ML23115A172

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Sacramento Municipal Utility District (Smud), Rancho Seco Report on Financial Assurance Status
ML23115A172
Person / Time
Site: 07200011
Issue date: 03/27/2023
From: Gacke B
Sacramento Municipal Utility District (SMUD)
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DPG 23-039
Download: ML23115A172 (1)
v • d • e


Text

March 27, 2023 DPG 23-039 U.S. Nuclear Regulatory Commission A TIN: Document Control 'Desk Washington, DC 20555 Docket No. 72-11 Rancho Seco Spent Fuel Storage Installation Renewed License No. SNM-251 O 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 CFR 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 t~rminated 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 Independent Spent Fuel Storage Installation (ISFSI) lic:;ensed under 10 CFR Part Ti.

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

.* . * . N""s~2t> 1

. N l'Y\ ss Rancho Seco Nuclear Generating Station I 14440 Twin Cities Road J Herald, CA 95638-9799 I 916.452.3211 I smud.org ~~:i~'

DPG 23-039. Page 2 of 4 funded. At this time, no .futur~ contributions are planned: but. SIYIUD will coptinue to.

performDecommissloning Cost Estimates as requked 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 2023, and the trJst fund.contained

$8.98 million. As discussed below, this exceeds:the amountqffunding estimated as.

required to complete decommissioning. lfduring the annual-review th.e. cost to,compJete 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.accordan.cewith the regulation,. the following comparison will be made:

  • Site-specific cost estimate for remainin~ \/vpr~ v~*?urr:rtly ~?ailable,,fu.n9s.

Site-Specific' Decommissioning Cost' Estimate.

  • -**;1> . . ' ' ' *

. l ,, . .

A copy of the 2022 Decommissioning Cost E~tirnate' for Ranchb Seed is included as Attach,ment. 1. The Decommissioning Cost Estirnat~ for Rancho. Seco is $6.5 Mill.ion.

"'". .* *  : I ,. ,- * . - ' -* . .  ;

Certification of Financial Assurance As of December 31, 2022, the available funds in the Decommissioning Trust Fund were

  • $8.98 million,* which exceeds the estimated funding n*eeded to complete dec?mmissioning. ' **

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 $8.98 *million to

  • complete decommissioning at Rancho Seco and terminate the Part 72 license ..
  • Adjustments to Cost Estimate and Trust Fund With the terminatiori of the Rancho Seco Part 50 license (DPR-054) on August 31, 2018, decommissioning costs for only the Rancho Seco ISFSI are being reported:As ..

the base assumptions used in the development and subsequent updates of th~ cost basis for decommissioning the ISFSI remain unchanged, this 2022 update consists of only an inflationary adjustment.

DPG 23-039 Page 3 of4 Assumptions Re,gardirig-Ratelh>f TrlistFUnd: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 cohttactual obligationS'associatedwith SMUB.1s:Financial AssuraFtce Plan or the operation.ofthe decommissioning;trustfuhd: *.

i l Modifications to Financial Assurance Method

  • 1. ~'.. -*:

No modifications have been made since last year's report. Th~ Trust has been fully fundedisince 2008 and remains.in*aR e~emal sinking fund as previously,descr~bed .

  • :**, s"*.,-* ** .. ' : *"* , " :-*;, ~ ., ' - ' .*
  • No material changes to the Trust Fund Agreement have*b-een-made since last year's report. The* Trust remains with Wells ,' I **

Fargo., -*~ l : '

Bar,,k, N.A.

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  • If you or members of your staff haVe qu*estions*or requfre additional information, please contact me by email at Brad.Gacke@smud.org or by pho~e, at (91q) 732-4812.

