3F1111-01, Document P23-1651-001, Rev. 0, Preliminary Decommissioning Cost Estimate for the Crystal River, Unit 3 Nuclear Generating Plant

Document P23-1651-001, Rev. 0, Preliminary Decommissioning Cost Estimate for the Crystal River, Unit 3 Nuclear Generating Plant

ML11339A041
Person / Time
Site:	Crystal River
Issue date:	11/21/2011
From:	Cloutier W TLG Services
To:	Office of Nuclear Reactor Regulation, Progress Energy Florida
References
3F1111-01 P23-1651-001, Rev 0
Download: ML11339A041 (103)

Text

Document P23-1651-001, Rev. 0 PRELIMINARY DECOMMISSIONING COST ESTIMATE for the CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT preparedfor Progress Energy Florida, Inc.

preparedby TLG Services, Inc.

Bridgewater, Connecticut November 2011

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001,Rev. 0 PreliminaryDecommissioning Cost Estimate Page ii of xxii APPROVALS Project Manager It//e'iolI William A. Cloutier, J.< Date Project Engineer Thomas/J. Garrett Date/

Technical Manager Francis W. Sey*mot/ Date TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Page iii of xxii TABLE OF CONTENTS SECTION PAGE SU M MVLARY ........................................................................................................... vi-xxii

1. INTRODU CTION ..................................................................................................... 1-1 1.1 Objectives of Study ........................................................................................... 1-1 1.2 Site Description ................................................................................................. 1-2 1.3 Regulatory Guidance ........................................................................................ 1-3 1.3.1 N uclear W aste Policy Act ...................................................................... 1-4 1.3.2 Low -Level Radioactive W aste Acts ...................................................... 1-6 1.3.3 Radiological Criteria for License Term ination .................................... 1-8

2. SAFSTOR DECOMMISSIONING ALTERNATIVE .............................................. 2-1 2.1 Period 1 - Preparations ..................................................................................... 2-1 2.2 Period 2 - Dorm ancy ......................................................................................... 2-2 2.3 Period 3 - Preparations for Decom m issioning ................................................ 2-3 2.4 Period 4 - Deferred Decom m issioning ............................................................. 2-4 2.5 Period 5 - Site Restoration ............................................................................... 2-7

3. COST ESTIM ATE ..................................................................................................... 3-1 3.1 Basis of Estim ate .............................................................................................. 3-1 3.2 M ethodology ...................................................................................................... 3-1 3.3 Financial Com ponents of the Cost M odel ....................................................... 3-3 3.3.1 Contingency ........................................................................................... 3-3 3.3.2 Financial Risk ........................................................................................ 3-5 3.4 Site-Specific Considerations ............................................................................. 3-6 3.4.1 Spent Fuel M anagem ent ....................................................................... 3-6 3.4.2 Reactor Vessel and Internal Com ponents ........................................... 3-8 3.4.3 Prim ary System Com ponents ............................................................... 3-9 3.4.4 Retired Com ponents ............................................................................ 3-10 3.4.5 M ain Turbine and Condenser ............................................................. 3-11 3.4.6 Transportation M ethods ..................................................................... 3-11 3.4.7 Low -Level Radioactive W aste Disposal ............................................. 3-12 3.4.8 Site Conditions Following Decom m issioning .................................... 3-13 3.5 Assum ptions .................................................................................................... 3-13 3.5.1 Estim ating Basis ................................................................................. 3-14 3.5.2 Labor Costs .......................................................................................... 3-14 3.5.3 Design Conditions ................................................................................ 3-14 3.5.4 General ................................................................................................. 3-15 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Page iv of xxii TABLE OF CONTENTS (continued)

SECTION PAGE 3.6 Cost Estimate Summary ............................................................................... 3-17

4. SCHEDULE ESTIMATE ........................................................................................ 4-1 4.1 Schedule Estimate Assumptions ..................................................................... 4-1 4.2 Project Schedule ................................................................................................ 4-2

5. RADIOACTIVE WASTES ........................................................................................ 5-1

6. R E S ULT S ................................................................................................................. 6-1

7. R E FE RE NC E S .......................................................................................................... 7-1 TABLES

1. Decommissioning Cost Elements ................................................................... xvii

2. Schedule of License Termination Expenditures ........................................... xviii

3. Funding Requirements for License Termination, 2016 Shutdown .............. xx 3.1 Schedule of Total Annual Expenditures ....................................................... 3-19 3.2 Schedule of License Termination Expenditures ........................................... 3-21 3.3 Schedule of Spent Fuel Management Expenditures .................................... 3-23 3.4 Schedule of Site Restoration Expenditures .................................................. 3-25 5.1 Decommissioning Waste Summary ................................................................. 5-4 6.1 Decommissioning Cost Element Contribution ................................................ 6-4 FIGURES 4.1 Activity Schedule .............................................................................................. 4-3 4.2 Decommissioning Timeline .............................................................................. 4-4 5.1 Decommissioning Waste Disposition .............................................................. 5-3 APPENDICES A. Unit Cost Factor Development ......................................................................... A-1 B. Unit Cost Factor Listing .................................................................................. B-1 C. Detailed Cost Analysis ....................................................................................... C-1 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate Page v of xxii REVISION LOG No. CRA No. Date Item Revised Reason for Revision 0 11-21-2011 Original Issue TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page vi of xxii

SUMMARY

Florida Power Corporation, doing business as Progress Energy Florida, Inc.

(Progress Energy), a subsidiary of Progress Energy, Inc., is seeking renewal of the operating license for the Crystal River Unit 3 Nuclear Generating Plant (Crystal River), currently set to expire at midnight on December 3, 2016. An application for the renewal of Facility Operating License No. DPR-72, for an additional 20-year period, was submitted to the Nuclear Regulatory Commission (NRC) on December 16, 2008. The application is currently under review.

However, pursuant to 10 CFR 50.75(f)(3), each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission. This report presents an estimate of the cost to decommission the Crystal River assuming a cessation of operations after a nominal 40-year operating life in 2016. The cost estimate includes an assessment of the major factors that could affect the cost to decommission the Crystal River nuclear unit.

Progress Energy is submitting this estimate to comply with the requirements of 10 CFR 50.75(f)(3). Progress Energy has not determined or committed to a specific decommissioning approach for Crystal River at this time. However, it is Progress Energy's current plan for purposes of demonstrating the adequacy of funding to meet regulatory requirements to use the SAFSTOR decommissioning option based on the current license expiration date. License renewal is likely to require a need to revise this preliminary plan.

The currently projected total cost to decommission the nuclear unit, assuming the SAFSTOR alternative, is estimated at $1,077.6 million, as reported in 2011 dollars.

The cost includes the monies anticipated to be spent for operating license termination, spent fuel storage and site remediation activities. The cost is based on several key assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, performance uncertainties (contingency) and site remediation and restoration requirements. The assumptions are discussed in more detail in this document.

Decommissioning Alternatives and Regulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material to levels at or below the site release criteria so that the license can be terminated. The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page vii of xxii June 27, 1988.111 In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC:

DECON, SAFSTOR, and ENTOMB.

DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be 21 released for unrestricted use shortly after cessation of operations."[

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[31 Decommissioning is to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety.

ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."[41 As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[51 The amendments allow for greater public participation and better define the transition process from operations to decommissioning.

Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. The format 1 U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988.

2 Ibid. Page FR24022, Column 3.

3 Ibid.

4 Ibid. Page FR24023, Column 2.

5 U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61, (p 39278 et seq.), July 29, 1996.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page viii of xxii and content of the estimate is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.[J]

Bases of the Cost Estimate For the purpose of the analysis, Crystal River was assumed to cease operations in December 2016, after 40 years of operations. The unit would then be placed into safe-storage (SAFSTOR), with the spent fuel relocated to an Independent Spent Fuel Storage Installation (ISFSI) to await transfer to a Department of Energy (DOE) facility. Based upon a 2020 start date for the pickup of spent fuel from the commercial nuclear power generators, Progress Energy anticipates that the removal of spent fuel from the site could be completed by the year 2057. For purposes of this analysis, the plant remains in safe-storage until 2071, at which time it will be decommissioned and the site released for alternative use without restriction, i.e., the license is terminated within the required 60-year time period.

The analysis relies upon site-specific, technical information from an evaluation prepared in 2008,[7] updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The economic basis was reviewed for the current analysis and updated to reflect current site costs and budgets. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available.

Methodology The primary goal of the decommissioning is the removal and disposal of the contaminated systems and structures so that the plant's operating license can be terminated. The analysis recognizes that spent fuel will be stored at the site in the plant's storage pool and/or in an independent spent fuel storage installation (ISFSI) until such time that it can be transferred to the U.S. Department of Energy (DOE).

Consequently, the estimate includes those costs to manage and subsequently decommission these interim storage facilities.

The estimate is based on numerous fundamental assumptions, including regulatory requirements, low-level radioactive waste disposal practices, high-level radioactive waste management options, project contingencies, and site restoration requirements. The estimate incorporates a minimum cooling period for the spent fuel that resides in the storage pool when operations cease. Any residual fuel 6 "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors,"

Regulatory Guide 1.202, U.S. Nuclear Regulatory Commission, February 2005 7 "Decommissioning Cost Analysis for the Crystal River Plant, Unit 3," Document No. P23-1597-002, Rev. 0, TLG Services, Inc., October 2008 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page ix of xxii remaining in the pool after the cooling period is relocated to the ISFSI to await transfer to a DOE facility. The estimate also includes the dismantling of site structures and non-essential facilities and the limited restoration of the site.

The methodology used to develop the estimate followed the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[8 ] and the DOE "Decommissioning Handbook."[9] These documents present a unit cost factor method for estimating decommissioning activity costs that simplifies the calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton),

and cutting costs ($/inch) were developed using local labor rates. The activity-dependent costs were then estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures relied upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.[101 The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services, such as quality control and security.

This analysis reflected lessons learned from TLG's involvement in the Shippingport Station decommissioning, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Connecticut Yankee, and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

8 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

9 W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980.

10 "Building Construction Cost Data 2011," Robert Snow Means Company, Inc., Kingston, Massachusetts.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page x of xxii Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur."["]1 The cost elements in the estimate are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

Contingency funds are expected to be fully expended throughout the program. As such, inclusion of contingency is necessary to provide assurance that sufficient funding will be available to accomplish the intended tasks.

Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,[121 and its Amendments of 1985,[131 the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. With the exception of Texas, no new compact facilities have been successfully sited, licensed, and constructed.

The disposal facility in Barnwell, South Carolina is currently closed to generators outside the Atlantic Compact (comprising the states of Connecticut, New Jersey and South Carolina). The commercial disposal facility on the Hanford Nuclear Reservation near Richland, Washington accepts low-level radioactive waste from the Northwest (Alaska, Hawaii, Idaho, Montana, Oregon, Utah, Washington and Wyoming) and Rocky Mountain (Colorado, Nevada, and New Mexico) Compact states. This leaves EnergySolutions' disposal facility in Clive, Utah as the only available option for the disposal of the majority of the low-level radioactive waste generated in 11 Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239.

12 "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980.

13 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Pagexi of xxii decommissioning Crystal River (the Texas facility has limited the importation of waste from outside the Texas Compact).

For the purpose of this analysis, Progress Energy's "Life of Plant Agreement" with EnergySolutions is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A [141). EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel.

The Texas Commission on Environmental Quality (TCEQ), the environmental agency for the state, is responsible for the licensing of a low-level radioactive waste disposal facility for the Texas Compact. The agency granted Waste Control Specialists (WCS) a disposal license in 2009 and approval to commence construction in early 2011.

Construction of the disposal facility is now essentially complete and the facility was declared operational in November 2011. However, to date, the TCEQ has only published interim disposal rates for the facility, in advance of the formal disposal rate-setting process, and only for Compact generators. As a proxy, disposition of the Class B and C waste is based upon the last published rate schedule for non-compact waste for the Barnwell facility.

The dismantling of the components residing closest to the reactor core generates radioactive waste that may be considered unsuitable for shallow-land disposal (i.e.,

low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (Greater-than-Class C or GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance.

For purposes of this study, GTCC is packaged in the same canisters used for spent fuel. The GTCC material is shipped directly to a DOE facility as it is generated.

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or 14 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Page xii of xxii decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Crystal River reflects the savings from waste recovery/volume reduction.

High-Level Radioactive Waste Management Congress passed the "Nuclear Waste Policy Act"[151 (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high-level radioactive waste and utilities would pay the cost of the disposition services for that material. NWPA, along with the individual contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to accept any spent fuel or high level waste, as required by the NWPA and utility contracts. Delays continue and, as a result, generators have initiated legal action against the DOE in an attempt to obtain compensation for DOE's breach of contract.

Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Progress Energy's current spent fuel management plan for the Crystal River spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility and 2) expectations for spent fuel receipt by the DOE for the Crystal River fuel. Fuel could be completely removed from the site as early as 2057, based on an oldest fuel first priority, and the DOE achieving an annual rate of transfer (3,000 metric tons of uranium year) as reflected in DOE's latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567).

The assumed 2020 DOE start date is nominally based on the last position stated by the DOE. On July 15, 2008, the then-Director of the DOE's Office of Civilian Radioactive Waste Management testified before Congress that DOE "could be ready to begin accepting spent nuclear fuel by 2020," but his statement was based on continued program funding.[16 ] The current administration has cut the budget for the geological 15 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982 16 Statement of Edward F. Sproat, III, Director Office of Civilian Radioactive Waste Management, U.S. Department of Energy, Before the Subcommittee on Energy and Air Quality Committee on TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Pagexiii of xxii repository program, but the administration has also appointed a Blue Ribbon Commission on America's Nuclear Future to make recommendations for a new plan for nuclear waste disposal. That Commission's charter includes a requirement that the Commission consider "options for safe storage of used nuclear fuel while final disposition pathways are selected and deployed." Progress Energy believes that one or more monitored retrievable storage facilities could be put into place following a Blue Ribbon Commission recommendation for the same, within a relatively short time frame, at least by 2020. For example, a facility such as that licensed by the NRC to Private Fuel Storage could be used by the DOE to store fuel until a final disposition is determined.

It is generally necessary that spent fuel be cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[1 71 This requirement is prepared for through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.

The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following six and one half years the assemblies are packaged into multipurpose canisters for transfer to the DOE or to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the transport and/or storage requirements for decay heat.

An ISFSI, operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[18]), is in the process of being constructed to support continued plant operations. The facility is assumed to be available to support future decommissioning operations. Once the wet storage pool is emptied, the auxiliary building can be prepared for long-term storage.

Progress Energy's position is that the DOE has a contractual obligation to accept Crystal River's fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of Energy and Commerce U.S. House of Representatives, July 15, 2008.

17 U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," Subpart 54 (bb), "Conditions of Licenses."

18 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Page xiv of xxii sufficient decommissioning funds at the end of the station's life if, contrary to its contractual obligation, the DOE has not performed earlier.

Site Restoration Prompt dismantling of site structures (once the facilities are decontaminated) is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process is deferred.

Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force.

Consequently, this study assumes that site structures are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then to be graded and stabilized.

Decommissioning Trust Funds As of September 30, 2011, the aggregate trust fund balance for Crystal River was approximately $578.0 million. The total includes Progress Energy Florida's share (91.8%), as well as that of the nine minority owners.[19]

Financial Assurance Progress Energy intends to fund the expenditures for license termination (comprising approximately 70% of the total cost) from the decommissioning trust fund currently held by Progress Energy as well as the nine minority owners. The management of the spent fuel, until it can be transferred to the DOE, may be funded from excess trust fund earnings and from proceeds from spent fuel litigation against the Department of Energy (DOE). Expenditures from the trust fund for the management of the spent fuel will not reduce the value of the decommissioning trust fund to below the amount necessary to place and maintain the reactor in safe storage. The licensee would make the appropriate submittals for an exemption, in accordance with 10 CFR 50.12, from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

The total cost projected for license termination (in accordance with 10 CFR 50.75) for the deferred decommissioning alternative (SAFSTOR) is shown at the bottom of Table 19 Total decommissioning funds available include Progress Energy Florida's share (91.8%) as well as that of the nine minority owners: City of Alachua, City of Bushnell, City of Gainesville, City of Kissimmee, City of Leesburg, City of Ocala, Orlando Utilities Commission, Seminole Electric Cooperative, and City of New Smyrna Beach TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Pagexv of xxii 1 ($753.717million). The schedule of expenditures for license termination activities is provided in Table 2. Table 3 provides the details of the proposed funding plan for decommissioning Crystal River based on a 2% real rate of return on the decommissioning trust fund. As shown in Table 3, the current trust funds (as of September 30, 2011) are sufficient to accomplish the intended tasks and terminate the operating license for Crystal River. The analysis also shows a surplus in the fund at the completion of decommissioning. This surplus could be made available to fund other activities at the site (e.g., spent fuel management and/or restoration activities),

recognizing that the licensee would need to make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

Summary The cost to decommission Crystal River assumes the removal of all contaminated and activated plant components and structural materials such that the owner may then have unrestricted use of the site with no further requirements for an operating license.

Low-level radioactive waste, other than GTCC waste, is sent to a commercial processor for treatment/conditioning or to a controlled disposal facility.

Decommissioning is accomplished within the 60-year period required by current NRC regulations. In the interim, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility is complete. Once emptied, the storage facilities are also decommissioned.

The decommissioning scenario is described in Section 2. The assumptions are presented in Section 3, along with schedules of annual expenditures. The major cost contributors are identified in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendix C. The major cost components are also identified in the cost summary provided at the end of this section.

The cost elements in the estimate are assigned to one of three subcategories: NRC License Termination, Spent Fuel Management, and Site Restoration. The subcategory "NRC License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in its financial assurance regulations (i.e.,

10 CFR Part 50.75). In situations where the long-term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.

The "Spent Fuel Management" subcategory contains costs associated with the containerization and transfer of spent fuel to the ISFSI and the management of the TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Page xvi of xxii ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g., geologic repository) is complete.

"Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to three feet below grade and backfilled.

It should be noted that the costs assigned to these subcategories are allocations.

Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., Asset Retirement Obligation determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

As noted within this document, the estimate is developed and costs are presented in 2011 dollars. As such, the estimate does not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the reactor or during the decommissioning period.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page xvii of xxii TABLE 1 DECOMMISSIONING COST ELEMENTS (thousands of 2011 dollars)

Cost Element Cost [I' Decontamination 12,409 Removal 101,075 Packaging 22,681 Transportation 11,922 Waste Disposal 46,245 Off-site Waste Processing 23,246 Program Management [2] 306,020 Site Security 183,679 Spent Fuel Pool Isolation 11,822 Spent Fuel Management [3] 129,013 Insurance and Regulatory Fees 61,040 Energy 13,491 Characterization and Licensing Surveys 15,110 Property Taxes 87,216 Utility Site Indirect 19,326 Corporate Allocations 14,257 Miscellaneous Equipment 19,045 Total [4] 1,077,596 Cost Element License Termination 753,717 Spent Fuel Management 271,910 Site Restoration 51,969 Total [41 1,077,596

[1J Total costs reported (i.e., there is no cost allocation by ownership share)

[21 Includes engineering and security costs

[31 Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging/spent fuel pool O&M and EP fees

[41 Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear Generating Plant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Page xviii of xxii TABLE 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2016 3,035 103 94 3 823 4,058 2017 38,811 2,388 1,179 418 10,610 53,405 2018 19,075 3,990 568 1,335 18,447 43,415 2019 2,862 438 118 14 2,175 5,607 2020 2,870 439 118 14 2,181 5,622 2021 2,862. 438 118 14 2,175 5,607 2022 2,862 438 118 14 2,175 5,607 2023 2,862 362 118 10 2,174 5,525 2024 2,869 307 118 7 2,179 5,479 2025 1 2,862 306 118 7 2,173 5,465 2026 2,862 306 118 7 2,173 5,465 2027 2,862 306 118 7 2,173 5,465 2028 2,869 307 118 7 2,179 5,479 2029 2,862 306 118 7 2,173 5,465 2030 2,862 306 118 7 2,173 5,465 2031 2,862 306 118 7 2,173 5,465 2032 2,869 307 118 7 2,179 5,479 2033 2,862 306 118 7 2,173 5,465 2034 2,862 306 118 7 2,173 5,465 2035 2,862 306 118 7 2,173 5,465 2036 1 2,869 307 118 7 2,179 5,479 2037 2,862 306 118 7 2,173 5,465 2038 2,862 306 118 7 2,173 5,465 2039 2,862 306 118 7 2,173 5,465 2040 1 2,869 307 118 7 2,179 5,479 2041 2,862 306 118 7 2,173 5,465 2042 2,862 306 118 7 2,173 5,465 2043 2,862 306 118 7 2,173 5,465 2044 2,869 307 118 7 2,179 5,479 2045 2,862 306 118 7 2,173 5,465 2046 2,862 306 118 7 2,173 5,465 2047 2,862 306 118 7 2,173 5,465 2048 2,869 307 118 7 2,179 5,479 2049 2,862 306 118 7 2,173 5,465 2050 1 2,862 306 118 7 2,173 5,465 2051 1 2,862 306 118 7 2,173 5,465 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Pagexix of xxii TABLE 2 (continued)

SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2052 2,869 307 118 7 2,179 5,479 2053 2,862 306 118 7 2,173 5,465 2054 2,862 306 118 7 2,173 5,465 2055 2,862 306 118 7 2,173 5,465 2056 2,869 307 118 7 2,179 5,479 2057 2,862 306 118 7 2,173 5,464 2058 2,862 298 118 6 2,150 5,434 2059 2,862 298 118 6 2,150 5,434 2060 2,869 299 118 6 2,156 5,448 2061 2,862 298 118 6 2,150 5,434 2062 2,862 298 118 6 2,150 5,434 2063 2,862 298 118 6 2,150 5,434 2064 2,869 299 118 6 2,156 5,448 2065 2,862 298 118 6 2,150 5,434 2066 2,862 298 118 6 2,150 5,434 2067 2,862 298 118 6 2,150 5,434 2068 2,869 299 118 6 2,156 5,448 2069 2,862 298 118 6 2,150 5,434 2070 2,862 298 118 6 2,150 5,434 2071 4,621 472 176 8 2,276 7,553 2072 35,366 3,622 1,182 32 4,470 44,672 2073 43,439 21,970 1,146 18,390 13,820 98,766 2074 44,947 23,086 1,014 24,109 14,794 107,949 2075 43,442 8,421 884 12,763 6,699 72,209 2076 28,520 2,641 327 2,189 3,239 36,916 2077 121 0 0 0 0 121 2078 74 0 0 0 0 74 Total 410,355 83,088 12,703 59,624 187,946 753,717 Note: Total costs reported (i.e., there is no cost allocation by ownership share)

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page xx of xxii TABLE 3 FUNDING REQUIREMENTS FOR LICENSE TERMINATION 2016 SHUTDOWN Basis Year 2011 Fund Balance (9/30/2011) $578.026 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 2%

Cost Escalated at 0% (minus expenses)

Year (millions) (millions) (millions) 2011 $ 578.026 2012 $ 589.586 2013 $ 601.378 2014 $ 613.406 2015 _ - $ 625.674 2016 4.058 4.058 $ 634.129 2017 53.405 53.405 $ 593.407 2018 43.415 43.415 $ 561.859 2019 5.607 5.607 $ 567.490 2020 5.622 5.622 $ 573.217 2021 5.607 5.607 $ 579.074 2022 5.607 5.607 $ 585.049 2023 5.525 5.525 $ 591.225 2024 5.479 5.479 $ 597.570 2025 5.465 5.465 $ 604.057 2026 5.465 5.465 $ 610.674 2027 5.465 5.465 $ 617.423 2028 5.479 5.479 $ 624.292 2029 5.465 5.465 $ 631.313 2030 5.465 5.465 $ 638.475 2031 5.465 5.465 $ 645.780 2032 5.479 5.479 $ 653.216 2033 5.465 5.465 $ 660.816 2034 5.465 5.465 $ 668.567 2035 5.465 5.465 $ 676.474 2036 5.479 5.479 $ 684.524 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page xxi of xxii TABLE 3 (continued)

FUNDING REQUIREMENTS FOR LICENSE TERMINATION 2016 SHUTDOWN Basis Year 2011 Fund Balance (9/30/2011) $578.026 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 2%

Cost Escalated at 0% (minus expenses)

Year (millions) (millions) (millions) 2037 5.465 5.465 $ 692.750 2038 5.465 5.465 $ 701.141 2039 5.465 5.465 $ 709.699 2040 5.479 5.479 $ 718.413 2041 5.465 5.465 $ 727.317 2042 5.465 5.465 $ 736.399 2043 5.465 5.465 $ 745.662 2044 5.479 5.479 $ 755.096 2045 5.465 5.465 $ 764.734 2046 5.465 5.465 $ 774.564 2047 5.465 5.465 $ 784.591 2048 5.479 5.479 $ 794.803 2049 5.465 5.465 $ 805.234 2050 5.465 5.465 $ 815.875 2051 5.465 5.465 $ 826.728 2052 5.479 5.479 $ 837.783 2053 5.465 5.465 $ 849.074 2054 5.465 5.465 $ 860.591 2055 5.465 5.465 $ 872.338 2056 5.479 5.479 $ 884.305 2057 5.464 5.464 $ 896.527 2058 5.434 5.434 $ 909.024 2059 5.434 5.434 $ 921.771 2060 5.448 5.448 $ 934.758 2061 5.434 5.434 $ 948.019 2062 5.434 5.434 $ 961.546 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Page xxii of xxii TABLE 3 (continued)

FUNDING REQUIREMENTS FOR LICENSE TERMINATION 2016 SHUTDOWN Basis Year 2011 Fund Balance (9/30/2011) $578.026 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 2%

Cost Escalated at 0% (minus expenses)

Year (millions) (millions) (millions) 2063 5.434 5.434 $ 975.344 2064 5.448 5.448 $ 989.402 2065 5.434 5.434 $ 1,003.757 2066 5.434 5.434 $ 1,018.398 2067 5.434 5.434 $ 1,033.333 2068 5.448 5.448 $ 1,048.551 2069 5.434 5.434 $ 1,064.088 2070 5.434 5.434 $ 1,079.936 2071 7.553 7.553 $ 1,093.982 2072 44.672 44.672 $ 1,071.190 2073 98.766 98.766 $ 993.848 2074 107.949 107.949 $ 905.775 2075 72.209 72.209 $ 851.682 2076 36.916 36.916 $ 831.799 2077 0.121 0.121 $ 848.313 2078 0.074 0.074 $ 865.206 Total 753.717 753.717 Note: Total costs reported (i.e., there is no cost allocation by ownership share)

September 30, 2011 balance also used as year-end 2011 balance Calculations:

Column B= (A)*(1+.00)^(current year - 2011) or for 0%, B = A Column C = (Previous year's fund balance) * (1 + .02) - B (current year's decommissioning expenditures)

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 1 of 9

1. INTRODUCTION This report presents an estimate of the cost to decommission the Crystal River Unit 3 Nuclear Generating Plant, (Crystal River) following a scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2008,[1]* updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects.

Pursuant to 10 CFR 50.75(f)(3),[ 21 each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission. Progress Energy Florida, Inc. (Progress Energy) is submitting this estimate to comply with the requirements of 10 CFR 50.75(f)(3).

Progress Energy has not determined or committed to a specific decommissioning approach for Crystal River at this time. However, it is Progress Energy's current plan for purposes of demonstrating the adequacy of finding to meet regulatory requirements to use the SAFSTOR decommissioning option based on the current license expiration date. License renewal is likely to require a need to revise this preliminary plan.

The current estimate is designed to provide Progress Energy, the plant's majority owner, with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning.

1.1 OBJECTIVES OF STUDY The objectives of this study were to prepare a comprehensive estimate of the costs to decommission Crystal River, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.

The plant was issued its operating license in December 1976. The license currently expires in 2016. An application for the renewal of Facility Operating License No. DPR-72, for an additional 20-year period, was submitted to the Nuclear Regulatory Commission (NRC) on December 16, 2008. The application is currently under review. So, for the purposes of this study, the final

• References provided in Section 7 of the document TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 2 of 9 shutdown date (license expiration) is assumed to on December 3, 2016 or 40 years from the original license issue.

1.2 SITE DESCRIPTION The Crystal River site is located in Citrus County, Florida, approximately 70 miles north of Tampa on the shore of the Gulf of Mexico. The generating site is comprised of four fossil-fired units and one nuclear unit. The Gulf of Mexico provides the heat sink for both Units 1 and 2 fossil-fired units, and the nuclear unit (natural draft towers provide the cooling for Units 4 and 5).

The nuclear steam supply system (NSSS) consists of a pressurized water reactor and a two-loop reactor coolant system, designed by Babcock & Wilcox.

The generating unit has a reference core design of 2609 MWt (thermal), with a corresponding net dependable capability electrical rating of 860 megawatts (electric) with the reactor at rated power.

The reactor coolant system is comprised of the reactor vessel and two heat transfer loops, each loop containing a vertical once-through type steam generator, and two single speed centrifugal reactor coolant pumps. In addition, the system includes an electrically heated pressurizer, a reactor coolant drain tank and interconnected piping. The system is housed within the reactor containment building or reactor building, a seismic Category I reinforced concrete structure. The reactor building is a reinforced concrete structure composed of a vertical cylinder with a shallow dome and flat circular foundation slab. The cylinder wall is prestressed with a post-tensioning system in the vertical and horizontal directions. The dome roof is prestressed utilizing a three-way post-tensioning system. The foundation slab is reinforced with conventional mild steel. The inside surface of the reactor building is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

Heat produced in the reactor is converted to electrical energy by the steam and power conversion system. A turbine-generator system converts the thermal energy of steam produced in the steam generators into mechanical shaft power and then into electrical energy. The unit's turbine generator consists of high-pressure and low-pressure turbine sections driving a direct-coupled generator at 1800 rpm. The turbines are operated in a closed feedwater cycle, which condenses the steam; the heated feedwater is returned to the steam generators. Heat rejected in the main condensers is removed by the circulating water system. The condenser circulating water is taken from and returned to the Gulf of Mexico through the intake and discharge canals, respectively.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 3 of 9 1.3 REGULATORY GUIDANCE The NRC provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[31 This rule set forth financial criteria for decommissioning licensed nuclear power facilities. The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose. Subsequent to the rule, the NRC issued Regulatory Guide 1.159, 4

"Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"[ 1 which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.

The rule defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated or activated portion of the plant's systems, structures and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations.

The rule also placed limits on the time allowed to complete the decommissioning process. For SAFSTOR, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient leverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the definition of decommissioning. At the conclusion of a 60-year dormancy period (or longer for ENTOMB if the NRC approves such a case), the site would still require significant remediation to meet the unrestricted release limits for license termination.

The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. With rulemaking permitting the controlled release of a site,[5I the NRC has re-evaluated this alternative. The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. The staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative.

The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 4 of 9 entombments.[61 However, the NRC's staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRC's current priorities, at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.

In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.[7 ] When the decommissioning regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facility's operating licensed life.

Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process from operations to decommissioning.

Under the revised regulations, licensees will submit written certification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel.

Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Within two years of submitting notice of permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequence and schedule, and an estimate of expected costs. Prior to completing decommissioning, the licensee is required to submit an application to the NRC to terminate the license, which will include a license termination plan (LTP).

1.3.1 Nuclear Waste Policy Act Congress passed the "Nuclear Waste Policy Act"[8] (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high-level radioactive waste and utilities would pay the cost of the disposition services for that material. NWPA, TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate Section 1, Page 5 of 9 along with the individual contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to accept any spent fuel or high level waste, as required by the NWPA and utility contracts. Delays continue and, as a result, generators have initiated legal action against the DOE in an attempt to obtain compensation for DOE's breach of contract.

Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner.

DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Progress Energy's current spent fuel management plan for the Crystal River spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility and 2) expectations for spent fuel receipt by the DOE for the Crystal River fuel. Fuel could be completely removed from the site as early as 2057, based on an oldest fuel first priority, and the DOE achieving an annual rate of transfer (3,000 metric tons of uranium year) as reflected in DOE's latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567).

The assumed 2020 DOE start date is nominally based on the last position stated by the DOE. On July 15, 2008, the then-Director of the DOE's Office of Civilian Radioactive Waste Management testified before Congress that DOE "could be ready to begin accepting spent nuclear fuel by 2020," but his statement was based on continued program funding.[91 The current administration has cut the budget for the geological repository program, but the administration has also appointed a Blue Ribbon Commission on America's Nuclear Future to make recommendations for a new plan for nuclear waste disposal. That Commission's charter includes a requirement that the Commission consider "options for safe storage of used nuclear fuel while final disposition pathways are selected and deployed." Progress Energy believes that one or more monitored retrievable storage facilities could be put into place following a Blue Ribbon Commission recommendation for the same, within a relatively short time frame, at least by 2020. For example, a facility such as that licensed by the NRC to Private Fuel Storage could be used by the DOE to store fuel until a final disposition is determined.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 6 of 9 It is generally necessary that spent fuel be cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[ 101 This requirement is prepared for through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.

The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following six and one half years the assemblies are packaged into multipurpose canisters for transfer to the DOE or to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the transport and/or storage requirements for decay heat.

An ISFSI, operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K [111), is in the process of being constructed to support continued plant operations. The facility is assumed to be available to support future decommissioning operations. Once the wet storage pool is emptied, the auxiliary building can be prepared for long-term storage.

Progress Energy's position is that the DOE has a contractual obligation to accept Crystal River's fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds at the end of the station's life if, contrary to its contractual obligation, the DOE has not performed earlier.

1.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,[121 and its Amendments of 1985,[131 the states became ultimately responsible for the TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 7 of 9 disposition of low-level radioactive waste generated within their own borders.

The disposal facility in Barnwell, South Carolina is currently closed to generators outside the Atlantic Compact (comprising the states of Connecticut, New Jersey and South Carolina). The commercial disposal facility on the Hanford Nuclear Reservation near Richland, Washington accepts low-level radioactive waste from the Northwest (Alaska, Hawaii, Idaho, Montana, Oregon, Utah, Washington and Wyoming) and Rocky Mountain (Colorado, Nevada, and New Mexico) Compact states. This leaves EnergySolutions' disposal facility in Clive, Utah as the only available option for the disposal of the majority of the low-level radioactive waste generated in decommissioning Crystal River (the Texas facility has limited the importation of waste from outside the Texas Compact).

For the purpose of this analysis, Progress Energy's "Life of Plant Agreement" with EnergySolutions is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A [141).

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel.

The Texas Commission on Environmental Quality (TCEQ), the environmental agency for the state, is responsible for the licensing of a low-level radioactive waste disposal facility for the Texas Compact. The agency granted Waste Control Specialists (WCS) a disposal license in 2009 and approval to commence construction in early 2011. Construction of the disposal facility is now essentially complete and the facility was declared operational in November 2011. However, to date, the TCEQ has only published interim disposal rates for the facility, in advance of the formal disposal rate-setting process, and only for Compact generators.

As a proxy, disposition of the Class B and C waste is based upon the last published rate schedule for non-compact waste for the Barnwell facility.

The dismantling of the components residing closest to the reactor core generates radioactive waste that may be considered unsuitable for shallow-land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (Greater-than-Class C or GTCC)).

The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 8 of 9 resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance.

For purposes of this study, GTCC is packaged in the same canisters used for spent fuel. The GTCC material is shipped directly to a DOE facility as it is generated.

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Crystal River reflects the savings from waste recovery/volume reduction.

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination,"[151 amending 10 CFR Part 20. This subpart provides radiological criteria for releasing a facility for unrestricted use.

The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).

The decommissioning estimate assumes that the Crystal River site will be remediated to the levels specified in 10 CFR 20.1402, "Radiological criteria for unrestricted use," although the remediation measures included in this estimate are believed to be sufficient to result in substantially lower levels than required by the foregoing regulation.

It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 1, Page 9 of 9 16 Response, Compensation, and Liability Act (CERCLA or Superfund).[ 1 An additional and separate limit of 4 millirem per year, as defined in 40 17 CFR § 141.16, is applied to drinking water.[ 1 On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU)[18 ] provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.

The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees. The present study does not include any costs for this occurrence.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 2, Page I of 8

2. SAFSTOR DECOMMISSIONING ALTERNATIVE A detailed cost estimate was developed to decommission the Crystal River nuclear unit for the SAFSTOR decommissioning alternative. The following narrative describes the basic activities associated with the alternative. Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work, i.e., engineering and planning at the time of decommissioning.

The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e., power production) to facility de-activation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee is then prohibited from reactor operation.

The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimate developed for Crystal River is also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures.

2.1 PERIOD 1 - PREPARATIONS The NRC defines SAFSTOR as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use." The facility is left intact (during the dormancy period), with structures maintained in a sound condition. Systems that are not required to support the spent fuel pool or site surveillance and security are drained, de-energized, and secured. Minimal cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination is performed. Access to contaminated areas is secured to provide controlled access for inspection and maintenance.

Preparations for long-term storage include the planning for permanent defueling of the reactor, revision of technical specifications appropriate to the operating conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 2, Page 2 of 8 The process of placing the plant in safe-storage includes, but is not limited to, the following activities:

• Defueling of the reactor vessel.

" Isolation of the spent fuel pool and fuel handling systems so that safe-storage operations may commence on the balance of the plant. The pool will remain operational for approximately six and one-half years following the cessation of operations before the inventory resident at shutdown can be completely transferred to the ISFSI. This activity may be carried out by plant personnel in accordance with existing operating technical specifications. Activities are scheduled around the fuel handling systems to the greatest extent possible.

• Draining and de-energizing of the non-contaminated systems not required to support continued site operations or maintenance.

" Disposing of contaminated filter elements and resin beds not required for processing wastes from layup activities or for future dormancy operations.

• Draining of the reactor vessel, with the internals left in place and the vessel head secured.

• Draining and de-energizing non-essential, contaminated systems with decontamination as required for future maintenance and inspection.

• Preparing lighting and alarm systems whose continued use is required; de-energizing portions of fire protection, electric power, and HVAC systems whose continued use is not required.

• Cleaning of the loose surface contamination from building access pathways.

• Performing an interim radiation survey of plant, posting warning signs where appropriate.

Erecting physical barriers and/or securing all access to radioactive or contaminated areas, except as required for inspection and maintenance.

Installing security and surveillance monitoring equipment and relocating security fence around secured structures, as required.

2.2 PERIOD 2 - DORMANCY The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phases of the deferred decommissioning alternatives. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 2, Page 3 of 8 structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel perform equipment maintenance, inspection activities, routine services to maintain safe conditions, adequate lighting, heating, and ventilation, and periodic preventive maintenance on essential site services.

An environmental surveillance program is carried out during the dormancy period to ensure that releases of radioactive material to the environment are prevented and/or detected and controlled. Appropriate emergency procedures are established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program constitutes an abbreviated version of the program in effect during normal plant operations.

Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public from the consequences of its own actions. The security fence, sensors, alarms, and other surveillance equipment provide security. Fire and radiation alarms are also monitored and maintained.

The spent fuel storage pool is emptied within six and one-half years of the cessation of operations. The transfer of the spent fuel from the ISFSI to a DOE facility begins in 2024 and continues throughout the dormancy period until completed in 2057. Once emptied, the ISFSI is secured for storage and decommissioned along with the power block structures in Period 4.

After an optional period of storage (such that license termination is accomplished within 60 years of final shutdown), it is required that the licensee submit an application to terminate the license, along with an LTP, thereby initiating the third phase.

2.3 PERIOD 3 - PREPARATIONS FOR DECOMMISSIONING Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning.

Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for activities and the writing of activity specifications and detailed procedures are also initiated at this time.

At least two years prior to the anticipated date of license termination, an LTP is required. Submitted as a supplement to the Final Safety Analysis Report (FSAR) or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 2, Page 4 of 8 procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission.

