ML20057E152
| ML20057E152 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 09/30/1993 |
| From: | Leroy P LOUISIANA ENERGY SERVICES |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9310070378 | |
| Download: ML20057E152 (10) | |
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- ouisiana Eneigy Servces (202) 467-5490 Si
- 2600 Virginia Avenue, NW (202) 467-5495 Fax-Suite 608 j
Washington, DC 20037 September 30,1093 l
Mr. John W. N. Hickey, Chief Enrichment Branch Division of Fuel Cycle Safety and Safeguards, NMSS U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Docket No.: 70-3070 Louisiana Energy Services Claiborne Enrichment Center Additional Information File: 6046-00-2001.01
Dear Mr. Hickey:
Provided in Attachment A is the additional information requested by your letter to LES dated September 27,1993 related to the cost estimate for decommissioning funding.
Please call me at (704) 382-2834 if there are any questions concerning this.
Sincerely, f/ilA $ h Peter G. LeRoy Licensing Manager PGUN102.993 Enclosures 070043 s.
ADOCK 07003070- @Klgs l
9310070378 930930 j
d-PDR
-C PDR 1-i
September 30,1993 Mr. John W. N. Hickey, Chief Page 2 xc:
(w/ enclosures)
Mr. Morton B. Margulies, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Diane Curran, Esquire Harmon, Curran, Gallagher, & Spielberg 2001 S Street, NW, Suite 430 Washington, DC 20009-1125 Mr. R. Wascom Office of Air Quality and Radiation Protection Iouisiana Department of Environmental Quality PO Box 82135 Baton Rouge, Imuisiana 70884-2135 Ms. Nathalie Walker Sierra Club Legal Defense Fund 400 Magazine Street Suite 401 New Orleans, LA 70130 l
i September 30,1993 Mr. John W. N. Hickey, Chief Page 3 bxc:
(w/ enclosures)
V M Anthony W H Arnold (LES)
E F Kraska (Urenco)
J M McGarry (W&S)
W R Griffin (FDI)
A Brown (Urenco)
H A Hammond Central Records Project Files
Attachment A AdditionalInformation Requested by NRC Staff Comments Related to Facility and Site Decommissioning 1.
Increase your estimates for facility and site characterization and generation of the decommissioning plan by $0.1 million each. NRC staff expects characterization of the CEC at the time of decommissioning to involve development of a characterization plan, conduct of the actual characterization activities and generation of the characterization report. For a facility of the nature and size of the CEC, the staff estimates the characterization plan and the report to each cost $0.05 million, and characterization activities to cost $0.1 million for a total of $0.2 million. In addition the staff estimates that generation of the decommissioning p!an would cost about $0.2 million.
Response
The decommissioning estimate has been revised in accordance with the above comments.
Safety Analysis Report (SAR) Table 11.8-2 has been revised to include the revised cost estimates, as well as the revised schedule and cost comments noted below, and is enclosed. A revision to the SAR, Environmental Report, and License Application will be made in the near future to reflect the revised cost estimate.
2.
Revise your estimate of 2 months required to characterize the facility and site to six months. Assuming that the characterization plan is fimalized before cessation of enrichment activities at the CEC, the staff anticipates that an additional six-month period will be required to complete facility and site characterization.
Response
The estimated time to characterize the CEC has been revised from two months to six months. The estimated overall schedule for decommissioning is shown in Figure 1
" Estimated Decommissioning Schedule."
3.
The staff anticipates that twelve months will be required to complete the final radiation survey, and an additional three ionths will be required to complete NRC's confirmatory survey. Revise the overall project decommissioning schedule accordingly.
Response
The decommissioning schedule has been revised in accordance with the comment.
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Attachment A l
Additional Information Requested by NRC Staff l
4 4.
Estimate the cost of maintaining the CEC idle during the time prior to decommissioning plan approval and, after completion of dismantlement and decontamination activities, prior to license termination.
Response
The cost of maintaining the CEC idle during the time prior to decommissioning plan approval should be minimal. LES will be managing operations and decommissioning activities to ensure costs are minimized. $1 million ($1996) has been added to the cost estimate to account for any idle time that may be encountered. The idle time added to the overall decommissioning schedule is estimated to be six n;onths. This time has been added to the decommissioning schedule. Figure 1 is a timeline of activities expected to be part of decommissioning activities. This timeline has been developed as an aid for accounting for and estimating the cost of decommissioning activities. It is realized that actual decommissioning activities, for e'xample characterization and decommissioning plan development, may overlap or occur in a slightly different order.
5.
State whether the two European pilot plants were characterized prior to centrifuge dismantling activities. If so then provide levels of contamination detected outside process equipment, i.e. on walls, floors, soils, etc. prior to the decontamination of the two pilot plants. Did the pilot plants have facilities comparable to the Technical Services Area of the CEC? If so, then provide contamination levels ia these areas as well.
Eesponse:
The Almelo pilot plants were not " characterized" prior to the beginning of the decontamination and decommissioning process. This was not necessary. Urenco knew that uranium residues in pipework and equipment other than centrifuges are negligible.
