ML15061A230: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(9 intermediate revisions by the same user not shown)
Line 1: Line 1:
{{Adams
#REDIRECT [[ZS-2015-0034, License Termination Plan Update of the Site-Specific Decommissioning Costs]]
| number = ML15061A230
| issue date = 02/26/2015
| title = Zion Nuclear Power Station, Units 1 and 2 - License Termination Plan Update of the Site-Specific Decommissioning Costs
| author name = VanNoordennen G P
| author affiliation = ZionSolutions, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS
| docket = 05000295, 05000304
| license number = DPR-039, DPR-048
| contact person =
| case reference number = ZS-2015-0034
| package number = ML15061A281
| document type = Letter
| page count = 23
}}
 
=Text=
{{#Wiki_filter:ZIONSOLUTIONSLLCAn EnergySodtona Comp.ny10 CFR 50.82 (a)(9)(i)10 CFR 50.82 (a)(9)(ii)(F)10 CFR 50.4(b)(1)10 CFR 2.390(a)(4)February 26, 2015 ZS-2015-0034U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Zion Nuclear Power Station, Units 1 and 2Facility Operating License Nos. DPR-39 and DPR-48NRC Docket Nos. 50-295 and 50-304
 
==Subject:==
License Termination Plan Update of the Site-Specific Decommissioning Costs
 
==Reference:==
: 1) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear RegulatoryCommission, "License Amendment Request for the License Termination Plan", datedDecember 19, 2014Portions of this submittal provide the Nuclear Regulatory Commission (NRC) with financialinformation owned by ZionSolutions, LLC (ZS) to aid in the review of the Zion Nuclear PowerStation (ZNPS) License Termination Plan (LTP). ZS considers this proprietary financialinformation to be confidential and requests NRC to withhold it from public disclosure under10 CFR 2.390(a)(4).Attachment 1 of this submittal consists of ZionSolutions Proprietary Financial InformationAffidavit pursuant to 10 CFR 2.390. The Affidavit sets forth the basis for which the informationmay be withheld from public disclosure by the Commission and addresses with specificity theconsiderations listed in 10 CFR 2.390(b)(4). All documents within the scope of this affidavit aremarked as "withhold from public disclosure under 10 CFR 2.390."As committed to in Reference 1, ZionSolutions is submitting proposed Chapter 7 of the ZNPSLTP titled, "Update of the Site-Specific Decommissioning Costs." The submittal is due no laterthan February 27, 2015. All other ZNPS LTP Chapters were previously submitted in theReference 1 correspondence. The associated TLG Services, Inc. decommissioning cost estimatewill be available upon request by the NRC staff.Attachment 2 provides Chapter 7 of the ZNPS LTP for NRC review and approval. Inaccordance with 10 CFR 50.82(a)(9)(i), Chapter 7 of the ZNPS LTP is being submitted as asupplement to the Defueled Safety Analysis Report (DSAR), and is being maintainedaccordingly. In accordance with 10 CFR 50.82 (a)(9)(ii)(F), Chapter 7 provides an updated site-specific estimate of the remaining decommissioning costs.101 Shiloh Boulevard, Zion -IL 60099(224) 789-4016 -Fax: (224) 789-4008 -www.zionsolutionscompany.com ZionSolutions, LLCZS-2015-0034Page 2 of 2Attachment 2 of this submittal contains the proprietary financial information ZS is providing tothe NRC and seeks to have withheld from public disclosure in its entirety. The informationprovided includes updated financial data to aid in the NRC's review of the ZNPS LTP.Attachment 3 of this submittal contains a redacted version of ZNPS LTP Chapter 7 for publicdisclosure.There are no regulatory commitments made in this submittal. If you should have any questionsregarding this submittal, please contact me at (224) 789-4025.I declare under penalty of perjury that the foregoing is true and correct.Executed on February 26, 2015.Respectfully,Gerard van NoordennenVice President Regulatory AffairsAttachments:1) Attachment 1: ZionSolutions, LLC Proprietary Financial Information Affidavit2) Attachment 2: LTP Chapter 7, "Update of the Site-Specific Decommissioning Costs"(Proprietary)3) Attachment 3: LTP Chapter 7 Redacted Version, "Update of the Site-SpecificDecommissioning Costs" (Non-Proprietary)cc: John Hickman, U.S. NRC Senior Project ManagerService List (without Attachment 2)  ZIONSOLUTIONS, LLC PROPRIETARY FINANCIAL INFORMATION AFFIDAVITAffidavit of Gerard van Noordennen, Vice President Regulatory Affairs, ZionSolutions, LLC.Attachment 2 of this submittal consists of proprietary financial information that ZionSolutions, LLCconsiders confidential. Release of this information would cause irreparable harm to the competitiveposition of ZionSolutions, LLC. The basis for this declaration is:i. This information is owned and maintained as proprietary by ZionSolutions, LLC,ii. This information is routinely held in confidence by ZionSolutions, LLC and not disclosed tothe public,iii. This information is being requested to be held in confidence by the NRC by this petition,iv. This information is not available in public sources,v. This information would cause substantial harm to ZionSolutions, LLC if it were releasedpublicly, because it would reveal confidential pricing information that competitors could useto the detriment of ZionSolutions and its affiliates in bidding for decommissioning work, orthat could be used to the detriment of ZionSolutions in contract negotiations, andvi. The information to be withheld is being transmitted to NRC in confidence.I, Gerard van Noordennen , being duly sworn, state that I am the person who subscribes my name theforegoing statement, I am authorized to execute the Affidavit on behalf of ZionSolutions, LLC, andthat the matters and facts set forth in the statement are true to the best of my knowledge, information,and belief.Name: Gerard van NoordennenTitle: Vice President Regulatory AffairsCompany: ZionSolutions, LLCSWORN TO AND SUBSCRIBED BEFORE METHIS 26th DAY of February 2015 LNDA CHOUOFFICIAL SEALNotary Public, Stats of IllinoisMy Commission ExpiresDecember 07. 