ML20108F566

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Report on Financial Assurance Status
ML20108F566
Person / Time
Site: 07200011
Issue date: 03/31/2020
From: Gacke B
Sacramento Municipal Utility District (SMUD)
To: William Allen
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DPG 20-047
Download: ML20108F566 (21)
v • d • e


Text

~* ; . "

Powering forward. Together.

  • SMUD March 31 , 2020

. DPG 20-047 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555 Docket No. 72-11 Rancho Seco Spent Fuel Storage Installation Renewed License No. SNM-2510 RANCHO SECO REPORT ON FINANCIAL ASSURANCE STATUS Attention: William Allen As required by 10 CFR 72.30(c) and 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 CF.R 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 Part 72.

Decommissioning Financial Assurance Method and Trust Fund Status An "External Sinking Decommissioning Trust Fund" continues to be maintained by Wells l Fargo Bank on behalf of SMUD.Per the Financial Assurance Plan, SMUD made MOP contributions to the Trust Fund through 2008, at which time it was considered to be fully 1

  • * ~~552~

µ/Jr ss Rancho Seco Nuclear Generating Station I 14440 Twin Cities Road I Herald, CA 95638-9799 I 916.452.3211 I smud.org

DPG 20-047 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 Fund The trust fund holdings were reviewed in January 2020, and the trust fund contained

$8.77 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 2019 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 January 31, 2020, the available funds in the Decommissioning Trust Fund were

$8.77 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 $8.77 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 beihg reported. As the base assumptions' used in the development and subsequent updates of the cost basis for decommissioning the ISFSI remain unchanged, this 2019 update consists of only an inflationary adjustment.

DPG 20-047 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 trust fund.

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 Brad.Gacke@smud.org or by phone at (916) 732-4812.

Sincerely, Brad Gacke Manager, Rancho Seco Assets : DPG 20-46, 2019 Rancho Seco ISFSI Decommissioning Cost Estimate Cc: NRC, Region IV (w/Attachment)

RIC: 1F,099

DPG 20-047 Page 4 of 4 ATTACHMENT 1 2019 DECOMMISSIONING COST ESTIMATE RANCHO SEGO ISFSI DECOMMISSIONING .* *.*. - . -

~

~. .

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201 9 DE..COMMISSIONING COST ESTIMATE..

RANCHO SECO ISFSI DECOMMISSIONING

Page ii of iii APPROVALS Prepared by:

Manager, Rancho Seco Assets (outgoing) d>~-*

Dan A. '.Fman * **

Approv~d by:

Manager, Rancho Seco Assets

  • Brad Gacke On the cover: ISFSI - regulated by Part 72 License

Page iii of iii TABLE OF CONTENTS PAGE Approvals ................................................................................................................ 11 Summary ..............................................................................................................:.***1 B*ackground ................*..... :: ........................................... ,.,'.... ,....,; .... ;:.. ,~ ... ,.._.... ,..:,**"*i, ..-...,.*........ 2.

Introduction .............................................................................................................. 4 Financial Assurance for ISFSI Decommissioning ...................................... :.:: .. :.4 Methodology and Approach*.................................................................................... 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 Internal Components .................................................................. 8 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

DPG20:046 Page 1 of i4 2019 DECOMMISSIONING ~OST ESTIMATE SU+\'fMARY.

The Rancho Sec_o 10 CFR Part 50 lic~nse was terminated by the NRC effective August 31, 20t8; th¢r~f()re;,1~p :fu~hir <l~comrfiissioning costs are anticipated fot the Part 50 .

licens~~d no further reportirig*ofthe associated costs will b~ made.**

  • The.projected cost to.cqmpiete the decortnµissioning of the Rancho Seco Nuclear Station Independent* Spent Fuel Storage Instaiiatioh (ISFSI) is $5.6 million. This *1ncludes all projected costs to terminate the 10 CFR Part 72 license.

. *: ,., . .. ' . .'  ; ' . . . ; . . .: - . .  : . ' ~ ' . \- . .

