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| author name = Mecca S
| author name = Mecca S
| author affiliation = State of RI, Atomic Energy Comm, Nuclear Science Ctr
| author affiliation = State of RI, Atomic Energy Comm, Nuclear Science Ctr
| addressee name = Kennedy W B
| addressee name = Kennedy W
| addressee affiliation = NRC/NRR/DPR
| addressee affiliation = NRC/NRR/DPR
| docket = 05000193
| docket = 05000193
Line 12: Line 12:
| document type = Letter
| document type = Letter
| page count = 7
| page count = 7
| project =
| stage = Response to RAI
}}
}}


=Text=
=Text=
{{#Wiki_filter:STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS P RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 Mr. William B. Kennedy, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 January 19, 2010 Re: Letter dated November 24, 2009 Docket No. 50-193  
{{#Wiki_filter:STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS P     RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 Mr. William B. Kennedy, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 January 19, 2010 Re:     Letter dated November 24, 2009 Docket No. 50-193


==Dear Mr. Kennedy:==
==Dear Mr. Kennedy:==
This is the third and final part of our response to your request for additional information concerning our plans for decommissioning the facility at the end of its useful life, ref item 3 parts a, b and c of the your letter. It should be noted that it is our expectation that the Reactor and the Center will safely operate for the duration of the extended license. As you are aware, the Reactor underwent a successful LEU upgrade in 1993 and during that process, significant safety analyses were performed to justify the redesign.
 
During the intervening, years, the Commission has invested in all the upgrades necessary to keep the facility functioning in a safe and usable condition.
This is the third and final part of our response to your request for additional information concerning our plans for decommissioning the facility at the end of its useful life, ref item 3 parts a, b and c of the your letter. It should be noted that it is our expectation that the Reactor and the Center will safely operate for the duration of the extended license. As you are aware, the Reactor underwent a successful LEU upgrade in 1993 and during that process, significant safety analyses were performed to justify the redesign. During the intervening, years, the Commission has invested in all the upgrades necessary to keep the facility functioning in a safe and usable condition. That notwithstanding, the RINSC staff and the RI Atomic Energy Commission have refined our review of decommissioning options with the following underlying observations:
That notwithstanding, the RINSC staff and the RI Atomic Energy Commission have refined our review of decommissioning options with the following underlying observations:
* There are multiple planning scenarios possible, each with different costing elements.
* There are multiple planning scenarios possible, each with different costing elements." Some scenarios are hampered by the fact that we currently lack access to disposal of class B & class C wastes.* The actual scenario that would play out would depend on the context of state plans for the facility and the space it occupies at the time of a decommissioning decision." Decommissioning planning now should look at a typical scenario and plan for contingency funding to span the estimates of the range of likely costs for options available.
    " Some scenarios are hampered by the fact that we currently lack access to disposal of class B & class C wastes.
* Current contingency figures were last assembled a decade ago and the NRC request has offered the opportunity for revisiting these figures.kffd?
* The actual scenario that would play out would depend on the context of state plans for the facility and the space it occupies at the time of a decommissioning decision.
In developing a decommissioning plan, we considered the decommissioning alternative for what we can call a base case, including the major technical activities needed to carry out the decommissioning safely, Rhode Island's situation with regard to disposal of radioactive waste, residual radioactivity criteria to be used in the release of the facility and the location of our facility within theconfines of the Graduate School of Oceanography of the University Of Rhode Island. The aforementioned lack of access to disposal for Class B and C wastes severely limits our ability to reach a level of decontamination and removal of radioactive materials sufficient to allow the unconditional immediate release of the facility.
    " Decommissioning planning now should look at a typical scenario and plan for contingency funding to span the estimates of the range of likely costs for options available.
Although this situation could change during the twenty-year license renewal period, we thought it prudent to assume that it wouldn't and plan accordingly.
* Current contingency figures were last assembled a decade ago and the NRC request has offered the opportunity for revisiting these figures.
We recognize that 10 CFR 50.82(b)(1)(ii) requires that a non-power reactor be decommissioned without significant delay, except when concern for public health and safety makes delay necessary.
kffd?
We noted that among the factors that may warrant a delay in decommissioning was unavailability of waste disposal facilities.
 
