ML20045B202
| ML20045B202 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 06/07/1993 |
| From: | Arnold W LOUISIANA ENERGY SERVICES |
| To: | Hall J ENERGY, DEPT. OF |
| References | |
| NUDOCS 9306160408 | |
| Download: ML20045B202 (5) | |
Text
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Louis;ana Energy Sereces (202) 467 5490 2600 Wg:nta Avenue. NW (202) 467 5495 Fax E
ERGY Suite 608 Washington. DC 20037 W. Howa'd Arnold Presicent June 7,1993 Mr. James C. Hall Assistant Manager for Enriching Operations U.S. Department of Energy Oak Ridge Operations Office P.O. Box 2001 Oak Ridge, TN 37831
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Re:
IAuisiana Energy Services Claiborne Enrichment Center Tails Disposal LES File: 8.9.1
Dear Mr. Hall:
I am writing to follow up on your statements in the NRC Commissioners' briefing of June 1, 1993. In response to a question about disposal of depleted uranium hexafluoride tailings, you mentioned that DOE was preparing the uranium inventory study mandated in the Energy Policy Act of 1992. You also stated that this study would include planning for handling and ultimate disposition of the tailings inventories held by DOE as well as those to be generated by USEC starting July 1,1993.
We are of course interested in the same issue, as the Claiborne Enrichment Center will begin generating this material when it commences operations--now scheduled for late in 1998. In the course of our licensing proceedings, we have been discussing the topic of disposition of tailings with the NRC, and have taken the position stated in our letter of December 14,1992 to Mr.
Hickey, a copy of which is attached. In summary, the position is that we would agree to convert this material to U 0, and dispose of in a sub-surface facility. Since we anticipated that 3
the DOE and the USEC would be required to do something similar, we also wrote DOE on November 6,1992 offering to participate in the uranium inventory study, and to share in the costs of the ultimate disposal. This letter is also attached.
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i Since we have not received a reply to our letter to Mr. Duffy, I would appreciate your bringing it again to the attention of the Department. I believe that coordination on this issue would be important, as commitments made in the course of our licensing procedure could affect other parties than just LES. Although our deadline for removing the first increment of tailings from the LES site may be as late as the year 2013, we appear to be leading the planning and schedule for handling and disposing of tailings at least as far as it relates to regulatory actions on the part of NRC. Such actions should take account of the most cost effective and consistent approach that can be developed by all U. S. producers of this material.
I encourage expeditious discussion and analysis of this subject so as to achieve the best and most acceptable result in terms of all our interests.
Sincerely, k,
cc:
Mr. Thomas P. Grumbly i
Assistant Secretary for Environmental Restoration and Waste Management U.S.D.O.E.
Mr. John Hickey, Chief Enrichment Branch Division of Fuel Cycle Safety & Safeguards Office of Nuclear Material Safety & Safeguards U.S.N.R.C Mr. Sam Fowler Chief Counsel Senate Energy Committee 2
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Louisana Energy Ss n
(2c2) 4ET 5490
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2121 K Stract. NW (2C2) 467 54S5 Fax ENFRGY Wastung:cn. CC 20ca7
't W. Mcwarc Arncfd Prescent Novemb= 6, ly92 l
Mr. Leo Duffy, Assistant Secre:ary for Environmen:al Restoration r.nd Waste Management United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re:
I.cuisiana Energy Services Claibo-rw-~~r Center Energy Policy Act of 1992 Uranium Inventcry Study LES File #: 8.4.6
Dear Mr. Duffy:
Tne Energy Policy Act of 1992 (" Energy Act"), Sec.1016 receires dat a umnium inventer /
24, 1993.
Among oder things, $1s smdy shall indude study be performed by October The "recommendadons for the fumre use and disposition of such [ uranium] inventodes."
referenced inventories indude depleted iniHngs (i.e., depleted uranium hexafluoride). By the year 2000, it is expec:ed 62t at least three domestic entities - the Departnent of Ene.Ty
(" DOE *), the United States Endchment Corporation ("USEC"), and Louisiana Energy Servic
("LES") will possess signhnt cuantities of depleted uranium hexaficodde ("DUF, ").