2015LINDA CHOU Zion Nuclear Power Station, Unit 1 and 2 License Transfer Service Listcc:John ChristianPresident Logistics Processing andDisposal GroupEnergySolutions1750 Tysons Boulevard, Suite 1500McLean, VA 22102John SaugerExecutive VP & General ManagerZionSolutions, LLC101 Shiloh BoulevardZion, IL 60099Gerard van NoordennenVP Regulatory AffairsZionSolutions, LLC101 Shiloh BoulevardZion, IL 60099Anthony OrawiecDecommissioning Plant ManagerZionSolutions, LLC101 Shiloh BoulevardZion, IL 60099Dan ShrumSenior VP Regulatory AffairsEnergySolutions423 West 300 South, Suite 200Salt Lake City, UT 84101Russ WorkmanGeneral CounselEnergySolutions423 West 300 South, Suite 200Salt Lake City, UT 84101Alwyn C. SettlesSection Head, Nuclear Facility InspectionBureau of Nuclear Facility SafetyIllinois Emergency Management Agency1011 North St., PO Box 250Mazon, IL 60444Kelly F. GrahnSenior Health Physicist, Unit SupervisorBureau of Radiation Safety, EnvironmentalManagementIllinois Emergency Management Agency245 W Roosevelt Road, Building 8, Suite 55West Chicago, IL 60185Kent McKenzieEmergency Management CoordinatorLake County Emergency ManagementAgency1303 N. Milwaukee AvenueLibertyville, IL 60048-1308Regional AdministratorU.S. NRC, Region III2443 Warrenville RoadLisle, IL 60532-4352John E. MatthewsMorgan, Lewis & Bockius LLP1111 Pennsylvania Avenue, NWWashington, DC 20004 REDACTED VERSION FOR PUBLIC DISCLOSUREAttachment 3LTP Chapter 7, "Update of the Site-Specific Decommissioning Costs"REDACTED VERSION FOR PUBLIC DISCLOSURE ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLANSECTION 7UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN ZIONSOLUTIONSr--TABLE OF CONTENTS7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS ............................... 7-17 .1. In tro du ctio n ................................................................................................................... 7-17.1.1. Cost Estimates Previously Docketed with the NRC .............................................. 7-27.2. D ecom m issioning Cost Estim ate .................................................................................. 7-27.2.1. Cost Estimate Description and Methodology ........................................................ 7-37.2.2. Summary of the Site-Specific Decommissioning Cost Estimate ........................... 7-37.2.3. Radiological Decommissioning Costs ................................................................... 7-47.2.3.1. C lass A Large C om ponents ............................................................................. 7-67.2.3.2. C lass A B ulk M aterials .................................................................................... 7-67.2.3.3. C lass A Containerized W astes ......................................................................... 7-67.2.3.4. C lass B /C W aste .............................................................................................. 7-67.2.4. Spent Fuel M anagem ent Costs ............................................................................... 7-77.2.5. Site R estoration C osts ............................................................................................ 7-87.2 .6. C ontingency ........................................................................................................... 7-97.3. D ecom m issioning Funding Plan ................................................................................... 7-97 .4 .R eferen ces ................................................................................................................... 7-1 1LIST OF TABLESTable 7-1 Cost for Radiological Decommissioning, Spent Fuel Management, and SiteR estoration ............................................................................................................. 7-4Table 7-2 Estimated Base Radiological Decommissioning Cost by Resource Category ...... 7-5Table 7-3 Estimated Radiological Decommissioning Cost by Major Project Activity ......... 7-5Table 7-4 Estimated Base Spent Fuel Management Cost by Major Resource ....................... 7-8Table 7-5 Estimated Site Restoration Cost by Major Resource Category ............................. 7-9Table 7-6 Detailed Breakdown of Radiological Decommissioning Costs by ResourceR equirem ent ........................................................................................................ 