We also noted that the Nuclear Regulatory Commission would not terminate our license until our facility met release criteria.As a result of these considerations, we envisioned the following decommissioning scenario:* According to 10 CFR 50.82, two general approaches to decommissioning are acceptable.
In developing a decommissioning plan, we considered the decommissioning alternative for what we can call a base case, including the major technical activities needed to carry out the decommissioning safely, Rhode Island's situation with regard to disposal of radioactive waste, residual radioactivity criteria to be used in the release of the facility and the location of our facility within theconfines of the Graduate School of Oceanography of the University Of Rhode Island. The aforementioned lack of access to disposal for Class B and C wastes severely limits our ability to reach a level of decontamination and removal of radioactive materials sufficient to allow the unconditional immediate release of the facility. Although this situation could change during the twenty-year license renewal period, we thought it prudent to assume that it wouldn't and plan accordingly.
One approach is to start decommissioning activities soon after operations cease and proceed toward terminating the license and releasing the facility.
We recognize that 10 CFR 50.82(b)(1)(ii) requires that a non-power reactor be decommissioned without significant delay, except when concern for public health and safety makes delay necessary. We noted that among the factors that may warrant a delay in decommissioning was unavailability of waste disposal facilities. We also noted that the Nuclear Regulatory Commission would not terminate our license until our facility met release criteria.
The other approach is to perform limited decommissioning activities soon after operations cease to prepare the facility for safe storage and maintain safe conditions until we can remove the remaining radioactivity.
As a result of these considerations, we envisioned the following decommissioning scenario:
We chose the latter and planned accordingly.
* According to 10 CFR 50.82, two general approaches to decommissioning are acceptable. One approach is to start decommissioning activities soon after operations cease and proceed toward terminating the license and releasing the facility. The other approach is to perform limited decommissioning activities soon after operations cease to prepare the facility for safe storage and maintain safe conditions until we can remove the remaining radioactivity. We chose the latter and planned accordingly.
* We will remove the fuel from the core as soon as possible after reactor operations permanently cease and ship the fuel off site in accordance with Department of Energy, Nuclear Regulatory Commission and Department of Transportation regulations.
* We will remove the fuel from the core as soon as possible after reactor operations permanently cease and ship the fuel off site in accordance with Department of Energy, Nuclear Regulatory Commission and Department of Transportation regulations.
* We will hire a contractor to dismantle the remaining non-fuel components of the reactor, characterize their radioactivity levels and prepare them for either safe storage or shipment since many of them are anticipated to be Class B and C radioactive wastes for which Rhode Island has no viable disposal option at this time." We will ship those non-fuel components that characterization shows meet Class A radioactive waste criteria to a licensed processor for subsequent disposal.
* We will hire a contractor to dismantle the remaining non-fuel components of the reactor, characterize their radioactivity levels and prepare them for either safe storage or shipment since many of them are anticipated to be Class B and C radioactive wastes for which Rhode Island has no viable disposal option at this time.
We used processing and disposal rates quoted by a broker for Class A radioactive wastes in our cost estimate.* We will store the remaining radioactive wastes until they can be safely and legally shipped for disposal.
    " We will ship those non-fuel components that characterization shows meet Class A radioactive waste criteria to a licensed processor for subsequent disposal. We used processing and disposal rates quoted by a broker for Class A radioactive wastes in our cost estimate.
For costing purposes, we assumed that disposal of Class B and C radioactive wastes became available before decommissioning and estimated their cost based on current Barnwell rates.
* We will store the remaining radioactive wastes until they can be safely and legally shipped for disposal. For costing purposes, we assumed that disposal of Class B and C radioactive wastes became available before decommissioning and estimated their cost based on current Barnwell rates.
f.4 Ii a-i* We will survey those areas of the facility that have been cleared of reactor components and, if Nuclear Regulatory Commission release criteria are met, release them for other uses.To respond to your questions, we undertook a gross estimate of the decommissioning costs associated with the base case scenario.
 
You should note that the resulting costs are a gross estimate with large uncertainties.
f.4 Ii a-i
We assumed that we would only remove the reactor itself leaving the building intact for possible other radioactive materials uses. We didn't include the costs of removing anything associated with the reactor that wasn't either contaminated or activated.
* We will survey those areas of the facility that have been cleared of reactor components and, if Nuclear Regulatory Commission release criteria are met, release them for other uses.
Thus, for example, you won't find any estimated costs for removing the dump heat exchangers.
To respond to your questions, we undertook a gross estimate of the decommissioning costs associated with the base case scenario. You should note that the resulting costs are a gross estimate with large uncertainties. We assumed that we would only remove the reactor itself leaving the building intact for possible other radioactive materials uses. We didn't include the costs of removing anything associated with the reactor that wasn't either contaminated or activated. Thus, for example, you won't find any estimated costs for removing the dump heat exchangers.
We have enclosed worksheets showing the cost estimate and labor rates (Exhibits 1 and 2 respectively) for the base case scenario.
We have enclosed worksheets showing the cost estimate and labor rates (Exhibits 1 and 2 respectively) for the base case scenario. Craft hours are only for removal and packaging.
Craft hours are only for removal and packaging.
No transportation costs are included. Labor rates are estimates based on Rhode Island Department of Labor and "Rent-a-tech" rates. The methodology and numbers for the labor averages used are included in Exhibit 2.
No transportation costs are included.
As shown in the attached worksheet, the computed cost less management and operations fees is $7. 1M; the process would span between 2 and 4 years during which staffing is expected to remain at levels mandated by our license.: This would add between. $1.6M and $3.2M (without discounting or escalation) to the cost bringing the range for this base case scenario to $8.7M to $10.3M. We decided to compare these estimates to one based on the experience of other facility decommissioning costs or estimates. In preparing these experience-based estimates, six reactors were considered: Penn State, Georgia Tech, MIT, Watertown, Virginia and Ohio State. If the estimates for these are equally weighted, the average decommissioning cost is $13M; weighting Virginia's (a reactor closer to our own) estimate a bit higher and Army Watertown a bit lower, gives an estimate of $12M. Averaging this range and the range of our base case calculation, we observe a difference of some 31.5%, which is a bit higher than the contingency factor you have asked us to include in our final estimates.
Labor rates are estimates based on Rhode Island Department of Labor and "Rent-a-tech" rates. The methodology and numbers for the labor averages used are included in Exhibit 2.As shown in the attached worksheet, the computed cost less management and operations fees is $7. 1M; the process would span between 2 and 4 years during which staffing is expected to remain at levels mandated by our license.:
To obtain an estimate of the more realistic costs of the decommissioning as envisioned with initial deconstruction, removal of present A wastes and subsequent removal of class B & C wastes when they decay to A class wastes, we began with the base case analysis and computed all costs out over 20 years, i.e. the time span of the pending relicense. This analysis is shown in Exhibit 3. Under a safe store scenario, one would incur disposal costs for B and C wastes as A wastes assumed to be an average of 20 years out. The results are shown in Exhibit 3. We have included a 5% per year inflationary rise in all decommissioning related costs, for the projected twenty years before we undertake final disposition. We noted that since 2001, the average consumer price index (CPI) has averaged about 2.85% but believe that an inflationary rate of 5% would more accurately reflect the costs associated with this type of project. In order to put all future costs in 2010 dollars, we show present values of total costs using discount rates of 2.85 % (the recent~historical CPI) and 0 % (no discounting). Note that staffing for management, monitoring and maintenance of required equipment is included. The Commission
This would add between. $1.6M and $3.2M (without discounting or escalation) to the cost bringing the range for this base case scenario to $8.7M to $10.3M. We decided to compare these estimates to one based on the experience of other facility decommissioning costs or estimates.
 
