $320,659; however, they should have been reported as $418,252. In 2019, these costs increased to $424,981, because of labor costs increases from $220.04/hr. to $223.58/hr. The contractor cost estimate for license termination planning and execution increased from $560,000 to

$611,926, an increase of $51,926. The expected decommissioning costs increased to

$1,143,162 from $1,091,696 (revised upward from $994,103), a net increase of

$51,436.

Document Control Desk LAC-14375 ATIACHMENT2 Page 2 March 15, 2019 Introduction Dairyland Power Cooperative (DPC) is the holder of a general license under 10 CFR 72, Subpart K for the LACBWR ISFSI. Five NAC-MPC dry cask's store all LACBWR spent fuel and fuel debris. Casks were loaded, and transport operations were completed on September 19, 2012. No additional spent fuel is to 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.

The decommissioning plan for the ISFSI is based on information contained in the NAC-MPC FSAR, Section 2.A.4, "Decommissioning Considerations." The ISFSI will be decommissioned after the stored spent fuel is removed and transferred to the Department of Energy. The NAC-MPC dry cask storage systems in use at the ISFSI are designated as MPC-LACBWR.

The principal elements of the MPC-LACBWR storage system are the vertical concrete cask (VCC) and the transportable storage canister (TSC). The VCC provides biological shielding and physical protection for the contents of the TSC during long-term storage. The VCC is not expected to become surface contaminated during use, except through incidental. contact with other contaminated surfaces.

Incidental contact could occur at the interior 1.iner surface of the VCC, tbe top surface that supports the transfer cask during loading and unloading operations, and the pedestal of the VCC that supports the TSC. These surfaces are carbon steel and could be decontaminated as necessary for decommissioning. A Y4-inch stainless steel plate is placed on the carbon steel pedestal of the MPC-LACBWR VCC to separate. it from the stainless steel TSC bottom. Contamination of these surfaces is expected to be minimal, since the TSC is isolated from spent fuel pool water during loading in the pool and the transfer cask is decontaminated prior to transfer of the TSC to the VCC. Activation of the VCC carbon steel liner, concrete, support plates, and reinforcing bar could occur due to neutron flux from the stored fuel. Since the neutron flux rate is low, only minimal activation of carbon steel in the VCC is expected to occur.

Decommissioning of the VCC would involve the removal of the TSC and the subsequent disassembly of the VCC. It is expected that the concrete would be broken up, and steel components segmented to reduce volume. It is anticipated that the debris resulting from the decommissioning will be disposed of as clean waste using the MARSAME process.

Assumptions

1) The five vertical concrete casks and lids, 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 industrial waste.

4) All fencing, lighting, security systems, and building will be left as is.
5) Costs are based on S&L Report, "Independent Review of Decommissioning Cost Study for LACBWR," SL-010039, April 15, 201.0 and 2019 RS Means Building Construction Cost Data
6) All material removed will be released and wm 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

Document Control Desk LAC-14375 ATTACHMENT 2 Page 3 March 15, 2019 (2) 2019 RS Means Building Construction Cost Data (3) WI-QA-07, Preparing the Triennial ISFSI Decommission Fund Status Report, Revision 2 System Classification Concrete will be released as non-contaminated ruble using MARSAME release methods.

Expected ISFSI Decommissioning Costs Wl-QA*07 . . Revisipl) ~

Pr~P~ring the inenn1a1 l$i=,SJ Deco!'tjmis~!o~ Fun~- ~tat1Js .Rep,ort Dec'oh11nissiohlng ¢ostW9rk~h~et: :

Attachmeni-5.1 .

ti~e 1 , 223.58 -

22~.58.*~28

. line 2 _:1iaoso.24 _

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  • 92395:9p8*i.15 l(ne $ Qispo~al Cijsf - 106,255.36
  • _ Line 9ttP cost : --- .*, *;,.,'
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tine _10 fS~ Cost _.: :- --

- -_- 1;143,162.20. _*

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Prepared b y : ~ - ~ -

. Verified by.

License Termination Planning (LTP) and Execution Based on an estimate from a contractor who will provide this service for the LACBWR LTP and execution:

License termination plan development - $524,508 (increase from 2016)

Final Site Survey and Final Report- $87,418 (increase from 2016)

Document Control Desk LAC-14430 ATTACHMENT 3 Page 1 March 15, 2019 WORK INSTRUCTION WI-QA-07 PREPARING THE TRIENNIAL ISFSI DECOMMISSIONING FUND STATUS REPORT 1.0 PURPOSE 10 CFR 72.30(c) requires 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 on decommissioning costs:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material (2) Facility modifications (3) Changes in authorized possession limits (4) Actual remediation costs that exceed the previous cost estimate In accordance with NU REG 1757, Licensees under 10 CFR Part 72 must submit a decommissioning funding plan and are NOT required to submit the originals of the financial instruments but are required to submit financial assurance documents.

