HBL-10-009, P01-1604-002, Rev. 0, Decommissioning Cost Study for the Humboldt Bay Power Plant Unit 3, 2010 Safstor

P01-1604-002, Rev. 0, Decommissioning Cost Study for the Humboldt Bay Power Plant Unit 3, 2010 Safstor

ML101020034
Person / Time
Site:	Humboldt Bay
Issue date:	03/31/2009
From:	TLG Services
To:	NRC/FSME, Pacific Gas & Electric Co
References
HBL-10-009, OP-DPR-07 P01-1604-002, Rev 0
Download: ML101020034 (91)

Text

Document P01-1604-002, Rev. 0 DECOMMISSIONING COST STUDY for the HUMBOLDT BAY POWER PLANT UNIT 3 2010 SAFSTOR preparedfor PACIFIC GAS & ELECTRIC COMPANY preparedby TLG Services, Inc.

Bridgewater, Connecticut March 2009

Humboidt Bay Power Plaht U*it 3 DocUment P01-1604-002,Rev. 0 DecommissioningCost Study 2010 SAFSTOR Page ii of xiii APPROVALS Project Engineer William J, Project.Manager Date- "

Technical Manager a

Quality Assurance Manager 0.'v "

iat e

'TLGServices,Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page iii of xiii TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

............................................................................. vii

1. INTRODUCTION ...................................................................................... 1-1 1.1 O bjective of Study ................................................................................. 1-1 1.2 Site D escription ..................................................................................... 1-1 1.3 R egulatory Guidance ............................................................................. 1-2 1.3.1 Nuclear Waste Policy Act ........................................................... 1-4 1.3.2 Low-Level Radioactive Waste Policy Amendments Act ............ 1-5 1.3.3 Radiological Criteria for License Termination .......................... 1-6

2. SAFSTOR DECOMMISSIONING ACTIVITIES ....................................... 2-1 2.1 Period 2 - Safe Storage and Decommissioning Preparations ............. 2-2 2.2 Period 3 - Preparations ....................................................................... 2-2 2.2.1 Engineering and Planning ......................................................... 2-3 2.2.2 Site Preparations ........................................................................ 2-3 2.3 Period 4 - Decommissioning Operations and License Termination ... 2-4 2.3.1 System R em oval ......................................................................... 2-4 2.3.2 Reactor Vessel Rem oval ............................................................. 2-5 2.3.3 Prepare Buildings for Demolition .............................................. 2-7 2.3.4 Building Demolition, Yard Work, Soil Remediation ................. 2-7 2.3.5 Final Site Survey - License Termination .................................. 2-8 2.4 Period 5 - Site Restoration ................................................................... 2-8 2.5 Post-Period 5 - ISFSI Operations and Demolition .............................. 2-9

3. COST ESTIMATE .......................................................................................... 3-1 3.1 B asis of E stim ate ................................................................................... 3-1 3.2 M ethodology ........................................................................................... 3-2 3.3 Financial Components of the Cost Model ............................................. 3-3 3.3.1 C ontingency ................................................................................ 3-4 3.3.2 Financial R isk ............................................................................. 3-6 3.4 Site Specific Considerations ............................... 3-7 3.4.1 Spent Fuel D isposition ............................................................... 3-7 3.4.2 Reactor Vessel and Internal Components ................................. 3-7 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page iv of xiii TABLE OF CONTENTS (continued)

SECTION PAGE 3.4.3 Main Turbine and Condenser ................................................... 3-8 3.4.4 Plant System s ............................................................................. 3-9 3.4.5 Humboldt Bay Unit 3 Facilities ................................................. 3-9 3.4.6 Transportation M ethods ........................................................... 3-11 3.4.7 Coordination with. Units 1 and 2 ...................... 3-12 3.4.8 Site Conditions Following Decommissioning .......................... 3-13 3.5 A ssum ptions ........................................................................................ 3-13 3.5.1 E stim ating B asis ...................................................................... 3-13 3.5.2 L abor C osts ............................................................................... 3-14 3.5.3 G eneral .............. .......................................................................... 3-14 3.6 Cost Estim ate Sum m ary ..................................................................... 3-16

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

5. RADIOACTIVE WASTE .............................................................................. 5-1

6. R E SU L T S ....................................................................................................... 6-1

7. REFEREN CES .......................................................................... ................... ,7-1 TLG Services, Inc.

Humboldt Bay Power PlantUnit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page v of xiii TABLE OF CONTENTS (continued)

SECTION PAGE TABLES Summary of Decommissioning Cost Contributors ..................... xiii 3.1a Schedule of Expenditures .................................................................................... 3-17

3. lb Schedule of Expenditures, Excluding CPUC Disallowances ............................ 3-18 5.1 Decommissioning Waste Disposal Summary ...................................................... 5-3 6.1 Summary of Decommissioning Cost Contributors .............................................. 6-3 FIGURES 1.1 Layout of the Nuclear Plant Site and Surrounding Area ................................... 1-8 1.2 Schematic Diagram of the Vessel and Internals ................................................. 1-9 1.3 Sectional View Through the Caisson .................................................................. 1-10 4.1 Decom m issioning Tim eline ................................................................................... 4-3 APPENDICES A Work Diffi culty Factor Adjustments ................................................................... A- 1 B Unit Cost Factor Developm ent .......................................................................... B-1 C Unit Cost Factor Listing (Representative) ..................................................... C-1 D Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR Decommissioning Cost Estimate ............................ ..... I D-1 E Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR CPU C Cost Disallow ances ............................................................................... E-1 F Humboldt Bay 2010 SAFSTOR Decommissioning Schedule ....................... F-1 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page vi of xiii REVISION LOG Rev. No. CRA No. a ItemRevised Reason for Revisison 0 3/30/09 Original Issue TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page vii of xiii EXECUTIVE

SUMMARY

TLG Services, Inc. (TLG) has prepared a site-specific cost study for decommissioning the Humboldt Bay Power Plant Unit 3 (HBPP3) for the Pacific Gas and Electric Company (PG&E); this will be referred to as the 2010 SAFSTOR study. This estimate includes a comprehensive cost and schedule estimate for completing the decommissioning of HBPP3 based on outlined work areas of the plant. Manpower levels and activity durations were developed and are reflected within the project schedule along with other associated site programs. This estimate incorporates the site specific decommissioning tasks and detailed plans which have been identified as a result of the ongoing detailed planning effort. The projected total cost to decommission HBPP3, including costs spent to date and a 25% contingency applied to remaining work, is estimated to be approximately $499.8 million (2008 dollars).

The California Public Utility Commission (CPUC) has previously ruled that certain costs that were incurred after HBPP3 was permanently shutdown would not be included in rates for recovery of decommissioning costs. The costs associated with decommissioning activities on systems and components which have been identified by the CPUC as decommissioning disallowances is estimated at $385,520.

The major cost contributors to the overall decommissioning cost are labor, spent fuel storage and the disposition of waste generated in the decontamination and demolition of the unit. The estimate is based on several key assumptions, including regulatory requirements, estimating methodology, contingency requirements, low-level radioactive waste (LLRW) disposal availability, high-level radioactive waste disposal schedule, and site restoration requirements. A summary of decommissioning cost contributors is provided at the end of this section and a complete discussion of the, assumptions used in this estimate is presented in Section 3.

Alternatives and Regulations The Nuclear Regulatory Commission (NRC) provided general decommissioning guidance in the rule adopted on June 27, 1988.[11 In this rule the NRC sets f6rth technical and financial criteria for decommissioning licensed nuclear facilities. The regulation addresses planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three 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+), June 27, 1988.

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HumboldtBay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page viii of xiii decommissioning alternatives as being acceptable to the NRC - DECON, SAFSTOR and ENTOMB.

DECON was 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 released for unrestricted use shortly after cessation of operations." [2]

SAFSTOR was 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." [3]

ENTOMB was 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 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. The amendments allow for greater public participation and better define 'the transition process from operations to decommissioning. The costs and schedules presented in this estimate follow the general guidance and sequence in the amended regulations.

Methodology The methodology used to develop the decommissioning cost estimates for HBPP3 follows the basic approach originally presented in the Guidelines.[5 ] This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporates site-specific costs and the latest available information on worker productivity in decommissioning.

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 2 Ibid. Page FR24022, Column 3.

3 Ibid.

4 Ibid. Page FR24023, Column 2.

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

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page ix of xiii include program management, administration, field 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 cost estimate.

This study assumes that utility and contractor personnel are already experienced in the techniques and technology of nuclear power plant decommissioning, and therefore performs all work (both field activities and project management) in an efficient manner.

Contingency Consistent with industry 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."[6 1 The cost elements in this 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 ufiiversal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, is based on a preliminary technical position [71 to reflect the California Public Utilities Commission's desire for owners to conservatively establish an appropriate contingency factor for inclusion in the decommissioning revenue requirements. It should also be noted that contingency, as used- in this estimate, does not account for price escalation and inflation in the cost of decommissioning during the decommissioning period.

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) 6 Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239.+

7 "Technical Position Paper for Establishing an Appropriate Contingency Factor for Inclusion in the Decommissioning Revenue Requirements", Study Number: DECON-POS-H002, Revision A, Status:

Preliminary (provided by PG&E).

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Pagex of xiii waste, although not all of the material is suitable for "shallow-land" disposal. [8] With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980, [9] and its Amendments of 1985, [101 the states became ultimately responsible for the disposition of low-level radioactive waste (LLRW) generated within their own borders.

Until recently, there were two facilities available to PG&E for the disposal of low-level radioactive waste generated by HBPP3. As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of the states of Connecticut, New Jersey and South Carolina). This leaves the facility in Clive, Utah, operated by EnergySolutions, as the only available destination for low-level radioactive waste requiring controlled disposal.

For the purpose of this analysis, the EnergySolutions' facility is used as the disposal site (for purposes of determining the cost of transportation and the cost of disposal) for the majority of the radioactive waste (Class A). There are no currently operating disposal facilities available to PG&E that 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. As such, waste disposal costs and waste transportation distances, and availability must be estimated. The disposal cost and transportation distance for low-level radioactive waste is based on a study sponsored by PG&E and Southern California Edison Company, "Establishing an Appropriate Disposal Rate for Low Level Radioactive Waste During Decommissioning."["] The study was done to reflect the California Public Utilities Commission's desire for these owners to conservatively estimate their nuclear decommissioning LLRW disposal rates. It is assumed for this estimate that Class B and C waste disposal facilities become available by 2016.

The dismantling of the components residing closest to the reactor core 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. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

8 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" 9 "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980.

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

11 "Establishing an Appropriate Disposal Rate for Low Level Radioactive Waste During Decommissioning", Robert A Snyder NEWEX, Revision 0, July 2008 (provided by PG&E).

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Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Page xi of xiii For purposes of this study, GTCC is packaged in the same type of canister used for spent fuel. The GTCC material is either stored with the spent fuel at the ISFSI or shipped directly to a DOE facility as it is generated (depending upon the timing of the decommissioning and whether the spent fuel has been removed from the site prior to the start of decommissioning).

High-Level Waste Congress passed the "Nuclear Waste Policy Act"[12] (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. The 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.

Operation of DOE's yet-to-be constructed repository is contingent upon the review and approval of the facility's license application by the NRC and the successful resolution of pending litigation. The DOE submitted its license application to the NRC on June 3, 2008, seeking authorization to construct the repository at Yucca Mountain, Nevada.

Assuming a timely review and adequate funding, the DOE expects that receipt of fuel could begin as early as 2020. [13]

The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. For purposes of this analysis, acceptance of commercial spent fuel by the DOE is expected to begin in 2020. All assemblies are expected to be removed from the Humboldt Bay site in 2020.

All fuel has been transferred to the ISFSI. The ISFSI will remain operational until 2020.

12 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982 13 DOE-RW-0604, "Project Decision Schedule", U.S. DOE Office of Civilian Radioactive Waste Management, January 2009".

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Humboldt Bay Power PlantUnit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Pagexii of xiii Site Restoration The efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC guidelines will result in substantial damage to many of the site structures. Blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially damage power block structures, potentially weakening the footings and structural supports. This study assumes that the majority of the site buildings are demolished as part of the license termination activities, and any remaining buildings are demolished immediately after license termination.

All demolition debris is assumed to be potentially radioactively contaminated, and therefore transported and disposed of at a Low-Level Radiological Waste (LLRW) disposal facility. This study assumes that structures are removed to a nominal depth of three feet below grade level. Below grade structures will be decontaminated and left in place. Below grade voids are backfilled with clean fill.

The site is assumed to be graded and landscaped.

Summary The costs to decommission HBPP3 were evaluated for a SAFSTOR decommissioning alternative. The estimate includes costs spent-to-date. The estimate assumes the eventual removal of all the contaminated and activated plant components and structural materials, such that the facility operator may then have use of the site with no further requirement for an NRC license. Decommissioning is initiated after the spent fuel has been removed from the spent fuel pool and is accomplished within the 60-year period required by current NRC regulations. The estimate assumes that the spent fuel remains in storage at the site until such time that the transfer to a DOE facility can be completed. Once the transfer is complete, the storage facility is also decommissioned.

A detailed breakdown of these major cost contributors to the decommissioning cost estimate is reported at the end of this section and in Section 6 of this document.

Schedules of annual expenditures are provided in Section 3, and detailed cost, waste volume, and man-hour schedules are provided in Appendix D and E. Costs are reported in 2008 dollars. Cash flows and expenditures to date are based on schedule forecasts as of December 2008. The estimate includes the costs for storing the HBPP3 spent fuel until such time that the Department of Energy (DOE) can complete the transfer to an off-site facility.

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Pagexiii of xiii

SUMMARY

OF DECOMMISSIONING COST CONTRIBUTORS Work Category Costs 08' $ Percent of Costs 04' $

(thousands) Total (thousands)

Decontamination 978 0.2% 1,865 Removal 48,360 9.7% 23,899 Packaging 9,258 1.9% 3,087 Shipping 11,722 2.3% 5,578 Waste Processing & Recycling 675 0.1% 8,877 LLRW Burial 77,596 15.5% 17,446 Demolition LLRW Burial 23,872 4.8% 38,528 Staffing 132,760 26.6% 70,516 Security 45,687 9.1% 4,149 License Termination Survey 1,958 0.4% 9,874 Insurance 1,000 0.2% 786 Energy 1,254 0.3% 827 NRC & EP Fees 5,386 1.1% 1,935 NRC ISFSI Fees 1,023 0.2% 3,745 ISFSI Capital, O&M, Fixed & Security 57,798 11.6% 66,391 Non-ISFSI Expenditures 28,015 5.6% 20,282 Equipment & Supplies 28,797 5.8% 28,520 Engineering 23,618 4.7% 11,121 Total 499,759 100.0% 317,424 CPUC Disallowances Removal 193 50.1% 172 Packaging 21 5.5% 14 Shipping 4 0.9% 5 Waste Processing & Recycling 0 0.0% 30" LLRW Burial 165 42.8% 135 Equipment & Supplies 3 0.7% 2 Total 386 100.0% 357 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page1 of 10

1. INTRODUCTION TLG prepared this decommissioning cost estimate to provide Pacific Gas and Electric Company (PG&E) with sufficient information to prepare the financial planning documents for decommissioning, as required by the Nuclear Regulatory Commission (NRC). 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 OBJECTIVE OF STUDY The objective of the study is to prepare a comprehensive estimate of the cost, a schedule of the associated activities, and an estimate of the volume of radioactive waste generated during decommissioning of the Humboldt Bay Power Plant Unit 3 (HBPP3).