In preparing these experience-based estimates, six reactors were considered:
estimated this residual (post initial deconstruction) staffing would be between 20 and 30% of the present staffing of the Center. A figure of 25% was used beginning in year 4 and continuing through year 20.
Penn State, Georgia Tech, MIT, Watertown, Virginia and Ohio State. If the estimates for these are equally weighted, the average decommissioning cost is $13M; weighting Virginia's (a reactor closer to our own) estimate a bit higher and Army Watertown a bit lower, gives an estimate of $12M. Averaging this range and the range of our base case calculation, we observe a difference of some 31.5%, which is a bit higher than the contingency factor you have asked us to include in our final estimates.
The results give present values of $12.8M and $15.2M for discount rates of 2.85% and 0 (no discounting) respectively. The last elements in this summary include contingency factors 25%, 31.5% and 60 %. The latter, which is the highest contingency we have noted in the experience of other reactors. The 25%-factor is the one you have asked us to use. 31.5% appears to be one that is consistent with our base case estimates and the aforementioned experience-ba'sed average noted earlier.
To obtain an estimate of the more realistic costs of the decommissioning as envisioned with initial deconstruction, removal of present A wastes and subsequent removal of class B & C wastes when they decay to A class wastes, we began with the base case analysis and computed all costs out over 20 years, i.e. the time span of the pending relicense.
In summary, the Rhode Island Atomic Energy Commission is planning for the safe, successful and productive operation of our reactor and facilities for the duration of our license renewal. -Nevertheless we are pleased to offer this letter and supporting exhibits relating to decommissioning planning and estimations requested in your letter of November 24, 2009. Our best estimate for the present value of costs associated with a decommissioning scenario, involving initial deconstruction and disposal of A class wastes, Safe Store of B and - class wastes for the duration of the license and disposal of final wastes at the end of that period, is $16.8M in 2010 dollars. This includes a contingency factor of 31.5%, decommissioning related costs escalating at 5% and the use of a discount rate of 2.85%. The recent decommissioning contingency amount included in our annual budget is $30M; this allows for the extremes of the calculations shown plus a cushion for returning the site to readiness for another use.. It should be noted that the facility is built on a former gun mount, which would require significant demolition work to return, to remove. We will expect to review these estimates .periodically during the term of our license especially at times when the context of all'waste disposal options has changed..'
This analysis is shown in Exhibit 3. Under a safe store scenario, one would incur disposal costs for B and C wastes as A wastes assumed to be an average of 20 years out. The results are shown in Exhibit 3. We have included a 5% per year inflationary rise in all decommissioning related costs, for the projected twenty years before we undertake final disposition.
Very truly yours, Stephen Mecca, Ph.D., Chairman Rhode Island Atomic Energy Commission I certify under penalty of perjury that the representations made above are true and correct.
We noted that since 2001, the average consumer price index (CPI) has averaged about 2.85% but believe that an inflationary rate of 5% would more accurately reflect the costs associated with this type of project. In order to put all future costs in 2010 dollars, we show present values of total costs using discount rates of 2.85 % (the recent~historical CPI) and 0 % (no discounting).
Executed on:                     -'oBBy:
Note that staffing for management, monitoring and maintenance of required equipment is included.
The Commission estimated this residual (post initial deconstruction) staffing would be between 20 and 30% of the present staffing of the Center. A figure of 25% was used beginning in year 4 and continuing through year 20.The results give present values of $12.8M and $15.2M for discount rates of 2.85% and 0 (no discounting) respectively.
The last elements in this summary include contingency factors 25%, 31.5% and 60 %. The latter, which is the highest contingency we have noted in the experience of other reactors.
The 25%-factor is the one you have asked us to use. 31.5% appears to be one that is consistent with our base case estimates and the aforementioned experience-ba'sed average noted earlier.In summary, the Rhode Island Atomic Energy Commission is planning for the safe, successful and productive operation of our reactor and facilities for the duration of our license renewal. -Nevertheless we are pleased to offer this letter and supporting exhibits relating to decommissioning planning and estimations requested in your letter of November 24, 2009. Our best estimate for the present value of costs associated with a decommissioning scenario, involving initial deconstruction and disposal of A class wastes, Safe Store of B and -class wastes for the duration of the license and disposal of final wastes at the end of that period, is $16.8M in 2010 dollars. This includes a contingency factor of 31.5%, decommissioning related costs escalating at 5% and the use of a discount rate of 2.85%. The recent decommissioning contingency amount included in our annual budget is $30M; this allows for the extremes of the calculations shown plus a cushion for returning the site to readiness for another use.. It should be noted that the facility is built on a former gun mount, which would require significant demolition work to return, to remove. We will expect to review these estimates .periodically during the term of our license especially at times when the context of all'waste disposal options has changed..'
Very truly yours, Stephen Mecca, Ph.D., Chairman Rhode Island Atomic Energy Commission I certify under penalty of perjury that the representations made above are true and correct.Executed on: -'oBBy:  


