L-PI-08-062, Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates

Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates

ML082260425
Person / Time
Site:	Prairie Island
Issue date:	08/08/2008
From:	Wadley M Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-08-062
Download: ML082260425 (124)

Text

NMC Committed to NuclearExcellen Prairie Island Nuclear Generating Plant Operated by Nuclear Management Company, LLC SAUG 0 8 2008 L-PI-08-062 10 CFR 50.54 10 CFR 50.75 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for Prairie Island Nuclear Generating Plant (PINGP)

References:

1) Nuclear Management Company, LLC (NMC) letter to US Nuclear Regulatory Commission (NRC), "Application for Renewed Operating Licenses," dated April 11, 2008, Accession No. ML081130673.

2) NMC letter to NRC, "Decommissioning Funding Status Reports," dated March 30, 2007, Accession No. ML070890622.

The enclosed Irradiated Fuel Management Plan (Enclosure 1) and Preliminary Decommissioning Cost Estimate (Enclosure 2) are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.54(bb) "Conditions of Licenses," and 10 CFR 50.75(f)(3), "Reporting and Recordkeeping for Decommissioning Planning," respectively, for PINGP. As holder of the plant operating license, NMC is submitting these reports on behalf of the plant owner, Xcel Energy.

The financial information provided in the enclosures reflects information provided to NMC by Xcel Energy.

Pursuant to 10 CFR 50.54(bb), a licensee shall "submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." Accordingly, the Irradiated Fuel Management Plan (Enclosure 1) is provided for NRC review and preliminary approval.

Additionally, 10 CFR 50.75(f)(3), "Reporting and Recordkeeping for Decommissioning Planning" states, "each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to 1717 Wakonade Drive East

• Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 decommission." Accordingly, the Preliminary Decommissioning Cost Estimate (Enclosure 2) is provided for NRC review and approval.

NMC submitted a sufficient application for renewal of the PINGP operating licenses (Reference 1) and therefore, in accordance with 10 CFR 2.109, "Effect of Timely Renewal Application," "the existing license will not be deemed to have expired until the application has been finally determined." Although NMC is seeking license renewal, the Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate are submitted based on the current operating license expiration date of August 9, 2013 for PINGP Unit 1. If PINGP's licenses are renewed, the current Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate would no longer be applicable, and a new plan and cost estimate will be submitted in accordance with 10 CFR 50.54(bb) and 10 CFR 50.75(f)(3), respectively.

If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

Michael D. Wadley Site Vice President, Prairie Island Nuclear Generating Plant, Units 1 and 2 Nuclear Management Company, LLC

Enclosures:

(2) cc: Administrator, Region III, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC

Enclosure 1 Irradiated Fuel Management Plan For Prairie Island Nuclear Generating Plant

1. Background The Preliminary Decommissioning Cost Estimate (Enclosure 2) in accordance with 10 CFR 50.75(f)(3) for Prairie Island Nuclear Generating Plant (PINGP) Unit 1 and Unit 2 evaluates the DECON strategy with operating licenses expiration of August 9, 2013 for Unit 1 and October 29, 2014 for Unit 2. The Irradiated Fuel Management Plan is also based on the DECON analysis and current operating license expiration dates. There is one independent spent fuel storage installation (ISFSI) on the PINGP site operating under a Site Specific Nuclear Regulatory Commission (NRC) license. Xcel Energy reserves the right to choose the ultimate decommissioning option in accordance with its business needs, recognizing the need to ensure the chosen option meets NRC requirements for decommissioning funding. Inclusion of costs in this submittal is not in-tended to acknowledge that these costs will ultimately be borne by Xcel Energy or Nuclear Management Company, LLC (NMC), as some (or all) are expected to be the responsibility of the U.S. Department of Energy as a result of the breach of the Standard Contract of Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste.

I1. Spent Fuel Management Strategy The NRC requires (10 CFR 50.54(bb)) 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 U. S. Department of Energy (DOE).

Interim storage of the irradiated fuel will be either in the spent fuel storage pool or the ISFSI located on the PINGP site until the DOE has completed the transfer to a repository. The ISFSI operates under an independent site specific license from the Nuclear Regulatory Commission. The design of the ISFSI provides room for expansion that will accommodate the inventory of spent fuel residing in PINGP's storage pool at the conclusion of the required cooling period. The ISFSI if expanded would store all spent nuclear fuel on-site.