1.2 SITE DESCRIPTION HBPP3 is located approximately four miles southwest of Eureka, California. The site consists of approximately 143 acres located on the mainland shore of Humboldt Bay. Figure 1.1 shows the layout of the site and the surrounding area.

The adjacent generating units (Units 1 and 2) are fossil-fueled and are not considered in the scope of this study, except where noted.

The Nuclear Steam Supply System (NSSS) for HBPP3 consists of a single cycle, natural circulation, boiling water reactor and the associated control and support systems. Figure 1.2 shows a schematic diagram of the reactor pressure vessel and internal components. The generating unit had a rated core thermal power of 220 MWth (thermal) with a corresponding net electrical output of 65 MWe (electric).

The NSSS is located within the "primary containment structure." The primary containment is located mostly below grade and consists of a drywell vessel and a suppression chamber. Both the drywell and the suppression. chamber area are located within a reinforced concrete caisson. The drywell vessel is centrally located in the caisson and serves as the primary containment vessel. The suppression chamber is constructed of reinforced concrete and lined with carbon steel plate. Six vent pipes connect the drywell to a common ring header at the top of the suppression chamber. Downcomers drop from the ring header and terminate below the normal water level of the suppression pool. As a system, the drywell, suppression chamber, and interconnecting piping were designed to reduce the pressure increase in the event of a local process system piping failure.

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Humboldt Bay PowerPlant Unit 3 'Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page2 of 10 Figure 1.3, a sectional view through the caisson, depicts this general arrangement and the associated concrete structure.

The turbine-generator system converts heat produced in the reactor to electrical energy. This system converted the thermal energy of steam produced in the reactor vessel into mechanical shaft power and then into electrical energy. The unit's turbine-generator consists of a tandem, compound, double flow, condensing turbine directly connected to a 13,800V, 3-phase, 60 cycle, hydrogen-cooled, synchronous generator. The turbine consists of a single flow high-pressure section and a double flow, low-pressure section with a crossover pipe connecting the two sections. The turbine was operated in a closed feedwater cycle whereby steam was condensed and the condensate/feedwater was returned to the reactor vessel. Heat rejected in the main condenser was removed by the Circulating Water System (CWS). The CWS delivers the water required to remove the heat load from the main condenser and other auxiliary equipment and returns it to the bay through the discharge pipes and a canal.

Commercial operation began in August of 1963 and continued until July of 1976, at which time the unit was shut down after approximately 13 years of operation to conduct seismic modifications. In 1983 PG&E announced the decision to decommission Unit 3. The plant has been maintained in NRC SAFSTOR since that time. Fuel transfer to the ISFSI has been completed.

1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[1]* 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, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"[21 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.

• Annotated references for citations in Sections 1-6 are provided in Section 7.

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Humboldt Bay Power PlantUnit 3 Document P01.1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 3 of 10 The rule defined three decommissioning alternatives as being a cceptable 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. However, with recent rulemaking permitting the controlled release of a site, the NRC has re-evaluated this alternative.[31 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. However, 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 entombments.[41 However, the NRC staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the disposition of greater-than-Class C material (GTCC) using this option, and the NRC's current priorities, at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.

The NRC published revisions to the general requirements for decommissioning nuclear power plants in 1996.[5] When the regulations were originally 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 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page4 of 10 decommissioning process. The new 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"[6] (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. The NWPAI 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.

Operation of DOE's yet-to-be constructed repository is contingent upon the review and- approval of the facility's license application by the NRC and the successful resolution of pending litigation. The DOE submitted its license application to the NRC on June 3, 2008, seeking authorization to construct the repository at Yucca Mountain, Nevada. Assuming a timely review and adequate funding, the DOE expects that receipt of fuel could begin as early as 2020. [71 TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 5 of 10 It is generally necessary that spent fuel be actively 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). [8] This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the continued operation of the ISFSLI DOE's contracts with utilities order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. For purposes of this analysis, acceptance of commercial spent fuel by the DOE is expected to begin in 2020 (in accordance 'With DOE's latest published schedule). Since the estimate assumes that all spent fuel will be transferred to the DOE during the first year, the estimate includes spent fuel caretaking costs through the year 2020.

1.3.2 Low-Level Radioactive Waste Policy Amendments Act The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, [9] 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, [10] and its Amendments of 1985, [11] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

Until recently, there were two facilities available to PG&E for the disposal of low-level radioactive waste generated by Humboldt. As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of the states of Connecticut, New Jersey and South Carolina). This leaves the facility in Clive, Utah, operated by EnergySolutions, as the only available destination for low-level radioactive waste requiring controlled disposal.

For the purpose of this analysis, the EnergySolutions' facility is used as the disposal site for the majority of the radioactive waste (Class A).

There are no currently operating disposal facilities available to PG&E that have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 6 of 10 reactor vessel. As such, waste disposal costs must be estimated. The disposal cost for low-level radioactive waste is based on a study sponsored by PG&E and Southern California Edison Company, "Establishing an Appropriate Disposal Rate for Low Level Radioactive Waste During Decommissioning."[ 12] The study w'as done to reflect the California Public Utilities Commission's desire for these owners to conservatively estimate their nuclear decommissioning LLRW disposal rates. Although no current licensed facility exists for Class B and C waste, the study assumes that a facility will be available by 2016 to support decommissioning.

The dismantling of the components residing closest to the reactor core 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.

However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

For purposes of this study, GTCC is packaged in the same type of canister used for spent fuel. The GTCC material is either stored with the spent fuel or shipped directly to a DOE facility as it is generated (depending upon the timing of the decommissioning and whether the spent, fuel has been removed from the site prior to the start of decommissioning).

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination,"[ 131 amending 10 CFR §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).

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 7 of 10 The decommissioning estimates for HBPP3 assume that the site will be remediated to a residual level consistent with the NRC-prescribed level.

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 Response, Compensation, and Liability Act (CERCLA or Superfund).[ 141 An additional limit of 4 millirem per year, as defined in 40 CFR §141.16, is applied to the drinking water exposure pathway.[151]

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) [16] 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.

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 8 of 10 FIGURE 1.1 LAYOUT OF THE NUCLEAR PLANT SITE AND SURROUNDING AREA TLG Services, Inc.

HumboldtBay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 9 of 10 FIGURE 1.2 SCHEMATIC DIAGRAM OF THE VESSEL AND INTERNALS

• JWADoY!R sws o LEVE pLm IRED WmGE TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 1, Page 10 of 10 FI FIGURE 1.3 SECTIONAL VIEW THROUGH THE CAISSON HEAT EXCHANGERS

-CORE SPRA:Y PUMPS NO. I & 2 i6UCT. REACTOR CLEAN.-UP PUMP' OISCH.

-j TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page 1 of 9

2. SAFSTOR DECOMMISSIONING ACTIVITIES This section describes the activities associated with the decontamination and disassembly of the plant. 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 understanding the expected scope of work, i.e., engineering and planning at the time of decommissioning.

The operation, shut down, and safe storage of the nuclear unit were described in detail in the decommissioning plan, "SAFSTOR Decommissioning Plan for the Humboldt Bay Power Plant, Unit No. 3". [171 The activities and associated costs expended prior to 1996, and routine operations and maintenance costs for dormancy, are not included in the estimate. This study understanding specifically addresses those activities and costs associated with the conclusion of the safe storage period and the subsequent decommissioning process.

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 a level that permits release for unrestricted use." The decommissioning scenario evaluated in this study presumes that final decommissioning activities will start in 2010.

The SAFSTOR decommissioning plan prepared by PG&E primarily addressed the activities and tasks related to preparing and maintaining the facility in safe storage.,

The document was originally intended to be revised (updated) prior to initiating decommissioning activities in the year 2007. Under the current NRC decommissioning requirements, the SAFSTOR Decommissioning Plan was considered to be both a Preliminary Shutdown Decommissioning Activities Report (PSDAR) and a Defueled Safety Analysis Report (DSAR). As a result, PG&E submitted a PSDAR in February 1998 that describes planned decommissioning activities and associated schedule and cost.[18] The SAFSTOR Decommissioning Plan was renamed the DSAR, and it contains system descriptions, administrative controls, and accident analysis. PG&E will submit a License Termination Plan at least two years prior to license termination.

The current NRC guidance (Reg. Guide 1.184 Decommissioning of Nuclear Power Reactors) defines decommissioning in three phases. The current plant status (safe storage) is addressed in Phase II. This phase is applicable to the dormancy phase of the deferred decommissioning alternatives. Phase III pertains to the activities involved in license termination.

The TLG cost estimating methodology subdivides the decommissioning project into periods, based upon major milestones in the project. Continuing Phase II expenses are TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page 2 of 9 included in Period 2 of this study, Phase III, includes the activities associated with license termination, is subdivided into Periods 3 and 4 in the cost estimate. Period .5 includes those activities required for site restoration. Post-Period 5 covers ISFSI operations, fuel transfer to the DOE, and ISFSI demolition..

2.1 PERIOD 2 - SAFE STORAGE AND DECOMMISSIONING PREPARATIONS With the recent completion of spent fuel transfer to the ISFSI, the emphasis has shifted to activities associated with preparation for active decommissioning tasks. Site activities include: preventive and corrective maintenance on essential systems, general building maintenance, operation and maintenance of heating and ventilation equipment, routine radiological inspections of contaminated structures, maintenance of structural integrity, and monitoring of environmental and radiation conditions.

The estimate includes some specific decommissioning preparation line items based upon the in depth planning activities which have occurred prior to and including 2008.

The following additional preparatory activities have occurred or are scheduled to occur prior to the start of formal decommissioning: abatement of remaining asbestos, performance of a vessel and internals activation analysis, performance of a radiological characterization survey of work areas, major components, and structures (including the drywell), sampling of internal piping and primary shield cores, development of cost and work control program, development of detailed work plans and schedules, development of a radioactive waste processing and disposal plan, and the development of the engineering decommissioning licensing basis.

2.2 PERIOD 3 - PREPARATIONS In anticipation of decommissioning, preparations are undertaken to provide a smooth transition from safe storage. The organization required to plan and manage the intended decommissioning activities is-assumed to be assembled from available utility staff and outside resources, as required. For purposes of this study, a combination of utility and outside contracted resources is utilized to manage the decommissioning and to manage and perform the physical decommissioning activities and associated management functions. A combination of utility staff and outside contracted resources will be employed to manage the processing and disposal of decommissioning waste, including the disposition of equipment, components, and material and the disposal of all TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Section 2, Page 3 of 9 decommissioning waste, including concrete and steel structural debris, contaminated soil, and associated hazardous and mixed waste.

2.2.1 Engineering and Planning Significant technical and engineering planning and evaluation must be performed in preparation for physical decommissioning activities.

Technical requirements documents are prepared for systems, components, and structures during each phase of the decommissioning (many of these requirements documents are already complete). These engineering requirements are then transferred into specific documents for the preparation of material and services contracts and for the preparation of detailed work plans and work authorization documents. Also, regulations require the preparation of a license termination plan. The plan is required at least two years prior to the anticipated date of license termination. The plan includes a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of any reuse of the site, an updated cost estimate to complete the decommissioning, and resolution of environmental concerns. The NRC will make the plan available for public comment. Plan approval will be subject to conditions and limitations as deemed appropriate by the NRC. Much of the information needed in preparing this submittal will have been used to develop the detailed engineering plans and procedures needed to support Period 4 activities.

Other engineering and planning work activities performed during Period 3 include: evaluating alternatives for the removal of highly radioactive reactor vessel components, identifying specialty contractors, selecting the methodology and requirements for systems and structures decontamination, preparing procedures for radioactive material disposal, and designing and procuring specialty tooling.

2.2.2 Site Preparations In preparation for the actual decommissioning, the following physical tasks are performed and included in the cost estimate:

" The design and licensing of the ISFSI facility (completed).

" Constructing and modifying site support and storage facilities, as required (in progress).

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Section 2, Page 4 of 9

" Processing and disposal of residual liquid, solid, and mixed waste inventories (in progress).

" Procuring waste containers, including specialty containers for the disposition of highly activated and hazardous materials. The types of containers needed to support decommissioning operations include strong-tight steel boxes and drums, shielded transport casks, dry fuel storage liners, high integrity containers, intermodal containers, and shipping transportation trailers. -J

" Developing procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste including dry active waste (DAW), resins, filter media, metallic and non-metallic components generated in decommissioning, site security and emergency programs, hazardous waste identification and processing, and industrial safety.

2.3 PERIOD 4 - DECOMMISSIONING OPERATIONS AND LICENSE TERMINATION The decommissioning cost estimate has divided this period into sub-periods to assist in the development of cost elements and to better understand the work sequence and its impact on the overall duration of the work phase.

2.3.1 System Removal This phase includes: construction of temporary facilities and shielding, modification of existing storage facilities to support the dismantling activities, decontamination of selected systems and components, procurement of specialty tooling, and modifications to systems and structures to support handling of the waste from reactor vessel and spent fuel pool removal.

The following is the list of the system and component removal activities performed during this sub-period.

" Removal of major turbine components, e.g. generator, turbine and condenser.

" Removal of components and systems in the Turbine Building, including piping, pumps, heat exchangers and associated mechanical and electrical components.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page 5 of 9

• Removal of electrical control boards, distribution buses, and transformers.

e Provide equipment handling capability and personnel access to equipment and components within the Refuel Building.

• Remove equipment and components in the Refuel Building..

q

• Removal of Hot Machine Shop equipment and piping.

2.3.2 Reactor Vessel Removal The following is a list of the system and component removal activities performed during this sub-period:

" Removal of the reactor vessel closure head. The head is assumed to be disposed of as low-level radioactive waste. Segmentation of the head may be desirable to increase packaging efficiency and minimize its disposal volume.

" Removal and segmenting of the steam dryer, core spray piping, feedwater sparger and chimney, as required, for transport. Component segmentation may be performed in the reactor vessel; however, relocation to the spent fuel pool would allow greater control with respect to water clarity and provide greater flexibility in packaging, i.e.,

homogenization of the waste forms. Material meeting 10 CFR 61 Class C criteria or less may be routed for off-site disposal at a commercial shallow-land waste disposal facility.