Decomm_issioni11g activities related to the ISFSI include the transfer of the' u~ed nuclear fuel and Greater Than.Class "C',. (GTCC) radioactive waste to th~ Depai-bnenfofEnergy (DQE) 1~ ~O?) 1.fbllowed by decpll1missioning and license termination activiHes * .

necessary 'fo d~rrioristrate compliance with the facility release standards in l'O CFR. 20 for the Part 72 licensed area. . - . .*. . '* . . . . . '

Sine~ 2009, used fuel mimagemerit costs are considered a normal operation and maintenance (O&M) expense, recoverable from the DOE, and are not included in the Decommissioning Cost..**Estimate.

'* :. ~

.*.)." .-. .l .

~ ..... *. '

1 Based on the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste", January 2013.

DPG20-046 Page 2of 14 BACKGROUND

. .  : K 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 ofland that is owned by the Sacramento Municipal Utility District (SMUD). The original nuclear station within the IA was comprised of a single B&W-designed generation unit with support facilities.

Rancho. Seco comnien~ed rea6tor ope.rations.Qn-Septe~ber 16, 1:~74:and*b~g~ . '.' '

commerd.ai operation April *18, 1975. SMUD,pei:manently teimiriated operations* at

  • Rancho Seco on June 7, 1989 following passage 'of a*public referendum }i.me 6, 'i 989.

The reactor was completely_defueled on December 8, 1989 and_a Posse~sion Only License, along with Permanently Defueled Technical *specitic~tions, became effective '

A ril28; 1992. . . . '  : .. * .. ,

p . ' ' - ...

  • .** , ** J *.

On May 20, 1.991, SMUD submitted a proposed Decommissioning Plan to the NRC that outiinedth~ .4ecoinmissioniJ.Jg option of Hardened SAFSTOR This altematiye put the ..

fuel in dry:-_stqrage and placed the plant in a safe, dorrp.~t condition with a small site ., . '

maintenanc*e staff until 2008 when* a Decommissioning Operations Corifractor would be '

brought ii.1 to complete decommissioning. This allowed for the Deco~J~~ioning Tnisl Fund to be fully funded before dismantlement began. The NRC issued*'a ..

decommissioning order and approved the Rancho Seco decommissioning funding plan on March 20~ 1995. - * * * * '* *

  • Beginning in 1995, TLG Services, Inc. (TLG) provided SMUT.) with altern~tive ~ost 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.

DPG 20-046 Page 3of 14 In the interim, the NRC issued SMUD a specific license for fuel storage in the Independent Spent Fuel Storage Installatiop. (ISFSI) under Part 72 in June of 2000.

Transfer of all nuclear fuel to dry storage in the ISFSI wµ.s completed August 22, 2002.

With the closure of the Barnwell, S.C. waste disposal facility, there were 0

no options for disposition.of Class B'and Class C LLRW avaiiable to SMUD begiiining in 2008. The

,Class B and *class C LLRW was stored in the IOSBuntil the Waste Control Specialists, Inc. (WCS) facility in Andrews, Texas was deemed by SMUD as a suitable facility for disposafofthe'material. Shipping of the* stored waste was'completed in November 2014.

Phase II decommissioning of the IOSB and surrounding land ~as completed in 2016 and the NRC terminated the 10 CFR 50 license effective August 31, 2018 .

A~*a precutsor:to the decommissioning of the ISFSI, the esfo::nated date for DOE acceptance* of th~* used nuclear fuel and OTCC 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 2Q12 report by the Bh1e-Ribbon Commission on America's Nuclear Future still provides the best available published information on the potential for DOE to take possession of the material stored at the ISFSI. ~MUD recognizefthat the scheliule pfovided within the DOE report has been severely' _

compromised by 'the ::failtire of Congress. to pass the necessary enabling legislation, however; considedng that theDecommissioning Trust Fund is fully funded, and SMUD is notrelyirig'qn increases in trust fund value through investmenfgrowth to ensure available funds for decommissioning; the uncertainty in the schedule for used fuel removardoes nofimpact'SMlJD's ability to fund ail decommissioning activities.

With the continued failure of congress to pass the required enabling legislation, a.;llowing tlieDO:E to ineetits' conttacttiai obligations~ SMDD subtnitteci a license.renewal

  • application for the ISFSI on March*19, 2018 pursuant to to CFR 72.42(a) (Agehcywide Document~ Access ~d Management System (ADAMS) Accession No. MLl81QlA024).

