ML20057F569
| ML20057F569 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 10/14/1993 |
| From: | LOUISIANA ENERGY SERVICES |
| To: | |
| Shared Package | |
| ML20057F563 | List: |
| References | |
| NUDOCS 9310180196 | |
| Download: ML20057F569 (13) | |
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Page 1 of 1 Louisiana Energy Services License Application Push-Pull Instructions Revision 7, October 14, 1993 Remove Insert i
" List of Effective Pages"
" List Of Effective Pages"
- pages 1-2
- pages 1-2
" Exhibit I"
" Exhibit I"
- Title Page
- Title Page
- pages 1-10
- pages 1-9 I
Notes:
1)
Each page affected by this revision has the month and year of the revision printed in the lower right hand corner of the page.
2)
All changes or additions to text of each document are indicated by a sidebar ( l ) in the right hand margin.
In the case of deletion of text, the sidebar appears in the right hand margin with a perpendicular line towards the text ( f ) indicating where material was deleted.
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LOLTISIANA ENERGY SERVICES
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APPLICATION FOR-LICENSES Y
LIST OF EFFECTIVE PAGES Pace / Table / Figure Number
- Revision Number Date of Revision APPLICATION FOR LICENSE -
p1 6, 07/30/93 p2 6, 07/30/93 p3 6, 07/30/93 p4 6, 07/30/93 p5 6, 07/30/93 p6 6, 07/30/93 p7 6, 07/30/93 J
p8 6, 07/30/93 AFFIRMATION 0, 01/29/91 SEAL 0, 01/29//91 EXHIBIT 1 p EX 1-1 7, 10/12/93 p EX 1-2 7, 10/12/93 p EX 1-3 7, 10/12/93 p EX 1-3 7, 10/12/93 p EX 1-4 7, 10/12/93 p EX 1-5 7, 10/12/93 i
p EX 1-6 7, 10/12/93 p EX 1-7 7, 10/12/93 p EX 1-8
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p EX 1-9 7, 10/12/93 EXHIBIT 1 ATTACHMENT A p A-1 1, 03/31/92 p A-2 1, 03/31/92 p A-3 1, 03/31/92 p A-4 1, 03/31/92 p A-5 1, 03/31/92 p A-6 1, 03/31/92 p A-7 1, 03/31/92 p A-8 1, 03/31/92 Louisiana Energy Services Page 1 of 2 October 1993
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License Application Revision 7
LOLTISIANA ENERGY SERVICES
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APPLICATION FOR LICENSES V;
LIST OF EFFECTIVE PAGES EXHIBIT 1 ATTACHMENT B p B-1 1, 03/31/92 p B-2 1, 03/31/92 i
p B-3 1, 03/31/92 p B-4 1, 03/31/92 EXHIBIT 1 ATTACHMENT C p C-1 1, 03/31/92 p C-2 1, 03/31/92 p C-3 1, 03/31/92 p C-4 1, 03/31/92 i
p C-5 1, 03/31/92 p C-6 1, 03/31/92 p C-7 1, 03/31/92 p C-8 1, 03/31/92
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Louisiana Energy Services Page 2 of 2 October 1993 License Application Revision 7
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-1 EXHIBIT I TO APPLICATION OF i
5 LOUISIANA ENERGY SERVICES i
I Decommissioning Funding Plan
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LOUISIANA ENERGY SERVICES CLAIBORNE ENRICHMENT CENTER
. DECOMMISSIONING FUNDING PLAN
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Introduction:==
Louisiana Energy Services (" Application") hereby submits, pursuant to the provisions of the Atomic Energy Act of 1954, as amended, and the Rules and Regulations of the Nuclear Regulatory Commission,its Decommissioning Funding Plan for the Claibome Enrichment Center. This Decommissioning Funding Plan (" Plan") sets forth that information required by 10 CFR Parts 40 and 70 regarding the Applicant's plans for funding the ultimate decommissioning of the Claiborne Enrichment Center.