==Enclosures:==
==Enclosures:==
Base Case Cost Worksheet Craft Hour Cost Worksheet Summary Sheet
ITEM                        Material          Cu. Yds. Cu. Ft. Labor Hrs Labor Rate Labor Cost Class Rate  RW Cost Total Cost Pool Base                  Barytes  Concrete      293    7911  1977.75    $84.00  $166,131 A      $110  $870,210 $1,036,341 RX Floor around IR Base    Barytes  Concrete      135    3645    911.25    $84.00    $76,545 A      $110  $400,950  $477,495 Gamma room floor            Barytes  Concrete      76    2052      513    $84.00    $43,092 A      $110  $225,720  $268,812 Pool Liner grout to base    Barytes  Concrete      35      945    236.25    $84.00    $19,845 A      $110  $103,950  $123,795 Cleanup/demin walls        Barytes  Concrete      3.5        95  23.625    $84.00      $1,985 A    $110    $10,395    $12,380 Cleanup/demin walls        Barytes  Concrete      7.5      203    50.625    $84.00      $4,253 A    $110    $22,275    $26,528 Holdup Tank Walls          Barytes  Concrete      26      702    175.5    $84.00    $14,742 A      $110    $77,220    $91,962 Holdup Tank Walls          Barytes  Concrete      2.5        68  16.875    $84.00      $1,418 A    $110      $7,425    $8,843 Holdup Tank Walls          Barytes  Concrete      4.5      122  ,30.375    $84.00      $2,552 A    $110    $13,365    $15,917 Bio Shield/pool liner      Barytes  Concrete      299    8073  2018.25      $84.00  $169,533 A      $110  $888,030 $1,057,563 Around pool liner          Barytes  Concrete      199    5373  1343.25    $84.00  $112,833 A      $110  $591,030  $703,863 Bioshield                  Barytes  Concrete        7      189    47.25    $84.00      $3,969 A    $110    $20,790    $24,759 Floor holding tank          Barytes  Concrete        7      189    47.25    $84.00      $3,969 A    $110    $20,790    $24,759 Bioshield                  Barytes  Concrete      71    1917    479.25    $84.00    $40,257 A'    $110  $210,870 . $251,127 Bioshield                  Barytes  Concrete      14      378      94.5    $84.00      $7,938 A    $110    $41,580    $49,518 Gate                                                        295        56    $84.00      $4,704 A    $110    $32,492    $37,196 Reactor Bridge                                            1552      240    $84.00    $20,160 A      $110  $170,690  $190,850*
Final Decon                                                  75    1040    $135.00  $140,400 A      $110      $8,250  $148,650 Guide Tube                                                    35        40    $84.00      $3,360 B  $1,000    $35,000  $38,360 Thermal Column Case                                          40        56    $84.00      $4,704 B  $1,000    -$40,000  $44,704 Cooling Plate                                                56      240    $84.00    $20,160 B    $1,000    $56,000  $76,160 6-in thru tube                                                40        40    $84.00      $3,360 B  $1,000    $40,000  $43,360 Startup Counter                                              12        8    $84.00        $672 B  $1,000    $12,000  $12,672 Grid Box                                                    150        84    $84.00      $7,056 B  $1,000  $150,357  $157,413 Ion Chamber                                                  33        16    $84.00      $1,344 B  $1,000    $33,103  $34,447 Guide Thimbles, etc                                        123        84    $84.00      $7,056 B  $1,000  $123,214  $130,270 Servo Shaft, rod & coupling                                  11      110    $84.00      $9,240 B  $1,000    $11,282  $20,522 Beam Tubes                                                  207      120    $84.00    $10,080 B    $1,000  $207,143  $217,223 Shutter Housing                                            162      160    $84.00    $13,440 B    $1,000  $162,414  $175,854 Fuel Rod End Pieces        Al                                10        1    $84.00        $84 B  $1,000    $10,000  $10,084 Graphite Reflectors                                          30        16    $84.00      $1,344 C  $1,000    $30,000  $31,344 Control Blade                                                22        8    $84.00        $672 C  $1,000    $22,143  $22,815 Thermal Column              Graphite/Al            40    1080      270    $84.00    $22,680 C    $1,000 $1,080,000 $1,102,680 Old Graphite Reflectors    Graphite/Al                      10        1    $84.00        $84 C  $1,000    $10,000  $10,084
                                                                                                    $0                    $0.        $0
                                                                                                    $0                    $0        $0
                                                                                                    $0                    $0        $0 Rad Con Support                                                    2000    $135.00    $270,000                          $270,000 Release Survey                                                      1040  $135.00    $140,400                          $140,400 2023                      $1,350,060            $5,738,688 $7,088,748 222492
* r,*,
Worker                                  Rate          Fringe  Hourly Rate Asbestos Worker                      $35.25          $19.88        $55.13 Hazardous Mtls Handler                $17.65          $9.95        $27.60 Stonemason                            $33.80          $18.45        $52.25 Carpenter                            $30.75          $19.94        $50.69 Millwright                            $31.75          $19.94        $51.69 Welder                                $31.75          $19.94        $51.69 Electrician                          $34.08          $18.18        $52.26 Laborer                              $27.10          $16.00        $43.10 Toxic Waste Remover                  $27.03          $19.10        $46.13 Power Equipment Operator              $31.25          $19.10        $50.35 Plumbers & Pipefitters                $33.61          $23.22        $56.83 Sheet Metal Worker                    $29.60          $22.61        $52.21 Truck Driver                          $26.66          $14.05        $40.71 Boilermaker                          $38.25          $17.04        $55.29 Operating Engineer                    $32.90          $19.10        $52.00 Elevator Mechanic                    $40.90          $18.28        $59.18 Stone Crusher                        $23.68          $19.10        $42.78 Crane Operator                        $28.05          $19.10        $47.15 Mechanic                              $25.63          $19.10        $44.73 Average                $49.04 Note: $84/hour provides approximately $35/hr more than the average prevailing rate for crafts in Rhode Island i Decon Technician                      $75.00          $34.50      $109.50 HP Technician                        $85.00          $39.10      $124.10 HP Supervisor                        $110.00          $50.60      $160.60
                                                                  $131.40 Note: Rates for decon tech, hp tech and hp supervisor based on contracted rates from Bartlett.