2.0 REFERENCES

2.1 10 CFR 72.30, "Financial assurance and recordkeeping for decommissioning" 2.2 NUREG-1757, Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness.

2.3 ACP 20-06.02, "Routine Reporting and Submittals to NRC" 2.4 Sargent & Lundy Report, "Independent Review of Decommissioning Cost Study for LACBWR," SL-010039, April 15, 2010 2.5 2019 RSMeans Building Construction Cost Data 3.0 RESPONSIBILITIES 3.1 ISFSI Manager - prepare the report and submit to CEO for approval.

Document Control Desk LAC-14430 ATIACHMENT3 Page 2 March 15, 2019 4.0 PROCEDURE 4.1 Obtain the current copy of the RSMeans Building Construction Cost Data from the DPC library. It may be necessary to order the book.

4.1.1 Using table 02 41 16 - Structure Demolition, identify the crew type for demolition of concrete. (In 2016 this was crew B-13L).

4.1.2 Apply a factor of 2 multiplier for 22" concrete, 20% upcharge for heavy reinforcement, and a 200% upcharge for congested site. This constitutes a contingency factor of approximately 400% for the labor.

4.2 Using information found in 4.1 enter the following into Attachment 5.1 as follows:

4.2.1 In the crew-standard table find the costs per labor hour for the crew. Include the equipment in the table for the crew in the total costs.

Enter line 1 of Table.

4.2.2 Using the man-hour estimate of 264 man-hours from the 201 O S&L Report.-

multiply the cost per labor hour by the 264-man hours by 2

  • Multiply line 1
  • 528 and insert number line 2 of Table 4.2.3 Multiply the amount in line* 2 by 1.2 and insert number into line 3 of Table.*

4.2.4 Multiply the amount in Line 3 by 3 and insert into line 4. This is the cost for demolition of the vertical concrete casks.

4.3 Using table 02 41 16 - Structure Demolition, identify the crew type for disposal of the concrete. (crew B-30) 4.3.1 In the crew-standard table find the costs per labor hour for the crew. Include the equipment in the table for the crew in the total costs.

Insert this number into line 5 4.3.2 Apply a multiplier of 19.6 to haul the concrete 5 miles from site.

Multiply line 5 by 19.6 and insert result into Line 6 (This is the cost of labor) 4.3.3 Using the man-hour estimate of 28 man-hours from the 2010 S&L Report, multiply the cost per labor hour by 28 man-hours. This is the cost for shipping of the waste from the site.

Enter the results into Line 7 4.3.4 Apply a contingency factor of 0.15 by multiplying the Line 7 by 1.15.

Enter the results in line 8, this is the disposal cost.

4.4 Obtain from a vendor an estimate to develop a License Termination Plan cost and

Document Control Desk LAC-14430 ATIACHMENT3 Page 3 March 15, 2019 surveys of the vertical concrete casks to release as clean material as well as a Final Site Status (FSS) survey.

Enter the LTP cost into line 9 Enter the FSS cost into line 10.

4.5 Add lines 4, 8, 9 and 10. This is the Total cost for decommissioning.

4.6 Obtain from DPC Finance Dept the amount of money in the ISFSI trust fund.

5.0 ATTACHMENTS/RECORDS Attachment Document Title Location Retention 5.1 Decommissioning Cost Worksheet N/A Triennial Report 2 hr/P8 LT

~

LACROSSESOW110NS February 25, 2019 LS-MEM0-005 From: Joseph A. Nowak, La Crosse Solutions General Manager To: Cheryl Olson

Subject:

Rough Order of Magnitude (ROM) Estimate for LACBWR ISFSI License Termination Plan and implementation.

Cheryl, Please find below the Rough-Order-of-Magnitude (ROM) estimate that you requested regarding the assessed approximate costs for the LTP development, FSS, and Final Report. Estimated costs have remained constant, updated for 3 years of escalation. The ROM estimate below was developed using the assumption that Solutions would be completing the work for DPC:

LTP and supporting TSD development $524,508 FSS and Final Report $87,4 rs

Signed, Joseph A. Nowak La CrosseSolutions LACBWR General Manager CC:

J. Sauger (Senior Executive Vice President and CNO)

Donald E. Williams Jr. ,('VP.:Radiological and Environmental,Controls)

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