Sincerely, Brad Gacke * ** *, *. "

  • Manager, Rancho Seco Ass~ts : DPG 23-038, 2022 Rancho Seco ISFSI Decommissioning Cost Estimate Cc:  ; NRC, Region IV twtAttachment)**

RIC: tF'.099 ' '** *' * . ,;.,

2022 DE.COMMISSIONING COST ESTIMATE.

RANCHO SECO ISFSI DECOMMISSIONING DPG 23-038

Page ii of iii APPROVALS

'* Approved by:

-- Manager, Rancho Seco Assets ~ Brad Gacke Date On the cover: Rancho Seco ISFSI - regulated by Part 72 License

Page ii of iii APPROVALS

~

'* Approved by: ,,,

, Manager, Ranclio Seco ,Assets

. Btad Gacke Date*

r '

On the cover: Rancho Seco ISFSI - regulated by Part 72 License

Page iii of iii TABLE OF CONTENTS PAGE Approvals ................................................................................................................ ii Summary .................................................................................................................. l Background ************************************************************************************************************.;*2.

Introduction ......................... ~ ..... *: ...., ..................................*..................,. ********.****'*******:****.*****4*...

.Finc\Ilcia1 Assurance forl_SfSI D~commissioning ............................................. .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 .........................................................................*..................................... l 0 Glossary of Acronyms and Abbreviations ............................................................. 12 References .............................................................................................................. 13 TABLES

1. Decommissioning Cost Estimate ..................................................................... 14

DPG23-038 Page,1of14 2022 DECOMMISSIONING COST ESTIMATE

SUMMARY

The projected cost to complete the decommissioning of the Rancho'SeGo Nuclear Station ,,

IndependentBpentFuel Storage Insta1lat10n (ISFSJ).ts,$6.5 miJlion. Thisindudes*alt....

projected costs. to terminate the 10 CFRPart 72 Jicense.  :, ,. . 1 ,, **

Decommissioning activities related to,the IS:Jt1SI include the transfer of the used nuclear.*

fuel and Greater Than Class "C" (GTCC}radiqactive;w.aste to the Department o{Energy.

(DOE) followed by decommissioning and license termination activities necessary .to *

  • demonstrate compliance with the facility release standards in IO CFR 20 for unrestricted use of thei Part 72Jicensed area.

Since 2009, used fuel management costs* are considered a aorinal operation and-maintenance (O&M) expense, recoverable* from the DOE;* and "are not included in.th~:. :;

Decommissioning Cost Estimate.

t .

DPG23-038 Page 2 of.14*

BACKGROUND Rancho Seco is located approximately 25 miles southeast of Sacramento, California.* The Industrial Area (IA) was 87 acres and sit~.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 commenced*reactor operatfons.on.*September 16, 1974 and began .

commercial operation April 18, 1975-.

  • SJ.\,fUD permanently ceased operation of the*,.*

Rancho Seco reactor on June 7, 1989, following passage of a public referendum June 6, 1989. The reactor-was completely defu.eled on December 8, 1989, and a Possession Only License, along with,Pennanently Defueled*Technical Specifications, became effective April 28, 1992. *. .,, :

On May 20, 1991, SMUD submitted a proposed Decommissioning Plan to the NRC that outlined the decommissioning option of Hardened SAFSTOR. This alternative put the fuel in dry storage*and placed the plant iriasafe, dormant condition with a small site *.

maintenance staff until 2008 when; a Decommissioning Operations Contractor would be brought in to complete decommissioning. This allowed for'the Decommissioning Trust 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 SMUD with alternative cost 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 of Envirocare'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 23-038 Page.Bo£ 14:

In the interim, the NRC issued SMUD a specific license for fuel storage-in.the _

Independent Spent Fuel Storage Installation (ISFSI) under Part 72 in June of 2000.

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

With the closure of the Barnwell; S.C. waste disposal facility; there were no .options for disposition of Class,B arid Class C LLRW: available to SMUD :beginning *in 2008. The Class B and.Class C LLRW was stored in the JOSH until the Waste ControlSpecialists, Inc. (WCS) facility in Andrews, Texas was deemed by SMUD as a suitable facility for disposal ofthe material. Shipping ofthe,stored waste was completed in.November 2014.

Phase II decommissioning of the IOSB and surrounding land was,completed in 2017 and, the NRC terminated the 10 CFR 50 license effective August 31, 2018.