I Rather than have three or four separate entities deal with this issue in different ways and on different time scales, we would suggest that DOE take the lead and e::2blish a national progrzm for the handling of this potentially valuable mater'al. Such a program would be most economical for all par:ies because of economics of scale, and a single point of control could allow the environmental consecuenc= of shipment, conversion, handling and storage to be min;4-d.
Absent such a coordie-d program, one or more of thme enddes could take actions which might prejudice the optimum solution of this situation. LES would be pleased to participate in a program, and we would be prepared to provide assistance in de study phase and s expenses for conversion, storage and disposiden on an equitable basis.
I LES applied for a lice::se to consnuct and operate de Claiborne Enrichmen't Center ('
The applicadon is currently und= review by the United States NuclearI in January 1991.
Mr. Leo Duffy
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Novemb= o,1992 Page 2 Regulatory Commission ("NRC"). We expect a license to construct and operate the facil be issued in the third quarter of 1994. One of the outstanding licensing issues is disposition of the depleted uranium hexa 5uodde produced at the CEC. Although net a waste, the NR indicated they believe it will be tmated as such.
Depleted uranium is a potential energy source, and should be pr=:ved in retdevable One potential is as input to a future endchment plant, which would become economica price of separative work to drop signincantly or the price of namral uranium ore to dramatically. Anoder potentialis as breeding matedalin liquid metal reac: ors. Such reactors have been demonstrated to be technically feasible, and may become economical if the price natural uranium ore becomes high enough. However, such uses are undcubtedly decades away and extended storage of the m tedal will be recuired before it can be decided that the mate is indeed useful or should be cispositioned.
The LES license applicaden postuisted that UF. would be suffd=dy stable for ext =ded 22,1992 (ccpy enclosed), has stated pededs, but the NRC, by letic to LES dated September its preference for disposiden to be as U 0, in a facility not as yet de5ned ober t 3
not licensed under 10 CFR[part 61. Such an approach, our studies show, could b cosdy and result in a disposal plan which reaches well beyond the low leve! of r by depleted tails. However, we do agree that U 0, is stable, non-cormsive, an 3
water so dat it would be an excellent form for eiser extenced storage or disposal. In a dr study prepared for DOE by Manin Madetta dated September 1991, it is stated $2 opdon (as opposed to disposing of the DU 0,) may be to create a s:rategic ms 3
converted matedal in retrievable form in a facility designed for inde5 nite, low maint=ance opeation. This is curently being done in France with a perdon of the DUF. be in the Eurodif gaseous diffusion facility.
DOE currently possesses essend211y all the DUF. inventory in the United States. H USEC will begin to generate this mfe-ial as soon as the DOE facilides come under i Since the Ene.w Act also opendonal control via the lease speci5ed in the Energy Act.
specines that the USEC must be certi5ed by the NRC within two years, we an NRC requirements indicated to us in the letter of Septe=ber 22 will apply to the The LES licensing and the USEC c=ti5 cation reguladons are now being exnmked prompting an early recolution of this issue. This schedule is compatible your uranium inventory study, so we urge that you de5ne its scope br these issues. As our date of commencement of operzdons is no earlier than th and the demiline for removal of the Erst DUF. from the CEC site is well beyond 2 expect that there will be suf5cient time for us to coorrfinnm the specise acum! handling of our matedal once the plan is in place. Indeed, in this time parties could also gen = ate depleted uranium in the United States. F I
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Mr. Leo Dufff November 6,1992 Page 3 contemplates licensing the Atomic Vapor Laser Isotope Separation ("APdS") technology currently owned by DOE to a private entity who would build an en:ichment plant.
1 As stated above, LES would be pleased to participate with you and the USEC in discussing this matter at your earliest ccavenience. We are prepared to provide input to your smdy, tnd would look forward to working with you in the implementation phase when our inventory of DUE is to be dealt with.