As indicated below, Louisiana Energy Services presently intends to provide for decommissioning funding through an external tmst, coupled with a surety bond, in accordance with applicable requirements of 10 CFR Parts 40 and 70. Appropriate model documentation for this funding method is attached hereto. Upon execution of the funding instruments, Louisiana Energy Services will supplement this portion of its application.
General Information:
Facility
Description:
Louisiana Energy Services, a Delaware limited partnership, was formed to provide uranium enrichment services for comniercial nuclear power plants for the purpose of generating electricity. These services are proposed to be provided at a facility to be known as the "Claiborne Enrichment Center," located in Claiborne Parish, Louisiana.'
i Licensed Material: The Application for the Claiborne Enrichment Center seeks authorization to operate that facility to produce uranium enriched up to 5.000 wt% in the U*
isotope.. The facility, when at full capacity, will nominally produce 1,500,000 kilograms of separative work (SWU) per year. The unsealed uranium source material, and the unsealed special nuclear material, will contain uranium isotopes in amounts which exceed 10' times the applicable quantities set forth in Appendix C to 10 CFR Part 20. Accordingly, pursuant to 10 CFR @%40.36(a) and 70.25(a), a Decommissioning Funding Plan is required.2 i
Details regarding the planned operations of the Claibome Enrichment Center may be found in the Application for Licences, and the accompanying Safety Analysis Report and
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Environmental Report.
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2 The panicular isotopes and quantities to be received and processed are described in Section 4.1 of the Safety Analysis Report.
O Louisiana Energy Services EX.1-1 October 1993 License Application Revision 7 T
i Schedule: The projected start-up date for the Claiborne Enrichment Center is
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September,1998. The facility is expected to reach full capacity in December,2000.
l Period of Operation: The Application for Operation seeks authorization to operate i
for a period of thirty years.
l Decommissioning Costs: Louisiana Energy Services has prepared a site-specific decommissioning cost estimate for the ultimate decommissioning of the Claiborne Enrichment Center. This cost estimate utilizes current information regarding the activities and associated costs of decommissioning. Louisiana Energy Services has utilized both existing engineering expertise and actual decommissioning experience, from similar facilities decommissioned by Urenco, Ltd., in Europe, to develop this cost estimate. The estimate and associated funding mechanisms will be adjusted over time, in accordance with the applicable provisions of 10 CFR Parts 40 and 70.
Decommissioning Funding: As set forth in this Plan, Louisiana Energy Services presently intends to utilize an external trust, coupled with a surety bond, to provide reasonable assurance of the availability of decommissioning funds when needed. This funding mechanism is intended to satisfy the provisions of 10 CFR Parts 40 and 70 with respect to i
decommissioning financial assurance for license applicants under those provisions.
Decommissionine Cost Estimate:
Ag Pursuant to 10 CFR ff40.36(d) and 70.25(e), Louisiana Energy Services has evaluated the estimated costs of decommissioning the Claibome Enrichment Center. The facility will be decommissioned such that the site and facilities may be released for unrestricted use. A summary of the estimated costs of decommissioning, arranged by principal activity, is set forth in the table below. The sources of the cost estimate data are also provided below.3 As indicated, the total estimated cost of decommissioning the facility is $518.34 million (S1996). l i
Louisiana Energy Services' evaluation of decommissioning costs included an evaluation of current experience by one of the general partners in the project, Urenco, Ltd., at similar facilities in Europe. Appropriate adjustments have been made to account for cost differences associated with the performance of specific activities in the United States and
'i escalated to S1996.
Facility and Site Characterization S 0.22 million l _
This is based upon Urenco's on-going experience in the decommissioning of gaseous centrifuge enrichment facilities.
3 A detailed description of the activities associated with decommissioning is also set forth in Section 11.8 of the Louisiana Energy Services Claiborne Enrichment Center Safety Analysis Report.
O Louisiana Energy Services EX.I-2 October 1993 License Application Revision 7
NRC Review of Facility and Site Characterization
$ 0.05 million This is based upon the costs incurred to date by the NRC to review the LES license application.