Base Case Cost Worksheet Craft Hour Cost Worksheet Summary Sheet ITEM Pool Base RX Floor around IR Base Gamma room floor Pool Liner grout to base Cleanup/demin walls Cleanup/demin walls Holdup Tank Walls Holdup Tank Walls Holdup Tank Walls Bio Shield/pool liner Around pool liner Bioshield Floor holding tank Bioshield Bioshield Gate Reactor Bridge Final Decon Guide Tube Thermal Column Case Cooling Plate 6-in thru tube Startup Counter Grid Box Ion Chamber Guide Thimbles, etc Servo Shaft, rod & coupling Beam Tubes Shutter Housing Fuel Rod End Pieces Graphite Reflectors Control Blade Thermal Column Old Graphite Reflectors Material Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Barytes Concrete Al Graphite/Al Graphite/Al Cu. Yds. Cu. Ft. Labor Hrs Labor Rate Labor Cost Class Rate RW Cost Total Cost 293 7911 135 3645 76 2052 35 945 3.5 95 7.5 203 26 702 2.5 68 4.5 122 299 8073 199 5373 7 189 7 189 71 1917 14 378 295 1552 75 35 40 56 40 12 150 33 123 11 207 162 10 30 22 40 1080 10 1977.75 $84.00 $166,131 A 911.25 $84.00 $76,545 A 513 $84.00 $43,092 A 236.25 $84.00 $19,845 A 23.625 $84.00 $1,985 A 50.625 $84.00 $4,253 A 175.5 $84.00 $14,742 A 16.875 $84.00 $1,418 A ,30.375 $84.00 $2,552 A 2018.25 $84.00 $169,533 A 1343.25 $84.00 $112,833 A 47.25 $84.00 $3,969 A 47.25 $84.00 $3,969 A 479.25 $84.00 $40,257 A'94.5 $84.00 $7,938 A 56 $84.00 $4,704 A 240 $84.00 $20,160 A 1040 $135.00 $140,400 A 40 $84.00 $3,360 B 56 $84.00 $4,704 B 240 $84.00 $20,160 B 40 $84.00 $3,360 B 8 $84.00 $672 B 84 $84.00 $7,056 B 16 $84.00 $1,344 B 84 $84.00 $7,056 B 110 $84.00 $9,240 B 120 $84.00 $10,080 B 160 $84.00 $13,440 B 1 $84.00 $84 B 16 $84.00 $1,344 C 8 $84.00 $672 C 270 $84.00 $22,680 C 1 $84.00 $84 C$0$0$0 2000 $135.00 $270,000 1040 $135.00 $140,400$110$110$110$110$110$110$110$110$110$110$110$110$110$110$110$110$110$110$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$1,000$870,210 $1,036,341
Summary Decommissioning Calculations Assumed Assumed      Assumed Decom Discount .Discount Rate escalation Rate Factor    Factor factor 0.05        .0285          0 Management Year  Maintenance &  PV Total      PV Total Supervision 1      $800,000    $5,866,092   $5,866,092 2       $840,000    $816,723      $840,000 3       $882,000     $833,796      $882,000 4      $231,525    $212,807      $231,525 5      $243,101    $217,255      $243,101 6      $255,256    $221,797      $255,256 7      $268,019    $226,433      $268,019 8      $281,420    $231,167      $281,420 9      $295,491    $235,999      $295,491 10      $310,266    $240,932      $310,266 11      $325,779    $245,969      $325,779 12       $342,068    $251,111      $342,068 13       $359,171    $256,360      $359,171 14      $377,130    $261,719      $377,130 15      $395,986    $267,190     $395,986 16      $415,786    $272,775      $415,786 17      $436, 575    $278,477      $436, 575 18      $458,404    $284,299      $458,404 19      $481,324    $290,242      $481,324 20       $505,390    $1,249,857    $2,131,778          Contingency Factors 0.25        0.32           0.60 Total   $12,760,999               $15,951,2 49 $16,780,714    $20,417,599 Total        $15,197,170 $18,996,4 63 $19,984,279   $24,315,473}}
$400,950 $477,495$225,720 $268,812$103,950 $123,795$10,395 $12,380$22,275 $26,528$77,220 $91,962$7,425 $8,843$13,365 $15,917$888,030 $1,057,563
$591,030 $703,863$20,790 $24,759$20,790 $24,759$210,870 .$251,127$41,580 $49,518$32,492 $37,196$170,690 $190,850*$8,250 $148,650$35,000 $38,360-$40,000 $44,704$56,000 $76,160$40,000 $43,360$12,000 $12,672$150,357 $157,413$33,103 $34,447$123,214 $130,270$11,282 $20,522$207,143 $217,223$162,414 $175,854$10,000 $10,084$30,000 $31,344$22,143 $22,815$1,080,000
$1,102,680
$10,000 $10,084$0. $0$0 $0$0 $0$270,000$140,400$5,738,688
$7,088,748 Rad Con Support Release Survey 2023 222492$1,350,060
* Worker Asbestos Worker Hazardous Mtls Handler Stonemason Carpenter Millwright Welder Electrician Laborer Toxic Waste Remover Power Equipment Operator Plumbers & Pipefitters Sheet Metal Worker Truck Driver Boilermaker Operating Engineer Elevator Mechanic Stone Crusher Crane Operator Mechanic Rate$35.25$17.65$33.80$30.75$31.75$31.75$34.08$27.10$27.03$31.25$33.61$29.60$26.66$38.25$32.90$40.90$23.68$28.05$25.63 Fringe$19.88$9.95$18.45$19.94$19.94$19.94$18.18$16.00$19.10$19.10$23.22$22.61$14.05$17.04$19.10$18.28$19.10$19.10$19.10 Hourly Rate$55.13$27.60$52.25$50.69$51.69$51.69$52.26$43.10$46.13$50.35$56.83$52.21$40.71$55.29$52.00$59.18$42.78$47.15$44.73$49.04 Average Note: $84/hour provides approximately
$35/hr more than the average prevailing rate for crafts in Rhode Island i Decon Technician
$75.00 $34.50 $109.50 HP Technician
$85.00 $39.10 $124.10 HP Supervisor
$110.00 $50.60 $160.60$131.40 Note: Rates for decon tech, hp tech and hp supervisor based on contracted rates from Bartlett.
Summary Decommissioning Calculations Assumed Decom escalation factor 0.05 Assumed Discount Rate Factor.0285 Assumed.Discount Rate Factor 0 Management Year Maintenance
&Supervision PV Total PV Total 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20$800,000$840,000$882,000$231,525$243,101$255,256$268,019$281,420$295,491$310,266$325,779$342,068$359,171$377,130$395,986$415,786$436, 575$458,404$481,324$505,390$5,866,092
$816,723$833,796$212,807$217,255$221,797$226,433$231,167$235,999$240,932$245,969$251,111$256,360$261,719$267,190$272,775$278,477$284,299$290,242$1,249,857
$12,760,999 Total$5,866,092
$840,000$882,000$231,525$243,101$255,256$268,019$281,420$295,491$310,266$325,779$342,068$359,171$377,130$395,986$415,786$436, 575$458,404$481,324$2,131,778 0.25$15,951,2$15,197,170  
$18,996,4 Contingency Factors 0.32 0.60 49 $16,780,714
$20,417,599 63 $19,984,279  
$24,315,473 Total}}