As a precursor to the decommissioning ofthe,JSFSI, the-estimated date for DOE .

acceptance of the used nuclear fuel:and.GTCCwaste,was 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 2012 report by the Blue-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. SMUD recognizes that the schedule provided.within the.DOE report has not been met, however, considering that.the Decommissioning Trust Fund is fully.funded, and SMUDis Iiot ,

relying on increases in trust fund value through investment growth to ensure available .

funds for decommissioning, the uncertainty in the. schedule for used fuel-removal does not impact SMUD's ability to fund all decommissioning activities. ,

With the continued failure of Congress to pass the required enabling legislation allowing the DOE to meet its contractual obligations, SMUD submitted a license renewal application for the ISFSI on March 1-9, 2018;*pursuantto 10 CFR 72.42(a) (Agencywide.

  • Documents Access and Management System{ADAMS)Accession No .. ML18101A024).

On March 9, 2020, the NRC approved the renewal of SNM-2510 through June 30, 2060 (AgencywideDocuments Access and:Management,System(ADAlvj:S) Accession No.'

ML20065N277) .

. r: ',. l ' ,

DPG23-038 Page 4 of 14 INTRODUCTION*,

This decominissionihg cost _estimate, is prepared to satisfy the requirements of Title; 10 of .

the Code ofF ederal Regulations; Pait 72.3 0. *As the base assumptio*ns. used in the development and ,subsequent updates ofthe :cost basis for decommissioning the ISFSI remain unchanged, this 2022-update consists* ofonly an* inflationary adjustment. *. * * *.

This Estimate includes all I'SFSI decommissioning costs. The current cost estimate for .

decommissioning the Rancho Seco ISFSI is $6:5 ,, million.

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

This cost estimate carries forward the infomiation nece*ssary to allow compliance with the regulations in 10 CFR 72.30 which*is being*updated:in this report in accordance with : **

those regulations.

Financial Assurance' for TSFSI Decommissioning* :

SMUD fully funded the Part50 Decomrriissioning Trust'Fund*bymaking,the last.*-*; ,'

contribution ih *2008. However; because ofth:e,level .of.uncertainty inherent'iri power reactor decommissioning, the amountoffunding*ptov:rded was conservative;: When the decommissioning and l:i'cense termination ofthe.10 Part 50 license was-completedin .

2018 enough funds remained to assure available funding for the Part 72 ISFSI * *,

  • decommissioning. Therefore, no additional contributions to the Trust Fund are currently planned. * ,,'.,

10 CPR 72:3 0* contains** specific requirements* for documenting: the financial assmance. for

  • ISFSI decommissioning. *These specifics are)addressed here.

72.30(b)(1 )* requires documentation -of how'funds. will. be, prov.ided:* The ,Trust *Fund initially established for Part 50 Decommissioning was over-funded. The remaining funds will be maintained 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.

DPG23-038* Page 5'of 14, 72.30(b)(2)(ii)requires an adequate contingency factor:. A factor .of 15% is used.; This is**

sufficient to account for projec_t uncertainties.and .demonstrates complianc'e;*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 nature of the sealed fuel storage systems, there is little radiological uncertainty regarding the condition of the facility.and :

  • 15% provides a.sufficient margin.

72.30(b)(2)(iii) requires inclusion of the cost of meeting the radiological.criteria for license termination contained.in 10 CFR20: Those activities .are specifically included in .

this cost estimate demonstrating compliance with.this requirement. , * **

72.30(b)(3) requires identification and justification of the key assumptions used in the cost estimate: That information is specifically included later in this document, demonstrating compliance with this requirement. - , 1 ,*

72.30(b)(4) requires a description of assuring funds for decommissioning and a meaIJ.s for adjusting the cost estimate periodically overthe life of,the facility: The funds for

  • decommissioning were already contained in*aDecommissioning Trust Fund set aside for Part 50 license termination. 72.30(c) requires that:the decommissioning funding plan be resubmitted aUntervals not,to exceed 3 years. In 2014through 2018 updated plans were submitted annually, reflecting the updated schedule for Part 50 decommissioning. As required pursuant to 72.30(c), the Rancho S.ec'o Independent Spent Fuel Storage Installation decommissioning funding plan was.r.esubmitted with the license renewal application. As none of the bas,eline a:ssunu:>tiorts for decommissioning and. license .

termination costs of the Rancho Seco ISFSI have changed, this 2022 update;consists of only an inflationary adjustment of the 20L9update;*and the financial instrument used.to dem0nstrate assurance with 72.30(e) will continue to .be the existing Trust Fund.