Variations in the length of the dormancy period are expected to have little effect upon the quantities of radioactive wastes generated from system and structure removal operations. Given the levels of radioactivity and spectrum of radionuclides expected from forty years of plant operation, no plant process system identified as being contaminated upon final shutdown will become releasable due to the decay period alone, i.e., there is no significant reduction in the waste generated from the decommissioning activities. However, due to the lower activity levels, a greater percentage of the waste volume can be designated for off-site processing and recovery.

The delay in decommissioning also yields lower working area radiation levels.

As such, the estimate for this delayed scenario incorporates reduced ALARA controls for the SAFSTOR's lower occupational exposure potential.

2.4 PERIOD 4 - DEFERRED DECOMMISSIONING This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR §50 operating license. Although the initial radiation levels due to 60Co will decrease during the dormancy period, the internal components of the reactor vessel will still exhibit sufficiently high radiation dose rates to require remote sectioning under water due to the presence of long-lived radionuclides such as 94Nb, 59Ni, and 63Ni. Therefore, the remote dismantling procedures would still be employed during this scenario. Portions of the biological shield will still be radioactive due to the presence of activated trace elements with long half-lives (152Eu and 154Eu). Decontamination will require controlled removal and disposal. It is assumed that radioactive corrosion products on inner surfaces of piping and components will not have decayed to levels that will permit unrestricted use or allow conventional removal. These systems and components will be surveyed as they are removed and disposed of in accordance with the existing radioactive release criteria.

Significant decommissioning activities in this phase include:

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Crystal River Unit 3 Nuclear GeneratingPlant DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 2, Page 5 of 8

• Construction of temporary facilities and/or modification of existing facilities to support dismantling activities. This may include a centralized processing area to facilitate equipment removal and component preparations for off-site disposal.

" Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on- and off-site) to facilitate hauling and transport. Modifications may be required to the reactor building to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the reactor building to support the segmentation of the reactor vessel internals and component extraction.

• Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

• Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages for the disposition of low-level radioactive waste.

• Decontamination of components and piping systems as required to control (minimize) worker exposure.

" Removal of piping and components no longer essential to support decommissioning operations.

• Removal of control rod drive housings and the head service structure from the reactor vessel head. Segmentation of the vessel closure head.

" Removal and segmentation of the upper internals assemblies.

Segmentation will maximize the loading of the shielded transport casks, i.e., by weight and activity. The operations are conducted under water using remotely operated tooling and contamination controls.

• Disassembly and segmentation of the remaining reactor internals, including the core shroud and lower core support assembly. Some material is expected to exceed Class C disposal requirements. As such, the segments will be packaged in modified fuel storage canisters for geologic disposal.

• Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air using remotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Segments are transferred in-air to containers that are stored under water, for example, in an isolated area of the refueling canal.

" Removal of the activated portions of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate Section 2, Page 6 of 8 associated cubicles necessary for access and component extraction are removed.

• Removal of the steam generators and pressurizer for material recovery and controlled disposal. The generators will be moved to an on-site processing center and prepared for transport to the disposal site. To facilitate transport, the generators are cut in half, across the tube bundle. The exposed ends are capped and sealed. The segments can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized. A similar process will be used to prepare the retired units for disposal. The pressurizer is disposed of intact.

" Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems).

• Removal of the steel liners from refueling canal, disposing of the activated and contaminated sections as radioactive waste. Removal of any activated/

contaminated concrete.

• Surveys of the decontaminated areas of the reactor building.

• Remediation and removal of the contaminated equipment and material from the auxiliary building and any other contaminated facility. Radiation and contamination controls will be utilized until residual levels indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems and components (both clean and contaminated) located within these buildings. This activity facilitates surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.

Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination is released for unrestricted disposition, e.g., as scrap, recycle, or general disposal. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.

Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)."[19] This document incorporates the statistical approaches to survey design and data TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 2, Page 7 of 8 interpretation used by the EPA. It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys.

Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied.

Once the survey is complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on the requested change to the operating license (that would release the property, exclusive of the ISFSI, for unrestricted use).

The NRC will terminate the operating license if it determines that site remediation has been performed in accordance with the LTP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.

2.5 PERIOD 5 - SITE RESTORATION Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the structures. Although performed in a controlled and safe manner, the blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures. Under certain circumstances, verifying that subsurface radionuclide concentrations meet NRC site release requirements will require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity will be necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station.

Prompt dismantling of site structures is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.

This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity. Foundations and TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 2, Page 8 of 8 exterior walls are removed to a nominal depth of three feet below grade. The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.

Non-contaminated concrete rubble produced by demolition activities is processed to remove reinforcing steel and miscellaneous embedments. The processed material is then used on site to backfill foundation voids. Excess non-contaminated materials are trucked to an off-site area for disposal as construction debris.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 1 of 26

3. COST ESTIMATE The cost estimate prepared for decommissioning Crystal River considers the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimate, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.

3.1 BASIS OF ESTIMATE The estimate was developed using the site-specific, technical information from the 2008 analysis. This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.

3.2 METHODOLOGY The methodology used to develop the estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[20 1 and the DOE "Decommissioning Handbook."[ 21] These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates. The activity-dependent costs are estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures rely upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.[221 The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 2 of 26 This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

Work Difficulty Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment. WDFs are assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined, hazardous environments.

The ranges used for the WDFs are as follows:

• Access Factor 10% to 20%

• Respiratory Protection Factor 10% to 50%

• Radiation/ALARA Factor 10% to 37%

• Protective Clothing Factor 10% to 30%

• Work Break Factor 8.33%

The factors and their associated range of values were developed in conjunction with the AIF/NESP-036 study. The application of the factors is discussed in more detail in that publication.

Scheduling Program Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiological controlled areas.

The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is based upon productivity information available from the "Building Construction Cost Data" publication.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 3 of 26 engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs.

3.3 FINANCIAL COMPONENTS OF THE COST MODEL TLG's proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.

3.3.1 Contingency The activity- and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers "Project and Cost Engineers' Handbook"[2 3] as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, contingency is included. In the AIF/NESP-036 study, the types of unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 4 of 26 successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 10% to 75%,

depending on the degree of difficulty judged to be appropriate from TLG's actual decommissioning experience. The contingency values used in this study are as follows:

• Decontamination 50%

• Contaminated Component Removal 25%

• Contaminated Component Packaging 10%

• Contaminated Component Transport 15%

• Low-Level Radioactive Waste Disposal 25%

• Reactor Segmentation 75%

• NSSS Component Removal 25%

• Reactor Waste Packaging 25%

• Reactor Waste Transport 25%

• Reactor Vessel Component Disposal 50%

• GTCC Disposal 15%

• Non-Radioactive Component Removal 15%

• Heavy Equipment and Tooling 15%

• Supplies 25%

• Engineering 15%

• Energy 15%

• Characterization and Termination Surveys 30%

• Construction 15%

• Taxes and Fees 10%

• Insurance 10%

• Staffing 15%

The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of the detailed estimate (Appendix C). For example, the composite contingency value reported in Appendix C is approximately 16.1%.

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Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 5 of 26 3.3.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk.

Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur.

Consideration is sometimes necessary to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term "financial risk." Included within the category of financial risk are:

• Transition activities and costs: ancillary expenses associated with eliminating 50% to 80% of the site labor force shortly after the cessation of plant operations, added cost for worker separation packages throughout the decommissioning program, national or company-mandated retraining, and retention incentives for key personnel.

" Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, legal challenges, and national and local hearings.

• Changes in the project work scope from the baseline estimate, involving the discovery of unexpected levels of contaminants, contamination in places not previously expected, contaminated soil previously undiscovered (either radioactive or hazardous material contamination), variations in plant inventory or configuration not indicated by the as-built drawings.

• Regulatory changes, for example, affecting worker health and safety, site release criteria, waste transportation, and disposal.

• Policy decisions altering national commitments (e.g., in the ability to accommodate certain waste forms for disposition), or in the timetable for such, for example, the start and rate of acceptance of spent fuel by the DOE.

" Pricing changes for basic inputs such as labor, energy, materials, and disposal. Items subject to widespread price competition (such as materials) may not show significant variation; however, others such as waste disposal could exhibit large pricing uncertainties, particularly in markets where limited access to services is available.

This cost study does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 6 of 26 project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimate.

3.4 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study.

3.4.1 Spent Fuel Management The cost to dispose the spent fuel generated from plant operations is not reflected within the estimate to decommission Crystal River. Ultimate disposition of the spent fuel is within the province of the DOE's Waste Management System, as defined by the Nuclear Waste Policy Act. As such, the disposal cost is financed by a 1 mill/kWhr surcharge paid into the DOE's waste fund during operations. However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimate, as described below.

Completion of the decommissioning process is highly dependent upon the DOE's ability to remove spent fuel from the site. The timing for removal of spent fuel from the site is based upon the DOE's most recently published annual acceptance rates of 400 MTU/year for year 1, 3,800 MTU total for years 2 through 4 and 3,000 MTU/year for year 5 and beyond.[241 The DOE contracts provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst utilities and the option of providing priority acceptance from permanently shutdown nuclear reactors.

Because it is unclear how these mechanisms may operate once DOE begins accepting spent fuel from commercial reactors, this study assumes that DOE will accept spent fuel in an oldest fuel first order.

ISFSI The ISFSI, constructed to support plant operations, will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. Assuming that DOE commences repository operation in TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 7 of 26 2020, Crystal River fuel is projected to be first removed from the site beginning in 2024. The process is expected to be completed by the year 2057, based upon the current shutdown date. Based upon the expected completion date for fuel transfer, the ISFSI will be emptied prior to the commencement of decommissioning operations.

Operation and maintenance costs for the ISFSI are included within the estimate and address the cost for staffing the facility, as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters. Costs are also provided for the final disposition of the facility once the transfer is complete.

Storage Canister Design DOE has not identified any cask systems it may use. As such, for the purpose of this analysis, the design and capacity of the ISFSI is based upon the NUHOMS system, with a 32 fuel assembly capacity. A unit cost of approximately $1.46 million is used for pricing the internal multi-purpose canister (MPC) and the horizontal concrete storage module.

Canister Loading and Transfer An average cost of $700,000 is used for the labor and equipment to seal each spent fuel canister once it is loaded and to load/transport the spent fuel from the pool to the ISFSI pad. For estimating purposes, $100,000 is used to estimate the unit cost to transfer the fuel from the ISFSI into a DOE transport cask.

Operations and Maintenance An annual cost (excluding labor) of approximately $764,000 and $89,000 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively. Pool operations are expected to continue approximately six and one-half years after the cessation of operations.

ISFSI operating costs are based upon a 41 year period of operations following plant shutdown.

ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a horizontal, reinforced concrete storage module is used as a basis for the cost analysis. The final core off load, equivalent to 6 modules, are TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 8 of 26 assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel (i.e., to levels exceeding free-release limits). The steel support structure is assumed to be removed from these modules for controlled disposal. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the estimate.

GTCC The dismantling of the reactor internals generates radioactive waste considered unsuitable for shallow land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)).

The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the Federal Government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. Although there are strong arguments that GTCC waste is covered by the spent fuel contract with DOE and the fees being paid pursuant to that contract, DOE has taken the position that GTCC waste is not covered by that contract or its fees and that utilities, including Progress Energy, will have to pay an additional fee for the disposal of their GTCC waste. However, to date, the Federal Government has not identified a cost for disposing of GTCC or a schedule for acceptance. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used to store spent fuel and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

The GTCC material is assumed to be shipped directly to a DOE facility as it is generated from the segmentation of the reactor vessel internals.

3.4.2 Reactor Vessel and Internal Components The reactor pressure vessel and internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed in the refueling canal, where a turntable and remote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor cavity. Transportation cask specifications and transportation regulations dictate the segmentation and packaging methodology.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 9 of 26 Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites currently being decommissioned.

Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel.

Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (including the internals). However, its location on the Columbia River simplified the transportation analysis since:

• the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport,

• there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and

• transport speeds were very low, limited by the overland transport vehicle and the river barge.

As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State.

The characteristics of this arid site proved favorable in demonstrating compliance with land disposal regulations.

It is not known whether this option will be available when the Crystal River unit ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition. With lower levels of activation, the vessel shell can be packaged more efficiently than the curie-limited internal components.

This will allow the use of more conventional waste packages rather than shielded casks for transport.

3.4.3 Primary System Components Due to the natural decay of radionuclides over the dormancy period, a chemical decontamination is not included.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 10 of 26 The following discussion deals with the removal and disposition of the steam generators, but the techniques involved are also applicable to other large components, such as heat exchangers, component coolers, and the pressurizer. The steam generators' size and weight, as well as their location within the reactor building, will ultimately determine the removal strategy.

A trolley crane is set up for the removal of the generators. It can also be used to move portions of the steam generator cubicle walls and floor slabs from the reactor building to a location where they can be decontaminated and transported to the material handling area.

Interferences within the work area, such as grating, piping, and other components are removed to create sufficient laydown space for processing these large components.

The generators are rigged for removal, disconnected from the surrounding piping and supports, and maneuvered into the open area where they are lowered onto a dolly. Each generator is rotated into the horizontal position for extraction from the reactor building and placed onto a multi-wheeled vehicle for transport to an on-site processing and storage area.

The generators are segmented on-site to facilitate transportation. Each unit is cut in half, across the tube bundle. The exposed ends are capped and sealed. The interior volume is filled with low-density cellular concrete for stabilization of the internal contamination. Each component is then loaded onto a rail car for transport to the disposal facility.

Reactor coolant piping is cut from the reactor vessel once the water level in the ve'ssel (used for personnel shielding during dismantling and cutting operations in and around the vessel) is dropped below the nozzle zone. The piping is boxed and transported by shielded van. The reactor coolant pumps and motors are lifted out intact, packaged, and transported for processing and/or disposal.

3.4.4 Retired Components The estimate includes the cost to dispose of the retired reactor closure head expected to be in storage at the site upon the cessation of plant operations. The component is segmented, with the segments placed in sea-land containers or custom containers for disposal. The retired steam generators, currently in storage at the site, will be segmented to facilitate transportation.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 11 of 26 3.4.5 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled demolition. The main condensers are also disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it is surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.

3.4.6 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.1251 The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.

Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137 Cs, 9 0Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.

Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per shipment assumed permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 12 of 26 The transport of large intact components (e.g., large heat exchangers and other oversized components) will be by a combination of truck, rail, and/or multi-wheeled transporter.

Transportation costs for material requiring controlled disposal are based upon the mileage to the EnergySolutions facility in Clive, Utah and the Waste Control Specialist facility in Andrews County, Texas.

Transportation costs for off-site waste processing are based upon the mileage to Memphis, Tennessee. Truck transport costs are estimated 261 using published tariffs from Tri-State Motor Transit.[

3.4.7 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptance criteria of the disposal site) and recovery of the waste stream is performed off site at a licensed processing center. Any material leaving the site is subject to a survey and release charge, at a minimum.

The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in Appendix C, and summarized in Section 5. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete.

Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. The volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 13 of 26 Disposal fees are based upon estimated charges, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the majority of the material generated from the decontamination and dismantling activities is based upon the current cost for disposal at EnergySolutions facility in Clive, Utah. As a proxy, disposition of the Class B and C waste is based upon the last published rate schedule for non-compact waste for the Barnwell facility.

3.4.8 Site Conditions Following Decommissioning The NRC will terminate the site license if it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. The NRC's involvement in the decommissioning process will end at this point. Local building codes and state environmental regulations will dictate the next step in the decommissioning process, as well as the owner's own future plans for the site.

Non-essential structures or buildings severely damaged in decontamination process are removed to a nominal depth of three feet below grade. Concrete rubble generated from demolition activities is processed and made available as clean fill for the power block foundations. Excess construction debris is trucked off site as an alternative to onsite disposal. The excavations will be regraded such that the power block area will have a final contour consistent with adjacent surroundings. Certain facilities, which have continued use or value (e.g., the switchyard) are left intact.

The estimate includes the remediation of the west settling pond (approximately (500 cubic yards). This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria. Costs are also included for the remediation of the firing range (i.e., removal of soil containing lead residue).

3.5 ASSUMPTIONS The following are the major assumptions made in the development of the estimate for decommissioning the site.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Section 3, Page 14 of 26 3.5.1 Estimating Basis The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.

3.5.2 Labor Costs The craft labor required to decontaminate and dismantle the nuclear unit is acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis.

Progress Energy, as the licensee, will continue to provide site operations support, including decommissioning program management, licensing, radiological protection, and site security. A Decommissioning Operations Contractor (DOC) will provide the supervisory staff needed to oversee the labor subcontractors, consultants, and specialty contractors needed to perform the work required for the decontamination and dismantling effort. The DOC will also provide the engineering services needed to develop activity specifications, detailed procedures, detailed activation analyses, and support field activities such as structural modifications.

Personnel costs are based upon average salary information provided by Progress Energy. Overhead costs are included for site and corporate support, reduced commensurate with the staffing of the project.

Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel.

3.5.3 Design Conditions Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137 Cs, 9 0Sr, or transuranics) has been prevented from reaching levels exceeding those TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 15 of 26 that permit the major NSSS components to be shipped under current transportation regulations and disposal requirements.

The curie contents of the vessel and internals at final shutdown are derived from those listed in NUREG/CR-3474.[271 Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Crystal River components, projected operating life, and period of decay. Additional short-lived isotopes were derived from NUREG/CR-0130[28] and NUREG/CR-0672,[291 and benchmarked to the long-lived values from NUREG/CR-3474.

The control elements are disposed of along with the spent fuel, i.e., there is no additional cost provided for their disposal.

Activation of the reactor building is confined to the biological shield.

More extensive activation (at very low levels) of the interior structures within reactor buildings has been detected at several reactors and the owners have elected to dispose of the affected material at a controlled facility rather than reuse the material as fill on site or send it to a landfill. The ultimate disposition of the material removed from the reactor building will depend upon the site release criteria selected, as well as the designated end use for the site.

3.5.4 General Transition Activities Existing warehouses are cleared of non-essential material and remain for use by Progress Energy and its subcontractors. The plant's operating staff performs the following activities at no additional cost or credit to the project during the transition period:

" Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale.

• Drain and collect acids, caustics, and other chemical stores for recycle and/or sale.

• Process operating waste inventories, i.e., the estimate does not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioning expense.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 16 of 26 Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Progress Energy will make economically reasonable efforts to salvage equipment following final plant shutdown. However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts.

It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimate do not include the additional cost for size reduction and preparation to meet "furnace ready" conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project.

Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property is removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts are also made available for alternative use.

Energy For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage.

Replacement power costs are used to calculate the cost of energy consumed during decommissioning for tooling, lighting, ventilation, and essential services.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 17 of 26 Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."[30° The NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.

Taxes The tax model is based upon the current tax obligation by the owers.

Taxes on plant systems and structures are included (at a reduced level) and further reduced as dismantling operations proceed. Taxes are included on the land and the ISFSI (during its operation), throughout the decommissioning timeframe.

Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.

3.6 COST ESTIMATE

SUMMARY

Schedules of expenditures are provided in Tables 3.1 through 3.4. The tables delineate the cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).

The cost elements are also assigned to one of three subcategories: "License Termination," "Spent Fuel Management," and "Site Restoration." The subcategory "License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in its financial assurance regulations (i.e., 10 CFR §50.75). In situations where the long-term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.

The "Spent Fuel Management" subcategory contains costs associated with the construction of an ISFSI, the containerization and transfer of spent fuel to the ISFSI over the six and one-half years of post-shutdown pool operations, and TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 18 of 26 the management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g., geologic repository) is complete.

"Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.

Decommissioning costs are reported in 2011 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedule is based upon the detailed activity costs reported in Appendix C, along with the timeline presented in Section 4.

TLG Services, Inc.