O,n March 9; 2020~ t_he NRC'approve~fthe renewal of SNM-2510 through Jillie '30; 2060 (Agericywide :Uo~funents Access and Management System (ADAMS) Accessitjri No ..

ML20065N277). ' . .*

  • L ' ,: .  :*

DPG20-046 Pag~ 4of J4 INTRODUCTION This decommissioning cost es_timate i~ prepared to sati~fy the requireITients 'of Title 10, ~f the Code of Federal Regulatiop.s, Part 72.30. As.the base assumptions use4 ,n the

  • of development and subsequent lipdates tlie cost basis for decommissioning th~ ISFSI .

remain unchanged,' t~is *2019 updat~ co~sists .of, only <l:Il inflationary adjµstment.*

  • This Estimate i,ncludes all ISFSt deco:mmissioning co~ts, .The *current cqst es}imate for decommissioning R8:1:icho Sec_o* is $5 ,? million... . . . . . . .. . , _* ... _*, _: .. , *..

'  : *,/

Financial assurance for ISFSI decommissioning.has been required since December 2013.*

This cost estimate carries forward the information necessary to allo.:w compliance with tp.~

regulationsin,JO CFR72.30 which is being updated in this report in a~wrµance with __ .

those regulatfqns1, . . . .. . *: *. *' . : . * * . . . . ' , : <, '. *_ -~: .

Fin~cial 4ssurance for ISFSi Decommissioning

  • _

SMUD fuii; ~ded the Part 50 DecommissioningTru~t Fund by.m:aking th~J~st: ,

contribution in 2008. However, because of the level-of_u,ncertainty jnherent in power: ..

reactor decommissioning, the amount of funding provided w~s conservative. When.the *.

decommissioning and license. termination ~f th~ 10 Part 5Cfliceru;;e was completed in.. . .

2018 enough funds remained to assure *ava1lable funding for the Part 72 ~SFSI : _* .*

decommissioning .. Tlierefo~e,110 additioncil contrib~tipns to the Trust F\uid' are cµrrently _

planned. *. * * * * * * * * * * * **

  • 10 CFR 72)Q ~oritainsspecific.requirements fqr.docuqi~niirig.the fjnanci~i'assmance for.

ISFSI decqIP111issioning. These specifics are addres~ed_'here:.... . . . . . *. *. . . . ,.

I , . * , * * .. * .* ' .. ..,_ -~: (,

72.30(b)(J) ;equires documentatio~ of°how funds.wili b_e:prb~i~ed: Thi(Trust,Fund initialiy.,estaplished for Part 50 Decommissipning ;was o'ver:-fun.ded.. Thi remaining funds will be m:aintained 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.

DPGJJ0-046 Page 5 of 14 72.30(b)(2)(ii) requires ari. adequate contingency factor: A factor of 15% is used. This is sufficient to account for project wicertainties and demonstrates compliance with this requirement. Contingency is provided to account for uncertainties in the decommissioning process. Given that detailed information exists documenting the radiological conditions of the facility, and the robust 11ature of the sealed fuel storage systems, there is little radiological unc~rtainty regarding the condition of the facility and 15%provides a ~~fficientmcirgih. * * * . . .*. *. ,* . ..

  • 72.30(b)(2)(i1i) ~eqtiires iriclusf'6n of the cost ofineeting the r~diofogical*criteria for licens¢ term1.nat1~n contained in 10 CFR 20: Those activities are specifically included in this cosf *esti.tnat~ demonstrating compliance with this requirement.

72.30(b)(3) requires identification and justification of the key assumptions used in the cost estimate: That il'.!formation is specifically included later in this docmpent, demonstrating compliance' with this. requirement. . . '

72.30(b)(4) requll'es a :description of assuring funds for' decommissioning'a'.iid' ti. inearis for adjusting the cosf estimate perfodfoaily over the life of the facility: The funds for .

decoiinrussioning were already contained in* a Decommissioning Trust Fund sef aside for Part 5 0 license termination.. 72. 3 0(c) requires that the decommissioning funding plan be resubmitted at intervals not to exceed 3 years. In 2014 through 2018 updated plans were submitted annually, reflecting the updated schedule for Part 50 decommissioning. As required pursuant to 72.3'0(c),the Rancho S~co Independent'Spent Fuel Storage Installation decommissioriing'.fiinding plan was res_ubmitted with the license renewal application. As* none of the paseline assumptions for decommissimiing and ficerise * .

termination costs of the Rancho Seed 1SF~I *hav~ *changed, this 2019 update cdrisists of only an inflationary ac;ljustment. of the-201' 8 update, and the financial iristiumerit Used to demonstrat.e assutan~~- wljh 72.3 0(e}°will continue to be the existing Trust *Fiin& ..

