3F1219-01, Supplemental Information in Support of Crystal River Unit 3 (CR3)- Revised Post Shutdown Decommissioning Activities Report and Decommissioning Cost Estimate

Supplemental Information in Support of Crystal River Unit 3 (CR3)- Revised Post Shutdown Decommissioning Activities Report and Decommissioning Cost Estimate

ML20006E788
Person / Time
Site:	Crystal River
Issue date:	12/26/2019
From:	State S Accelerated Decommissioning Partners
To:	John Hickman Office of Nuclear Material Safety and Safeguards
References
3F1219-01
Download: ML20006E788 (3)

Text

Accelerated Dec*ommissio.ning Partners, LLC 17101 Preston Road, Suite 115 I Dallas, TX. 7524$

Scott E. State, P.E., Chief Executive Offker sstate@NorthSta~.com I o.682.503.2240 I c.303.898.8035 10 CFR 50.80 10 CFR 50.90 10 CFR 72.50-December 26, 2019 3F1219-Ql United States Nuclear Regulatory C,C>mmission Washington, D.C. 20555-QOl AlTN: John B. H!ckman, Project Manag~r Reactor Decom~issionlng Branch .

Division. of D*ecommissior'lll)g, .uranium R~covery, and Waste Program,§ Office of Nuclear Material Safety and Safeguards

Subject:

Supplemental Information in Support of Crystal River Unit 3 (CR3}-- Revised Post Shut~o~ Decommissioning Activities Repo.rt and Decommissioning Cost Estimate

References:

(1) Letter, Duke Energy Florida, LLC to US.NRC, "Crystal River Unit 3 - Site

' I * * '

Specific D_ecommissionii:tg Cost Estimate>>, dated June*27, 2018 (ADAMS

. Accession No.ML18~78A181)

(2) Letter; Duke Energy Florida, LLC to-USNRC, HApplication for Order Consenting to !)irect Transfer of Control of Licenses and Approving_

~onformi~g License Amendment", dated June 14, 2019 (ADAMS Accession No. ML19170A194) *

(3) Letter, ADP CR3, LLC {ADP), "Notification of Revised Post-Shutdown Decommis~ioning Activities Report", dated June 26, 2019 (ADAMS Accession

-* No .. ML19177A080) .

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191

Dear Mr. Hickman:

ADP CR3, LLC (ADP) submlts"the followin_g Supplemental Information In support_of the review <?f

• the Revised Post Shutdown (?ecommission1ng Activlti~s Report Identified in Reference (3). This Supplemental Information provides additional detail regarding the decommissioning c~st estima'te a*ssoclated with radioactive waste prov'ide*d in both Referen~e (2) and Reference (3).

ADP estimated the radioactive waste volumes for the Crystal River Unit 3 Plant based on data from the nG 2018_Decommissioning Co~ Estimate_ (D_CE) pro'{ided in Reference (1). Through its*

reyiew of pl~nt conditions, ma~erial takeoff calculatlons and available documentation, Including_

groundwater monitoring da_ta, the h!storlcal site assessment and drawings, ADP Increased th_e total volume of radioactive waste by nearly 80%. T~is-substantial increase in waste volume wlll

_accommodate ADP's p_lanned de_construction methodology that foc.use*s on lowering 'dose to wqrkers by removing material for disposal after reduced surface decontaminatib~ time than originally assumed In Refe.rence (1). This method will generate add~d low activity waste volume that wlll _be ~isposed of in the Waste Control Specialists LLC's (WCS) exempt waste cell at the wcs*tacillty.

There is also a red_uction in Class A waste compared to the TLG estimate that is accomplis,hed by WCS exempt cell.* ADP utilized the WCS low activity Class A material . *being disposed ' of in the Waste

. , . ' Low Activity Waste (LAW) and Class A wast~ for Acceptance Criteria (WAC} for Exempt '

determining t_he classification of CR3 radiological waste. TLG has not hlstorlcally considered the WC5! exempt cell for disposal as*tt is a relatively new cell (Initial waste acc~ptance in 2015_). This reclassification has resulted in a lower overali cost for radioactive wa,ste disposal compared to TLG's estimate.

It should_be noted that_the ab~ve ADP approach is entirely conslste.nt with th*e a~proach applied at Vermont Yankee ~y NorthStar. To date Northstar has shippe~ over 3,0-00 to~s of waste to WCS with the percentage meeting the exempt .WAC exceeding our calculated volumes of exempt classification since some waste expected to be Class A was classified as exempt,

~ - J ' - * -

while all waste expected to be exempt has.been accepted as such.

The 'table below provides a detailed comparison of the ADP VS TLG estimated waste volumes*.

All disp~sal costing in our estimate Is directly derived from these volumes and contracted_ rates committed to by WCS for the duration of the CR_3 decommissioning project.

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191 Waste Class UOM nG2018DCE ADP_,-,-

Process/Exempt CF 279,214 810,869 Class A CF -187,369 , 29,674 Class B CF 1,252 .. 800 Class C CF 642 800 GTCC. CF 1,654 1,650 Total Waste Volume 470,131 843,793 ADP notes that although:volumes are "estimated," the unit costs used for each category of waste in the total cost estimate are fixed, because the unit cost rates have been contracted and committed.

ADP appreci~tes the opportunity to provide this information, and we look forward to further discussions.

Sincerely, Scott E: State, P.E.

, Chief Executive Officer Docket 50-302 Docket 72-1035 Operating Ucer\se*DPR-72 Page 3 of 3