Crystal River Unit 3 Nuclear Generating Plant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 19 of 26 TABLE 3.1 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2016 3,035 103 94 3 969 4,204 2017 38,811 2,388 1,179 418 12,447 55,243 2018 24,371 6,630 636 1,335 28,746 61,718 2019 12,067 5,027 236 14 18,718 36,062 2020 12,100 5,040 236 14 18,769 36,160 2021 12,067 5,027 236 14 18,718 36,062 2022 12,067 5,027 236 14 18,718 36,062 2023 8,019 2,367 168 10 9,719 20,281 2024 5,078 426 118 7 3,159 8,788 2025 5,064 425 118 7 3,150 8,764 2026 5,064 425 118 7 3,150 8,764 2027 5,064 425 118 7 3,150 8,764 2028 5,078 426 118 7 3,159 8,788 2029 5,064 425 118 7 3,150 8,764 2030 5,064 425 118 7 3,150 8,764 2031 5,064 425 118 7 3,150 8,764 2032 5,078 426 118 7 3,159 8,788 2033 5,064 425 118 7 3,150 8,764 2034 5,064 425 118 7 3,150 8,764 2035 5,064 425 118 7 3,150 8,764 2036 1 5,078 426 118 7 3,159 8,788 2037 5,064 425 118 7 3,150 8,764 2038 5,064 425 118 7 3,150 8,764 2039 5,064 425 118 7 3,150 8,764 2040 1 5,078 426 118 7 3,159 8,788 2041 5,064 425 118 7 3,150 8,764 2042 5,064 425 118 7 3,150 8,764 2043 5,064 425 118 7 3,150 8,764 2044 1 5,078 426 118 7 3,159 8,788 2045 5,064 425 118 7 3,150 8,764 2046 5,064 425 118 7 3,150 8,764 2047 5,064 425 118 7 3,150 8,764 2048 1 5,078 426 118 7 3,159 8,788 2049 5,064 425 118 7 3,150 8,764 2050 5,064 425 118 7 3,150 8,764 2051 5,064 425 118 7 3,150 8,764 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 20 of 26 TABLE 3.1 (continued)

SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2052 5,078 426 118 7 3,159 8,788 2053 5,064 425 118 7 3,150 8,764 2054 5,064 425 118 7 3,150 8,764 2055 5,064 425 118 7 3,150 8,764 2056 5,078 426 118 7 3,159 8,788 2057 5,058 425 118 7 3,148 8,755 2058 2,862 298 118 6 2,150 5,434 2059 2,862 298 118 6 2,150 5,434 2060 2,869 299 118 6 2,156 5,448 2061 2,862 298 118 6 2,150 5,434 2062 2,862 298 118 6 2,150 5,434 2063 2,862 298 118 6 2,150 5,434 2064 2,869 299 118 6 2,156 5,448 2065 2,862 298 118 6 2,150 5,434 2066 2,862 298 118 6 2,150 5,434 2067 2,862 298 118 6 2,150 5,434 2068 2,869 299 118 6 2,156 5,448 2069 2,862 298 118 6 2,150 5,434 2070 2,862 298 118 6 2,150 5,434 2071 4,656 472 176 8 2,276 7,587 2072 36,052 3,622 1,182 32 4,470 45,358 2073 45,234 22,009 1,146 18,390 13,878 100,657 2074 46,421 23,157 1,014 24,118 15,270 109,980 2075 44,354 8,495 884 12,783 7,629 74,145 2076 30,089 3,499 337 2,193 3,450 39,568 2077 17,331 10,279 118 0 655 28,382 2078 10,541 6,252 72 0 398 17,263 Total 566,727 127,742 13,491 59,657 309,979 1,077,596 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear Generating Plant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 21 of 26 TABLE 3.2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2016 3,035 103 94 3 823 4,058 2017 38,811 2,388 1,179 418 10,610 53,405 2018 19,075 3,990 568 1,335 18,447 43,415 2019 2,862 438 118 14 2,175 5,607 2020 2,870 439 118 14 2,181 5,622 2021 2,862 438 118 14 2,175 5,607 2022 2,862 438 118 14 2,175 5,607 2023 2,862 362 118 10 2,174 5,525 2024 1 2,869 307 118 7 2,179 5,479 2025 2,862 306 118 7 2,173 5,465 2026 2,862 306 118 7 2,173 5,465 2027 2,862 306 118 7 2,173 5,465 2028 1 2,869 307 118 7 2,179 5,479 2029 2,862 306 118 7 2,173 5,465 2030 2,862 306 118 7 2,173 5,465 2031 2,862 306 118 7 2,173 5,465 2032 1 2,869 307 118 7 2,179 5,479 2033 2,862 306 118 7 2,173 5,465 2034 2,862 306 118 7 2,173 5,465 2035 2,862 306 118 7 2,173 5,465 2036 1 2,869 307 118 7 2,179 5,479 2037 2,862 306 118 7 2,173 5,465 2038 2,862 306 118 7 2,173 5,465 2039 2,862 306 118 7 2,173 5,465 2040 1 2,869 307 118 7 2,179 5,479 2041 2,862 306 118 7 2,173 5,465 2042 2,862 306 118 7 2,173 5,465 2043 2,862 306 118 7 2,173 5,465 2044 2,869 307 118 7 2,179 5,479 2045 2,862 306 118 7 2,173 5,465.

2046 2,862 306 118 7 2,173 5,465 2047 2,862 306 118 7 2,173 5,465 2048 2,869 307 118 7 2,179 5,479 2049 2,862 306 118 7 2,173 5,465 2050 2,862 306 118 7 2,173 5,465 2051 2,862 306 118 7 2,17 5,465 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant DocumentP23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Section 3, Page22 of 26 TABLE 3.2 (continued)

SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2052 2,869 307 118 7 2,179 5,479 2053 2,862 306 118 7 2,173 5,465 2054 2,862 306 118 7 2,173 5,465 2055 2,862 306 118 7 2,173 5,465 2056 2,869 307 118 7 2,179 5,479 2057 2,862 306 118 7 2,173 5,464 2058 2,862 298 118 6 2,150 5,434 2059 2,862 298 118 6 2,150 5,434 2060 2,869 299 118 6 2,156 5,448 2061 2,862 298 118 6 2,150 5,434 2062 2,862 298 118 6 2,150 5,434 2063 2,862 298 118 6 2,150 5,434 2064 2,869 299 118 6 2,156 5,448 2065 2,862 298 118 6 2,150 5,434 2066 2,862 298 118 6 2,150 5,434 2067 2,862 298 118 6 2,150 5,434 2068 2,869 299 118 6 2,156 5,448 2069 2,862 298 118 6 2,150 5,434 2070 2,862 298 118 6 2,150 5,434 2071 4,621 472 176 8 2,276 7,553 2072 35,366 3,622 1,182 32 4,470 44,672 2073 43,439 21,970 1,146 18,390 13,820 98,766 2074 44,947 23,086 1,014 24,109 14,794 107,949 2075 43,442 8,421 884 12,763 6,699 72,209 2076 28,520 2,641 327 2,189 3,239 36,916 2077 121 0 0 0 0 121 2078 74 0 0 0 0 74 Total 410,355 83,088 12,703 59,624 187,946 753,717 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 3, Page 23 of 26 TABLE 3.3 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2016 0 0 0 0 146 146 2017 0 0 0 0 1,838 1,838 2018 5,296 2,640 68 0 10,298 18,302 2019 9,205 4,589 118 0 16,543 30,455 2020 9,231 4,601 118 0 16,588 30,538 2021 9,205 4,589 118 0 16,543 30,455 2022 9,205 4,589 118 0 16,543 30,455 2023 5,157 2,005 50 0 7,545 14,757 2024 2,208 120 0 0 980 3,309 2025 2,202 120 0 0 978 3,300 2026 2,202 120 0 0 978 3,300 2027 2,202 120 0 0 978 3,300 2028 2,208 120 0 0 980 3,309 2029 2,202 120 0 0 978 3,300 2030 2,202 120 0 0 978 3,300 2031 2,202 120 0 0 978 3,300 2032 2,208 120 0 0 980 3,309 2033 2,202 120 0 0 978 3,300 2034 2,202 120 0 0 978 3,300 2035 2,202 120 0 0 978 3,300 2036 2,208 120 0 0 980 3,309 2037 2,202 120 0 0 978 3,300 2038 2,202 120 0 0 978 3,300 2039 2,202 120 0 0 978 3,300 2040 2,208 120 0 0 980 3,309 2041 2,202 120 0 0 978 3,300 2042 2,202 120 0 0 978 3,300 2043 2,202 120 0 0 978 3,300 2044 2,208 120 0 0 980 3,309 2045 2,202 120 0 0 978 3,300 2046 2,202 120 0 0 978 3,300 2047 2,202 120 0 0 978 3,300 2048 2,208 120 0 0 980 3,309 2049 2,202 120 0 0 978 3,300 2050 2,202 120 0 0 978 3,300 2051 2,202 120 0 0 978 3,300 TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 24 of 26 TABLE 3.3 (continued)

SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2052 2,208 120 0 0 980 3,309 2053 2,202 120 0 0 978 3,300 2054 2,202 120 0 0 978 3,300 2055 2,202 120 0 0 978 3,300 2056 2,208 120 0 0 980 3,309 2057 2,196 119 0 0 975 3,290 2058 0 0 0 0 0 0 2059 0 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0 2062 0 0 0 0 0 0 2063 0 0 0 0 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 0 0 0 0 0 0 2068 0 0 0 0 0 0 2069 0 0 0 0 0 0 2070 0 0 0 0 0 0 2071 0 0 0 0 0 0 2072 124 82 0 29 1,347 1,583 2073 0 0 0 0 0 0 2074 0 0 0 0 0 0 2075 0 0 0 0 0 0 2076 156 435 0 3 193 788 2077 0 0 0 0 0 0 2078 79 239 0 0 20 338 Total 122,583 27,839 589 32 120,866 271,910 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 25 of 26 TABLE 3.4 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2016 0 0 0 0 0 0 2017 0 0 0 0 0 0 2018 0 0 0 0 0 0 2019 0 0 0 0 0 0 2020 0 0 0 0 0 0 2021 0 0 0 0 0 0 2022 0 0 0 0 0 0 2023 0 0 0 0 0 0 2024 0 0 0 0 0 0 2025 0 0 0 0 0 0 2026 0 0 0 0 0 0 2027 0 0 0 0 0 0 2028 0 0 0 0 0 0 2029 0 0 0 0 0 0 2030 0 0 0 0 0 0 2031 0 0 0 0 0 0 2032 0 0 0 0 0 0 2033 0 0 0 0 0 0 2034 0 0 0 0 0 0 2035 0 0 0 0 0 0 2036 0 0 0 0 0 0 2037 0 0 0 0 0 0 2038 0 0 0 0 0 0 2039 0 0 0 0 0 0 2040 0 0 0 0 0 0 2041 0 0 0 0 0 0 2042 0 0 0 0 0 0 2043 0 0 0 0 0 0 2044 0 0 0 0 0 0 2045 0 0 0 0 0 0 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 TLG Services, Inc.

CrystalRiver Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 3, Page 26 of 26 TABLE 3.4 (continued)

SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2011 dollars)

Equipment & LLRW Year Labor Materials Energy Disposal Other Total 2052 0 0 0 0 0 0 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 2055 0 0 0 0 0 0 2056 0 0 0 0 0 0 2057 0 0 0 0 0 0 2058 0 0 0 0 0 0 2059 0 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0 2062 0 0 0 0 0 0 2063 0 0 0 0 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 0 0 0 0 0 0 2068 0 0 0 0 0 0 2069 0 0 0 0 0 0 2070 0 0 0 0 0 0 2071 34 0 0 0 0 34 2072 686 0 0 0 0 686 2073 1,794 38 0 0 58 1,890 2074 1,436 46 0 0 58 1,540 2075 827 17 0 0 0 844 2076 1,544 815 10 0 51 2,420 2077 17,079 9,886 118 0 622 27,705 2078 10,388 6,013 72 0 378 16,850 Total 33,789 16,814 199 0 1,167 51,969 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 4, Page I of 4

4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follow the sequences presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan described in Section 3.4.1.

A schedule or sequence of activities for the deferred decommissioning portion of the SAFSTOR alternative is presented in Figure 4.1. The scheduling sequence assumes that fuel has been removed from the site prior to the start of decontamination and dismantling activities. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was 31 prepared using the "Microsoft Project Professional 2010" computer software.[ 1 4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique) Software Package. The *work activity durations used in the precedence network reflect the actual person-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:

• The spent fuel handling area in the auxiliary building is isolated until such time that all spent fuel has been discharged from the spent fuel pool to the ISFSI.

• All work (except vessel and internals removal) is performed during an 8-hour workday, 5 days per week, with no overtime. There are eleven paid holidays per year.

• Reactor and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for the second shift.

" Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 4, Page 2 of 4 For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activity.

4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based upon the durations developed in the schedules for decommissioning. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs.

The project timeline is provided in Figure 4.2 with milestone dates based on a 2016 shutdown date. The fuel pool is emptied approximately six and one-half years after shutdown, while ISFSI operations continue until the DOE can complete the transfer of assemblies to its geologic repository. Deferred decommissioning is assumed to commence so that the operating license is terminated within a 60-year period from the cessation of plant operations.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001,Rev. 0 PreliminaryDecommissioning Cost Estimate Section 4, Page 3 of 4 FIGURE 4.1 ACTIVITY SCHEDULE 2075 2076 2077 2078 STask Name2074 2Q Q1QI Q2 1 3 104 1 1. Q2 IQ3 1(4 1Q2I Q2 IQ3 IQ4 IQ1I Q2 IQ3 IQ4 IQ1I Q2 IQ3 IQ4 IQ1I IQ21 1OTs~meQ 1 PERIOD 3a - Reactivate Site 2 Reconfigure plant 3 Prepare activity specifications 4 Perform site characterization 5 DOC staff mobilized 6 PERIOD 3b - Decommissioning Prep 7 Reconfigure plant a Prepare detailed work procedures 9 Decon NSSS 10 PERIOD 4a - Large Component Removal --

11 Prep for reactor vessel removal 12 Reactor vessel & internals 13 Remaining large NSSS components 14 Non-essential systems 15 Main turbine/generator 16 Main condenser 27 Reactor building systems removal 18 Systems removal not supporting RPV 19 PERIOD 4b - Site Decontamination 20 Reactor building systems removal 21 Reactor building Decon 22 Remaining Decom Activities 23 Removal of remaining systems 24 License termination plan approved 25 Decontamination of remaining buildings 26 PERIOD 4e- Ucense Termination 27 Final site survey 28 NRC review & approval 29 Part 50 license terminated 30 PERIOD 5b- site restoration 31 Building demoltions, backfill, landscape 32 Decommissioning Complete Legend: 1. Blue bars indicate overall duration of activity

2. Red bars indicate critical path activities

3. Diamond symbols indicate major milestones TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 4, Page 4 of 4 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale)

Shutdown Operating License December 3, 2016 Terminated 1 I Period 1 Period 2 Period 3 Period 4 Period 5 SAFSTOR Dormancy Decommissioning Deferred Site Preparations Preparations Decommissioning Restoration 12/2016 06/2018 12/2071 06/2073 12/2076 08/2078 Wet Transfer Complete Transfer of Irradiated Fuel from Pool to ISFS1 Dry Transfer 06/2023 Complete T

Transfer of Irradiated Fuel from ISFSI to DOE 2023 2057 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 5, Page I of 4

5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[321 the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.

Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR Parts 173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in 10 CFR

§173.411). For this study, commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.

The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in Appendix C, and summarized in Table 5.1. The quantified waste volume summaries shown in these tables are consistent with Part 61 classifications. The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.

The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners.

In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements .of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste),

where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone (i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides).

While the dose rates decrease with time, radionuclides such as 13 7Cs will still control the disposition requirements.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 5, Page 2 of 4 The waste material produced in the decontamination and dismantling of the nuclear unit is primarily generated during Period 4. The assumed disposition of waste material is shown in Figure 5.1. Material that is considered potentially contaminated when removed from the radiological controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.

Disposal fees are based upon estimated charges, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the majority of the material generated from the decontamination and dismantling activities is based upon the current cost for disposal at EnergySolutions facility in Clive, Utah. Separate rates were used for containerized waste and large components, including the steam generators and reactor coolant pump motors. Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste. As a proxy, disposition of the Class B and C waste is based upon the last published rate schedule for non-compact waste for the Barnwell facility.

TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 5, Page 3 of 4 FIGURE 5.1 DECOMMISSIONING WASTE DISPOSITION TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 5, Page 4 of 4 TABLE 5.1 DECOMMISSIONING WASTE

SUMMARY

Waste Volume Mass Waste Cost Basis Class [1] (cubic feet) (pounds)

Low-Level Radioactive Waste (near-surface EnergySolutions A 133,758 9,951,211 disposal)

Barnwell B 250 27,400 Barnwell C 501 57,900 Greater than Class C Spent Fuel (geologic repository) Equivalent GTCC 2,142 423,646 Processed/Conditioned Recycling (off-site recycling center) Vendors A 234,503 11,217,670 Total [21 371,154 21,677,830

[1] Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55

[2] Columns may not add due to rounding.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 6, Page 1 of 4

6. RESULTS The analysis to estimate the cost to decommission Crystal River relied upon the site-specific, technical information developed for a previous analysis prepared in 2008. While not an engineering study, the estimate provides Progress Energy with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The estimate described in this report is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The decommissioning scenarios assume continued operation of the station's spent fuel pool for a minimum of six and one half years following the cessation of operations for continued cooling of the assemblies. An ISFSI will be used to safeguard the spent fuel, once sufficiently cooled, until such time that the DOE can complete the transfer of the assemblies to its repository.

The cost projected for deferred decommissioning (SAFSTOR) is estimated to be

$1,077.6 million. The majority of this cost (approximately 70.0%) is associated with placing the unit in storage, ongoing caretaking of the unit during dormancy, and the eventual physical decontamination and dismantling of the nuclear unit so that the operating license can be terminated. Another 25.2% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 4.8% is for the demolition of the designated structures and limited restoration of the site.

The primary cost contributors, identified in Table 6.1, are either labor-related or associated with the management and disposition of the radioactive waste. Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the decommissioning, as well as the duration of the program. It is assumed, for purposes of this analysis, that Progress Energy will oversee the decommissioning program, using a DOC to manage the decommissioning labor force and the associated subcontractors. The size and composition of the management organization varies with the decommissioning phase and associated site activities.

However, once the operating license is terminated, the staff is substantially reduced for the conventional demolition and restoration of the site.

As described in this report, the spent fuel pool will remain operational for a minimum of six and one half years following the cessation of operations. The pool will be isolated and an independent spent fuel island created. Over the six and one-TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 6, Page2 of 4 half-year period, the spent fuel will be packaged into transportable steel canisters for interim storage at the ISFSI. Dry storage of the fuel provides additional flexibility in the event the DOE is not able to meet the current timetable for completing the transfer of assemblies to an off-site facility and minimizes the associated caretaking expenses.

The cost for waste disposal includes only those costs associated with the controlled disposition of the low-level radioactive waste generated from decontamination and dismantling activities, including plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, the EnergySolutions facility in Utah is the assumed destination for the majority of the low-level radioactive material required controlled disposal, with the remaining, high-activity waste destined for the newly opened Waste Control Specialists facility in Texas. Components, requiring additional isolation from the environment (i.e.,

GTCC), are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.

A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processes as survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at one of the currently operating facilities. The cost identified in the summary tables for processing is all-inclusive, incorporating the ultimate disposition of the material.

Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program.

Decontamination and packaging costs also have a large labor component that is based upon prevailing union wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can be more cost effective than deferral, due to the deterioration of the facilities (and therefore the working conditions) with time.

The reported cost for transport includes the tariffs and surcharges associated with moving large components and/or overweight shielded casks overland, as well as the general expense, e.g., labor and fuel, of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 6, Page 3 of 4 Decontamination is used to reduce the plant's radiation fields and minimize worker exposure. Slightly contaminated material or material located within a contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for uncontrolled release in-situ. Centralized processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear unit.

License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings. The status of any plant components and materials not removed in the decommissioning process will also require confirmation and will add to the expense of surveying the facilities alone.

The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.

TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate Section 6, Page 4 of 4 TABLE 6.1 DECOMMISSIONING COST ELEMENT CONTRIBUTION (thousands of 2011 dollars)

Cost Element Total Percentage Decontamination 12,409 1.2 Removal 101,075 9.4 Packaging 22,681 2.1 Transportation 11,922 1.1 Waste Disposal 46,245 4.3 Off-site Waste Processing 23,246 2.2 Program Management [1] 306,020 28.4 Site Security 183,679 17.0 Spent Fuel Pool Isolation 11,822 1.1 Spent Fuel Management [21 129,013 12.0 Insurance and Regulatory Fees 61,040 5.7 Energy 13,491 1.3 Characterization and Licensing Surveys 15,110 1.4 Property Taxes 87,216 8.1 Utility Site Indirect 19,326 1.8 Corporate Allocations 14,257 1.3 Miscellaneous Equipment 19,045 1.8 Total [31 1,077,596 100 Cost Element Total Percentage License Termination 753,717 70.0 Spent Fuel Management 271,910 25.2 Site Restoration 51,969 4.8 Total [31 1,077.,596 100

[1] Includes engineering and security costs

[21 Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees

[31 Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 7, Page 1 of 3

7. REFERENCES

1. "Decommissioning Cost Analysis for the Crystal River Plant, Unit 3," Document No. P23-1597-002, Rev. 0, TLG Services, Inc., October 2008

2. U.S. Code of Federal Regulations, Title 10, Part 50.75, "Reporting and recordkeeping for decommissioning planning," Subpart (f0(3)

3. U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988

4. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," October 2003

5. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "Radiological Criteria for License Termination"

6. U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, "Entombment Options for Power Reactors," Advanced Notice of Proposed Rulemaking, Federal Register Volume 66, Number 200, October 16, 2001

7. U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61 (p 39278 et seq.), July 29, 1996.

8. "Nuclear Waste Policy Act of 1982 and Amendments," U.S. Department of Energy's Office of Civilian Radioactive Management, 1982

9. Testimony of Edward Sproat, Director, Office of Civilian Radioactive Waste Management, before a U.S. House of Representatives subcommittee on the status of Yucca Mountain, July 15, 2008

10. U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," Subpart 54 (bb), "Conditions of Licenses"

11. U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Section 7, Page 2 of 3

7. REFERENCES (continued)

12. "Low Level Radioactive Waste Policy Act," Public Law 96-573, 1980

13. "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986

14. Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55

15. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "Radiological Criteria for License Termination," Federal Register, Volume 62, Number 139 (p 39058 et seq.), July 21, 1997

16. "Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination," EPA Memorandum OSWER No. 9200.4-18, August 22, 1997.

17. U.S. Code of Federal Regulations, Title 40, Part 141.16, "Maximum contaminant levels for beta particle and photon radioactivity from man-made radionuclides in community water systems"

18. "Memorandum of Understanding Between the Environmental Protection Agency and the Nuclear Regulatory Commission: Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites," OSWER 9295.8-06a, October 9, 2002

19. "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),"

NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000

20. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986

21. W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.

Department of Energy, DOE/EV/10128-1, November 1980

22. "Building Construction Cost Data 2011," Robert Snow Means Company, Inc.,

Kingston, Massachusetts

23. Project and Cost Engineers' Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984 TLG Services, Inc.

CrystalRiver Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Section 7, Page 3 of 3

7. REFERENCES (continued)

24. Civilian Radioactive Waste Management System Waste Acceptance System Requirements Document, Revision 5" (DOE/RW-0351) issued May 31, 2007

25. U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178

26. Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, August 2011

27. J.C. Evans et al., "Long-Lived Activation Products in Reactor Materials" NUREG/CR-3474, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. August 1984

28. R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,"

NUREG/CR-0130 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1978

29. H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1980

30. "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors," 10 CFR Parts 50 and 140, Federal Register Notice, Vol. 62, No. 210, October 30, 1997

31. "Microsoft Project Professional 2010," Microsoft Corporation, Redmond, WA.

32. "Atomic Energy Act of 1954," (68 Stat. 919)

TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Appendix A, Page I of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Appendix A, Page 2 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example: Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1. SCOPE Heat exchangers weighing < 3,000 lbs. will be removed in one piece using a crane or small hoist. They will be disconnected from the inlet and outlet piping. The heat exchanger will be sent to the waste processing area.

2. CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes) (minutes)*

a Remove insulation 60 (b) b Mount pipe cutters 60 60 c Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e Cap openings 20 (d) f Rig for removal 30 30 g Unbolt from mounts 30 30 h Remove contamination controls 15 15 i Remove, wrap, send to waste processing area 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):

+ Respiratory protection adjustment (50% of critical duration) 128

+ Radiation/ALARA adjustment (37% of critical duration) 95 Adjusted work duration 478

+ Protective clothing adjustment (30% of adjusted duration) 143 Productive work duration 621

+ Work break adjustment (8.33 %of productive duration) 52 Total work duration (minutes) 673

• • • Total duration = 11.217 hr *

• alpha designators indicate activities that can be performed in parallel TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate Appendix A, Page 3 of 4 APPENDIX A (continued)

3. LABOR REQUIRED Duration Rate Crew Number (hours) ($Ihr) Cost Laborers 3.00 11.217 $28.05 $943.91 Craftsmen 2.00 11.217 $51.72 $1,160.92 Foreman 1.00 11.217 $60.83 $682.33 General Foreman 0.25 11.217 $63.09 $176.92 Fire Watch 0.05 11.217 $28.05 $15.73 Health Physics Technician 1.00 11.217 $44.00 $493.55 Total Labor Cost $3,472.73

4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs

-Universal Sorbent 50 @ $0.62 sq ft {(} $31.00

-Tarpaulins (oil resistant/fire retardant) 50 @ $0.46/sq ft 12} $23.00

-Gas torch consumables 1 @ $11.84/hr x 1 hr {(3 $11.84 Subtotal cost of equipment and materials $65.84 Overhead & profit on equipment and materials @ 16.00 % $10.53 Total costs, equipment & material $76.37 TOTAL COST:

Removal of contaminated heat exchanger <3000 pounds: $3,549.10 Total labor cost: $3,472.73 Total equipment/material costs: $76.37 Total craft labor man-hours required per unit: 81.88 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Appendix A, Page 4 of 4

5. NOTES AND REFERENCES

• Work difficulty factors were developed in conjunction with the Atomic Industrial Forum's (now NEI) program to standardize nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5 of the "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

" References for equipment & consumables costs:

1. www.mcmaster.com online catalog, McMaster Carr Spill Control (7193T88)

2. R.S. Means (2011) Division 01 56, Section 13.60-0600, page 20

3. R.S. Means (2011) Division 01 54 33, Section 40-6360, page 664

• Material and consumable costs were adjusted using the regional indices for Tampa, Florida.

TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001,Rev. 0 Preliminary Decommissioning Cost Estimate Appendix B, Page I of 7 APPENDIX B UNIT COST FACTOR LISTING (SAFSTOR: Power Block Structures Only)

TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.36 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 3.62 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 5.50 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 11.41 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 21.18 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 27.56 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 40.54 Removal of clean pipe >36 inches diameter, $/linear foot 48.16 Removal of clean valve >2 to 4 inches 76.72 Removal of clean valve >4 to 8 inches 114.08 Removal of clean valve >8 to 14 inches 211.82 Removal of clean valve >14 to 20 inches 275.56 Removal of clean valve >20 to 36 inches 405.40 Removal of clean valve >36 inches 481.61 Removal of clean pipe hanger for small bore piping 24.48 Removal of clean pipe hanger for large bore piping 82.23 Removal of clean pump, <300 pound 192.65 Removal of clean pump, 300-1000 pound 550.51 Removal of clean pump, 1000-10,000 pound 2,149.11 Removal of clean pump, >10,000 pound 4,156.91 Removal of clean pump motor, 300-1000 pound 230.87 Removal of clean pump motor, 1000-10,000 pound 894.31 Removal of clean pump motor, >10,000 pound 2,012.19 Removal of clean heat exchanger <3000 pound 1,164.56 Removal of clean heat exchanger >3000 pound 2,932.13 Removal of clean feedwater heater/deaerator 8,191.42 Removal of clean moisture separator/reheater 16,745.08 Removal of clean tank, <300 gallons 247.78 Removal of clean tank, 300-3000 gallon 780.85 Removal of clean tank, >3000 gallons, $/square foot surface area 6.76 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean electrical equipment, <300 pound 104.76 Removal of clean electrical equipment, 300-1000 pound 375.90 Removal of clean electrical equipment, 1000-10,000 pound 751.80 Removal of clean electrical equipment, >10,000 pound 1,841.91 Removal of clean electrical transformer < 30 tons 1,279.18 Removal of clean electrical transformer > 30 tons 3,683.82 Removal of clean standby diesel generator, <100 kW 1,306.57 Removal of clean standby diesel generator, 100 kW to 1 MW 2,916.36 Removal of clean standby diesel generator, >1 MW 6,037.46 Removal of clean electrical cable tray, $/linear foot 9.82 Removal of clean electrical conduit, $/linear foot 4.29 Removal of clean mechanical equipment, <300 pound 104.76 Removal of clean mechanical equipment, 300-1000 pound 375.90 Removal of clean mechanical equipment, 1000-10,000 pound 751.80 Removal of clean mechanical equipment, >10,000 pound 1,841.91 Removal of clean HVAC equipment, <300 pound 126.69 Removal of clean HVAC equipment, 300-1000 pound 451.67 Removal of clean HVAC equipment, 1000-10,000 pound 900.18 Removal of clean HVAC equipment, >10,000 pound 1,841.91 Removal of clean HVAC ductwork, $/pound 0.38 Removal of contaminated instrument and sampling tubing, $/linear foot 1.19 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 18.15 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 30.28 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 49.50 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 93.16 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 110.95 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 151.69 Removal of contaminated pipe >36 inches diameter, $/linear foot 178.39 Removal of contaminated valve >2 to 4 inches 370.40 Removal of contaminated valve >4 to 8 inches 437.70 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated valve >8 to 14 inches 868.96 Removal of contaminated valve >14 to 20 inches 1,098.06 Removal of contaminated valve >20 to 36 inches 1,454.27 Removal of contaminated valve >36 inches 1,721.27 Removal of contaminated pipe hanger for small bore piping 115.54 Removal of contaminated pipe hanger for large bore piping 370.99 Removal of contaminated pump, <300 pound 783.33 Removal of contaminated pump, 300-1000 pound 1,841.28 Removal of contaminated pump, 1000-10,000 pound 5,810.90 Removal of contaminated pump, >10,000 pound 14,145.54 Removal of contaminated pump motor, 300-1000 pound 810.42 Removal of contaminated pump motor, 1000-10,000 pound 2,394.87 Removal of contaminated pump motor, >10,000 pound 5,376.99 Removal of contaminated heat exchanger <3000 pound 3,549.10 Removal of contaminated heat exchanger >3000 pound 10,358.57 Removal of contaminated tank, <300 gallons 1,310.02 Removal of contaminated tank, >300 gallons, $/square foot 25.36 Removal of contaminated electrical equipment, <300 pound 596.45 Removal of contaminated electrical equipment, 300-1000 pound 1,488.20 Removal of contaminated electrical equipment, 1000-10,000 pound 2,867.82 Removal of contaminated electrical equipment, >10,000 pound 5,776.36 Removal of contaminated electrical cable tray, $/linear foot 28.72 Removal of contaminated electrical conduit, $/linear foot 14.91 Removal of contaminated mechanical equipment, <300 pound 662.99 Removal of contaminated mechanical equipment, 300-1000 pound 1,641.54 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,158.03 Removal of contaminated mechanical equipment, >10,000 pound 5,776.36 Removal of contaminated HVAC equipment, <300 pound 662.99 Removal of contaminated HVAC equipment, 300-1000 pound 1,641.54 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,158.03 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated HVAC equipment, >10,000 pound 5,776.36 Removal of contaminated HVAC ductwork, $/pound 1.80 Removal/plasma arc cut of contaminated thin metal components, $/linear in. 3.23 Additional decontamination of surface by washing, $/square foot 6.53 Additional decontamination of surfaces by hydrolasing, $/square foot 31.91 Decontamination rig hook up and flush, $/ 250 foot length 5,548.30 Chemical flush of components/systems, $/gallon 19.54 Removal of clean standard reinforced concrete, $/cubic yard 129.38 Removal of grade slab concrete, $/cubic yard 162.13 Removal of clean concrete floors, $/cubic yard 341.10 Removal of sections of clean concrete floors, $/cubic yard 995.12 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 229.00 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,919.93 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 289.56 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,536.65 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 429.87 Removal of below-grade suspended floors, $/cubic yard 341.10 Removal of clean monolithic concrete structures, $/cubic yard 817.52 Removal of contaminated monolithic concrete structures, $/cubic yard 1,904.47 Removal of clean foundation concrete, $/cubic yard 643.51 Removal of contaminated foundation concrete, $/cubic yard 1,774.63 Explosive demolition of bulk concrete, $/cubic yard 29.38 Removal of clean hollow masonry block wall, $/cubic yard 77.50 Removal of contaminated hollow masonry block wall, $/cubic yard 265.37 Removal of clean solid masonry block wall, $/cubic yard 77.50 Removal of contaminated solid masonry block wall, $/cubic yard 265.37 Backfill of below-grade voids, $/cubic yard 34.32 Removal of subterranean tunnels/voids, $/linear foot 96.84 Placement of concrete for below-grade voids, $/cubic yard 137.89 Excavation of clean material, $/cubic yard 3.36 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Excavation of contaminated material, $/cubic yard 40.38 Removal of clean concrete rubble (tipping fee included), $/cubic yard 24.09 Removal of contaminated concrete rubble, $/cubic yard 23.97 Removal of building by volume, $/cubic foot 0.29 Removal of clean building metal siding, $/square foot 0.86 Removal of contaminated building metal siding, $/square foot 3.17 Removal of standard asphalt roofing, $/square foot 1.70 Removal of transite panels, $/square foot 1.88 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 11.67 Scabbling contaminated concrete floors, $/square foot 6.61 Scabbling contaminated concrete walls, $/square foot 17.02 Scabbling contaminated ceilings, $/square foot 57.99 Scabbling structural steel, $/square foot 5.54 Removal of clean overhead crane/monorail < 10 ton capacity 551.82 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,560.67 Removal of clean overhead crane/monorail >10-50 ton capacity 1,324.37 Removal of contaminated overhead crane/monorail >10-50 ton capacity 3,744.98 Removal of polar crane > 50 ton capacity 5,680.92 Removal of gantry crane > 50 ton capacity 23,023.90 Removal of structural steel, $/pound 0.19 Removal of clean steel floor grating, $/square foot 4.27 Removal of contaminated steel floor grating, $/square foot 12.24 Removal of clean free standing steel liner, $/square foot 10.13 Removal of contaminated free standing steel liner, $/square foot 29.57 Removal of clean concrete-anchored steel liner, $/square foot 5.06 Removal of contaminated concrete-anchored steel liner, $/square foot 34.44 Placement of scaffolding in clean areas, $/square foot 17.33 Placement of scaffolding in contaminated areas, $/square foot 25.14 Landscaping with topsoil, $/acre 31,052.99 Cost of CPC B-88 LSA box & preparation for use 2,330.58 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Cost of CPC B-25 LSA box & preparation for use 2,128.87 Cost of CPC B- 12V 12 gauge LSA box & preparation for use 1,720.00 Cost of CPC B- 144 LSA box & preparation for use 12,064.98 Cost of LSA drum & preparation for use 198.16 Cost of cask liner for CNSI 8 120A cask (resins) 8,331.49 Cost of cask liner for CNSI 8 120A cask (filters) 8,734.69 Decontamination of surfaces with vacuuming, $/square foot 0.68 TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate Appendix C, Page I of 12 APPENDIX C DETAILED COST ANALYSIS TLG Services, Inc.

C-y*atl River Unit 3 Nuclear Generting Plant Document P23-16I1-001, Ret. 0 Preliinuey Deo.Iealuning Cat EatlU-te Appendix C. Page 2f 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (tht.uusnds of 2011 dollar.)

I eoon Rmeoual Pack.giog Trenopon Off-site Po..iog LLRW Dihpu..l Other Totl Tutul NRC LIe-T.erm . Sp-n Fuel gent S te ReM.oraeio. Pr-se Vol.oe,,r-a1 Cl.ss A Cl.ss B V.I.e Cl... -Bur'alI/

C OTCC P-e--d Craft Ufflky-ad Co--tror IA[-dwtp .......... Co.. C.t" Co.-. Cu-e. Cute. Cste. Cute. Contiogeocy Cut. Cut. Cute. Co.- Cu. Feet Cu. Fot Cu. Feet C.. Fee Cu. Feet W., Lh.. M.nhoour. 3M.ihou PERIOD 1. - Shutdowo though T'r.osiioo Perosd HoDir-etDeooooie.iooiogdi Aetirlid 1.1.1 SAFSTOR sith.e e6 .- er i-ti.o-uuy 347 2N 451 451 a.1.2 Prupte prelimrinaryd oi-sirm gsotot 149 171 171 13600 I,. '.3 Notifirtioo of Ceation of r Qerau.os

.1.4 Ro-- f..u & .o..ur m Ic.1.5 No.ifi.Uisr of P-sre-t Defuelsog la.1.6 peo

.,i -,tep.tosy.suo

& p-ro -aote 1a.l.7 Prrtepe uod -ubmitPSDAR 229 4 263 263 2. I0 IsI8 Reviewpl-n dwgp& spo. 149 22 171 171 1.30M

]Ia] tPrforrederoiled rtd .ursso Is IS OIerrtlmtu by-prodootloornoory 114 17 M97 197 odprols d-esriplon ad1.11 1]4 17 132 132 Is 7 S2uDcidby.produs indenlory 172 27 197 i97 le.t.l3 Deu moj.or -ok-oque... 114 17 132 132 5.00o S14 PtrformSER .. d EA M35 5M 408 408 le.t.15 P-rfsrro Sisa-SpeoiflrCostStudy 86 01 658 AdritalySpci-ilo-s ole 3142 2132 le.N.I6. Prepe - plit t-d Sidbie, f., SAF,33 R M8 N48 G48 4.920 Ia.1.162 'lest eyeetoo 277 72 59 N49 4.167 1I..1.16.3 'I~to tsrturets od buldiog, M57 54 411 ,11 3.120 le.1.6.4 I, We o s.emtl 29 %3 263 2."00 1a.1.16.5 Pacdhty oedsiteadsrronoy M4 M 203 2.600 Ia 1.16 Tostal 27,8 2.133 2.133 16207 DetuitedWorhPornleea*

l1,1.17.1 l'leseyrsrso 1,183 l,..7.3 F.dscis d.o. t & d.-otry 137 273 41 314 311 2.a33 Ia 1.17 Total I, 1.10 Pros-os,,sumorrdresinesytrste I1I 2 13 13 10M l1 1.19 Prtiolde-orsrgize oosnorret s oa I 1.20 Dri. & dey NSSS 10.l.21 Srsirtide-rrrrSizeuossrausnrtedyurer l 1.22 Deoolsure ooramrodroody Cea' laot SubloralPuriod laeAcliisty Csos 145 720 5 173 5175 Period1t Colle.er.l Co.s.

..,3.1 Florid, LLRWlospectiroFee Is3 Subot] Poriod l. CellaerI Co.s-Period I, Poriod.DjpoedrrtCo-1 l4 4.1 r-rsur 1.334 1043 1.457 1.007 1 42 Propertytrato. 3.715 372 4007 4.007 1.4.3 Health phycio tuppht in 127 627 la.4.4 H_ y eruipmoentrenat 490 73 W`3 5%3 1.4.5 Dspoalof DAWgeoertatd 610 12.1W0 20 la 4.6 Ptoener.-budge. 1,025 15 1.179 1,179 l1a..7 NRCF1 7 45 846 l,4.0 rer.--oS PluooingFe 7. .157 -

la.4.9 UsiblySitu Trdiers 1,871 2M1 2 152 2,152 Is.4.10 Sport FPolPost O&M 763 1]4 878 1,.4.11 ISPSI OptebratnCosla 89 13 I03M 13 1.4.12 Co-r=ote A2l6'ons 214 1.602 1.642 le.4.13 INI'ClFers 135 la.4 14 Soerity SsuftCot 6598 600 7.588 7.508 157.471 le 4.15 -l1oitySaffCost S 22 197 3330 25.526 22.526 423.40W I0.4 Subhes] Poriod It Period-L*S.psrdrrs i.oe 14 W 30 40705 .5 95 47.735 45897 610 12190 20 580.871 991 10.0 TOTALPERIOD1.5l COST Iý30 45 16t 6705 52911 51.074 61W ]1- 1 20 616.761 14 TLG SeniceInc.