7-12Table 7-7 Detailed Breakdown of Radiological Decommissioning Costs byD ecom m issioning A ctivity .................................................................................. 7-13Table 7-8 Detailed Breakdown of Spent Fuel Management Costs byR esource R equirem ent ........................................................................................ 7-14Table 7-9 Detailed Breakdown of Site Restoration Costs by Resource Requirement ......... 7-157-i ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS-=-LIST OF ACRONYMS AND ABBREVIATIONSComnEd Commonwealth EdisonExelon Exelon CorporationFRS Final Radiation SurveyFSAR Final Safety Analysis ReportGTCC Greater Than Class CISFSI Independent Spent Fuel Storage InstallationLTP License Termination PlanNRC Nuclear Regulatory CommissionPSDAR Post-Shutdown Decommissioning Activities ReportTLG TLG Services, Inc.WCS Waste Control SpecialistsZNPS Zion Nuclear Power StationZSRP Zion Station Restoration Project7-ii ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS&#xfd;,=7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS7.1. IntroductionIn accordance with 10 CFR 50.82(a)(9)(ii)(F) (Ref 7-1) and Regulatory Guide 1.179 (Ref 7-2),the updated site specific cost estimates and funding plans for the Zion Station Restoration Project(ZSRP) are provided. Regulatory Guide 1.179 provides guidance on the details of theinformation to be presented in the License Termination Plan (LTP).The LTP must provide an estimate of the remaining decommissioning costs at the time of LTPsubmittal and also compare these estimated costs with the present funds set aside fordecommissioning. If it is determined that there is a deficit in the present funding, the LTP mustindicate the means for ensuring that adequate funds are available to complete thedecommissioning.The decommissioning cost estimate, at a minimum, needs to include an evaluation of thefollowing cost elements:* Cost assumptions used, including contingency factor;* Major decommissioning activities and tasks;* Unit cost factors;* Estimated costs of decontamination and removal of equipment and structures;* Estimated costs of waste disposal, including disposal site surcharges;* Estimated Final Radiation Survey (FRS) costs; and* Estimated total costs.The cost estimate should focus on the remaining work, detailed activity by activity, includingcosts of labor, materials, equipment, energy, and services. The cost estimate should include thecost of the planned remediation activities as well as the cost of the transportation and disposal ofthe waste generated by the remedial work conducted.Historical PerspectiveBy 1998, Exelon Corporation (Exelon), formerly Commonwealth Edison Company, or CoinEd,had completely shut down the two unit Zion Nuclear Power Station (ZNPS) and made plans toimplement a delayed-DECON decommissioning scenario, with decommissioning expected tocommence at the original license expiration date (November 14, 2013). As part of its postshutdown planning, Exelon contracted a specialty decommissioning consultant, TLG Services,Inc. (TLG) to develop a decommissioning cost estimate for the ZNPS Units I and 2. This costestimate was provided with the Post-Shutdown Decommissioning Activities Report (PSDAR)(Ref 7-3) Exelon submitted in 2000 to the NRC.Exelon later entered into discussions with EnergySolutions for the possible transfer of the ZNPSlicenses and the decommissioning fund to EnergySolutions to accelerate the decommissioning ofthe plant. As part of its application for the license transfers, ZionSolutions, LLC, a whollyowned subsidiary of EnergySolutions, amended the PSDAR and submitted it to the NRC in2008. This amended PSDAR provided significant decommissioning cost milestone changes andan estimate of expected decommissioning costs.7-1 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS -The license transfers were completed and ZionSolutions started decommissioning operations bySeptember 2010. In compliance with 10 CFR 50.75(f)(1) (Ref 7-4) and 10 CFR 50.82(a)(8)(v)-(viii), ZionSolutions continues to demonstrate financial assurance on an annual basis.7.1.1. Cost Estimates Previously Docketed with the NRCExelon submitted its PSDAR to the NRC on February 14, 2000. As previously noted, inaccordance with 10 CFR 50.82(a)(8)(iii), a Zion site-specific decommissioning cost estimate wasalso prepared and submitted in a letter dated February 14, 2000 (Ref 7-5). This submittal,docketed with the NRC, included an Attachment, "Zion Nuclear Power Station Units I and 2Site-Specific Decommissioning Cost Estimate" which was the cost estimate study prepared byTLG.During the process of ZionSolutions, LLC's application to take over the licenses of Zion Units 1and 2 from Exelon, ZionSolutions submitted an Amended PSDAR, including an estimate ofexpected decommissioning costs, on March 18, 2008. This submittal was also docketed with theNRC.7.2. Decommissioning Cost EstimateThe decommissioning cost estimate presented herein represents the cost to complete theremaining decommissioning work as of the end of the 3rd quarter 2014. This estimate wasprepared based upon the schedule of the remaining work, incorporating the experience that hasbeen gained while performing similar decommissioning