The spent fuel pool will remain operational for a minimum of 15 years following the cessation of operations. This period provides the necessary cooling for the final irradiated fuel removed from the reactor core to meet dry storage canister requirements for decay heat. The spent fuel pool will be isolated and a spent fuel island created. Over the fifteen year cool-down period, the irradiated fuel would be packaged into TN-40 casks for transfer to DOE from the ISFSI. Transfer of irradiated fuel from the spent fuel pool to dry storage in the ISFS1 allows for early decontamination and dismantlement of plant structures. The ISFSI will remain operational and provide interim storage of spent fuel until such time that the DOE.

Page 1 of 4

Enclosure I completes fuel acceptance. Consequently, costs are included within the estimate below for the long-term caretaking of the irradiated fuel at PINGP through the year 2053.

The shipping of spent nuclear fuel assemblies to DOE during decommissioning is based upon several assumptions. First DOE would begin accepting irradiated fuel from PINGP in 2028. Second, based on DOE generator allocation/receipt schedules, the oldest irradiated fuel receives the highest acceptance priority.

Third, the maximum rate at which irradiated fuel is removed from commercial sites like PINGP is based upon 3,000 metric tons of uranium (MTU) national ac6eptance rate. However, any delay in the startup of the repository or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in the fuel remaining at the site longer. In the DECON scenario, the ISFSI will continue to operate until such time that the transfer of irradiated fuel to the DOE is complete. Finally, assuming that the DOE commences repository operation in 2025, irradiated fuel is projected to be removed from the PINGP site by the end of 2053. Consequently, costs are included within this analysis for the continued operation of the storage pool and ISFSI, as required, and for the long-term caretaking of the spent fuel until the year 2053. At the conclusion of the spent fuel transfer process the ISFSI will be decommissioned.

Operation and maintenance costs for the storage facilities (ISFSI and the spent fuel pool) are included within the estimate below and address the cost for staffing the facilities, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to an ISFSI. A cost-estimate for irradiated fuel management at PINGP under the DECON scenario may be found in Table 1.

In the event that PINGP ceases operation in 2013 and 2014 for Unit 1 and Unit 2 respectively, PINGP will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and each ISFSI, as necessary, under the decommissioning scenario ultimately selected. In addition, PINGP will also comply with applicable license termination requirements in accordance with 10 CFR 50.82 with respect to plant shutdown and post-shutdown activities including seeking such NRC approvals and on such schedules as necessary to satisfy these requirements consistent with the continued safe storage of irradiated fuel.

Page 2 of 4

Enclosure 1 III. Funding for Spent Fuel Management Based on the DECON Decommissioning Option The NRC minimum decommissioning financial assurance requirement as reported in Reference 2 and set forth in 10 CFR 50.75(c) for PINGP is approximately $324.9 million for Unit1 and $324.9 million for Unit 2.

As of December 31, 2007, the PINGP decommissioning trust funds balance were

$402.4 million for Unit 1 and $430.2 for Unit 2. These funds are being supplemented with annual total Company contributions of approximately $15 million for Unit 1 and $19 million for Unit 2 based on a prescribed schedule per Minnesota Public Utility Commission direction. Adjustments to the annual contribution require approval of multiple state public utilities commissions. The trust fund monies will be used for radiological decommissioning and to pay for irradiated fuel management. However, inclusion of irradiated fuel costs in this submittal is not intended to acknowledge that these costs will ultimately be borne by Xcel Energy or NMC, as some (or all) are expected to be the responsibility of the U.S. Department of Energy as a result of the breach of the Standard Contract of Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste.

IV. Cost Estimate For Spent Fuel Management Based on the DECON Decommissioning Option The "Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant," included cost estimates of $404 million for spent fuel management,

$1,026 million for decommissioning and $83.7 million for site restoration using a DECON scenario (Table 1). The following items are key costs estimates:

(1) The estimated cost to isolate the spent fuel pool and fuel handling systems is

$11.8 million. This cost is based on spent fuel pool isolation costs at other decommissioned facilities and engineering judgment. This cost is part of the activities necessary to maintain the spent fuel in a safe and controlled state both during the initial decommissioning activities and during the irradiated fuel cool-down period to meet dry storage canister requirement for decay heat.

(2) The estimated annual cost for the dry storage ISFSI at PINGP is approximately $6.6 million. This cost is based on actual costs at decommissioned facilities, estimated costs for facilities similar to PINGP and engineering judgment. These are annual costs incurred during the storage period, beginning in 2031 and continuing through removal of all fuel and "Greater Than Class C" radioactive material in 2053.

