L-13-287, Program for Management of Irradiated Fuel
| ML14115A301 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/24/2014 |
| From: | Lieb R FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-13-287 | |
| Download: ML14115A301 (108) | |
Text
{{#Wiki_filter:FENOC' 5501 North State Route 2 Oak Harbor, Ohio 43449 FirstEnergy Nuclear Operating Company Raymond A. Lieb 419-321-7676 Vice President, Nuclear Fax: 419-321-7582 April 24, 2014 L-13-287 10 CFR 50.54(bb) 10 CFR 72.218 10 CFR 50. 75(f)(3) ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Program for Management of Irradiated Fuel In accordance with 10 CFR 50.54(bb), FirstEnergy Nuclear Operating Company (FENOC) hereby submits Attachment 1, the Program for Management of Irradiated Fuel for the Davis-Besse Nuclear Power Station (DBNPS), for review and preliminary approval. FENOC, in accordance with 10 CFR 50. 75(f)(3), submitted a decommissioning cost estimate (DCE) for DBNPS to the NRC by letter dated August 22, 2013 (Accession No. ML13247A054). The DCE was subsequently revised in December 2013. The DBNPS irradiated fuel management program is based upon the 2013 revision. The 2013 DCE revision is enclosed. The DBNPS operating license currently expires on April 22, 2017. However, FENOC does not intend on ceasing DBNPS commercial operations at that time. By correspondence dated August 27, 2010 (Accession No. ML102450565), FENOC submitted an application to the Nuclear Regulatory Commission (NRC) to extend the DBNPS operating license until 2037. Should the NRC processing of the application extend beyond April 22, 2017, FENOC intends to continue full power operations under 10 CFR 2.109(b) until such time that the NRC completes the final determination on the license extension application. Should FENOC decide not to continue commercial operations after April 22, 2017, or if the NRC
Davis-Besse Nuclear Power Station L-13-287 Page 2 does not approve the license extension, then the attached program would remain in effect. If the operating license is extended, the attached program and the regulatory commitment listed in Attachment 2 would be cancelled, and a new program would be submitted five years before the end of the extended life in accordance with 10 CFR 50.54(bb). FENOC is currently evaluating the use of SAFSTOR as another decommissioning option. If FENOC determines the use of SAFSTOR is an acceptable option, then FENOC intends to revise the DBNPS DCE in 2014. The attached DBNPS irradiated fuel management program would be revised, if warranted. FENOC acknowledges submittal of the program for management of irradiated fuel is not in accordance with the schedule requirements of 10 CFR 50.54(bb). As a result, the scheduling issue has been entered into the FENOC corrective action program. This letter contains a regulatory commitment as listed in Attachment 2. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager- Fleet Licensing, at (330) 315-6810. Sincerely, Attachments:
- 1. Program for Management of Irradiated Fuel
- 2. Regulatory Commitment List
Enclosure:
"Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," December 2013 cc: NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Utility Radiological Safety Board
Attachment 1 L-13-287 Program for Management of Irradiated Fuel Page 1 of 7
Background
Congress passed the Nuclear Waste Policy Act (NWPA) in 1982 assigning the federal government's long-standing responsibility for disposal of the irradiated nuclear fuel created by the commercial nuclear utilities to the Department of Energy (DOE). The DOE contracts with utilities for the disposal of spent nuclear fuel. The contracts incorporate an initial ranking scheme based on the age of the fuel, although the contracts also include an exchange clause, as well as providing a priority for shutdown reactors. Pursuant to 10 CFR Part 50.54(bb), the Nuclear Regulatory Commission (NRC) requires licensees to establish a program to manage and provide funding for the management of irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. This requirement is satisfied through inclusion of specific cost elements within the Davis-Besse Nuclear Power Station (DBNPS) decommissioning cost estimate (DCE). FirstEnergy Nuclear Operating Company (FENOC) provided the DCE in a letter to the NRC dated August 22, 2013 (Accession No. ML13247A054). The DCE was subsequently revised in December 2013. The irradiated fuel management program is based upon the 2013 revision. The 2013 DCE revision is enclosed. An assumption contained in both DCE revisions is that the DBNPS operating license expires on April 22, 2017, and decommissioning commences at that time. As a result, the DBNPS irradiated fuel management program uses this date throughout the program. However, FENOC does not intend on ceasing DBNPS commercial operations at that time. By correspondence dated August 27, 2010 (Accession No. ML102450565), FENOC submitted an application to the NRC to extend the DBNPS operating license until 2037. Should the NRC processing of the application extend beyond April 22, 2017, FE NOC intends to continue full power operations under 10 CFR 2.109(b) until such time that the NRC completes the final determination on the extension application. Irradiated Fuel Management Strategy The FENOC irradiated fuel management strategy is based upon the following assumptions. As stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting irradiated fuel for storage from the nation's commercial
Attachment 1 L-13-287 Page 2of7 nuclear plants beginning in 2021, with an initial focus on shutdown reactors. The DCE assumes that DBNPS will shutdown and cease operations in 2017 and that DBNPS will use this DOE storage facility. Using the rankings for irradiated fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987 and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004, DBNPS fuel would be accepted at the DOE storage facility six years after it commences operation. Therefore, the DOE would start accepting DBNPS fuel in 2026. FENOC has constructed an independent spent fuel storage installation (ISFSI) at DBNPS to support continued plant operations. Based upon the assumptions in the DCE regarding DOE performance, the ISFSI will require expansion once plant operations cease to support decommissioning operations (that is, off-load the spent fuel pool, such that the fuel handling area of the auxiliary building can be deactivated and decommissioned). The ISFSI is expected to be available to support future decommissioning operations. This will allow decommissioning to be completed and the operating license amended to release the property, exclusive of the ISFSI, for unrestricted use. The ISFSI will continue to operate until such time that the transfer of irradiated fuel to the DOE can be completed. Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided within the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFSI is complete. The spent fuel pool is expected to contain freshly discharged fuel assemblies (from the most recent refueling cycles), as well as the final reactor core at shutdown. Over the following 5 1/2 years, the assemblies would be packaged into multipurpose canisters for transfer to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling time for the final core to meet the storage requirements for decay heat. Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. The DCE assumes that the irradiated fuel has been completely removed from the site by 2056. L-13-287 Page 3 of 7 Cost Estimate The DCE for DBNPS provides the basis for the costs associated with irradiated fuel management. It was revised in 2013 to update the fuel management assumptions with costs expressed in 2010 dollars. This submittal converts those costs to 2013 dollars using a factor of 1.0685 based on the Consumer Price Index. The DCE includes the cost of operating and maintaining the spent fuel pool and the ISFSI. Pool operations are expected to continue approximately 5 1/2 years after the cessation of plant operations. ISFSI operating costs are based upon a 39 year period of operation following plant shutdown. The cost for the labor and equipment to load and transfer each irradiated fuel canister to the ISFSI from the spent fuel pool is also included. Fifty percent of this cost is used to estimate the future cost for transferring the fuel from the ISFSI into the DOE transport cask. A multi-purpose dry shielded storage canister with a horizontal, reinforced concrete storage module is used as a basis for the cost analyses. The modules are assumed to have some level of neutron-induced activation exceeding free-release limits as a result of the long-term storage of the fuel. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the DCE. The irradiated fuel management plan assumes DBNPS begins decommissioning preparations upon shutdown in 2017. Dismantlement of the plant commences in 2018 and is completed by 2024. The fuel in the spent fuel pool is moved to the ISFSI by 2022. DOE begins accepting DBNPS fuel in 2026, and this continues until 2056 when the fuel has been completely removed from the site. The ISFSI decommissioning is completed by 2057. Table 1 provides a summary of the irradiated fuel management activities contained in the DCE. The table provides the decommissioning period associated with the irradiated fuel program, the activity, cost estimates, and the approximate duration of the activity. L-13-287 Page 4 of 7 Table 1 Decommissioning Decommissioning Irradiated Fuel Approximate Period 1 Activity 1 Management Duration (thousands, 2013 (months) 1*2 dollars )2 *3 *4 1 Transition and 23,474 18 Preparation 2 Decommissioning 104,521 65 3b Site Restoration 25,098 26 3c and 3d Fuel Storage 215,929 371 Operations and Shipping 3e and 3f ISFSI 4,640 7 Decontamination/Site Restoration Total 373,662 NIA Notes:
- 1. "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," December 2013, Figure 4.2, "Decommissioning Timeline (not to scale)."
- 2. "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," December 2013, Table C, "Detailed Cost Analysis."
- 3. A Consumer Price Index factor of 1.0685 was used to convert the costs from 2010 to 2013 dollars.
- 4. Values were rounded.
Table 2 provides an expenditure summary for the irradiated fuel program. Table 2 1*2 *3.4 Year Expenditure 2017 7,426 2018 21,653 2019 29,229 2020 25,502 2021 24,082 2022 19,551 2023 458 2024 9,400 2025 11,595 2026 8,299 L-13-287 Page 5 of 7 Table 2 (continued) 2027 6,431 2028 6,449 2029 6,431 2030 6,431 2031 8,198 2032 7,281 2033 6,431 2034 7,264 2035 7,200 2036 7,178 2037 7,212 2038 7,238 2039 7,405 2040 7,447 2041 6,457 2042 7,430 2043 7,430 2044 7,371 2045 7,046 2046 7,046 2047 7,046 2048 7,064 2049 7,046 2050 7,046 2051 7,046 2052 7,064 2053 7,046 2054 7,046 2055 7,046 2056 7,000 2057 4,639 Total 373,660 Notes:
- 1. "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station,"
December 2013, Table 3.3, "Davis-Besse Nuclear Power Station Schedule Of Spent Fuel Management Expenditures (thousands, 2010 dollars)."
- 2. A Consumer Price Index factor of 1.0685 was used to convert the costs from 2010 to 2013 dollars.
- 3. Values were rounded.
- 4. Values are in thousands of dollars.
Attachment 1 L-13-287 Page 6 of 7 Funding The extended irradiated fuel management costs in the DBNPS irradiated fuel management program are caused by the DOE's failure to pick up the irradiated fuel in accordance with the DOE contract. If the DOE was performing in accordance with its legal obligations, these irradiated fuel management costs would not be incurred. The DOE will have to comply with its contractual obligation, either through actual performance or through damage payments. Courts have held the DOE legally responsible for utility costs associated with interim storage of the irradiated fuel. As a result, the FirstEnergy Nuclear Generation, LLC (FENGEN) actual expenses may be reduced by DOE payment for the costs of the interim on-site storage of such fuel. However, funding of the DBNPS irradiated fuel management program does not include any actual or expected payments from the DOE. FENGEN is the owner of DBNPS. FENGEN intends to pay for the irradiated fuel expenditures listed in Table 2 using a combination of operational income and decommissioning trust funds. FENGEN owns assets other than DBNPS, which includes the Beaver Valley Nuclear Power Station, Unit No. 1, and portions of the Beaver Valley Nuclear Power Station, Unit No. 2 and the Perry Nuclear Power Plant. FENGEN's net income for 2013 was $333 million. Adjusting this value to eliminate the contribution for DBNPS operation, the revised net income for the same period would be $198 million. Comparing this value to the largest annual DBNPS irradiated fuel management program expenditure of approximately $29.2 million, which occurs in 2019, FENGEN's expected net income would adequately cover the expense. Additionally, FENGEN has a $400 million support agreement with its parent, FirstEnergy Corp., to provide FENGEN funds deemed necessary to meet operating expenses and NRC obligations. FENGEN also possesses a parent guarantee for $4.7 million (Accession Nos. ML12352A194 and ML13169A322) to support the decommissioning of the DBNPS ISFSI. The Perry Nuclear Power Plant operating license expires on March 18, 2026; the Beaver Valley Power Station, Unit No. 1 operating license expires on January 29, 2036; and the Beaver Valley Power Station, Unit No. 2 operating license expires in on May 27, 2047. The income for FENGEN will decrease as the plants cease commercial operations. Additionally, the $400 million support agreement will end in when the last FENGEN plant ceases commercial operation. FENGEN will use operational income to address the DBNPS L-13-287 Page 7 of 7 irradiated fuel management program expenditures through 2035. To ensure adequate funds are available for the irradiated fuel management program beyond 2035, FENGEN commits to depositing $123 million into the DBNPS decommissioning trust fund by 2026. These funds will then be available for use by the DBNPS irradiated fuel management program in 2036 and beyond, when the Perry Nuclear Power Plant and the Beaver Valley Power Station, Unit No. 1 will no longer be providing income for FENGEN. The $123 million will provide assurance that funds will be available for the DBNPS irradiated fuel management program as the FENGEN plants cease commercial operations. FENOC intends to submit exemptions, in accordance with 10 CFR 50.12, from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the trust fund to support the irradiated fuel program expenditures commencing in 2036. Since FENOC annually reports the status of the DBNPS decommissioning trust, FENOC will make any adjustments, as needed, to ensure the adequacy of the trust for use in irradiated fuel management.
Attachment 2 L-13-287 Regulatory Commitment List Page 1 of 1 The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for the Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in this submittal represent intended or planned actions by FENOC. They are described only as information and are not Regulatory Commitments. Please notify Mr. Thomas A. Lentz, Manager- Fleet Licensing, at (330) 315-6810 of any questions regarding this document or associated Regulatory Commitment. Regulatory Commitment Due Date
- 1. FENGEN (FirstEnergy Nuclear Generation, LLC) commits December 31, 2025 to depositing $123 million into the DBNPS decommissioning trust fund by 2026.
Enclosure L-13-287 "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," December 2013 (97 pages follow)
Document F07-1619-004, Rev. 2 I DECOMMISSIONING COST ANALYSIS for the DAVIS-BESSE NUCLEAR POWER STATION prepared for FirstEnergy Corp. prepared by TLG Services, Inc. Bridgewater, Connecticut December 2013
Daui*Besse Nuclear Power Station Document F07-1619-004, Reu. 2 D ecom.rnissioning Cost An alysi s Page ii of xvi APPROVALS Project Manager Project Engineer rcJq"ls Technical Manager William A. Cloutier, J TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F0 7-I 619-004,Reu. 2 D ecomrnissioning Cost An aly sis Page iii of xui TABLE OF CONTENTS SECTION PAGE EXECUTIVE
SUMMARY
vi-xvr
- 1. INTRODUCTION .......... 1-1 1.1 Objectivesof Study .......1-1 I.2 Site Description. .. 1-1 1.3 RegulatoryGuidance ...........I-2 1.3.1 Nuclear Waste PolicyAct. ......I-4 I.3.2 Low-LevelRadioactiveWasteActs .............l'7 1.3.3 RadiologicalCriteria for LicenseTermination...... ....1-8
- 2. DECON DECOMMISSIONING ALTERNATIVE ..........2.7 2.I Period 1 - Preparations .2-2 2.2 Period 2 - DecommissioningOperations....... ...2'4 2.3 Period 3 - Site Restoration ............2-7 2.4 ISFSI Operationsand Decommissioning........... ......2-8
- 3. COSTESTIMATE.......... ....3-1 3.1 Basisof Estimate...,. ............. 3-1 3.2 Methodology .....3-1 3.3 Financial Componentsof the Cost Model ........... 3-B 3.3.1 Contingency .......3-3 3.3.2 Financial Risk .....3-4 3.4 Site-specific Considerations. .3-6 3.4.1 Spent Fuel Management.. ...3-6 3.4.2 Reactor Vessel and Internal Components .3-8 3.4.3 Primary System Components.. ..........3-9 3.4.4 Main Turbine and Condenser.. 3-10 3.4.5 TransportationMethods........... 3-10 3 .4.6 Low-Level RadioactiveWaste Disposal....... 3-11 3.4.7 Site ConditionsFollowingDecommissioning........... ...3'L2 3.5 Assumptions ......3-13 3.5.1 EstimatingBasis.......... ....3-13 3.5.2 Labor Costs 3-13 3.5.3 Design Conditions.... 3-L4 3.5.4 General 3-14 3.6 CostEstimate Summarry. .....3-17 TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost An aly sis Page iu of xui TABLE OF CONTENTS (continued) SECTION PAGE
- 4. SCHEDULEESTIMATE ......4-L 4.I Schedule EstimateAssumptions ....-.......4-I 4.2 ProjectSchedule........... -....4-2
- 5. RADIOACTIVE WASTES..... ..........5.1
- 6. RESULTS ..........6-1
- 7. REFERENCES ..7.L TABLES Cost Summary, Decommissioning Cost Elements.... -. xvi 3.1 Scheduleof Total Annual Expenditures .....3-19 3.2 Scheduleof License Termination Expenditures ....3-2L 3.3 Scheduleof Spent Fuel Management Expenditures ....3'22 3.4 Schedule of Site Restoration Expenditures 3-24 5.1 DecommissioningWaste Summary... ..5-3 6.1 DecommissioningCost Elements... ..--...6'4 FIGURES 1.1 site Photo " 1-10 4.1 Activity Schedule.... .4-3 4.2 Decommissioning Timeline.. ..4'4 APPENDICES A. Unit Cost Factor Development .......A-1 B. Unit Cost Factor Listing ... B-1 C. Detailed CostAnalvsis....... ....C-l TLG Seruices, Inc.
DavisBesse Nuclear Power Station Document F07-1619-0M,Reu. 2 D ecomrnissioning Cost An aly sis Page u of xui REVISION LOG No. Date Item Revised Reason for Revision 0 04-15-2011 Original Issue 1 05-13-2011Executive Summary, Revised costs to include Tables3.1 - 3.4,Table 5.1, contaminated soil disposition Chapter 6, Appendix C 2 r211912013Table of Contents, Revised date of last shipment of Executive Summary, spent fuel to DOE from 2100 to Sections l - 4, Sections 6 - 2056 7, Appendix C TLG Seruices, Inc.
DauiyBesse Nuclear Power Station Docum.entF07-1619-004,Reu. 2 D ecorntnissioning Cost An aly si s Page ui of xui EXECUTIVE
SUMMARY
This report presents an estimate of the cost to decommission the Davis-Besse Nuclear Power Station (Davis-Besse), for the selected decommissioning scenario, following the currently scheduled cessation of operation. The analysis relies upon site-specific, technical information from an evaluation prepared in 2005,1Uupdated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The current estimate is designed to provide FirstEnergy Corp. (FirstEnergy) with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station. The estimate does not reflect the actual plan to decommission Davis-Besse; the plan may differ from the assumptions made in this analysis based on facts that exist at the time of decommissioning. The primary goal of the decommissioning is the removal and disposal of the contaminated systems and structures so that the operating license can be terminated. The analysis recognizes that spent fuel will be stored at the site in an independent spent fuel storage installation (ISFSI) until such time that it can be transferred to the U.S. Department of EnergSr(DOE). Consequently, the estimate also includes those costs to manage and subsequently decommission these interim storage facilities. The currently projected cost to promptly decommission the station shortly after the cessation of operations (the DECON alternative), is estimated at $955.O94million, as reported in 2010 dollars. The estimate is based on numerous fundamental assumptions, including regulatory requirements, low-Ievel radioactive waste disposal practices, high-level radioactive waste management options, project contingencies, and site restoration requirements. The estimate incorporates a minimum cooling period for the spent fuel that resides in the storage pool when operations cease. Once sufficiently cooled the spent fuel is transferred to the ISFSI for interim storage. The estimate also includes the dismantling of site structures and non-essential facilities and the limited restoration of the site. Alternatives and Resulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material so that the license can be terminated. The Nuclear Regulatory Commission (NRC) provided initial decommissioning "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," DocumentFOT-1525-003. Rev. 0. TLG Services.Inc.. October 2005 TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An alysis Page uii of xui requirements in its rule adopted on June 27, 1988.t21In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations.rr[31 SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted qss."[41 Decommissioning is to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety. ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property.r'[5]Ag with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years. The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of Iong-lived radioactive material. In 1997, the NRC directed its staff to re-evaluate this alternative and identifu the technical requirements and regulatory actions that would be necessaly for entombment to become a viable option. The resulting evaluation provided several recommendations; however, rulemaking has been deferred pending the U.S. Code of Federal Regulations,Title 10, Parts 30, 40, 50, 51, 70 and T2"General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24OLBet seq.),June 27,1988 Ibid. Page FR24022, Column 3 Ibid. Ibid. Page FR24023, Column 2 TLG Seruices, Inc.
DauisBesse Nuclear Pouter Station Docurnent F07-1619-004, Reu. 2, D ecommissioning Cost An aly si s Page uiii of xui completion of additional research studies, for example, on engineered barriers. In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants to clarifii ambiguities and codifit procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[6]The amendments allow for greater public participation and better defi,ne the transition process from operations to decommissioning. Regulatory Guide L.L84, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning process. The costs and schedulespresented in this analysis follow the general guidance and processesdescribed in the amended regulations. The format and content of the estimate is also consistent with the recommendations of Regulatory Guide I.202, issued in February 200$.tzl Methodoloe.v The methodology used to develop the estimate described within this document follows the basic approach originally presented in the cost estimating guidslinsslsl developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest available information on worker productivity in decommissioning. The estimate also reflects lessons learned from TLG's involvement in the Shippingport Station decommissioning, completed in 1989, and the decommissioning of the Cintichem reactor, hot cells and associated facilities, completed in L997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Connecticut Yankee and San Onofre- 1 nuclear units have provided additional insight into the process, the regulatory aspects, and technical challenges of decommissioning commercial nuclear units. U.S. Codeof Federal Regulations,Title 10, Parts 2,50, and 51, "Decommissioningof Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61, fu 39278 et seq.),July 29, 1996 "standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," Regulatory Guide I.202, U.S. Nuclear Regulatory Commission, February 2005 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIFA{trSP-036, May 1986 TLG Seruices, Ine.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2, D ecornmissioning Cost An aly sis Page ix of xui An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services, such as quality control and security. Continsency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope,particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur."[elThe cost elements in the estimate are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingercy, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station. Contingency funds are expected to be fully expended throughout the program. As such, inclusion of contingency is necessary to provide assurance that sufficient funding will be available to accomplish the intended tasks. Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,t101and its Amendments of 1985,tttlthe states becameultimately responsiblefor the disposition of low-Ievel radioactive waste generated within their own borders. However, with the exception of Texas (which has issued a license for a new facility), Do new compact facilities have been successfullv sited. licensed. and constructed. Until recently, there were two facilities available to FirstEnergy for the disposal of low-Ievel radioactive waste generated by Davis-Besse.As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic e Project and Cost Engineers' Handbook, SecondEdition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239. 10 "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980. 11 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986. TLG Seruices, Inc.