72.3 ()(b )( 5) requirei foformatfofr ~egarding the*:subsurface residual*radioactiv'ity that will require remediation to meet the radiological criteria for license termination: No' removal of subsurface materials-will be, required to meet the radiological release _criteric:1...: The radiological condition of the land area 0f the ISFSI was evaluated prior to construction and no residual radioacfrvity* was evident.. :Given that the material in storage,atthe facility resides.inr9bust, sealed containers and there is no reasonable design:basis- ,

accident that .can o~cur to cause faillll:'.e of the containers, there is no*reasqnable Hkelih,ooq.

that the stored radioactiye,materials will*enter the environment. Detailed radiological surveys conducted, during the process of moving the fuel. from wet to dry storage ...

document that no contamination of the areaoccurred during operations. In addition,- .

radiological* surveys conducted during occup~tion of the FTESB and perio<;l.ically. s_ince have detected no detectable contamination of the structure or pad. With no creqible method ofintroducing radioactive materials ip.to the land within the ISFSI facility, there is no reasonable expectation that subsurface,materials will require remediation. This.

documents compliance with the requirement.

DPG20.-046 Page 6of 14 72.30(b)(6) requireS, certification that financial assurance for decommissioning be provided: Compliance with this requirement was. satisfied by a separate letter: RANCHO SECO REPORT ON FINANCiAL ASSURANCE STATUS, DPG 20-47, dated March 31,2020 . -

As discussed previo~sly, SMUD. fully funded the Part.50Decommi~sioning Tmst Fund by ni.aking the last contribution in 200s. However, b*ecaus~-,ofthe leveJ of uncertainty

  • inherent in power reactor decommissioning, the amount of funding provided was
  • conservative. With t:he Part 50 decommissioning and lice,nsy termin~tion ..i;ictivities. now ..

complete, an. excess of available funds exists in the Decomrriissfomng Trust fund. This excess provides more than enough funds to assure availabfo funding for futur(;": ISFSl ...

decommissioning. Therefore; no-additional co-ntributions to the Trust Fund are currently -

planned.

to 72.30(c) At the time of license renewal and.at intervals not exceed 3 years, the*,* *, ., ..

decommissioning funding plan must be resubmitted with adjustments as necessary to account rw changes in costs and the extent of contamination. If the am9unt qf financial .

assurance .wili be adjusted downward, this cannot be .done .iiniil tq.e updated . . ' -. . . ....

decommissioning funding plan is approved. The deco~issioning ~ding plan.mus( . _: ..

update the information submitted with the original 9r prior approved plan' and iriust ._ ......*

specifically consider the effect of the following events on decommissioning costs: ... :*.

72.30(C)(1) ~pills ofradioactive material producing additional residual radioactivity in onsite subsurface mate!ial: .Section 9.6 of the Rancho Seco IS_FSLFSAR stat~s "Pue fo the zero-:-le.akage design, of the NUHOMS PSCs, Sfy!UD expects no r~sidual. .

contapiinatjqn on t.he ISFSI concrete base pad." Therefore, neithe! liquid spills of* .

substances':-PO.ntaining radioactive 'material, nor' ,those ~~it may com~ in coµtact with .

radioacti~i m~terial are considered credible.atthis stag~ of de'comniis'siblling, 'since.the' ..

remaining radioactive material is* in solid form and not .dispersible. thi;dack of . - .

credibility extends to t;he potential for contamination. of the so~l .in qontact with the ISFSI

  • concrete pact * * * - - -* - . -- .,. - . . . ,;* . . ...