Latest revision as of 22:23, 13 November 2019

Response to Request for Additional Information Concerning Plans for Decommissioning Facility at the End of Useful Life Ref Item 3 Parts a, B, and C
ML100270176
Person / Time
Site: Rhode Island Atomic Energy Commission
Issue date: 01/19/2010
From: Mecca S
State of RI, Atomic Energy Comm, Nuclear Science Ctr
To: William Kennedy
Division of Policy and Rulemaking
References
Download: ML100270176 (7)
v • d • e


Text

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS P RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 Mr. William B. Kennedy, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 January 19, 2010 Re: Letter dated November 24, 2009 Docket No. 50-193

Dear Mr. Kennedy:

This is the third and final part of our response to your request for additional information concerning our plans for decommissioning the facility at the end of its useful life, ref item 3 parts a, b and c of the your letter. It should be noted that it is our expectation that the Reactor and the Center will safely operate for the duration of the extended license. As you are aware, the Reactor underwent a successful LEU upgrade in 1993 and during that process, significant safety analyses were performed to justify the redesign. During the intervening, years, the Commission has invested in all the upgrades necessary to keep the facility functioning in a safe and usable condition. That notwithstanding, the RINSC staff and the RI Atomic Energy Commission have refined our review of decommissioning options with the following underlying observations:

  • There are multiple planning scenarios possible, each with different costing elements.

" Some scenarios are hampered by the fact that we currently lack access to disposal of class B & class C wastes.

  • The actual scenario that would play out would depend on the context of state plans for the facility and the space it occupies at the time of a decommissioning decision.

" Decommissioning planning now should look at a typical scenario and plan for contingency funding to span the estimates of the range of likely costs for options available.

  • Current contingency figures were last assembled a decade ago and the NRC request has offered the opportunity for revisiting these figures.

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In developing a decommissioning plan, we considered the decommissioning alternative for what we can call a base case, including the major technical activities needed to carry out the decommissioning safely, Rhode Island's situation with regard to disposal of radioactive waste, residual radioactivity criteria to be used in the release of the facility and the location of our facility within theconfines of the Graduate School of Oceanography of the University Of Rhode Island. The aforementioned lack of access to disposal for Class B and C wastes severely limits our ability to reach a level of decontamination and removal of radioactive materials sufficient to allow the unconditional immediate release of the facility. Although this situation could change during the twenty-year license renewal period, we thought it prudent to assume that it wouldn't and plan accordingly.

We recognize that 10 CFR 50.82(b)(1)(ii) requires that a non-power reactor be decommissioned without significant delay, except when concern for public health and safety makes delay necessary. We noted that among the factors that may warrant a delay in decommissioning was unavailability of waste disposal facilities. We also noted that the Nuclear Regulatory Commission would not terminate our license until our facility met release criteria.

As a result of these considerations, we envisioned the following decommissioning scenario:

  • According to 10 CFR 50.82, two general approaches to decommissioning are acceptable. One approach is to start decommissioning activities soon after operations cease and proceed toward terminating the license and releasing the facility. The other approach is to perform limited decommissioning activities soon after operations cease to prepare the facility for safe storage and maintain safe conditions until we can remove the remaining radioactivity. We chose the latter and planned accordingly.
  • We will remove the fuel from the core as soon as possible after reactor operations permanently cease and ship the fuel off site in accordance with Department of Energy, Nuclear Regulatory Commission and Department of Transportation regulations.
  • We will hire a contractor to dismantle the remaining non-fuel components of the reactor, characterize their radioactivity levels and prepare them for either safe storage or shipment since many of them are anticipated to be Class B and C radioactive wastes for which Rhode Island has no viable disposal option at this time.

" We will ship those non-fuel components that characterization shows meet Class A radioactive waste criteria to a licensed processor for subsequent disposal. We used processing and disposal rates quoted by a broker for Class A radioactive wastes in our cost estimate.

  • We will store the remaining radioactive wastes until they can be safely and legally shipped for disposal. For costing purposes, we assumed that disposal of Class B and C radioactive wastes became available before decommissioning and estimated their cost based on current Barnwell rates.