Sincerely, WHA /pp Enclosure 6
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.f UNITED STATES o
7, NUCLEAR REGULATORY CO' <!SSION
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WASHINGTON. D. C. 20:5h
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5eptemaer 22, 1992 Docket No:
70-3070 Louisiana Energy Services, L.P.
ATTN:
W. Howard Arnold President 2121 K Street, N.W.
Suite 850 Washington, DC 20037 Gentlemen:
Since disposition of depleted uranium (DU) tails is an important decommissioning licensing issue for the' proposed Claiborne Enrichment Center, the Nuclear Regulatory Commission performed an assessment of the issues Our evaluation assumes that the bulk of DU tails will eventually be involved.
We examined the acceptability of disposal of the LES disposed of as a waste.
enrichment plant tails, as depleted UF, in a licensed 10 CFR Part 61 dis:csal t
facility as suggested by LES's " Depleted Uranium Hexafiueride Management Study." We have ccmpleted our review of this proposal.
Based on our analysis, we have reached the following conclusions.
The preferred chemical form for final disposition of the DU tails is U 0, 3
regardless of U-235 concentration.
Even if stored tails were later furt'ner processed and depleted of U-235, the bulk of DU tails must still be disposed -
)
is the more stable physicochemical form and the of.
Compared with UF, U 033 more compatible, as regaros to safety, with long-term disposition of tails.
t to DUFc for final disposition is not acceptable because Conversion of the DUF its physicochemical, 3long-term stability is incompatible with final disposal under 10 CFR Part 61.
I The Environmental Impact Statement (EIS) supporting 10 CFR Part 61 did not contemplate large volumes of DU tails. Our analysis, using methodology similar to that used for the Part 61 EIS, concludes that near-surface disposal of such large quantities of DU tails is not appropriate, both because of its However, other potential radiological impact and its chemical toxicity.
disposal alternatives under 10 CFR Part 61 may be viable; e.g.,
deep mine Therefore, disposal options, other than near-surface disposal, must disposal.
Disposal options must be accompanied with be considered for the DU tails.
The analyses should include funding provisions for l
supporting analyses.
storage, tails conversion to the oxide form, final disposition and, if applicable, transportation costs.
Your analyses should also consider an appropriate schedule for conversion and Since you are proposing to start production in phases, which may disposal.
take several years, the conversion of DUF to DU 0, or other suitable waste 3s form, should start 10 to 15 years after initiating production, or after generating 80,000 tons of tails, whichever is reached first.
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W. Howard Arnold.
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In su=ary, demonstration of viable mearis of DU tails ultimate dispositien and provision for financial assurance are needed.
It is reccgnized that the total volume of waste to be generated for the LES Claiborne Enrichment Center is part of a much larger national inventory. Therefore, LES DU tails dispositien may be addressed as part of the national inventory disposal scheme.
We would be pleased to discuss these matters further with you after you have considered them.
If you have any questions, please centact Dr. Lidia A.
Roche' at (301) 504-2595, Sincarzly, 0 /s
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v chn V.N. Hickey, Chief
. Fuel Cycle Safety Sranch Division of Industrial and Medical Safety Office of Nuclear Material Safety I
and Safeguards t
cc:
Attached list f
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ATTACHED LIST Dr. W. Howard Arnold Mr. Michael Mariotte President Executive Director Louisiana Energy Services-Nuclear Information and 2121 K Street, NW Resource Service Suite 850 1424 16th Street,fN Washington, DC 20037 Suite 601 Mr. Peter'G. LeRoy Licensing Manager Administrative Judge Louisiana Energy Services Richard F. Cole c/o Duke Engineering & Services, Inc.