72.30(b)(5) requires information regarding the. subsurface*residu3;l-radioactivity that will require remediation to meet the radiological criteria for license termination: No removal .

of subsurface materials will be required to mt:::yt the radiological release criteria. The radiological,ponditiop,: of the land area orilie,_IS1 FSI ~as eyafuateci prior t? co~stru~ti'qn and_no residual r~dioactivity was evident. Giv'en,that the material in storage at the ..

facility resides ~n-robust, s~aled ,contain~r,s ~µ,\~et~; is 'no reasonable design ba~is .

of accident that can occ,ur to ca1J,se failure the containers, there is no reasonab~e likeliho,od that the stored radioactive materials will 'enterthe*e~~irbnment. Detailed radi~logical ' .

suiveys co,riducted. du,ring th~ p~ocess of mo,~irig the* ,fu.el (rom wet to; dry storage . ; '

document that no contamination of the area occurred during operations. In addition, radiologicai.suJ:Veys conducted dur1ng occupation'*of the FTESB and periodically since have detect~d no detectable contamip.ation ofthe'structtire or pad. Witl1.;no'credible .* .,

method ~f introducing radioactive materials info the l~nd within the Is:~sI faciltty, tµer~ ..

is no reasonable expeda,t\on that subsurface materials will require remediation. This .. : .' .

documents compliance with the.requirem~nt.. : '** . '. , .. . ..

.k

DPG23-038 Page 6of14 72.30(b)(6) requires certification that.firrancialassurance for,decommissioning be a

provided: Compliance with this requirement was. satisfied by separate letter: RANCHO .

SECO REPORT ON FINANCIALASSURANCE STATUS,:DPG:23-039, dated March*

27, 2023 : ) * *,',, . ,

. i:.

As discussed previously,: .SMUDfully :funded the; Part ,50 Decommissioning Trust Fund by making the last contribution in 2008. However, because of the level of uncertainty

  • inherent in power reactor decommissioning, the amount of funding provided was conservative .. *With the,Part 50 deco.mmissioning and license termination activities now complete, :an excess of available funds,exists* in the Decommissioning Trust ,Fund. This' excess provides more than enough .funcls to ;assure* available funding for future ISFSI .*

decommissioning. Therefore, no additional contributions to the Trust Fund are currently planned.

  • 72.30(c) At the time oflicense renewal and at intervals not to exceed 3*years, the
  • decommissioning funding plan must be resubmitted with adjustments as necessary to account for changes in costs and the extent cif contamination. If the amount of financial assurance will be adjusted downward, this:cannot.be done untilthe updated decommissioning funding plan-is*'approved:.. The decommissioning funding. plan must update th~ information submittedwiththe original or prior approved plan and must*

specifically considerthe effectofthe'following*events on decommissioning costs:, .

72.30(c)(1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material: Section 9.6 0f the,Ranch9 Seco ISFSI FSAR states "Due to the zero-leakage design of the NUHOMS DSC~;:SMUD e:x:pects noresidual. 1 contamination,on the* ISFSI concrete*base pad."'Therefore; neither'liquid spills of substances containing radioactive material, nm those that may come in contact with, radioactive 'material are,considered *credible it this stage:of decommissioning, since the remaining radioactive material is in solid form and not dispersible. This lack of credibility :extends to the potential for-contamination of the son- in contact with the ISESI concrete pad.: ,.... ,,: * * ,.. *; **;__; ',-,,

10 CFR 72.3_0(t) (2}faciiity ~oclificatioti~:.A.lh~port~d'tci the NRC 111 SMlJD l~tter .]:: ; '

"RANCHO SECO BIENNIAL REPORT,a~iea July *,4; 2016 (AD.AMS A.ccessfori},lo. ,,.

ML 16208Al 09.), SMUJ) install~d a 4000 *~ciiµare foot Fu~l Transfer Equipm~nJ Storage .

