ML19102A026
| ML19102A026 | |
| Person / Time | |
|---|---|
| Site: | 07200011 |
| Issue date: | 03/28/2019 |
| From: | Tallman D Sacramento Municipal Utility District (SMUD) |
| To: | William Allen Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| DPG 19-040 | |
| Download: ML19102A026 (21) | |
Text
()SMUD March 28, 2019 DPG 19-040 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Docket No. 72-11 Rancho Seco Spent Fuel Storage Installation License No. SNM-2510 Powering forward. Together.
RANCHO SECO REPORT ON FINANCIAL ASSURANCE STATUS Attention: William Allen*
As required by 1 O CFR 72.30(b)(6), this letter provides the information on the status of financial assurance for decommissioning at Rancho Seco.
Background
Rancho Seco began commercial power operation in April 1975 and shut down permanently in June 1989. In 1991, the Sacramento Municipal Utility District (SMUD) submitted the proposed Decommissioning Plan for Rancho Seco, along with a Revised Financial Assurance Plan. The NRC approved the Decommissioning Plan in March 1995. Due to revisions to 10 CFR 50.82, SMUD submitted the Post Shutdown Decommissioning Activities Report for Rancho Seco in March 1997. Rancho Seco began decommissioning in February 1997. In April 2006, SMUD submitted the License Termination Plan for Rancho Seco outlining a phased approach to decommissioning.
Phase I of the decommissioning was completed in 2009 when the majority of the facility land area, including the major plant systems and structures, was released from the license. Phase II of decommissioning (a 1-acre land area that contains the Interim Onsite Storage Building) was completed in 2017. The NRC terminated the 10 CFR 50 license (DPR-054) effective August 31, 2018. The only remaining portion of the site that will require decommissioning is the approximately 14-acre ISFSI licensed under 10 CFR t
Part 72'.
A) J-1.5 SL Decommissioning Financial Assurance Method and Trust Fund Status An "External Sinking Decommissioning Trust Fund" continues to be maintained by Wells Fargo Bank on behalf of SMUD. Per the Financial Assurance Plan, SMUD made contributions to the Trust Fund through 2008, at which time it was considered to be fully Rancho Seco Nuclear Generating Station I 14440 Twin Cities Road I Herald, CA 95638-9799 I 916.452.3211 I smud.org
DPG 19-040 Page 2 of 4 funded. At this time, no future contributions are planned but SMUD will continue to.
perform Decommissioning, Cost Estimates as required and compare the results with the available funds in the Decommissioning Trust Fund to ensure reasonable financial assurance.
Administration of the Decommissioning Fu rid The trust fund holdings were reviewed at the end of 2018, and the trust fund contained
$8.54 million. As discussed below, this exceeds the amount of funding estimated as.
required to complete decommissioning. If during the annual review the cost to complete decommissioning exceeded the available funds, a contribution would be made as required by 10 CFR 72.30(g) to provide reasonable financial assurance.
Estimating Required Decommissioning Funding To demonstrate reasonable financial assurance in accordance with the regulation, the following comparison will be made:
Site-specific cost estimate for remaining work vs. currently available funds Site-Specific Decommissioning Cost Estimate A copy of the 2018 Decommissioning Cost Estimate for Rancho Seco is included as. The Decommissioning Cost Estimate for Rancho Seco is $5.6 Million.
Certification of Financial Assurance As of December 31, 2018, the available funds in the Decommissioning Trust Fund were
$8.54 million, which exceeds the estimated funding needed to complete decommissioning.
Certification in accordance with 10 CFR 72.30(b)(6) is hereby made that financial assurance is being provided through an external sinking fund for $8.54 million to complete decommissioning at Rancho Seco and terminate the Part 72 license.
Adjustments to Cost Estimate and Trust Fund With the termination of the Rancho Seco Part 50 license (DPR-054) on August 31, 2018, decommissioning costs for only the Rancho Seco ISFSI are being reported. As the base assumptions used in the development and subsequent updates of the cost basis for decommissfoning the ISFSI remain unchanged, this 2018 update consists of only an inflationary adjustment.
DPG 19-040 Page 3 of 4 Assumptions Regarding Rates of Trust Fund Escalation and Earnings Since, the Trust Fund contains sufficient funding to complete all decommissioning work, no assumptions are necessary concerning the rate of return to demonstrate sufficient funding.