tasks over the past four years. To a largeextent, this decommissioning cost estimate is based upon an existing and operatingdecommissioning organization, in which actual contracts for services are already in place. Assuch, there is a high degree of certainty regarding expected work productivity, the cost of laborand the cost of services required to support the remainder of the project. The decommissioningcost estimate also includes application of contingency, as specific provision for unforeseeableelements of cost within the defined project scope. Contingencies are particularly importantwhere previous experience has shown that unforeseeable events, which may increase costs, arelikely to occur. The contingency, as used in this estimate, does not account for price escalationand inflation in the costs of decommissioning over the remaining project duration.The cost estimate was prepared to include all costs associated with the decommissioning andunrestricted release of the Zion site other than the area bounded by the Independent Spent FuelStorage Installation (ISFSI), and includes radiological decommissioning (i.e., those costsrequired to accomplish such unrestricted release), spent fuel management (transfer of the spentfuel to the ISFSI and operation of the ISFSI until the partial site release is achieved, at whichtime the released portion of the site and the remaining ISFSI will be transferred back to Exelon),and site restoration (i.e., non-radiological remediation aimed at leaving the site in a safe andstable condition). As was reflected in the Application relating to the transfer of the Zion licensesto ZionSolutions, Exelon has retained title to the spent fuel and Greater Than Class C (GTCC)waste, as well as the obligation for ultimate disposition of the spent fuel and the GTCC waste inthe ISFSI and the decommissioning of the ISFSI.The site-specific decommissioning cost estimate provided with this LTP has been prepared as acollaborative effort by ZionSolutions and TLG and presents a breakdown of the remaining costs7-2 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS.-to complete the decommissioning process and release all portions of the site for unrestrictedrelease, with the exception of the area bounded by the ISFSI.The following subsections present a description of how the cost estimate was prepared and asummary and breakdown of the estimated costs.7.2.1. Cost Estimate Description and MethodologyDuring the summer and fall of 2014, the ZionSolutions decommissioning project organizationundertook an effort to update the baseline schedule, risks and the costs to complete thedecommissioning project. This resulted in a revised work breakdown structure that provided adetailed listing of the remaining work activities and support services needed to complete theproject. Task durations, crew compositions and material and contracted services needs werederived from the results of detailed process planning carried out by each of the decommissioningand support organizations (e.g., decommissioning operations, engineering, security, radiationprotection, radiological engineering, waste management, safety, FRS, etc.).Additionally, ZionSolutions performed a contingency and risk analysis so that the potentialadditional costs due to expected but undefined risks and uncertainties could be addressed andincluded in the cost estimate.The resulting information was then compiled into a decommissioning cost estimate by TLG. Thefollowing sections provide a summaiy of those results.7.2.2. Summary of the Site-Specific Decommissioning Cost EstimateThe overall remaining decommissioning cost (including scope risk contingency) was estimatedto be $389 Million (in year of expenditure dollars), with a base estimated cost of $358 Million(without the scope risk contingency). The cost estimates include provisions for cost escalationbased upon the following assumptions:* Labor costs are assumed to escalate at 1.992% per year, this cost escalation factor beingbased on the forecast of the Consumer Price Index, Services, CUSASNS as published byGlobal Insight Company, and applied per the Zion project Asset Sale Agreement." Non-Labor costs that are not covered by fixed prices, fixed rates or escalation provisionsin contractual agreements, are similarly assumed to escalate at 1.992% per year, this costescalation factor being based on the Consumer Price Index, Services, CUSASNS aspublished by Global Insight Company, and applied per the Zion project Asset SaleAgreement." For Class A and Class B&C waste costs, ZionSolutions has largely mitigated thisescalation risk by having a fixed price arrangement with EnergySolutions (Class A) andcontractually defined costs for B/C waste.The cost estimate includes the costs for radiological decommissioning, spent fuel management,and site restoration. A breakout of the cost for each part of the decommissioning program isprovided in Table 7-1.7-3 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS.=Table 7-1 Cost for Radiological Decommissioning, Spent Fuel Management,and Site RestorationRadiological Spent FuelDecommissioning Management*Baseamu $284.3 Million $37.4 Million $36.2 MillionAmountContingency $24.7 Million $3.3 Million $3.2 MillionTotal $309.0 Million $40.7 Million* $39.4 Million**included for completeness, but not required for license termination funding purposes.Detailed breakdowns of the estimated costs for radiological decommissioning, spent fuelmanagement and site restoration programs are provided in sections 7.2.3, 7.2.4 and 7.2.5,respectively. Section 7.2.6 presents the estimated contingency costs for each of these programs.7.2.3. Radiological Decommissioning CostsConsistent with the NRC definition of decommissioning under 10 CFR 50.2, the radiologicaldecommissioning costs under this category consider only those costs associated with normaldecommissioning activities necessary for release of the site (other than the ISFSI) forunrestricted use. It does not include costs associated with the disposal of non-radiologicalmaterials or structures beyond those necessary to terminate the Part 50 license or the costsassociated with construction or operation of an ISFSI.As summarized in section 7.2.2 above, the total estimated cost for radiological decommissioning,including contingency is $309 Million. The estimated cost for the anticipated base work scope is$284.3 Million. Application of a contingency of $24.7 Million results in a total estimated cost of$309 Million.The remaining decommissioning scope of work included in this estimate is described in detail inother chapters of this LTP. Overall, that work scope includes completion of the removal,transportation and disposal of the major components; completion of the removal, transportationand disposal of the remaining equipment; decontamination and/or bulk demolition ofradiological impacted structures and transportation and disposal of the resulting radioactivewastes; performance of the FRS and associated license termination activities. The estimatedcosts include the labor, equipment, materials, services and fees needed to conduct the work. Theestimated cost also includes all of the program support activities and services necessary tomanage and safely carry out a large scale dismantlement and demolition project. These programsupport activities include project management, work controls and site administration; technicalsupport services, such as radiation protection, safety, engineering, security, QA/QC,environmental monitoring, waste management and decommissioning subject matter expertsneeded to support the project.A high level breakdown of the estimated base radiological decommissioning cost, by majorresource category, is provided in Table 7-2.07-4 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN:ZIONSOLUTIONS;7,Table 7-2 Estimated Base Radiological Decommissioning Cost by Resource CategoryLabor $119.8 Million (b)Equipment, Materials and Supplies $24.9 MillionFixed- Price Contracts, Services & Fees $55.5 MillionRadioactive Waste Packaging, Transportation & Disposal $84.1 MillionTotal (c) $284.3 Million(b) Includes contracted specialty labor costs(c) Columns may not add due to roundingA high level breakdown of the estimated radiological decommissioning cost, alternatively bymajor project activity, is provided in Table 7-3.Table 7-3 Estimated Radiological Decommissioning Cost by Major Project ActivityMajor Component Removal $30.8 MillionEquipment and Structure Decontamination / Removal $63.8 MillionWaste Disposition $84.1 MillionProgram Management and Support Services (excluding Final Status $75.7 MillionSurvey and License Termination Activities)Final Radiation Survey and License Termination Activities $8.0 MillionOther Lump-Sum Costs (e.g., regulatory fees, financing) $21.9 MillionTotal (a) $284.3 Million(a) Columns may not add due to roundingA more detailed breakdown of the costs by resource requirements (e.g., labor, materials,services, etc.) and by decommissioning activity (e.g., component removal, structuraldecontamination, program support functions, waste management functions, etc.) are provided inTables 7-6 and 7-7 respectively.The total estimated cost for radioactive waste disposition (containers, transportation anddisposal) is $84.1 Million. As presented in Table 7-7, these waste management costs arecomprised of four distinct categories; Class A Large Components, Class B/C Waste, Class AContainerized Wastes and Class A Bulk Materials. Costs for on-site handling of GTCC waste(i.e., reactor vessel internals) are included in the "Major Component Removal" category shown7-5 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONSU---on Table 7-7. However, no costs for disposal of this waste is included in the estimate, as it isassumed that disposal of this waste will be included as a part of spent fuel disposition.The project has in place a unique contracting approach for disposal of the resulting radioactivewastes that eliminates much of the cost uncertainty and waste volume estimation risk that isoften associated with decommissioning projects. As such, the reported waste management costsare unlikely to vary due to waste volume uncertainties. The resulting radioactive waste streamsand the disposal and transportation contracts that are in place can be categorized by thefollowing:7.2.3.1. Class A Large ComponentsThis category of waste includes equipment that will