ML15189A169

License Transfer Presentation

ML15189A169
Person / Time
Site:	La Crosse  File:Dairyland Power Cooperative icon.png
Issue date:	07/08/2015
From:	Vaaler M G Reactor Decommissioning Branch
To:	Dairyland Power Cooperative, EnergySolutions
Vaaler M
References
Download: ML15189A169 (21)

Text

La Crosse License TransferforAccelerated Decommissioning 1

LACBWR License TransferAgenda*Introductions -Ken Robuck

• Purpose of the Meeting -Rob Palmberg

• La Crosse Background and Current Status -Rob Palmberg*Overview of the License Transfer Agreements/Timing-John Hess*La Crosse Technical Qualifications, Decommissioning Approach & Schedule -Nick Williams*Financial Qualifications and Assurance -John Matthews

• Summary 2 LACBWR License Transfer*Communicate intent to accelerate decommissioning of the La Crosse BWR -LACBWR overview and current status*Describe the approach and benefits of license transfer to LaCrosseSolutions*Overview of the structure of the agreements

• Overview of LaCrosseSolutionsplanned decommissioning approach & schedule*Overview of the organization and qualifications-Zion Update 3Purpose of the Meeting LACBWR License TransferLACBWR Key FactsBWR (50MWe)-AEC Demonstration Reactor

-Owned by DairylandPower Cooperative (DPC)-Operated from 1967 to 1987

-Licensed site shared with operational fossil plant LACBWR License Transfer 5LACBWR Site LACBWR License Transfer 6LACBWR Site LACBWR License Transfer*LACBWR staff performed limited dismantlement work between 1996 and 2004*In 2005, efforts shifted to RPV and Class B/C waste removal that was successfully completed in 2007.-ES performed the removal and disposal of the RPV and B/C waste at the Barnwell disposal facility*Fuel transfer to dry storage commenced in 2008 and was completed September 19, 2012*Additional dismantlement work completed in 2012 -2014 including removal of fuel racks and completion of main turbine generator component removal 7Decommissioning to Date LACBWR License Transfer*All spent fuel is in dry storage on the Independent Spent Fuel Storage Facility (ISFSI)License amended to provide nuclear security for the ISFSI area only*Plant buildings still standing

• LACBWR placed in Passive SAFSTOR in 2014

• ES providing RPM and RP program management

• Initial Site Characterization completed by ES

• License Termination Plan being prepared by ESExpect to submit to NRC NLT Q4 2015 8LACBWR Current Status LACBWR License Transfer*Dairyland'scost estimate to decommission LACBWR plant through site restoration is approximately $85M*NDT balance to decommission LACBWR plant is approximately $91M as of 12/31/14*Dairyland'sestimate of costs to decommission the ISFSI is approximately $1.5M as of 12/31/14*NDT balance to decommission the ISFSI is approximately $1.8M as of 12/31/14*Dairylandfunds the ISFSI costs from its operating budget, not from the NDT.*Dairylandhas a meeting scheduled with the State of Wisconsin on June 26thto discuss the project-Governor's Office, PSC, Emergency Management, & Department of Health 9LACBWR Current Status LACBWR License Transfer*Transfers risk to EnergySolutions/LaCrosseSolutions*Leverages EnergySolutionscore competencies-Decommissioning

-Waste Management & Disposal*Enables accelerated schedule for completion of D&D-Expeditious reduction of radiological source term/liability-Earlier release of the site for beneficial reuse*Eliminates uncertainty with LLRW disposal-Cost & Access*Provides additional assurances beyond the Nuclear Decommissioning Trust funds*EnergySolutions/LaCrosseSolutionsassumes direct license responsibility to the NRC10Why Pursue a Different Approach?

LACBWR License Transfer*EnergySolutionswill create a special purpose subsidiary, LaCrosseSolutions, to be licensee for LACBWR*LaCrosseSolutionswill:-Become the lead licensee for LACBWR Decommissioning Operations-Take possession of the used nuclear fuel (but not ownership)-Assume full responsibility for licensed activities

-Assume all liabilities and obligations for radiological decommissioning and site restoration directly related to the LACBWR decommissioning*Dairylandwill remain the licensed owner and retain title to:-Used nuclear fuel

-The Nuclear Decommissioning Trust

-Real estate and site improvements11Overview of the Agreements LACBWR License Transfer*Used Nuclear Fuel-Dairylandhas a Standard Contract with DOE for disposal of used nuclear fuelInitial round of litigation completed -awarded $37.6M2ndround of litigation pending*LaCrosseSolutionsdoes not require a Standard Contract per 42 U.S.C. 10222(b)(1)(A), because it is not authorized to use any fuel in the reactor and will not own the fuel*LaCrosseSolutionswill subcontract the security and maintenance of the fuel/ISFSI to Dairyland, which will retain the liability to fund the storage costs for the fuel12Overview of the Agreements LACBWR License Transfer*LaCrosseSolutionsand Dairylandplan to execute a Decommissioning Agreement-Provides for access to the Nuclear Decommissioning Trust to pay for decommissioning costs-ES believes funds are sufficient to cover all remaining decommissioning and license termination costs-ES has performed a detailed cost estimate and due diligence to validate*Additional Financial Assurance Provided-3rd Party Performance Bond/Surety for 20% of cost (~$17M)-Parent Guarantee ($15M)