Contractual Obligations There are no contractual obligations associated with SMUD's Financial Assurance Plan or the operation of the decommissioning tru.stfund.
Modifications to Financial Assurance Method.
No modifications have been made since last year's report. The Trust has been fully funded since 2008 and remains in an external sinking fund as previously described.
Material Changes to the Trust Fund Agreement No material changes to the Trust Fund Agreement have been made since last year's report. The Trust remains with Wells Fargo Bank, N.A.
If you or members of your staff have questions or require additional information, please contact me by email at dan.tallman@smud.org or by phone at (916) 732-4893.
Sincerely, Dan A. Tallman Manager, Rancho Seco Assets : DPG 19-034, 2018 Rancho Seco ISFSI Decommissioning Cost Estimate Cc:
NRC, Region IV (w/Attachment)
RIC: 1F.099
DPG 19-040 ATTACHMENT 1 2019 Dl;.COMMISSIONING COST ESTIMATE RANCHO SECO ISFSI DECOMMISSIONING Page 4 of 4
201 8 DECOMMISSIONING COST ESTIMATE RANCHO SECO ISFSI DECOMMISSIONING
Page ii of iii Prepared by:.
- Assistant.Superintendent, Rancho Seco Ass_et~
Approved by:
Manager, Rancho Seco Assets
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On the cover: ISFSI - regulated by Part 72 License
Page iii of iii TABLE OF CONTENTS PAGE Approvals................................................................................................................ ii Summary****:****:**.-***************:.:**:.**_::-._:**************************************************************************" 1,, -,*
Background................... :..... ::::~'...................... ::*.::*.....-... ~:.:.:... :*.... ::..... *.'.'...:.:... :.:.. '..:*.'.. i.2,**
Introduction.......................................................................................................... :... 4 Financial Assurance for ISFSI Decommissioning......................................,.... ~...4
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Methodology and-Approach.:;.i........................................................ :...................... 7 Overview of Decommissioning Cost Estimate Components.............................. 7 Financial Components of the Cost Model............................................................... 7 Assumptions............................................................................................................. 8 Used Fuel............................................................................................................ 8 ISFSI Decommissioning..................................................................................... 8 Reactor Vessel and Internal Components........................................................... 9 Transportation Methods...................................................................................... 9 Low-Level Radioactive Waste Disposal............................................................. 9 Estimating Basis.................................................................................................. 9 Labor Costs......................................................................................................... 9 General.............................................................................................................. 10 Glossary of Acronyms and Abbreviations............................................................. 12 References.............................................................................................................. 13 TABLES
- 1. Decommissioning Cost Estimate..................................................................... 14
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- DPG,19-034 Page 1 of 14*
2018 DECOMMISSIONING COST ESTIMATE
SUMMARY
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! l The Rancho Seco 10 CFR Part 50 license was terminated by the NRC effective August 31, 2018; therefore, no further decommissioning-costs c\\fe* anticipated for the Part 50.
- license and no furt;herreporting ofthe associated ;costs will p'e made: * * *
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The projected cost to complete the.decommissioning of the Rancho Seco Nuclear Station Independent Spent Fuel Storage Installation. (ISFSI) is $5.6 million; This includes all *.
- projected costs to terminate the 10 CFR Part 72 license.
Decommissioning activities related to.the.-;ISFSI include.the transfer of the used nuclear fuel and Greater:Than Class "C" (GTCC) radioactive waste. to the.Department of Energy (DOE)_in 2021 1 followed b.y.decommissionihg and license termination activities necessary to demonstrate compliance.with the* facility release standards in 10 CFR 20 for the Part 72 licensed area.
Since 2009, used fuel management costs are considered a normal operation and*
maintenance (O&M) expense, recoverable from the DOE, and are not included in the:
Decommissioning Cost Estimate.
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1 Based on the DOE's "Strategy for the Management and Disposal ofUsed Nuclear Fuel and High-Level Radioactive Waste", January 2013.
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BACKGROUND Rancho Seco is located approximately 25 miles southeast of Sacramento, California. The Industrial Area (IA) is 87 acres and sits within a 2,480-acre plot of land that is owned by the Sacramento Municipal Utility District (SMUD). The original nuclear stationwithin, *.
the IA was comprised of a single B& W-designed generation unit with support facilities.