• Disassembly/segmentation of remaining reactor internals, including the core shroud, core support assembly, control rod guide tube and other miscellaneous components. These operations will probably be confined to the reactor vessel due to the higher activation levels of the components.

" Segmentation/sectioning of the reactor vessel, placing segments into shielded containers. The operation is performed remotely, in-air, using a shielded work platform and a contamination control envelope.

Sections are placed in liners and stored in the spent fuel pool. The liners are loaded into shielded transport casks for disposal at a commercial shallow-land waste disposal facility.

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page 6 of 9 Removal of control rod drive housings from reactor vessel bottom head and packaging for controlled disposal. The bottom head may be highly contaminated from the swarf generated from in-vessel segmentation activities. It may be advantageous to relocate the head to the spent fuel pool for additional processing and preparation for disposal. This will also significantly lower the working radiation levels within the drywell and allow disassembly work to proceed.

Removal of systems and associated components as they become non-essential to the vessel removal operation, related decommissioning activities, or worker health and safety (e.g., waste collection and processing systems, electrical and ventilation systems, etc.).

Removal of steel drywell liner and decontamination of the steel vent pipes connecting the drywell to the suppression chamber.

Contaminated surfaces can be designated for decontamination while activated portions are packaged for direct disposal. This work would also include the removal of activated concrete from behind the drywell steel and the concrete floor slab at the bottom of caisson, and packaging the material for direct disposal.

• Decontamination and removal of the suppression chamber steel, disposition of the waste as appropriate.

" Removal of contaminated equipment and material from the Radwaste Treatment and Refueling Buildings. Decontaminate the structures, e.g.,

scarifying concrete surfaces until residual levels of contamination are acceptable for unrestricted release.

" Decontamination of remaining contaminated site buildings and facilities. Package and dispose of all remaining low-level radioactive waste, and any remaining hazardous and toxic materials.

" Removal of remaining components, equipment, and plant services in support of the area release survey(s).

" Removal of contaminated soil and contaminated drain and catch basins. Remediation of the intake and discharge canals.

Components removed in the decontamination and dismantling of HBPP3 will be routed to an on-site central packaging and processing area.

Contaminated material will be characterized and packaged for disposal at the designated low-level radioactive waste disposal facility. Material that TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page 7 of 9 has been surveyed and found to be free of contamination will be released as scrap.

2.3.3 Prepare Buildings for Demolition Buildings in the Restricted Area (RA) will be decontaminated as necessary to allow conventional demolition. Structures will be removed down to three feet below grade.

Remaining systems will be removed, surveyed and either released or disposed of as radioactive waste.

Building decontamination debris and waste soil will be shipped using intermodal containers via truck to a LLRW disposal facility.

The internally contaminated pipe tunnel between the Radwaste Building and Turbine Building is expected to be filled with concrete, the soil surrounding the tunnel excavated, and the tunnel will be segmented into blocks and shipped to and disposed of at a LLRW disposal facility.

The spent fuel pool walls (the 3 exterior walls) and tremie floor beneath the pool will be removed and disposed of as radioactive waste. Removal of the walls and tremie requires special engineering controls due to the depth of the structures and soil conditions. A combination of ground freezing and sheet pile is expected to be utilized to provide access to this area.

2.3.4 Building Demolition, Yard Work, Soil Remediation Buildings in the Restricted Area (RA) will be demolished using conventional demolition. Most structures (including the Refuel Building and Turbine Building) will be removed down to three feet below grade.

Buildings entirely at grade will be completely removed. The Radwaste Building will also be removed in its entirety.

Contaminated soil will be excavated, and processed as needed to remove excess moisture.

Building demolition debris and contaminated soil will be packaged in intermodal containers and transferred via highway transport to EnergySolutions.

TLG Services, Inc.

Humboldt Bay Power PlantUnit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page 8 of 9 2.3.5 Final Site Survey License Termination 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, 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.

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)."[191 This document incorporates the statistical approaches to survey design and data 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 final termination of the license.

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.

.2.4 PERIOD 5 - SITE RESTORATION Excavated areas will be backfilled to grade using clean fill. The existing intake and discharge canals will also be backfilled.

Site areas affected by the dismantling activities are cleaned and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 2, Page9 of 9 The remaining Class B & C 'radioactive waste will'be shipped and disposed of at a yet to be approved licensed Class B/C disposal facility (assumed for purposes of the estimate to be Andrews County, Texas).

2.5 POST-PERIOD 5 - ISFSI OPERATIONS AND DEMOLITION The ISFSI will operate under a separate and independent license (10 CFR §72) following the termination of the §50 operating license. The ISFSI will continue to operate until all spent fuel and greater than Class C (GTCC) material has been transferred to the DOE. This study assumes that the DOE will transfer all spent fuel from HBPP3 in the year 2020.

At the conclusion of the transfer process, the ISFSI will be decommissioned. The storage modules are not assumed to be activated from the storage of fuel, due to the age of the fuel when placed in the modules. and the relatively short residence time. 'Consequently, this estimate does not include the cost of any significant decontamination of the ISFSI facility. Confirmation of the radiological status will be obtained through surveys and sampling of the modules.

The Commission will terminate the ISFSI 10 CFR 72 license when it determines that site remediation has been performed in accordance with a license termination plan and the terminal radiation survey and associated documentation demonstrate that the structure is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI.

The assumed design for the ISFSI is based upon the use of a multi-purpose canister installed in a steel-lined below grade engineered concrete vault. For purposes of this cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, required decontamination performed, and the license for the facility terminated, the concrete vault can be dismantled using conventional techniques for the demolition of reinforced concrete. After removal of the concrete vault and loading ramps the area will be graded and landscaped to conform to the surrounding environment.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 DecommissioningCost Study 2010,SAFSTOR Section 3, Page 1 of 18

3. COST ESTIMATE A site-specific cost estimate was prepared for decommissioning HBPP3. The estimate accounts for the unique features of the site, including the nuclear boiler, electric power generating systems, structures, and supporting facilities. The estimate incorporates the site specific and special tasks that have been defined as a result of the ongoing decommissioning planning. The basis of the estimate and the sources of information, methodology, site-specific considerations, assumptions, and total costs are described in this section.

3.1 BASIS OF ESTIMATE The estimate was developed using work areas as the incremental unit. As part of the 1997 cost estimate, each accessible area was visually inspected and a physical inventory of equipment, commodities and structural components of each area was documented. Specific consideration included material accessibility and egress, radiological conditions, and physical limitations for staging work crews. The current estimate maintains these work area designations and incorporates changes in decontamination and dismantling techniques based on ongoing on-site planning. The current estimate reflects the changes in the inventory which have occurred since the original estimate was performed.

Drawings and other documentation were used to plan and schedule activities in high radiation areas and areas currently inaccessible due to the plant's configuration. The unit factors used in developing equipment and component removal costs were adjusted for the working conditions determined for each area. Adaptation of the unit factors was accomplished by the manipulation of the duration adjustment variables or "Work Difficulty Factors" (WDF's).

The waste stream is assumed to be transferred to an on-site radioactive waste handling area for packaging and disposal preparation. Class A low-level radioactive waste generated in the decontamination and dismantling of HBPP3 is assumed to be buried at a LLRW disposal facility. Class B and C low-level radioactive waste is assumed to be stored&onsite until a Class B/C disposal facility becomes available.

Spent fuel has been relocated to the ISFSI. This allows for decontamination and dismantling activities to proceed on the refueling building without the constraint to maintain active spent fuel storage pool systems and services, as well as to eliminate any safety issues associated with dismantling activities in the vicinity of the pool.

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page2 of 18 HBPP3 above grade structures will be demolished using standard methods and all demolition debris will be shipped off site to a LLRW disposal facility.

Below grade portions of structures such as the Refuel and Turbine Buildings will be decontaminated and left in place. The Radwaste Building will be removed in its entirety.

As the licensee, PG&E will oversee the decommissioning operations. The plant staff will be augmented with the resources necessary to ensure a safe and efficient operation. This organization will supervise the decontamination and dismantling of the nuclear unit. Oversight will continue in a reduced capacity during site restoration and beyond, as dictated by the management of the spent fuel.

3.2 METHODOLOGY The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[201 and the DOE "Decommissioning Handbook."[ 2 1] 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) were developed using local labor rates. The activity-dependent costs were 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 22 Data," published by R.S. Means.[ ]

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.

The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail available in the unit cost factors for activity time, labor (by craft), and equipment and consumable costs provide assurance that cost elements has not been omitted. These detailed unit cost factors, coupled TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page3 of 18 with the plant-specific inventory of piping, components, and structures provide.

a high degree of confidence in the reliability of the cost estimates.

Work Difficulty Factors WDF were assigned to each area, commensurate with the inefficiencies associated with working in confined hazardous environments. The ranges used for the WDFs are as follows:

Access Factor 0% - 75%

Respirator Protection Factor 0% - 100%

Radiation/ALARA Factor 0% - 100%

Protective Clothing Factor 0% - 100%

Work Break Factor 8.33%

Alpha Adjustment Factor 0% - 200%

These factors and their associated range of values were developed in conjunction with the Atomic Industrial Forum's guideline. The factors (and their suggested application) are discussed in more detail in that publication. The WDF assigned to each work area is delineated in Appendix A.

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 radiologically 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 are based upon productivity information available from the "Building Construction Cost Data" publication.

PG&E established the work sequence and duration based upon the length of time and resources required to prepare for and remove the reactor vessel and internals. 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 systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.

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 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page4 of 18 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"'[23] 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, includes contingency based on a preliminary technical position[241 to reflect the California Public Utilities Commission's desire for owners to conservatively establish an appropriate contingency factor for inclusion in the decommissioning revenue requirements.

Contingency Based on AIF Guidelines As stated in the AIF study contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a 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 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Section'3, Page5 of 18 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:

o Decontamination 50%

o Contaminated Component Removal 25%

o Contaminated Component Packaging 10%

• Contaminated Component Transport 15%

• Low-Level Radioactive Waste Disposal 25%

o Reactor Segmentation 75%

o NSSS Component Removal 25%

o Reactor Waste Packaging 25%

o Reactor Waste Transport 25%

o Reactor Vessel Component Disposal 50%

o GTCC Disposal 15%

" Non-Radioactive Component Removal 15%

• Heavy Equipment and Tooling 15%

o Supplies 25%

• Engineering 15%

• Energy 15%

o Characterization and Termination Surveys 30%

• Construction 15%

o Taxes and Fees 10%

• Insurance 10%

o Staffing 15%

The contingency values are applied to the appropriate components of the estimates on a line item basis. The composite contingency value (excluding additional contingency described in the Preliminary Technical Position) is 21.7%.

Contingency Based on Preliminary Technical Position In addition to the contingency based on the AIF guidelines additional contingency was added to reflect the California Public Utilities Commission desire for owners to conservatively establish an appropriate contingency factor for inclusion in the decommissioning revenue requirements. Based on the previously referenced technical position, additional contingency was added to reflect an overall project TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page6 of 18 contingency of 25%. This contingency was incorporated on a line item basis, with each line item receiving a pro-rated share of the increase.

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 decom~missioning 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:

o 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.

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

o 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.

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

o 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.

o Pricing changes for basic inputs such as labor, energy, materials, and disposal. Items subject to widespread price competition (such as TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 7 of 18 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.

It has been TLG's experience that the results of a risk analysis, when compared with the base case estimate for decommissioning, indicate that the chances of the base decommissioning estimate's being too high is a low probability, and the chances that the estimate is too low is a higher probability. This is mostly due to the pricing uncertainty for low-level radioactive waste burial, and to a lesser extent due to schedule increases from changes in plant conditions and to pricing variations in the cost of labor (both craft and staff. This cost study, however, does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities.

Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.

3.4 SITE SPECIFIC CONSIDERATIONS 3.4.1 Spent Fuel Disposition The ISFSI design consists of a multi-purpose (storage and transport) dry canister within a vertical multi-purpose steel cask. The ISFSI is also designed and sized to handle one container of greater than Class C (GTCC) waste that will be generated during the reactor vessel dismantling. The ISFSI will operate until 2020, the current projected date for the DOE to remove all spent fuel from the facility. Any delays in the transfer date to the DOE will increase the overall operations and maintenance cost.

The cost estimate includes the cost for the ISFSI canisters, the concrete storage facility, the road to the storage facility, and all engineering, construction, licensing, and cask handling (most of these costs have been incurred, see cost table ISFSI Completed Projects). The decommissioning cost estimate includes costs for operation, maintenance, inspections, and security.

3.4.2 Reactor Vessel and Internal Components The reactor vessel and internal components will be segmented in place and transported for disposal in shielded transportation, casks.

Segmentation of the less activated components is performed in the spent TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page8 of 18 fuel storage pool to the extent practical. The highly activated components can be disassembled in the vessel as long as water clarity is maintained. The vessel is segmented in place, using a mast-mounted cutter.

The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal, i.e., GTCC. Although the material is not classified as high-level waste, the DOE has indicated it will accept this waste for disposal at the future high-level waste repository.[25 ] However, the DOE has not been forthcoming 'With an acceptance criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and waste form requirements. As such, for purposes of this study, the GTCC has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel. It is not anticipated that the DOE would accept, this waste prior to completing the transfer of spent fuel.

Therefore, until such time the DOE is ready to accept GTCC waste, it is reasonable to assume that this material would remain in storage at the HBPP3 site.

Feedwater piping is cut from the reactor vessel once the water level in the vessel (used for personnel 'shielding during dismantling and cutting operations in and around the vessel) is dropped below the nozzles.

The estimate further assumes that the fuel failures that occurred released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes has been prevented from reaching levels exceeding those which permit the major NSSS components to be shipped under current DOT regulations and to be buried within the requirements of 10 CFR 61.

The cost to remove and dispose of 48 control rod blades is included in the estimate.

3.4.3 Main Turbine and Condenser Due to the internal alpha particle contamination within the turbine, condenser and the associated components, PG&E plans to dismantle the components intact (disassemble pack, and ship without disassembly as much as possible) thereby minimizing the potential spread of radioactive contamination. The current estimate reflects these methods.

Each component is surveyed, packaged and shipped a LLRW disposal facility.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page9 of 18 3.4.4 Plant Systems Due to the high levels of alpha contamination, mechanical cutting using saws and portable pipe cutters is the primary method of removing mechanical and electrical components. The cut areas for internally contaminated components will be sealed prior to mechanical cutting to mitigate the spread of internal contamination. The work difficulty factors and the unit cost factors for component removal and for selective building structural decontamination have been adjusted to account for the impact of working in areas containing alpha contamination.

Mechanical cutting using saws and portable pipe cutters is the primary method of component removal used in the estimate.