Decommissioning Plan Development
$ 0.22 million This is based upon LES' experience in developing and submitting NRC required information.
NRC Review and Approval of Decommissioning Plan 5 0.05 million This is based upon the costs incurred to date by the NRC to review the LES license application.
Idle Time Before Decommissioning
$ 1.0 million This is based on a 6-month delay between cessation of operations and start of-decommissioning activities.
Decontamination Facility Installation System Cleaning Dismantling Decontamination S 23.1 million This is based upon over ten year's of Urenco experience decommissioning two pilot umnium enrichment centrifuge facilities at the Almelo enrichment facility in the Netherlands.
Decontamination / Decommissioning of Decontamination Facility S 1.9 million This is based upon the size of the decontamination facility and an independent estimate provided by Naylor Industrial Services, Inc., transmitted by letter dated September 11,1990.
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Louisiana Energy Services EX.1-3 October 1993 License Application Revision 7 a
-f Radioactive Waste Disposal S 1.4 million O
1 This assumes 100 m' @ S350 per ft), in 1992 dollars, escalated to 1996 dollars.
This cost of disposal is estimated specifically for radioactive waste disposal in
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the Central States Compact. (References 5 and 6) l 3
(The Urenco estimate of 200 m of low-level waste in the cited reference was l
reduced by half due to a closer look at solid arisings from the decontamination j
process. A facsimile from Urenco's Almelo facility,23 August,1990, provides 1
an estimate of 2 m' of " citric cake" arisings. This " citric cake" was considered in the Urenco cost estimate as a major portion of the low-level solid wastes -
from decommissioning; thus, it was concluded the estimate of 200 m' was
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high.)
l Hazardous / Mixed Waste Disposal 5 0.1 million l
l Decontamination and decommissioning processes, as described in this section, j
do not result in the production of hazardous or mixed wastes for disposal.
Normal accumulation of hazardous and mixed wastes will occur during the l
final months of CEC operation. The volume of these final wastes, not due to D&D activities, are estimated to be approximately equivalent to the annual amounts listed in the CEC Safety Analysis Report, Table 7.1-1.
l Tails Disposal
$485.3 million The annual tails disposal cost is estimated to be $16.175 million. This is multiplied by 30 years to arrive at the $485.3 million figure. Costs are based on converting UF. to U 0, with subsequent disposal in a facility under j
3 cognizance of the NRC. U 0, conversion costs are based on estimates by a l
3 vendor which could make this service available to LES. Disposal costs are based on NRC recommendations and a study by Martin Marietta. The conversion and disposal costs are added and escalated to 1996 dollars.
The disposition of tails from the CEC, including potential disposition at the end i
of facility operation, is an element of authorized normal operating activities. It involves neither decommissioning waste nor is it a part of decommissioning j
activities. The disposal of these tails is analogous to the disposal of radioactive j
materials generated in the course of normal operations (even including spent j
fuel in the case of a power reactor), which is authorized by the operating
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license and subject to separate disposition requirements (i.e., requirements such as reflected in 10 CFR Part 20). Such costs are not appropriately included in decommissioning costs (this principle (in the Part 50 context) is discussed in Regulatory Guide 1.159, Section 1.4.2, page 1.159-8). Funher, the " tails" products from the CEC are not mill tailings, as regulated pursuant to the Uranium Mill Tailings Radiation Control Act, as amended (42 USC 7901, et O
Inuisiana Energy Services EX.1-4 October 1993 License Application Revision 7
seq) and 10 CFR Part 40, Appendix A, and are not subject to the financial t
requirements applicable to mill tailings.
Nevertheless, LES intends to provide during facility life for expected tails disposition costs (even assuming ultimate disposal as waste). Funds to cover these costs, estimated at $16.175 million ($1996) per equivalent years of tails' production, will be set aside during the operating life of the CEC.
i Accordingly, tails disposition costs are now explicitly reflected in the funding table (also SAR Table 11.8-2, ER Table 4.4-2), which reflect both decommissioning funding and the separate matter of contingent end-of-life tails disposition fundmg.