Cryetal Ricer Unit 3 Nuclear Generatin Plant Docinent P23-1651-001, Rev. 0 Preliminay Decommiaioning Cot &timnmte Appendi. C, Page3 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (tlnu,,ndof 2011 dollses)

IActivity Devon Removsl Pcksaging Trsnsport Possiog VNRC thberLL~t, Tot-1 Disp.ossI Off-Site Total Lie.Term. M.n.ge-t Sp-n Fuel Setorutioo Site Volume P-o-sd ClIss A lans B VolmsBrilIUilt-n

.-uria luss

. C TC Prom d Lt Crf Contrsctor AInden Actvity DlescripuionLu Ct Cout Lost. Losts Cout- CLout CLots Continr Ln ost.

- Co. Cots Ctost Cu. Fet C Feet Cu. Feet C. Feet C. Feet Wt.. Lbs. M.nhobr. Mnhsour.

PERIOD I1 - SAFSTORLimited DECONAtlultlu.

peritd lb DireDt DnmoomiuitoiotAcsioitis DecontaminstjonotSitn Btildiogs

b.l.I, Rnottr 980 490 1.470 1.400 lb.t.t.2 Auuliery Buddig 329 1"4 493 493 - - - - 7.527 1b.t..3 Fuslisodling Attn(un Bldo) 80& ,01 1-204 1.204 lb.l.t.4 Inte datne Bldg 67 34 10l 101 - . - - 1.557 tb.t.l.5 MachineSao. - Hot 46 23 69 69 1.031,

b.t.1.6 R"tW.b..o.2 14 43 4 lb.t.1.7 RVCHStorge Bnuildog 4 9061 tI.i.i Total. 2.258 1.12 3,386 3.386 lb.t Subotal PeriodIb Adtiýto C-t. 2.258 1,12 33&6 3.386 Psriol lb Addiu.on.l Lot Ib2.1 MiscWnta 425 w-0 681 241 1,987 1.987 2.343 1I.4 253 2892 lb.3 Subtotal Poodli Addti..onl Cot 422 633 681 211 1,987 1.987 2.343 158,W53. 2.892 Ptriod lb CLllabursl CLos lb.3.t D-tnteutcmeot 964 - - 145 1.109 1.109 lb.3.2 Pr- ds-tooomouiiog ut-rne~ta 33 318 254 1.057 1.057 841 5O.433 Iq4 tb.3.4 Stoal tool sllowuooo 6 47 47 41 3141 7 1 8 a lb.3 5 Gopids L+/-5Wlapnclou Fo 184 lb.3 Subtotal Periodlb Contol C-ost 1.097 318 2 355 2222 2.=2 841 58.433 Psriod Ib Priod-Dopendot Louts

b.4.l Dtoo upplits 901 225 1.126 1.126 lb.4.2 lootrsom 344 36 34 370 7 tb.4.3 Propertytout. &M8 64 701 261 Ib..s lltbh phbito -upplin YA' -92 458 ,58 tb.4.5 lýmy nquipmeot rentol S - 9 142 142 lb.4.6 Dipusl f DAWgooerstod -30 - 0o 1 61 602 12.041 20 lb.4.7 Plut eoergybtdgst 39 297 257 lb.4.l NRC Fo. 194 19 213 213 1b.4.9 cE,r lsoo ing Ions Pec 13 .2o 21G 216 1 2 1b..0 UtilityS-te 1Idto*,t 472 71, 542 &12 192 29 221 b:.4.11 Sptot FuelPool.. & 221 lb..12 JSFSIOperUtiogLots 23 3 26 tb.s.13 Corptorsto

' lt'onsu 3w0 64 414 414 lbs. I4 Snotity StaffCt 1.663 249 ],913 1.913 39*9]

tb.4.15 UtilityStff Lout M5595 69 60.34 6.4341 106.720 ib.4 Subttl Ptood Ib Ptriol.-D~eodtyt Lust. Sol 490 14 10 -302 9927 1.767 13.138 12,675 4Q* - 602 12 41 20 146.411 lb.2 TOTALFERIODlb,LST 4.5 531 1. 99977 601 348 9934 3.491 20.734 20270 463 2343 14,13 1.610.727 51.216 146.411 PERIOD t. - Preprut ion. fto SAPFTORD....,y Priod k Ditet Demtvtisstodtn titmilis le.].l Preprn supporttequipmetnt rot stuorge 4", 64 489 489 3.060 le.].2 Installtotaiveoot pressoo equsIlines 5 42 42 e1v13 ioterit sut"ey p-orttot dtormny 733 220 353 953 15,678 l.] .4 S--re buildiog s

1. 1b Prepar & sbrtttrmrpr 1,7 to 77 77 583

l. I Subtotal PeriodI Aftivity Cout. 800 .299 1,5W 1,560 W8 Period IeAdditioul CLt.

le 2 I Spt, FotI Inolsuoo 12.280 1.542' 1.022 11.022 lc 2 Subtotal Petid Ik AdditiuoslCLout 10.280 ,542 11.022 I 1.822 P.rted k Coll.teral Lost,

e.3.1 Pr-ss de.mmwssinionstar wsste 71 41s 386 247 1.2s3 1283 199 33 Smell

- to] .l 4 3 4 4 1,020 0],230

,3 4 Florids LLIRW Inespetio F.t 3 3

.68 2 24s 1.29. 9 199 1s3 Subtotal PFriudIt L Lout

-ll1tursI 71 TLG Se1ices, Inc.

Crystal Rier Unit 3 Nuclear Genermain Plant Document P23-1651-001.R.t. 0 PreliminaryDecommiioning Coat Estimate Appendix C, Page 4of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousa.nds f 2011 d,11a-)

I Off-Sit. LLRW NRC S-1n Sit Iue Pr-ed Bur0al -o1.-e -ri. I UIit Y.d I 3tdm ...... ...........

De-on Cost Iemotal Cost P-1bagoig Costs Tr.nsport Costs Pcosstg Costs Disposal Costs Otthet Co-Costs Costt Toa l Total loTerm.

Co(tt Maoagsent Costs Re.stortioo Co.ss VRolIn C.. Feet Class A C.Feet Class 5 CuFeet Class C C.Feet OTCC C.Feet Poross-d Wt., Lhs.

Cru-Mtanhtoura Contr.ctor Mahouo PttM 1, t H drid-OtpeodcotCosts 6,4.1 lotosoc 14 370 370 1e.4.2 Procortytotts It 4.3 Hlotth phytt* topplies 217 54 272 272 93 19 P,03 142 142 lo.4.4 HZ- tcotptet t-ot,1 le 4 L5 fpotolof D9W -geort.d 4 3 3 73 5 238 lol4 Pl-t eergybudgt 39 297 9 97

-c.4.7 NRCFstt 194 19 213 213 1c48 Emere-c Plannlng Fee 19% 20 216 216 lc.4.9 UtilitySile lodi-ot 472 542 kl.0 Sp.t Ful PtolO&M 192 29 M.

to 4t1 lSFSlOpertannosCosts 2*

1 to.4.t2 Ctro-ts .Slotioos 54 41 1414 olt13 Stortty Sff Cot 1663 249 h9ý11 39.,91 839 43,1 6434 *1 .721 t-.14 UtilityStf r"o"t t.4 Subtotl Petiod 1t Prottd.-ptdeot Costs Mi4 1 3 .120 1.526 12 NoO 11,6,,7 463 3 073 5 143311 Ic.0 TOTALPERIODt, COST 16, 806 74 4.0 194 21302 3414 26 772 463 4,0220 7319 582 146 PERIOD I TOTALS 4.417 2,328 584 IM7, GI 772 76.397 13811 lM.417 ,7.65.3 2764 2343 3.226 .672201 71318 9LO168 PERIOD 2a - SAFSTORDoorancy with WtoSpet Fool SIotos Perod 2o Fh[2rt t D o iooiog At-io 2a.lI.I Q ..toly Ittpettioo 2t.13 Prtpatrttrepor 2o14 Rttotuinoooorfreplstometot 347 37 2114 134 2t.1.5 Mioao.ntetnc upplim 925 843 92 269 206 842 1.127 1 127 2t.. Subtotat Potiot 2oAotivityCosa Piod 2a Collatel Cos..

2. 3 I Sp-nt FoolCapital sd Tsotrr 24.400 05w0 2a32 [IFSMlapittl E-poodotot 0069 67.997 67997 2o33 Florida LLRW1nsp-t.o. Fto 2 0

lt 3 Su.Mot P-.ld 2. 'olla tdrlcs 09.730 125M9 98.590 98587 PoeolJ2a. PEiod.Dtpoodot Cos-3508 351 3,859 3 487 372

2. 4 2 Prooertytatet 9881 908 10 M9 5 2N 5*2 4.t 3 H-tlth phtsi* sopplios 1,005 251 1,257 1,257 2o44 4 D,--oosalofDAW -- ertd 27 2 20 123 123 1.110 23.w08 38 2I 45 Pltt to-ty bodoet 1 025 154 1.171 589 589 20426 NRCF.os 1.102 1t0  :.212 1,212 2a47 mErey Plannin F- 999 too I1093 2.8 I t~t I=e[dr-t 1 732 200 h.992 52, 24 9 Spont Fue PloolO&M 1816 573 4.309 5438

2. 110 [SFSIOpertttiCgCt.t 447 07 510 40.

11 tooport .loa t ioot 1389 354 1,244

2. 4 12 Se 'tryStaff C-t 50743 3561 27.304 5.1, IS8286 555121 2.4 13 SholotyStffloI t 2911 20."I 3327 a'.198 411929 2s 4 Sobtotal Pettod 23 Period-DopendentCostt 1005 7 20 56 Q9553 9 930 80,59t 13 X6 1 150 23,900 38 967.250 2..0 TtITALP0RttD 2. C1OST 1.05 2 5% 156,205 229ý95 W80308 280335 152273 1.150 23.900 38 907250 PERIOD 2b- SAFSPItO)R Do-maooy itbhDry Spot Fool Storuge Potiod21,Dtro Doootonttt Attootii 26.1 I Qoartotrlyo[spoctiooo 2b 1.2 Serti.sooual nrobo eonotoltoooo Tb.]I3 Poeparetrepoot 2h.l.4 Ottotinoustrooftrtltooentt 1 711 27 1.947 7.N7 26 1.5 Mlaiottensnosupplits 4. 1, 167 3.035 5 :135 21..I Subtotal Pottolr2bAotioityCoota*

4370 1.424 7.002 7.80 Peroiod 2b toOllattra/Cotst 2b.3.1 Spent FootCtpiltMatd Trostert 48090 721 5.5211 2h632 lISFSIl*.apitoltpendlttoes ý3.0, 45. 3.45 3.45

.4520 2b.3.3 FI..tida FF010lospctttoo oet 7I TLG Saniees, Inc.

C"1.ta Rier Unit 3 N-clear Gene. ti Piant DIocment P23-1651-001,Ret. 0 Preiminaey Decommissioning Cot Estimate Appendix C, Page S of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thooaonds of 2011 dollars)

Z..ttoit lode. At~itity Description De-on Cost Removat Coo P.oksging Cost.

Transpntt Cost.

P.ssing Co.a Disposat Casts Other Costs Tot-t Contingenoy Total Costs Lit. Term.

Cos Management Costs e.Restoion Costs Voluie C. Feet Class A C. Feet Clh"sB C. Feet Cl... C C.. Fee GTCC C. Feet P eo d Wt., Lbs.

C-st M.nhoou Contrsotnr Mjnhouh I

2b3 Sobtotal P'tol 215 Coll2tbrslCott 7.807 I,171 8.978 8 8.970 Period2b Ptriod-Deptod-r Costa 2b4.f1 1-sts 22478 2.2N8 24.729 24,132 503 2b 4 2 Proprty tost. 45845 4.585 50.430 36.236 14.t93 2b 4 3 Hsthh phyios spphls 3.375 844 4.219 4219 2b.4.4 Dispose1ofDAW -t-ootttd 90 65 187 - 6ý 408 408 3.824 76.481 125 Sb4.5 Plt etorgy bodget 3546 532 4.778 4,078 2b 4.6 NRCFos. 7.625 792 8.M87 8387 2b 4.7 Em-rgencyP]ot- Fo s 6915 692 7,607 - 7.607 2b 48 Ubtty Sit, lodirect 5238 784 6,M24 3,37 2.395 2b4. ISFSIOpsrttng Co.tt 3095 464 3.559 - 3.559 2b4.t0 CorportetAltoaos 3894 584 4.478 2.449 2.029 2b 4.tt Se tfyStaff Cost 88783 13.318 102.101 62,402 39.699 I.lt8,4.01 2b4.12 Ubty StaffCost 6t1M1 9.188 70,438 3W.321 35.117 1.t51.,51 2b 4 Subtoti Period2bPtrioi-Oependeot Costa 3.375 w 187 20.677 04,27 286.450 181,262 105,194 3.82M 79.51 325 3.103126 2b.0 TOTALPERIOD 21bCOOT 3.375 SO 187 292.M57 20.663 303.236 189,072 114,164 3.824 798.81 32 Sf19 PERIOD t - SAFOTORDormsnoy without Spent Faet Storage Pooa SoDtra-oDooototog AdUt.to

'. Qotrttry Iopsotioo a .] 2 Seri..n..sltoiroo. talosroy So3.3 Fropoosrtpoot 2o.t.4 Bitumnousroof r-plo--ot I

990 344 784 794 20.1.5 MOf -tooosupphit 1,883 471 2,323 2353 2,.1 SubtotolPorod 2oAotivityCosts 3.573 574 3.147 3.1M 7 Pertod2SCo.latersl Cott-20.3.1 Florid, LLRW opspetioo Feo 3 0 0 33 2o.3 Sobtotal Poriot 2e Cofltorsl C.,

Period2oPod. DopodettCo.ts 2 1.4.t fosor- 8,849 8M5 9.734 M.734 2o.4.2 Propottytato 13287 1.329 14.616 14.616 2o4.3A sslth physioaspplies 3W I'M0 I.MO 2o.4.4 Dipas ofDAWgeotratd 34 24 70

• 24 152 152 1.421 25.412 46 20.4.5 Plst t..erg bodeto 1.430 215 1.645 1365 2a.4.6 NrRCFP 2,787 279 3.099 3095 2.4.7 Wtay Ott Iodtret, 1.273 391 1.464 1.464 2 '.4.8 Co-o-ratadl tlonbos 859 32M 903 950 2o4.9 SeoaoityStff Cost 21.M07 3.M03 2M,174 25.170 436.929 So4.10 ttlity Staff Cost 12,349 1.858 14247 14,247 254.700 2o.4 SObtotalPooiod2, Ptriod-D-ptodentCostt I28M 34 24 70 62,761 8.513 72.681 72.681 t.12t 28.412 46 6913329 1.281 34 24 21.0 TOTALPERIOD SoCOST 70 93.337 9.707 75831 75.831 1.421 28.412 46 6919.3-2 PERIOD 2tT~rALS3 5.,1 151 109 313 484398 68.743 559,376 292,939 2%437 6.39% 127.9M 209 4.761,704 PERIOD 3.. llestivste SitelF.nI.ooogOSAPcOR Dorosooy Poriod3. Di-rool Atibtiý A,,Mmossiooiog 3t.3.t CIropso po..tti oory oi~tio gri do-.t st 149 22 171 L71 1.377 3s.t.2 Rta so plsot dots & sps. 527 79 60% -0 4.700 3.13 Perfor detaldod todooy 3s.1.4 ERdprodootdotript ioo 17 132 132 iWoo 23.1.5 Detailedby-prodoutionoetoro S 171 173 0 149 3.i.9 Doino major.ook sntuooo 29 487 487 7.0oo t.t .7 Psrfor SER -d EA 149 53 403 403 3.3IM 3s.3 8 Perofot Sita.Spoflo CostSOtod 3.1.9 Poopattobot Lao Torooo Pba 70 ý9 539 3.3.I1 ReoeioeNRCspproosiof t pIS prin.tioo A'dtySped-eUon 3s.3.tf t Ro.sottoataplsnt&tteoporsoyfooliooa A44 17 970 873 97 7.370 3s.t.t .2 Pltnt"sstso 477 72 549 494 4.167 3t 1.113 Rastori.taro-aý 813 2 935 93 7,1W0 TLG So-1ice, Inc.

Crytal River Unit 3 Nuclear Gene ating Plant DIoeent P23-1651-001. Rev. 0 Preliminary Devnmissioning Cost FRttate Appendix C, Page of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thoussnds of 2011 dollars) tn... .... ..... . .. to....

. A. .. .. ...... ..

Aotiv 'itv Dnvxn Re mottvsl r v ksgtng Tvsn spxrt Pvxv ing Dlspxss l Othee To tls Tot l Li Te

e. rtx. M axsget e nt 5e-t restloe Volo me Cl ass A Clsss a 'lassC C GTCC Pvo xssed C rsfD svtxe r C ent led es Avitity Desl ripti on C.o st Cost Coets C ostt Costs Costs Costs C onti ngenoy Cosa Cots Cost s Costs C . F et C u.

Ftt C.. F et C.. Feet C . Fee Wt., Lbs.. Ml nhto urs M .nh o urs Ativity Spedf1iotlos (Onxliuxd) 3a.l.l1.4 Ret-o nsse] 744 112 856 856

3. 1115S Soaloevolsbield 57 3a.l.l 1.6 Sos., gtxteroato 337 54 111 411 3a 11.7 Moloford- d ot 183 27 211 105 3a.l.l1.8 Maix Ttbin. 46 53 3s.l.ll.S Maio Cx do._e 46ý 53 53 3.1.11.10 Pl'lte -troto & bSoidiogs 357 2O 3.12o 3a.I.Il.Il W~t~elavatgtvoent 527 7 606 Goo

• 4.600

3. 1 11.12wFdhty& stedcout 15 118 59 59 4,55w 61i3 5.23 4,609 627

3. 1 11 TotI "9.777 Planoog & Site Poep=stiot 3.1.12 Preparedisxttxioesevuen 275 41 316 316 2400 3a.113 Planoprep &oopxsve 2.800 4_20 3.210 3.2-20 3a. 14 De o atorvl*.upestlm

-rn 10 24 is, 184 3e.1.15 Rigglg/Con. Col Enalpvtloxltoleto 2.2o) 330 2.530 2.530 3.1 16 Prxt-k.4.-koers & -xt-ie- 141 21 162 162 1,230 3..1 Sobtota Period3. Aciity Cott 13.322 1998 15.321 1169' 627, 72 7W Ptriod 3, Adduoo...lCott 3t2.1 Sit Ch-txeoielxon Sovey 2.771 831 3.602 3.602 19.100 7,852 3a.2 Sobtotal Ptriod 3. AdditioxalCots 2.771 .31 3,602 3.602 19.100 7.852 Petitd 3UC.llstersl Cott 3:.3 I Flotd L W Ilpeotio F.t I0 I 3s.3 Sobtotal Period3e Collaterl Cots Perod 3 Period.Depxd.t Coe-3.4 1 lxeosxron 934 03 1.0-5 1,705 3o.0.2 Propt~ly tates 930 3e.4 3 Ieltth 1 ph ti vvppht- 438 Ito "I3 54 3t.4.4 Ilxy tqolpmo t tentsl 49o 73 563 602 3.4 5 Dsposal o D- W gdenert-d D 12 25 9 55 55 to 2ft.'17 3a.4 6 Plattene- budgel 1.025 154 1.179 1.179 3,.47 NRCF-, t 272 27 299 2-9 3a.4 8 Uoliey S.. Ildi-et 1,215 182 1,397 1,397 33.4.9 C--otto All-,...s 872 131 1W63 1.0Z3 3S.4 IS Sevoity Staff cxt 2.919 435 3357 3.357 G5,900 3atl1 UtilibtySff Co-t 13.6M5 2.044 15Go 15.669 2.5.629 25 21.513 514 102117 17 3M807 3,.1 SobtotalPeti)d 3. Ptriod.LDpeodet Cot. 920 12 3.326 25813 2.033 3.0 TOTALPERIOD 3a COST 9M8 12 25 37608 6.156 14.737 41110 627, 514 10.2117 19.117 404362 PERIOD 8b - Deeomlsion-g Prepration Peritd 3b [orv Doxoioiooite AL-i-ilid DetailedWorkProctd-3b.l.:.I PlIteeotexo 362 81 6M3 561 3b.1.1.2 Retctor iateelo 43 3_29 3N 2.500 155 3b.lI 3 Pe-siixaboildite, 178 44 3b.I.14 CRD 1itg -sembly 114 02 132 132 1000 3b.1.1.5 CRDhlooix & ICI tobs 32 32 I.000 3b.1.16 lovoreiotldmettai 17 132 132 I.000 3b.1.1.7 I lettolr -.- I 416 3.430 3I..1.8 IS Fality -l.ote 137 27 1,200 3b.1.1.9 M1issilextbields 12 59 I59 450 35.1.1.10 Siologixal shield 158 M5 3b.1.1.11 Steto genxertots 27 306 606 IO-3b.1.1.12 Rootrorctdtnxos , 17 1560ý

'79 V05 3b.1.1.13 Wmin Torbine 27 1w5*

3b51.1.14Matin(otd~oeser 179 20, 47 23 3b1.1.15 Ao-liry boodh.g 313 273M 47 133 3b.1.1.16Ieator. boildiog 313 0.24 3.00 2.730 547 3b 1.1 TolaI 3.601 32243 4.214 3b1 Sobooal Priod A3Aerily C-.to 3.691 554 3,421 32Z43 TLG Serices, Ic.