3) The estimated cost for preparation, packaging, and shipping of irradiated fuel to the Department of Energy (DOE) is $220 million. This cost includes the unit cost of approximately $4.1 million for each TN-40 cask. This cost is based on Page 3 of 4

Enclosure I actual costs at decommissioned facilities, estimated costs for facilities similar to PINGP, and engineering judgment.

(4) An average cost of $100,000 is used for labor and equipment to load each TN-40 onto a DOE- provided railcar for transport of the irradiated fuel to a DOE repository.

(5) The estimated ISFSI Decontamination & Dismantling cost is $12.9 million.

This cost includes disposal of the TN-40 casks.

The decommissioning schedule includes the following program period and durations for a DECON with dry storage scenario:

Period # Activity Unit 1 & 2 Irradiated Fuel Duration (a) (thousands, 2008 dollars) (Months) 1 Transition and Preparation 37,582 20 2 Decommissioning 196,051 194 3b Site Restoration 20,288 28 3c & 3d ISFSI Operations 135,682 244 ISFSI Decommissioning 14,452 7 3e & 3f Dismantlement & Restoration TOTALS(b) 404,056 493 (a) Figure 4.2, Decommissioning Timeline, TLG Services, Inc. Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant. August 2008.

(b) Columns may not add due to rounding.

Page 4 of 4

Enclosure 2 Prairie Island Nuclear Generating Plant Preliminary Decommissioning Cost Estimate I. Introduction This report presents a summary of the preliminary decommissioning cost estimate to decommission Prairie Island Nuclear Generating Plant (PINGP) Unit 1 and Unit 2, as required by 10CFR50.75(f)(3). This cost estimate is based on the "Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant" and premised on the assumption that PINGP Unit 1 and Unit 2 permanently cease to operate in August 2013 and October 2014, respectively. The estimate assumes the eventual removal of all contaminated and activated plant components and structural materials, such that the PINGP operating licenses may be terminated to permit unrestricted use of the site. Although Nuclear Management Company, LLC (NMC) is currently seeking license renewal for PINGP, this cost estimate is based on the current operating licenses expiration dates for PINGP. If license renewal for PINGP is granted, this Preliminary Decommissioning Cost Estimate would no longer be applicable and a new estimate will be submitted in accordance with 10CFR50.75(f)(3).

I1. Comparison of the Preliminary Cost Estimate to the Minimum Required Decommissioning Fund The minimum decommissioning financial assurance requirement for PINGP, as reported in Reference 2 and set forth in 10CFR50.75(c), is approximately $324.9 million for each unit. The total preliminary decommissioning cost estimate based on the "Decommissioning Cost Analysis" is approximately $1,513.7 million. This estimate includes approximately $1,026 million for decommissioning costs, $404 million for spent fuel management and $83.7 million for site restoration (Table 1).

II1. Assessment of Maoor Factors That Could Affect Preliminary Cost Estimate A. Decommissioningq Option/Method This Preliminary Decommissioning Cost Estimate assumes a DECON decommissioning option with dry storage of spent nuclear fuel. This estimate assumes cessation of operation for Unit 1 in August 2013 and Unit 2 in October 2014 and a Department of Energy (DOE) spent fuel repository open in 2025 with the first irradiated fuel leaving the plant in 2028. Interim safe storage of the irradiated fuel will be in the spent nuclear fuel storage pool and/or the ISFSI located on the PINGP site until the DOE assumes title to the spent fuel. The Page 1 of 8

Enclosure 2 ISFSI which operates under an independent Site Specific NRC license, will accommodate the inventory of spent fuel residing in the spent nuclear fuel storage pool at the conclusion of the required irradiated fuel cooling period. This cost estimate scenario includes the decontamination and dismantlement of the facility, irradiated fuel management, and restoration of the site.

B. Potential for Known or Suspected Contamination The Preliminary Decommissioning Cost Estimate does not assume the remediation of any significant volume of contaminated soil. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria.

C. LLW Disposition Plan Low Level (Radioactive) Waste (LLW) disposal costs include processing, packaging, shipping, and burial/vendor costs. This Preliminary Decommissioning Cost Estimate assumes that additional disposal capacity will be available to support reactor decommissioning, particularly for the isolation of the more highly radioactive material. Therefore, for estimating purposes, Class B and C waste disposal costs were generated using the last available published pricing schedule for Barnwell in South Carolina for non-Atlantic members. Costs related to Class A waste uses the Energy Solutions rates for their open facility in Utah. Due to the high cost per cubic foot of LLW disposal, decontamination, recycling, conditioning and metal processing were incorporated into the decommissioning cost calculations in order to reduce the overall LLW disposal. costs.