be transported and disposed of intact,enclosed in rail cars or prepared to serve as its own waste container. These items have beenradiologically and physically characterized. As such, the inventory of these items and theirdisposal volumes are known. The associated waste management costs are covered by existingfixed-price contracts with EnergySolutions. Therefore, the waste mana ement costs for theseitems are well known and not ie ov7.2.3.2. Class A Bulk MaterialsThis category of waste primarily consists of concrete rubble or similar materials contaminatedwith very low levels of radioactivity (and large components described above). This material willbe transported in covered gondola rail cars to the EnergySolutions disposal site in Clive, Utah.The cost for disposal and transportation of this material is covered by a fixed-price contract thatcovers any and all material of this type from this decommissioning project, without regard to thetotal mass or volume. Therefore, these costs are known and are unlikely to vary. This category ofwaste comprises > 95% of the total volume and mass and > 80% of the estimated wastemanagement costs for all radioactive waste expected to be generated by this decommissioningeffort.7.2.3.3. Class A Containerized WastesThis category of waste primarily consists of material that will need to be packaged in strong-tight/ Industrial containers, such as intermodals or steel boxes. Typically, this would include smallpieces of contaminated equipment, pipe or debris which require containerization to meet DOTregulations or mitigate radiological handling concerns. This material will be trans orted b rail,for disposal at the EnergySolutions disposal site in Clive, Utah.I I7.2.3.4. Class B/C WasteThis category of waste is primarily composed of segmented pieces of the activated reactorinternals and, to a much lesser extent, higher radioactivity level resins, filters, sludge and cuttingfines. These materials will require packing in liners or high integrity containers, and transported7-6 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS -in shielded licensed transportation casks by truck to the Waste Control Specialists (WCS) facilityin Andrews, Texas. The volume (or mass) of this waste material is well known, characterized,and will be generated from a limited set of reactor components.Disposal cost variability for thiscategory of waste has been largely mitigated by established contractual terms in place withWCS.7.2.4. Spent Fuel Management CostsZionSohltions acknowledges that the costs to construct and operate an ISFSI (previously defined)and other spent fuel related management costs are not considered by the NRC staff as part ofdecommissioning costs. Nevertheless, as there is significant interest by many stakeholders inthese costs, they are presented herein. As presented in Section 7.2.2 above, the estimated cost forthe anticipated base work scope is $37.4 Million. A contingency of $3.3 Million was appliedresulting in total spent fuel management costs of $40.7 Million.Overall, the spent fuel management work scope includes transfer of the remaining spent fuel tothe ISFSI and operation of the ISFSI until termination of the reactor license, with the exceptionof the area bounded by the ISFSI, projected to take place in 2019.Construction of the ISFSI was completed in April 2013 and spent fuel transfer operations werestarted by December 2013 with the first spent fuel cask being placed on the ISFSI in earlyJanuary 2014. As of the end of September 2014, approximately 64% of the spent fuel has beentransferred to the ISFSI, contained in 39 dry storage casks on the ISFSI pad. Note that spent fueltransfer was completed on January 10, 2015.The estimated costs include the labor, equipment, materials, services, fees, and program supportactivities necessary to safely manage the spent nuclear fuel. ISFSI operational costs areestimated through mid-year 2019, when partial site release and the transfer of the site and ISFSIback to Exelon are expected, and subsequent management of the spent fuel is consistent with theIrradiated Fuel Management Plan for Zion under 10 CFR 50.54 (bb) (Ref 7-6). Exelon hasprovided a decommissioning funding plan to the NRC for the Zion ISFSI (Ref 7-7).A high level breakdown of the estimated base spent fuel management cost, by major resourcecategory, is provided in Table 7-4.7-7 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLANZIONSOLUTIONS;T,Table 7-4 Estimated Base Spent Fuel Management Cost by Major ResourceLabor 1$29.9 Million (b)Equipment, Materials and Supplies $1.3 MillionFixed- Price Contracts, Services & Fees $6.2 MillionRadioactive Waste Packaging, Transportation & Disposal $0Total (c) $37.4 Million(b) Includes contracted specialty labor costs(c) Columns may not add due to roundingA more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services,etc.) is provided in Table 7.8.7.2.5. Site Restoration CostsZionSolutions acknowledges that the costs to restore the Zion Plant property are not consideredby the NRC staff as part of decommissioning costs. Nevertheless, there is significant interest bymany stakeholders in these costs and they are presented herein. The estimated