Davi*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost An aly sis Page x of xui Compact (comprised of the states of Connecticut, New Jersey and South Carolina). This leaves the facility in Clive, Utah, operated by EnergySolutions, 3s the only available destination for low-level radioactive waste requiring controlled disposal, until the construction of Waste Control Specialist's facility in Andrews County, Texas, is complete. For the puryose of this analysis, the EnergySolutions' facility is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A Ir21). EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel. As a proxy, the disposal cost for this material is based upon the last published rate schedule for non-compact waste for the Barnwell facility. The dismantling of the components residing closest to the reactor core generates radioactive waste that may be considered unsuitable for shallow-Iand 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. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used for spent fuel. The GTCC is disposed of in a manner similar to high-Ievel waste, at a cost equivalent to that envisioned for the spent fuel. Until a facility is available to accept the GTCC, it is stored with the spent fuel at the ISFSI. A signifi.cant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Davis-Besse reflects the savings from waste recovery/volume reduction. t2 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost Analysis Page xi of xui Hieh-Level Radioactive Waste Manaeement Congress passed the "Nuclear Waste Policy Act" (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 DOE was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made. Today, the country is at an impasse on high-level waste disposal, even with the License Application for a geologic repository submitted by the DOE to the NRC in 2008. The current administration has cut the budget for the repository prbgram while promising to "conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle ... and make recommendations for a new plan."[ls1 Towards this goal, the administration appointed a Blue Ribbon Commission on America's Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commission's charter includes a requirement that it consider "[o]ptions for safe storage of used nuclear fuel while final disposition pathways are selected and deployed."F4l On January 26, 2012, the Blue Ribbon Commission issued its "Report to the Secretary of Energy" containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are:
. "[T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage facilities"[l5l 3 "[T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear wasts."[16)
In January 2O13,the DOE issued the "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the 13 Blue Ribbon Commission on America's Nuclear Future's Charter, i-r3;lGihttp:/furc.eov/index.php?q=page/charter httn://q,ber:cemeter:v.unt.edu/alchiveflrlc/20120(i202I 14 Ibid. 15 "Blue Ribbon Commission on America's Nuclear Future, Report to the Secretary of Energy," finalreport ian2012.pdf,p.32, January http://wwrv.brc.gor'/sit,es/default/files/doctrrnt'nls/blt: 2012 16 I bid. , p .2 7 TLG Seruices, Ine.
Daui*Besse Nuclear Pouter Station Document F07-1619-004,Reu. 2 D ecorntnissioning Cost Analy si s Page xii of xui recommendations made by the Blue Ribbon Commission and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel.. ."lr7l "With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that: Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2O2I with an initial focus on accepting used nuclear fuel from shut-down reactor sites; Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and
. Makes demonstrable progress on the siting and characterization of repository sites to facilitate the availability of a geologic repository by 2049."1181 The NRC's review of DOE's license application to construct a geologic repository at Yucca Mountain was suspended in 2011 when the Administration slashed the budget for completing that work. However, the US Court of Appeals for the District of Columbia Circuit recently issued a writ of mandamus (in August 2013) ordering NRC to comply with federal law and restart its review of DOE's Yucca Mountain repository license application.
Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program had assumed that spent fuel allocations would be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.[le] FirstEnergy's current spent fuel management plan for the Davis-Bessespent fuel is based in general upon: 1) a 2O2L start date for DOE initiating transfer of commercial spent fuel to a federal facility r7 "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive W as t e ,"U .S . D O E , J a n u a ry 1 1 , 2 0 13 18 I bid. , p .2 re U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptancepriority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance.,." TLG Seruiees, Inc.
Daui*Besse Nuclear Pouter Station Document F07-1619-004,Reu. 2 Decotntnissioning Cost Analy sis Page xiii of xui ftased upon the proposed timeline for the availability of the first interim storage facility), and 2) expectations for spent fuel receipt by the DOE for the Davis-Besse fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium (N{TLI)/year, [20]and the aforementioned assumptions on spent fuel management, the spent fuel from Davis-Besse is completely removed from the site by 2056 if the unit ceasesoperating in 2017. The NRC requires that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. lzzlInterim storage of the fuel, until the DOE has completed the transfer, will be in the auxiliary building's fuel storage pool as well as at an on-site ISFSI. The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following five and one half years the assemblies are packaged into multipurpose canisters for transfer to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the storage requirements for decay heat. An ISFSI, operated under a Part 50 General License (in accordancewith 10 CFR 72, Subpart K t231), has been constructed to support continued plant operations. Spent fuel stored at the ISFSI will be transferred to the DOE once the spent fuel assemblies in the storage pool have been removed. Once the storage pool is emptied, the spent fuel pool area of the auxiliary building can be decontaminated and dismantled. FirstEnergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach becauseit insures the availability of sufficient decommissioning funds at the end of the station's life if, contrary to its contractual obligation, the DOE has not performed earlier. 20 "AcceptancePriority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 22 U.S. Code of Federal Regulations, Title 10, Part 50 - Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), "Conditions of Licenses" 23 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites." TLG Seruices, Ine.
Daui*Besse Nuclear Power Station Document F07-1619-004,Rev. 2 D ecornmissioning Cost An aly sis Page xiv of xui Site Restoration The efficient removal of the contaminated materials at the site may result in d.amage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities will substantially damage power block structures, potentially weakening the footings and structural supports. Prompt dismantling of site structures (once the facilities are decontaminated) is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process is deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force. Consequently, this study assumes that site structures are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then to be graded and stabilized. Summary The costs to decommission Davis-Besse assumes the removal of all contaminated and activated plant components and structural materials such that the owner may then have unrestricted use of the site with no further requirements for an operating license. Low-level radioactive waste, other than GTCC waste, is sent to a commercial processor for treatment/conditioning or to a controlled disposal facility. Decommissioning is accomplished within the 60-year period required by current NRC regulations. Throughout, and beyond, the spent fueI remains in storage at the site until such time that the transfer to a DOE facility is complete. Once emptied, the ISFSI is decommissioned. The decommissioning scenario is described in Section 2. The assumptions are presented in Section 3, along with the schedule of annual expenditures. The major cost contributors are identified in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendix C. The major cost components are also identified in the cost summary provided at the end of this section. The cost elements in the estimate are assigned to one of three subcategories: NRC License Termination, Spent FueI Management, and Site Restoration. The subcategoly "NRC License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in its financial assurance regulations (i.e., 10 CFR Part 50.75). The cost reported for this subcategoly is generally sufficient to terminate the unit's operating license, recognizing that there may be some additional cost impact from spent fuel management. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost An aly sis Page xu of xui The "Spent FueI Management" subcategory contains costs associated. with the containenzation and transfer of spent fuel from the wet storage pool to the ISFSI for interim storage, as well as the transfer of the fuel in storage at the ISFSI to the DOE. Costs are included for the operation of the storage pool and the management of the ISFSI until such time that the transfer is complete. "Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade. It should be noted that the costs assigned to these subcategories are allocations. Delegation of cost elements is for the purposes of comparison (e.g.,with NRC financial guidelines) or to permit specific financial treatment (e.g., ARO determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, oD owner may decide to remove non-contaminated structures early in the project to improve accessto highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executedas described. As noted within this document, the estimate was developed and costs are presented in 2010 dollars. As such, the estimate does not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the plant or during the decommissioning period. TLG Seruices, Inc.
Dauis-Besse Nuelear Pouer Station Document F07-1619-004,Rea. 2 D ecomrnissioning Cost An aly sis Page xvi of xui COST
SUMMARY
DECOMMISSIONING COST ELEMENTS (thousandsof 2010dollars) Cost Element Decontamination Removal r22,605 Bsstesstg- 16,307 Transportation Waste Disnosal _Qff S$eILApL"__P rocess_i I g-" **2_0,822 rsltalnsetles!ql
$per'Jqltql PqeJl,p,o-let"'-q-q 1r,477 Spss!qge*l ggFsl R-u lels4I!]l 167.003 Insurance and Regulatory Fees 27.3r9 Ene 16.243 Charactertzatton and Licensing Surveys ** L7.543 Miscellaneous Equipment Site O&M \IAW Concorate A&G 22,394 Q1hg1 tal 1,203 Total t41 955,O94 Cost Element NRC Li"""r" f"i'*ination 530.343 fusnffisel-YI"-?-+?s-ne+-! 349,706 Site Restoration 75,O45 955.094 tu Includes engineering costs l2l Excludes program management costs (staffrng) but includes costs for spent fuel loading/transfer'/spent fuel pool O&M and EP fees t31 Disposal of clean asbestoscontaining materials, e.g., from the cooling tower t4l Columns may not add due to rounding TLG Seruices, Ine.
Dauis-Besse Nuclear Power Station Document F07-1619-004, Reu. 2 D ecommissioning Cost An aly sis Section 7, Page I of 10 I. INTRODUCTION This report presents an estimate of the costs to d.ecommissionthe Davis-Besse Nuclear Power Station @avis-Besse) following the currently scheduled cessation of station operations. The analysis relies upon site-specific,technical information from an earlier evaluation prepared in 2005,[U.qpflated to reflect current assumptions pertaining to the disposition of the nuclear station and relevant industry experience in undertaking such projects. The current estimate is designed to provide FirstEnergy Corp. (FirstEnergy) with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that wiII be required to carry out the decommissioning. 1.1 OBJECTIVES OF STUDY The objectives of this study are to prepare a comprehensive estimate of the cost to decommission Davis-Besse, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities. The operating license for the nuclear unit was issued on April 22, 1977. An application for license renewal was filed on August 30,2010 to permit operations up to 60 years. However, for purposes of this analysis, Davis-Besse is assumed to ceaseoperations on April 22, 2017, after approximately 40 years. L.2 SITE DESCRIPTION The Davis-Besse is site located on the southwestern shore of Lake Erie in Ottawa County, Ohio (Figure 1). The City of Toledo is located approximately 2O miles to the west of the power station. The Bechtel Corporation and its affiliate, the Bechtel Company, provided architectural engineering services for the station design and construction management services for the plant construction. The Nuclear Steam Supply System (NSSS) consists of a pressurrzed water reactor and a two-loop Reactor Coolant System (RCS), supplied by the Babcock and Wilcox Company. Following a L.63% power uprate in 2008, the generating unit has a reference core design of 2,817 MWt (megawatts-thermal). This corresponds to a net design electrical output of 908 MWe (megawatts-electric) Referencesprovided in Section 7 of the document TLG Seruices, Inc.
Daui*Besse Nuclear Pouter Stqtion Document F07-1619-004,Reu. 2 D ecornmissioning Cost An aly si s Section 7, Page 2 of 10 and maximum dependable net electrical capacity of 894 MWe, with the reactor at rated power. The RCS is comprised of the reactor vessel and two heat transfer loops, each containing a vertical once-through steam generator, and two shaft sealed coolant-circulating pumps. In addition, the system includes an electrically heated pressurrzer, a pressurrzer relief tank, and interconnecting piping. The system is housed within a free-standing, steel-shell containment, which is Iocated within a separate reinforced concrete shield building. The concrete shield building consists of an upright cylinder topped with a hemispherical dome, supported on a reinforced concrete foundation mat that is keyed into sound rock. Heat produced in the reactor is converted to electrical energy by the steam and power conversion system. A turbine-generator system converts the thermal energy of steam produced in the steam generators into mechanical shaft power and then into electrical energy. The unit turbine-generator is a General Electric 1800-rpm, M-7 design tandem-compound unit. It consists of a double-flow, high-pressure section, and two double-flow low-pressure sections. The turbine provides the extraction steam for six stages of feedwater heating and two steam generator feed pump turbines. Steam leaving the high-pressure turbine is passed through two moisture separator units (in parallel) where the steam is dried and reheated. The steam then enters the two low-pressure turbines. The condenser circulating water system is sized to handle the maximum condenser heat loads and consists of a closed system utilizing a hyperbolic natural draft cooling tower and the associated circulating water pumps, piping and valves. FiII and makeup water is taken from Lake Erie through the intake water system and intake structure. There are four circulating water pumps which take their suction from the cooling tower discharge channel, the water is pumped through the condenser and then back to the cooling tower. 1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.t21 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, TLG Seruices,Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu,2 D ecommissioning Cost An aly sis Section l, Page 3 of 10 the NRC issued Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"[3]which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule. The rule defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated or activated portion of the plant's systems, structures and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations. The rule also placed limits on the time allowed to complete the decommissioning process. For SAFSTOR, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient leverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the definition of decommissioning. At the conclusion of a 60-year dormancy period (or longer for ENTOMB if the NRC approves such a case), the site would still require significant remediation to meet the unrestricted release limits for license termination. The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with rulemaking permitting the controlled release of a site,t+l the NRC has re-evaluated this alternative. The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. 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 clari$r the use of engineered barriers for reactor entombmenfs.tsl The NRC's staff has recommended that rulemaking be deferred, based upon several factors, .g., no licensee has committed to pursuing the entombment option, and the NRC's current priorities, at least until after the additional research studies are complete. The NRC Commissioners concurred with the staff s recommendation. In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.leJ When the decommissioning TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Docurnent F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Section 7, Page 4 of 10 regulations were adopted in 1988, it was assumed that the majority of licensees would operate for their fuII licensed life. However, shortly after the regulations were enacted, 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 codifi' procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process from operations to decommissioning. Under the revised regulations, licensees will submit written certification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel. Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Within two years of submitting notice of permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequenceand 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 Policv Act Congress passed the "Nuclear Waste Policy Act" (NWPA) in LgB2,17l 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 N\ fPA Amendments Act of 1987181 designated Yucca Mountain as the sole site to be considered for a permanent geologicrepository. The DOE was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fueI from commercial generating sites has been made. Today, the country is at an impasse on high-level waste disposal, even with the License Application for a geologic repository submitted by the DOE to the NRC in 2008. The current administration has cut the budget for the repository program while promising to "conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle ... and make recommendations for a new plan." Towards this goal, the administration appointed a Blue Ribbon Commission on America's TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-0A4, Reu. 2 D ecomrnissioning Cost Analy sis Section 7, Page 5 of 10 Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. On January 26, 2012, the Blue Ribbon Commission issued its "Report to the Secretary of Energy" el containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are:
. "[T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage facilities" o "[T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear waste."
In January 2013, the DOE issued the "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel..."[1ol "With the appropriate authorizations from Congress,the Administration currently plans to implement a program over the next 10 years that: Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2O2l with an initial focus on accepting used nuclear fuel from shut-d.ownreactor sites;
. Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptanceof enough used nuclear fuel to reduce expected government liabilities; and
. Makes demonstrable progress on the siting and characterization of repository sites to facilitate the availability of a geologic repository by 2048."
The NRC's review of DOE's license application to construct a geologic repository at Yucca Mountain was suspended in ?OLI when the Administration slashed the budget for completing that work. However, the US Court of Appeals for the District of Columbia Circuit recently issued a writ of mandamus (in August 2013) ordering NRC to comply TLG Seruices, Inc.
Daui*Besse Nuclear Pouter Station Document F07-1619-004,Reu. 2 D ecomm,issioning Cost Analy sis Section 7, Page 6 of 10 with federal law and restart its review of DOE's Yucca Mountain repository license application. Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program had assumed that spent fuel allocations would be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.[ll] FirstEnergy's current spent fuel management plan for the Davis-Besse spent fuel is based in general upon: 1) a \OZL start date for DOE initiating transfer of commercial spent fuel to a federal facility ftased upon the proposed timeline for the availability of the first interim storage facility), and 2) expectations for spent fuel receipt by the DOE for the Davis-Besse fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium (MTU)/year,[12] and the aforementioned assumptions on spent fuel management, the spent fuel from Davis-Besse is completely removed from the site by 2056 if the unit ceasesoperating in 2017. The NRC requires that licensees establish a program to manage and provide funding for the caretaking of aII irradiated fuel at the reactor site until titte of the fuel is transferred to the DOE.tttl Interim storage of the fuel, until the DOE has completed the transfer, will be in the auxiliary building's storage pool as well as at an on-site ISFSI. The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following five and one half years the assemblies are packaged into multipurpose canisters for transfer to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the storage requirements for decay heat. An ISFSI, operated under a Part 50 General License (in accordancewith 10 CFR 72, Subpart K tl41),has been constructed to support continued plant operations. Spent fuel stored at the ISFSI will be transferred to the DOE once the spent fuel assemblies in the storage pool have been removed. Once the storage pools are emptied, the fuel pool area of the auxiliary building can be decontaminated and dismantled. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004'Reu. 2 D econrmissioning Cost An aly sis Section 7, Page 7 of 10 FirstEnerg"y's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach becauseit insures the availability of sufficient decommissioning funds at the end of the station's life if, contrary to its contractual obligation, the DOE has not performed earlier. I.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,ttrl and its Amendments of 1985,ttclthe states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. However, with the exception of Texas (which has issued a license for a new facility), ro new compact facilities have been successfullv sited. licensed. and constructed. Untit *u"*rrrtn, there were two facilities available to FirstEnergy for the disposal of low-level radioactive waste generated by Davis-Besse. 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, until the construction of Waste Control Specialist's facility in Andrews County, Texas, is complete. For the purpose of this analysis, the EnergySolutions' facility is used as the basis for estimating the disposal cost for the lowest level and majority of the radioactive waste (Class A t171). EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel. As a proxy, the disposal cost for this material is based upon the last published rate schedule for non-compact waste for the Barnwell facility. The dismantling of the components residing closest to the reactor core generates radioactive waste that may be considered unsuitable for shallow-Iand disposal (i.e., low-level radioactive waste with TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Section 7, Page 8 of 10 concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (Greater-than Class C or GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used for spent fuel. The GTCC is disposed of in the same manner as high-Ievel waste, at a cost equivalent to that envisioned for the spent fuel. Until a facility is available to accept the GTCC, it is stored with the spent fuel at the ISFSI. A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to Iicensed facilities for further analysis, for processing and./or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-Ievel radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys, decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Davis-Besse reflects the savings from waste recovery/volume reduction. 1.3.3 Radioloeical Criteria for License Termination In L997, the NRC published Subpart E, "Radiological Criteria for License Termination,"[1s] amending 10 CFR Part 20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excessof 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (AIARA). The decommissioning estimate assumes that the Davis-Besse site will be remediated to a residual level consistent with the NRC-prescribed level. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost An aly sis Section 7, Page I of 10 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).ttol An additional and separate limit of 4 millirem per year, as defined in 40 CFR S141.16,is applied to drinking water.[z0] 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)tztt 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 excessof 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 Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004, Reu. 2 D ecornmissioning Cost An aly sis Sectiort 7, Page 10 of 10 FIGURE 1.1 DAVIS-BESSE NUCLEAR POWER STATION SITE PHOTO
.?;
. t.r
,t r
I r l>: t M TLG Seruices, In,e.
Daui*Besse Nuelear Power Station Document F07-161g-004,Reu.2 l D ecommissioning Cost An alysi s Section 2, Page I of 8
- 2. DECON DECOMMISSIONING ALTERNATIVE A detailed cost estimate was developed to decommission Davis-Besse utilizing the approved decommissioning alternative of DECON, with the ultimate objective of the release of the site for unrestricted use.
The operating license currently expires in April 2OI7. Spent fuel, generated over the operating life of the nuclear unit, is transferred to the ISFSI so as to facilitate decontamination and dismantling activities within the fuel handling area of the auxiliary building. Spent fuel storage operations continue at the site until the transfer of the fuel to the DOE is complete, assumed to be in the year 2056. The following sections describe the basic activities associated with the DECON alternative. Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work, i.e., engineering and planning at the time of decommissioning. The DECON alternative, as defined by the NRC, is "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." This study does not address the cost to dispose of the spent fuel residing at the site; such costs are funded through a surcharge on electrical generation. However, the study does estimate the costs incurred with the interim on-site storage of the fuel pending shipment by the DOE to an off-site disposal facility. The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commenceswith the effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e., power production) to facility deactivation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee would then be prohibited from reactor operation. The second phase encompassesactivities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimate developed for Davis-Besse is also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures. TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004, Rev. 2 D ecotnrnissioning Cost An alysis Section 2, Page 2 of I 2.I PERIOD 1 - PREPARATIONS In anticipation of the cessation of plant operations, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Through implementation of a staffing transition plan, the organrzation required to manage the intended decommissioning activities is assembled from available plant staff and outside resources. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications appiicable to the operating conditions and requirements, a characterrzation of the facility and major components, and the development of the PSDAR. Ensineerins and Plannine The PSDAR, required within two years of the notice to cease operations, provides a description of the licensee's planned decommissioning activities, a timetable, and the associated financial requirements of the intended decommissioning program. Upon receipt of the PSDAR, the NRC will make the document available to the public for comment in a local hearing to be held in the vicinity of the reactor site. Ninety days following submittal and NRC receipt of the PSDAR, the licensee may begin to perform major decommissioning activities under a modified 10 CFR $50.59 procedure, i.e., without specific NRC approval. Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC, as defined by 10 CFR 56l.Major components are further defined as comprising the reactor vessel and internals, Iarge bore reactor coolant system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the $50.59 process in decommissioning. The proposed activity must not:
. forecloserelease of the site for possible unrestricted use,
. significantly increase decommissioning costs,
. cause any significant environmental impact, or
. violate the terms of the licensee'sexisting license.
Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations. The environmental impact associated with the planned decommissioning activities is also considered. Typically, u licensee will not be allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously TLG Seruices, Inc.
DauisBesse Nuclear Pouer Station Document F07-1619-004,Reu. 2 D ecornrni ssioning Cost An alysi s Seetion 2, Page 3 of 8 evaluated environmental assessmentsor impact statements. In this instance, the licensee would have to submit a license amendment for the specific activity and update the environmental report. The decommissioning program outlined in the PSDAR will be designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR S20) for protection of personnel from exposure to radiation hazards. It will also address the continued protection of the health and safety of the public and the environment during the dismantling activity. Consequently, with the development of the PSDAR, activity specifications, cost-benefit and safety analyses, and work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities. Site Preparations Following final plant shutdown, and in preparation for actual decommissioning activities, the following activities are initiated:
. Initial characterization of the site and surrounding environs. This includes radiation surveys of work areas, major components (including the reactor vessel and its internals), internal piping, and sacrificial shield cores.
. Expansion of the existing ISFSI for the interim storage of spent fuel in the fuel storage pool.
. Isolation of the spent fuel storage pool and fuel handling systems, such that decommissioning operations can commence on the balance of the plant. Decommissioning operations are scheduled around the fuel handling area of the auxiliary building to optimize the overall project schedule. The fuel is transferred to the ISFSI as it decays to the point that it meets the heat load criteria of the containers. Consequently, it is assumed that the fuel pool remains operational for approximately five and one-half years following the cessation of plant operations.
. Specification of transport and disposal requirements for activated materials and/or hazardous materials, including shielding and waste stabilization.
. Development of procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste (including dry-active waste, resins, filter media, metallic and non-metallic components generated in decommissioning), site security and emergency programs, and industrial safety.
TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecornrnissioning Cost An aly sis Section 2, Page 4 of I 2.2 PERIOD 2 - DECOMMISSIONING OPERATIONS This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR $50 operating license. Significant decommissioning activities in this phase include:
. Construction of temporary facilities and/or modification of existing facilities to support dismantling activities. This may include a centralized processing area to facilitate equipment removal and component preparations for off-site disposal.
Reconfiguration and modification of site structures and facilitres as needed to support decommissioning operations. This may include the upgrading of roads (on- and off-site) to facilitate hauling and transport. Modifications may be required to the containment structure to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the building to support the segmentation of the reactor vessel internals and component extraction. Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes,and the procurement of specialty tooling. Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages. Decontamination of components and piping systems as required to control (minimize) worker exposure. Removal of piping and components no longer essential to support decommissioning operations. I Removal of control rod drive housings and the head service structure from reactor vessel head. Segmentation of the vessel closure head. Removal and segmentation of the upper internals assemblies. Segmentation wiII maximize tlne loading of the shielded transport casks, i.e., by weight and activity. The operations are conducted under water using remotely operated tooling and contamination controls. Disassembly and segmentation of the remaining reactor internals, including the core former and lower core support assembly. Some material is expected to exceed Class C disposal requirements. As such, the segments will be packaged in modified fuel storage canisters for geologic disposal. TLG Services, Inc.
Dauis-Besse Nuclear Pouter Station Document F07-1619-004,Reu. 2 D ecornmissioning Cost An aly sis Seetion 2, Page 5 of I Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air using remotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Segments are transferred in-air to containers that are stored under water, for example, in an isolated area of the refueling canal. Removal of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressuruzer removal scenarios, those portions of the associated steam generator D-rings necessaryfor accessand component extraction are removed. Removal of the steam generators and pressurrzet for material recovery and controlled disposal. These components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized, .S., with grout. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations.
. Transfer of the spent fuel from the storage pool to the ISFSI pad for interim storage. Spent fuel storage operations continue throughout the active decommissioning period.
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 characterrzattort, 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. With the release criteria established via the approved LTP, the licensee may then commence with the final remediation of site facilities and services, including:
. Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems).
- Removal of the steel liners from the refueling canal, disposing of the activated and contaminated sections as radioactive waste. Removal of anv activated/contaminated concrete.
r Survevs of the decontaminated areas of the containment structure. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 Decommissioning Cost An aly sis Section 2, Page 6 of 8 Removal of the contaminated equipment and material from the auxiliary building, and any other contaminated facility. Use radiation and contamination control techniques until radiation surveys indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems and components ftoth clean and contaminated) located within the buildings. This activity will facilitate surface decontamination and subsequent verification surveys required prior to obtaining release for demolition. Removal of the remaining components, equipment, and plant services in support of the area release survey(s).
. Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination is released for unrestricted disposition, .g., as scrap, recycle, or general disposal. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-Ievel radioactive waste disposal facility.
Incorporated into the LTP is the Final Survey PIan. 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 O{ARSSIMT."LzzIThis document incorporates the statistical approaches to survey design and data interpretation used by the EPA. It also identifies commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the survey is complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on the requested change to the operating license (that would release the property, exclusive of the ISFSI, for unrestricted use). The NRC will amend 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. TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-0A4, Reu. 2 l Deeornmissioning Cost An alysis Section 2, Page 7 of 8 2.3 PERIOD 3 - SITE RESTORATION Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the structures. Although performed in a controlled, safe manner; blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures including the reactor and auxiliary buildings. Under certain circumstances, verifying that subsurface radionuclide concentrations meet NRC site release requirements will require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity will be necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station. Prompt dismantling of site structures is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as weII as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards. This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity. Foundations and exterior walls are removed to a nominal depth of three feet below grade. The three-foot depth allows for the placement of gravel for drainage, as weII as topsoil, so that vegetation can be established for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials. Non-contaminated concrete rubble produced by demolition activities is processed to remove rebar and miscellaneous embedments. The processed material is then used on site to backfill voids. Excess non-contaminated materials are trucked to an off-site area for disposal as construction debris. TLG Seruices, Inc.
Daui*Besse Nucleq.r Pouer Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Section 2, Page 8 of 8 2.4 ISFSI OPERATIONS AND DECOMMISSIONING The ISFSI will continue to operate under a general license (10 CFR $50) following the amendment of the operating license to release the adjacent (former power block) property. Assuming the DOE starts accepting fuel in 2OZI, transfer of spent fuel from the ISFSI is anticipated to continue through the year 2056. At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The Commission will terminate the $50 license if it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI. Spent fuel is stored on the ISFSI in multi-purpose canisters, within a horizontal storage module. For purposes of this cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, ony required decontamination performed on the module (some minor activation is assumed), and the license for the facility terminated, the concrete modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad is then removed and the area regraded. TLG Seruices, Inc.
Dauis-Besse Nuclear Pouter Station Docurnent F07-1619-004,Reu. 2 D ecornmissioning Cost An aly sis Section 3, Page I of 24
- 3. COST ESTIMATE The cost estimate prepared for decommissioning Davis-Besse considers the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimate, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.
3 . 1 BASIS OF ESTIMATE The estimate was developed using the site-specific, technical information from the 2005 analysis. This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes. 3 . 2 METHODOLOGY The methodology used to develop the estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[23] and the DOE "Decommissioning Handbos}.'r[zal These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates. The activity-dependent costs are estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures rely upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.t2sl The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, Iabor costs fty craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis. TLG Seruiees, Inc.
Davi*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 De commissioning Cost An aly sis Section 3, Page 2 of 24 This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre- 1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units. Work Difficultv Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment. WDFs are assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined, hazardous environments. The ranges used for the WDFs are as follows: Access Factor loo/oto 2oo/o Respiratory Protection Factor LO%to \jo/o Radiation/ALARA Factor LO%to 37% Protective Clothing Factor LOo/oto 3O% Work Break Factor 8.334/o The factors and their associated range of values were developed in conjunction with the AIF/NESP-036 study. The application of the factors is discussed in more detail in that publication. Schedulins Prosram Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiological controlled areas. The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is based upon productivity information available from the "Building Construction Cost Data" publication. An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ec ommi ssionin g Cost An aly si s Section 3, Page 3 of 24 engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs. 3.3 FINANCIAL COMPONENTS OF THE COST MODEL TLG's proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration. 3.3.1 Contineency Inherent in any cost estimate that does not rely on historical data is the inability to specifi' 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. 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' Handbosk"[26]as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, contingency is included. In the AIF/NESP-036 study, the types of unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station. Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Docurnent F07-1619-004,Reu. 2 D ecornnt issioning Cost An aly sis Section 3, Page 4 of 24 successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from IO% to 75o/o, 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: C Decontaminatron 50% a Contaminated Component Removal 25% I Contaminated Component Packaging I0o/o a Contaminated Component Transport $% I Low-Level Radioactive Waste Disposal 25o/o Reactor Segmentation 75% NSSS Component Removal 25% Reactor Waste Packaging 25% Reactor Waste Transport 25% Reactor Vessel Component Disposal 50% GTCC Disposal t5% a Non-Radioactive Component Removal I5o/o I Heavy Equipment and Tooling I5o/o a Supplies 25o/o I Engineering l5o/o
- Energy L5%
a Charact enzatron and Termination Survevs 30% I Construction L5% e Taxes and Fees I0o/o a Insurance LOo/o I Staffing I5o/o The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of the detailed estimate provided in Appendix C (i.e., 16.63%). 3.3.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk. TLG Seruices, Inc.
Daui*Besse Nuclear Pawer Station Document F07-1619-004,Reu. 2 D ecommissioning Cost Analy sis Section 3, Page 5 of 24 Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur. Consideration is sometimes necessary to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term "financial risk." Included within the category of financial risk are: Transition activities and costs: ancillary expenses associated with eliminating 50% to 80% of the site labor force shortly after the cessation of plant operations, added cost for worker separation packages throughout the decommissioning program, national or company-mandated retraining, and retention incentives for key personnel. Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, legal challenges, and national and local hearings. Changes in the project work scope from the baseline estimate, involving the discovery of unexpected levels of contaminants, contamination in places not previously expected, contaminated soil previously undiscovered (either radioactive or hazardous material contamination), variations in plant inventory or configuration not indicated by the as-built drawings. Regulatory changes, for example, affecting worker health and safety, site release criteria, waste transportation, and disposal. Policy decisions altering national commitments (e.9., in the ability to accommodate certain waste forms for disposition), or in the timetable for such, for example, the start and rate of acceptanceof spent fuel by the DOE. Pricing changes for basic inputs such as labor, energy, materials, and disposal. Items subject to widespread price competition (such as materials) may not show significant variation; however, others such as waste disposal could exhibit large pricing uncertainties, particularly in markets where limited accessto services is available. This cost study does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimate. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecornrnissioning Cost An aly si s Section 3, Page 6 of 24 3.4 SITE.SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method foor dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost studv. 3.4.I Spent Fuel Manasement The cost to dispose the spent fuel generated from plant operations is not reflected within the estimate to decommission Davis-Besse. Ultimate disposition of the spent fuel is within the province of the DOE's Waste Management System, as defined by the Nuclear Waste Policy Act. As such, the disposal cost is financed by a 1 mill/kWhr surcharge paid into the DOE's waste fund during operations. However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy. This funding requirement is futfilled through inclusion of certain high-level waste cost elements within the estimate. as described below. ISFSI FirstEnergy has constructed an ISFSI to permit continued plant operations (e.g., maintain full core off-load capability). Based upon the assumptions in this analysis regarding DOE performance, the ISFSI wilt need to be expanded once site operations cease to support decommissioning operations (e.g., off-Ioad the wet storage pool so that the fuel handling area of the auxiliary building can be deactivated and/or decommissioned). The ISFSI will continue to operate throughout decommissioning, and beyond, until such time that the transfer of spent fuel to the DOE can be completed. Assuming that the DOE starts accepting fuel tn 202I, the process is expected to be completed by the year 2056. Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the estimate and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided for the final disposition of the facilities once the transfer is complete. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu.2 D ecornmissioning Cost An aly si s Section 3, Page 7 of 24 Canister Desisn The spent fuel management costs included within the decommissioning estimate are based upon a horizontal dry storage cask system for long-term storage (e.g., the NUHOMS'o system). Cask capacity is assumed to be 24 spent fuel assemblies. It is also assumed that there wiII be sufficient older (and cooler) fuel in the storage pool at the time of plant shutdown to mix with the warmer, last core load that the pool can be emptied within five and one half years after shutdown (i.e., that the heat load can be managed so as not to require short-loading of the casks or a longer active cooling period). Canister Loadine and Transfer The estimate includes the cost for the labor and equipment to load and transfer each spent fuel canister to the ISFSI from the wet storage pool. For estimating purposes, 50% of this cost is used to estimate the future cost to transfer the fuel from the ISFSI into the DOE transport cask. Operations and Maintenance The estimate also includes the cost of operating and maintaining the spent fuel pool and the ISFSI, respectively. PooI operations are expected to continue approximately five and one half years after the cessation of operations. ISFSI operating costs are based upon a 39 year period of operations following shutdown. ISFSI Desisn Considerations A multi-purpose (storage and transport) dry shielded storage canister with a horizontal, reinforced concrete storage module is used as a basis for the cost analyses. The modules are assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel, i.e., to levels exceedingfree-releaselimits. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the estimate. GTCC The dismantling of the reactor internals may generate radioactive waste considered unsuitable for shallow land disposal (i.e., Iow-level radioactive waste with concentrations of radionuclides that exceed the limits established bv the NRC for Class C radioactive waste (GTCC)). TLG Seruices,Inc.
Dauis-Besse Nuclear Power Station Docurnent F07-1619-004,Reu. 2 D ecornrnissioning Cost An aly si s Section 3, Page 8 of 24 The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. Although the DOE is responsible for disposing of GTCC waste, any costs for that service have not been determined. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged and disposedof in a manner similar to high-Ievel waste, at a cost equivalent to that envisioned for the spent fuel. For purposes of this study, GTCC is packaged in the same canisters used to store spent fuel. Disposal costs are based upon 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 with the spent fuel in the ISFSI at the Davis-Bessesite. 3.4.2 Reactor Vessel and Internal Components The reactor pressure vessel and internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed in the refueling canal, where a turntable and remote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor cavity. Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology. Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites that have been decommissioned. Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel. Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (inctuding the internals). However, its location on the Columbia River simplified the transportation analysis since: TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecotnmissioning Cost Analy sis Section 3, Page I of 24 r the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport,
. there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and r transport speeds were very low, limited by the overland transport vehicle and the river barge.
As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State. The characteristics of this arid site proved favorable in demonstrating compliance with land disposal regulations. It is not known whether intact disposal (of the vessel shell or the complete vessel and internals) will be available when Davis-Besse ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition. With lower levels of activation, the vessel shell can be packaged more efficiently than the curie-limited internal components. This will allow the use of more conventional waste packages rather than shielded casks for transport (although some shielded casks are still required). 3.4.3 Primarv Svstem Components The NSSS (reactor vessel and reactor coolant system components) will be decontaminated using chemical agents prior to the start of cutting operations. A decontamination factor (average reduction) of 10 is assumed for the process. Disposal of the decontamination solution effluent is included within the estimate as a "process liquid waste" charge. The following discussion deals with the removal and disposition of the steam generators, but the techniqrles involved are also applicable to other large components, such as heat exchangers, component coolers, and the pressurizer. The steam generators' size and weight, as well as their location within the reactor building, will ultimately determine the removal strategy. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecornmissioning Cost An aly sis Section 3, Page 10 of 24 A trolley crane will be set up for the removal of the generators. It can also be used to move portions of the steam generator cubicle walls and floor slabs from the reactor building to a location where they can be decontaminated and transported to the material handling area. Interferences within the work area, such as grating, piping and other components, wiII be removed to create sufficient laydown space for processing these large components. The generators wilt be rigged for removal, disconnected from the surrounding piping and supports, and maneuvered into the open area where they will be lowered onto a dolly. Once each steam generator has been placed in the horizontal position, nozzles and other openings wiII be welded closed. The lower shell will have a carbon steel membrane welded to its outside surface for shielding, if required, during transport. The interior volume will be filled with low-density cellular concrete for stabilization of the internal contamination and to satisfii burial ground packaging requirements. When this stage has been completed, each generator will be moved out of containment and lowered onto a multi-wheeled transporter to be staged at an on-site storage area and await transport to the disposal facility. The pressuruzer will be removed using the same technique. Each component will then be loaded onto a railcar for transport to the disposal facility. 3.4.4 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled demolition. The main condensers are also disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it is surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordancewith the intended disposition. 3.4.5 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualifi' as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.1211The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart Il3.4IL) for transport unless demonstrated to qualify as their own shipping TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecomnt issioning Cost An aly si s Section 3, Page 11 of 24 containers. The reactor vessel and internal components are expected to be transported in accordancewith Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptablefor transport. A.ry fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that g0Sr, or the buildup of quantities of long-Iived isotopes (e.g., 137Cs, transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements. Transport of the highly activated.metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per shipment assumed permissible was based.upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits. The transport of large intact components (e.g., large heat exchangers and other oversized components) will be by a combination of truck, rail, and/or multi-wheeled transporter. Transportation costs for material requiring controlled disposal are based upon the mileage to the EnergySolutions facility in Clive, Utah. Transportation costs for off-site waste processing are based upon the mileage to Oak Ridge, Tennessee.Truck transport costs are estimated using published tariffs from Tri-State Motor f1'2nslf .tz8l 3.4.6 Low-Level RadioactiveWaste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptancecriteria of the disposal site) and recovery of the waste stream is performed. off site at a licensed processing center. Costs were based upon contracted rates for off-site processing. TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D econt rnissioning Cost Analy sis Section 3, Page 12 of 24 The mass of radioactive waste generated during the varrous decommissioning activities at the site is shown on a line-item basis in the detailed Appendix C and summanzed in Section 5. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, accessways, and penetrations. The volumes are calculated based.on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers. The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating d.isposal costs, the burial fees are applied against the liner volume, as weII 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. Disposal fees are based upon estimated charges, with surcharges added for the highty activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the lowest level and majority of the material generated from the decontamination and d.ismantling activities is based upon the current cost for disposal at EnergySolutions facility in Clive, Utah. Disposal costs for the higher activity waste (Class B and C) were based upon the last published rate schedule for non-compact waste for the Barnwell facility (as a proxy). 3.4.7 The NRC will terminate (or amend) the site license if it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. The NRC's involvement in the decommissioning process will end at this point. Building codes and environmental regulations will dictate the next step in the decommissioning process, as well as FirstEnergy's' own future plans for the site. Non-essential structures or buildings severely damaged in d.econtamination process are removed to a nominal depth of three feet below grade. Concrete rubble generated from demolition activities is TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004'Rea. 2 Decomnt issioning Cost An aly si s Section 3, Page 13 of 24 processed and made available as clean fill. The excavations will be regraded such that the power block area will have a final contour consistent with adjacent surroundings. The estimate assumes the remediation of approximately 60,000 cubic feet of contaminated soil, 30,000 pounds of contaminated lead, 5,500 gallons of contaminated hazardous liquid wastes, 143,000 cubic feet of contaminated asbestos, and 1,000 pounds of other contaminated hazardous materials. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria. 3.5 ASSUMPTIONS The following are the major assumptions made in the development of the estimate for decommissioning the site. 3.5.1 Estimatine Basis The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. AIARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule. 3.5.2 Labor Costs The craft labor required to decontaminate and dismantle the nuclear unit will be acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis. Costs for site administration, operations, construction, and maintenance personnel are based upon average salary information provided by FirstEnergy or from comparable industry information. FirstEnergy wilt hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. The owner will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases. Contract personnel will provide engineering services, .., for TLG Seruices, Ine.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost Analy sis Section 3, Page 14 of 24 preparing the activity specifications, work procedures, activation, and structural analyses, under the direction of FirstEnergy. Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel. 3.5.3 Design Conditions Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.9., 137Cs,eoSr,or transuranics) has been prevented from reaching levels exceeding those that permit the major NSSS components to be shipped under current transportation regulations and disposal requirements. The curie contents of the vessel and internals at final shutdown are derived from those listed in NUREG/CR-3474.t'nl Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Davis-Besse components, projected operating life, and different periods of decay. Additional short-lived isotopes were derived from CR-0130t301and CR-0672,13r1 and benchmarked to the long-lived values from CR-3474. The control elements are disposed of along with the spent fuel, there is no additional cost provided for their disposal. Activation of the reactor building structures is confined to the surrounding biological shield. More extensive activation (at very low levels) of the interior structures within containment has been detected at several reactors and the owners have elected to dispose of the affected material at a controlled facility rather than reuse the material as fill on site or send it to a landfill. The ultimate disposition of the material removed from the reactor building will depend upon the site release criteria selected, as well as the designated end use for the site. 3.5.4 General Buried Pipine Yard piping that is potentially contaminated will be excavated and the piping removed for survey and disposal. Clean yard piping that is less than one foot in diameter will be abandoned in place; all other yard TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Section 3, Page 15 of 24 piping will be either excavated or backfilled to prevent future surface subsidence. Transition Activities Existing warehouses will be cleared of non-essential material and remain for use by FirstEnergy and its subcontractors during the d.ecommissioning program, after which the warehouses will be demolished. The plant's operating staff will perform the following activities at no additional cost or credit to the project during the transition period: Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale. Drain and collect acids, caustics, and other chemical stores for recycle and/or sale. Process operating waste inventories, i.e., the estimate does not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioningexpense. Scrap and Salvaee The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. FirstEnergy will make economically reasonable efforts to salvage equipment following final plant shutdown. However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required. for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis d.oes not attempt to quantify the value that an owner may reahze based upon those efforts. It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimate do not include the additional cost for size reduction and preparation to meet "furnace TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Section 3, Page 16 of 24 ready" conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project. Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property owned by FirstEnergy will be removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts will also be made available for alternative use. Enerey For estimating purposes, the plant is assumed to be de-energized,with the exception of those facilities associated with spent fuel storage. Replacement power costs are used for the cost of energy consumption during decommissioning for tooling, Iighting, ventilation, and essential services. Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based. upon the guid.ance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactsl's."[321 NRC's financial protection requirements are based on various reactor (and spent fuel) configurations. Taxes Property taxes are included for all decommissioning periods through the demolition of the ISFSI. TLG Seruices, Inc.