-Disposal Capacity Asset for Clive Disposal of Class A Waste (no Class B/C Waste expected to remain)13Structure of the Agreements LACBWR License Transfer*Decommissioning Agreements executed within the next few weeks*Dairylandand EnergySolutionswill then submit:-Application for transfer of the 10 CFR 50 license

-EnergySolutionsdecommissioning cost estimate-PSDAR update*EnergySolutionscommences detailed decommissioning planning in Q3 under a separate contract with Dairyland-These costs are included in ES cost estimate*Closing follows NRC approval of license transfer and receipt of other necessary approvals14Timing LACBWR License Transfer*EnergySolutionstechnical capabilities are based upon:-Decommissioning core competence

-ZionSolutionsand EnergySolutionsemployees-Key Zion contractors

-Zion systems and processes where applicable

-EnergySolutionsdisposal assets*Zion update & applicability to LACBWR

• LACBWR decommissioning approach and schedule15La CrosseSolutionsTechnical Qualifications LACBWR License TransferZion Decommissioning Summary*Dual Unit Westinghouse 4 Loop Pressurized Water Reactor Site (Each Unit 3250 MWt/1085 MWe)*Permanent Cessation of Operations 1998

• Part 50 Operating License and asset transfer from Exelon to ZionSolutionsin Sept 2010 to begin site active decommissioning *Original target completion -2020

• Current target completion -FSS complete mid -2018

• Decommissioning fund continues to provide adequate financial assurance*Safe and efficient site remediation with systematic approach that prioritizes the elimination of site risks*Protection of the environment, the workforce and public, ultimately returning the site for future beneficial reuse16 LACBWR License TransferReactor Decommissioning Group*Leadership Team composed primarily of personnel with 20-30+ years commercial reactor decommissioning experience will be integrated with the LACBWR D&D*Engrained NRC culture of:-Safety first/procedure compliance

-Self-identification/continuous improvement*Have successfully and safely completed complex high risk tasks at Zion, e.g.:-65 Canister Fuel Transfer/GTCC Campaign

-Unit 1 and 2 Reactor Vessel Internal Segmentation

-37 B/C Waste Shipments

-Post fuel program and Emergency Plan transition17 LACBWR License TransferZion Video*Show Zion Video18 LACBWR License TransferZion Fuel Transfer Operations1961 pf 61 Canisters processed and transported to ISFSI 52 Week Campaign 18.1 Person Rem Est.

16.3 Person Rem Goal 11.1 Person Rem Actual LACBWR License TransferZion Fuel Canister In Processing20Transfer Cask Being Lowered into Spent Fuel Pool Robotic Welding on First Fully Loaded Fuel Canister LACBWR License TransferZion's First Fuel Canister In Processing21Loaded Fuel Cask In Transport to Zion's ISFSI LACBWR License TransferZion Reactor Vessel Segmentation*Unit 1 and Unit 2 Lower Internals Complete.*Four GTCC waste canisters to ISFSI (Complete 3/6/2015)*U2 and U1 Cavities have been drained and decontaminated. Paint fixative applied to cavity walls and floor. *Unit 2 reactor vessel segmentation started22Cutting on Lower internalsUnit 1 LACBWR License Transfer23U2 RV Segmentation Equipment in PlaceU2 Strand Jack System and TSP in Refueling CavityU2 Bridged Strand Jack System LACBWR License TransferEnvironmental Protection ZionSolutionsEnvironmental Protection -Compliance

-Stewardship24 LACBWR License TransferSite At Completion (End State)*Zoned for Heavy Industrial Use

• Above grade buildings demolished and removed (to a minimum 3' below grade)*Basement areas backfilled and land areas returned to natural contours*Roadways and rail lines will remain

• Intake and discharge piping from and into Lake Michigan will remain*Some buried piping will remain

• Adjacent facilities/structures to remain:-ComEd Switchyard (to the West)

-ISFSI Complex (to the Southwest)

-ISFSI Warehouse (to the Southwest)

-Microwave Tower (to the South)

-Sewage Lift StationSeptember 3, 201425BeforeAfter LACBWR License TransferZion 2015 Summary*FTO Complete January 9th*GTCC Complete March 6th*Vessel Internals Complete Jan 15th*License Term. Plan Submitted Dec/14-NRC Accepted Apr/15*Unit 2 Rx Vessel Segmentation (2ndQuarter)*Unit 1 Rx Vessel Segmentation (4thQuarter)*Crib House Demo (2ndQuarter)*Unit 2 Large Components (4thQuarter)*Unit 1 Large Components (1st Quarter-2016)

• Turbine Building Unconditional Release Surveys (4thQuarter)*Start Turbine Building Demolition (4thQuarter)26 LACBWR License TransferFuture Site Owner27 LACBWR License TransferZion/LACBWR Comparison*Zion-Large site, twin 1085 MWePWRs

-Multiple large buildings-operational/logistical complexity-GTCC/Fuel dose rates up to 13,000 R/hr