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  • We will survey those areas of the facility that have been cleared of reactor components and, if Nuclear Regulatory Commission release criteria are met, release them for other uses.

To respond to your questions, we undertook a gross estimate of the decommissioning costs associated with the base case scenario. You should note that the resulting costs are a gross estimate with large uncertainties. We assumed that we would only remove the reactor itself leaving the building intact for possible other radioactive materials uses. We didn't include the costs of removing anything associated with the reactor that wasn't either contaminated or activated. Thus, for example, you won't find any estimated costs for removing the dump heat exchangers.

We have enclosed worksheets showing the cost estimate and labor rates (Exhibits 1 and 2 respectively) for the base case scenario. Craft hours are only for removal and packaging.

No transportation costs are included. Labor rates are estimates based on Rhode Island Department of Labor and "Rent-a-tech" rates. The methodology and numbers for the labor averages used are included in Exhibit 2.

As shown in the attached worksheet, the computed cost less management and operations fees is $7. 1M; the process would span between 2 and 4 years during which staffing is expected to remain at levels mandated by our license.: This would add between. $1.6M and $3.2M (without discounting or escalation) to the cost bringing the range for this base case scenario to $8.7M to $10.3M. We decided to compare these estimates to one based on the experience of other facility decommissioning costs or estimates. In preparing these experience-based estimates, six reactors were considered: Penn State, Georgia Tech, MIT, Watertown, Virginia and Ohio State. If the estimates for these are equally weighted, the average decommissioning cost is $13M; weighting Virginia's (a reactor closer to our own) estimate a bit higher and Army Watertown a bit lower, gives an estimate of $12M. Averaging this range and the range of our base case calculation, we observe a difference of some 31.5%, which is a bit higher than the contingency factor you have asked us to include in our final estimates.

To obtain an estimate of the more realistic costs of the decommissioning as envisioned with initial deconstruction, removal of present A wastes and subsequent removal of class B & C wastes when they decay to A class wastes, we began with the base case analysis and computed all costs out over 20 years, i.e. the time span of the pending relicense. This analysis is shown in Exhibit 3. Under a safe store scenario, one would incur disposal costs for B and C wastes as A wastes assumed to be an average of 20 years out. The results are shown in Exhibit 3. We have included a 5% per year inflationary rise in all decommissioning related costs, for the projected twenty years before we undertake final disposition. We noted that since 2001, the average consumer price index (CPI) has averaged about 2.85% but believe that an inflationary rate of 5% would more accurately reflect the costs associated with this type of project. In order to put all future costs in 2010 dollars, we show present values of total costs using discount rates of 2.85 % (the recent~historical CPI) and 0 % (no discounting). Note that staffing for management, monitoring and maintenance of required equipment is included. The Commission

estimated this residual (post initial deconstruction) staffing would be between 20 and 30% of the present staffing of the Center. A figure of 25% was used beginning in year 4 and continuing through year 20.

The results give present values of $12.8M and $15.2M for discount rates of 2.85% and 0 (no discounting) respectively. The last elements in this summary include contingency factors 25%, 31.5% and 60 %. The latter, which is the highest contingency we have noted in the experience of other reactors. The 25%-factor is the one you have asked us to use. 31.5% appears to be one that is consistent with our base case estimates and the aforementioned experience-ba'sed average noted earlier.

In summary, the Rhode Island Atomic Energy Commission is planning for the safe, successful and productive operation of our reactor and facilities for the duration of our license renewal. -Nevertheless we are pleased to offer this letter and supporting exhibits relating to decommissioning planning and estimations requested in your letter of November 24, 2009. Our best estimate for the present value of costs associated with a decommissioning scenario, involving initial deconstruction and disposal of A class wastes, Safe Store of B and - class wastes for the duration of the license and disposal of final wastes at the end of that period, is $16.8M in 2010 dollars. This includes a contingency factor of 31.5%, decommissioning related costs escalating at 5% and the use of a discount rate of 2.85%. The recent decommissioning contingency amount included in our annual budget is $30M; this allows for the extremes of the calculations shown plus a cushion for returning the site to readiness for another use.. It should be noted that the facility is built on a former gun mount, which would require significant demolition work to return, to remove. We will expect to review these estimates .periodically during the term of our license especially at times when the context of all'waste disposal options has changed..'

Very truly yours, Stephen Mecca, Ph.D., Chairman Rhode Island Atomic Energy Commission I certify under penalty of perjury that the representations made above are true and correct.

Executed on: -'oBBy:

Enclosures:

Base Case Cost Worksheet Craft Hour Cost Worksheet Summary Sheet

ITEM Material Cu. Yds. Cu. Ft. Labor Hrs Labor Rate Labor Cost Class Rate RW Cost Total Cost Pool Base Barytes Concrete 293 7911 1977.75 $84.00 $166,131 A $110 $870,210 $1,036,341 RX Floor around IR Base Barytes Concrete 135 3645 911.25 $84.00 $76,545 A $110 $400,950 $477,495 Gamma room floor Barytes Concrete 76 2052 513 $84.00 $43,092 A $110 $225,720 $268,812 Pool Liner grout to base Barytes Concrete 35 945 236.25 $84.00 $19,845 A $110 $103,950 $123,795 Cleanup/demin walls Barytes Concrete 3.5 95 23.625 $84.00 $1,985 A $110 $10,395 $12,380 Cleanup/demin walls Barytes Concrete 7.5 203 50.625 $84.00 $4,253 A $110 $22,275 $26,528 Holdup Tank Walls Barytes Concrete 26 702 175.5 $84.00 $14,742 A $110 $77,220 $91,962 Holdup Tank Walls Barytes Concrete 2.5 68 16.875 $84.00 $1,418 A $110 $7,425 $8,843 Holdup Tank Walls Barytes Concrete 4.5 122 ,30.375 $84.00 $2,552 A $110 $13,365 $15,917 Bio Shield/pool liner Barytes Concrete 299 8073 2018.25 $84.00 $169,533 A $110 $888,030 $1,057,563 Around pool liner Barytes Concrete 199 5373 1343.25 $84.00 $112,833 A $110 $591,030 $703,863 Bioshield Barytes Concrete 7 189 47.25 $84.00 $3,969 A $110 $20,790 $24,759 Floor holding tank Barytes Concrete 7 189 47.25 $84.00 $3,969 A $110 $20,790 $24,759 Bioshield Barytes Concrete 71 1917 479.25 $84.00 $40,257 A' $110 $210,870 . $251,127 Bioshield Barytes Concrete 14 378 94.5 $84.00 $7,938 A $110 $41,580 $49,518 Gate 295 56 $84.00 $4,704 A $110 $32,492 $37,196 Reactor Bridge 1552 240 $84.00 $20,160 A $110 $170,690 $190,850*