Dauis-Besse Nuelear Power Station Docurnent F07-1619-004,Reu. 2 D ecommissioning Cost Analy sis Section 3, Page 17 of 24 Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security PIan in force during the various stages of the project. Road and parking lot surfaces will be broken up and the asphalt material disposed of in a local construction debris landfill. 3.6 COST ESTIMATE
SUMMARY
Schedules of expenditures are provided in Tables 3.1 through 3.4. The tables delineate the cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal). In Appendix C, the cost elements are also assigned to one of three subcategories: "License Termination," "Spent Fuel Management," and "Site Restoration." The subcategory "License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in its financial assuranceregulations (i.e., 10 CFR 550.75).The cost reported for this subcategory is generally sufficient to terminate the plant's operating license, recogni zrrrg that there may be some additional cost impact from spent fuel management. The "Spent Fuel Management" subcategory contains costs associated with the expansion of the ISFSI, containerization and transfer of spent fuel from the pool to the ISFSI for interim stor?ge, and the transfer of casks from the ISFSI to the DOE. Costs are also included for the operations of the pool and management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g., geologicrepository) is complete.
"Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.
As discussed in Section 3.4.1, it is not anticipated that the DOE will accept the GTCC waste prior to completing the transfer of spent fuel. Therefore, the cost of GTCC disposal is shown in the final year of ISFSI operation. While designated for disposal at the geologic repository along with the spent fuel, TLG Seruices, Ine.
Daui*Besse Nuclear Pou;er Station Document F07-1619-004' Reu. 2 D ecotnmissioning Cost An aly sis Section 3, Page 18 of 24 GTCC waste is still classified as low-Ievel radioactive waste and, as such, included as a "License Termination" expense. Decommissioning costs are reported in 2010 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedules are based upon the detailed activity costs reported in Appendix C, along with the timeline presented in Section 4. TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Docurnent F07-1619-004'Reu. 2 D eeotnmissioning Cost An aly sis Section 3, Page 19 of 24 TABLE 3.1 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF TOTAL ANNUAL DPENDITURES (thousands,2010dollars) Equipment & Year Labor Materials Energy Burial Other 20r7 31.253 8,067 1,908 919 r0.428 52,574 2018 55,729 26.531 4.098 10,638 26,762 123.757 2019 54,r58 40.509 2.605 23,838 L6,I27 r37"236 2020 51.118 26,099 2.206 t3.327 13.864 106,615 202r 49.847 20.879 _?,-0_q9 9,54r 13,008 95.332 2022 45.852 T7,76L r.872 8.356 12,416 86.257 2023 29.690 2.883 795 r,526 9,443 44,338 2024 21,794 8,162 330 6 8,648 38,940 2025 19,615 9.802 274 0 8,517 38,208 2026 9.22L 3,545 99 0 4,795 17,660 2027 3,332 0 0 0 2,687 6,019 2028 3.341 0 0 0 2,694 6,036 2429 3,332 0 0 0 2,687 6,019 2030 3,332 0 q 0 2,687 6,019 2031 3,745 r.240 0 0 2,687 7,672 2032 3,536 584 0 0 2,694 6,814 2033 3,332 0 0 0 2,687 6,019 2034 3.527 584 0 0 2,687 6,798 2035 3.512 539 0 0 2,687 6.738 2036 3,512 5L2 0 0 2.694 6,718 2037 3.515 548 0 0 2,687 6,750 2038 3,521 566 0 0 2,687 6 , 7 74 2039 3,560 683 q 0 2,687 6,930 2040 3.575 701 0 0 2,694 6,970 2041 3,338 18 0 0 2,687 6,043 2042 3,566 701 0 0 2,687 6,954 2043 3.566 70r 0 _0 2,687 6,954 2044 3.557 647 q 0 2,694 6,898 2045 3.476 43L a 0 2,687 6,594 2046 3,476 43r 0 0 2,687 6,594 2047 3.476 43r 0 0 2,687 6.594 2048 3.485 43r -a 0 2,694 6,611 2049 3.476 431 0 0 2,687 6,594 2050 3,476 43r 0 0 2,687 6.594 TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecornmissioning Cost An aly sis Section 3, Page 20 of 24 TABLE 3.1 (continued) DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF TOTAL ANNUAL DPENDITURES (thousands,2010dollars) Equipment & Year Labor Materials Energy Burial Other 13,46L L8.r42 TLG Seruices, Inc.
Davis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 Decornmissioning Cost Analy sis Section 3, Page 21 of 24 TABLE 3.2 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands,2010 dollars) Equipment & Year Labor Materials Energy Burial Other Total 2AI7 29.843 4.924 1,908 919 7,668 45.262 2018 50,504 r4,097 4.098 10,638 22,982 102.318 2019 46.889 2r,878 2,605 23.838 13,I27 108.337 2020 42,444 9.890 2,206 L3,327 10,835 78,703 202r 40,707 5.591 _ 2,0[q 9.54r 9.980 67,876 2022 38,464 5.405 r.872 8,356 9,887 63,984 2023 29.690 2,883 795 r.526 9,015 43.909 2024 6 , 11 5 293 110 6 r,725 8,249 2A25 83 0 0 0 0 83 2026 30 0 0 0 0 30 Years 2OZ7through 2055 0
---825 2056 0 0 0 r0,766 11,591 2057 0 0 0 0 0 0 Totals 284.770 65,788 L5,649 68,150 95,986 530,343 TLG Seruices, Inc.
DauisBesse Nuclear Power Station Document F07-1619-004,Reu. 2 D eeornmissioning Cost An aly sis Section 3, Page 22 of 24 TABLE 3.3 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands,2010dollars) Equipment & Year Labor Materials Bnergy Burial Other Total 3.143 t2.428 18,600 14,gg7 2022 i 4,039 _9 0 __ 3,332 3,745 _ _r,uv* 6,798
,6,83 0 701 0 18 0
_ 791 701 647 2,687 : 6,594 43r 2047 49_1 2048 i 3.485 43_1 3,476 43L 3,476 594 TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Docuntent F07-1619-004, Reu. 2 Decornmissioning Cost Analysis Section 3, Page 23 of 24 TABLE 3.3 (continued) DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands,2010dollars) Equipment& Year Labor Materials Energy Burial Totals I4L.6L7 113.871 349.706 TLG Seruices, Inc.
Daois-Besse Nuclear Pouter Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Section 3, Page 24 of 24 TABLE 3.4 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SITE RESTORATION DPENDITURES (thousands,2010 dollars) Equipment & Year Labor Materials Energy Burial 2017 362 0 0 0 0 362 2018 1,082 6 0 0 85 1,173 2019 1,069 32 0 0 444 r,544 2020 3.347 231 0 0 466 4,044 202r 4.L45 301 0 0 472 4,918 2022 3,350 243 0 0 382 3,975 2023 0 0 0 0 0 0 2024 12,664 6.727 220 0 2,281 21.893 2025 15,777 8.380 274 0 2,842 27,273 2026 5.706 3.03r 99 0 1,028 9,863 Totals 47,502 19,951 593 0 7,999 75,045 TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-161g-004,Reu. 2 l Decomrni ssioning Cost Analy sis Section 4, Page I of 4
- 4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follows the sequencepresented in the NF/\TESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan describedin Section 3.4.L.
A schedule or sequence of activities for the DECON alternative from shutdown through site restoration is presented in Figure 4.I. The scheduling sequence is based on the fuel being removed from the spent fuel pool within five and one half years. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project Professional 2010" computer softwa1's.[331 4.L SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedencenetwork developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique) Software Package. The work activity durations used in the precedencenetwork reflect the actual man-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:
. The fuel handling area of the auxiliary building is isolated until such time that aII spent fuel has been discharged from the spent fuel pool to the ISFSI. Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel to the ISFSI is complete.
. All work (except vessel and internals removal) is performed during an 8-hour workday, 5 days per week, with no overtime. There are eleven paid holidays per year.
. Reactor and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for the second shift.
. Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.
TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Docum.entF07-1619-004,Reu. 2 Decommissioning Cost An aly sis Section 4, Page 2 of 4 For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activitv. 4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost table are based upon the durations developed in the schedule for decommissioning Davis-Besse. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is also shown for the spent fuel cooling period, which determines the release of the auxiliary building for final decontamination. A project timeline is provided in Figure 4.2. Milestone dates are based on a shutdown date of April 22, 2Ol7 . TLG Seruices, Inc.
Daui*Besse Nuelear Power Station Document F07-1619-004,Reu.2 Deeornmissioning Cost An alysis Section 4, Page 3 of 4 FIGURE 4.I ACTIVITY SCHEDULE Datis-Bc$ Unit I DECON Shutdorrn Urait I Certificate of lrermanent oessation of olrrations submittd Drj- frrel $ornge ns Reconfigure plant Pnepanv ations PgD^{n submittd l\rritten crertificate of permanent removal of fuel submitted Site epecfic de.cromrnissioning oost estimate submitted DOC staff ?A lb L-uit I - Demrnrris.sioning Recronfigure plant (centinuedl Dry fuel st{Eflge olerations Pnepare flecrn:\-SSE I elent frrel rool D?T-fuet storage qrcratione Pneparation for reactor rrsrcl r.enroval Reactor te=sel & internal= Remainiug large ttsgS components disposition Non-e eystems ltain t gDerator
}[ain condensrr Lice ns. teryu.ination plan subudtted Period ?b L*nit I - frrcl)
Fuel storf,,g pool operations Drr' fuel storage operations Remon-e sl'stems not g wer fuel storagc Liae nse tr.rrninatioa plan appr.ore.d Fuel storage pool ar-ailable for deconmissionrng Period Ic L-nrt I - Decuntamination g n'ct frrcl storagc Dn- fuel storage operations Removr nemaining s1-s,terns Decon r..'et fuel storage ara Period !d Uuit I - Drhv btfsre li,csnse terrniuation D{'- fueI storage cperations Final Site Sun-e3-
\:RC rer-ien' & approral Part *0 license te.rminattd P 3b Unit l- $ite nestorariou Dr5- fuel =rorage oprrarions Builfing de rnolitions" b ackfill aud landscaping TLG Seruices, Ine.
Davi*Besse Nucl ear Power Station Document F07-1619-004,Reu. 2 D ecommissioning Cost An aly sis Section 4, Page 4 of 4 FIGURE 4.2 DE COMMISSIONING TIMELINE (not to scale) DECON ALTERNATIVE (Shutdown April 22, 2017) Period 1 Period 3 Transition and Period 2 Site ISFSI Preparations Decommissioning Restoration D&D 10/2018 1212056 0712057 Spent FueI Pool Operations/ Fuel Transfer to ISFSI ISFSI Operations 0u2026 L212056 TLG Seruices, Inc.
Daui*Besse Nuclear Pouter Station Docutnent F07-1619-004,Reu. 2 D ecommissioning Cost Analy sis Section 5, Page 1 of 3
- 5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of aII 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,t3al16.
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 7L 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 L73-L78. Shipping containers are required to be Industrial Packages (IP- 1, IP-z or IP-3, as defined in 10 CFR $ 173.411). For this study, commercially available steel containers are presumed to be used for the disposal of piping, small components, and. concrete. Larger components can serve as their own containers, with proper closure of all openings, accessways, and penetrations. The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in Appendix C, and summarized in 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 containerrzed material and on the displaced volume of components serving as their own waste containers. The reactor vessel and internals are categortzed as large quantity shipments and, accordingly, wiII 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 shutd.own 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). White the dose rates decrease with time, radionuclides such as 137Cswill still control the disposition requirements. TLG Seruices, Ine.
Daui*Besse Nuclear Pouer Station Document F07-1619-004, Reu.2 l Decomrnissioning Cost An aly sis Seetion 5, Page 2 of 3 The waste material produced in the decontamination and dismantling of the nuclear plants is primarily generated during Period 2. Material that is considered potentially contaminated when removed from the radiological controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling. For purposes of constructing the estimate, the cost for disposal at the EnergySolutions and Barnwell facilities were used as a proxy for future disposal facilities. Separate rates were used for containerized waste and large components, including the steam generators, reactor coolant pumps and motors. Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste. Since EnergySolutions is not currently able to receive the more highly radioactive components generated in the decontamination and dismantling of the reactor, disposal costs for the Class B and C material were based upon the last published rate schedule for non-compact waste for the Barnwell facility (as a proxy). Additional surcharges were included for activity, dose rate, and/or handling added as appropriate for the particular package. TLG Seruices, Inc.
DauisBesse Nuclear Power Station Doeument F07-1619-004,Reu. 2 l D eeommissioning Cost An aly sis Section 5, Page 3 of 3 TABLE 5.1 DECON ALTERNATIVE DECOMMISSIONING WASTE
SUMMARY
Waste Volume Mass Waste Cost Basis Class ttl (cubic feet) (pounds) Low-Level Radioactive EnergySolutions A 305,825 15,524,887 Waste (near-surface disposal) Barnwell B r,712 192,069 Barnwell C 517 61,605 Greater than Class C Spent Fuel (geologicrepository) Equivalent GTCC 453 89.800 Processed/Conditioned Recycling (off-site recycling center) Ve-r_rdg{s, A 2ro,629 9,452,583 J6f2l tzJ 519.136 25,320,944 tu Waste is classifiedaccordingto the requirementsas delineatedin Title 10 CFR,Part 61.55 l2l Columnsmay not add due to rounding. TLG Seruices, Inc.
Daui*Besse Nuclear Pouter Station Doeument F07-1619-004,Reu. 2 D ecornrnissioning Cost An aly sis Section 6, Page I of 4
- 6. RESULTS The analysis to estimate the costs to decommission Davis-Besse relies upon the site-specific, technical information developed for a previous analysis prepared in 2005.
While not an engineering study, the estimate provides FirstEnergy with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station. The estimate described in this report is based on numerous fundamental assumptions, including regulatory requirements, Iow-level radioactive waste disposal practices, high-level radioactive waste management options, project contingencies, and site restoration requirements. The decommissioning scenario assumes continued operation of the station's spent fuel pool for a minimum of five and one half years following the cessation of operations for continued cooling of the assemblies. The cost projected to promptly decommission(DECON) Davis-Besseis estimated to be $955.094 million. The cost associated with the physical decontamination and dismantling of the nuclear plant, so that the operating license can be terminated, represents approximately 55 .5% of the total cost. Another 36.60/ois related to the management, interim storage, and eventual transfer of the spent fuel. The remaining 7 .9% is for the demolition of the designated structures and limited restoration of the site. The primary cost contributors, identified in Table 6.1, are either labor-related or associated with the management and disposition of the radioactive waste. Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the otganuzation required to manage the decommissioning and ISFSI operations, as well as the duration of the program. It is assumed, for purposes of this analysis, that FirstEnergy will hire a contractor to manage the decommissioning. The size and composition of the management organizations (owner and contractor) varies with the decommissioning phase and associated site activities. However, once the operating license is amended, and the site exclusive of the ISFSI released for unrestricted use, 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, the spent fuel pool will remain operational for a minimum of five and one half years following the cessation of operations. The pool will be isolated and an independent spent fuel island created. This will allow decommissioning operations to proceed in and around the pool area. Over the five TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-161g-004,Reu. 2 l D ecomrnissioning Cost An alysis Section 6, Page 2 of 4 and one half-year period, the spent fuel will be packaged into transportable canisters for relocation to the ISFSI. 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, disposition of the majority of the low-level radioactive material requiring controlled disposal is at the EnergySolutions' facility. Highly activated components, requiring additional isolation from the environment (GTCC), are packaged for geologic disposal. The cost of geologicdisposal is based upon a cost equivalent for spent fuel. A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processesas survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at the EnergySolutions facility. The cost identified in the summary tables for processing is all-inclusive, incorporating the ultimate disposition of the material. Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program. Decontamination and packaging costs also have a large labor component that is based upon prevailing wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can be more cost effective than deferral, due to the deterioration of the facilities (and therefore the working conditions) with time. The reported cost for transport includes the tariffs and surcharges associated with moving large components and/or overweight shielded casks overland, as well as the general expense, .g., Iabor and fuel, of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck. Decontamination is used to reduce the plant's radiation fields and minimize worker exposure. Slightly contaminated material or material located within a contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for TLG Seruices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004, Reu.2 I D ecomrnissioning Cost An aly sis Section 6, Page & of 4 uncontrolled release in-situ. Centraluzed processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear plant. License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings. The status of any plant components and materials not removed in the decommissioning process will also require confirmation and will add to the expense of surveying the facilities alone. The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level. TLG Seruices, Inc.
Daui*Besse Nuclear Pouter Station Document F07-1619-004,Reu. 2 D ecommissioning Cost An aly sis Section 6, Page 4 of 4 TABLE 6.1 DECOMMISSIONING COST ELEMENTS (thousandsof 2010dollars) Cost Element Total Percentage Decontaminatron 10.385 1.1
&"go:al r22,605 12.B Packaging 16,307 r.7 Transportation L2,796 1.3 Waste Disposal 58,160 6.1 Off-site Waste Processing 20,822 2.2 Program Managemsnf [u 355,567 37.2 Spent Fuel PooI Isolation TL,477 L.2 Spent Fuel (ISFSI Related) tzl 167,003 L7.5 Insurance and Regulatory Fees 27,3r9 2.9 Energy 16,243 r.7 Charact enzation and Licensing Survevs 17,543 1.8 Property Taxes 74,457 7.8 Miscellaneous Equipment 6,605 0.7 Site O&M 14,207 1.5 CorporateA&G 22,394 2.3 Other tsl 1,203 0.1 Tls1fl ta1 955.094 100.0 Cost Element Total Percentage License Termination 530,343 DD.D Spent Fuel Management 349.706 36.6 Site Restoration 75,045 7.9 f6f2] t+1 955,094 100.00 tu Includes engineering costs l2l Excludes program management costs (staffing) but includes costs for spent fuel loading/transfer costs/spentfuel pool O&M and EP fees t3l Disposal of clean asbestoscontaining materials, e.g., from the cooling tower t4l Columns may not add due to rounding TLG Seruices, Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecornrn issioning Cost Analysis Section 7, Page l of 3
- 7. REFERENCES
- 1. "Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station,"
Document F07-1525-003,Rev. 0, TLG Services,Inc., October 2005
- 2. U.S. Code of Federal Regulations, Title 10, Parts 30, 40,50, 51, 70 al)d 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.),June 27, L988
- 3. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability.of Funds for Decommissioning Nuclear Reactors," October 2003
- 4. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "Radiological Criteria for License Termination"
- 5. U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, "Entombment Options for Power Reactors," Advanced Notice of Proposed Rulemakitg, Federal Register Volume 66, Number 200, October 16, 2001
- 6. 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.
- 7. "Nuclear Waste Policy Act of 1982,"42U.5. Code 10101,et seq.
- 8. "Nuclear Waste Policv Amendments of 1987,"42 U.S. Code IOl72
- 9. "Blue Ribbon Commission on America's Nuclear Future, Report to the Secretary of Energy," http://u'ww.blc.gov/,January 2OL2
- 10. "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level RadioactiveWaste," U.S. DOE, January 11, 2013
- 11. U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) "... DOE shall issue an annual acceptancepriority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance..."
TLG Seruices,Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecommi ssioning Cost An alysis Seetion 7, Page 2 of 3
- 7. REFERENCES (continued)
L2. 'Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004
- 13. U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," Subpart 54 00b),"Conditions of Licenses."
t4. U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent FueI at Power Reactor Sites."
- 15. "Low Level Radioactive Waste Policy Act," Public Law 96'573, 1980
- 16. "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law g9-240,1986 L7. Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10,Part 61.55
- 18. 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 2I, 1997
- 19. "Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination," EPA Memorandum OSWER No. 9200.4-18,August 22, 1997.
- 20. U.S. Code of Federal Regulations, Title 40, Part L4I.L6, "Maximum contaminant levels for beta particle and photon radioactivity from man-made radionuclides in commuruty water systems" 2L. "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,October9, 2OO2
- 22. "Multi-Agency Radiation Survey and Site Investigation Manual MARSSIIVI),"
NUREG/CR-L575,Rev. 1, EPA 4O2-R-97-OI6, Rev. 1, August 2000
- 23. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant DecommissioningCost Estimates," AIF/NESP-036, May 1986 TLG Seruices,Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Reu. 2 Decomrnissioning Cost Analy sis Section 7, Page 3 of 3
- 7. REFERENCES (continued)
- 23. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant DecommissioningCost Estimates," AIFAIESP-036, May 1986
- 24. W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook,"
Department of Energy, DOE/EV/10128-1,November 1980
- 25. "Building Construction Cost Data 2010," Robert Snow Means Company, Inc.,
Kingston, Massachusetts
- 26. Project and Cost Engineers' Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984
- 27. U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178
- 28. Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-4277I9 Rules Tariff, March 2004, Radioactive Materials Tariff. March 2010
- 29. J.C. Evans et 2I., "Long-Lived Activation Products in Reactor Materials" NIIREG ICR-3474, Pacific Northwest Laboratory for the Nuclear Regulatory Commission,August 1984
- 30. R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology,Safety and Costs of Decommissioning a Reference Pressurtzed Water Reactor Power Station,"
NUREG/CR-0130 and addenda, Pacifi.c Northwest Laboratory for the Nuclear Regulatory Commission. June 1978
- 31. H.D. Oak, et al., "Technology,Safety and Costs of Decommissioninga Reference Boiling Water Reactor Power Station," NUREG/CR-0672 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1980
- 32. "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors," 10 CFR Parts 50 and l4O, Federal Register Notice, Vol. 62, No. zLO, October 30, 1997
- 33. "Microsoft Project Professional 2010," Microsoft Corporation, Redmond, WA.