3.4.5 Humboldt Bay Unit 3 Facilities Typically surface contamination can be removed by scarification where the contamination is limited to a thin surface layer. This technique is most~effective on smooth, unbroken surfaces. The concrete surfaces were originally uncoated and were subject to additional contamination deposits due to failed fuel in early cycles. As such, the contamination has likely migrated to depths greater than can be effectively removed by surface scarification techniques. This condition was observed during the plant stack removal project where the vendor had difficulty in meeting the free-release criteria for the stack material, even after extensive surface decontamination. As a result of this expected plant condition and for the purposes of this estimate, structural material removed as part of the decommissioning project was assumed to be disposed of at a LLRW disposal facility. Although this same condition is expected to exist in below grade structures, due to the high water table and resulting cost to remove below grade structures, most of these structures will be decontaminated and surveyed in place.

Decontaminating below-grade structures to free-release is expected to be more cost-effective than complete removal.

The spent fuel pool walls and tremie concrete beneath the pool is not expected to be cost effectively decontaminated to meet free-release limits. Consequently the estimate assumes an engineered approach to allow the excavation of the soil and, removal of the spent fuel pool walls and floor. A combination of sheet pile and a freeze seal in the soil surrounding the spent fuel pool will be installed to facilitate the excavation and to prevent the in-leakage of groundwater into the area requiring remediation. Contaminated concrete and soil will be disposed of as radioactive material.

TLG Services, Inc.

HumboldtBay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 10 of 18 The concrete pipe tunnel (connecting the radwaste, refueling and turbine buildings) is not expected to be able to be cost effectively decontaminated to meet free-release limits. This structure will be removed in its entirety by excavating the soil surrounding the tunnel, filling the free space with grout, removing, packaging and disposal of the material as radioactive material.

Significant alpha contamination exists within primary systems and as fixed contamination in the Refueling, Radwaste, and Turbine buildings as a result of failed fuel. The presence of alpha contamination will result in the need for additional radiological controls and will reduce overall worker productivity and the efficiency of component removal activities.

The additional controls are designed to protect personnel from receiving internal alpha dose. These controls will include: additional time for the set up of localized control of the contamination, additional respiratory protection requirements and controls, additional resources to perform surveys and establish contamination controls, additional time to obtain, dry, and prepare for counting alpha samples, and additional nonproductive time for personnel involved in removal activities due to the alpha contamination. Therefore, the WDF for building decontamination activities in specified work areas has been increased from 50 to 100% to account for these activities.

The caisson surrounding the reactor vessel, which constitutes the containment structure, will remain in place. The estimate assumes that the removal of the suppression pool liner and the decontamination of the concrete surfaces beneath the liner should be adequate to preclude wholesale removal of the entire caisson structure.

Additional facilities will be required in support of decommissioning activities. This estimate provides for the following: personnel decontamination facility, protective clothing change-out facility, new radiological area access control point, relocation of the radiological counting room, additional laydown areas (paved and unpaved) for storage or radioactive material, storage area for waste shipping containers, radwaste shipment truck weighing & monitoring area, a bulk material drying and storage area. An allowance has also been provided in the Period 3 costs for modification and upgrade of the Refueling Building crane. These upgrades are required prior to the start of decommissioning work in the buildings.

The HBPP site is physically small and the current restricted area is within 100 feet of the sites boundary. As such, the Radwaste Process TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 11 of 18 Facility must be situated in a location to minimize the potential radiation exposure to the public.

The estimate assumes perimeter fence and in-plant security barriers will be moved as appropriate to maintain public exposures ALARA.

All buildings scheduled for demolition will be removed to a nominal depth of three feet below grade, with the decontaminated or non-contaminated sub grade foundations remaining in place. Holes will be drilled in each of the foundation basemats to allow for natural drainage.

Building foundations will be backfilled with clean backfill, and the site will be graded and landscaped. All areas affected by dismantling activities will be cleaned up, covered with loam, and seeded.

A cost has been included for the survey of structures after decontamination and prior to the demolition and disposal of the debris.

Decontamination and survey of the structures will allow more efficient structures demolition with reduced radioactive materials monitoring and controls.

Yard drainage piping and surrounding soils are contaminated and will be excavated and removed as radioactive material.

The existing circulating water discharge piping will be abandoned in place.

The discharge canals and portions of the intake canal will be remediated. Contaminated material will be excavated and disposed of as low-level radioactive waste. The existing intake and discharge canals will be permanently backfilled with clean material. One third of the intake and discharge backfill cost is assigned to HBPP3.

A small volume of clean asphalt paving' will be shipped to a facility (Portland, Oregon) for disposal.

3.4.6 Transportation Methods Class A waste (including waste from the reactor vessel segmentation) will be shipped by truck to the EnergySolutions disposal site. Class B and C low-level radioactive waste will be moved overland by truck or shielded van to a yet to be determined site but assumed to be Andrews County, Texas. Building demolition debris and waste soil will be shipped using intermodal containers via truck to EnergySolutions.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 12 of 18 Portions of the reactor vessel and internal components will be transported in accordance with 10 CFR 71, as Type B and C waste. It is conceivable that the reactor, due to its limited specific activity, could qualify as Low Specific Activity (LSA) II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated with the packaging to attenuate the dose to levels acceptable for transport under 49 CFR 173.[26] Contaminated piping, components, and structural steel other than the reactor vessel and internals, will qualify as LSA - I, II, or III or SCO-I, or II, as described in 49 CFR Part 173. The contaminated material will be packaged in Industrial Packages (IP I, II, or III) for transport unless demonstrated to qualify as their own shipping containers.

Shielded truck casks will be used to transport highly activated metal produced in the segmentation of the reactor vessel and internal components. Cask shipments may exceed 95,000 pounds due to the weight of the vessel segments(s), supplementary shielding, cask tie-downs and the tractor-trailer. The maximum curies per shipment assumed permissible is based upon the license limits of available shielded shipping casks. The number and curie content of vessel segments are selected to meet these limits. The number of cask shipments out of the Refueling Building is expected to average one per week. Non-cask shipments will be limited to five per week.

An allowance has been provided in the estimate for the purchase of 28 special trailer beds. State law restricts the size of the trucks on local roads. Since shortened truck beds are not readily available for lease, PG&E has decided to purchase the equipment.

Transportation costs are estimated using published tariffs from Tri-271 State Motor Transit.[

3.4.7 Coordination with Units 1 and 2 Unit 1 and 2 are scheduled to be dismantled concurrent with the decommissioning of Unit 3.

This estimate includes the cost of removal of the entire site drainage network. A portion of the excavated soil will require remediation and will be disposed of as radioactive waste. The estimate includes a cost element for the replacement of essential portions of the yard drainage system that may still be required for Units 1 or 2.

TLG Services, Inc.

I Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 13 of 18 Wherever shared process systems exist, between the fossil units and Unit 3, the Unit 3 systems will be isolated from the remaining operational portions. Unit 1 and 2 portions of these systems that contain residual contamination will be remediated and decontaminated.

In accordance with NRC requirements, and based upon known radioactive contamination, limited exterior radiological surveys of Units 1 and 2 will be conducted as part of the Final Site Survey.

3.4.8 Site Conditions Following Decommissioning It is assumed that the Unit 3 structures and site facilities will be dismantled following their decontamination. Most structures which contain below-grade areas (such as the Refuel and Turbine Buildings) will be removed to a nominal depth of 3 feet below grade. Due to expected radiological conditions, the Radwaste Building will be demolished in its entirety. The below-grade voids would be backfilled with clean debris and capped with soil. The site would then be graded to conform to the adjacent landscape. Vegetation would be established to inhibit erosion.

The canals will be backfilled with clean material. The switchyard will remain in place, as well as the site access road.

3.5 ASSUMPTIONS The following additional factors and conditions were used in developing the decommissioning cost estimate for HBPP3. Radwaste estimating assumptions are contained in Section 5.

3.5.1 Estimating Basis The estimate is performed in accordance with the methodology described in the AIF/NESP-036 study. Decommissioning costs are reported in the year of projected expenditures; however, the values are reported in 2008 dollars for the current estimate. Costs are not inflated or escalated over the period of performance.

Plant drawings, equipment, and structural specifications, including construction details, were provided by PG&E. TLG personnel prepared the inventory of plant equipment.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 14 of 18 3.5.2 Labor Costs Although PG&E will oversee the decommissioning operations, this study assumes that PG&E augments its workforce with contractors to support planning, engineering, procurement, field supervision, and labor. This outside contracted managerial and professional workforce is referred to as the "DOC Staff Cost" in the Period-Dependent Costs line items in the Appendix D detailed cost table.

Utility staffing requirements will vary with the level of effort associated with the various phases of the project. Once the decommissioning program. starts, only those staff positions necessary to support the decommissioning program are included. There are no costs reflected Within the estimate for the transition of the maintenance organization to decommissioning, e.g., separation packages, re-training, severance, incentives, etc.

The craft labor required to decontaminate and dismantle the nuclear unit will be acquired through standard contracting practices. Current local craft labor rates were used in the estimate. Costs for site administrative, operations, construction and maintenance personnel are based upon current PG&E salary information. Engineering services for such items as writing activity specifications, detailed procedures, and work procedures are assumed to be provided by the DOC.

3.5.3 General The existing plant equipment inventory is obsolete and only suitable for scrap as deadweight quantities. No equipment is salvageable. Scrap generated during decommissioning is not recognized as having any value because (1) scrap value generally offsets scrap removal and processing costs and (2) scrap materials have a relatively low market value. Scrap processing and site removal costs are not included in the estimate.

Clean asbestos will be disposed in an approved landfill. Contaminated asbestos will be buried as radioactive waste.

PG&E will provide the electrical power for decommissioning.

PG&E will remove all items of furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, other similar mobile equipment, and other such items of personal property owned by PG&E that will be TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 15 of 18 easily removed without the use of special equipment at no cost or credit to the project.

Existing 'warehouses will remain for use by PG&E and its subcontractors.

The study follows the principles of ALARA through the use of work duration adjustment factors. These factors adjust. the time and cost for performing tasks after consideration of factors such as use of protective clothing and respirators and the' effect of indoctrination and mock-up training. These items lengthen a task's duration, which increase the costs and lengthen the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures.

Nuclear liability insurance provides coverage for off-site damage or injuries due to radiation exposure from equipment and material.

Nuclear property insurance provides protection against direct physical damage to on-site property by a broad range of causes including, radioactive contamination, fires, floods, etc. This estimate includes the premium cost for both liability and property insurance. The premiums are adjusted to reflect the relative changes in risk during the various phases of decommissioning. Insurance is required until both the Part 50 and Part 72 licenses are terminated.

The perimeter fence and in-plant security barriers will be moved as appropriate to conform with the Security Plan in force at the various stages in the project. Additional survey equipment will be purchased to support the large radiological protection program and the Final Status Survey (FSS) effort.

The existing electrical switchyard will remain after decommissioning in support of the remaining site generating units and the utility's electrical transmission and distribution system.

Underground concrete pipe will be decontaminated and abandoned.

Underground steel pipe will be removed, surveyed for contamination, removed from the site, and disposed of as clean scrap. Electrical manholes will be backfilled with suitable earthen material and abandoned.

The caisson encapsulating the reactor vessel compartment will be decontaminated and abandoned in place.

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3,.Page 16 of 18 A series of groundwater monitoring wells will be installed to sample groundwater for 90Sr and other mobile radionuclides. A nominal amount of mixed waste will be disposed of and 169,000 cubic feet (packaged volume) of contaminated soil will require removal and disposal.

3.6 COST ESTIMATE

SUMMARY

A summary of the decommissioning costs and annual expenditures is provided in the cash flow summary in Table 3.la. Table 3.lb is a similar table of annual expenditures but omits those costs disallowed by the California Public Utility Commission (CPUC). Table 6.1 provides a breakdown of those same decommissioning costs into the components of decontamination, removal, packaging, etc. The costs were extracted from the detailed reports in Appendices D & E, which provide a detailed listing of activities and associated costs for the decommissioning scenario.

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 17 of 18 TABLE 3.1a SCHEDULE OF EXPENDITURES (thousands, 2008 dollars)1 PG&E Equipment & Contractor Process &

Year Labor Materials Labor Burial Other Yearly Totals 1996 - 2008 81,801 81,801 2009 7,023 10,371 20,392 5,780 14,860 58,427 2010 7T,350 4,383 19,966 7,514 6,288 45,501 2011 7,689 10,291 19,872 11,224 6,225 55,301 2012 7,858 11,278 21,964 19,917 7,400 68,416 2013 7,605 7,059 24,274 34,549 9,647 83,133 2014 6,594 3,271 13,084 12,515 5,981 41,446 2015 6,127 2,432 14,093 8,383 6,079 37,115 2016 697 0 3,830 1,850 2,006 8,382 2017 370 3,471 525 4,365 2018 370 3,471 525 4,365 2019 370 3,471 525 4,365 2020 363 258 3,587 426 2,506 7,139 52,417 49,345 151,474 102,157 144,367 499,759 1 Columns may not add due to rounding TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 3, Page 18 of 18 TABLE 3.1b SCHEDULE OF EXPENDITURES, EXCLUDING CPUC DISALLOWANCES (thousands, 2008 dollars)1 PG&E Equipment & Contractor Process &

Year Labor Materials Labor Burial Other Yearly Totals 1996 - 2008 81,801 81,801 2009 7,023 10,371 20,392 5,780 14,860 58,427 2010 7,350 4,352 19,848 7,354 6,276 45,179 2011 7,689 10,291 19,872 11,224 6,225 55,301 2012 7,858 11,278 21,964 19,917 7,400 68,416 2013 7,605 7,059 24,274 34,549 9,647 83,133 2014 6,594 3,253 13,040 12,515 5,980 41,383 2015 6,127 2,432 14,093 8,383 6,079 37,115 2016 697 0 3,830 1,850 2,006 8,382 2017 370 3,471 525 4,365 2018 370 3,471 525 4,365 2019 370 3,471 525 4,365 2020 363 258 3,587 426 2,506 7,139 52,417 49,295 151,312 101,997 144,353 499,373 1 Columns may not add due to rounding TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 4, Page 1 of 3

4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follows the sequence presented in the AIF/NESP-036 study, with minor changes to reflect current planning and site-specific constraints. In addition, the schedule reflects the spent fuel management plan outlined for HBPP3.

Appendix F presents a GANTT chart schedule for the 2010 SAFSTOR decommissioning alternative. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the Appendix D cost table, but reflect sub-dividing some activities to facilitate understanding and combining others for clarity. The schedule was prepared using the "Microsoft Project for Windows" computer software. [28]

4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule estimate 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 schedule forecast is current as of December 2004. The following assumptions were made in the development of the decommissioning schedule:

• Spent fuel transfer to the ISFSI was completed in 2008. Only limited decommissioning activities have occurred up until now.