C091tal RiUer Uit 3 Neleor Ge ting Plant D-o. .eneP23-1651-001,Rev. 0 Peliminae7 De...iyioing Coat timsate Appendio C, Page 7 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousaands of2011 dollars)

Indez ~Aýli-y D-serptor.H D-.ve Cost RemovsI C

Psokaging Coss Tra. spora Coats P=so ot.

s i

I;g

.T02t50LK Dispoal Costs t1hter Cost.

Total Cotngrvy TotlI Costs 0002 LIe.T Coats openota*el Mr.. 8aoaget Coot.

eno tote Re-.ora.io.

Co.-

Yroveslra Voluee C.. Feet Class A C. Feet teurtat olumes Class Co. Fe ClasaC C. F-t OTCC C. Fet eaurial Pro.-s.sd Wat.,Lb.

Crate Macboors

.. ho.l-banoapa Utlt Co ntraot r o

I Period3bColtterl Cott 1b.3.

1 D-oo oqip"eot 964

• 145 ill0 IH09 3b.3.2 DOC staff roi-U.tioo aaseooa 1,58 ill 1.416 1446 lb.33 Cpaetbog " iolpmt 165 1.265 1265 2b.3.1 FloridaLLRWio-evtio Pso LIN110 18 0 1 1 3b 3 Sobtotl Piod 31b Collaoal Coot 1,7,8 498 3.821 3821 Period3b Period-Dopeoderl Cot.

3b.4.1 D-oo s-pp ia 3w 7 37 317 3b.4.3 PropatiytW.. 48 531 531 3b.4 4 H thhpvh,.. ovpplii 245 61 3M6 30N 3b.4.5 Heyquipmeot...ntaW 37 285 215 3b.4s Dopooi of DAWgeerated 14 31 3 '1 5.898 10 3b.1.7 Plot energy bodgot 519 7. 597 597 3b.4.8 NRC Peeso 11 152 152 3b.4I UtOhtyS-t. id-ooo*t 92 7W00 708 616 3b.4.10 Corpotet Allotios 442 3b.4.ii SecueityStaff Cot 1.480 222 1.702 1.702 33036 3b4 12 DOC'SffCot 5049 757 5800 5.800 59.2.

3b.4.13 Utility Stall Co-t 1.136 7842 7,942 131.086 3b.1 Sobtot] Period 3bPoel.Dvepodoet Coat. 3. 493 7 5 14 15.988 1.40 N8.998 18.M8 29% 5898 10 22I3.31 3b.0 TOTALPERIOD SbCOST 994 1,593 5 14 20937 3.512 27063 26.240 295 5.898 10 753564 PERIOD83 TOTALS 994 2,521 19 14 40 58545 9.668 71 801 70.350 823 809 16.185 19.126 659.936 PER10D 4. - LarIe Co-tpoaen Re-ota.

Patiod 4laDire- Dloeomieioniog Alivil No-iest Swtea SopplySy-tet Roetoos 4a.1.i.i1oactor Coolant Ppiog 126 1IN 580 5G4 597 W13787 2771 20 97 27 24 17S 580

.22 4 4 I5 86 80 is .1.2 Presst..ee RilMf Tk 21 27 9- 94 20.849 310 4s.i.i.3 Roector Colat Coops& MSttrs 22 74 47 3 669 2947 2,947 7.016 1,122318 2755 80 ls.iAi.1 Pseteiror 52 412 162 209 1 649 1."49 2 Q24 353593 ].19 1.700 4a.i.i.5 Sloes C~earstors 36 4,703 1.072 2.M4 S831 23.908 .1,92,167 10,251 2750 3,355 18301 [8.304 is.1.1.A Ret-redS. t ooratr oiUt. . 1072 2.3M - 6.831 2,164 17.392 12.392 2%. .98 ] 889 1W7 5 10 2.250 is.i.i.7 CRDNbleC]ieier oSt-_uoo Re.otou 29 80 312 71 56 3 122 553 853 753 M.100 91.378 2371 I4a .8 R-ottor Vassel loternsi 36 2316 12,373 470 2.114 182 6045 03525 0.52 1.32 9 5 01 217.620 18.750 982 Ia.i.l1.S CesoI& Ioteroale GTCCLMsptei - 1.180 9,049  %.019 -. 2112 423, *5 7.80W

4. i 1.10 R-actor Vessel - 5341 1.158 - 2.1617 182 5.515 111718 14,718 - 9.626 - - 9 978.700 18.750 882 4a.i.I Totas 157 12.688 1G,376 6.137 004 28.20 364 19,346 84.184 81.181 1.411 72.327 2) w51 2 142 0.697.382 62,933 7.841 Ro-votalofMj-orEquiptoso 4a.1.2 MSi TtrbtooG -eoeatar 244 101 26 521 161 1.133 1,133 2.931 257.966 6.378 4a. 1.3 Ma.inCoodensers 77,1 128 M 493 284 1.7N0 1.704 5.419 2M.3865 17.298 Caaodioa Co flet CleIo BuildiogDeoltt.on 4:.1.4.1 Rea-t 69w 104 790 7N4 8.169 Ia.l.4 2 Aueislr Boddog 170 - 2.063 26 121 124 4a. 1.4.3 PosI, odliogArea lA.o B1da 108 1.252 4a. 1.4.4 lotretodieat Bhle 4G 7 5w 1 4 557 4a.I.4. M-hioe Shlop.Hot 3 4 4.i .46 RMWehaoous I 1 1 0

4a. 1.4 T te.

l 1.1120 153 1.173 1.153 12.121 Disposalof Pivt Sotao 4a.I.5.1 A.az-er Sbras - 53 3 61 -

• 1391 31 13 76 76 - 1 -7 - 1525M 6M5 4a. 1.52 Ateiiaey Stao - RCA 2 4a.l1.53 Cbreleal Addtuoon.Coot 22 ,59 56 49 130 130 24.217 1.127 4a.1.S C -ealdddition.

1 Cent.-slated 3 17 12 61 2.461 159 4: 1.55 Cboolti-oAd-ditio- [estdd - RCA 4a 1.50 ChemikalAddtiOo - RCA 41 0 3 51 21 3

12' 15 15 12ý 61 2.401 26.704 12, 903 4a.1.5 7 Cheiool evi Srtondoy *Cd. 54 "14 331 4a.1.58 ie FeedlSoodeyoCyIe-oRCA F.ieol I12 0 13 13 2.0.7 107 "68

• 4.1.5 9 ChdAed Watr .520 61.

55 n 1.4 18

- 62 4a.1.5I0 Chiod Wtr - RCA 27.273 1,229 4.1.5.11 Croltiaig Wa.st 14 104 104 S - 2318 TLG Set-iva, I-a.

Cryatal Rite Unit 3 Nuclear Generting Plant Doument P23-1651-001, Rev. 0 PrIiminat Deeomtitioning Cast timate Appendix C, Page 8 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousands of2011 dollars) lo.de I=:~. Atity Desiption De-n C

Remos-l Packaging Cost CoCts Tranapor Coats Presaiog Coats Disposi Coats uthber Cost.

Tull Contlngeno' Total Costa Lie, Teem.

Custs Managemeot Coats Restoratiou Coats Volome Cu. et Class A Cu.Fe Cl... B CuFeet Class C Cu.Fet GTCC Cu. Feet I7d' Proeeed Wt.. Lbs.

Crsft nhours Contractor Mnlhours Duapinlsof PIvot Sstu.s lmoned) 4a.l.5.l2 CoodiDemnR bonorall to 43 49 1.049 1 49 "t 15 1 C.odootso 1w9 4 127 - 2868 40.l.5li Coondesloe&I De.lnWta Supply 27 t 1.515 Codtostu& Oool W.sltoeruply -Coo 2 40 2 127 127 19.101 1,284 4a.1.5 t- Conde1ta & SIolnWatr, Supply.-RCA 72 35 205 205 875 35538 1.773 4t.l.5.l7 Coodensate-Cent 161 2.5" 3 528 5. - 3.m6 131.415 3.586 4s IS5IS Codoioatsl Detinort.1zor 94 14 108

• 108 1.tI5 19 CondtouseDeolnertlioro-Cenl 3 7 132 55 3&0 330 65131 2.800 IM is15SO Coodouse AleRemoval&Pr'.-o *o 14 1014 4s 1521 I Do kyloMsketp Wltor - 1 *472 4a.l.522 Cyle MokeupDe-n Wte. RCA 2 12 134 29841 1.125 it 523 C.7lASttop 8 1 2o io.1.524 ylt S-ortp. RCA 2 35 68 51 L7,515 101 211 8 i45 25 F',-] Jsckot CI] t I4 1 2 438 4S 95 2o 0,ool-AIr CleClst 24 los Io.1.527 RRAPFO&C resead .r&Eohousl 42 I 1 S5 45 4i 1528 ED3 jLhn.1i .1028 I

4I.l.529 REFPS C3opreuad sodSlteoouno, ]I 2 12 12 4a .5.30 EP.3 Fool0,1Trer 7 19 19 4I 15.3 EPB R Sop Diaehaoe w it 1.5.32 E_,ere::y F-odoer, 69 4 Is. R5Eerenocy todwato,.RCA 121 52 32 32o 1,640 4t.1.5 Ni Etjacon Soe, 113 17 a .535 FWHote R'eIhdVent& Drais 46 7 I3 53 21.2 13 860 8 53 Ia 536 FWH Rater -Rlier Va-a& aDs-t -Coot 19 107 3158 -1

- - - 481 N- 1.187 1.222 4a 15.37 Fodnlator 13 223* 2.106 l.5.38 Feolwater - Inslad 7 291 152 4i 539 Fondwo 1r.Ioooattd

• RCA 4 o 18 54 353 5 572 9331M9 1,964 IsIi 4 Fon-wat ,RCA 1 2 47 13 - 3.243 453 26 19 40*

4a..5.41 HVAC.MmOutbtdi 15 2 19 86 4: 1 512 LP & HP Fýonwar Draisa & V.o 129 219 , 219 S5.018 Ia.I.5.13 LP & HP Fýeloso Dsa & VVnt - Cent 10 192 83 478 498 2m46 95.269 4.,14 4e.1.i.44 LUqd Sampliog.Coot t 26 2m 112 112 313 12.721 1.396 517 4s 15I5, L4qAdSomolog- RCA 194 1 28 18 102 102 13.,5. 1.10o 4a.I SIR6Lola 0,I 2 2I 12 4a.1547 Malt & RoheatS-am 209 13 %6

,135 2.98l 2981 96 22779 4a.1.5." Memn & Rehot Soe,. Coot - - 9m2.077 1I.999 4a.I 5.19 Mlin & Rohot Soe-. RCA 0 1 19 1 40o 40 226 9.182 27 4:.I 5.50 Uis,ToebtnaRlomSta* ralm 54 1,405 - 1.332

4. 1 5.51 MIss7oebt.,b R o S.e. Drsim Coot 2 1 67 MI3 Ml 57.049 2,735 46 Ia.l 5.52 Niitrounulydromen]Caroot Diotlda t 30 736 4 .1.5.53 No-Soc& Dm RHust Sa Wata. 7 M3 - 1.172 I:.1 5.5 N-oSo & DRoy ttt St Wtr *.Cent B34 3W7 459 4 459 151890 1.438 Is.1.5.55 NSeSe- & D., HRatSnaWa.r -RCA 46 16 wo 340 340 - 101697 1.45 In.1.5.56 RC & Ma_ Waat Es poraor 46 20 25 498 - IN( 1.176 1.176 6,075 w6 275.377 7.952 1

4a.I.5.57 RC& Mesaý e E-- aorotor. ala- 1Is 8 84 62 92 -1.030 633 Is.1.5.58 SormnW'ah W-at, 7* S 47 1989 4a.I.. SeI & Spray Wate Is. .5. Se"l &SprayWlte Coot IM 202 202 33.041 1.877 4I.I5. Soul& Sp'ay WRuer,RCA 29 174 174 7.3 31,81 1,379 is.I-S.

Is-I.S seoodoyCdSsels 63 Sseooaey CycAe Saooclio -oo 622 4:.1.5 63i eodery Cycle 9 liot - CeOt 3 7 17 2.419 IG9 1 6 6 810 57 Is-I. 65 SA CAt Samplie roiy [nased In 44 276 I 7 4a.1.S.66 S ondtrySort Clos.dCyoleColiog 19 -* 219 4.978 4.1.5 67 Tob BidgSu & Odly Water Sopastoo 21n 3 22 491 Os.1.5 68 T b-o GeneratlorSe (Oil 3 26 it.IS59 Toboe Clod St-a & Draies 17 26 3 4-.1 M 7 T~bl- Lub.¢] 5.19

• 1.107 lb1.7 1 Waste Drumln 2 9 3I 35 4.667 268 4.1.5 72 W-soes .,spos- l 127 736 736 - 2374 481 138.892 5321 40.1.5 Total 124 4.787 213 1 889 1236 M0,in 2.1IM 58,350 980 2 452.901 113,990 4s-IA Scsfildioe t aspportofdoeooooeioniot 784 5 71 5 211 1 097 1.097 2130 4.It SobIetsl PCoild4i AelotpyCost- 57 20518 6.,,19 6.076 29.138 361 22915 101.597 99.413 2.191 68896 73,391 no 501 2.142 9.691.321 233907 7.811 TLG Sen-,ee I.

1,

C(ntal Riter Unit 3 Nulear tenettng Plant Document P23-1651-001, R-y. 0 Prlininoey Derontaloning Con Ptitnate Appendix C, Page 9 f 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thouaands of 2011 dollars)

I=... .. .t. peotae Site a.

ae .1 ..... ma I Utiles A"at" Decono eoant Reol Pahkaging Transport Pressieg Disposal Other Total Total be. Term. Maoagen.et Restoration ooete Cas. A Class B Cl... C GTCC

? P.-d Craft Cootraetnr niea Aotylnt Desripttion Coat Co.t Cott Costs Coats Cost. Coats Cootineno Coat. Cost. Coat. Cotta Co. Free Cu. Feet Cu. Feet Cu. Feet Ca. Feat Wt., Lb.. M.nhotu,. M.anhno poriod a.Addilootl Costs 4:.2.1 RVCHSegmentationed Dispotal 255 1.562 1.565 2.,78 308.9(3 2.092 2.000 4.22 OTSCHot Itoa 158 '9' 41 217 1.102 1.102 2 940 172.000 -

4a.2 SobtototPeriod4t AdditionalCosta 158 M5 1.,493 471 2.667 2.667 54118 48t,903 2.092 2M00 Period to Coltateal Co-ta 4a.3.1 Pr tsdeommtinoing eat-rwasta 3 4 n 21 t 01 3 63 5* 3,379 1t 3t3 Sahol ai]

loHsn 194 29 223 M- 22 4t.3.4 FloridaLLRWinspeoionFaa 315 32 347 347 4 23 21 315 71 032 ti10 22 56 Ia3 Subotal Prod 4a CoIatoral Cos-Periodo. in-Detndot C.-oa 4a.4.1 1t*n oopplioa G5 16 01 81 773 77 850 850 4t.4 3 PMropotyon 105 1.154 1039 115 4a.4.4 Heialhphyea arpphlm 1,640 410 2.050 2050 4i.4.5 H11v euipment rental 2346 352 2.618 2690 4.4.6 DsoposalofDAWgtnerated 82 59 171 60 372 372 -14 4-.l.7 Fi. t energybudgt 1.072 11 1.233 1233 4a.l4. NRCFaet 75 869 869 ta.4.t Uity Sito [ndoet *1.347 202 1,550 1,550 4t It0 UiqoidRednwata Ptroting Uqotpmtonitroires 427 se 49! 491 "a..11t Corpotamt Aultat ient 96S 145 1.113 1.113 t 4At2 SoeootyStaffCot 3.215 482 3.698 3998 71.7186 4a.l.t3 DO StaffCot 12.969 Lots5 14.914 14,914 M58,03 a.4.14 UtilityStattCost 15.096 2264 171361 17.361 - 287.143 4, 4 Sobtotat Feod 4a Porind.Dtpendent(otto 65 3.987 82 59 171 37.707 6364 48.435 i8.319 115 3.4U3 -9,-6 .67 114 517.431 tat. TOTALPERIOD ts COST 226 24,698 17.075 71096 6.076 ev 304 33,387 28.%1 153.331 151.009 2.32! 60.896 82.352 2D 5so1 2 142 10.215270 236.121 527.275 PERIOD4b - Sitoleroteiostto Period4b Sint DDtomtiaioning AtiitiM 4b t.t Romoetspent ftol tsd.o 2N0.532 989 Disp 1 ofFItot Sotto 4b.t 1.4 dG Dittol Son. 16 2 18 36 12 8 43 43 ib.t 22 ChoemlZClteningStoemn -oCent 0 151 6.144 4b.t.2 3 ChonoaoCteaoingStem - - RCA 21 0 15 4 45 45 7642 399 4i.1 2.4 Cnntaineet Mooitring 18 103 103 351 14.268 1.o68 lb t 2.1 Cott Flooding 113 40 250 25 1,373 55,7.43 3.-

710 -o - 351.3011 4,555 4b. 2t6 DReayHSat Cosed (NA. hmgn 311 191 1.261 .26! 8.651 4bhi2 Deay Hot R--mo]al 07 M31 1.141 1.441 7.317 98 3801.145 6.106 4b1 I D-ee Ful oIhilTanta-USTSs 22 3 25 - 493 Sb.12.S DeomoticeWater 6 42 -

37 42 4b 1t2 DI -6eatiW--ator.RCA 61 13 119 129 5* 21.339 4bl 2.I

' II iM=. C"e" 82 w3 63() 13208 4b.! it12 E] rln.1-Contoodnttd 183 1.073 1.073 1.3941 178.159 10259 4b.! 2 13 Ele.t.l - Dtoontim-natod 3.5,18 69 4.433 8.614 8.644 1.69 - 1.693.,54 U3.485 4b.1.2 14 F-r Srvi*t /a*t 271 41 312 - 312 6.727 4b.! 145 FirSe&m 4iWetot - RCA 497 12 218 1.340 1.34L 7.126 289.375 9.742 4b.1.2 6 Fl*r & EqoipD[aa - Ado& Rte- Bldg 1 7 32 214 14 257 604 049 603 2.614 604 162.020 3.472 209 342 ýII 491 4,174 tb.1.2.17 HVAC -xAoiary Bldg 17 169.50W 4.279 4b 1 2 t8 HSAG. Clon MaeoinoShop 9 th.1.2 S SVAG-Coononi Conli 6 44 41 14 9168 4b 1 2 20 HVAC.- D-ai NonRBld ob1.221 HVAC - Fio Pmp H.oos 3 72 fl. 5433 '43 12l 88 476 ob.! 222 HVAC - FoelHandJlingDre 5 13 216 3690 4b 1 223 HVAC - Hot thtint Shop 33 I 2 12 13 93 M3 2o.735 662 oh.! 224 HVAC .nt=tBnoditt Hid, 63 ,t 8 148 39 262 No0 1,799 73,076 1291 4b.! 225 HVAC - Maintnene Soppot 5I 36 s - 7 162 4b.1.226 HVAC - CC-lioBld, 8 176 7,751 314 7.0 4b.1.227 HVAC-R-a1to Bldg lt9 12 634 199 [271 1 271 7743 4b.: 228 HVAG.TorbmeBlde 1ý5 3059 4b l2.29 [MIIný' _ aln 3 64 1J883 I 740 30.061 4b.t 2.32 Indostoal CoI:i Watnt 31 36 4 s8 472 472 73 4b 1231 IndotiaG Colot Watte. RCA M9 Z320 91.222 bb.1.2.32 Inttroent &USttiotSeAo"elit so 4b t233 Iostrment& AtattonSornimoir-Cn-1 2 53 3O5 305 1 160 47.115 3 121 TLG Senipea, In.