D. Preliminary Schedule of Decommissioninq Activities A schedule of the decommissioning scenario is illustrated in Table 3. Activity and period-dependent costs are estimated for each of the 5 decommissioning time periods, post-decommissioning ISFSI operation, and ISFSI decontamination and decommissioning. These time periods are briefly described in Section IV, below.

E. Other Factors That Could Significantly Affect the Cost to Decommission NMC is currently unaware of any major site-specific factors that could have a significant effect on the cost of decommissioning. In order to anticipate unknown or unplanned occurrences during decommissioning, e.g., tool breakage, accidents, illnesses, weather delays, and labor stoppages, contingencies are applied to the cost estimates. Contingencies are defined in the American Association of Cost Engineers "Project and Cost Engineers' Handbook" as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and Page 2 of 8

Enclosure 2 actual costs has shown that unforeseeable events which will increase costs are likely to occur." The amount of contingency depends on the status of design, procurement and construction; and the complexity and uncertainties within the defined project scope. The "Decommissioning Cost Analysis for PINGP" conducted by TLG Services, Inc, examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. The composite contingency value calculated for the PINGP DECON alternative is 17.07%.for Unit 1 and 17.23% for Unit 2. Individual activity contingencies range from 10% to 75%

depending on the degree of difficulty judged to be appropriate from actual decommissioning experience. Examples include: 15% for staffing and engineering; 25% for low level waste disposal; 50% for decontamination and 75% for reactor segmentation. 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.

IV. Preliminary Cost Estimate Considerations The Preliminary Decommissioning Cost Estimate is based on costs associated with the entire decommissioning work scope, including those activities related to the following periods of the decommissioning project: (1) Transition and Preparations, (2) Decommissioning (3) Site Restoration (4) ISFSl Operations and (5) ISFSI Decommissioning and Site Restoration. The cost estimate also includes ISFSI operating and decommissioning costs. The scope of each of those activities is described below. Disposition of LLW is also accounted for in the Preliminary Decommissioning Cost Estimate, as described in Section Ill.C, above.

A summary of activities and time duration for each DECON period follows (see Table 2 for summary of cost elements and Table 3 for cost estimates for each period):

(1) Transition and Preparations: Includes preliminary engineering and planning to permanently de-fuel the reactor, revision of Technical Specifications applicable to operating conditions and requirements, a characterization of the facility and major components, and the development of the Post-Shutdown Decommissioning Activities Report (PSDAR). This period includes activities including, but not limited to, transfer of the spent fuel to the ISFSI, draining and de-energizing of non-contaminated systems, disposal of contaminated filter elements and resin beds, decontamination of the reactor coolant system, draining of the reactor vessel, preparing lighting, alarm, and security systems, and performing radiation surveys. Period duration is estimated at 20 months.

Page 3 of 8

Enclosure 2 (2) Decommissioning: Includes continuation of spent fuel transfer from spent fuel pool to the ISFSI, commencement of shipments of irradiated fuel from the ISFSI to the DOE, removal of reactor internals and vessel, non-essential systems removal, structure decontamination, removal of spent fuel racks, and final site survey of reactor plant. Also included are physical decommissioning activities associated with the removal and disposal of contaminated components and structures. This period also includes surveys leading to the successful termination of the 10CFR50 operating license. Period duration estimated at 194 months.

(3b) Site Restoration: Includes activities required to remove contaminated materials and verify that residual radionuclide concentrations are below NRC limits. This will include prompt removal of site structures, removal of foundations and exterior walls to a nominal depth of three feet below grade, and fill and grading of the site. Period duration estimated at 28 months.

(3cl3d) ISFSI Operations: Includes continued on-site dry storage of spent fuel, completion of spent fuel shipment from pool to ISFSI. Period duration estimated at 244 months.

(3e/3f) ISFSI D&D: Includes completion of irradiated fuel shipments from dry storage to DOE, and a final survey of ISFSI and removal. Period duration estimated at 7 months.

V. Plans for Adiusting Levels of Funding NMC submitted a sufficient application for renewal of an operating license (Reference 1) and therefore, in accordance with 10 CFR 2.109, "Effect of Timely Renewal Application," "the existing license will not be deemed to have expired until the application has been finally determined." Although NMC is seeking license renewal, the Preliminary Decommissioning Cost Estimate is submitted based on the current operating license expiration dates of August 9, 2013 for PINGP Unit 1 and October 29, 2014 for Unit 2. If license renewal for PINGP is granted, the Preliminary Decommissioning Cost Estimate would no longer be applicable and a new plan and cost estimate will be submitted in accordance with 10 CFR 50.75(f)(3).