• All work (except vessel and internals removal) is performed during an 10-hour workday, 4 days per week, with no overtime.

e Vessel 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 the stringent safety measures necessary during demoli-tion of heavy components and structures.

• For removal of plant systems by area, the areas with the longest removal durations on the critical path are considered to determine the duration.

TLG Services, Inc.

Humboldt Bay Power PlantUnit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 4, Page 2 of 3 4.2 PROJECT SCHEDULE The period-dependent costs presented in the cost table in Appendix D are based upon the durations developed in the decommissioning project schedule.

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 total costs for these period-dependent items.

A project timeline for the decommissioning alternative is included in this section as Figure 4.1.

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 4, Page 3 of 3 FIGURE 4.1 DECOMMISSIONING TIMELINE (not to scale)

Period 3 Period 4 -Period 5 Post-Period 5 Systems Removal " Remove RPV / fuel pool Final term. survey Site restoration DOE fuel shipments Planning Activities Preparations for Reactor Vessel Removal Building Decoa Bluikling tlemolition I Dry fuel storage Dry fuel storage Plant preparations Dry Fuel Storage . Dry fuel storage Dry fuel storage 1/2009 4/2009 412011 10/2012 1/2016 1/2020 12P2020 Dewemmiosin ning Complete Key Assumutions:

1. Decommissioning commences on January of 2009.

2. Use of a Decommissioning Operations Contractor (DOC) in later Period 3 planning activities.

3. USDOE acceptance of spent fuel shipments occurs in 2020.

4. GTCC wastes are removed from the plant site with the spent fuel.

Critical Path Discussion:

Following removal of all spent fuel to long term dry storage, the decommissioning critical path is assumed to be sequentially composed of preparations for and removing the reactor vessel and spent fuel pool, decontamination of buildings, performing final site termination surveys, site restoration, and final spent fuel acceptance and removal by the USDOE.

TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 5, Page 1 of 3

5. RADIOACTIVE WASTE 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,[291 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, and small components. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. Demolition debris (including concrete) and contaminated soil is packaged and transported in reusable 25-yard steel intermodal containers.

The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in Appendices D, and summarized in Tables 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).

TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 5, Page 2 of 3 13 7Cs will still While the dose rates decrease with time, radionuclides such as control the disposition requirements.

The waste material produced in the decontamination and dismantling of the nuclear plants is primarily generated during Period 4 of SAFSTOR. Material that is removed from the radiological controlled areas is routed for controlled disposal.

Structural demolition debris and soil will be loaded onto intermodal containers and shipped by truck to a LLRW disposal facility. The estimate assumes that PG&E will purchase 28 shipping trailers that are sized to meet the overland road shipping limitations of local highways. The cost of the facility and the trailers are included in the estimate.

For the purpose of this analysis, the EnergySolutions' facility is used as the disposal site for the majority of the radioactive waste (Class A). This waste was disposed of at a rate of $62 per cubic foot for "Bulk" waste, and a rate of $252 per cubic foot for "General" waste. These rates include State of Utah taxes and Southwest Compact fees. There are' no currently operating disposal facilities available to PG&E that 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. As such, waste disposal costs and waste transportation distances were estimated. For purposes of estimating the Class B and C waste transportation cost it was assumed that this waste was shipped to Andrews County, Texas. The cost for disposal for Class B and C waste was $2,916 per cubic foot. This rate includes Southwest Compact fees.

These disposal costs for low-level radioactive waste are based on a study sponsored by PG&E and Southern California Edison Company. The study was done to reflect the California Public Utilities Commission's desire for these owners to conservatively estimate their nuclear decommissioning LLRW disposal rates.

TLG Services, Inc.

HumboldtBay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR 1 Section 5, Page 3 of 3 TABLE 5.1 DECOMMISSIONING WASTE DISPOSAL

SUMMARY

3 Waste Volume (cubic feet)

Low-Level Radioactive Waste1 Class A2 328,201 Class B 3,083 Class C 566 GTCC 17 Subtotal 331,866 Miscellaneous Wastes Demolition Debris 327,036 Notes: 1 Radioactive waste is classified according to the requirements as delineated in Title 10 of the Code of Federal Regulations, Part 61.55.

2 Class A waste includes soil, discharge canal sediment and reactor caisson mixed waste.

3 Column may not add due to rounding.

TLG Services, Inc.

Humboldt Bay Power PlantUnit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 6, Page 1 of 3

6. RESULTS The analysis to estimate the costs to decommission HBPP3 relied upon the site-specific, technical information developed for previous analyses prepared in 1997, 2001, and 2004. The estimate also incorporates additional activities and considerations which have been identified as a result of the ongoing planning. While not an engineering study, the analysis provides PG&E with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The estimates described in this report are 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 scenario reflects the fact that all spent fuel has been transferred to the ISFSI and it will remain in the ISFSI until such time that the DOE can complete the transfer of the assemblies to its repository.

The cost projected to decommission (SAFSTOR 2010) HBPP3 is $499.8 million (including 25% contingency) in 2008 dollars. This total includes $385,520 that has been classified as CPUC's disallowances. The majority of this cost (84.3%) is associated with the physical decontamination and dismantling of the nuclear units so that the licenses can be terminated. Another 15.3% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 0.4% 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 (staffing) 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 PG&E 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, and the long-term care of the spent fuel.

As described in this report, spent fuel has been transferred to the ISFSI and will remain there until the DOE is able to receive it. Dry storage of the fuel under a TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 6, Page 2 of 3 separate license 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, disposal of the radioactive material, including concrete and structural steel, as well as the highly radioactive material, is sent to either a currently licensed LLRW facility (Class A waste) or the a yet to be licensed (Class B and C waste) burial site. Highly activated reactor vessel components (GTCC), requiring additional isolation from the environment, are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.

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 wages.

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.

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. J TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 6, Page 3 of 3 TABLE 6.1

SUMMARY

OF DECOMMISSIONING COST CONTRIBUTORS Work Category Costs 08' $ -. Percent of Costs 04' $

(thousands) Total (thousands)

Decontamination 978 0.2% 1,865 Removal 48,360 9.7% 23,899 Packaging 9,258 1.9% 3,087 Shipping 11,722 2.3% 5,578 Waste Processing & Recycling 675 0.1% 8,877 LLRW Burial 77,596 15.5% 17,446 Demolition LLRW Burial 23,872 4.8% 38,528 Staffing 132,760 26.6% 70,516 Security 45,687 9.1% 4,149 License Termination Survey 1,958 0.4% 9,874 Insurance 1,000 0.2% 786 Energy 1,254 0.3% 827 NRC & EP Fees 5,386 1.1% 1,935 NRC ISFSI Fees 1,023 0.2% 3,745 ISFSI Capital, O&M, Fixed & Security 57,798 11.6% 66,391 Non-ISFSI Expenditures 28,015 5.6% 20,282 Equipment & Supplies 28,797 5.8% 28,520 Engineering 23,618 4.7% '11,121 Total 499,759 100.0% 317,424 CPUC Disallowances Removal 193 50.1% 172 Packaging 21 5.5% 14 Shipping 4 0.9% 5 Waste Processing & Recycling 0 0.0% 30 LLRW Burial 165 42.8% 135 Equipment & Supplies 3 0.7% 2 Total 386 100.0% 357 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 7, Page 1 of 3

7. REFERENCES

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

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

4. 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

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

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

7. DOE/RW-0604, "Project Decision Schedule," U.S. Department of Energy's Office of Civilian Radioactive Waste Management, January 2009

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

9. U.S. Code of Federal Regulations, Title 10, Part 61.55, "Waste classification"

10. "Low-LevelRadioactive Waste Policy," Public Law 96-573, 1980

11. "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, January 15, 1986:

12. "Establishing an Appropriate Disposal Rate for Low Level Radioactive Waste During Decommissioning", Robert A Snyder NEWEX, Revision 0, July 2008 TLG Services, Inc.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 7, Page 2 of 3

7. REFERENCES (continued)

13. 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

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

15. 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"

16. "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

17. SAFSTOR Decommissioning Plan for the Humboldt Bay Power Plant, Unit No.

3, July 1984

18. Preliminary Shutdown Decommissioning Activities Report, PG&E letter HBL-98-002 dated February 27, 1998

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 2004," 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.

HumboldtBay Power Plant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Section 7, Page 3 of 3

7. REFERENCES (continued)

24. "Technical Position Paper for Establishing an Appropriate Contingency Factor for Inclusion in the Decommissioning Revenue Requirements", Study Number:

DECON-POS-H002, Revision A, Status: Preliminary (provided by PG&E)

25. "Strategy for Management and Disposal of Greater-Than-Class C Low- Level Radioactive Waste," Federal Register Volume 60, Number 48 (p 13424 et seq.),

March 1995

26. U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 1996.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+), June 27, 1988

27. Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, January 2008

28. "Microsoft Project 2003," Microsoft Corporation, Redmond, WA, 2002

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

TLG Services, Inc.

Humboldt Bay Power PlantUnit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix A, Page 1 of 4 1'

APPENDIX A WORK DIFFICULTY FACTOR ADJUSTMENTS TLG Services, Inc.

HumboldtBay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix A, Page 2 of 4 APPENDIX A WORK DIFFICULTY FACTOR ADJUSTMENT Respiratory Protective Alpha AREA AREA DESCRIPTION Access Protection ALARA clothing Adjust..

RB1-1 Emergency Condenser 20 25 10 30 200 RB1-2 Spent Fuel Pool 20 25 10 30 200 RB1-3 Cask Shipping Area 10 25 10 30 150 RB1-4 SFP Pumps/Filters 0 25 10 30 150 RB1-5 LaydowniCask Washdown General Area 10 25 10 30 150 RB1-6 Reactor Vessel Cavity 30 50 40 50 150 RB2-1 El -2 Suppression Pool Cooler 10 25 10 30 150 RB2-2 Elev. - 14, Manlift 10 25 10 30 150 RB2-3 Elev. -24, CRD Hydraulic Filters 30 50 40 50 150 RB2-4 Elev. -34, Suppression Pool Access Hatch 10 25 20 30 150 RB2-5 Elev. -44, CRD Piping 10 50 20 30 150 RB2-6 Elev. -54, CRD Trip Accumulators 10 25 20 30 150 RB2-7 Elev. -66, Caisson Sump, REDT 10 25 20 30 150 RB2-8 Suppression Pool - North 30 50 40 50 150 RB2-9 Suppression Pool - South 30 50 40 50 150 RB3-1 Cleanup Heat Exchangers 10 50 20 30 150 RB3-2 New Fuel Storage/Fuel Pool Coolers 20 25 20 30 150 1 RB4-1 Shutdown Heat Exchangers/Pumps 50 50 20 50 200 RB4-2 TBDT/Floor Drain Pumps 20 50 20 50 200 RB5-1 RFB Roof (HVAC only) 0 25 10 30 100 RB5-1 RFB Roof 0-- 25 10 30 100 TB 1-1' Main Turbine 75 75 20 50 200 TB 1-2 Main Generator/Exciter House 0 0 0 0 100 TB1-3 Hydrogen Yard 0 0 10 30 100 TB2-1 Main Condenser 75 75 20 50 200 TB2-2 Seal Oil Unit/Exciter Swgr 0 0 10 30 100 TB3-1 Reactor Feed/Lube Oil/Air Sytems 10 25 10 30 150 TB3-2 Propane Engine Generator 0 0 0 0 100 TB3-3 2400/480V Transformers 0 0 10 0 100 TB4-1 Laundry Drain Tank/Pipe Tunnel 10 25 20 30 150' TB4-2 Pipe Gallery 50 50 20 50 200 TB5-1 Anion/Cation/Resin Tanks 10 25 20 30 150 TB5-2 Condensate Demineralizers 10 25 20 30 150 TB6-1 Air Ejector/Gland Seal Condenser 10 25 10 30 150 TB6-2 Vacuum Pump/Condensate Pumps 0 25 10 30 150 TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix A, Page3 of 4 APPENDIX A WORK DIFFICULTY FACTOR ADJUSTMENT (continued)

Respiratory Protective Alpha AREA AREA DESCRIPTION Access Protection ALARA clothing Adjust.

TB17-1 Main Control Room 0 25 10 30 100 TB17-2 Instr Repair/Counting Room/Vent Equip 0 0 10 0 100 TB17-3 Locker Room/Personnel Decon 0 0 10 0 100 TB7-4 Hot Lab 10 25 10 30 150 TB7-5 Demin Control Panel/RFB Access 0 0 10 0 100 TB7-6 Hot Lab Attic 10 25 10 30 100 TB7-7 RP Office/Count Room 0 0 0 0 100 RWl-1 RWB - Concentrator/Pumps/Filters 10 25 20 30 150 RW1-2 RWB - Waste Receiver/Hold Tanks 10 25 20 30 150 RW1-3 Radwaste Demineralizer 30 50 40 50 150 RW1-4 Concentrated Waste Tanks 50 50 20 50 200 RW1-5 Resin Disposal Tank 50 50 40 50 200 RW1-6 Upper Elevation - RWB 0 25 10 30 100 RW1-7 Packaged Radwaste Storage Bldg 0 0 10 0, 100 RWl-8 Low Level Waste Storage Bldg 0 0 10 0 100 RW1-9 SolidWaste Vault 10 25 20 30 100 YD1-1 Main Transformers 0 0 0 0 100 YD1-2 CCW Heat Exchangers/Pumps 0 25 10 30 100 YD1-5 Intake Structure 0 0 10 30 100 YD2-1 Stack - Elev 0'0" .10 25 10 30 150 YD2-2 Stack - Elev. 12'0" 10 25 10 30 100 YD2-3 Stack - Elev. 26'0" 10 25 10 30 100 YD2-4 Condensate/Demin Water Storage Tank 0 25 10 30 150 YD2-5 Plant Exhaust Fans 25 50 20 30 150 YD2-6 Gaseous Radwaste Holdup Tunnel 30 50 40 50 150 HMS1-1 HMS Decon Area 0 25 10 30 100 HMS1-2 Calibration Lab 10 25 20 30 100 TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604.002,Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix A, Page 4 of 4 APPENDIXA WORK DIFFICULTY FACTOR ADJUSTMENT (continued)

Respiratory Protective Alpha AREA AREA DESCRIPTION Access Protection ALARA clothing Adjust.