Final Radiation Survey S 1.5 million l
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This figure was estimated by two methods, as follows:
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The first method is by extrapolation from " Technology and Cost of Termination Surveys Associated With Decommissioning of Nuclear Facilities, _
NUREG 2241, February,1982. The 1980 costs of decommissioning a fuel e
fabrication facility and a UF6 Production facility were escalated at 5% per year to 1990. The higher of the two costs, (calculated for a 1 mrem and a 5 mrem i
dose to the public), were selected and then averaged, for a total of $750,000.
Further escalation brings the cost to $950,000.
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The second estimate was roughly approximated at S725,000, in 1990 dollars, and is escalated to 1996 dollars. The estimate was based on experience, using the following assumptions:
~ 12,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for grid of property and gamma count
$23,000 for soil sampling 150 core holes for depth profile Building size of 750' x 380' Workhour rate, including per diem, 560/ hour Extensive use of swipes Final analyses and report included Based upon the costs incurred to date to review the LES license application, the cost of the NRC's confinnatory survey of the facility and site following the j
final radiation survey is $0.5 million.
O Louisiana Energy Services EX.I-5 October 1993 License Application Revision 7 v
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Contingency
' S 3.5 million i
O A contingency of 5 3.5 million has been added to the estimate to account for J
unanticipated costs. This is based on the fact that LES will be updating the '
f decommissioning cost estimate it least once every five years. Therefore, a larger contingency is not warranted.
Total Estimate
$ 518.34 million l i
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Louisiana Energy Services EX.1-6 October 1993 License Application Revision 7
Summary of Estimated Decommissioning and Tails Disposition Costs
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Estimated Cost Activity
($MM, $1996)
Characterize CEC facility / site
$ 0.22 NRC Staff review of facility / site characterization 0.05 Develop and submit to NRC detailed decommissioning plan 0.22 NRC Staff review and approval of decommissioning plan 0.05 Idle time before decommissioning 1.00 Decontamination Facility Installation, System Cleaning, Dismantling, Decontamination 23.10 Decontamination / Decommissioning of Decoritamination Facility -
1.90 Sale / Salvage 0.00 Radioactive Waste Disposal 1.40 Hazardous / Mixed Waste Disposal 0.10 Tails Disposition 485.3 LES Final Radiation Survey and NRC Confirmatory Survey 1.50 Contingency 3.50 TOTAL
$ 518.34 Finally, Louisiana Energy Services recognizes the need to adjust cost estimates and funding levels periodically, pursuant to 10 CFR %%40.36(d) and 70.25(e). These measures are described below. Louisiana Energy Services also recognizes that, pursuant to 10 CFR s&40.42(c) (2) (iii) (d) and 70.38 (c) (2) (iii) (d), it must update its detailed cost estimate at the time of license termination and provide, if necessary, additional assurance of the availability of adequate funds for completion of decommissioning.
O Louisiana Energy Services EX.1-7 October 1993 License Application Revision 7
j Decommissioninc Fundine Mechanism:
f Louisiana Energy Services presently intends to utilize an external tmst, coupled with a surety bond, to provide reasonable assurance of decommissioning funding, pursuant to 10 CFR f 640.36(e) (3) and 70.25(f)(3). Accordingly, Louisiana Energy Services provides with this application model documentation related to the use of the external tmst/ surety method of i
providing decommissioning financial assurance.' Upon finalization of the specific funding j
instruments to be utilized, Louisiana Energy Services will supplement 'its application to include the executed documentation. Funher, as indicated by the attached material, Louisiana-i Energy Services intends to provide continuous financial assurance from the time of initial -
licensing to the completion of decommissioning and termination of the license.