Building (F~ES~) with~n the Part 72 li¢en~~~*15~U11dary. This' structure, external to th~

ISFSI pad, provides environmentally sheltered storage for fuel handling* equipment _

contaminated with lic~nsed radioactive *material. This,, contamination is either fixed (as in .

the case ofthe_MP~187 Transfer Cas~). 0fCO~tain~rized to preclude'i~; spr~ad',-while iµ ,.

storage. SMUD. anticipll;fes a*n_iaximurri of Jrfi.ncl:l st~~s *survey units to demonstrate,.. . .

satisfaction of the release criteria contained in 10 CFR 20. 'As ccmfamination of this new .

structure IS not ahtiiipateclJm additi,onal Class 3 survef linit for the E,SB interior,cdid ,c *.

exterior would be added. As the ,survey design criteria for Class 3 survey units are ., .. * .

minimal, the impact ~n the overall cost of decommissioning the ISFSI would be .

insignificant. ** *

  • DPG23-038 Page *7,of 14 ,

10 CFR 72.30(c) (3} changes in authorized possessi0n limits: SMUD completed the- -*,

transfer ofall,SNF and GTCC waste tothelSFSI in-2006. SNM-2510, Amendment4,,.

(11/24/2017) provided for the storage*of a 200 µCi Sr-90 byproduct material source for use as a check source for radiological detection.equipment identified within SMUD_'s.'

Radiation Pr~tection and Emergency Preparedness :Plans .. This is :a change to .the authorized possession limits., since the approval of the ISFSI Decommissioning Furtding Plan. The impact on the overall cost of decommissioning the ISFSl resulting. from this increase will be insignificant.

10 CPR 72.30(c) (4) actual remediation costs that exceed the previous cost estitri.att'/ .

SMUD will not begin to decommission the Rancho Seco ISFSI until after the U.S.

Departmetit of Energy takes possession oft~e spen.f fu~i and' ,ot,cc \yc1~te: *1'.'J-;1et~f~r~,

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

METHODOLOGY AND APPROACH Overview of Decommissioning Cost Estimate. Components The, c~st estimate provides an overali'~ost for the, dllfatioµ' ~f the isF~I deco~issioning project. This includes all costs inc~ed *after removal of the spent nuclear fuel and GTCC waste through the Part 72 license tennJnation, , -

Staff costs include the cost for con,tract staff to. perform the Final -Status Surveys and, remaining license termination activities of the ISFSI.

Miscellaneous costs have-been inchidedtff:documerit the support :costs that.are, specifically-identified for the duration of the.ISFSr decommissioning project. These costs also include material costs for decommissioning.'. *

  • FINANCIAL COMPONENTS OF THEC0ST MODEL The decommissioning cost estimate in total is defined as the funding required to complete,

decommissioning through license termination. Historically, the estimate consisted of a large numbet of calculated costs. based on *cdsffactors, *and the cost assigned 'to a giv~n line' item within the estimate was nbtas rigorotisly*defended as the total. 'A basic .

assumption of the estiiriating'process hasb~eri 1tliatwhe:ri specific line itenis have been over-estimated, the unspent funds will be required 'to cover the cost's -associated with other line items that have been under.,;estimated. 'Tl:ie historical costs for the Part 50 -

decommissioning reflect that the cost ofthtfwork'cofupleted was; in general,*over- *...

estimated and similar assumptions are anticipated to be applicable to the ISFSI decommissioning process. * * *

  • Examples of remaining contingencies include changes in the regulatory environmeJ?.t and cost or regulatory changes that would impact remaining license termivaiio1s1 activities.

The cost ~rµpacts of the*se uncertainties have been _defined by TLG in'*pre-Viou_s estimates under the term "fi11,aricialrisk". To date, financial risk has riot been specifically . - *,

Page 8of14 addressed within any Rancho Seco decommissioning cost estimate.. ,Outside .of the sc*ope of the tostestimate'itself, staff deals with these 1uncertainties on a project.:by.:project - -

basis: An overall risk assessment considering any anticipatedriskfactor* wo~ld typically

  • be addressed-through :a probability analysis, perhaps*utilizing a Monte Carlo-type' probability simulation. Such a detailed'.riskanalysis*is considered to be outside of the.

scope of the decommissioning'cost estimate ..' However; contingency isincluded as a component of the estimate.