There was abundant experience with routine decontamination for maintenance purposes.
No abnormalities were encountered.
The original decontamination service of SP1 was decommissioned as well. All former UF. and non-enrichment services were removed. The building is still there. The cost estimates in the Urenco decommissioning information submitted to the NRC by LES letter dated September 21,1993, and therefore LES' estimate, included the removal of non-enrichment services.
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4 Attachment A Additional Information Requested by NRC Staff 6.
State whether a final survey was performed for Pilot Plant 1. If so, then briefly l
describe the nature and extent of the final survey.
Response
The contamination in the pilot plant building of SP1 was practically zero. Note that floors in the hex handling areas and the walls in labs and decontamination areas had a special coating which makes decontamination by simple cleaning very easy. Floors in these areas were cleaned / washed at least once a week during plant operation. There were very few spots with contamination where the top layer of the floor had to be chipped off by some millimeters. The total area was a few square-meters only, was virtually restricted to pits for potentially slightly contaminated water.
2 These surfaces had to be decontaminated to less than 0.4 Bq/cm for low toxic alpha (uranium) and 4 Bq/cm' for beta plus gamma according to Dutch regulations.
The building of SP1 is now available for unrestricted use. The status of decontamination and decommissioning of SP2 is not comparable to SP1, since part of SP2 is still operational.
There was no contamination of soil around the plant. Urenco Nederland has undertaken a general survey in which they compared soil of the same kind in the immediate neighborhood of the plant with soil within the perimeter fence. No difference was observed.
7.
State whether the $7.4 million cost of decommissioning 12,400 centrifuges at Almelo is appropriately escalated to 1993 dollars.
Resnonse:
Please note that as stated in our letter dated September 21,1993,14,500 centrifuges l
have been decommissioned at the Almelo facility.
The following adjustments were considered when evaluating the cost of decommissioning the CEC versus the cost figures provided by Urenco's experience with the pilot plants at Almelo. However, they are not included because they are minor adjustments and do not materially affect the overall decommissioning estimate.
a)
Consideration was given to escalating each year of Almelo's cost to 1993 dollars.
However, this would result in a ver;' small change in the overall decommissioning cost estimate. Also, no attempt was made to estimate cash flows during the 7 years estimated to decommission the plant. A similar savings in decommissioning costs could be estimated since not all decommissioning funds will be expended on.
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Attachment A Additional Information Requested by NRC Staff
" day one" of decommissioning activities. Therefore, no a$ustment was made for escalating the Urenco cash flows nor the anticipated CEC cash flows.
b) It is expected that between now and when the CEC is decommissioned that additional decommissioning experience will be accumulated. This will result in -
cost savings for CEC decommissioning activities. These cost savings have not been factond into the cost estimate.
A contingency of $3.5 million has been included in the cost estimate. This accounts for j
minor disempancies in cost estimating, such as inaccuracies in inflation estimates and currency exchange rate estimates.
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i TABLE 11.8-2 Estimated Decommissioning and Tails Disposition Costs & Duration Cost ($ MM, Time Activity 1996 $s)
(Yrs)
Characterize CEC facility / site
$ 0.22 0.50 NRC Staff review of facility / site 0.05 0.33 characterization Develop and submit to NRC detailed 0.22 0.50 (c) decommissioning plan NRC Staff review and approval of 0.05 0.33 decommissioning plan Idle time between cessation of operations 1.00 0.50 and start of decommissioning activities.
Decontamination Facility Installation, System Cleaning, Dismantling, 23.10 4.00 Decontamination Decontamination / Decommissioning of Decontamination Facility 1.90 (a)
Sale / Salvage 0.00 (a) i Radioactive Waste Disposal 1.40 (a)
Hazardous / Mixed Waste Disposal 0.10 (a)
Tails Disposition (b) 485.3 (a)
LES Final Radiation Survey and NRC Confirmatory Survey 1.50 1.25 Contingency 3.50 N/A TOTALS
$ 518.34
=7 For related information, reference also the decommissioning funding plan contained in the CEC License Application.
(a) To be performed along with dismantling and decontamination.
(b) Tails disposal costs are estimated to be $16.175 million per year of tails production.
1 (c) Four months overlaps with NRC review of characterization.
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Figure 1 Estimated Decommissioning Schedule O (years) 1 2
3 4
5 6
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i a) Characterizefacility and site - 6 months.
b) NRC staf review offacility and site characterization - 4 months.
c) Generate detailed decommissioning plan - 6 months.
d) NRC staf review and appmval of the decommissioning plan - 4 months.
c) idle time betuten cessation ofoperations and start ofdecommissioning activities (eJ, and time beturen confinnation sunty and tennination ofdecommissioning activities (e,) - 6 months overall addition.
f) Install decontaminationfacility, system cleaning, dismantlement, decontamination, waste disposal - 4 years.
_ g) Final radiation sunty and NRC confinnatory sunty - 1.25 years.
h) Tennination ofdecommissioning activities.
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