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Rancho Seco' commenced reactor operations on.September 16, -19? 4 and began,. *,
commercial operation April 18, 1975. SMUD permanently tentI.inated operations at*,. *..
Rancho Seco on June 7, 1989 following passage of a public referendum June 6, 1989.
The reactor was completely defueled on December 8;, 1989 and a, Possession, Only.*;, -,,,--,
- License, along with Permanently Defueled :Fe¢hnical Specifications; became effective*1* *1.-::t April 28, 1992.
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On May 20, 1991,,SMUD submitted'a*proposedDecominissioning Plan to,.the NRCthat.
outlined the decommissioning option of Hardened 'SAFSTOR. This alternative put the '.
fuel in dry storage and placed the plant in a safe,,donnant condition with a small site,..
maintenance staff until 2008 when a Decommissioning Operations Contractor would be
- brought in to complete decommissioning. This allowed for the DecomrilissionihgTrust Fund to be fully funded before dismantlement began. The NRC issued a decommissioning order*and approved the Rancho Seco decomrpissioning funding plan on March 20; 1995.
Beginning in 1995, TLG Services, Inc. (TLG) provided SMUD with alternative cost estimates that included options for the decommissioning of the facility. Delays in the Dry Fuel Storage project caused increases in projected costs, and alternatives were provided to take advantage of available opportunities, including: availability of SMUD staff on site to support dismantlement due to delays in the Dry Fuel Storage project, and; availability ofEnvirocare's Clive, Utah disposal facility (Envirocare is now EnergySolutions) as an appealing option for low level radioactive waste (LLRW) disposal.
In January of 1997, the SMUD Board of Directors (the Board) approved the Incremental Decommissioning Project, and physical dismantlement of the facility began later that year. In 1999, the Board approved expansion of the Incremental Decommissioning Project to include all activities necessary for license termination. In April of 2006, SMUD submitted the License Termination Plan (LTP) to the NRC, outlining the activities necessary for the NRC to allow license termination in two Phases. The LTP was approved by the NRC in November 2007. In September 2009, following completion of Phase I decommissioning, the NRC approved SMUD's request for modification of the Part 50 license. This modification left only the Interim Onsite Storage Building (IOSB) and the land enclosed by the exterior fence (approximately 1 acre) licensed under Part 50.
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DPG*l9-034 Page of 14
- In the interim, the NRC issued SMUD a specific license for fuel storage in the
- Independent Spent Fuel Storage Installation (ISFSI) under Part 72 in June of 2000.
Transfer of all nuclear fuel to dcy storage in:..the ISFSI was,completed August 22, 2002..
With the closure of the Barnwell,. S.C. waste disposal facility, there were no options for.
disposition ofqassH and Class C LLRW available to SMUp*beginning in 2008. The.
Class B and;Class C LLRW was stored:in the IOSB until the.Waste Control Specialists,.*
Inc. (WCS) facility in Andrews, Texas was deemed by SMUD as a suitable facility for disposal-ofthe material. Shipping of the ~tored waste was completed in November.2014.
Phase II decommissioning of the IOSB and surrounding land wa:s completed in 2016 and the NRC terminated the 10 CFR 50 license effective August 31, 2018.
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As *a,precursor to the decommissioning,of.theJSFSI, the estimated date for DOE::.. *.
acceptance of,the used.nuclear*fueland' GTC~. waste.is 2021 based on the DOE's'<- *-*:'.,
"Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level,.
Radioactive Waste". That report, and the 2012 report by the Blue-Ribbon Commission on America's Nuclear Future still provide~ the best-available pµblisheclinform~tio:µ on the potential for DOE to take possession of the material stored at the ISFSI. SMUD recognizes'. that the schedule provided*withinthe DOE report has been-severely compromised by the failure of Congress to pass.the necessary enabling legislation, *
- however, considering that the Decommissioning Trust Fund* is fully funded, and SMUD is not relying on increases in trust fund value through investment growth to ensure available funds for decommissioning, the uncertainty in the schedule for used fuel removal does not impact SMUD's ability to fund.all decommissioning activities..