ASSUMPTIONS The following ~re th~- as~uinptions used ,iri dev~\oping the Rancho Seed ISFSI cost. ; '

estimate. Some assumptions* are generic_ in 'nature, and some are specific to the Rancho Seco site. , ** * * ** * * ' * * * *

  • Used Fuel
1. The cost to remove and dispose of the used fuel from the site is not reflected 'within the estimate to decommission Rancho Seco. The Nuclear Waste Policy Act assigns

_t '

s

'.

  • this respbnsibility to the DOE' Waste* Management System.

°J ' 1*,,,

2. The ISFSI will remain operational uitderthe 10 CFR 72-license until the DOE takes possession of, or accepts responsibility for, the fuel and GTCC waste. The cost for maintenance of the iSFSiis oonsiderea*o&M and is not included in this cost estimate.
3. DOE acceptance of.the fuel:and GTCC:waste'in'2027. *This will be reviewed .for .
  • each subsequent estimate as then:tis currently great uncertainty with the acceptance date. Note that the actual date qf fuel. ac'ceptance is currently not a factor :in demonstrating financial assurance because the decommissioning costs are fully funded and do not rely on areturn:on ifivestinerits overtime.

ISFSI. Decommissioning , :,, *. *.

' .,.. __ .,*_ . ,,  ! i (!,_ :i*. *, *.. *. _, . ' ..

1. No reµiecliation will be require~ for ~y st~ctµres o;r l~d areas ~t:the ISf SI. . ,

Evaluation of Reference 4 indicates .~lJ.c:).-!,activation of materials .at the ISFSI will not result in co11taminaJion that re.qllires :r~mediation.._No J.oose. 9ontami.1,1at~on _at the

.lSFSI was m,easµred during the fu.elmqY;ement act,iviti~s; iIJ2000 through_ 209~*, 1aµd fuel canister leakage is b.eyoµd,the ISF~l;design basis. No surface co,nt~inatio;n ,*

has been detected, nor.is ~ticipated, c;tt Jh~JTES];l. ,. ~

Reactor Vessel Intern:al Components

1. ; The react~r vessel internal compon~nts classified ~s GTCC material is st~red ill the

. ISFSI untfl the DOE takes possession of the material. i-Iowev~r, the DOE ha~ not. _*

  • ' yet establish.eel ~~ceptance qrit~ria or a disposition schedule for this material. *. **, _**
  • Therefore,' this cost estimate is based upon industry-accepted assumptions regarding

BPG23-038 Page '9of14 DOE schedules. Industry assumptions for the acceptance criteria are modeled-on the packaging for the used nuclear fuel: the GTCC is stored in a canister with the same outer geometry as the used fuel canister:s. *

2. The cost for transfer and disposal oftheGTCC materiai is notincluded,in this cost estimate. Legal opinions and court decisions indicate that the GTCC disposal is the responsibility*ofthe DOK
  • Transportation Methods
1. Contaminated materials resulting from any remaining decommissioning activities will qualify under Title 49 of the Code' of Federal Regulations Part 173 .as LSA -1, -

II, or -III, or SCO-1 or -II.

2. Transportation of Class A LLRW. is by:truck or rail to EnergySolutio:p.s in Cliv~,

, UT or Radioactive Waste Processing, Facilities appropriately licensed and approved bySMUD.

Low-Level Radioactive Waste Disposal

1. The amount of the LLRW generated dµri11g decommissioning will be minimal based on the absence of contamination present. Future disposal rates for Class A

. waste used irt the* estimate are based uport historical rates and disposal cost escalation factors listed in NUREG-1307, Revision 19.

' 1:. *1, l

Estimating Basis

1. Future decommissioning costs are in general reported in the current year's currency regardless of the scheduled year ofthe\expertditure; therefore, changes in schedule do not impact the cost estim~te.
2. Remaining co*sts* are based upon an estimate of the remaining activities including contract staff to perform the activities and other costs such as waste disposal.

'* ~ *, ";.1.:

Labor Costs

1. The craft labor required to complete decommissioning is obtained through standard SMUD c_ontracting 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, arid work procedures are assumed to be performed by contracted staff.