J As noted, Louisiana Energy Services presently intends to utilize an external trust coupled with a surety bond to provide financLJ assurance for decommissioning. The trust will be used to collect decommissioning funds over the life of the plant. The surety bond will provide an ultimate guarantee that decommissioning costs will be paid in the event Louisiana Energy Services is unable to meet its decommissioning obligations at the time of j
decommissioning. The trust and surety bond instmments will become effective upon LES receipt of licensed material. A copy of a model tmst agreement and a copy of a model surety.
i bond are provided in Appendices A and B, respectively, to this Plan. Louisiana Energy l
Services describes below the particular attributes it presently anticipates including in the trust.
agreement and surety bond.
i With respect to the trust, Louisiana Energy Services presently intends to provide for the following attributes. First, the tmst fund will be bxternal to Louisiana Energy Services, with fund assets derived from periodic contributions and administered by a trustee. Second, the tmst will be governed by a trust agreement which will provide, among other 4
restrictions, for the distribution of fund assets only upon commencement of deconunissioning
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activities. Further, the trust may retain property with face value, and the tmstee may make j
reasonable pmdent investments, with investment income accruing to the trust.
i With mspect to the Surety Bond, Louisiana Energy Services presently anticipates providing for the following attributes. First, the bond will be issued by a Company which is listed as a qualified surety listed in the Department of Treasury, Circular 570. Second, the bond will be written for a specified term and will be renewable automatically unless the The model documentation is derived from NRC guidance (see NRC Regulatory Guide 3.66, " Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70 and 72" (June 1990).) Louisiana Energy Services will consider this.model documentation as guidance in preparing and -
executing funding instruments for the Claiborne Enrichment Center. In the event Louisiana Energy Services ultimately selects another form of decommissioning funding, model documentation from Regulatory Guide 3.66 will also be used as guidance in the preparation of funding instruments.
Louisiana Energy Services EXJ-8 October 1993 License Application Revision 7
issuer serves notice et least 90 days prior to expiration of an intent not to renew. Such notice i
must be served upon 'he NRC, the trustee of the Standby Trust, and Louisiana Energy.
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- Services. Further, in the event Louisiana Energy Services is ' unable to provide an acceptable replacaent within M days of such notice, the full amount of the bond will be payable j
a t.atomatically, prior to expiration, without proof of forfeiture.
a The Surety Bond will require that any funds paid under its terms will be deposited y
directly into the external trust or, if necessary or sopropriate, a Standby Trust by the surety company. A copy of a mvlel Standby Trur. is provided as Appendix C to this plan.'
i Adiusting Decommissioning Costs and Fundine-
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Pursuant to 10 CFR ((40.36(d) and 70.25(e), Louisiana Energy Services will update j
the decommissioning ccst estimate for the Claiborne Enrichment Center and the associated funding levels over the life of the facility. These updates will take into account changes resulting from inflation or site-specific factors, such as changes in facility conditions or expected decommissioning procedures.
1 Louisiana Energy Services presently anticipates such updating to occur approximately every five years. A record of the updating effon and results will be retained for eview (see i
further discussion regarding recordkeeping, below). The NRC will be notified c: any material changes to the decommissioning cost estimate and associated funding levels (e.g., significant -
increases in costs beyond anticipated inflation). To the extent the underlying instruments are
. y revised to reflect changes in funding levels, the NRC will be notified as appropriate.
Recordkeepine Plans Related to Decommissioning Funding-i i
Pursuant to 10 CFR f $40.36 (f) and 70.25(g), Louisiana Energy Services will keep records until the termination of the license of information that could have a material effect on the ultimate costs of decommissioning. These records will include information regarding: (1)
I spills or other contamination that cause contaminants to remain following contemporaneous cleanup effons, (2) as-built drawings of structures and modifications thereto where radioactive contamination exists (e.g., from the use or storage of such materials), (3) original and modified cost estimates of decommissioning, and (4) original and modified decommissioning funding instruments and supporting documentation.
Louisiana Energy Services will notify the NRC of material changes to the j
decommissioning cost estimates or associated funding mechanisms.
Louisiana Energy Services EXJ-9 October 1993 License Application Revision 7
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