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DPG 19~034 Page 4of 14, INTRODUCTION
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This *decommissioning cost,estimate is prepaxed to S;:ltisfy the requirements of Title 10 of '
the Code of Federal Regulations;, Part 7230. As the base assumptions used in the development and subsequentupdates of.tlie*cost basis for decommissioning the ISFSI remain unchanged,' this 2018
- update consists of only an in:flatioriary *.adjustment.,:.:* *,
..t' This Estimate*includes all ISFSI decommissioning.costs.
- The current cost estimate for, decommissioning Rancho, Seco is $5.6 million. :.,. : * ** :,.,
Financial assurance for ISFSI decommissioning has been required since December 2013.
This cost estimate carries forward the information.necessary*to allowcompliancerwiththe'\\
regulations in 10 CFR72.30 which is being updatetlinthis.report in."accordariae*with,;: _, :.-:
those regulations.
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SMUD fully funded the *Part 50 Decommissioning Trust Fund by,making the last contribution.in 2008. However, because 6fthe levelofuncertainty inherent in power reactor decommissioning,' the amount of funding provided was conservative.. When. the decommissioning and license* termination of the 10 Part 50* license was completed in.
2018 enough funds remained to assure available funding' for the Part 72 ISFSI *
- decommissioning. Therefore, no additional contributions to the Trust Fund,are currently planned.
10 CFR 72.30 contains specific requirements for documenting the financial assurance for ISFSI decommissioning. These specifics are addressed here.
72.30(b )(1) requires documentation of how funds will be provided: The Trust Fund initially established for Part 50 Decommissioning was over-funded. The remaining funds will be maintained in the Trust Fund to provide financial assurance for the ISFSI decommissioning. The activities to decommission Rancho Seco include activities necessary for terminating the Part 72 NRC license. This cost estimate demonstrates that sufficient funds are available in the Trust Fund to provide financial assurance for ISFSI decommissioning.
72.30(b)(2) requires a detailed cost estimate for decommissioning the ISFSI: This document provides the information required.
72.30(b )(2)(i) requires that the cost estimate include the cost of an independent contractor to perform decommissioning activities: This cost estimate assumes all activities are conducted by an independent contractor in compliance with this requirement, in addition to including the cost of a SMUD Project Manager.
DPG 19-034 Page 5 of 14 72.30(b )(2)(ii),requires an adequate contingency factor: A factor. of 15% is* used.* This is sufficient to account for proj.ect uncertainties and demonstrates. compliance with this.
requirement. Contingency is provided to account for uncertainties in the decommissioning.process. Given that detailed information,exists documenting the.,
radiologi:'cal conditions.of the facility, and the robust nature of the.sealed fuel storage
- systems, there is little*radiological uncertainty regarding the condition of the facility and
- 15% provides a sufficient margin.
72.30(b )(2)(iii) requires inclusion ;of the cost of meeting the radiological criteria for*.
license termination*contained:in 10CFR20:**Those activities are* specifically included in*:
this cost estimate demonstrating compliance, with. this requirement.-.
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72.3Q..(b)(3) :requires i9-entification.andjustification,0Hhe.key assumptions*used in the.
cost estimate: That.information is,spec.ifically included later inthis*document, demonstrating.compliance with this i;equire.ment,.
72.30(b )( 4) requires a description of assuring funds for decommissioning and a means for adjusting the cost estimate periodically-over, the life of the faeility:. The funds for decommissioning were already contained in a Decommissioning Trust Fund set aside for Part SO.license termination. 72.JO(c).requires that the decommissioning funding.plan be resubmitted at intervals not to exceed 3 *years. In 2014, 2015, 2016,.and 2017 updated.
plans_were submitted reflecting the updated schedule for Part 50 decommissioning. As.
none of the baseline assumptions.. for, decommissioning and license. termination cost of the Rancho Seco ISFSI have. changed,;this update consists of only an inflationary adjustment of the 2017 update. License termination of the Part 50 license occurred in 2018.
Therefore, it is expected, that when the next Part 72 decommissioning funding plan is,
- upda,ted, only Part 72 decommissioning,_ costs will remain, and the.financial instrument*:.
used to demonstrate.assurance with'72.30(e) will reflect that information. Until then,,the.*,,
existing Trust Fund is justified for pro:viding finanpial assurance. The Rancho *Sec<'> :.
ISFSI License.expires in 2020, so per 72.30(c), the decommissioning funding plan-was resubmitted with the license :renewal application. The license renewal process will:
incorporate a mechanism for. future funding plan updates.
