ML24156A067
| ML24156A067 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 05/31/2024 |
| From: | Lux J Environmental Properties Management |
| To: | Miller R, James Smith Document Control Desk, Office of Nuclear Material Safety and Safeguards, State of OK, Dept of Environmental Quality (DEQ) |
| References | |
| Download: ML24156A067 (1) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com May 31, 2024 Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Rachel Miller Oklahoma Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73101 Re: Docket No. 07000925; License No. SNM-928 Cimarron Environmental Response Trust Corrected Decommissioning Cost Estimate
Dear Recipients:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein a corrected version of the updated decommissioning cost estimate (DCE) for the decommissioning of the Cimarron site. Facility Decommissioning Plan - Rev 3 (the D-Plan, accession number ML22287A079) included a DCE in Table 16-5.
EPM had submitted an updated DCE to the U. S. Nuclear Regulatory Commission (NRC) and the Oklahoma Department of Environmental Quality (DEQ) in a letter dated April 24, 2024 (ML24116A171). Attachment 1 to that letter presented a revised version of Tables 16-5a and 16-5b.
When reviewing the updated DCE, DEQ personnel noticed that the Total Annual Costs in Table 16-5a did not equal the sum of the component (i.e., License Compliance, Decommissioning, DEQ fees, etc.) costs.
Fortunately, Table 16-5b calculated the escalated annual cost for each component in Table 16-5a, not the Total Annual Cost in Table 16-5a. Consequently, all of the annual costs and the Year-End Available Funds presented in Table 16-5b were correct.
EPM encloses herein a corrected revision of the updated DCE presented in Tables 16-5a and 16-5b. Because Table 16-5b is unchanged from the April 24 submittal, this revised DCE still indicates that sufficient funding is available to achieve the NRC Criterion for groundwater.
Please note that the cost for construction represent approximately one-third of the available funds in this DCE, and that optimization of groundwater extraction and treated water injection rates provide opportunity to shorten the projected duration of remediation.
If you have any questions or desire clarification, please contact me at jlux@envpm.com or (405) 642-5152.
Sincerely, Jeff Lux Project Manager cc: (electronic copies only)
Stephanie Anderson and Linda Gersey, NRC Region IV Paul Davis, Keisha Cornelius, Christopher Robinson, David Cates, and Jonathan Reid, DEQ NRC Public Document Room vcpsubmittals@deq.ok.gov
CIMARRON ENVIRONMENTAL RESPONSE TRUST DECOMMISSIONING COST ESTIMATE ELIMINATING OVERSIGHT FEES Table 16-5a - Costs in 2022 Dollars Description 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 License Compliance
$864,610
$730,000
$880,000
$850,000
$840,000
$840,000
$840,000
$840,000
$840,000
$840,000 NRC Fees
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0 Decomissioning
$3,855,770
$24,038,750
$1,850,000
$1,785,000
$1,680,000
$1,680,000
$1,680,000
$1,680,000
$1,680,000
$1,680,000 ODEQ Fees
$0
$1,500
$6,000
$6,000
$6,000
$6,000
$6,000
$6,000
$6,000
$6,000 Total Annual Cost
$4,720,380
$24,770,250
$2,736,000
$2,641,000
$2,526,000
$2,526,000
$2,526,000
$2,526,000
$2,526,000
$2,526,000 Description 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 License Compliance
$840,000
$840,000
$840,000
$840,000
$703,962
$567,924
$567,924
$467,924
$253,962
$126,981 NRC Fees
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0 Decomissioning
$1,680,000
$1,680,000
$1,680,000
$1,180,000
$1,040,550
$241,100
$940,550
$1,380,000
$205,000
$115,000 ODEQ Fees
$6,000
$6,000
$6,000
$6,000
$6,000
$0
$0
$0
$0
$0 Total Annual Cost
$2,526,000
$2,526,000
$2,526,000
$2,026,000
$1,750,512
$809,024
$1,508,474
$1,847,924
$458,962
$241,981 Table 16-5b - 3% Annum Escalation 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 "n" Value --->
3 4
5 6
7 8
9 10 11 License Compliance
$864,610
$797,691
$990,448
$985,383
$1,003,004
$1,033,094
$1,064,087
$1,096,009
$1,128,890
$1,162,756 NRC Fees
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0 Decomissioning
$3,855,770
$26,267,791
$2,082,191
$2,069,304
$2,006,008
$2,066,188
$2,128,174
$2,192,019
$2,257,780
$2,325,513 ODEQ Fees
$0
$1,639
$6,753
$6,956
$7,164
$7,379
$7,601
$7,829
$8,063
$8,305 Total Annual Cost
$4,720,380
$27,067,121
$3,079,392
$3,061,643
$3,016,176
$3,106,661
$3,199,861
$3,295,857
$3,394,733
$3,496,575 Initial Available Funds (1/1/2024)
$72,373,517 Year-End Available Funds
$68,376,872
$41,993,520
$39,334,063
$36,665,761
$34,016,242
$31,249,743
$28,362,380
$25,350,146
$22,208,915
$18,934,429 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 12 13 14 15 16 17 18 19 20 21 License Compliance
$1,197,639
$1,233,568
$1,270,575
$1,308,693
$1,129,652
$938,692
$966,853
$820,508
$458,684
$236,222 NRC Fees
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0 Decomissioning
$2,395,278
$2,467,137
$2,541,151
$1,838,402
$1,669,777
$398,502
$1,601,223
$2,419,838
$370,253
$213,934 ODEQ Fees
$8,555
$8,811
$9,076
$9,348
$9,628
$0
$0
$0
$0
$0 Total Annual Cost
$3,601,472
$3,709,516
$3,820,802
$3,156,442
$2,809,058
$1,337,193
$2,568,076
$3,240,346
$828,936
$450,156 Year-End Available Funds
$15,522,302
$11,968,009
$8,266,887
$5,193,114
$2,435,987
$1,123,154
($1,433,691)
($4,688,374)
($5,564,194)
($6,069,992)
Notes:
$72,373,517 is the funding available in the Federal, State and Standby Trust Accounts as of December 31, 2023.
For Table 16-5b, Year-End Available Funds were calculated by adding 1% to the previous year's Year-End Available Funds and subtracting the year's Total Annual Cost.
For Table 16-5b, the Total Annual Cost in 2022 dollars is escalated by 3% per annum by (1.03^n, where "n" is the number of years post-2022).
Yellow highlighted cells were identified as incorrect on 5/8/2024. Formulae had been replaced by values which were not correct.
Description Description