DPG23-038- Page 10 of14 General I '

1. The approximately 14-acre ISFSlremains under the Part 72 license., Following transfer of the used fuel and GTCC material to the DOE, a decommissioning project

-wiU:commence to:terminate this license.* '

2. NRC oversight of the decommissioning process is estimated based on previous license termination activities. The amount of oversight effort is proportioned based on the number of Survey Units for license termination as a reasonable basis for*the estimate.
3. . Equipment costs: for use ,during deconimissioning are included as Miscellaneous Costs.
4. -Demonstration of compliance with-the radiological criteria for license termination of the Part:-72 facilities will require documentation of no more than27 Survey Units as follows;

-Ji.

Units * -* * :.. 'Description* Locatidii Classification 22 -. HSMs ISFSI Class 1 1 Concrete Pad ISFSI Class 2 1 Concrete Apron ISFSI Class 3 1 .i  : :_ Land.Area . ISFSI* Class 3 Equipment Storage Building

. , _l ,,, , 1, , "' , .' . . .Interior : . .,.

. ;. - . *'. ;-~~t. *.' ,: ; .*

Equipment Storage Building 1 Exterior ISFSI  ::Class 3

5. Equipment such as administrative equipment (desks, chairs, etc.), forklifts, trucks,

, other mobile equipment, and- items of personal property owned by SMUD will be easily removed without the use of special equipment atno cost or credit to the project.

6. The decommissioning activities are performed in accordance with applicable regulations.

DPG23-038\* Page,lFof.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 projeQt at no
  • cost to the project.

Page 12of14

  • *GLOSSARY OF ACRONYMS,AND ABBREVIATIONS 1, -. ALARA: As Low As Reasonably Achi'.evable *,- -
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

5. GTCC: Greater Than Class "C" Waste - disposal of this waste is the responsibility oftheDOE
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 in Andrews, TX

DPG 23-038 Page 13 of 14

.~ -.. ; ,'-;J,,,)> ,":'__ S. Vt ,: .,.... '*""r", ~

REFERENCES

1. "2019 Decommissioning Cost Estimate for the Rancho '

Seco1~uclear

' ,. l Generating Station", March 31, 2020, DPG,20-946"

2. Letter to NRC, "Rancho Seco R;epoi-t on Financial Assurance. Sttus", March 31, 2020, DPG 20-04 7 . . . ;
3. Rancho Seco Part 72 License Tbrmination cost basi~,--TLG s:ervi~es, Inc "Independent Spent Fuel Storage Irt~tallation Decommission~ng':; Cost Summary, 2003; ARO Response to Data Request and Assumptions, Attachment S 11-1481-0302 s i '
4. SMUD Engine¢iing Calculation#Z~:XXX-N0057, Rkvision 1, October 4, 1993,

' , ' l . . '

"Neutron Activation of a Pacific Nuclear NUHOMS" ' , *

5. "Strategy for the Management and Disposal ofUsed'Nuclear Fu~l and High-Level Radioactive Waste", Department of Energy, January 2013 , :;
6. "Report to the Secretary ofEnei*gy'\ Blue Ribbon Cb:mriiissi~n ~n America'.st Nuclear Future, January 2012 1. . : . . . . .. .. J * .. * ! '. *. ,__
l i

.J

.. / *---- "' .,.,._, -*

l

Banclw Seco iYuclear Generating Station DPG28-088 D.-:commissioning Cost Estim.at~ Page 14of 14 Table 1 Decommissioning Cost Estimate (Thousands of 2022 Dollarii)

COSTS BY ACTIVITY COSTS BY YEAR Waste Disposal *:% .. ,,

DESC SHIP BURY STAFF MISC CNTGCY CNTGCY TOTAL - 2022 .. 2027 2028 TOTAL License Termination Actvities ..

Part 72 license tennination 4 34 3,745 1,836 843 *15%

  • 6,463 0 ,.::o  :: 6,463 6,463 TOTAL COST IDCE 2022) 4 34 3 745 1.836 843 c15% 6.463 .. 0 0 '*. 6,463 6,463 Total Decommissioning Cost
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