72.30(b )(5) requires information regarding the subsurface residual radioactivity, that will require remediation to meet the radiological criteria for license termina~ion: No remoyal of subsurface materials will be required tb meet the radiological release: criteria: The :
radiological condition of the' land area of the ISFSI was evaluate:<l: prior to con,sthlctioii and no residµal tadioactivlty was evident.: Given that the niateti~l m storage ~t the facility re*sides in robust~ sealed_container~_a):ld there ii no reaion~ble'desig1?:_basis' accident that can occur to cause failure of the containers, there is lio reasonable likelihood.
that th~ *stored radioactive materials will ente~ the environment. Detailed iadioiogical ' **
surveys conducted quririg the process of moying the'fuel from.wet to:*diy storage.
document that no contamination or the ar~a occurred during operations. With no reasohabi~ method ofint~odt1cciilg radioactive'ffiaterials into the iand wi'.thin the ISFSI_.. ;*;
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DPG 19-034 Page 6of14 facility, there is no teasonable"expectation that subsurfaee materials-will require:...
remediation. This*documents compliance withtlie.requirement:',. ".,. **
'I 72.30(b )( 6) requires certification that financial *assurance for decommissioning be*
- provided: Coinpliance with this requirement was satisfied by a'Separate letter: RANCHO*
SEGO REPORT ON FINANCIAL*.ASSURANCE STATUS, DPG'19-040, 'dated March 28,2019 As discussed*previously; SMUD fully funded the*1Part 50 Decommissioning Trust Fund....
by making the last contribution ih 2008. HoweverJ because of the level of uncertainty;'*..
inherent in power reactor.decommissioning, the amount of funding pmvide& was ;, * * *,, : :. *,
conservative. With the Part 50 decommissioning and license termination activities now complete; ah excess of available-funds exists 'irl the Decommissioning Trust Pund.* This. ;.
- excess provides moretharl enough funds to,as!;utelavailable funding.for future.JSFS'I decommissioning. Therefore, no additional contributions' to the Trust Fund are currently
- planned.
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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 :for1 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 ori decommissioning costs:'.
- 72.30(c)(l) spills of radioactive materialprbducing*additional-residual radioactivity in onsite.subsurfaceniaterial: Section9.6 of the Rancho Seco ISFSI FSAR states "Due to*
the zero-l'eakage design of the NUHOMS DSCs,.SMDD expects no residual *,
contamination' on the ISFSI concrete base :pad:'?, Therefore,. neither liquid *spills of substances containing radioactive material, nor'thos*e that may come *in contact with:.
radioactive material are* considered credible at this stage of decommissioning, *since the.
remaining radioactive material is in Solid form and not dispersible. This lack of * '** * *
- credibility extends to the potential for contamination of the soil in contact with the ISFSI concrete pad..
- 10* CFR 72jo(c) (2) facility mpdifications: As ~eported.to tl).e NRC in SMUD letter "RANCHO SECO B°IENNIAL'IIBPORT" dated iuly 14, 2016 (ADAMS Accessiop No.
ML16208A109), Sl\\WD iristaHed a 40p square foot Fuel Transfer Equipment,Stprage Building (ESB) within the Part 72 licensed b01.µ1dary. This structur~, e.xternal to _the.
ISFSI pad, provides envirorunentally sheltered storage for.Juel handling equipment :.
coritaininated \\\\;'ith licensed radioactive rriateriaL This contamination is either fixed (as in.
the case ofth~ MP-i87 Transfer Cask) or contain.erized to preclude its spread whHe in storage. sMUp'anticjpat~s a maximum of27 fina.l status suryey ~its to'dem6nstra~e *...
satisfaction of the release criteria contained in 10 CFR 20. As contamination of'this new structure is n.ot antidp~t~cl, ail additional Class 3. surv~y uciff~r the 'EsB* interior1a.hd.. *, *.
DPG 19-034 Page 7of 14
- exteriorwould be added.. As the survey*design-criteria for Class 3-survey units are-minimal, the'impact-on the overall cost-of decommissioning the1SFSI,*would be insignificant.