-37 B/C Waste liners typically 400 to 1000 R/hr

-High risk items handled safely to date by ZionSolutions*LACBWR-Small site, single 50 MWeBWR

-Small building footprints, reduced operational/logistical challenges-Resin/sludge dose rates to 1 R/hrRemoval this summer by ES-Thermal shield dose rates to 130 mR/hr

-Areas of high alpha contamination28 LACBWR License TransferProject Similarities*Highest risk work already complete at both sites

• Primary remaining activities-Class A waste removal, shipping, disposal

-Building decon/demolition

-Final Status Survey

-Site restoration*Allows ES Reactor Group to manage similar tasks in the 2016 to 2018 timeframe29 LACBWR License Transfer

• Project Organization-Upon license transfer LaCrosseSolutionsassumes full responsibility for and control over the LACBWR-LaCrosseSolutionswill adopt the existing emergency preparedness, training, and security procedures from LACBWR and revise the QAPD-Establish these functions at LACBWR using project personnel30La CrosseSolutionsTechnical Qualifications LACBWR License Transfer

• Project Controls-Based on lessons learned from past D&D projects

-Baseline project controls tied to financial reporting systems to track costs to specific WBS elements-Report monthly on cost and schedule variances plus earned value-Manage cash flow to baseline to ensure the trust fund has adequate funds to cover estimate to complete-Accountability reviews by corporate and external stakeholders31La CrosseSolutionsTechnical Qualifications LACBWR License Transfer*Source term removal within radiologicallycontrolled areas-Minimize survey and surgical removal

-Utilize large capacity intermodal and/or gondola rail cars to move LLW to Clive-Remove structures to a minimum of 3 feet below grade

-Affected systems/buildings -ship to Clive

-Release plan using MARSAME guidance for unaffected systems/buildings32Decommissioning Approach & Schedule LACBWR License Transfer*Non-Rad Materials and Areas-Remove hazardous materials such as asbestos, light ballasts, PCB's, Hg switches, and oil before removal of components or demolition as necessary to meet disposal site WAC*Clean components with scrap value will be evaluated for salvage (not to impact critical path)33Decommissioning Approach & Schedule LACBWR License Transfer*Demolish buildings-Radioactive building debris sent to Clive

-Final Status Survey per MARSSIM

-NRC/ORISE Confirmatory Survey

-Backfill*License Termination Plan-LTP under development by Dairyland/EnergySolutions-Target submittal by Dairylandin Q4 2015

-LTP and Final Status Survey approach similar to Zion LTP (recently accepted for review by NRC)34Decommissioning Approach & Schedule LACBWR License Transfer*Logistics is key to effective D&D

• Construct new rail lines for waste loading & transportWaste Removal/Transport Logistics LACBWR License Transfer36Decommissioning Approach & Schedule LACBWR License Transfer*Nuclear Decommissioning Trust Fund Established-Existing Dairylandnon-taxable Grantor Trust

-Pre-paid external sinking fund per 10 CFR 50.75(e)(1)(i)*NDT sufficient to fund remaining radiological decommissioning and site restoration costsBased on EnergySolutionsupdated cost estimateWithout accounting for future earnings Includes cost of site restoration*Current ES decommissioning estimate -$85.6M-In 2015$'s as of June 2, 2015

-Includes radiological decommissioning and site restorationIncludes decommissioning planning and related costs incurred pre-closing37La CrosseSolutionsFinancial Qualifications LACBWR License Transfer*20% Performance Bond/Surety (approx. $17M)-Third party surety provided to Dairylandfor obligations under the Decommissioning Agreement-Expected to satisfy the assurance requirement per 10 CFR 50.75(e)(1)(iii)(A)*LLW Disposal Capacity Asset-Covers disposal of all Class A LLW from LACBWR at Clive, UT facility-Held by back-up NDTSpecial purpose easement (legal instrument)Protected in the event of EnergySolutionsbankruptcy38La CrosseSolutionsFinancial Qualifications LACBWR License Transfer*Parent Guarantee ($15M)-Provided to Dairylandfor obligations of EnergySolutions' subsidiary -LaCrosseSolutions, LLC*EnergySolutions'equity interest in LaCrosseSolutions, LLC also pledged as collateral*Default under the Decommissioning AgreementDairylandwill have the right to take possession of the subsidiary and the Back-up NDTLaCrosseSolutions, LLC structured to provide protection against EnergySolutionsbankruptcy (non-consolidation)One LaCrosseSolutionsDirector appointed by DairylandUnanimous vote for voluntary bankruptcy filing39La CrosseSolutionsFinancial Qualifications LACBWR License Transfer*Dairylandand EnergySolutionsare near final agreement on arrangements to transfer license responsibility for LACBWR decommissioning*LaCrosseSolutionswill have the technical qualifications to assume license responsibility*The parties have strengthened the financial assurances that will be available to complete the LACBWR decommissioning*LaCrosseSolutionswill be financially qualified to assume licensee responsibility*A license transfer application will be submitted in weeks*Approval of the license transfer will enable accelerated completion of LACBWR decommissioning40Summary