OTS-1 Hydrogen Analyzer/MCC #14 0 0 0 0 100 OTS-2 Moisture Skid/Sump Pump 0 0 0 0 100 OTS-3 Jet Compressor/Recombiner/Carbon Guard 0 0 0 0 100 OTS-4 Carbon Adsorbers 0 0 0 0 100 OTS-5 Pipe Tunnel 25 50 20 30 150 OTS-6 HEPA Filter (outside access only) 0 0 0 0 100 YARD General Yard 0 0 0 0 100 RBP Refueling Building - Embedded Piping 10 50 20 30 150 TBP Turbine Building - Embedded Piping 25 50 20 30 150 YDP Buried Yard Piping/Catch Basins, Etc. 20 0 0 0 100 RWP Radwaste Building - Embedded Piping 10 50 20 30 150 HMSP Hot Machine Shop - Embedded Piping 10 50 20 30 150 TLG Services, Inc.

)

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix B, Page 1 of 4 APPENDIX B UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix B, Page2 of 4 APPENDIX B 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 Description Critical Duration (minutes)

Install contamination controls, remove insulation, and mount pipe cutters 60 Foam pipe 15 Disconnect inlet and outlet lines, cap openings 60 Rig for removal 30 Unbolt from mounts 30 Remove contamination controls 15 Remove heat exchanger, wrap in plastic, and send to packing area 60 Critical Duration 270 Work Adjustments (Work Difficulty Factors)

+Duration adjustment(s)

Area-specific alpha adjustment (50% of Critical Duration) 135 405

+ Respiratory Protection (25% of Critical Duration) 101

+ RadiationlALARA (10% of Critical Duration) 41 Adjusted Work Duration 547

+ Protective Clothing (30% of Adjusted Work Duration) 164 Productive Work Duration 711

+ Work break adjustment (8.33 % of Productive Work Duration) 59 Total Work Duration 770

• Total Work Duration = 770 minutes or 12.833 hours0.00964 days <br />0.231 hours <br />0.00138 weeks <br />3.169565e-4 months <br />

• TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix B, Page3 of 4 APPENDIX B (continued)

3. LABOR REQUIRED Crew Number Duration Rate Cost (hours) ($/hr)

Laborers 3.00 12.833 $51.54 $1,984.24 Craftsmen 2.00 12.833 $62.62 $1,607.20 Foreman 1.00 12.833 $65.45 $839.92 General Foreman 0.25 12.833 $68.59 $220.05 Fire Watch 0.05 12.833 $51.54 $33.07 Health Physics Technician 1.00 12.833 $50.45 $647.42 Total Labor Cost $5,331.90

4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs

-Portable electric band saw 1 @ $0.30/hr x 12.833 hrs {97} $3.85 Consumables/Materials Costs

-Blotting paper 50 @ $0.60 sq ft {2} $30.00

-Plastic sheets/bags 50 @ $0.18/sq ft {3} $9.00

-Band Saw blades 1 @ $8.92/hr x .25/ hr {1} $2.23

-Foam sealant .7 @ $31.92 ! cubic foot {99} 22.34 Subtotal Cost Of Equipment And Materials $67.42 Overhead & Sales Tax On Equipment And Materials @ 17.25% $11.63 Total Costs, Equipment & Material $79.05 TOTAL COST: Removal of Contaminated Heat Exchanger <3000 Pounds:

$5,410.95 Total Labor Cost: $5,331.90 Total Equipment/Material Costs: $79.05 Total Craft Labor Man-Hours Required Per Unit: 93.68 TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix B, Page 4 of 4 APPENDIX B (continued)

5. NOTES AND REFERENCES

• Work difficulty factors were developed in conjunction with the AIF (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. The Wachs Companies, Quote dated 8/2008

2. McMaster-Carr website on-line catalog

3. R.S. Means (2008) Division 015 Section 602-0200 pg 17

• Material and consumable costs were adjusted using the regional indices for Eureka, California.

TLG Services, Inc.

HumboldtBay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix C, Page 1 of 7 APPENDIX C UNIT COST FACTOR LISTING (Representative)

TLG Services, Inc.

HumboldtBay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix C, Page 2 of 7 APPENDIX C UNIT COST FACTOR LISTING (Representative)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.55 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 5.94 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 8.40 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 16.16 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 22.74 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 32.51 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 51.34 Removal of clean pipe >36 inches diameter, $/linear foot 62.64 Removal of clean valve >2 to 4 inches 107.37 Removal of clean valve >4 to 8 inches 161.59 Removal of clean valve >8 to 14 inches 227.42 Removal of clean valve >14 to 20 inches 325.10 Removal of clean valve >20 to 36 inches 513.38 Removal of clean valve >36 inches 626.43 Removal of clean pipe hanger for small bore piping 35.52 Removal of clean pipe hanger for large bore piping 130.45 Removal of clean pump, <300 pound' 270.78 pump, 300-1000 pound 747.95 Removal of clean Removal of clean pump, 1000-10,000 pound 2,975.45 Removal of clean pump, >10,000 pound 5,748.35 Removal of clean pump motor, 300-1000 pound 314.65 Removal of clean pump motor, 1000-10,000 pound 1,239.21; Removal of clean pump motor, >10,000 pound 2,788.21 Removal of clean heat exchanger <3000 pound 1,594.28 Removal of clean heat exchanger >3000 pound 4,004.79 TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix C, Page 3 of 7 APPENDIX C (continued)

Unit Cost Factor CostlUnit($)

Removal of clean feedwater heater/deaerator 10,067.99 Removal of clean moisture separator/reheater 20,206.49 Removal of clean tank, <300 gallons 348.54 Removal of clean tank, 300-3000 gallon 1,102.38 Removal of clean tank, >3000 gallons, $/square foot surface area 9.15 Removal of clean electrical equipment, <300 pound 148.42 Removal of clean electrical equipment, 300-1000 pound 512.28 Removal of clean electrical equipment, 1000-10,000 pound 1,024.54 Removal of clean electrical equipment, >10,000 pound 2,425.15 Removal of clean electrical transformer < 30 tons 1,684.24 Removal of clean electrical transformer > 30 tons 4,850.31 Removal of clean standby diesel generator, <100 kW 1,720.30 Removal of clean standby diesel generator, 100 kW to 1 MW 3,839.83 Removal of clean standby diesel generator, >1 MW 7,949.23 Removal of clean electrical cable tray, $/linear foot 13.83 Removal of clean electrical conduit, $/linear foot 6.04 Removal of clean mechanical equipment, <300 pound 148.42 Removal of clean mechanical equipment, 300-1000 pound 512.28 Removal of clean mechanical equipment, 1000-10,000 pound 1,024.54 Removal of clean mechanical equipment, >10,000 pound 2,425.15 Removal of clean HVAC equipment, <300 pound 148.42 Removal of clean HVAC equipment, 300-1000 pound 512.28 Removal of clean HVAC equipment, 1000-10,000 pound 1,024.54 Removal of clean HVAC equipment, >10,000 pound 2,425.15 Removal of clean HVAC ductwork, $/pound 0.58 Removal of contaminated instrument and sampling tubing, $/linear foot 1.74 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 35.75 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 46.84 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 99.14 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 164.71 TLG Services, Inc.

HumboldtBay Power Plant Unit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix C, Page 4 of 7 APPENDIX C (continued)

Unit Cost Factor Cost!Unit($)

Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 239.48 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 473.70 Removal of contaminated pipe >36 inches diameter, $/linear foot 820.49 Removal of contaminated valve >2 to 4 inches 566.35 Removal of contaminated valve >4 to 8 inches 932.37 Removal of contaminated valve >8 to 14 inches 1,601.39 Removal of contaminated valve >14 to 20 inches 2,441.90 Removal of contaminated valve >20 to 36 inches 4,691.29 Removal of contaminated valve >36 inches 8,310.16 Removal of contaminated pipe hanger for small bore piping 136.43 Removal of contaminated pipe hanger for large bore piping 444.12 Removal of contaminated pump, <300 pound 1,292.55 Removal of contaminated pump, 300-1000 pound 2,817.30 Removal of contaminated pump, 1000-10,000 pound 10,813.41 Removal of contaminated pump, >10,000 pound 26,570.44 Removal of contaminated pump motor, 300-1000 pound 1,073.11 Removal of contaminated pump motor, 1000-10,000 pound 3,315.52 Removal of contaminated pump motor, >10,000 pound 7,479.31 Removal of contaminated heat exchanger <3000 pound 5,410.95 Removal of contaminated heat exchanger >3000 pound 17,054.39 Removal of contaminated feedwater heater/deaerator 40,490.70 Removal of contaminated moisture separator/reheater 85,839.84 Removal of contaminated tank, <300 gallons 1,892.52 Removal of contaminated tank, >300 gallons, $/square foot 49.04 Removal of contaminated electrical equipment, <300 pound 863.36 Removal of contaminated electrical equipment, 300-1000 pound 2,080.09 Removal of contaminated electrical equipment, 1000-10,000 pound 4,000.50 Removal of contaminated electrical equipment, >10,000 pound 7,573.91 Removal of contaminated electrical cable tray, $/linear foot 41.74 Removal of contaminated electrical conduit, $/linear foot 18.66 TLG Services, Inc.

Humboldt Bay Power PlantUnit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix C, Page 5 of 7 APPENDIX C (continued)

Unit Cost Factor Cost/Unit($)

Removal of contaminated mechanical equipment, <300 pound 932.10 Removal of contaminated mechanical equipment, 300-1000 pound 2,229.58 Removal of contaminated mechanical equipment, 1000-10,000 pound 4,293.69 Removal of contaminated mechanical equipment, >10,000 pound 7,573.91 Removal of contaminated HVAC equipment, <300 pound 932.10 Removal of contaminated HVAC equipment, 300-1000 pound 2,229.58 Removal of contaminated HVAC equipment, 1000-10,000 pound J4,293.69 Removal of contaminated HVAC equipment, >10,000 pound 7,573.91 Removal of contaminated HVAC ductwork, $/pound 2.50 Removal/plasma arc cut of contaminated thin metal components, $/linear in. 4.49 Additional decontamination of surface by washing, $/square foot 9.29 Additional decontamination of surfaces by hydrolasing, $/square foot 39:31 Decontamination rig hook up and flush, $/ 250 foot length. 7,886.42 Chemical flush of components/systems, $/gallon 17.10 Removal of clean standard reinforced concrete, $/cubic yard 79.69 Removal of grade slab concrete, $/cubic yard 90.60 Removal of clean concrete floors, $/cubic yard 929.62 Removal of sections of clean concrete floors, $/cubic yard 3,031.35 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 114.96 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 2,447.26 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 155.74 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 3,237.70 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 1,242.24 Removal of below-grade suspended floors, $/cubic yard 218.31 Removal of clean monolithic concrete structures, $/cubic yard 2,447.78 Removal of contaminated monolithic concrete structures, $/cubic yard 2,446.51 Removal of clean foundation- concrete, $/cubic yard 2,125.41 Removal of contaminated foundation concrete, $/cubic yard 2,276.31 Explosive demolition of bulk concrete, $/cubic yard 89.89 Removal of clean hollow masonry block wall, $/cubic yard 393.67 TLG Services, Inc.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix C, Page 6 of 7 APPENDIX C (continued)

Unit Cost Factor Cost/Unit($)

Removal of contaminated hollow masonry block wall, $/cubic yard 393.67 Removal of clean solid masonry block wall, $/cubic yard 393.67 Removal of contaminated solid masonry block wall, $/cubic yard 393.67 Backfill of below-grade voids, $/cubic yard 45.00 Removal of subterranean tunnels/voids, $/linear foot 407.55 Placement of concrete for below-grade voids, $/cubic yard 201.08 Excavation of clean material, $/cubic yard 8.94 Excavation of contaminated material, $/cubic yard 47.52 Removal of clean concrete rubble (tipping fee included), $/cubic yard 41.60 Removal of containinated concrete rubble, $/cubic yard 33.26 Removal of building by volume, $/cubic foot 0.93 Removal of clean building metal siding, $/square foot 4.84 Removal of contaminated building metal siding, $/square foot 4.84 Removal of standard asphalt roofing, $/square foot 8.03 Removal of transite panels, $/square foot 7.51 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 17.46 Scabbling contaminated concrete floors, $/square foot 10.37 Scabbling contaminated concrete walls, $/square foot 24.51 Scabbling contaminated ceilings, $/square foot 83.77 Scabbling structural steel, $/square foot .7.82 Removal of clean overhead crane/monorail < 10 ton capacity 2,058.81 Removal of contaminated overhead crane/monorail < 10 ton capacity 2,058.81 Removal of clean overhead crane/monorail >10-50 ton capacity 4,936.36 Removal of contaminated overhead crane/monorail >10-50 ton capacity 4,936.36 Removalof polar crane > 50 ton capacity 18,318.72 Removal of gantry crane > 50 ton capacity 77,245.55 Removal of structural steel, $/pound 0.70 Removal of clean steel floor grating, $/square foot 15.27 Removal of contaminated steel floor grating, $/square foot 15.27 Removal of clean free standing steel liner, $/square foot 37.73 TLG Services, Inc.

HumboldtBay Power PlantUnit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix C, Page 7 of 7 APPENDIX C (continued)

Unit Cost Factor Cost/Unit($)

Removal of contaminated free standing steel liner, $/square foot 40.80 Removal of clean concrete-anchored steel liner, $/square foot 19.17 Removal of contaminated concrete-anchored steel liner, $/square foot 47.43 Placement of scaffolding in clean areas, $/square foot 29.86 Placement of scaffolding in contaminated areas, $/square foot 31.27 Landscaping with topsoil, $/acre 30,307.60 Cost of CPC B-88 LSA box & preparation for use 2,033.70 Cost of CPC B-25 LSA box & preparation for use 1,800.10 Cost of CPC B- 12V 12 gauge LSA box & preparation for use 1,764.38 Cost of CPC B- 144 LSA box & preparation for use 10,429.50 Cost of LSA drum & preparation for use 260.39 Cost of cask liner for CNSI 14 195 cask 593.81 Cost of cask liner for CNSI 8 120A cask (resins) 10,974.89 Cost of cask liner for CNSI 8 120A cask (filters) 4,017.47 Decontamination of surfaces with vacuuming, $/square foot 2.15 TLG Services, Inc.

HumboldtBay Power PlantUnit 3 Document P01-1604-002, Rev. 0 DecommissioningCost Study 2010 SAFSTOR Appendix D, Page 1 of 10 APPENDIX D HUMBOLDT BAY POWER PLANT UNIT 3 2010 SAFSTOR AREA-BY-AREA ESTIMATE TLG Services, Inc.

0n4t0n444a., Pn.na-P4nnthat4 0-71= IDt-ttOO.O0 On10, NntstsssatnsasgCastOOn4o2titOACSt02O Appendix .

Humboldt Buy Power Plant, Unit 3 2010 SAFSTOR Decommisoioning Cost Estimate

('Thousand. of 2008Dollart)

Antulo o Roy .nsea cts TrojM ts sT P t a noe T' tam L-T.

iT . = =t R idn V.s olan n A Oas B 0 a 000 P-a an1 non aonCast tsol Oonta nats Onus Onto nto nto 000 s Onst anu Ona Onu O.