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10 CFR 72,.30(c) (3) changes hi authorized*p6ssession limits:: SMUD completed the transfer of.all SNF 0ruid GtCC waste to the'ISFSI'in.200(5. SNM-2510, Amendment 4 (11/24/20.17) provided_ for the storage pf a '200 :µCi Sr-90' byproduct material :source for use as 8:_check ~mµ'.ce_for radiological detection ecj\\i1pirl~nt'idelitified within SMUD's Radiatidn Protection anc(Emergericy Pi'epai;ednes~ Plans'.* Thi~: is a change to the*
authori:z:edpossession*li.mits since the approva:1 *of the ISFS°I Decommissioning Fund1ng Plan.'* The' impact 'on the** overall cost 0:f decoriimis.sionmg the ISFSI *resulting from this increase will be insignificant.
10 CFR 72.30(c) (4) actual remediation costs that exceed the previous cost estim~te::
SMUD will not begin to decommission the Rancho Seco ISFSI until after the U.S.
Department of Energy takes possessi~n o;f.ithe spent fuel and GTCC waste. Therefore, there have been no actual remediatiorucosts,.that exceed previous cost estimates.
- METHODOLOGY AND APPROACH Overview of D_~commissioning Cost Estimate Components r
The cost estimate provides1 an overall cost for the duration of the ISFSI decommissioning project. This includes all costs incurred aftet temoval of the spent'miclear fuel and GTCC waste through the P8;11: 72 li~ens~ termination.
- , *1 ~ :.r Staff costs include the cost for' contract' staff to perf~m'l the Final Status Surveys* aiid remaininglicense*tennination activities of the iSFSI. * *,
Miscellaneous co,sts have been includ~d t9 ~9_c~ei;i{ t~e su_()port.costs that are specifically iden~ified for the 4uration of the'I~FSI decommi~si6ning proj~ct..These costs also include material costs for decomrtrissi6nirig.
FINANCIAL COMPONENTS OF THE COST MODEL The decommissioning cost estimate in total is defined as the funding required to complete_.
decommissioning through license termination. Historically, the estimate consisted of a large number of calcuh~.teq costs based. on cost factors, and the Gost assigned to a given li.p.e item within the estimate w.as not ascrigo,rously defended as the total: ~ b,asi~
assumption of the estimating process has been that wh~n specific. li11-e it~ms ha.ye bee1,1 over-estimated, the unspent funds will b,e required to ~~ver the' cos.ts a~sociated with ~ther line items that have been under-estimated. The historical costs for Jh~ Part.SQ.
decommissioning reflect that the cost of the work completed 'was, in general, over:
estimated and similar assumptions are anticipated to be applicable to the ISFSI decommissioning process.
DPG 19-034 Page 8 of 14'.
Examples of remaining contingencies include changes in the regulatory environment and cost or regulatory changes that would.impact remaining license termination activities.-
- The cost impacts of these uncertainties have been defined by TLG in previous estimates..
under the. term "financial risk". To dat~, linancial risk has not bee1,1; specifically i..
addressed within a.I).y R~cho Seco
- de~ommissioning cost estimate.* Outsid,~ ofthe scope of the cqst e~timate Hself, staff.deals with the.Sf un_certainties on /i,PXO]~Ct-by~proj~ct.
basis. An overall rjsk asses~m~nt taking into.'a~.comi.t any antic_ipat~d risk factqr wo~d typicaily be 'a~~e~ise~.* thr9ugh a pr9pal?ility
- an~~y~is, perhaps utilizing a Monte *tarfo-.. -. _
type probability si111ulat1qn. such a.detailed risk 81).aly~is is c*onsidered, to he outs1de of* '.
the scop~* of the d~C.OD;lill~SsioO:ing ~p~t estimate:. !11b\\vev~r., cqnfi.~gen~y: is ih~1~4ed a~ ~-..
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ASSUMPTIONS
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The following are the assmnptions used in developing-the*Rancho'Seco r8FSI cost*.**
estimate. Some assumptions are* generic in nature; and, some are specific to the Rancho Seco site.
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Used Fuel
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The cost to remove and dispose of the used*fu~l 'from the site is n~t reflect6d within the estimate to decommission Rancho Seco. The.Nuclear. Waste Pol~cy Act assigns.
this responsibility tcrthe DQEs Wai;te I\\/1:an~geme1:1,t System.,.
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The ISFSI will remain operation~i uncle~ the 10 CFR 72 li~ense until the DbE tak~s*
possys~ion,of, or accepts responsi~ility for, tlie,fu~l and GTCC waste: -:C:he c;ost ~or maintenance of the ISFSI is consid~r~d O~M and is pot incJuded in this cost estimate.