- 34. 'Atomic Energy Act of 1954," (68 Stat. 919)
TLG Seruices,Inc.
Daui*Besse Nuclear Power Station Docurnent F07-1619-004,Reu. 2 D ecornrnissioning Cost An aly sis Appendix A, Page I of 4 APPENDIXA UNIT COST FACTOR DEVELOPMENT TLG Seruices, Inc.
DauisBesse Nuclear Power Station Document F07-1619-004,Rev. 2 Decornmissioning Cost Analy sis Append.ix 4 Pq,ge2 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example: Unit Factor for Removalof ContaminatedHeat Exchanger< 3,000lbs.
- 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 exchangerwill be sent to the waste processingarea.
- 2. CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes) (minutes)*
a Remove insulation 60 ft) b Mount pipe cutters 60 60 c Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e Cap openings 20 (d) t Rig for removal 30 30 g D Unbolt from mounts 30 30 h Remove contamination controls 15 15 i Remove,wrap, send to waste processingarea 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):
+ Respiratory protection adjustment (5O%of critical duration) r28 + Radiation/ALARA adjustment (37% of critical duration) 95 Adjusted work duration 478
- Protective clothing adjustment (30% of adjusted duration) t43 Productive work duration 62L
+ Work break adjustment (8.33 o/oofproductive duration) 52 Total work duration (minutes) 673
*** folal duration = ll.2l7 hr ***
' alpha designators indicate activities that can be performed in parallel TLG Seruices,Inc.
Daui*Besse Nuelear Power Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Appendix 4 Page 3 of 4 APPENDIXA (continued)
- 3. LABOR REQUIRED Duration Rate Crew Number (hours) ($nrr) Cost Laborers 3.00 rr.2r7 $3e.51 $1,329.55 Craftsmen 2.00 TT.2I7 $56.8e $L,276.27 Foreman 1.00 LL.2T7 $60.02 $673.24 General Foreman 0.25 LI.2L7 $62.81 $176.13 Fire Watch 0.05 rt.2L7 $3e.51 fi22.16 Health Physics Technician 1.00 IL.2L7 $41.28 $463.04 Total Labor Cost $3,940.39
- 4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs ConsumablesAVlaterialsCosts
-Blotting paper 50 @ $0.49 sq f1 ttt $24.5O
-Tarp, oiUfire retardant, 7.5 mils, 50 @ $0.36/sqft tzl $18.00
-Gas torch consumables1 @ $8.9l/hr x t hr {3} $8.91 Subtotal cost of equipment and materials $51.41 Overhead & profit on equipment and materials @ L7.OO% $8.74 Total costs, equipment & material $60.15 TOTAL COST:
Removal of contaminated heat exchanger <3000 pounds: $4,000.54 Total labor cost: $3,940.39 Total equipment/material costs: $60.15 Total craft labor man-hours required per unit: 81.88 TLG Serwices, Inc.
Daui*Besse Nuclear Power Station Document F07-1619-004, Reu. 2 Decommissioning Cost An aly sis Appendix A, Page 4 of 4 D. NOTES AND REFERENCES Work difficulty factors were developed in conjunction with the Atomic Industrial Forum's (now NEI) program to standardtze nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5 of the "Guidelines for Producing Commercial Nuclear Power Plant DecommissioningCost Estimates," AIFAIESP-036, May 1986.
. Referencesfor equipment & consumables costs:
- 1. www.mcmaster'.comonline catalog, McMaster Carr Spill Control (7 428Tr3)
- 2. R.S. Means (2010)Division 01 56, Section 13.60-0600,page 20
- 3. R.S. Means (2010)Division 01 54 33, Section 40-6360,page 658 Material and consumable costs were adjusted using the regional indices for Toledo, Ohio.
TLG Seruices,Inc.
Daui*Besse Nuclear Power Station Reu.2 l Document F07-1619-004, D ecommissioning Cost An alysi s Appendix B, Page I of 7 APPENDIX B UMT COST FACTOR LISTING (DECON: Power Block Structures Only) TLG Seruices,Inc.
DauisBesse Nuclear Power Station Document F07-1619-004,Rev. 2 D ecorntni ssioning Cost An alysi s Appendix B, Page 2 of 7 APPENDIX B UMT COST FACTOR LISTING (Power Block Structures Only) Unit Cost Factor Cost/Unit($) Removal of clean instrument and sampling tubing, $Ainear foot 0.45 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.70 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 6.79 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 13.55 Removal of clean pipe >8 to 14 inches diameter, $Ainear foot 25.92 Removal of clean pipe >I4 ta 20 inches diameter, $/linear foot 33.63 Removal of clean pipe >2Oto 36 inches diameter, $/linear foot 49.49 Removal of clean pipe >36 inches diameter, $/linear foot 58.83 Removal of clean valve >2 to 4 inches 89.38 Removal of clean valve >4 to 8 inches 135.50 Removal of clean valve >8 to 14 inches 259.L8 Removal of clean valve >L4 to 20 inches 336.26 Removal of clean valve >20 to 36 inches 494.89 Removal of clean valve >36 inches 588.33 Removal of clean pipe hanger for small bore piping 28.78 Removal of clean pipe hanger for large bore piping r03.44 Removal of clean pump, <300 pound 227.02 Removal of clean pump, 300-1000 pound 639.03 Removal of clean pump, 1000-10,000pound 2,523.23 Removal of clean pump, >10,000 pound 4,874.43 Removal of clean pump motor, 300-1000 pound 269.r8 Removal of clean pump motor, 1000-10,000pound 1,05L.52 Removal of clean pump motor, >10,000 pound 2,365.93 Removal of clean heat exchanger<3000 pound 1,353.69 Removal of clean heat exchanger >3000 pound 3,400.03 Removal of clean feedwater heater/deaerator 9,593.36 Removal of clean moisture separator/reheater 19,734.6r Removal of clean tank, <300 gallons 292.2L Removal of clean tank, 300-3000gallon 924.30 Removal of clean tank, >3000 gallons, $/square foot surface area 7.82 TLG Seruices,Inc.
DauisBesse Nuclear Power Station Docurnent F07-1619-0A4,Reu. 2 D ecommissioning Cost An alysis Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only) Unit Cost Factor Cost/Unit($) Removal of clean electrical equipment, <300 pound I24.60 Removal of clean electrical equipment, 300-1000pound 438.26 Removal of clean electrical equipment, 1000-10,000pound 876.51 Removal of clean electrical equipment, >10,000pound 2,094.48 Removal of clean electrical transformer < 30 tons 1,454.59 Removal of clean electrical transformer > 30 tons 4,188.95 Removal of clean standby diesel generator, <100 kW r,485.73 Removal of clean standby diesel generator, 100 kW to 1 MW 3,316.26 Removal of clean standby diesel generator, ) 1 MW 6,865.31 Removal of clean electrical cable tray, $/linear foot 11.60 Removal of clean electrical conduit, $Ainear foot 5.06 Removal of clean mechanical equipment, <300 pound L24.64 Removal of clean mechanical equipment, 300-1000 pound 438.26 Removal of clean mechanical equipment, 1000-10,000pound 876.5L Removal of clean mechanical equipment, )10,000 pound 2,094.48 Removal of clean HVAC equipment, <300 pound 150.66 Removal of clean HVAC equipment, 300-1000 pound 526.59 Removal of clean HVAC equipment, 1000-10,000pound 1,049.51 Removal of clean IIVAC equipment, >10,000pound 2,O94.48 Removal of clean HVAC ductwork, $/pound 0.47 Removal of contaminated instrument and sampling tubing, $/linear foot 1.36 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot L9.47 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 33.39 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 53.47 Removal of contaminated pipe >8 to 14 inches diameter, $Ainear foot 104.10 Removal of contaminated pipe >I4 to 20 inches diameter, $/linear foot L24.80 Removal of contaminated pipe >20 to 36 inches diameter, $Ainear foot L72.35 Removal of contaminated pipe >36 inches diameter, $llinear foot 203.54 Removal of contaminated valve >2 to 4 inches 401.58 Removal of contaminated valve >4 to 8 inches 485.01 TLG Seruices,Inc.
Dauis-Besse Nuclear Power Station Document F07-1619-004,Rev. 2 D ecomrnissioning Cost An alysis Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only) Unit Cost Factor Cost/Unit($) Removal of contaminated valve >8 to 14 inches 991.3 1 Removal of contaminated valve >I4 to 20 inches 1,258.05 Removal of contaminated valve >20 to 36 inches L,673.7 4 Removal of contaminated valve >36 inches 1,985.69 Removal of contaminated pipe hanger for small bore piping L28.26 Removal of contaminated pipe hanger for large bore piping 427.L2 Removal of contaminated pump, <300 pound 864.24 Removal of contaminated pump, 300-1000 pound 2,028.46 Removal of contaminated pump, 1000-10,000pound 6,631.35 Removal of contaminated pump, >10,000 pound L6,r47.96 Removal of contaminated pump motor, 300-1000 pound 869.86 Removal of contaminated pump motor, 1000-10,000pound 2,706.87 Removal of contaminated pump motor, >10,000pound 6,077.30 Removal of contaminated heat exchanger <3000 pound 4,000.54 Removal of contaminated heat exchanger >3000 pound 11,604.80 Removal of contaminated tank, <300 gallons r,439.37 Removal of contaminated tank, >300 gallons, $/square foot 28.34 Removal of contaminated electrical equipment, <300 pound 670.09 Removal of contaminated electrical equipment, 300-1000 pound 1,655.55 Removal of contaminated electrical equipment, 1000-10,000pound 3,188.99 Removal of contaminated.electrical equipment, >10,000 pound 6,303.48 Removal of contaminated electrical cable tray, $/linear foot 32.28 Removal of contaminated electrical conduit, $Ainear foot 15.93 Removal of contaminated mechanical equipment, <300 pound 7 45.35 Removal of contaminated mechanical equipment, 300-1000pound 1,827.96 Removal of contaminated mechanical equipment, 1000-10,000pound 3,515.33 Removal of contaminated mechanical equipmeht, )10,000 pound 6,303.48 Removal of contaminated HVAC equipment, <300 pound 7 45.35 Removal of contaminated HVAC equipment, 300-1000pound L,827.96 Removal of contaminated HVAC equipment, 1000-10,000pound 3,515.33 TLG Seruices, Inc.
Davi*Besse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecomrnissioning Cost An aly sis Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only) Unit Cost Factor Cost/Unit($) Removal of contaminated HVAC equipment, )10,000 pound 6,303.48 Removal of contaminated IIVAC ductwork, $/pound 1.90 RemovaUplasmaarc cut of contaminated thin metal components, $Ainear in. 3.63 Additional decontamination of surface by washing, $/square foot 7.36 Additional decontamination of surfaces by hydrolasing, $/square foot 33.58 Decontamination rig hook up and flush, $/ 250 foot length 6,275.83 Chemical flush of components/systems,$/gallon 14.77 Removal of clean standard reinforced concrete, $/cubic yard L32.29 Removal of grade slab concrete, $/cubic yard t75.02 Removal of clean concrete floors, $/cubic yard 342.66 Removal of sections of clean concrete floors, $/cubic yard 1,016.94 Removal of clean heavily rein concrete wl#9 rebar, $/cubic yard 226.96 Removal of contaminated heavily rein concrete wl#9 rebar, $/cubic yard 1,996.51 Removal of clean heavily rein concrete wl#18 rebar, $/cubic yard 287.03 Removal of contaminated heavily rein concrete wl#18 rebar, $/cubic yard 2,640.4A Removal heavily rein concrete wfr#18rebar & steel embedments, $/cubic yard 432.49 Removal of below-grade suspended floors, $/cubic yard 342.66 Removal of clean monolithic concrete structures, $/cubic yard 854.A7 Removal of contaminated monolithic concrete structures, $/cubic yard 1,986.80 Removal of clean foundation concrete, $/cubic yard 670.L7 Removal of contaminated foundation concrete, $/cubic yard 1,850.94 Explosive demolition of bulk concrete, $/cubic yard 29.42 Removal of clean hollow masonry block waII, $/cubic yard 92.07 Removal of contaminated hollow masonry block wall, $/cubic yard 296.04 Removal of clean solid masonry block wall, $/cubic yard 92.07 Removal of contaminated solid masonry block wall, $/cubic yard 296.04 Backfill of below-grade voids, $/cubic yard 2L.57 Removal of subterranean tunnels/voids, $/linear foot 707.84 Placement of concrete for below-grade voids, $/cubic yard 114.68 Excavation of clean material, $/cubic yard 2.9r TLG Serwices,Inc.
DauisBesse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecornrnissioning Cost An aly sis Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only) Unit Cost Factor Cost/Unit($) Excavation of contaminated material, $/cubic yard 4A.LT Removal of clean concrete rubble (tipping fee included), $/cubic yard 22.L9 Removal of contaminated concrete rubble, $/cubic yard 25.r3 Removal of building by volume, $/cubic foot 0.30 Removal of clean building metal siding, $/square foot 1.04 Removal of contaminated building metal siding, $/square foot 3.53 Removal of standard asphalt roofing, $/square foot 2.to Removal of transite panels, $/square foot 2.03 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 1r.67 Scabbling contaminated concrete floors, $/square foot 7.L4 Scabbling contaminated concrete walls, $/square foot 18.90 Scabbling contaminated ceilings, $/square foot 64.88 Scabbling structural steel, $/square foot 5.78 Removal of clean overhead crane/monorail < 10 ton capacity 62r.24 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,696.73 Removal of clean overhead crane/monorail >10-50 ton capacity 1,490.98 Removal of contaminated overhead crane/monorail >10-50 ton capacity 4,071.50 Removal of polar crane > 50 ton capacity 6,252.44 Removal of gantry crane > 50 ton capacity 26,L80.94 Removal of structural steel, $/pound 0.19 Removal of clean steel floor grating, $/square foot 4.47 Removal of contaminated steel floor grating, $/square foot 12.60 Removal of clean free standing steel liner, $/square foot LI.72 Removal of contaminated free standing steel liner, $/square foot 33.16 Removal of clean concrete-anchoredsteel liner, $/square foot 5.86 Removal of contaminated concrete-anchoredsteel liner, $/square foot 38.62 Placement of scaffolding in clean areas, $/square foot 15.4r Placement of scaffolding in contaminated areas, $/square foot 24.39 Landscaping with topsoil, $/acre 23,754.59 Cost of CPC B-88 LSA box & preparation for use 1,896.43 TLG Seruices,Inc.
Daui*Besse Nuclear Power Station Doeument F07-1619-004,Reu. 2 Decotnrnissioning Cost Analy sis Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only) Unit Cost Factor Cost/Unit($) Cost of CPC B-25 LSA box & preparation for use r,736.37 Cost of CPC B-12V 12 gauge LSA box & preparation for use L,4L2.O5 Cost of CPC B-I44 LSA box & preparation for use 8,293.40 Cost of LSA drum & preparation for use L79.45 Cost of cask liner for CNSI 8 1204' cask (resins) 6,690.92 Cost of cask liner for CNSI 8 120.4'cask (filters) 7,326.78 Decontamination of surfaces with vacuuming, $/square foot o.7r TLG Seruices,Inc.
DaviyBesse Nuclear Power Station Document F07-1619-004,Reu. 2 D ecotnrni ssioning Cost An aly sis Appendix C, Page I of 14 APPENDIX C DETAILED COST ANALYSIS TLG Setvices,Inc.
C\\tt OO OOOOOOIO oF\OOOoOoOoOQQ\ A a ocn Jo EEE cfl OO o-.o-OOOOOOoI
- o. o- crl q n q o-i(to6666N6OONooN iti = ro = rn' rn rr' . rto . + + F{ \o crr 0Q o
o s m!n
.! r-sEE q c\l N sl FI F{ Fl N cO rn sf ststNlocfl(nF cri+ Fi c.i i icri ai .qr
.at sR.
\'i\ v o SH sJ es q: EE \: qoX oF \:l = d5 E F\ -O
-o
'(tEr Oo dE o-8$
oE o6 Efl G -,: 6d o6 3fl G-j 6d
<6 sfl G.:
6d EE ft! 9.3 r\@ Nr.o(oOl NO tr Ln sl ot$sN Ln (\ o t.r) EE LUI fiE o t c o En s rroE q Eo Gl
=
lJ)tnC)(nr\rnt{ Olei @l.\OO0OOtN ('rOlf!c{\OOelOFlsl Ool i cnN e{rl!n(Otnl.-f\ o co IJ') f-t $ l.rt lJ) ol NNtncnFc\tOcn$i{
,4-t\
q) =u, Ntndrl F{0ocnLnS lJlst@t_cn rlrJ) 0O^ NoJ--1
+)
d VEE 2 aE cn cn c! cn Fl rH = o.= {J
-i^
d rY r-.l Eg 3 -S- -3R -S333hKF - @ Or cO f\ @
\o f.'f} -l sf
!n Ol st ro Ln OO $
(o ot q rn .! O'4 5l':l (oo-rodcn NC!r.oCnSfm tFt^ A +, 6 >- ' g ' Eg Ft s (\u) FlFiFl@cnu)sl Ln\t@f\(n-l ft1tnrl(n s NN-ll-r)Flf\ cri c.i + 9rxd rv l7\ \v -- Lv o OOttn!nO(nFtnFl sl cn m F m oO F- sl' (o (o F\ Ol sl 09 (OOFIOoof\ (n(.oFlFtNrlSF(O 't i\ !( nO O O t s f N s t r O r l ( o coNNCndrn 5 bnn A f ! a d $cn@. rt
- - l { F v
( ) . F - v t cb o c! ON E-9'aE
-EEE gBAU)t' bg cO Ft O@OOmtnFlOri c! $ Fl Fl Fi N CY'l ln sf c..IFOOOONQOONQQ!!
i l i - l ' h -'
+ +
='-n r- t3l t n e r 6 <-
m =
< ci t.o ot cn sf 90
\
OQOACNF
$ Q $ O c!
N oq -l t.t -l f-ot ol;; a O - lf]ao 8.g crl c! e.l a q)5 Eng
.22
)a
-Y Es 66 W
,iv Z\ o
- E) n '-a c
I fr8 xo o-E 8e
?
go 8 Et
'69 E8 Ho o-t!
>v g8 b()
t, 60-c R*-6.E I-o(oEo(J Hs *c 33 ;Ei E \-t6 c'F 5
*gE is
.9UH.."EP =EE SEs
-E ro = s<f;'
E iEEfl"'"saE Fg iFE B E.s
'\F P \Sl EiH:e;f$giEsE+eE:
F
=
- PEt - 3E= ee ,tIEl x E t E t r l s E x !#E .- g _= f,sa=;E hs "d;8 P+E:Fo It H sFqaEfEg;;H;EEE;+
Yti.=uoL F Er_EE H?Hi EEFEiss
.fig3;!EE qo i EE!*!E;i*3ss:8"F6- FcE;seEn,HgFE r,Q Bv Sql E E-gE+EfrEEgi:iFEIiI EHSHSEf gH ;EEEti;gEEF{
;EEE$35EcsiF- FEgE*I;;
tEEiE;EEEg _5E.=-FHls 4 gggE;ssf fr EE?uEESEESs$Fl ;s"FsSs;
':c
$SExEnFs'E o
Fro a
- (n O -r c.'l cYl oU G o_ o 6.3 .r to vt bo ss Q -
o Fr o-srsgs n.icYla'rlq\oqojnnnl
'.Ea 5 : : 5 : 5 5 5 5 5 i ! i i =c Fqt q r rRF tnF i{ ls { r v) o :.1 no?n4q\oqoln.'! nnnnn .3 .i.i.t.1 !!nn!!!!!-
' a=l o = :.i.innnnn..1 nnn.i.i.i.i.i SE H 3SSSSS.9SS.sSSS.sS.9S .{Ss.{S"$Ss.sssss.s fs.ss.{ss S t!