.Fast Ca.- CmO.- Cast n se O..Ft.. s. tcos eot

'tool amoco Lktncnc2003Q~

ItoolDsign& LaWn 2000 - 5,302 t3O2 5,30 IoI D-tgc L&o I000 3.4 . 34 to - IcL& nw ItotI anc a Luatn20 t

Ito' - nIDLnt&Icrnta SIac --catnntton 20(

2000 1tt2 1...2 te5.

I D-I[* & -1e~n 0 - 3527 0.547 2.547 0*00 20.00 20.00 toO:SOaetoignoa.2nsntauonsJc 2000 Ca~ncOanlu.*of Vespon lc 5,720 5,7.t 1,52 1.52 OupptessiocOttanosiroo Bai ase &lOOraIns cant 1,31 W

7,93 0s'a(*oslohpnsChanceonRat1/ 786 IOsdotudal Cltacr~ nleSentaFIPC Claysutansot O 732

- - . .00 2.-'2 2,67_

IttanusOt~u3Clt OprtoCal 2 Csat toOpoa 2-,

122 Recol S Dspusal Oet atoi r ntat Ecag *~m 2,75 cRw Ie& Diaponleactor 0Water Cl3o0 D tp OoopzeenTtana 1.04 3;

Resoataatpnsal Clan0 RaontoniOats Cosa' Retonl0tosnal Con e0& C ltntterasil Osac 4.8= 4a22 8230 82X30 .8,-1 , 54,286 p3niOt 00.0000n nOg ndprepoCarationoneoan 3t2.n OAno~ auponti FaCt~etan.

PoandFtatocnLsytont ta 73 1,.2 622 451 3625 RtplaoemntcatoRadO44note Arnt,*

n c* otam* ystw 4.0 3b2-c PixtpWstyttet*petyintal~ ttt

- - .- --- tot - '31 3.50 4183 126 201 Onbn O11~

• XeaLaty nlan g Cots 3bnt 212 -POotIlstltnvetogtto TlanEqiet 761 103 21. 1218 13070 an '2 Pobotscalperaod o Ad onnl a~to os t

-b 1 De oneqpýt .4 3b32 0O0 s2ta reo3 p 1,4w6 277 173 ,1 7n22 00 suctalnPrnu3 Claterotatod t321 2- 750 1,000 003 -1too-303b0t 143 1,211 4t2t 4,.t2 P20 3bp-. sr-ios 3b4 1 - suppoi.. 14 T0, Co-oet 00-

-.. p.

flootet4OOe0 PemPt.eeit tlet 0 A- t-ttid-24

-, em. o tteeoeo4..Oes,2e, Tot.SOot, OttO TOOIOOTitO Appeo4$t. O Pogeeitef tt Appendix D Humboldt Boy Power Pious. Unit 2010 SAFSTOR Decommissioning Cost Estim.te (Thoousds of 20t8 Do.1ar.)

I I

tt 0m es R=W Stgt PiOti.S tC seit Tr-dor 00.s*

• tmet p..lng LLRW 015mM DlsoMa C=tis C eulC Tm

_y tot.

T, NR0 Lie esto 1-*

Spe-tle mog

-m- m t.

Retot o etrsssd VeO.

Vr* C..",::

I e.itt vet.e tlmC ttoV eetUICr"-C et C00l0F Bol 1U.5554*

GlTICCPredC- 0,l f Utite tnottst Mnh

-~o 3b Z-W*42 ,*epR-eO1 (1- 1=*

0040 Prepe'oittes 47 192 l9t 24 20 00 0040 701ts401ootolWge e o 4ý

.1 25 Z- I 00 10411 O tafftts~T 21 2,1*1 27 107 1,07 21113 1,0414 STtsl U~tdy1, C 1 1.219 o 2,-10 61,000 004 T0TALmPtERIO o eCOST 40 1231 7o 20,713 1 1,22 10 10.931 4.,- 23..45 23845 gg 1219 4 7 121 Re ! f Ma*E"'.~e~

• mlestetof ~=Sseemoe S 440

.51 70 014

.2 31!4.

1007

.i

- 0 1,414 2,67t 1702 2,1 1.7.2 - .242 241.00 1,.4

- 11 23 21 51 . 20 01 43a $116 U0701 211 750 12 55 MRR 2on11

-813 Re~

23~ ue al its lit 2-551P~~li 2o 21 lw 410 410 242.

41,259 2001 2 7. 310 3;0 l1,14 R2-4 3 1 131 575 7 121 - 1.U41 50,10 4001 RB34 '4 24 1.3*

V,5ý7 14 110 1,.66 -

3. - 1,014 51,34 2,516 41 4151. TB1.2 5 1 21 21 117 -25 3. .* 202 2.- . 4.1 1,513 T s- - 1,514 31 3162 1, 1 1,31 4,3.514 T M 151 T 1*

.a1.51 T3-3.1e---re 41,517 T4-1 117 20 167 3102 1,5 7 697 62 1, 5 3.2 1,815 ,1 9887 ' 711 41011 411.1 TB-I 00511eo.3 llt~lostt 1.3 12 3 141 .7 4 .64C 280 2.0 1 21 TB-1a 92 8O 34 3" 40522 101- -

4a1522 T,- 2 111 474 414 4343 2.166

• 1523 YARD 1 2 2 - 31 M -524 yDI-1cd.- are

- 78

• 1 5 T_* 4719 -5 1.2 5,.2 3,3.0 1440 14,4Q6 1,02,100 10005.

4a6 s-dw--ol u*oto o~ .gi o.N[* 151 4 i1. 6 3 242. .25.

1.1571110 01.,O0 T7G -crelm,I-.

4-llmo ýlBy Po~.. n Ui 3 A--~d, D,Pete,4 of10 Appendix D Humboldt Boy Power Plont, Unit 3 2010 SAFSTOR Decommittioning Cost Estimate (Thootod. of 2008Doll.r1) o".t" LLRW NRC t-t F Foel too Pro - Brio -lVol.*, 0urial Utyo1d I ^111i, .0- t....... t 5ing o..... ..... 04opel t., Tol o, u'.T,. AMn .1*1, ..t.. .. .... .. l .. ... ..

C .

C.. C GTCc P.o c-l. C2.0..343 I 40 I 44.Ind0 0444 4000A.-VI41 ..-l9240813c005n I .. , C.. C- C.- c.l. C C_ C.- c. F.t C. F. C C. - C. 1, 4l2.1 M44, tl1 tSu14240 g s b,Equr Re-a

a. 1.8 10 P~ole 4* APJ~oeo-eodlCotsc 4431 26 6,25! 2 Pcpey.,watt SO 1'23 1'3 104 4452 a-1-II.-oo0 alowan 26 22 11 232 U61 27 117 . 7 54 154 1l2 21 183 18 40a 41 e1 1 1111 CO, C-42435 7M6 3,152 3 152

• *44 407 1,315 1315 41430 In21111t clell 1el1 273 1,'128 1,128

.4a47 lntney tgt 11 4,

4.

- -1, 1,31 1.c 1.205 1,45

_ 0 /I1 lE*rn~t glni-n Suppot 4a2 S 675 8675 1.273 414 ISFSI Serating 2 133,43

• 412 S-u* ataff t 1,4 3,47 3341

,-* 13 0.. S.1f*s *40* 2:;77 5, 77 251,787 11324 ý3a6 11 a0 11,;70 21S,61S 4414 ,ubto4al1r24 o s 117 31514 50,143 11,05 65,515 34715 30974 2 53 392 17S 3497 440 TOTAL PRIO4 4COST C 137 9,373 1434 3. 10 1 5 3t 10034 41,011 410.3 1.931414 87.103 348304

• N04b 1.1.Re tor VsooIn04r RD.-s & .- - l ti.Rva 24,43 526 -

4 31 104 4 201 1 14 44 44 30,504 12200 534 4 407 54t 144 1406 119 90.40 22,158 0..154 13,g 66

"'!31" 20 5,404 4,09 536 4,.34 243 12,73 341.013 41,413 1,S.X 2,6.9 470 34.,9m4 27,043 14320 1,312 R-oc.10--0 14415 50114

,a 21a 237 90 6 123,326 .,3 27 117,173 544 2

401.3 R34-1 l 265 a4 7 1S1 7.4 7.4 42,705 4 Ma0 4012 3 a62 R123 45 .11t 16 171 514

,27" .303 471 I V627 Rr14 111 4 23 N8 4Z2 ,412 1124 233242 2,124 12: RW1-:

a*2 R1-6 51 1'4 4 32 144 144 174 127 5 1. 4=7 47 66211 -W1-S 1oaa~ 1 3 a 13 7S 1; 171 2 132.

Sa 57 235 2.5 277, 1 22a .. a0 500 21 72 4.28. 34,951 a3 a 6* 2a1 a81 7.4.8 1,C31 217 125. 2. 7 SI S..ota -eio4. Activty st 2443 1,95 4,51 310 14 10948 42. 14434 43,1704 .. 0,10 TLGSrlýi-s, 1.,

OsotosOsOOs,bososs-btoso ttsta --eesos ,bl-0eOO o,.

Doses ioskos OsgCoot0osot~ 0024SObObOx A- bogs lo 1t

-osstot, Appendix D0 Humboldt Bay Power Plont, Unit 3 2010 SAFSTOR Decoomissioning Cost Eotimote (Thsoeooods of 2008D.olls.)

o0""0t LLRW NRC Sptt Fool Wit. p.100. BP.l-tolul Buttlt t sInd AfltOs¢l~ons 00 CsoStoOse* tests tegs Cotso tests Ctest totlsnOs sos ts ools toots tootsC. Foot to. boot Cu.Fbot 02. FosStoC.Foee Ot.,Lbs. ObshotnorOhnhooss 01 2 a 4 74 . 04 34

.b22 A-btIe -al . . . .. 28- 4 3.

It 2 3 ~ ar-I WatepakgngLy-nAe 021 01 01 1 17556 85 bolos40AssOdonet0t Costs 40421 Coosrsopprs 21C 40.0 oaleioq.txxo - 10 - 4 52 210 5l0 70501 11 4b0731 ots -ls110...s 12,581 55 31 73 la 685 75 314 314 210 404 32 sto01oalolowane 40.44ft C.1 00 12o0 5 40.46 Ospoolateldoogotoo 475 4 01, 514 012 040 70 4 130 104 It 413 It4a ls H

LeanstpltCo 1,822 585a 2,4. 2- )

It 4a D_- y uple -dl - 2:26'1 --

403 tsool rl00F llteoot t 72 2,-7 2:'aa a 3 65 - 211 .72 a72 1051 17 no42 107140000 ot 273 3 325 32 It1 4043 ~ooetoybseosotoax*

EI t ~nngSp osO~o

.'122' 990 152 117 2O 1,

a1 11 51'3 117

',9 171 564 19 .73 173 fb4s12 ISFSI Ope,-atngttsts t 128 2 152 12 It Ila 4004000-Pspeoo~llsogs sa-w s., "ogestated 6W It III DOC Cýf I$ 1'77,4 00415 L00 000=oot U1.1 l l 835 ,89 11,731 11:731 It I S-bttalPer->4b eod3prreCss 475 44-8 a a 52a 3a316 8,5. .,1, .5,-2 2 2587 - 0 51732 002 17 4 It, TOT-AL RIO-4bCOST .0a 12131 2a.8 7.2 1 11,N47 3697- 29 aa 3 88a. 88,01 211 2.,246 1... 470 1.112,768 070 47.4 p-*OD ft preFare Buildfings f*D-oItif 20100 1.40 8

3 3 1 15 24 ...

24 1c 24 1 0 26614,2,17 2 12 1 1.271 c1 116 HM81-

'1 7 7

.:113 TMS a41 4c:1. 1T-1 - 7 2 11 8 132 341 o 10 1]

3217 4ý1 Ie 3 1 21 15 13 13723 R1119 TS 2 7 1 .11 1417 1,*

4 11 4 50a 3 2.4 7o1 231* 199(

Q 1.114 RB1-4 5 211a 16 a 4 58 2. 21* 613 2a,14. 2,17 20 a a2 17a 695 69 34,2 4,2m 1000 024 127 7141 7 2 71 46 19 19. .07 11.592 1 12 4Z 2.15 TB11 3 1 911 47 47 9 3 2*18 8 17,6* 1 T7 1B2

• 1.1 2 2 a . 8 315 315 .:,465 2 7'10 32a

. 13 1a 5146

.*1.1.21 TT7.1 13 3 ý71

-c12a TB726 13 I1 o1 3 21 21 27 a 2 1, 13 61 131 4.

00,0502241 Be Ponsrflnst 02403 3

Owessss.,.osnr 00. 0ts4o8000 03001120 Ap-.- D, P-s 604lo Appendix D Humboldt Boy Power Plant. UnitS 2010 SAFSTOR Decommissioning Cost Estimate (F0.ousnods of 20o8Do.se.)

otofle D.oosonsRl Pock03Ing TI~seon P-1ge.

P~wssi~ln tlspei 00,.R T.ol Tal l-..T.

CT:: Sn r, R- Vol-. Cl1asA C- BOeClssC TCfc Prsw-- c-0 tostraw m 03 sow ton tonto Cor 0 Cx Cn two c-- Coo tl to. ts- t. t . FC C t..

C.. t C.F.s C.. F1. 0, Lft. m.ot. shoen 13 1 221 1,- 1,2 2 13 ,0 .

1 - 4,212 113 a 31 114 1 S3115 047 Ot 2 1 133 Y21 1 1.32 8 0* .128 TolagI lwl I anolnl 42502 1.034 0110 YDllI 15 278 1.;17 1,17ý 57 9 2,95 - .30 4I 1I Yll 3 5 1.- 7o 735" o - 31402 1,015 78 - 0 620 40,707

- 12,387 9*,5N -41 0 3 2 43 116

• 53 132S 2,.3 4~ 25 4 1 18 11 - 05201 0015 542 18.0 3 1 10.. 8.317 0.317 022123 COss 200 0 1 .3 1542 W l.01 6'.01 ,2,.

7 35 51 214 214 41700 1,02 7 3 le1512 1,200 T4*

g 19 4 3 12 11 47 7 1-5.411.4 188 22 1,280 810 2,3 2.U40 - 247,027 7,030

%.7 2 1 129 R*,n 3= 02 15 10 2S,620 1210 11 705 57 270 22

.93 1,54 47.

711 91 .1 85 33,97 3,0

.1 14,628 1,221 57 4 3 12 29 12 24 1369- 1,.