Atomic Safety and Licensing Board P.O. Box 1004 U.S. Nuclear Regulatory Commission Charlotte, NC 28201-1004 Washington, DC 20555 Mr. J. Michael McGarry, III Administrative Judge Winston & Strawn Frederick J. Shen 4
1400 L Street, NW Atomic Safety ano Licensing 5 card i
Washington, DC 20005 U.S. Nuclear Regulatory Co=ission Washington, DC 20555 Mr. Ronald L. Wascom Deputy Assistant Secretary Office of Cc= mission Appellate Office of Air Quality and Adjudication Radiation Protection U.S. Nuclear Regulatory Commissicn Louisiana Dept. of Environ. Quality Washington, DC 20555 P.O. Box 82135 Baton Rouge, LA 70884-2135 Morton B. Margulies, Chairman Atomic Safety and~ Licensing Board l
Ms. Diane Curran U.S. Nu. clear Regulatory Cc= mission Harmon, Curran, Gallagher, &
Washington, DC 20555 Spielberg l
2001 S Street, NW Suite 430 l
Washington, DC 2009-1125 Natalie M. Walker, Esq.
Sierra Club Legcl Defznse Fund, Inc.
400 Magazine Street, Suite 401 New Orleans, LA 70130
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LOJISIANA Pest Office i3cx 1004 E
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December 14, 1992 1
I RECEIVED Mr. John W.
N.' Hickey, Chief LOU!SMNA ENERGY SERVICES
[
Fuel Cycle Safety Branch Division of Industrial and DEC - l 7 lggg Medical Nuclear Safety l
I Office of Nuclear Material Safety i
and Safeguards
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U.S. Nuclear Regulatory Commission b.4. _-N
.3 Washington, D.C.
20555 i.
Subject:
Docket No.: 70-3070 Louisiana Energy Services
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Claiborne Enrichment Center l - ~"~~~~
Disposition of Depleted
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' T.[.] ;
Uranium Hexafluoride File: MTS-6046-00-2001.01 l%
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Dear Mr. Hickey:
This letter is in response to your letter to Louisiana Energy-i Services (LES) dated. September 22, 1992 regarding the disposition of depleted uranium hexafluoride (DUF ) produced at the Claiborne l
6 Enrichment Center (CEC).
As an applicant for a license to possess byproduct, source, and special nuclear material, LES is required by i
10 CFR Parts 40.36, 70.22 (a) (9),
and 70.25 to-submit a
decommissioning funding plan containing a cost estimate for decommissioning and a description of the method of assuring funds for decommissioning.
However, the costs LES will incur for removal
-j and disposition of DUFc are more properly characterized as operational and maintenance (O&M) in nature and thus should be treated in a manner different from the costs of decommissioning the CEC at the end of its useful life.
The decommissioning funding plan as well as the cost estimate for DUF disposition are detailed in the LES License Application, 6
Exhibit I, the LES Safety Analysis Report (SAR), section 11.8, and the LES Environmental Report (ER) section 4.4.
The cost estimate
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for removing DUF was provided in the same sections as the 6
decommissioning cost estimate as a matter of convenience since DUF6 eventually must be removed from the site in order to release the o
site for unrestricted use.-
Regarding decommissioning itself, LES understands that at this time it is not necessary for LES to submit a decommissioning plan required by 10 CFR Parts 30.36, 40.42, and 70.38.
The decommissioning plan will be submitted to the'NRC for j
approval shortly before cessation of licensed activities.
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ON Yi evg,- W
Mr. John W.
N.
Hickey, Chief December 14, 1992 Page 2 The "LES CEC Depleted Uranium Hexafluoride Management Study" referred to in your letter provided further detailed bases for LES' created at the CEC.
decisions concerning disposition of the DUF6 Specifically, one option in the report analyzed conversion of DUF 6 to DUF and then packaged, transported, and disposed of in a Near-4 Surface Disposal Facility licensed in accordance with 10 CFR Part 61.
LES analyzed this option because it conformed to processes i
that are currently licensed and available in the United States.
Your letter of September 22, 1992 indicated that LES should convert i
DUF to U 0 and not dispose of the U Og in a Near-Surface Disposal 4
3 8 3
Facility.
Disposal should be in another alternative; deep mine disposal was suggested.
Recognizing that the regulatory framework is currently under consideration for revision, for disposal of DUF6 LES has prepared the following estimate in response to your letter and as an option in addition to the previously submitted disposition options.
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I Table. 1 (attached) conpares the previously submitted figures with additional ones prepared in accordance with the following assumptions-e LES has the DUF produced at the CEC converted to depleted 6
(U Og) for disposition.