Crystal River Unit 3 N-.lear Generating Plant Dacsnent P23-1651-001,Ret'. 0 PreliminaryDermolslonlng Cost Estimate Appsndix C, Page 10 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2011 dollar-)

Artiit - -y........... ..-..-..

De -on C......-[

R o vaos l Pslksglog T r-n pore

- P r=o i.ng Dlspo sI Othse C....

Tosli Tosl L, ;el T s. M - ,ogo mes t R o srtoioo Vola. s C...-.......

CIl.s A C lasts C lsssC C.u........

GTCC Ptot ss d C raf Co ntra tors Dsposlotr Plnts tsty- (-..t.o.dt 4b.1.2.34 Instrt1ooo & Sttion Seroto At, - RCA 271 94 5.12 542 2.012 81.728 5162 3 0 659 -

4b ' 2.35 Lst. RFt=Toot.C-ot 31 178 178 29.355 1,775 4b 1.2.36 Loakl.ateTst -RCA S 4 78 32 192 192 945 30.385 I1 4b , 2.37 Lqttd Ws.- Dtspos 827 3M4 .998 1.998 3.528 1675 - 963566 2 17.036

b. 1.2.38 Makelp & Pootfiltion 570 7 18 357 M06 1,152 1.152 4.355 176876 11.685 4b.1.2.39 Mabkep & PAfrioftioo- tosatetd 144 2 4 77 48 274 274 941 38.212 2994 4b I 2.40 Nit-o-/o0-.doro/C.arbon Doode - Coot 0 0 12 7 12 12 148 6028 419 4b.1.2.41 Nittroso/Hydrooeo/CarbooDiowmds. RCA 80 A44 26.153 1402 tb 1.2.t2 Nob!eGsaEflloot Mtonittoring

• Ceot 152

- 277 6,172 3M9 4b I 2.43 Nob's tas Efllent onloMtonn.

• RCA 0 I 4 6 3M 32 152 6,172 4b.I.2.44 N-v S- Cloed C.de Cobg - C-ot 0 526 .0 -0 302 2069 2.049 12.315 -500136 13.503 4b.1.2.45 Not Sor Clood Cyle Coltog -RCA 26 65 3N6 1,281 2284 2.284 15.611 6,33.9M3 11.323 4b.l.246 PASSCootsto= Moobltornog - Coot 3 4 14 1777 147 4b.t.2.47 PASSCoott ent Mooniwtg - RCA - 3 79 - 5 207 3W6 16 27 30 4b.! 2.00 Post A-ýdoot Sa pitog - Cot 0 0 2 Io 57 57 8 339 57.9 4b.1.2.29 P.st Aoldoot d-Saphog - RCA o 1 19 5 ZO 5.1 237 - 629 560 4b.t.2 0 Po.t A=otdoot Ventog - Cot I 2 34 411 16,678 680 4b.t.231 Post Aodoot Vontng - RCA '12 11 1 6 581 24 2 4 13, 79 38 4b.I.0.32 RB PF.ett-o Coliog - RCA 5 45 3332 2233 S 3.005 2,178

'4 4b.t.2.53 RCP LobsOd 0 t-Cot 0 5o 2 06 387 2,361 85 11 302 2361 15 4b.l.2 54 RCP L*bs - RCA 3 122 10 142 4b.t1.2.96RadaosstDoottosrstttsr 2 3 [5 1 4b.! 236 RsoBttdtPtos*utSeoiog&Tsst 177 54 12,173 M.

lb.! 257 Rnt 2ld Pressre .S.sig & Tt - RCA 13 13 73 - 11.906 673 4 12 2 S- 2.75 4b.1.2.58 Reato.rBilding Spray 129

• 13 S 111.740 4.454 2In

• 4l. 2.59 Rofslting Eqttp..nt 7 14 116 54 1.412 230 78.597 3.003 4b.I.2.60 Sewsae 13 - . M22 4II w* 61 3232M lb.! 261 Speot FoI'Cloo7tot 13 0.6 7.38 3.930 985 251.108 10,0!)

lb.! 2.62-Wste GAsSstorhbo 62 1 2 M 71 122 122. 443 a8005 1.190 4b.! 2 63 Wst Layp/N2 Blatkotiog 112 4b.! 24 W4t opoN2Bt-k..., - Coos 7I 0 0 3 '40 1.626 132 4b I 265 Wet LbptN2 Blsnkobog - RCA 1 7 7 24 -

4b, 2 Totals 12573 359 S! U M21 1o67 5 2714 719 "19 32 ,254 136 148.708 4.530 - 15,713 6 257.974 n0.8 8 '

4b 13 S-Mitdtogtosopport ofNd.--.sso g 1 176 31 a 1M7 7 316 1,ý4o 16ot6 U8817 33321 1.,-176 131 Do~tooooooottoo o!Suto Bottdtogs 4b 14I Ro.tr 31 186 1080 968 ,1*I 4.161 9.759 8M2S28 32 10 897 M8 2.269 2b.t.4.2 AuoioAsoBilding 308 W. 41 55 206 757 757 IM0 497 1,173 111.373 8.770 4b 113 Foot Hlodho A,.. (A-s Bldg) 729 5Q3 -8 2.344 2.3 4 167 4.376 947 M231390 27.183 4b.l.l.1 Intoroedtste Btdg 42 14 170 170 -,08 242 - 23.998 1.823 4b 1 5 Machin Shop, Hst 48 1.

30 N0 104 3 181 15.752 1230 4b 14 RB BauitetoootBldg d HP O!Sr 2 5 19 1, t422 ,9 1:4 tb.t.4.7 RN!Wehbos- 63 65 - 9.906 773 4b 1 4 RVCHSorso Building 4 132 2 1 3 ' '27 3 2 176 130 2.0.84 9.5 590 1.85., 7,6X) 3 7.6XI lb 1.4 Totals 605 1.213 7.30 12.408 1, M487 72.622 4b t Subtotl Peritd 4lbAttoity Csta 2,A21 15.182 624 2* 12.911 2867 7.7%9 43 105 41.7,39 1.30 157.2"4 19.517 7.995898 34C Period4b Additioa Cots-4b.2.I Liln Temoionto Soeoy Ptsnioog - 1.445 134 1.79 1.879 12.480 35 "4 136 47 2-6 25o 4b.2.2 Asbostos Reooals Pssrsog 25,066 940 lb 2.3 IStM Ltt-ot Teroostion ISn 26 1.276 248 1769

• 1.768 ,77 N6.514 5.133 4b.2.4 Westatttiog Peod 770 - 207 1,065 1.065 13.513 1,053.006 309 4b 2 Sobt-tal Fritod4b Additioa Costa 932 2.722 937. 4.60 3.230 1.7,8 14.577 1 174,514 6.383 15.040 PerotdlbCollateral Costa lo 4b3.! Fross dsooo ssto wto wasto I- ste 2o6 d2 32 182 182 9.8n* 32 4b.3.3 Soot1 to*o sltovso 4b.3.4 DooMooottg ERuipmentDispstlioo 545 38 - 114 903 903 6.000 667 300,00 88 169 b.3.5 FlooIdsLLRWIopaoton F.m - 373 37 410 410 4b.3.6 o-st ooo s -d o-rstsas of 134.9tao Iolo ostattllo wst. 5 - 148 15 L.3 1I99o lb.3 Sobta.W Period4b Colist.r.I Costa 545 tO0 521 242 I'm9 1.999 W09825 120 6."O 83M poriot lb Portod-DopsodstCo-ta lb.l.tI Don sopplto 982 - 215 .=27 1.2W7 4b.42 1.136 111 1256 1M250 4b.4.3 Frsr ty -lts 1.449 145 1.594 1.594 TLG Serices, Inc.

Crystal River Unit 3 Nuclear Generting Plant Document P23-1651-001, Ret. 0 P-liminaryfDecammissIaln Cast Et inate Appendia C, Page 11 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2011 dollars)

. .s .... pant a..... -- d. a.. a I itypu Asteivtity asesaona-R-al .IPk.giag Tr..pan- = 1%sstnDis.p...l Othss T-t. ier.Ta.

T.] .anaent s*.rasian Volume Cl... A M. . B -0. C E GTCC P-aaed Crft Contsactta Iadet Aetiity Descrpttian Pust Cast Pots. Co.st . C.Ptt Ca.t. Coatinenscy C.t. Cous. Cost Co.t. Cu. Fea Pa. Fat Cu. Fast Ca. FPe Cu. Fan Wt. Lbs. M.ahour. M.nanhu peait 4b Ceri*l.Depaedeet Cet- (--nnttd, 4b 44 Health phbtin suppliat 2.513 S2,8 3 142 3 142 4b.4.5 H-y t tqipmeat

- vets] 3.421 - 513 3935 3,935 4b 463 apet,1fDAW nenerattd 1835 9 279 3 5.701 1]4.015 I86 4b.4.7 Fla, a.tten btdgat 1245 1t7 1.431 1L431 4b 4 8 NRCFe tl161 116 1278 1 278 4b 4 9 Utlity Stt Iadteat L887 2113 2 170 2 170 ib.4.10 LiquidRadnastaPrFesiag Eqtipm-enSarsau 94 722 722 4b 4 11 CorpteAllatliat L31,1 202 1,545 I 545 4b.4.l2 Ssity Staff Cast 4.727 709 5436 5.436 4b.4.13 DOCStaf C0t" 18601 2.790 21.391 21.391 21.3269 4b4 4 lityStaff Cet 21.4119 3.163 24.253 24,253 398.W03 4b.4 Subtatal Periodlb PFritd-DependtatCoas 982 5,9Z15 13M 97 - 279 53 2G6 9.287 69.981 69.981 5,701 114.015 186 73,.307 4b.0 TOTALPERIOD 41,COST 3.415 21.¢x 951 1,Q7 13457 t.178 565WI, 18.26. IM0.054 IS 919 .768 1.366 163.263 40.6M5 9.594.252 371.595 745.347 PERIOD0 4f1-Li--eaTvvsaiesle Pa.o.d4f Di-a e tee-e* i Asctittei

41. .1 ORISE -vetsasryesee_ 154 46 20W 2WO 4 .I.2 Termieattle a--

4.1 Sabtal Pasied tf Astity C.t.. 154 46 200 2WO Ported4f Addil... Cost 41.2.1 Lnsest Tetiatije St-ey 6048 1.815 7.863 7,863 123.073 6240 41.2 Sebtetal Ptriod 4f Addition.lCosta 0048 1.815 7.863 7863 123.073 6.240 P.] 4fOC.1atera. osl0t 413.1l Decs f re*fnnepr 1,M8 189 1.146 1.446 43.] FloaidaLLRW Ilpao.iee F- 1 9 1 1 41`3 Stb.tel PeeledlfCellaterl Cesta 1,258 189 1.447 1.447 Period4f Ploaia.DependentC t 41.4.1 Ie[ teta-4114.2 Propere tmy aa 61 639 639 41.4.3 Heasthphy*al supphl 654 M6 117 817 4".4.4 Disp-al f DAW--nratd 8 6 17 6 37 37 1t 41.4 Platr budgeet 6.9M tII 154 3 177 177 41.46 PaCt a W77 63 S3t SO]

4f14]7 Uity Site Ind-ee 436 w5 01 501 41.48 Ce"pert't A]ll-aiee 251 M828 HS5 4f 4 9 Seett Staff Cat 935 140 1.076 1.076 Ie.709 41.4 10 DO,'Sta!] 11-t 5.ffi4 760 5823 5.823 57.149 4f4 II UlihlyStaff 'o.t 4,42 666 5,108 5.108 74.321 41.4 Stbtotal Pastd 4f PCerAd.Depaedent Cts. 654 8 6 17 412.4 1980 15.131 15131 750 6999 I 150309 4].] TOTALPERIOD4fCOST 65t 8 6 17 19.92G 4029 24.641 746ý4] 350 6.999 123.085 156549 PERIOD4 TOTALS 3.6"1 47003 18031 8.72- 19.632 35.019 114.822 51.246 298.000 M9.570 1.768 387 232.10 123.327 7 00 2 142 1986.530 730004 1,429.171 PERIOD55tb - Sits lteaavsiee Peiodtb 5irvti Daaeea aAetieitia nieg rteteltit fem.atini Site Btildiep 5b.l.t I Raeat 4.063 4.672 4.672 47.8M0 5b.l. 2 AACDi-v G -eerto Butilling 19 22 22 5b. .t.3 AWSReatd W-tabhtte 154 23 177 17] 2.786 5b.t I 4 Atttltey Btfidtg .552 23M 1.782 1.782 19.,011 5b.t.1.5 Cent-I A]ee Statio 0 3 3 46 5b.t I 6 Cvrc -"l Storag 5biI] C1ottroComple- 114 874 874 9432 5b.l.t S Stesa]PeeOil Tankt USTD 2 17 133 F9 Ise T-1 IM D .::I GeaOil 14 3I 5b. I10 io P Ceetp Buddlg 12 19 147 1173 5b.l.I II PiraPeetpbeete 2 18 "38 5b.].1.12 Peel tedlee - vg(A-t Bid&) i63 1.173 12.445 Sb.]1.13 lntabkt DithbtgeStecetta, 65 496 "06I 5b.1.1.14 IBdteretabte mdg 73] ii -6 TLG Snticei Inc.

Crynata River Unit 3 No-car Generating Plant Doeomeot P23-1651-001,R. 0 PrelimiryDLvmmiaoiooiog Cot Estimate Appendix C, Page 12 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousand. of 2011 dollar.)

Off.ti- LLtW NRC Speot Fool St. Pressed Burial Voo-es Sorial' Utility .od D.ov Rvmoval Paikagiog Tr-anport Poosing Disposal Other Total Total Li.. Term. Management R.oaotion Voolum Cla.s A Cla.. B Class.C TCC Pvovo-ad Cr-ft Contraior Avtroitv Coat Co-t Coat. Coat. Costt Ctoo Cos.- Contingen Coat. Coat. Coot. Co.t. C. Fot C. Fot oFt Cu. Cu. Ft o Cu. F-e .. Lb.. M.ohoov. Manouo I I .............. * ...... p .....

ODemohlon of ReatoiniogSita 8tuildiogslmo6nutdl 51b1.1.15 MachineShop. Cold 12 93 93 51, 1 IS MahinooSltop-Hot I1 88 1.396 1.4*0 88 I.678 5b.l.l.17 MitoYardStu.est& F& odotioo 219 1.678 12.067

,b I1 18 OTSGS--ragoBuild..g 489 73 562 562 6.060 Sb.l.l.I9 RSo Mintoo -o-Blid, d HP CCio '2 1.077 Sb.l.l 20 t W51 h-ouoo 6 Z3 445 Sb 1.121 RVCHSt-ogoBu.lding 74 11 86 - 1.090 5b.t.l 22 Rsoty Bldg 228 31 263 - 3.770 2,101 2.416 27 791 5b.!.' 23 Ttbtoo Build~og 315 2.416 Sb.!.' 24 Turbtoe Fodoatal 442

.43 0 2 04.739 Sb.!.! Totalt 14.288 2,143 16,431 - 170,921 5b 1.2 BockFilS1o 830 125 955 1.4I1 Sb.13 0radeo& ltodtvpaltto 28 214 h.1.4 Finorepor toNRC -14 179 27 205 205 1.560 Sb.l SubtotalPCootd 51 Ao-oty Coat. 15,304 179 2.322 17.80G 205 17,600 172,608 1,560 Period51AdditionalCo..

hb2.'1 Cootroo 0:olhmo 654 2.511 48 185 Z23 554 040 90 5h.2.2 SfST Domolitioo-d Rstooation 4.410 IGO 51 2.3 lotoke& DitchargoStruotuo Cofferda- !18 78 9 59% 4.436 5b.2.4 Firing 'aogeolo`- 782 117 899 - 90 5b.2 Sobtotal Poriod SbAddtloon.lCoo. 2.G33 407 2.000 940 2,119 11360 160 PFotod5bColIttoral Co.ts S5h.!. Small tooalown 161 -2l ]as A8 5b.3.2 Corporatilolion. 232 35 276 267 5b.3.3 Uihty Silo Iodirtv 248 37 283 5h.3 Subtotal Period5b Collater.l Co 161 478 96 796 736 Periotd51Poriod-Daptndm Co-tt 5h.4.l loooto 55.4 2 Propertytatv - 451 45 496 495 5b.4.3 Hoyeqouipment -Wol 5.119 .. .70 5N70 . 5 887 . ..

54 4 Plot ooeoy bodgot 173 28 199 . 199 . . .

5b.4.5 SoottotyStat Cml 2.106 316 2.423 2,122 12309 Sb.4.6 DOCStalFCot I1.038 1.555 '2,093 12.693 119.874 b 427 Utihty Staff Cot - 4.044 607 4.-50 4.650 as5173 5b.4 Sobtol Poriod5b Prodi-DvptodoolCott 5.119 17 ]1t 3.417 26.=48 2.338 =230.93I 5b.0 TOTALPERIOD51b COST 23.218 18.521 6 238 47.978 206 960 46.832 184048 232.654 PERIOD8G TOTALS 23218 18,521 6.238 47.978 200 940 46.032 184048 232.654 FOTALCOSTTo 8ICOSMMISSION 9.052 80,730 18.788 10.280 20,214 36,143 752,683 149.706 1.077,596 763.717 271.910 51,969 234803 133.758 288 801 1.142 21.677,830 1.005,605 7.993.623 TOTAL COSiTTO DECOSIISSION"ITK 16.13% CONTINGENf'CY: $1,077.596 lhot...d.of 2011 dollara lOTALN5C LICENSETERMINATION COSTIS 0.4!; 08: $753,717 thloo..dtof 2011 dollars ISPENT FUELMANAOFM ENTCOSTIS26.23%OR: $271.10ltbootodtof 20811dollav INON-SUCLUA48 DEMO1LITION COSTIS4.82% OR: 151.969 tltooadt of 201t dollar.

TOTAL FSIMARYSITERADWASTEVOLUM E BURlIED: 134,09 tobloFeat TOTALGREATERTHANCLASSC R.8DWASTEVOLUMEGENERATED: 2,142 tobio f-o

[LOTAL SCHAAP METALREMOVED: 39,30 too.

KrOTAL CRAFT LABORREtUIREME8NTS: L.80,505 mao-h-oo.

Eod No.a.

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a calloontaiinhg".-",divooaootsazrotvloe TLG Service., 1-y.