N\ Flsl(O-l$ cnoooooooooooooo sb EEE ,, , , ,, $=Kb G co6o!nooocnotnooo(o\o NOlJ)mOOO\Oc{$N(oOtnlf) sgE \nr Fir.:dd + sl -l N rl Fl rt Fl (O Fl rl $ r{ -l Fl rn c! o) oo rn aip J CY') u) (o
.qa JA,
\ rs c)O ln \i\ \,/ l/)tn cnm c{ 6l rJ) s r.i Or Ol I EH st' =t- st Ln i! : r.r) t-.t \qto X \x bl. il 11 F N6l eas NN f, R FN Fl Fa F.' N N iFg NN OO r..i 6i C\ 8E oE o6 o o E '-,:t o 66 o (g o6 6 Efl lE -,: 66 Or Ol
<6 lnrn (o r r r r r l r l \ o el (o it 00@
E't
.E-:
dd
<ir s Fi rif 6d d d F{
gE 5t! 9s
\t(o @OrOl c rn Fl t.r)NF-o I t - l ri Fl Eg
;o 6 u
N N rn @N tn@ (o@ o c q, ' o No N , q00 r@Fl NQ Or O) f rri oi l! Fo dd r! dE c 9ro o Ho CL o lE
=
rl -l Sf $ o(o@if eic!{o or orQtn9st N olJ]@ollrrntn@otN@olm (o tr t-'l (o cf) rt lt $ + rn o) o t' ol c\l s ch il oo (n Fi Fl rl F{ t.r) cn N !n Flrl$e{tn a\ io cn cn qqF.n N@ 0o- otqt-..to- o- $elNrl v
+)
Cg EEE 3 ci(J
@co e{st c! Fl lO Ncn NslrO L0 a -
rlr 5 I
'-Y . ; +) i (o ro sf l.n 0O rn In IJ) f) c OO c! CO Ol It O) O)
=o Gg F{
OO ri $NF NN o
- m 6
cO st r-.{ rt tJ) c.,t st $ tn 6 o) cn oo N N O or Or o O ln Ln Or Q oo rJ) + ii @ l/) Fl Fi Fl rl (n rl) Cn C\ -l f\ F\
-IH^
Ul+r? F$ (n ro oo' oo' rf,
-i t
+
N rn F-c'i
@ Or c.'t'-i
@ 0O rr Ol d
$ F\ N O) ni ro^
(N st In rJ) f-tn rl N Fl Fl ri Fl $ Fl -l f) -l Fl rl rr 2 F 6 ) V - v t\ -i tsv o rn u) rl t.o \O @ cn 0O F\ Ol oo N c-l O rn cn O tn @ cO Q @ il N rn Ft oo cO o N rn rl
\n r{
lJ1 rl rt rn m r{ F\ 0o e{ ol (o ln Fl dl c! ff) a{ 6 boa !nlJ) tnLn NN N
-t O
i.'l S @- rn m N N N.!
+ -{
Fi
-l cncn Fl @
Ol OQ qOO-Ol Ol
.ij c! rJ) Ol v- T A r ' Ef ,E O .E o
- 3.efl o tr o
t6 8:
-E-E o o
rn rn
-l rl f\NNco$Olsfol<lolmLnf\@q) cflcn @cn
'c!NNO'cnFFLnFCOtJ.}r.oCOri o0(o-rOl(oOOtO(oIn@O m
cn N moOtnOOOcoOtnOOQ(o(o N - !n cn o o o ro c{ $
$ rl N -l Fl rl el cr.) Ft c{
Ft (o o rl tJ) tn el -l o ola ,ri 'ri .i + c.i .,t' .i ,ri oi o- N 4,)O5 o oo rtS ln U)ao o o-g trn3 <,o (E at f\ NN F\ f\ Ot N ro tn
.22 TvO io o
o ri rl j
>A tv
-tt o
\Y 7\ o
-r n vr-.l a\ ct) o.S o
=o o,4 ah s3 og o o
o-NA E @@ NT\ @ o o NN c{ CL at o .i-i e{ c o G' o AO N c! N El Ft Ft F.t F.l N g l l r l l l l l l l o Et o o
-ts o IJ G
o o.
$sf sf $ ON @\o IU Fl r{ ots cn ul
$-n tn<' r.o-4.
o o sl sl 3 r/) E o o o tr gs fre E
* ,eg -* Ec E.: -a t\
hu 35
^t: .E Ei n ocE$
.EE eE8 E *EH"
*c" EP ? , F E E .u 3 I : : E y r Ei ' i @
\o B\)
EclsiEt t,i**i;.;rEE.cE gEFflE$isFgFf,!Fsgs e EETeiEEEEE*i i EI i EF#EEEEEE e; s; e e Sur gs fr.8 ss (al E6
!gE;Ee E 5 s ^
9:: *: S : 6 iI . ..:' . .:r r 'i* 4.iq .i r : .io q.iq.iF.il q.iq i.il 'i.i 'i.i { 6B EE
- P E!i E:!i E::;iiiiiiiii!ii! E F E ffEEEEiE!EEEEEEEE S
N\ cn (O (n F{ (O Fl oococnNN Jo lq. EEg cncn$slcnm NFC!'N'st,<'
@ON-l cn@@o (oco Ft sE!
l \ \ l ol' c.i cri cri d d oiFidcd rl (O F\FOlJ) Orn aic cO cO Fl Fl Ncn sl o.
.q0 J1.
\i\
\J g NT\
\o(o Or{r{
Ol ooF-
\o (o
co rn N c! r-{ NN sri ' ooOO) r ( \ Nc! as F l d:
\i EE o.oE
.i.i oo' F.' rJi
(\ (n F\ co a{ ol (ox
\:f =
(5 F\ tt cn iir FtJ..)@ }\ -O
-aA mco rtj)r.r) , s l.r) cn (o
rOO e{ OrO)O rllnLf.)
'Gt rUo' Fi Fi ON t\ Fa ci c.,t' to(o N@ @N
=(J rrrO nn c{ c!
rl Lnlo c.i + o. o 8E od o6 o o E o-:
't 6d o
'io 6E r@
(\ NN
@00 o
sf G-j 6d rt Ol
<6 ,co sl O(o f\ -l E
o-: t @ s 6d Fl tntn LnrJ) or o) Or Ol EE
=l!
c{
-i-i sl rl
<l nn el st Fl
<t 9.1 O) Ol tr Ft rl Ol Fl Ol Fi
-i fY) o cO cn Nrr\ FN EE L3D Fl f;6 o
t mrnLn CO -l ot c\ o) c @@ o $tn o)oo(o q) ('totrrrrrrlJ1 $ Or Or Ol oioi -i Fl rl Fl Eg 9ao e l N gro
- o o
=
cnm!nNroNcl.rrnNFian sc!rnoNol-l Loololo$\o F m(ONN-l c!<l-i odod- oiot F.N+o q.oo.qo. insoor-
@otmn t.o- t.o NdcnQnco!ot"J NNrnN roi c! ONF\OO(oO
'tj)NLncncflN@
,.c0, N0o- 1(o^'q \s o EgE "i"i-1 m cO i- rn- N- O- Ft I el rl O'l N r\t cri ,ri -i oo' -i d
+r ri c!(ON td z 66 F { N si:
A-a : Y.i 5- 1 i c-g ssrsfc!rn NOI t.f)NFF{fr1 SNrf)QmLn ot N
!i (o or or o sl (o rn J (- -'n - (o N o F
N cf1 Fl
<- !n cOO o c\ N N c!
o e) o coN (Orl F{FlNOlrl F\NstOU.)NOf\'JfFl@$
!Y r-'1 sto fi;? E8
-(J cO cO OO cri F\ '.o
<i SOO(oO j'ric.l'd
@N(nFl j +
6l(OOltn
-iioioi NNcn.'l rrl-C{FlCOrn-lO
\$t4or$
.n1'4of F{
a ft.)
$d N r.rt r{NFl
-l lXd n l v -
Y t \ - ts\J o -l-lO)Sm F\ f\ f! rcl N (O !n @ O rn O c! F (O
- Ul m N (o
$ U.) Fr (O
Ol F\ cn N er rn N \q' (O F{
^l F\
N S N rt 0O o00 (otn st$orro(o cO cn 5 hoo Af!a SI NN oJrnc\Nd'oFo(oFi qcflmn (n
-{Fl @ -lNctl om Fl 0O-C\
6- 6 a-l Cn -l F{ $ l- $-\
-l (n LD IN
--l{-v Fi Ft rl C\
Y ( l t
. F -
ic o cg oN Ed O. 9 ' ao t
-EFE cn (n tn lJ) Om o0N rn rJ) e{
m@ (O sfoo(oLnLn@lJ)ol@tn o@(oooo$coQtq'lq) Or OS I\ OEil Fg F c.,l F\ c.,l c! ct!. ,
..'l ct1 rn Or rf) oid r u 1 g d
' F l '(oN oo' oi
+cncnoocn c'i i
<'@@@ol
.,i + oi ,ri (o
Cn co
-l tnO=
u)90 66 cn e{ r! fn r-{ H o ot treg $ r{ lJ) (o r\ c!@
.22 Es Nsf F r O F I
@cn r-l a!
>.\ E8
.go cn cn cn sl
-v IU Z\ o
-A \ J r-'l al ct) F\ (o (o r\ (F oN ( o
'ic .D ,tsf sl$
i6 'o r'{ -l 9?O 5o i
'o(o (o rl cO <l' t c\ t\ e.l oo NO
,oo No.
8.e r(ncn elN c! 28 Eo O) sl cn ON Et (n (t) cl Sf (O oN ( o
'ca g I r.r) l.l-)
E8 Ho G r.l O Fl N(n c\lsto (E sl c{ N t\ cY.) rl Fl I N c\,1 l,r,r'<-qo-e8 Fl el F I N bo tr (n oo co
@oo rn oN ONCO gs a! r! Nrf,sl
$rJ) OOtGI t\ f\
rn u') S'Ft i c.i 6j c\ 6 u! (!
;5 fl# E u 5e e- tg Eo1'l I -EE ;0r bS
(! ro o S.s ?s O r ^E H Y Hi.-$ -= FE I E 2 E F N3 :E E fiE rEE ! s uEE fi P h
.=6 E
uss^^6= 3: EafE -sfi.Egfl E! :: 5 aEat' P zP t q i 8E:: EEEEE= E t(a s.S gE FE ,EeE; 8FFF$ q"E *-" x;Ed; ,aEi Ei=p Fr?g fur: s.,E^ar6 t! B \,} pn= =i !"*FE8 a;s;.5*E^ i*c,tiA!Uo9eg-o,>EE9 L a Sqr 9.f *!c F-Ed.,oEEEFF
- iL: EiE* .oorE;;OE;;E E4EFoUnfi"l
':s Seg= Fg E?qBE fi:iilii=iriE Enqs*raigilAE:?=[g i .?
Rro EA tEpp E5 E--*i-Ee f;EHsFg$E-s;FEEs$gE*#Es.!-auEEBs; F F a i-". : : : F{ q) ss Q ) - Ft EF{Firie'{elO-tNcn$lJ)tOO I-i.j-r N Er-rc{cn !.rNcn<rrn(q\oq E.fldlAu'lq\oqqinn'"!'1nn O u) (as gdd"id"i A
'io S ;n.i (u-o-o-o
.j.r 3 " . i . . i" 1 " . r o-O-o-O-o-O-oCi<iCi "i "i":t :1Tt::1111s, 6ljli<iCic-o-o-o4!!-o!-o-o-o-O anq{anT I
-o IIJ l\l EE c-o o-o-o-o!
O F t F t F t r t F t o - F t F t e i c t o - d F t F t F t F t - r J F ; o - - t - t ; = = F t F { r l . < i - l F t r l F l r l F l r l e l O ' F.i
N\ sb tn!n<i EEg Or\tn F{0ON '
@Ol Frio sEE
'\\.i Fl lJ.) j-id p{ aip
.q!
,g R,
@o oO $ Or rl cn !n 0O OO F\ @ rl ri oO qoO0O \OOr -t Oq S 90 $ 4 !9.{
$\v sri E @slNNl'\Or-NF.r sfNtONr'tr'lrirtN SN oo,6 65,5 6 J
- r.
oi 6
!n$
cri 1'- 6 r.o or
- N -
IJ)orc! N Or c{ N + N N cn O $ -l Fcn F{ N Q
-J N or F - F c r - }I n Fl O (O O !n
(\ @ EE q 00. cn(ototJ)(orncncoN EH oi uioi-i+ddd \o sf o;m'"i; + -i -iui ++ol' c'i c'l'-i Fl'r-. -rl c\t 6: cO \ io X q oF r-lNC!6 \:3 = Nl5 S rJfo.tOrJ)@@OmF\OlrJ) (n Ol'} cn N
;EE orrooc!or@@m\orn(\l slF N t\
h lllNNNN(O(ntnF{@f\ r\ ln Fl @ r t l l l l
'tr or- cri i'/i d + -i i'ri cri,ri qt N Ncn (n rj) el
<l'Nsl'(oOr-Oln00 SOI rl Fi N m dEE rtNcnotNOrsfcocn c.i ui Fl cn N pq ed NF\
o6 r.{ r.l rnru.) Efi 3s c\t N o6 '6r@ Or Ol Efl G.: 66
<6 roc{$tJ.)f\rt lJ)OtF\Nsi.n c\,1 Ft olt N nF!n\oNsl NOOrl<t f\ an Fi N \O IJr.) F\ l r l l l l l l l l l l l l l l (o
(o E'fl .i d cri c.l' cri -i oo' r.i j .i j 3a Nsl
@F (\
ol or st r\ Or 0O c\ (o Oc! tn co t\ EE
=ll
@tn
+ ,ri tJ) c.i cn co rn c,i t r l l r l Nr<-
ot cn 9s O! Fr cO cO O sf r- t oO 0O \9 cfl O cn N Fl ri N rn C! d sf -l Fl Ot tn Fl rl o C\GlClrrlrlrl HE b8 6(J o tr, c o Eo o6
!4, o Eo GI E
(nFiOlc!9(oNr+N\OO el Ln rn @ @ rt') tr Nsl-strnNmotcosl ool ro 00o CN tn00 I(' crl -r o- q ,4 0o @. n 00- (o- !q t/) s t t r l Lnr(\ q) -ic.i
+)
rv E
- P cio E F l ( n F l F I F ( O N F l C n a { N e i N a!A
)l f o.=
5- l i (YlF{OlNSr'Oa{rlF Qcncn $ ri N rn cnOl rl cn!n Q Oq S F S 0OcO I oOO m @cn qQ S
- ! r-'t
+r-^ Eg r:6 N$sl'tnc{motco<l-mFlOOrLnoo@ri@ (o ln 6 :
6cr; J r^.ifrj d O n
'rt
- - =O m N f- -i d \
Nc{sf cn (n N Fl sl er Fl rl O) IJ) Fl rl el Ln eltq 1 a l* g' rlCt.)F{riF(ON r!NFtf\ F.l (n F{ r{ c\ tr 7, cE 6\V-v t\ ii tsv o f\iFiCn$rlONm Fl O) mri@frl N O Ln m (O er N (o o N cn !n (o N lJ.) cn N Fl rn (o cnN o el (o 5 bon F-rsfNm or---cfcncn(oFlFlrlFl OcnNmOrFf\cnrO (o <l co(ocnNdsf@!n N ( O Fl- C\$ Aala cri oo' 'ri oi a:'!= G o O C! ON Ec g.O9l f')dr ' E
-EflE o cncnN cn cn (o NN<I ogfi a O =
l./lao o o o! Eag -.tE r!@F{f\.ncncn<lC{
\O(OF{Olcfl@$OO C\N q0oct.i(\tot(\{
.22 -< w, oO io rl lOOtNri (n cn
>A
-Y
-o c\
A LY ,\
\-,
o ctt f\ LO Orl F
-a\ r't Ln O) rJ)
(n cn $ N 00 (n E g.q o 9" o. t Ln\OmOle{c{u)m(n ol ro s cON$O(OcOOrrJ.) $trl Le -{dq,$-m,,D. r!rllf) 28 go CD cosl_otLncn@otfrn $cn
'Eg NN(DtJ1@ornrO
$ lo- -l @. .f-N!OF.rO
,.o- -N -s f
-s8 to o.
$rJ)slNsfNotF.{oN@ rnc{(o c! sf N o cnN O -l l> QcnQ d 0o(o q! s \o or q99Q cn 90 Ot
(! Indo.tU.)sfr\ormr\N\o 6NdJ ; ! o +- -i r- i' c ! N N F$ I=: -r rl m O r r . \ l O c n r - r O o o < l ' or0Q Ncn
>e c\l ,4nI cY')N iliri;Nc'i rnO-
\ -l P8 Ln (\.t rn S Fi rt-bo v.
NNNQOIlnrnOIN
= J $riF\LnOltnr'{F\N NFirl 3eiO.
U8 6o 3. Eb&= "Eca FP S.s EEE: ;" = -EE uEe. =ss f E**5n EEpr^9"lE E 3 =EB-s
\s:
1., B J<r EE gE+E.tEi* ggtEgg$ ' F{5$ El l\(a
- s. ,Q Ev i E ;5E5E.E-asg 6$Eit#E'sss*
$! EEFsFEaEEg EEE :i:$eFgeeg;;EiiE3EEE i Sql ES xa E6 .3 ES Q ) o ' q: oo S Ft E H
- t=;;;;=;;- i:: *.=**- irr**nsins:;:x;:;:fir*ilil "E
$ :iiiiiEEEi 5ii 8iiii s.!E!!EEEiEiE!iiEi.!!iE!!! S
N\ ot$cnLo o sb I EEg O) -tdstI\N qqo-oo- q sEE \(o r l N C \ e { F l OrrnOLnr.o ai .or FrNsfm@
.a!
.s& \ .i dtnolrnol \i\ v <l' cOFlcnOlOr O O sl' $ sll I OOrsl'(oOr I,O O (O
!n Nc{
r r r r r r l r r l F { cn N\Ocn(ON rJ)NLnr!ln F{ N sl' F\ O F l r r {
.i 9S CA:
\n EE oE
-i F.'
io d (\ c.i cn 6l N (n N
+c.i+
cox \:3 = bl5 a'l S elr{(ocnoa{c{FN sl Ol
;EE Oel(not\ou)rntntn F c!F(o h lh,+,iyi=N-','6,,'oO,,r,0O r-l It\oJrU.'
'io- d oi o' r.i + oo' oo' oi oi N ,ri oi cri
=--c!@cn(nr\N @ (o (o (\
a) dFj Ol -1 N c\ F Fl o 8E o6 o6 8t aE -: 66 r! o6 Ol Efl o-: 6d 9(oN ss cn co Ol
<6 ' l ' l q \qo c n ( o (moc" no rrrrqtrrrrrrrq O) Ol 6 ri sf Gl cn cn Fi 3s Ln rJ) otN(oFOl ol @F O gE rn NrNrn00 (n c{
oo' rn u') oi tn oi
-lFloo
'(oolrlJ')
-i c.i
=t! Ft f\ N 9E
'OeiOOFtri c Fl sf OO @ N .',/ $sf o rulru.)l (oc\
Eg -i-i N
;8 o
E
@oo N @@ 00 N c NFOrF\stnoll l l l l l l l ' l l l l qq ct c! r.l F\ N o
cri Ee 9ao
\o {.o cncnm N .i oi gro Eo (E
=
NF00stot ri 00 Ol $r\oOO$'.oOr@ tn cncnQo0q A -lO sl Ou)0OOrFi c{ o-- o @ 6 6 o o c o o o s f F\ l-l-)r\NfioO o NFIF\ F @ Ol
=(,) F l r { - l @ Nrr<to F 6 f- 6 cO f- rl l (O st @ -l Ol @ (O 'Cn@rFl
'ri -i ,/i v
+)
CB E
- P qio E riJco ct1--t N F'{Note.lQ
-l NFIJ)
N al rt
}{
.1 ii 5 Y.i EU Eg N(ONF{()oSOtFlOr@Ol OFI!n$(OOtOlFlOFOl st F
+ o tJ. O @ cn 6 st (o or @
sl N o) tn 00 @ F N sl co tn co N o N co cn tn Ln rn stF.rO$sl stNiFrF i! f.l ^ F$ FlNFicnNlNOO) 1r .t\o.m (O- F{- cn'
\n c.l gl
.(o N
-c.t-r N Fi rl oo-l\
ao Ol f N a Ol NmOOrl U) {r {.oe{F(D(o m !n
!D @cocn e l N N Ol t RE i \ v -
r{ v r\ -i
>\,, o OONCDLnC! cn O Or N(Oc! F\
F{ c! N N bO rn (O r\l N tn sl o) O O Ol
<l' F
ro Or ei O ol F ql sl ol I O! (9 co r\ NCi(ONO cn (o co co 6 hon e{@rY.)t\ft.) ONorFl'N@ j j NON ncnii O
$r-tN(nd -tO-$-ol ,4 cn (o
--A trc E +d FINNOI cn e r.'EE o f\l q cB oN
= O) 'r{ cr
+a-oo
- E'EE c!()u.)6 0,
cn cr') NN
'cqcq ,
tJ) f\
-Lo F\ 6 t rn N
\t cn+@c!Frc!(o$NLn(o O O
<l- \O Fr cO rt Ol m er N (o'O OO r.O Ot ol) ql N
rJ)
-l oga - - (n rncncr{er(o ic.iol'.i iddoii cri u2o5 o (n u)90 o ()5 Eo3 ls Ol @sf
(\ F F.l m(n d ool
@oo sl' Ol (o
.22 -< uo 9 rrrrm N ' C !
r ll rl l r rl
>A -o C!
N (\ c.i iv
\Y 7\
Av o r.r)NOr@O (oN (o n Et rn oo LN
-.e NNNIf)O rFl c!
,roo-o.
E'; o cY') art v, ,^ rl cn Jo5 o 9-G E cn Ol cn(nrntn ln Fl CN cn Fl c\ oo rnNc{ (\ 8.e @ N I N
,/i t r r t l l l l d
28 Eo In rnrnN F\O Nrc ct) r l @ cocnN NC! rl
'Ea g l l l t l l rl Fl el E8 r-l rl Ho o-f! c! rfNlnN NNFlNln 0O$sl(oOrcnO r{$c!FrOO IE tn-lNcnln@O @@ Noo o @
)s Flrr< ,q,O- l l l l l r r I O-. C! -l C!
cYl @r n g8 (n ei c!
.iN- st (o t\
bo t F el ei N t\ !n otol(o(o @ g$ N rrrro r l l r l l l l l l l l l l -l j Fl bo3?; E-Eu:i
.' 5E E E ; E; iE g g 3I :
F 5.s P
=
E - t ! *=i FE
=F t! , *EH E E .