The conversion triuranium octoxide 3
and disposition are perfor=ed at non-LES f acilities of f-site.
e LES com::lences conversion of DUF to U 0 within 15 years of 3
3 s initiating enrichment at the CEC or after production of no more than 80,000 tons of DUF, whichever occurs first.
6 disposition For the purposes of the decommissioning and DUF6 e
cost estimate, LES assumes that the depleted UO will be 3 g disposed of in a facility, other than a near-surface disposal facility, under cognizance of the NRC.
These additional figures provide.a sufficient basis for assessing the adequacy of the O&M cost estimates contained in the ER.
The i
cost estimates in the License Application, Safety Analysis Report and Environmental Report will be updated in the near future to i
reflect the additional figures.
LES believes that commitment to a definitive or prescriptive l
resolution of the manner of disposition would be premature at this time.
The Energy Policy Act of 1992
(" Energy Act"), Sec. 1016 requires that a uranium inventory study be performed by the United I
States Department of Energy
(" DOE") by October 24, 1993.
Among other things, this study shall include " recommendations for the future use and disposition of such [ uranium) inventories."
The l
Mr. John W. N. Hickey, Chief December 14, 1992 Page 3 referenced inventories include depleted tailings (i.e.,
depleted uranium hexafluoride).
By the year 2000, it is expected that three domestic entities The
- DOE, the United States Enrich =ent Corporation ("USEC"), and Louisiana Energy Services ("LES") will possess significant quantities of depleted uranium hexafluoride.
The DOE currently possesses over 1 billion pounds of DUF.
The 6
newly created United States Enrichment Corporation (USEC, see below) will continue to produce DUF at a rate approximately 5-8 6
times that of the CEC, commencing on July 1, 1993.
Production at the CEC only begins later this decade.
The Energy Act also requires that NRC, in consultation wi'h the t
Environmental Protecticn Agency (EPA), must review the operations of the USEC with respect to the gaseous diffusion enrichment facilities leased by them from the DOE.
The Energy Act requires that the NRC establish standards to govern the gaseous diffusion enrichment facilities in order to protect the public from radiological hazard and provide for the common defense and security.
LES anticipates that there would be no basis to apply than to that produced at different standards to USEC-generated DUF6 the CEC.
The establishment of similar standards for the USEC should allow the depleted uranium hexafluoride produced by the USEC and LES to be handled in a similar manner.
This also will allow LES to assume the availability of reconversion and disposal facilities, and economies of scale in methods of handling the material.
Also LES will not be at a competitive disadvantage in these areas with LES' major domestic co=petitor.
The two years allowed by the Energy Act for the NRC to establish the standards for the gaseous diffusion enrichment facilities will permit additional information to be gathered by the NRC, EPA, DOE and LES on the disposition of depleted uranium hexafluoride, well in advance of the time scale for production from the CEC.
The DOE uranium inventory study referred to above will be a suitable forum for coordinating joint action among the three (or more) parties responsible for producing and disposing of the national inventory of depleted uranium.
I enclose a copy of the letter LES sent DOE stating our belief that this material represents a potential national resource, and that its future i
storage and ultimate use or disposition should be handled jointly among the parties involved.
LES has offered to participate in the study phase of the program and to contribute LES' appropriate share of the disposition costs themselves.
As stated currently in the License Application, Exhibit I, LES will
Mr. John W.
N.
Hickey, Chief December 14, 1992 Page 4 review and adjust as necessary the decommissioning cost estimate and decommissioning funding at least once every five years.
At such times, or more often if appropriate, LES will also review the cost basis of depleted uranium hexafluoride disposition.
This j
element of O&M costs will be recovered in the current pricing of the facility's product and need not be provided in advance as a surety fund.
i The funds thus gathered from enrichment services will be set aside by LES in a separate account to ensure the necessary funds are available to dispose of the current DUF6 inventory possessed by LES at any point in time.
Should the estimates for disposition of DUF6 i
provided in this letter not prove adequate, LES will adjust product pricing accordingly.