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DOE a~ceptance of the fuel and GTCC waste.in 2021. This will be ~eviewed for ea~h s~bsequent *e~timate-as the~i)liurre'ii.tly 'great unJert~inty with the,acceptance date. Note that the actual date of fuel acceptance is currentiy not a factor in*.
demonstrating financial assurance because the decommissioning co,sts are. fully.
funded and do not rely on a return on:investments over time.
ISFSI Decommissioning
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- No remediation will be required for any structures or land are~s at the ISFSI. -
Evaluation of Reference 4 indicates that activation of materials' *at the ISFSI will not
-result in contamination that requires remediation,. *No lbose containin~tion at the*
. TSFSI was rrieasuied-during the fuel mdvemeht activities in 2000 through 2002, arid fuel canister leakage is'beyond the ISFSI design'basis.
DPG l!J-034 Page '9 of.J4; Reactor Vessel Internal Components
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The reactor vessel internal components classified as GTCC material is stored in the ISFSI until the DOE takes possession of the material. However, the DOE has not yet established acceptance criteria or a disposition schedule for this material.
Therefore~ this cost estimate is based upqn industry.:.ac~epted assumptions regarding DOE schedules,,Industry assumptionsfor.the.accepU!.IJ.ce*criteria are modeled on the packaging for the used nuclear fuel:.the,_fffCC is ~toteq in.a canister with the same outer geometry as the used fuel canisters.
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.. 1 estimate;, Legal opinions atJ.d cour(qecjsions indicate that the GTCC disposal is the responsibility of the DOE.
Transportation Methods;.
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Contaminated materials resulting from any remaining decommissioning activities will qualify under, Title 49 of the Co4~ of fed~ral Regulations Part 17'JJ as. LSA-1, -*
II, or -'III, or SC0-1 or -II
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Transportation of Class A LLRW is by truck or rail to EnergySolutions in Clive, UT or Radioactive Waste Processing Facilities appropriately licensed and approved bySMUD.
Low-Level Radioactive Waste Disposal
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The amount of the LLR W generated during decommissioning will be minimal based on the absence of contamiriation:present. Future disposal rates for Class A waste used in the estimate are based upon historical rates and disposal cost escalation factors listed in NUREG-1307;'Revision 17.
Estimating* Basis
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Future decommissioning costs are in general reported in the current year's currency regardless of the scheduled year of the expenditure; therefore, changes in schedule do not impact the cost estimate.
- 2.
Remaining costs are based upon an estimate of the remaining activities including contract staff to perform the activities and other costs such as waste disposal.
Labor Costs
- 1.
The craft labor required to complete decommissioning is obtained through standard SMUD contracting practices. *
- 2.
Future activities such as waste shipments and license termination activities will be performed by contracted staff.
DPG,19-034 Page 10 of '14
- 3.
Engineering services for such items as writing activity specifications, detailed procedures, and work procedures are assumed to be performed by contracted staff.
('
l General.** *
- . '~.
. )' 1*
. !. ': *{. ~ ;
- 1.
0The approximately*l4.,.acre ISFSl,remaihsunder the Part 72 license., Following
. transfer of the used.fuel and GTCOm:aterial to the DOE, a decommissioning project
.will commence to teiminate.this'license. i* '.
.1
- 2.
NRC oversight of the decommissioning process is estimated based on previous license termination activities~, The amount of oversight effort is proportioned based **
on the number of SurveyUnits'for license tenn'in:ation as a-reasonable basis for the estimate.
- * *i '* *
- 3.
Equipment costs for use during decommissioning are included as Miscellaneous*:
Costs.
- 4.
Demonstration of compliance with the,radi.ofogical criteria for license termination of the Part 72 facilities will require documentation of.no more than 27 Survey Units as follows;,
- 5.
- 'J 22 1 *.
1 1
1
- 1.
Description HSMs
~*.
i.
Concrete Pad
.Concrete Apron ~.
Land Area Equipment Storage Building
- .Interior Equipment Storage Building Exterior
... ' ~.
Location Classification ISFSI ISFSI
. ISFSI.. *.