4=313* TB7 4o 179 7 e. 313 sr 2 .3 T

021.3.17 3 2 11 47 1,12 1. 7315 48 .1 041 0.0*19 CYt 1,1 511 S'3 27-O v 00 43 47,-3

2. -024 150,02

.83 14035. 8187 23 20833. 11,0,787 2.024 0453 T-1. M0e1 1,10e

.87 1,7 438 1,22 1,22 2.433 170,254 2,11 191 1,100 1,100 4c5 R=~a o13 ol al-11f~ 41. 140 0.101 0,101 24,1* 2210,C 4:'~l 14 14,72 43.0 43.0 27 Ol&Co meSog.

&o..t* Fac,l,ty 2,51 '44. 1 - 47.

3.30 220 125 8,303 30,024 12,822 15,20.00 82034

=0 !16.

S 11,354 08 S32 llt al

• 7 :4 31 0 1,31 1,701 2ý 17. Z 344 1,2- ,732

&43 x &rp, 4.44 Heýl phy..**plm

,a* 124 '24 4c4ý H-a -- etý, na TOWOeeoo, 102.

llumtold tay P plonAUnt4 u- -.. eaa poaltt-aggd-.,

tac 0 Jgoeeaasiesiasg class tudy201ttAFSgOt Appe-di lAPage 7Wo 10 Appendix D Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR DecommissioningCtcEstimate fThoosandsol 2008Dollars)

I ý-.1 Cost

-ot Costs Cses oRgi Poste TT-t'na isosa ts On., onnn a cT sas Lts analFt Ct.-

ots Costs V

c. tF..t A

F lB CPt C Cu. 0 GTCC Ptoil

- Wt.ss.

M -t C

O ntratrd Manhotrs N ý Aý .o- ý,A-et -o.t (--~d) 4,46 Dt Idc - -AWeerated iMl 3

_4 "NRe- 9 4c4 E _t "Te"bncge 14 1 4 154 44410 Elirco-laEtg cEn S-gcSupport .2 2 134. 21 111 114

,*411 RaaStegpR-n9 ER-IpJnUe 371 12 "17 -4 404 12 SF5 t "Cect foCo ss SS 1IS 0 101 IS,1 62 28 4283 44414 coccsost

- 1104428 414 4 s-1~a TOTAL PERIOD 4~i*,*e~cDed*Ct 44COST 5 127 1 1 ~

ic o rc 1415.757 22 131.0 2,217 3,7t7 543 31.-7 2M,274 2 .2 7,1 97,181 ..043 214444 PERIOtD -- g40 aselte Osdnos.casrsdaa A411' C'dastnatd EqStpatStase 7 1o 42

• 1 2 G.- S-ck S2 .31 1 347 44 1457444 ' 10.175 t2 2256 24 0.441 ASA 4-1.3 emcanhs Soa Caliratioc 95 7. 4.41 43047 A571,1 4414 N- On I41 .. t 3 163 51687

14. g97 2 -0 42 4.02 4.02 2847.575 1322

-1 1,247 84, 71 t94S,511 3,112 4 24 1,514 153 153 110,067 3

',22 1S65 10,375 10,376 74c0292 1.S74 1,181 141£ 4.03 20,015 5.26ý2 32,962 32,SS2 2.,832.536 71.70 I4c21 P Ocacel ftT1 OA t to IlA1 42 S -brl ec 4, Add-I

• Cost 281 1ý741 44415 RmeaalttstegTaceet 2 11 1

.42 P-opcrI ax0 Aý43 ý lýphycA*upW- 18 1.154 1.14

.4 44 HeISequirl M.1e~a 1 4eod4143

_45 -P-1 Costs Cllatel .f -A-~re Aý4S PSar uOt

-ey 4d4 R E rgn Pln gFe E-44 ý~~aP - 1 Englnnng uppo 7014 1 11W 1587 39 441 ISFSI OPra.ir -ot Aý41 Sýrt I-,= Stf -

14044 4,044 1431 1241 11052" 4414 utly SsITaco 17 .*0 7.7.c 410,244 A, 0 TOTAL RERID 44COST 1l4. 1,1. 4.3 20,174 144051 IA044 1446 1,1745 1,74142 44440314 7,-cc S.0241 TLGterce, aIe.

ThonOoOdO Oa,Po.aooPtoo,0 CoolS Olooonnmmong Pool 0004, 1010 0A000000 toenool'0.0t00-00Ow0 Appendix D Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR Decommissioning Coot Estimote (Thoostd, of 2008Dollar.)

Off-.*l

~r *NRC LLRW C400 T= l to U= .

5gn Fe-~ *gl~

t olnroto

• Pr..

I Vu Cý.sA B.-rvI.olu C*rSB BooC . C-SC

- GTCC P.-

. Co~o l!Iu In..-l C,*

-:1.

C

-fty -d 1

• n cktn l~*T~s P 00411.g T~alT= ce...

I = A-, -p-081.1 tOItSm lorl*no00l 151 2 1.0 18 12 Te= -"*ns Oi su000.'P01d 0.ACo0y Coo. 151 29 1.. 10 0.21 L000 Te10rr010n totoy (oapeoO & oqt.pmtoO

.00iltno 125 200 0.004 1.004 1003 010 1.004 1.0.0 "031 tOOt 100000n 0p00ses 1,430 077 1,713 1,710 1,430 077 1,7101.110 leoSwo.erCot00-oooo0l c0oo1 4,41 3

-842 1-'qe t...

o 2 152

.44 D- dRCWe

23. 30 273 34 4

.oA0ý

.A4 -,t00.'1000. s9000IFS C s-ran 12"4 3- 1 2s

0. 10sS m0r110. -O 00.

0 2,1.2 0528

-11 m smbttaPI,* e**cpnetC 1,457 A1 1.271 0-.. .0 R.0l.,-F~ot.. 1 0 34010 s'. I6 ss 714 74,0 Aeo 0.0 lOt -*IODAeCOsT TOTAL Ao0-00.- 192 7626 76 0.61 3,0W* 1 ý714 As 40,119 7,731 0.010 s. 74-4 1.,7. *0.== s6,.s 1,- 2 01.0 Fax re010t to 1 1.141 0.00 05401 2- 470 0.010 0...,shoe NCt 0ý.4s A.,O.0.101. I 00..00. Co.

41 155 105

2. I. 1,560 41 I9. 1 2117 2.

• . 63- 12 7 75 140 1,0.0 010 0,o00 015 100 1.107 -8 95 - 14t.

5b01 peo131 b

3b2 S-bt1otl Per-ot iina ot P-F 5bA-0 5fb* ~y 0r00n 148 14.00 103- 37s 32.4 75 384 Is6 14050 00b002 PSubtOtalPeriod 00A0,t0~Ct 0

540 00,40 P10""`1 N1.S11e 000 5l lt *1Co S a 12 s 13 2 1A Ill 1;

104 toot4 RSF01I0111 0.1 5b 45 EotlIy 00 Coo 0 n 5b46 Is'sI pftn ot 5bA7 S.* Saf Cs 1,4. 274 1,6 27,040 1b4 8 $.ISaf Cs 127 24 152 1 3C Ooeo4eoo, TI.00 0000.

tOoe.OoJOdOoeCatweCloaa CoOt Owaadmlm.Oo CooSoal,aIde0000000 A-- eAtoC PagtaflO Appendix D Humboldt Bay Power Plant, Unit3 2010 SAFSTOR Decommiosioning Cost Estimate Cflsoolaod.of 2008Dollse.)

A nRmv P-ýlng Tn--~ P.-Nl DI-w -1 T I mIo R-m*~

fo V.-m C.s ýA ClassBt Cý;ý C GTCC P. - Cr- C

-io- teal, tnt seto Falo ",aa, C Rot 0C oal lb toll Lsdoy S*lCtn a418 51i 511

.b4 S-*mPf odeeO O 2_de5 41s 2.6St z

7,54 504 TOTAL C-Rt00 5bCOST d 384 g6 14.- 1. 37.0 o 1,4Ot 3.Cl 1,1. 5,tt2 tote z.01 PFeODta-Foast,*. optoa 251 32 284 28' twa4t Platorotoemt Coett 544 NRcISF$1 F- 7m 91 SO1 S0 5ý47S Sods4 SFu*S*

C-.N tdllatattt COtae tt

.C4S DOCs.o 0 eat - 0 .00It- 0,827 I.0S, 21. .1. 1,* 14.617

.4 St 1aloogCana 12tt 2 2,401 5,-07 15047 od TOTAL P-O0 5, COST -O,.7

-14.0w 2,.-1 15t2d7

- 5,d7 pERIOD 5d Spnt Fatl aedGTCCshippina N Sr*e m AS.. R Ie

o. 1 Cutaot rActrmrlCOaS 7a59 1

11 17 3*I

4. g 51 1 to-Il 5Otetal Cpae Cm 551 toot ColC Ce- CTransfr CatopetoFoItt CoMt ~ 7 N43 Rar enrg -udge 57 44 NRC ISFSI -~ 13 51 5-05 EOrgerl -la-F.. 7 57

.47 6 ISFSI Operting s.uw .. , -t Costs 4ý 27: 1,705

.041 OC SOtol 1 2S tl 4 S--tootalProPt 21.7 I B41 2,.1 5(0 TOTAL -*ROD 5dCOST 3- 2.30. t 513 ,.07 d,70d C 17 S,.S too Otoo Patioto Cot-ter tet Coa

• 1 ISFSl I ora t 5 2 1 16 231 1e4te7 t 1et4i S  : 1. 16,19 231 147 147 116 toll SCattl al*t* 107SO d270 4.560 0

0 TOOCaalna la

00504445On, No.0450' 04552 Oeo.o...loose Os's 050430050030510030 Apee-is, Pý -fs(O Appendi. D Humboldt Boy Power Plant, Unit3 2010 SAFSTOR Decommissioning Cost Estimate (Th.osad. of 3008D.o.,s) 05-560t ILS.O NtC spset FueI so pr.5$45 Sut olo Oso,.rSlO

• I Utleysd l N"'s Tm n - I t Ie -R -o V-.u a ClassA C-ss . C-vc

- GCC f

t s 0 t mia RearR= P.=klig TTansf P~sn Crn zz'"C DisI 1.Cnn, C,

• oss CSS CS Cu.F.t C.. -ee Cu.F.t Cu.F* CG..TFCtC LX.= Znhour cn

.uny.......

I A=......

Nsow5. Peod-0pe Coss 26 5s42 e*op.Iyas 50043 Heasy e0ipeee1100. 118 23 141 141 5044 P* *wrlo024001 5 45 u17108500os 17.M0 17 21 21 170 6027 0l1.1y51.500t 57 15 114 114 5.4 SubtIal-.ero 5. P-rio-.p8r515n l1e - ,014 216 1007 - - - 10,210 5e0 TOTAL PER-O5, COST 124 10 2181 047 2,n4 2,764 lie 10,370 1,270 21,7"0 270 - - 2003 10 NAs.00aor 270 0.620 SF .o 3

5342 etopta *ely r Aos.. O* 3 1 3 513 e50d 5f 1ut57t0l trl 3 5425 Ipeoy Oaf Os 12- 7ý- 7ý S.7 p 51$*TL 11 1 12 12 54 1. 7:4

.1 See 19 3 1.17.

510 TOTAL 410.RI25 e5154-OST enl 334 04 I it 110 1701 . 3 3 2.... 10.340 TOA COSTOTA-100MISSCOSN 514 1,750 21,4 4r, 2.415 6,127 22,301 34 - 515 3 e 17 27e.50 20 2784009 Z214 41038 1 .8 3 0714 50- 71407 271.402 83,50 .75 421.241 7e..7 1,871 0433 e6.23 7 3,0.3 50 17 44053532 -005 0243.02 TOTAL COST TODECOM-*ONW N CONTIGN-Cy: -W,769 ua, dolar OTAL NRC LICEN$*S5 TEMAION COST O$s a 0 U&sOt O1 401 041 0 do,0 P -n 0NAG0T8 COST It 15.^ -t 507 O s a 2 sot.

NONINUCL0AR tEMO1T.ON COST 14Q OR:

5% 1.871 4560d01o1.

TOTAL C-s A0AD0STSVOLUM BURR: M5,237C-bt F5.8 TOTAL C-~s B& CRA-WST VOLUW* BUMISI: 3,W4 C-* F-TOTAL GREATR THN CUMCRA- WILUMGERR 17 Cu.4© Feet 050TAL 50" LRommBOR R 01U0T0 200 ,6 040

08. 1104C1. 1710t 00=

a800.5 0erl0118 8548011or 858a1n05 50751 81.34 e. 1 T:8 8-4301s043 000500

.. X-. 01- T. 5015I,-

TOOCaes4saa, 'so.

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002,Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix E, Page 1 of 2 APPENDIX E HUMBOLDT BAY POWER PLANT UNIT 3 2010 SAFSTOR CPUC COST DISALLOWANCES TLG Services, Inc.

t*o'ooooonog CodRebot.m201000007TOR A0704.0 Pes-loft Appendit E Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR CPUC COST DISALLOWANCES

('llhousads of 2108Doll.rs)

ItAoft ton, n vono P~okoaIg FrostoT Io Potoosg Ottpoog 070.t Cool toto Ut.NRC Coit ".tFo tonagor0 Si.

tReooooo Po .

000,00 ¢OasA-to¢lsS l 00-0 Bto Coot 0700 ItUl-Pooo... toO 00,00 I Aooto.ooto odo oa. ot -o., too ot 00 000Ot Co ot 00 to t.-

V0 Coo0.Fn oCot. t- Coo t 4C 0 O tooi too Omo.1 at000 Ooo UOOo 17 85 20 17,.04 I 41t

28. 20 17.-4 1,72 pulrtAAtol.0t.lOapn~iod-ton,,:n~ot ctoot 1 3 3 43 43

-AL -T o DAC-W O

.21 1

67' TOTAltlotOS TO 50C04008O 672 1884 24 5 12.

CPUC 07OlT.DI O OCt 0 000 C 0 00Cy 0750, NRC UCEN0 -MN OT 10,30 tO 0% 0 NOtN-UoLOARaDEOOOLTiO N OS0Io 220001 04014 TOTAL M-WA$TVOLUME BURIM* 5c- Fe I..~~

-OAL -RW-AOR 5P*IqT 2O5Mho

Humboldt Bay PowerPlant Unit 3 Document P01-1604-002, Rev. 0 Decommissioning Cost Study 2010 SAFSTOR Appendix F, Page1 of 2 APPENDIX F HUMBOLDT BAY 2010 SAFSTOR DECOMMISSIONING SCHEDULE TLG Services, Inc.

If.hoidI By P-w Pkr.. U~it 3 DtP01-160402-ýY R... 0 D-i..io..hg C~.4 Shtdy 2010 SAFSI'OR App.ndixF, AW.g 2 f2 HUMBOLDT BAY 2010 SAFSTOR DECOMMISSIONING SCHEDULE MLGS,-I- 1-c