10 CFR 72.3.0(c)(2) facility modifications: As reported to the NRC*ih* SMUD letter * '

"RANCHO.SECO BIENNIAL REPORTldated foly 14,-2016(ADAMS,Accession:No, *,

ML 16208Al09), SMUD installed*a 400 square foot Fuel Transfer Equipment Storage Building{FTESB) within the Part 72 licensed boundary. This structure, external to the**_,:

ISFSI-pad; provides environmentally sheltered storage for fuel haridling equipment . -:

contaminated with licensed radioactive material. This contamination is.either fixed (as :in -.*

the case of the MP-187 Transfer Cask) or containerized to*preclude its spread*while in storage. SMUD anticipates a maximum of 27 final status survey units to demonstrate ,

satisfaction ofthe release criteria contained in 10 CFR 20. As-contamination of this new:

structure is not anticipated, an additional Cfass 3 survey unit for the ESB interior and exterior would be added. As the survey design,criteria for Class Jsurvey units are of minimal, the impact oh the overall cost decommissioning 'the ISFSI would be

  • insignificant.

-~~--

DPG 20-046 Page 7of 14 10 *cFR72.30(c) (3) changes in authorized possession limits: SMUD completed the transfer of all SNF and GTCC waste to the ISFSI in 2006. SNM-2510, Amendment 4 (11/24/2017) provided for the storage of a *200 µCi Sr-90 byproduct material source for use as a.check source fqr radiological detection equipment identified within SMUD's Radiation Protectfon arid Emergency Pr~paredness Plans. This is a change to the authorized possession limlts *since the approval of the ISFSI Decommissioning Funding

  • Plan. The impact on the overall cost of decommissioning the ISFSI resulting from this
  • increase will be insignificant.

10 CFR 72.30(c) (4) actual remediation costs that exceed the previous cost estimate:

SMUD will not begin to-decorhmiss~on*the. Rancho Seco ISFSI until after the U.S.

Department ofEnergy takes possession of the spent fuel and GTCCwaste. Therefore,.

there have been no actual remediation costs that exceed previous cost estimates.

METHODOLOGY AND APPROACH Ovtb~iew of Deco1111111.ssioning Co'st E~timate Components*

The cost estimate provides an overall cost for the duration of the ISFSI decommissioning project. This includes all cost~ in~urred after removal of the spent nuclear fuel and GTCC waste_ through the Part 72 license termination.

Staff costs include the cost for contract staff to perform the Final Status Surveys. and remaining license termination activities of the ISFSI. **

Miscellaneous'costs:hive been iriciuded\o clo~~ent the support costs thatare _:.* -

spedfi.cally id~hti:fied fdr.thedtiration of thb.ISFSI decommissioning projeci'.':tfiese costs also indlude material costs foi deccnmnissioning. . .. . .. '

-., * . *. ,* ; '-~ . . . :~- 0*1*:*' !, :*. - ** :~ * ** * ~*.:?; .~*,._.

  • FINANCIAL COMPONENTS OF tiIEcosT MODEL
..:*._'J The decommissioning cost estimate in total is defined as the funding requireu*t~'complete decommissioning ~hr.ough lic~ns,e termination. Historically, the estimate co.nsisti:::d of a large number of calculated costs based on cost factors, and the cost 'assigned:ic) :a given iine item within the*estimat~_-was.-notas rigorously defend~d as the.total. Ah1si.c*. -

assumpti~n of the estimating process ha~ been that when specific line it~ms .have.been over-estimated, the. un~pent-funds will b~ required to cover the costs associat~c,fwith other line items that have been under-estimated. The historical costs for the Part 50 . -'

decommissioning reflect that the cost of the work ~oinpleted was, in general, over-*

estimated and similar assumptions are anticipated to be applicable to the !SF.SI decommissioning process.

Examples ofremaining 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 beer1 defined by TLG in previous. estimates under the term, "financialrisk". To_ date, financial risk has not been specifically .,

DPG20-046 Page 8of 14 addressed within any Rancho Seco*decommissioning cos.t estimate. Outside of the scope_

of the cost estimate itself, staff deals with these uncertainties on a project-by-project '.

basis. An overall risk assessment taking into account any 'anticipated :risk facfor would typically be addressed thrqugh a probability analysis, perhaps utilizing a Monte. Carlo- .

type probability si_niulation. Such.a detailed risk analysis is cpnsidered to be OlJtside oK the scope_ of the decorru.n,issiqning cost estimate~ :However, *contingency is iµcluded as. a component .of t4e estimate. . .. . '. .