cost for theanticipated work scope is $36.2 Million. A contingency of $3.2 Million was estimated, bringingthe total to $39.4 Million. Overall, that work scope includes removal of any remaining hazardousmaterials, demolition of remaining structures, backfilling of any open excavations or voidspaces, and final grading and stabilization against erosion.The estimated costs include the labor, equipment, materials, services and fees needed to conductthe work. In general, most of this work is anticipated to be performed by contractors; howeverthe estimated cost also includes all of the program support activities and services necessary tomanage and safely carry out project.A high level breakdown of the estimated site restoration cost, by major resource category, isprovided in Table 7-5.7-8 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS- =-Table 7-5 Estimated Site Restoration Cost by Major Resource CategoryLabor 1$58.8 Million (b)Equipment., Materials and Supplies $0.71 MillionFixed- Price Contracts, Services & Fees $29.7 MillionRadioactive Waste Packaging, Transportation & Disposal $0Total (c) $36.2 Million(b) Includes contracted specialty labor costs(c) Columns may not add due to roundingA more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services,etc.) is provided in Table 7.8.7.2.6. ContingencyUncertainty associated with the decommissioning cost estimate, and the need to allocateadditional funding to cover contingency for this project has been included in this estimate.Accounting for contingency has been evaluated from two standpoints, operational efficiency andscope expansion risk. Within the context of this cost estimate, operational efficiency contingencyis defined as the occurrence of events or circumstances that can prolong project duration or makethe execution of a given work scope more difficult. Examples of these types of events includeweather related delays, equipment or tool breakage or unavailability, and interferences fromother work activities. Scope expansion risk within the context of this estimate is defined as theneed to perform unplanned work activities or expansion of the work activities that were planned.Examples of this type of project risk would be discovering new or additional contaminated mediarequiring remediation, or a need to perform work in a different manner due to unforeseenconditions or changes in requirements.As was initially shown in section 7.2.2, contingency was estimated at $31.1 Million; apportionedas $24.7 Million for radiological decommissioning, $3.3 Million for spent fuel management and$3.2 Million for site restoration. This contingency was estimated using a quantitative MonteCarlo type probability analysis, with the $31.1 Million amount corresponding to the resulting 85percent confidence level amount.7.3. Decommissioning Funding PlanAs indicated in section 7.2, the estimated cost to complete the radiological decommissioning ofthe Zion nuclear station, including contingency, is $309 Million (year of expenditure dollars) asof Sept 30, 2014. These decommissioning costs will be paid for with funds from the station'snuclear decommissioning trust fund (NDT). Discounting those escalated costs at the rate of costinflation described in section 7.2.2 yields a cost of radiological decommissioning at constant2014 dollars of f.7-9 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS-7=-The actual cash balance of the NDT, as recorded by the ZionSolutions trustee as of Sept 30,2014, was .Recognizing that there were project costs incurred and recorded onSept 30, 2014 that had not been paid for from the NDT (outstanding disbursements), plus othertransactions in the last quarter of 2014 that have a bearing on these outstanding disbursements,the net balance of the NDT available to cover the future costs of radiological decommissioningwas $317.1 Million.Based on a time phased cash flow analysis of the radiological decommissioning costs, andassuming NDT returns at an annual 2% real, after tax rate of return, the required minimumfunding assurance amount to fund the future radiological decommissioning costs equals $302.6Million, which is below the $317.1 Million available balance described above.This NDT position, together with EnergySolutions resources and the $200 Million Letter ofCredit backup for the NDT agreed with Exelon in the Zion Nuclear Power Station Unit 1 and 2Asset Sale Agreement, that are available but are not relied upon here, provides for sufficientfunding and financial assurance for completion of radiological decommissioning of the ZionProject.On or before March 31, 2015, as required by 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)-(viii), ZionSolutions will be submitting the annual demonstration of financial assurance for theyear ending Dec 31, 2014. That submission will be based upon future project costs ofradiological decommissioning and the NDT balance as of that date.07-10 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN :ZIONSOLUTIONS;-m7.4. References7-1 Code of Federal Regulations, Title 10, Part 50.82, "Termination of License"7-2 US Nuclear Regulatory Commission Regulatory Guide 1. 