ISFSI ISFSI ISFSI Class 1 Class 2 Class 3 Qlass 3 Class 3
,Cla,ss 3 Equipment such as administrative equipment ( desks, chairs, etc.), forklifts, trucks, other.mobile equipment and items of personal property owned by SMUD will be easily removed without the use of special equipment at no cost or credit to the..
project.
~.
... : ' f. ~
DPG.19*034
- Page 11 of 14
- 6.
The decommissioning activities are:p~rfo.nn.ed in accordance, with applicable regulations.
- 7.
The principles of ALARA used in determining work duration adjustment factors are:
minimal for the remaining work scope, but remain an element in the cost estimate.
- 8.
SMUD provides the electrical power required for the decommissioning project at no cost to the project.
~. ' ;..
~. '
DPG 19-034 Page 12.of J4 GLOSSARY INCLUDING ACRONYMS AND MBRBVIATIONS
- 1.
- ALARA: As Low As Reasonably Achievable*
- 2.
- 3.
- 4.
- 5.
- 6.
- 7.
- 8.
- 9.
Barnwell: The Barnwell, SC LLRW Disposal Facility
- ~..
- J **
i:':
DOE: Department of Energy Energy Solutions: EnergySolutions, Inc., formerly Envirocare of Utah, Inc. -
headquartered in Salt Lake City that operates the LLRW disposal facility in Clive, UT and is a partner in "Sempra-Safe, LLC", a licensed resin processing technique in TN GTCC: Greater Than Class "C" Waste - disposal of this waste is the responsibility oftheDOE IOSB: Interim Onsite Storage Building ISFSI: Independent Spent Fuel Storage Installation LLR W: Low Level Radioactive Waste LTP: License Termination Plan
- 10.
NRC: Nuclear Regulatory Commission
- 11.
0 & M: Operation and Maintenance
- 12.
PWR: Pressurized Water Reactor
- 13.
Part 50: Title 10 of the Code of Federal Regulations, Part 50 -regulations governing the former operating plant license
- 14.
Rancho Seco: Used in reference to Rancho Seco ISFSI (Part 72)
- 15.
SMUD: Sacramento Municipal Utility District
- 16.
TLG: TLG Services, Inc
- 17.
Ward V ctlley: The proposed Ward Valley Low Level Waste Disposal Site in Needles, CA
- 18.
WCS: Waste Control Specialist, Inc. - operates the LLRW disposal facility being constructed in Andrews, TX
DPG 19-034 Page 13of 14 REFERENCES
- 1. "2016 Decommissioning Cost Estimate for the Rancho.-Seco.Nuclear Generating Station", March 23, 2017
- 2. Letter to NRC, "Rancho Seco Report on Decommissiqhlng Funging Status",
March 22, 2017 ii.~
- 3. Rancho Seco Part 72 License Termination cost basis, TLG S.e~i,~es, Inc "Independent Spent Fuel Storage Installation Decoimnissiori:in!t Cost Summary, 2003; ARO Response to Data Request and Assumptions, Attachment Sl 1-1481-m~
- 4. SMUD Engineering Calculation #Z-XXX-N0057, Revision 1, October 4, 1993, "Neutron Activation of a Pacific Nuclear NUHOMS"
- 5. "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste", Department ofEnergypanuary ~013
- 6. "Report to the Secretary of Energy", Blue Ribbon Connnission on Americ::a's Nuclear Future, January 2012
- _:~./. t
~-.
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Randlo Sero N uclfflr Gel!Batirig Statiori Area Bas,,d.Dea>m.mi.ssiol'li111 Cost Estimate Waste DiSl!QU DESC SHIP BURY License Termination Actvities Part 72 license termination 2
33 TOTAL-COST rcr 2018) 2 33 Total Decommissioning Cost Nata COSTS BY ACTIVITY STAFF SC 3,221 1,588 3,221 1,588 Table 1 Decommissioning Cost Estimate (Thousands of2018 Dollars)
CNTGCY CNTGCY TOTAL 727 15%
5,571 727 15%
5,571 5.§111
- oTAL COST (CE 201ar nlClf8l8ID 1ml CIINlded fuUe 8!lll\\llriZed DecomrniuiDnilQ Trust fund wlhdnlwa
- COSTS BY YEAR 2018 2027 2028 0
0 5,571 0
0 5,571 TOTAL 5,571 5,571 DPG19-034 Pa~Uof 14