E h *E F =- Ec
\
he hS) E$Ec E : ;;sxq 3 i.EE"o s Es 3 Fi : -Es YT s+ r=o r'Q iee*=c ; -E::?! e' 'EEi s:Ea-;te; 3 E r;;ir s:FF: s i f i*sp; ,"!-e;ia;gpErEB;cEEt 5 t E xrrrce i gv Soa esx(D Xa Es!!EE E3 3$r;F3 EEEFEFFi!sgFEg;Hs: E E i EE=EEs i ds Bc x+xn
- s ..-e=:e:es E { Ellllx .i
' o! ol ET a:) c
$ilrf l : i Friiii ;Ilii:i:ir*lillilr F E s F:l:i: s
N\ EU ir EEE cri qr s[.
.q!
sgE
\i\ \.'
$ i l g 3 6 S r A F $ S E E E S E 6 G E E 6 E 6 H E E q g h s s f i { E s E- E 6Ri r. S qfi gf; 3 3 : - i . : i : ' : : . ;E L
sri 9H cA: g J E 5x-" iTi:-- 5".3:-F3- - E$5fr:-*H-3.i'S*r. * 'i
\i oF \c xo x =
bl.s sl(n(ol.oONOelcf) \F NTINNNcocnF-{coNsl'olcnft@$c!dr\lJ1 sl@Fq\
;EE N N st-tsiN NN Fl !not@ 0o N olSlNQl@s sf o $sfrn 0o- s- ,cq ' 0o ' N ' F\otrJ)or\m irFi'r{(oor'cnr!(ool tcrr\\ n-1 \orn
'=o- -l \o ooNco rio !n F.!rt oi ri ic-r' ridS-<: r.a oi d cri oo' ,ri oo' Fi cr; LnN$sl-oON-l Ft nFf $- cl \nF =i Frl nO F O r. l - l F - \ O @ F T n N N N N ' . O U 1 tn S t C \ - l e l r ' { F l \o N lJ.) -l 8E o6 o6 th o
E sfl aE -i
= 6d o
(E t r 6
'tr m
8t (E-: 6d t\Ff\ cnoNLalos
<6 @C!NO
@steiFl r\
a{ cnoro 00 ' N00 I-o(oNoo(o
\t I i , ,OO- l l .r O-,f)
OrrrFlsf\O \ Efl Fi F l - l S 3s rl $ $o)FlF{ oO(D Fi OOO r\ a $!nq!9Qcnco OrNO)O@OOlcn$ cocftlJ.)coorrnm(c)m(oorr{(o(c)$f-Q(.oN(n LnFiOOIONFOOTI ofi O J' rONf\ l l o.r(o' Ft @rnrt' O'r' < oool$Flcn $ ' N n q'oo$cfloo-E.9 -r. oo' -ii <..i -i .i-i .i ,ri .ic'i.'l'c'i.i NN$-l tE F I N F i J oj
><)
O cnN SI (o (o NN cO or rn C Olsf,U1o.l f!N rn o) oo (o o I N I N m rl Fl C') rrrrc{ HE l . , )
*6 o
t c o Ee Itt 90 PO (E
=
(of\Ollnl-r)rl cnrnoot(or.o (o \l <l st c! tJ1 <' r.'l N tnslrn<'lJ)r\ Ft f\ Fl NFisl' F-@\9F{ F OstLnO@@ N I.r) cnotsfsto(o -INFOFIO O
,.=t, mO-r$Nft') <l- o) oo-nq ' co'n @lJ..)0r@c{ +rN'0Oo.t,dFrO(O 6l di ,ri v
+l CE E
o E do E cn rfr-{N-a!
.a ll =
\i .;
iu Eg OLncnF\+$LnS-LnF\oroF{FO(Oc{r\F\Or!ncn'4N.ricn$9St(oq?9!q\F!9O'f9$$ry'f}tnslNr\ 5
- ' cj+ - b + d lri oo (-o r \ c r t N r r r F r "c 'n "c 'n o ) o r $ s f d ' i c i 6 t o N J l-- F O r-l 6cl - tn O ri a 6 c! rr sf (o N 0o (o Fr
_sri^ u)? F$ ;6 il d-t cn { X m .ri < ol' : 6i 6.+{-' d ;- c.r-M + {' bo Ln 6 @ N + d r! 1^ co o) c{ F{ -r o_-\o Ln h 3! v z\ -i Lv o c l l m ( o 5 - r t $ F t F { c ! c ! c n c n r n f \ s f t . 6 l s f O r . : t c . , l 6 r r -N t n Q q Q O t N Q g O t o Q Q n o c ' ' l F - F- l6r 6OL$nF<Nc(no N N L r ) 0 O N ( O N Jiri-ci'ddoOm,.o-r qr-oj- AiOJ6iJ+606- FFr(nFtrfl (omNcotno o boQ AA-S - r l F f O O f ! $ - - F l F l - f - t ( o - l O l - l rr
--l{.!v E
o o
=
o "'E cg oN o.-* tE fr:
-ElE o OtrU .C a o o r)ao =
o o-c cn (o cn Ee3 o
$o r{ Cn
$c\
@cn rl F
ml/)@ f-NOl cn(o (n I cf) c!(oo r @ F - t
.22 -tr.
<, att c! -l rl F l F . l r r r l I
>A
-V
-.^
LY Z\ o llv F r-'t E Ococnomrn Fr@ cnco$sfO@ sf cn Or Or Ln Ol SOtOtOlcn st(osttn n ct) l/) (oNN Fr !n Gl cn@cnoN $@OtN oo st ..1 N
-.e O Or !n r-l f\ Ol ItFIN Sr{
!{ .- .^ r t r r \ r F l F { r! -l C{NNrl ndO.reirLJ.) j 6iifr NFi
- 8,q o9-a cn (o m s t-f l c o t\c{$(of\Orl -N- Olslsfsl erNslo(ocosl-oolo E H ln K a\,1j F.t rt d ci \j
=
O s\ Oj if nn oc nh F l N N ( \ n NN Fl r F rt\ \ rf, '
< O) Fl 8.e l l t l l l r l 28 go sroNN$ Ort\O OrrJ.)lncnN o- N cnsl00mr! Ore.lNOcn-lcnmcn Et H N( n N H ""- "'ii i i NaFi I:
N C! --l t FFlr rrnn ssf r r\t rrl Ft Fl
'ca g l l l l E8 Ho o-
@OOcOcnFl e{r.',1@F{cocOslON,.11tOOOcn(.9ql<felrlN(\N(glggO(C){-'tQ - O < Q ( o t \ ( O f ) N t / ) c n c O O O l ( O (l toSo r o r \
TE F
' i " Ns Ft c- OnN - { c l -l tJm. )- o6 r6). s+. Q s t: s- <t V -emt cd \col oc ! F rLFn r rq oc o! r nr iN c.,l(eoegNod Uai\i ki <N i'rl N Ncn!nNoro QFot'Ji P8 ---c!
bo tr g$
= s iY s"* qq g c.o^
S.s ES a E** * *i=!$ E E $e.E-EE. Ee E?,- .,EEri h$ i{ Ei!-.:;:g*sq cFEEE;g;cq+E.EEE
\o ii; !s EE,.EiE'-5;;tEE,cEAEi;n**==:E+rs;EirEEF;bE!iE i
L,Q B\J Sua E*;EpgEEEEEiaFtEE;EEitaAFF::F?:$5s6E 6;E;Y::XXX;XX:JEEEESEJEESSSEdET*;**;SFEEE9E:!EE
!sgEiFiPPE9::si EOOOif U.j Jd (fO(J -'J 6 o o otrtr EE l . nr ir ii E L (, r r - r - r i a:
$:E 9r :i -. j .*j -. ; -. . i 'ej - i= :. j ep :. ; . F. i . si . . iF. j :i . . ip; . ;R F N R F. i ; K R h K R s 6 $ s! i i! 'l1s E n s s e
.i.iF;in.1 n.1 nn.1 i qq+
nnn'1 { I \ qE n'1 n':n nn'1 q n q fr n'1
.l as EE EE xiiiiEEEEEFEIE.IFIII*EE*SEEIIEEEEEEEEEEE:FEEFI-:F.: H
N\ Eh EEg \oO aip de
.qt rB gE E q" ri g NcntnN@@Or0O(orimOsi
@$l.oOrslOstmNcnON\t O
rn m$l.l-)c\r oc!Lool @ ot (o Cn U) tn Ol ol rl 00N sli rJ o l-rq'4 nn\nqqno- \! n (oc{(osl N NeIO O-l ,N QS q: \qto X EE oE N lnSf -lFlslr{rnFlcnC) N (I) cn c\l c.,t' oo' c.i cri sl tJ) oi cn st c.,t' i F\F di \x =
- 5 S\ @rnFt OrNrJltnc! c{$roc! Ol oo N (o co F\
;Eq
'tr o-lf)l'\r.o$$cn$ol o.
cnlo(oFloroomrn s:. .1 ' ' qqaoo- q
',O s' c'J m Fl !n lt oiddd 6l
+
OOrtc{st OOf\rrf\'<' dd
'.o(c)cnOst d cri o nHE oNrncn co Cn N F.t rl r-l il lO ft.)
r\l Fl Fl rl O) ri -1 cr1 '4 14 ft.) cn {o rl t\ sr sl o 8E o6 oE s f-il
.E 6d o6 E
o -,:
'l 66 t\
<6 oorf,Oslr{O..{cn
\oLl1costF\coorol
-ro-,4 o.ot$\
t\ Fl sf N rcn O) Efl F{ (O 6 Fl Ol (o rl 3s 6l
$ N oo ('rr\OO Ft oOOScn $ oo ofi (oNOlslclFicnN(ooft.)O OO NtncnNsF\Orr.OOsl'tn o- o.
E .q) 'ri .i F.' + -i 'ri $ ro (o 5t! c! 6j
>o g Frn cn@ (o N co cn@oo o Ol tn tno sl sl@0o
, N r(\rlr@ m(o,(o Ee L(a Fl l-O rn(O@
*o 6 u
sst $ rl c Fl rl I r l l l l r I r l l l l l l l l I I I qq rrrrrlo. o Eo OO s tf) tJ)
!al,)
9)O E (E o
=
sl'OF\NOl 6rncnOlcOFlcOn ooooN@Frerl-cocncnFl$oto!n tr.,r F\stNc{SocnOr-lFit.oo\N I I rnLn
.o..o-od (o, cncl
< o^,
sl' { t-9F.OOOt.oc\ct)i 0 oc t l o l " r a . n
.o.
N Or rl N-ltocYl =t .tlOtN=l ot a?' O u- E z gE lJl cn Fi ln (o cn sf
$S-l Ncl-l(nlnu)C\tsl
\Y a! ,1 A!
}t =" ; < 5 Y.r E:Y Ur-'r E-g $
N F\ tn Or$ O cn @
!nN f\ {,O c!
LnC,N N orl sf ON
@ cn Or o.l Fl rl cn d (OOl m sl-
\o 00@ro 0Otnst '
co rt rf) .\t sf Ft Ln rj.) F\ (o 00 t\ cn co el $ O OO \O Gl cO rn (n u) ol o $ (n Fl Ft tn fi;a E8
-(J N NOr r-lr!F.tN.-i(Ort
.i.ii,/iqt st cnOlN<t (o- cO- ,4 (o sl f.r sf O jd orr cri ln O
rn
@ m
-ii di'ri
-l N O O
'ric'i++
\O s $ F-J ri o x 2= E tsv o @ F{ 00 cn o 6 c{ cn s cn @ .{ ro Fi c!
(o IJ.) f.r ol (o N s cn N$F\ N(OCn cn (Y') N rn tn d (O cn $ (o m lJ) @ N N N N Fl Ol Ol (y) cO lf) -l O'l 0O 0Q @ \O -l 5 boQ A{.t^ sr cn sl c{ FlFiFl-{Nc!r{NUl m sl N N r-.r ot o) $ oooo\ I rl !oor Fr F{ o
-i N (o Lo d m (o todH @ Fl dd
\- .-H,N,!Y' E E q cE 6N
= q)'icr TE fr:
- E'EE 10N@
sl C\t (o cnfi.) Ft\rnFtnNtF fn(o(0601 $ OEil E# OO j-i NC!rNNrilLn0orJ)O si+ -id +-icri+ aO= r]C)0 66 st s!- -l o o-g Ec3 (o@tn o orcnFo) <r ooq9 ro ol
.22
)ar
-Y Esa8 mNo c! rJ')
cri
=Ot-c.t@OOO o- n \
slNc! "4'4
@O roO tY ,\
A\J o s cn cf) n ctl N
,!1
@l.OclorcloN m\OFr(OOIN N crl co !n cn c\
ormcn Cnrlln N
\t \t 89" F N g6 -l t
rn@@@ an Fl E oosftJ.}rJ) NO F(OslF\ OcnFlLn (O OO O (n r(\ st 8.e r\ (\ C\ Or'crlcnN r.l rl 2 go 8 S cr1 Ft Cn slNlJ)ONoO s <f,6 Et
'E'e c\t sl t.r) e{LnNelol$
r{-lN cfl r!tn
' r { r F {
E8 Ho o-N(O(O<f,NO$NOO\OtnstFl cn (oOOq) O 9\\ o $ tncn In(oc!r/)c!(otl1cn o oom$o sl I"sn
>! rl NN NOl .n riN @-l -1 q \-lol n
P8 6rlFlOsl$ d C \ bo u r.o@@c{ N sl-NSfO}NF\ g$ (O l.o (O t r l r l l r l l crl c! JFIFI
.s !F
.rE E
- a # E EE*".*
3o E$ ? s g g . E E gE,Elf i=* cEE sEf; l E rs ssf E=- ;EEi e;p;y Esr*=,r h ti
\.a s.-Q I Egg$ EcEE ,Ei;$5 iu,*9CfH Er fEeiIEEE;gE*- EEi;EEg B \/
sbr r:S F a o FS x('
;a Q ) e 9;
*ii.;$.};ggSgSgsF
!,orroaqenrf EI==:==::::::-
mre i ;;C:=
^
E P::i-EgEE pn^rnqur EE:gEEE p'1 t i A
=i rEt "r",nqnc':cqi I EEIiI : E:ii EITiIIE SiIiIIiiiii ' o=So EE oc Fi!!ii:iii*rii F
N\ olf-tNFN Jo EEg Nr\u.)rnrn r F { F C { F l F t \g) aip
.q0 5E 5sE d,ric.i+
cncoNs9 cn$(o$ d d
+
s- '3[. \ rs OO rl \l\ v g (nN rt\o(oc!flNOOI Ool mootn$tnlnmN 00 rn sri rrNlJ) tn cqq qs- n '4 rl QS q: EE oF cfi rl slsl FF\
.*l N IJ.) f\
cn \: qoX rJ) \= =
- 5 (o S\ tt roo (n NOIF 006 @ N(Ocn
-O mLr) stcnN(oto(oo)l> 0O c! rl h -o rFc\ ot stosl (o(o N @ o{ \o.
'Gt (r, o) +oi NTN cnc{cnln@@ros NOrOltj)rnco Or rloN cfl cn q) frE o-rl CY1 o,l' d
F i C \ ( \ S cn (n s4 od o6 o o E sf Gl.:
= 6d o
.E o 6
'tr o
E o -,: f 6d t- N @ cOOri FFOrln Ft NOO
<6 CN (o In (oF sl st oo c\
'cnN Ol Ft r N q ro(o ro(.o F cr')
Efl cri Fl - l F I ( n 3.1 sl (n@^l rnlnSrl tnol!n oo@ cn N EF
=r (n 0O Ot cq of N N C N
<-r $-
9s F { tr (n o rn Ee L g D c.,t' f;6 o E
@o c! \o (o
c o) co N I N ' , 4- lqN Ee 90 c.i (o t\ ln qro Ho lE
=
rJ)Ordotmcn co (o ol sf sl O! F F{ -l @ Lorl!noF$\oola\cn i (o sl-@cocoNs FrooOl sfstOlNei-l cflN-rtnstsrnsroo ru.) ru)Nm$(oOl In lJ) sfsfNr{f\N (nl O N on 0O-$ cn r{ r\ a1 i(,) j c.ic.l' + .i E
- E E f\ Fl v NcnN@NO. Fl el
+)
R F{Cn(nNF ri Fl
. r Y F ! A cio l l l i {
)t 5 Y.-
5- ; Gg mOrOlJ)O)FlOrLnFi cn {o ol ss N F l r l @ rn (o el Ln oN$(oo)r\m rn$sf!n+oo bY r-I m(o(osf,oocnmcno F{@Or ss N F l r l cr') CnNrl o-q Ncnoo<f,cnF..{N _tJ V) +r l{ f A - p F$ NrnNlf)Ncnsdol c'i o,l' cri ..i oo' oi Fr(n(nN c.l' rt tn qq NN N F N
+ j.i - i d ol^ -i lrX6d x a\v-vz\-
(OF.{ Lv o Nst\tNO)f\$slF-{ (\NOl Ol Ol Nrntn rntno (r1 ONOt-l rJ)cnLnOrNrlOl Olr\cnft.)O)Fld(nN OO mOrOl N F{ 5 boA (! mF\NO$ r\ d - r.o ro o) cn (n rl (\ C{ Fi
--A f,o i+'rid S
\J h'EE q cg ON E.9'dt dOo6 "EEE (o$'.ocnOslUi)slrn (o (o Fg sfolNFro)-lclsl'oo rt F{
otslNNolrl stocfl (n cn o u t/ roa=
-i c.i.ioo'cri+ oi 56 J F I riclct.)o rjao :
o a)5 tra3 Ln !n E* Fl S lJt
,, ,R S sl
-H sl- OO
.22 Fa
)a 2V w Z\ o AE AV F{H rJ') LNFN r-l Fl sl F cn cn A ctt @Ol cn cn Ft cO <f st tr sl ' (o(o NC{cn 8# c\l g6 Fl rtr-l rl qt (i') c\
Fl Ln Fl E N (n cn OF\F\ FlFl tnln Ol co sl 8.e rr,u'). N 28 Eo rn OrO(otJ)tJ) fn Fl o0 sl c\ Et
'3e r F {
N cn J Fl Fl Cn ft1 cn F t ht t - l F l sl-E8 H(J o-IE
@(o st(oO lnlf}
N
' v Nt .( to r l N N
g8 F ct') rn G I N bo t s r\ co cn cn cn r\l g$ tJ) r(O s r\ NF c! ilge E
= E
= E E ii e
- E ep "iE Ei An
- ? E I s Eg gEtt ES S.s 5 E,g* H i^E-E E : ii, &< ? : lEE E
cr E! iE EE-,?E: hr 55
;g$ uct ;EEiEsE ;E g;sEE 'EigE Eu,'c,ii i: \a Ls B\)
Sua g-Eg8;i$Ee is sEE I E sE ; EEE EEE:EE tlHF59;E g
.;r 1O xa :B-rs$siH=5 F - i E" F
EE FSF33i q-'- =--
$ 3 g: grEEEs EEEs.EEs'5 s.3 t-'-"'"'--"'
trs
' a! os EE Ft !!!Ii!:!=
f*RF*Fn
.* g E=latit Etr = i *""'** Eii:::::
4' iR SRFR 8rx x i Eifi EfiiiI E:"ndiNnn $ N
At\ (oorslOr ONN$ S t\ aiv EEg LO Fl
'<-NmOst (n e{ Ol sl sl Nf!
@c!rJ)(O
@(O-l (O Oltn sEE q s + d oo'oi .i (D (.o d ei ,ri oo' sl r!
t-r)(oN@ O) IJ) C\i\ \ $FFlcntn
-lc{N -l rl t\
c\ 3qt ,n9^B (n oto - c{ oo sd N N (nF rl ei c! ol t\ rl Fl FIN SR F. oo' oo' oorl
- E coh rn $$
ri Ft Fl crl Ol \x \q F F { - l a Pd F c\ { NNbO rrrrO-rrrlO.O._rO-n sr N rr F\- f\ F- O c\,1 cn 00 a @ s c{ p4 o6 o6 Bf Gt -: 6d o6 E't o-: 6d riS $sr sl
<6 - H rrrllcr')rrrrlrrOO
!n.' rn rn NN 3fl Gl -:
Fl l/) t-r) r{ 6d s cn c6 N sf sl Ol
='l ro 9E r\
C r\ o t\ EE to si
;o 6 tr rn lJ) \n ln NNO (o s r!NN c
o r N l ,N N (\ F\ rlrrrlrrrrc! l ffl Cn 00-F Eg
!lo gro Eo GI
=
(O Or(O O0Osf OOFr \t FN FtrlOlOOlONlJ)OO9l-l-QcnO i-rr F666-tm 6 !NnNo @ C !@ qQ ONooslr'{C!<f!nO rn ' rl r{ ' (oOt,O.qn ,4 Ol Ol irtc.t mcOl- sl(o' on' s lo P n N Ir \ F AI
.lv
+)
v A Et$ J
-litn(OmO (\ rn
-l-t m' -i oi$do-rl o^
cO
.i Ol cY-)
'-Y . l
_ _ o{J Ln ln sg (oOlcl.r@l-rlOclosl'corOoi) N^F (o(o -l Fl o'oqloc.t4'nQ\oe)r\F-Fr Ji6 FrF- il6-co-roosf 6Nrnoq-{q0rl cn to
- r-'l OONoO(osfFtN$NN Ol slrONcn f\Nm@OO O cn
- a7', riNF{N r-t
,.oq(o-qs-Fl l.r) rO rY.)
f!