ASSUMPTIONS The followi_ng are the assumptions used in developing the*'Rancho Secq ISFSI cost .**

estimate. Some assumptions are generic.innature, and some,are specific.to.the Rancher,

  • Seco site.
  • Used Fuel
1. The cost to remove and dispose ofthe us~d.fµel fr:om_the site is notrefJ.egtedwitWn_.*

the estimate to decommission Rancho Seco. The Nuciear Waste Policy-Act assigns this responsibility to the DOE's Waste Management Systelll. .... , ..... -

  • ." 1'
2. The ISFSI will remain operational under.the 10 CFR 72 _license until__the DOE take,s possession of, or accepts responsibility for, the fuel and GTCC waste. The cost for maintenance of the ISFSI is considered O&M and is_p.oUncluded in this cost estimate.
3. DOE i;icceptance of the fuel and G TCC waste in 2qi 1. This will be reviewed for each subs~quent estimate as there is currently gre,at uncertainty ~ith the_ a~cept,ance date*. **Note'that the actual date offuel acceptanc:e. is C\lfl"~ntJy.119t.:a.facto:r.*in ' *-**.. -.. :.

demonstrating financial assurance because the decornrilissioi;_ing ~~sts are fully ': \

funded and do not rely on a returp Ol) investments, p~~tti~s:-..

ISFSI Decommissioning_

1. or No remediation wiil be required for ~y structures land. areas at the ISFSI. *
  • Evalhatfon {:>fR~ference 4 indicates that activation:of niaterials'at the ISFSl will not result in contamination that require~ remediation. N 6 °loose coiitainiiiatfon: at th6 * *. :
  • ISFS'i 'was measured during the fuel movement activities in:2000 through*2Q02,' ahd

. :fu~l danister leakage is beyond the ISFSI design basis.* No* surface contamination has beeii detected; nor is anticipated, at the FTESB': * * * '

Reactor Vessel Internal Components

1. 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 upon industry-accepted assumptions regarding

DPG20-046 Page 9of 14 DOE schedules. Industry assumptions for the acceptance criteria are modeled on the packaging for the used nudear fuel: the GTCC is stored in a canister with the same 9uter.geometry _as the used fuel canisters. -

2. The cost for transfer and disposal of the GTCC material is not included in this cost estimate. Legal opini9ns and court decisions indicate that the GJ:CC disposal is the

. responsipiljtyof th~ DO~. , ' - , . . - -

Tran-sp.orta'.t1on Methods

1. Contaminated materials resulting from any remaining decommissioning activities will.qualify under Title 49*ofthe Code of Federal Regulations Part 173 as LSA-I, -

II, or -III, or SCO-I or -IL

2. _* Ttansportatioh of Class A LLRW is by truck or rail to EnergyS0luti9ns iri Clive, ut or Radioactive Waste Processing Facilities appropriately*licensed and'approved bySMUD.

Low-Level Radioactive Waste Disposal L- The-amount ofthe LLRW generateddtiring decommissioning will be minimal bas~d on the absence of contamination present. Future disposal rates for Class A waste used iihhe estimate are based upon historical rates and disposal cost escalation factors listed in NUREG-13 07, Revision 17.

Estima~~ng Basis

1. Future deconunissioning 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 estim~te...... *
2. Remaining costs are based upon an *estimate of the remaining ~ctivities including contract staff to perform tp.e activities. and other costs such as waste disposal.
  • ., 5 I Labor Costs
1. The craft labor required to_complete decommissioning is obtained through standard SMUD cCJntracting practices ..
2. Future activities _such* as waste shipments and license termination activities will be performed 'by contracted staff..* * * * *
3. Engineering services for such items as writing activity specifications, detailed procedures, and work procedures are assumed to be performed by contracted 'staff.

DPG20-046 Page.

10 of.14.