Final Decon 75 1040 $135.00 $140,400 A $110 $8,250 $148,650 Guide Tube 35 40 $84.00 $3,360 B $1,000 $35,000 $38,360 Thermal Column Case 40 56 $84.00 $4,704 B $1,000 -$40,000 $44,704 Cooling Plate 56 240 $84.00 $20,160 B $1,000 $56,000 $76,160 6-in thru tube 40 40 $84.00 $3,360 B $1,000 $40,000 $43,360 Startup Counter 12 8 $84.00 $672 B $1,000 $12,000 $12,672 Grid Box 150 84 $84.00 $7,056 B $1,000 $150,357 $157,413 Ion Chamber 33 16 $84.00 $1,344 B $1,000 $33,103 $34,447 Guide Thimbles, etc 123 84 $84.00 $7,056 B $1,000 $123,214 $130,270 Servo Shaft, rod & coupling 11 110 $84.00 $9,240 B $1,000 $11,282 $20,522 Beam Tubes 207 120 $84.00 $10,080 B $1,000 $207,143 $217,223 Shutter Housing 162 160 $84.00 $13,440 B $1,000 $162,414 $175,854 Fuel Rod End Pieces Al 10 1 $84.00 $84 B $1,000 $10,000 $10,084 Graphite Reflectors 30 16 $84.00 $1,344 C $1,000 $30,000 $31,344 Control Blade 22 8 $84.00 $672 C $1,000 $22,143 $22,815 Thermal Column Graphite/Al 40 1080 270 $84.00 $22,680 C $1,000 $1,080,000 $1,102,680 Old Graphite Reflectors Graphite/Al 10 1 $84.00 $84 C $1,000 $10,000 $10,084

$0 $0. $0

$0 $0 $0

$0 $0 $0 Rad Con Support 2000 $135.00 $270,000 $270,000 Release Survey 1040 $135.00 $140,400 $140,400 2023 $1,350,060 $5,738,688 $7,088,748 222492

  • r,*,

Worker Rate Fringe Hourly Rate Asbestos Worker $35.25 $19.88 $55.13 Hazardous Mtls Handler $17.65 $9.95 $27.60 Stonemason $33.80 $18.45 $52.25 Carpenter $30.75 $19.94 $50.69 Millwright $31.75 $19.94 $51.69 Welder $31.75 $19.94 $51.69 Electrician $34.08 $18.18 $52.26 Laborer $27.10 $16.00 $43.10 Toxic Waste Remover $27.03 $19.10 $46.13 Power Equipment Operator $31.25 $19.10 $50.35 Plumbers & Pipefitters $33.61 $23.22 $56.83 Sheet Metal Worker $29.60 $22.61 $52.21 Truck Driver $26.66 $14.05 $40.71 Boilermaker $38.25 $17.04 $55.29 Operating Engineer $32.90 $19.10 $52.00 Elevator Mechanic $40.90 $18.28 $59.18 Stone Crusher $23.68 $19.10 $42.78 Crane Operator $28.05 $19.10 $47.15 Mechanic $25.63 $19.10 $44.73 Average $49.04 Note: $84/hour provides approximately $35/hr more than the average prevailing rate for crafts in Rhode Island i Decon Technician $75.00 $34.50 $109.50 HP Technician $85.00 $39.10 $124.10 HP Supervisor $110.00 $50.60 $160.60

$131.40 Note: Rates for decon tech, hp tech and hp supervisor based on contracted rates from Bartlett.

Summary Decommissioning Calculations Assumed Assumed Assumed Decom Discount .Discount Rate escalation Rate Factor Factor factor 0.05 .0285 0 Management Year Maintenance & PV Total PV Total Supervision 1 $800,000 $5,866,092 $5,866,092 2 $840,000 $816,723 $840,000 3 $882,000 $833,796 $882,000 4 $231,525 $212,807 $231,525 5 $243,101 $217,255 $243,101 6 $255,256 $221,797 $255,256 7 $268,019 $226,433 $268,019 8 $281,420 $231,167 $281,420 9 $295,491 $235,999 $295,491 10 $310,266 $240,932 $310,266 11 $325,779 $245,969 $325,779 12 $342,068 $251,111 $342,068 13 $359,171 $256,360 $359,171 14 $377,130 $261,719 $377,130 15 $395,986 $267,190 $395,986 16 $415,786 $272,775 $415,786 17 $436, 575 $278,477 $436, 575 18 $458,404 $284,299 $458,404 19 $481,324 $290,242 $481,324 20 $505,390 $1,249,857 $2,131,778 Contingency Factors 0.25 0.32 0.60 Total $12,760,999 $15,951,2 49 $16,780,714 $20,417,599 Total $15,197,170 $18,996,4 63 $19,984,279 $24,315,473

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