Since our domestic competitors would be dealing with similar regulations, LES anticipates being able to-recover any necessary price adjustments in the market' place.
LES will also limit the on-site inventory of ' DUF to the amount 6
specified in your September 22, 1992 letter.
3 If there are any questions concerning this, please do not hesitate to call me at (704) 373-8466.
F Sincerely, Peter G. LeRoy Licensing Manager PGL/N71.112 Enclosures 1
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T m
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Mr. John W. N. Hickey, Chief i
December 14, 1992 l
Page 5 xc:
(w/ enclosures) 1 Ms. Diane Curran, Esquire Harmon, Curran, Gallagher, & Spielberg 2001 S Street, NW, Suite 430 Washington, DC 20009-1125 Ms. Nathalie Walker Sierra Club Legal Defense Fund r
400 Magazine Street Suite 401 New Orleans, LA 70130 Mr.
R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality
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PO Box 82135 Baton Rouge, Louisiana 70884-2135 1
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Table 1 Comparison of Decommissioning and DUF, Disposition Costs Present Estimate' Revised Estimate' Cost Catecory
($1996)
($1996)
Decontamination and Decommissioning (D&D)
(one time costs)
D&D Facility Capital
$ 6.8
$ 6.8 D&D Facility Labor 1.4 1.4 l
UF, System Cleaning 1.1 1.1 l
Plant / System Dismantling 6.8 6.8 Decontamination 13.7 13.7 Aluminum Salvage Value (7.9)
(7.9)
Waste Disposal l.4 1.4 Hazardous & Mixed Waste Disposal 0.1 0.1 D&D Facility Decontamination 0.5 0.5 Final Radiation Survey 1.0 1.0 D&D Subtotal-
$ 24.9
$ 24.9 DUF, Disposition Costs (per year) 1 DUF, Transponation 0.8 /yr 0.8 /yr' DUF, Conversion 8.2 /yr-12.0 /yr Depleted Uranium Disposal (as DUF,)12.3 /vr (as DU,0.) 0.021/vr' DUF, Disposition Subtotal (1 yr)
$ 21.3 /yr
$ 12.821/yr DUF, Disposition Subtotal (30 yrs)
$ 639.0
$ 384.6 Total Decommissioning and DUFiDisposition Cost
$ 663.9
$ 409.5 Notes: 1) All agures shown are millions of dollars.
- 2) No change to transportation costs.- U 0, occupies approximately 1.4 times more volume than til.. Ilowever, the weight of U 0,is approximately 3
3 89% the weight of UF.,
- 3) See Table 2 for DU 0, disposition cost estimate basis.
3
-m_m.m_-__.___mm._-._
___._-m.___sm
___m.__m
_-._m._.--.
r Table 2 DU Og Disposition Estimated Costs 3
The CEC when operating at nominal capacity of 1.5 million sWU per year will produce approximately 300 48G cylinders of depleted UF, per year. Each cylinder of depleted UF. will result in approximately 11 tons (22,000 pounds) of depleted U 0, when converted. Therefore, 3
the CEC will produce approximately:
300 cylinders / year x 11 tons DU 0s/cylt
= 3300 tons DU 0 / year 3
33 The activities associated with deep mine disposal may be estimated by comparison with remedial action associated with cranium processing sites. As stated in The Energy Policy Act of 1992, Title X - Remedial Action and Uranium Revitalization, reimbursement made to licensees for remedial action shall not exceed $5.50 per ton of material. This figure ($5.50/ ton) agrees well with the cost (=570 million - $5.40/ ton) of disposition of 13 tons of material at the Union Carbide Uravan Mill.
Therefore, using $5.50 per ton of DU 0,, the cost ($1992) of Gpositioning 3300 tons of DU 0, 3
3 per year will be:
3300 tons DU 0, x S5.50 per ton = S18,150 (S1992) 3 escalating this at 4% per year to $1996:
$18,150 ($1992) x (1.04)4 = $21,250 ($1996)
Therefore, S21.250 per year will be used for the purpose of estimating the dispositioning costs for DU 0s.
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