\
O cn Fl -l F-F-o;oi c!c\\1 i.i mcfiF "i
.i o,t'++oi rl
-i ft')
9 O u.) h 8! v t\ '.i r.o O Lv o (oor$Nor$o$lo$ @ rJ) Frrt !o(o sf cnNlf)$@c-lQOqghQ!-.lm cno< rnLnNdcel olo0cnmrn rl n riri'-ri 6l.o 5 bon Aa!^ sfer!ncn@lJ)cno!nst FINNO)OIvt sl NC{rtFtm-t flc.l(o(oslq'o. N $
--l{av Nsl c.ic.i R
\-) l'EE q c! ON
= O).-*
t6 a:
-EEE OOtnOlNf\0Or-lNO(o rOortNsfu,)U1\OOt$tfi(o r.l
'b rt
'-.i rnrn 06 rnu) 60 sf f\
+N
@l'-qlQftNcnoo!0(9 tn\q!9'o'J)={o)o!o Nff)
N@ oEH F# $rt oN .n(o-oo.q.o- q J Fr 'nrn
-N-
-=
J; coO cri I I COtnNc!
-i (oOlFl iSdiol
.{\
l/}01 rJ) l'\ a o = l,)ao 56 F t F l \ f ' . O @ o : l
- d c\
(\ oo O (l).g tra3 F\ f- N@ Es rl $ In c.t
.22
.66 d)
>A
-Y rv
/\ \_/ 7\ o Fr r-l a\ ct) 00
(\ s Ol d 8# 9io rl 6o i Fi Fl Cn E sl(o (o s 00 8.e c{ oo' 2 go 8 (r") NF\oO ct) c! tn
'trE g $
a! E8 d A Ho r\ N (o r\ O) (E Cn rl to ro cn rrrrrrrrLn LN
># rrrrt4\ r r r r l r l l l l l n
(\ P8 FtN (o bo t Arn $ 00 NN sf Fl g ze
*5s 6EE E 5 g e E ,g E E.* 5 - !. t i; i aE Hc E u E ES fl e" u F E ra *' E5 E .iE A* - *H d b:
s+ ? : ;n E5,* Ef; EX E $-*E s , -* g
\o Ev
- axss sEB c E g !;;f EfiEEE!E cEE e5E siE;,tgEE,aiE=ifE E.Hfr;.iH$gE"*RE}I E Sqo
{,Eggg6EcFEI i E r;f R{o x(a a5': t(a EEEEsEssE=; 4d!o<(Jd F i tspsEss+Hs?EFE*.i!gsES;xgg E o a trs {n",Eiiqicq E !." *" !. * -----cn.-dr E ca
' (*aoS EE Fi:ii;:;i;i ; E 5::* fri ixr Et*ixxit*ti***x R -E N s
e\\ (o(o Q\ ^:o EEg rn u) 5$ el -l c.i \ sqt ^9 ^B 5sE tf ri N oo N c\l N t\ lJ1coo:t o <. I o Fl o cn\o N tn d ol m o o \9 (o olr tn a cor{ o
-r u-in S o<i -r,to'o;j ii N ro Or(oc.l nt rn rr rn N cn r- sf sf !'CJ F{ co @ q) d ln d\J c.i 'ribddrn Ntirncri iYicd66-e.itoadbS-tJi' o+-ro t0O rrO I o'r Qto'o SH .o'.n.o'- j ;ro'j -. ;' +- o , t ' o o ' d o r ' o ' $ di \: crioic't Cib u)FiN cO cn -lcrt c! Flr{
\: qo: Nr{ \x \e F<
;EE
'lo-q) dF=
o SE od o6 A,l G'.: 6d oE g't G-j 6d
<6 A,t 3s 3E
=tL 9s o) or tn cn Ft s Fi N O cn (O m N <l s .-r m o st ol o $ Er qr Fl o't q\t (o 90 (o F cn ol o g) c F + o- i a ; o t \ o L n r - NF b C! ' AQ o + ; j F r < J J r n i s o' r c { -r ! ( o o c n i + 'i-\ i -
J s fi in fr ;
" Fi i6 o' ^i .l oi io ,4 ' ^9 o t Q N
{ \: a 1 ? sf 11 He LO "Sf . ri rl cn N- Fiol
-l rl O
'{
< cO sf fo ; 8 tr s
c o s Eg 90 9ro Eo
.E
=
Or Ot FN et rl
=o v
+)
td EEE z.;d Hi: rAX :
'5; Y.i
- E.g otor Ln cn Fl s e.{ N o cn (o cn c! $ j el sl cno $ ql qo $ i Q -l q)
Jtoro rnF !--l (oo' N N Frrt r\ !p \ co ol$Ocn NOoOFT
- Y r-'1 + r n F - s - r - r N - $N; ro; r N . ' t \- o6 @
J'm <i\iF +Oa 9
- 1o nr o fi;? E8
-(J "$ l { \r.tJ JFl' i.i cO niqorNFrotlc'l Gt Fiof F.t "rl l l N
$ sl N Fi
+
O)
"ri cn oo' liX6 6\V-vr\-
Pv o io ri N ot s c.,l rn N N o co @ (o F N tJ) cf) ot (o @ Q O) oo N In OO cn(.ocnONF-O ON(oOrst$ otnolt cOmer@
*rncoli l.oF-N Nrl coC)Ftcoc{u'}rl 5 boQ -o tclJNsicnF{Ntn N F\
6i til.o ,n ,n o-rl A ! a c\
--l{-\z
( t . F - v tr
! cb .o .=
o cE ON E-9'at o C)
- E'EE cEC)lor^
bg (o (o r-r) rn F F
@Orr-{O to \o
'Lnsro cn Fah o
' rlai lO =
C N T N F l'lC)0 66 o a5 trn3
.22
>A
=
t Es
.46 d\/
rv AV Z\ o H Et
= 'u,6 s A
q, tr o I alt 9io o 6o i E 8.e 28 g(J El
'Ca g E8 Ho o-c! U1 cO cO !n \g'c) c..l lJ) O rl @ $ ql tn cn f\ F -l Ol -l el !Q Ol tn m oo $ sl F @ m tn (E cj - + ri bt J J:;5 i-i tri 5 = J tner cri a(tto n-.n a gr rn + ot !t:)
c -. .i - N N n @ o O er r\ ' cn s c! (QO tsO c !
)s cnolnd +- -! n
' ^- -
cfi+ P8 +5_.' .l.(c'. Fl
.i oo' Fl bo tr gs
=
BE Ecr E p s 3 Ei u-s sE fi ee& E E I b t Io E E & E r^^co'-. -E.n =E .s spco A ..9 E E!g E ES s E E _5=FE ?EEfl Fi blECo F e= o
= EE hB i{ F6E g p{^t;*s fi2lxs;;--: - :33 fsE8i,i s-EE H; I
#sE.;f t\(a s.S E\)
E E F
occoU gE,==aEi;EEEEgi*ggE;=$EE$ ,3EE
;E*qs Egsg E.:EE EitEE t)
S( )us{
+ s .;gEEEggEgE+pEfi5$E*rsPEEFiE E::58 ES
- !(a 6 u =pE;s#fiEgg:sFE;;;;E;Eg5EE g'r-i
; E 9 H FE =v,:,E*;
- o<uotr{9:Jzz'z'\)o'Eavlu)tttt-Ft-2 H 9t,g Ffi > F > : = X*;E I EEEE EEs$; I.;.95EE*s; o
E E=.9 E F b fE q 4.3 'E-^cn$rn.oN@-31:P:Pg5*ERFNfrNil 3 I 9. ss I f; H a q) 6 n E ;-i.i.iii.ri.i.r.r.i'i'i'i'i-ii'i'i'i'i'innn d*t1.., Eil" Eiilil*
%s
-, E - -i-i -i -i -i -r i-i n n.1 n.1 n i n nn n i ! ! i nn'l cr!! l EE F s Ass888s8s#8#8ssfff;88##8#ss## Sssss s8#8 8ff#8f $
Fr
c\ \tr slOOst I F.r cn {f, sf 3h Eie l l l I l l
-lOOrlF. rniro(o
$dtnu) sEE
\O.,4.t \
\6{ (o@@co $ $dlnu) NcntnlJ) 6i\ \
$ I N F { N N e i e l F { $ S l NSrlFl rl NN Dqt J^B
- rl ri g cn dv g J (o SH d:R EE oF d
LN \: (o: 6l \x = \a ooo FS ooo
@@00 oi oi oi 00@@
ru mcncn Ln rJ) rn 8E $stsl o6 ot A,t o-: 6d oE E Gt -i fl 6d
<6 sfl 3s eE F0t 5l!
6j
>o Cn cn Ft a{ lJ) ljl Ol Ol (no)(otnNNcnN o rLnlJ)rIrtololNoto Eg d c.i c.l' 'ri oo' F t N t n oi o 6 u
Nc\lONFINO<tO) oo @ F -l ri cr'l rl ln @ Ol sl' @ tJ) OtO'OOf\OtF{OOOO mm rn(o sf QcONg)rn!>Fl tn c i/i i/i ' coo(oF-{OFrooco @ o o(o(or\c!ronrNon<t <'o Eo. -i 6i ,ri i oi cri -- ,ri.'i oid'ricriuid'riS S (D7i F.l a! Firt F{cnFlt-^Lc{ qro Ho G
=
rl Fl rl O OO ot Or O) Ol F t l r\ l l l l t l l l l r l l l.rlrntn
= rrt o- E
- g E F { F { - l Fl Fl rl IY cio r? xI A =
/ar ti
. F Y.r
--A Nc!mcnOF-Ftra(ntnLn$N oo 00 t\ Fl r.t Cr') rl ln OO Ol sl OO Ln el -i Fl Gg OrOmOr(oON(oslF\mN Ol rn cn in(o sf ocoN\otnFd '4) Ol Or Ol
- Y r-'1 ctl o- (o- n o- n oo.
E$ 'o-' @. cvl v) IJ) rn
- o. ro- ur rn Lo N N n cq or $- n1,o- LN LN n fi;" F-r olt {,O a! (O N N CO F l $ @
a! NN rl Fl 3S --HK$ I r< F.{ Ft
-l ri el r
o x2= e Fl r\ O 00 00 sfLnlJ)crl Or Or O) L\J otcnc!Nosorc\lNNO(o O l'nOolOlst@ri stocoo(ocnFcn NNT\ otNrnN(o(oN@c{o\FNrl @@ o@ ry
<lnn 6 ulQ A.l^
@0o N@(oor@ ctr NC! +o ' o0orF\$(oorcocn oi cri (\.i to cti FI lnO c{ (\ i cri Fl <{ Fl G (!
r- . rF r arY' E E o
- 3.eil
*.-AO
-EnE d () a6 q,
co or or o) N t\ l r.o o F.r o rn (o cn N sf or (o rl o oo
@ cn r-r 00 rn c!
Ln F ro r-{ sf oo r-l rt o OO l56 N..i Nqr LnO O(b qlSl-Qr-bq)qN Oro)q)-l rsf O@r\SNsl-Ot ONOr@ c\ rY') r! ogA oo' i'r i.idd + ;-'
-=
<'O
;m
@'oidoidro-'orloi
-^9 d aO=
l,90 o -{( n$ : O OE trng G NC{ (n cf) c! cfl
.22 -< ,toI O) o) Ol
>A
-Y
-o A\J lY 7\ o l-r-'t cll al -.e
-tF_
a 0r. o-a
- 8.E o 9-o-
E 8.e 2 go 8 ctt Ln rn lf)
'Ee NT\N E8 HC) 4 (E
HF{ \o 6@ F
>e ',o-rr..o. cn P8 oo' N
bo E 83, cjo ou E g.gy g kE F n E * [ :E S.s d gE rt 3 tEh EE5i ES E E.g-* FHEg ifin P q? EEu:
;,seEfi .E-';
- xfl*u**
hs i{
'\(a r-Q B \.)
i -E*-E' E E tqFgif qJ tr:
*e;+E;Pb>arE' O-E,:;-b e g = ,9.o xn,-hi-;E=f;H- *pEH:EEaE' il = e ;E 3 Sul R{o xa
?EE;EsssEsfiEl LE E E f l # = 5 aa;533E 6 55; ;
i t fl EEltEEE=$FgBsgE ts i F J 5 u isE E-*d piF!Es5$#g=F P=oo'2fi o!2it6='^ i H FF u fl e E a?-E E pF s E ; ta 6.3 q ) d -odt()QL)(nEU' L cnor-r;-mcnoacnLtr SS :n"rc!qnq\oqqnn A t !' 3
- "t": E.-."r,"la.1q\Tq= E E - E' 1' - .n. 't 1 q ' o* So SinininnRaRRn q = = Ecqcnqsi=:1 1T q E i E Bq) S8888383#88#8 # H 3 S.li,g PSS.H,H,H,H#,Hg;; ,H H S iSSS lrl Fr
c\\ OOO O cncn(o(o sb EEE '.o$o F I I N F o F \
-.i O -l o- 0or oo.
F\ cq sEE \ft! c.i ol' ..i rncn@rl c.i \ FI 3q0 J^ (n g sd sti rJ EE rri
- E (ot oF
=
\x \e r\ F< cn
;Eq
'tr o-Ol oo nFf @ N e) rl 8E o6 o6 sfl G .,:
6d o6 sfl G-i 66 T\F
<6 (n (n FT\
Et G -,: 6d c6 E.9
=r EJ
>c) c o
Er(,' g
;6 o
t Ol c\ c{ cO f\ st (O rJ') N n d N9 -ILOONO)Ol (o(o (ornN<lOol c o FIS el r,l Ot an cn N (\ (i') Fl Cn c \ N F I C O F{ a{ Eo 9a a, 9ro Eo G
=
ol
,\ ln F ! A v
+)
cg
)i Ets 5 Fl Fl o.=
5f (\ F\$ sg FN irnONOl Ol d v / O l N N c n N s t i . O l n c ! F i
@oo {o (o (ornNsto rri^
q) 9 F r $ r i F l O ) C O a n
' N @
N j FF Fl (n NNrl
-i 6
oi
, 6 - Fl lrXcd 6 \ V -
v zr li
-Lo! / o c { s l F l - 1 F I F { d N S F \ lO u1 rn u)tn rn Fl cn at')
OO F\ Or c! NcOc\l sf F Fr c{ hoQ r.r) c!N Fi cn
--t-tnY r i F a
.i v
I I ' F - gb I O Cd 6N Ec Eg9 u. ld E
- EEE @6FlFlLOcn(Om@si$
rt (nrtFl@c{OO
' N r.,l r\N scs c! t\,1 NetcnOOdOro rj)cnLnsfo)-l@
rlcn'FlNOl CN cn N olU aO= r)()0
$ F{ Fl 6i o q)5 Ea3 3n a\l
'o an Or Ol com co
.22 a6
!+o oi
)a
-Y .go bU Z\ o nv
- r-l l{
t^ E)
'c6 9 ff8 6o i
t 00 00 NC! 8.e t l l l l l E8 go ct) c
'Et g E8 Ho o-cn cf)
G Fl rl
># GIN P8 bo tr gs a 6 q
8 (J z Eq 6 9EE O L 6 = q O oo0ro o0J uo-d E E E.= E3 E g+Ec E tq I
* - E
.E E q
e= P oE d . y F I G : 6 b: = u.q;'i *g E o - 'u4F ' E { g E : EE FrE E n s H EarUE6por, s* N ! S E 5 E-E ; E ; F{ roon I I E-,6 g
\a gE UFsFgg g.q: R E g P E piF #6 6u{3 H,9E se
- s. -Q B \,) . E ^ EE 6 F g ' - a E E;E I E E ,9EF 3-b F- I EL fi1 EE^F
(, (o 4 aE (J O_ C, LU a 9g ;qs:iE : = 1- Aj 9.1 S Sea EE d* g E-g=E! ;#PFs" bE>. .; 'Ea= . A i - - o 6 o-e
-dro b:6 AEFfiEEAEE
- sQ:86'E-6 EE ;sg;=He:6EaE i F ? sEgCt X H=*E3;==E .D1 a EE P;F-F9PTI?E3=5 ENE s t5s b E (=uF=9L. i( ,o5=5; 3x = E,=i Rro ovra ts x(a E; FEi#=,58El;33,i ; 5 io.;
3.s as E6 EEtYioo
-(noOcr')rn Er-r OJ cn EdP-rNcO$lntof\
cn CJ 9. ca
! P-r Ncn$ulrgF.oqq-(DS O E q
'io EE P": 9{": q+iiq+c{s c E i E"'ll P "at: " ot:
a 3 { oi n o.,* i lqJt noJ o 0J qJ q q -0J t.I ES 3S 8HE3H3SH3SE3 H H 3 33.9 o- co on o- an co cn cn co cn co (n (n F\ aa
N\f NOI\O (ooo EEg N(oOl Or orn(r) F{ lJ1 \^ \: e rnlJ.)o
^i:
i6 J^s sf ri sEE g 00 cn 00 cn
., .i + sl@F Oo co orO tt)
NrO
-l rn
<t Ct) r.o d\r g J o) o) ot$t sri G)Fr EE oF
'Ji ,Ji L N N I O (oq,
\c o: l c\l N
\x = Fl
\d P< NO
;Eq
'tr o-cn
@ch Fad
-l
<t N
dHf N 'YI rn N co (n 8F lJ) st tl sf oE o6 o o tr E(o-j f
= 6d o
N
'i IE o6 o
Efl G-j 6d f\ ln
<6 cnN N
E f-,:l u1 G o 6(i ryt o) N
!to ro F(l, 0
5t! N 9E O'r rjl c! <f o oo Ee L g D Orln rnF t6 o tr cn cn sl Fr@r-rNt.l) cnf\ro c 00@ @mc!doln $FlO Or Ol 'rltrlelst $otF o Eo rl Ol Nsf Or OE Ndt 9ro EC) o
=
Fi (Yr ti r . , ' F<f r\ aYt
.id
+r v
c! EgE t
<;()
Fl (V' t'l
?IA AI :
Y.i E:Y U r-'l 6g cn cn ut r.rl s oo F{@-l
.n .\l d Nln.nto<f O tn sf Fl Ctr fi;" E$ Or Ol r{rl<f $r \
Oln oln O. r 2; 6 \ V - cn ctl Y z l : L\J O 006 rl ri N slS$cONFOltro (O r<rtln@Ol 5 boQ N C ! Fl rl d rr qn tro r- .rA r ' E E Ln rto G co (Y' o Ft q c! ON tr
=O'rr+r o
+.-111O o
- E'EE CE()(/ )TA (lt tt (o(o sl st NNsl'.OOlCO (oNNOtOOO
'Ft'<-
t sl ot r{ln fl dt
<l th OE; o oo tn<f aO= NN NrO u]ao IA t^ 1A Vl O O,E L b b Ea3 o rl@
oo s gsg
-< t, oI o $or o ooo
.22 o o
or <t sf
!t =rE!t
)nr
-Y
-o o o ooo F{ F{ Ft lu r^v r\ o o N
ooo N N N Fl r,l 5 l-l F\ Et o ooo
.A o.E
=o aDO
.-i o o
o T' c f *f alGtlb.c E $ : EIJ o at 29e.9.9,aL og o o 5 666.0c=
- o. ;ii66P=
qfdt@ql t !?Pg'4u1 r49 o o $Rtq$:1 _-r. o o ;'068h8 6+\;6ri c o rn ari (t> g o 1l\ {.tt F{ Ln U1 E) rtl lY!
.= o E)
F\00 (n lg o l( o o o o o-Or Ol sf rf) aYt o i-r o t\
>! @@ @slo P8 Or c{
O1 qr bo t gs @ rn o d l,!l x (J 5L
!0s c, bo z UJ oc EJ I
z UJ q e ; q = Y z&, 19 FO IJ =8F R^ z\o L d 9S f 8=F nt L C? il, OE o n9.e
. = 6 ( l J bR tYt u;
ljl o o q Y e EU I E 91^ x s llI
'3E 5,q u 3 E-o rg-q r{)
09 t^ d i,n E (o
- -> p F - E Eg rY) 3 ,t
!EU(o E.: E E E .I + =z 9 I ri o z Pqc Etg9 NT E ; ;E E e i t-- z zq 1^
o ah o UJ
- d. & o UJ
= YTqN L=6^
hB E = EE 88 E 6 I P 0 crF
= rJ (J f c0 I lrt LU
'.t> H - s g; i
vl G z H :a -EE xE ; .5n ssE E 2 o >.e UJ ttl Y;Z o
=E zIJJ 5 o f trEo-tn 9 - - v
\o
+ E EEF iF E EIqT=E;F =tr = = f lJ tIJ IIJ '-fi=E r,Q s\) g n (J-o-dZa H_gi E E o r - u,l LU (9
o E o z 4 E &
.=E;.s 5.g.e = qj sbo i E eaE EiE +.FeHEAatE 5 e H I ut^
oz z UJ a u,l I o o
. . - C r F C I P P : l r i s q ErE gE ;$**?;g F i F EEEP ttl E qs 9U c, UJ o P+ . =P
,,i q,)
T g =b; k Ero
;a t";; ;EE#8;E==, I F ; IIJ 3 o l!
c!
,.833c Q) C
; ( 4
*er s i 5H r/n(J 8Z ut l
(J f 01 E (9 0c (J ta el u 8 .:x*E I ES S ) d E6 Acncnc'lcne: o z X=9.oQa
>:EF: q
' ai os EE E E
'- E.r
'ic.rc.r E.-.
'icom E.r"rc't 9'r-r9\
'iss$$<tst<fsl o oz
= z u,l !c. *o\ = , f l g E E t! (l.l oJdd 0.,.j+i (lJ,jdd+d*s !(n: + !J o Luc(oo(os Ba) c! o- o- cn in o- cn (n o- cn (r1 rn cn rn(.n cn cn B F atl FI}}