General

1. The approximately 14-acre ISFSI remains ~der the Pait 72 license. Following transfer of the used fuel and GTCC materiai'to the DOE/a decommissioning project will commence to te~inate this license.
2. . NRC oversight of the-decommissioriing p~oce*ss is ~stimated bas¢d _on previous license termination activities. The amount of oversight effort is proportioned *based on the number of Survey Units for license termination as a reason<,lble basis for the .

estimate. .. _r*.~ : **- ... **.**

3. Equipment costs fm.use during decommissioning are* included asMisc~Haneous Costs. * * ** ** * * * ** ** * * *
4. Demonstratiop. of compliance with the radiologicµ.l criteria for license tern;iination oftlie:,Part72 facilities will require documentation ofno more tl;ian 27. Survey Units' as foll~ws'; - . . . . , . . . ' ' . *'

!l Units. Description, Location . Classification

22. HSMs . ISF,SI . Class 1 1 Concrete Pad. ISFSI Class 2 I

1 Concrete Apron ISFSI '.: * *Class3' I

  • *t { 1~ .* 1 LandArea *  :  ;. \*

I ~.* *

.*fsps1**** Class 3 Equipment Storage Building

"-.. : ~ t :

1 Interior

~-\

ISFSI Class 3

,
  • J Equipment Storage Building 1 Exterior ISFSI Class 3
5. Equipment such as administrative equipment (desks, thairs, :etc.), forklifts, trucks, other 111obile equipment and items of personal property owned by SMUD wUI be easily* removed without the use of special equipment~t no co'st 'or credit tp tlie project. *
6. Th~ decommis;ioning activitie's are performed in, a~cordance with applicabl~

regulations.

DPG20-046 Page 11 of 14

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.
.  :-~ .

DPG20-046 Page 12 of.14 GLOSSARY OF ACRONYMS AND ABBREVIATIONS

1. ALA.RA: A~ Low As Reasonably_Achievable
2. Barnwell: The Barnwell, SC LLRW Disposal Facility
3. DOE: Department of Energy
4. 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

5. GTCC: Greater Than Class "C" Waste - disposal of this waste is the responsibility of the DOE
6. IOSB: Interim Onsite Storage Building
7. ISFSI: Independent Spent Fuel Storage Installation
8. LLRW: Low Level Radioactive Waste
9. 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 SO-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. WCS: Waste Control Specialist, Inc. - operates the LLRW disposal facility being constructed in Andrews, TX

DPG20-046 Page 13 of 14 REFERENCES

1. "2016 Decommissioning Cost Estimate for the* Rancho Seep Nuclear Generating Station", March 23, 2017 ! . *
2. Letter to NRC, "Rancho Seco Report on Decmfunissioning'Funding Status",

March 22, 2017 ,:, ,:

3. Rancho Seco Part 72 License Termination cost basis, TtG Services, Inc "Independent Spent Fuel Storage Installation Decommissioning" Cost Summary, 2003; ARO Response to Data Request and AssU)Ilptions, Attachment S 11-1481-mm ~ .
4. SMUD Engineering CaicJlation #Z-XXX-N0057, Revisio~ 1, October 4, 1993, "Neutron Activation of a Pacific Nuclear NUHOMS"
5. "Strategy,.f.orthe Managerµent and Disposalof!Used Nucle~ Fuel and High-Level Radioact~ye Waste", Dep~ment of Energy, Jaiiu~ 2013 .
6. "Report to th~ Secretary of Energy", Blue Ribbon Commission on America's Nuclear Futute, January 2b12 f,' *-*. t::J I .

I.

Rancho Seco Nucl<<lr Gmerating Station DPG 20-046 Area Baud Decom1ttinioning Cost &timate Pa#l4 o/ 14 Table 1 Decommissioning Cost E~imat*

{Thouunds of 2019 Dollars)

COSTS BY ACTIVITY COSTS BY YEAR Waite Dlsoosal  %

DESC SHIP BURY STAfF MISC CNTGCY CNTGCY TOTAL 2019 2021 2028 TOTAL ucenH T8fflWlalion AcMbn Pat 72 license lllfflllllallllrl 2 33 3 308 1490 725 15% S 558 0 0 5.558 §558

'TOTAL COST /OCE 2019) 2 33 3.308 1.490 725 15% 5.558 0 0 5.558 5,558 Total Decommi..lonlng Coat

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