179, Revision 1, "StandardFormat and Content of License Termination Plans for Nuclear Power Reactors", June20117-3 Letter from ZionSolutions ,LLC to the U.S. Nuclear Regulatory Commission,"Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR)for Zion Nuclear Power Station, Units 1 and 2 in Accordance with 10 CFR 50.82(a)(7)",dated March 18, 20087-4 Code of Federal Regulations, Title 10, Part 50.75, "Reporting and Recordkeeping forDecommissioning Planning"7-5 Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission,"Submittal of the Zion Nuclear Power Station Site-Specific Decommissioning CostEstimate", dated February 14, 20007-6 Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission,"Submittal of the Zion Nuclear Power Station Irradiated Fuel Management Plan", datedFebruary 14, 20007-7 Letter from Exelon Generation to the U.S. Nuclear Regulatory Commission, "ProposedIndependent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan forZion", dated October 17, 20137-11 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN:ZIONSOLUTIONSz.Table 7-6 Detailed Breakdown of Radiological Decommissioning Costsby Resource RequirementLabor: TOTAL $119.8 MillionCraft $38.6 MillionTechnician $14.3 MillionProfessional (Sci. & Eng.) $36.8 MillionManagement $18.1 MillionOther -contract service labor $11.9 MillionEquipment & Materials: TOTAL $24.9 MillionDurable Equipment $5.3 MillionConsumable Supplies $16.0 MillionUtilities and Energy $3.6 MillionContracts, Services & Fees: TOTAL $55.5 MillionEquipment Rental <$0.1 MillionContracted Services $27.9 MillionLaboratory & Analytical Services $1.8 MillionTravel & Living $1.5 MillionInsurance and Finance Fees $20.1 MillionLicensee Fees & Permits $4.2 MillionRadioactive Waste Packaging, TOTAL $84.1 MillionTransportation & Disposal: Class A WasteClass B/C WasteTOTAL $284.3 MillionColumns may not add due to rounding7-12 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN:ZIONSOLUTION&S=Table 7-7 Detailed Breakdown of Radiological Decommissioning Costsby Decommissioning ActivityMajor Component TOTAL $30.8 MillionRemoval Reactor Vessels and Internals $21.1 MillionSteam Generators 9.0 MillionPressurizers $0.7 MillionSSC Removal and TOTAL $27.2 MillionDecontamination Equipment Removal / Structural Decontamination $18.4 MillionBulk Structural Material Removal $7.9 MillionIn-process Characterization and Remedial Action $0.9 MillionSupportWaste Management TOTAL $84.1 MillionClass B/C Waste: Packaging, Transportation andDisposal Surveys and SamplingClass A Waste: Rail Car Preparation forLarge ComponentsClass A Bulk Waste: Rail Car Transportationand DisposalClass A Packaged Waste: Containers,Transportation and DisposalProgram Management TOTAL $120.3 Millionand Support Services Program and Project Management and Site $32.1 MillionAdministrationTechnical Services and Services- (e.g., $47.9 MillionEngineering, Rad. Protection, EnvironmentalMonitoring, Site Characterization, Waste Mgmt,QA/QC, Safety, Worker Qualifications)Security $7.7 MillionSite O&M $4.9 MillionSpecial Projects (Cold & Dark, Bld. Mods.) $8.5 MillionEquipment, Materials, Consumable Supplies and $11.2 MillionUtilitiesFSS, LT and Material Release Program $8.0 MillionOther Lump-Sum Costs TOTAL $21.9 MillionFinancing $9.8 MillionRegulatory Fees $12.1 MillionTOTAL $284.3 MillionColumns may not add due to rounding7-13 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN:ZIONSOLUTIONS,.Table 7-8 Detailed Breakdown of Spent Fuel Management Costsby Resource RequirementLabor:TOTAL-$29.9 MillionCraft $3.7 MillionTechnician $1.5 MillionProfessional (Sci. & Eng.) $3.7 MillionManagement $1.8 MillionOther (contract service lab -exclusive of management)$19.2 MillionEquipment & TOTAL $1.7 MillionMaterials:Durable Equipment <$0.1 MillionConsumable Supplies $1.2 MillionUtilities and Energy $0.4 MillionContracts, Services & TOTAL $5.8 MillionFees:Equipment Related Services $1.3 MillionContracted Services (excluding security provided $2.2 Millionin labor above)Laboratory & Analytical Services <$0.1 MillionTravel & Living <$ 0.1 MillionInsurance, Finance, Licensee and Permit fees $2.3 MillionRadioactive Waste TOTAL $0Packaging,Transportation & Class A Waste $0Disposal:Class B/C Waste $0TOTAL $37.4 MillionColumns may not add due to rounding7-14 ZION STATION RESTORATION PROJECTLICENSE TERMINATION PLAN:ZIONSOLUTIONS.-Table 7-9 Detailed Breakdown of Site Restoration Costs by Resource RequirementLabor: TOTAL $5.8 MillionCraft $2.2 MillionTechnician $0.16 MillionManrofessional (Sci. & Eng.) $1.9 MillionOther- contract service labor $1.6 MillionEquipment & Materials: TOTAL $1.2 MillionDurable Equipment <$0.1 MillionConsumable Supplies $0.7 MillionUtilities and Energy $0.5 MillionContracts, Services & TOTAL $29.2 MillionFees:Equipment Rental <$0.1 MillionContracted Services $27.6 MillionLaboratory & Analytical Services <$0.1 MillionTravel & Living <$0.1 MillionInsurance, Finance, Licensee & Permit fees, $1.6 MillionRadioactive Waste TOTAL $0Packaging,Transportation & Class A Waste $0Disposal:Class B/C Waste $0TOTAL $36.2 MillionColumns may not add due to rounding7-15}}

Latest revision as of 15:19, 9 March 2020

Redirect to:

Retrieved from "https://kanterella.com/w/index.php?title=ML15061A230&oldid=2542133"