The cost to decommission PINGP is estimated to be $1,513.7 million in 2008 dollars. The "Decommissioning Cost Analysis for PINGP" included cost estimates of approximately $1,026 million for decommissioning costs, $404 million for spent fuel management and $83.7 million for site restoration using a DECON scenario. The total estimated decommissioning costs by period and decommissioning activity are provided in Tables 1 and 2.

Page 4 of 8

Enclosure 2 The NRC minimum decommissioning financial assurance requirement for PINGP as reported in Reference 2 and set forth in1OCFR50.75(c) is approximately

$324.9 million for each unit at PINGP. As of December 31, 2007, the PINGP decommissioning trust fund balance was $402.4 million for Unit 1 and $430.2 million for Unit 2.

Xcel Energy applies reasonable earnings rates to the decommissioning funds throughout the decommissioning periods described above. In addition, the Preliminary Decommissioning Cost Estimate includes reasonable escalation factors for the decommissioning activities. Based on a cash flow analysis for the decommissioning activities to be performed for the periods described above, Xcel Energy believes that there is reasonable assurance that adequate decommissioning funds will be available to decommission PINGP Unit 1 and Unit 2 as described herein (assuming an August 2013 and October 2014 cessation of operations dates for each respective unit). Xcel Energy plans to review the decommissioning fund status on a regular basis as described above.

Page 5 of 8

Table 1 Summary of Annual D&D, Irradiated Fuel, and Site Restoration Costs (thousands, 2008 dollars)

Year Site D&D IFM Site Restore Total 2013 22,964 4,639 224 27,827 2014 82,929 14,691 997 98,617 2015 163,925 25,478 1,882 191,285 2016 169,706 23,604 2,785 196,095 2017 139,661 18,776 2,752 161,189 2018 88,448 13,724 1,524 103,696 2019 53,248 12,696 696 66,640 2020 19,457 12,098 0 31,555 2021 19,404 12,065 0 31,469 2022 19,404 12,065 0 31,469 2023 19,404 12,065 0 31,469 2024 19,457 12,098 0 31,555 2025 19,404 12,065 0 31,469 2026 19,404 12,065 0 31,469 2027 19,404 12,065 0 31,469 2028 19,457 12,098 0 31,555 2029 29,444 10,122 0 39,566 2030 65,192 979 0 66,171 2031 14,444 6,627 22,918 43,989 2032 120 8,788 31,533 40,441 2033 70 7,880 18,352 26,302 2034 0 6,644 0 6,644 2035 0 6,644 0 6,644 2036 0 6,662 0 6,662 2037 0 6,644 0 6,644 2038 0 6,644 0 6,644 2039 0 6,644 0 6,644 2040 0 6,662 0 6,662 2041 0 6,644 0 6,644 2042 0 6,644 0 6,644 2043 0 6,644 0 6,644 2044 0 6,662 0 6,662 2045 0 6,644 0 6,644 2046 0 6,644 0 6,644 2047 0 6,644 0 6,644 2048 0 6,662 0 6,662 2049 0 6,644 0 6,644 2050 0 6,644 0 6,644 2051 0 6,644 0 6,644 2052 0 6,662 0 6,662 2053 21,028 6,710 0 27,738 2054 14,346 0 14,346 Total 1,025,971 404,056 83,662 1,513,689 "I Section 3, TLG Services, Inc. Decomm issioning Cost Analysis for Prairie Island Nuclear Generating Plant.

August 2008.

(b) Columns may not add due to rounding.

Page 6 of 8

Table 2 (a)

Unit I & 2 Cost Summary of Decommissioning Cost Elements (thousands, 2008 dollars)

Cost Element Unit I Unit 2 Total Percentage Decontamination 8,873 14,101 22,974 1.5%

Removal 71,116 91,943 163,059 10.8%

Packaging 18,148 18,447 36,595 2.4%

Transportation 6,828 7,411 14,239 0.9%

Waste Disposal 48,983 50,257 99,240 6.6%

Off-site Waste Processing 13,211 15,534 28,745 1.9%

Program Management (1) 334,149 381,084 715,233 47.3%

Spent Fuel Pool Isolation 5,911 5,911 11,822 0.8%

Spent Fuel Management (direct costs) (2) 128,061 127,342 255,403 16.9%

Insurance and Regulatory Fees 24,638 22,277 46,915 3.1%

Energy 24,306 23,721 48,027 3.2%

Characterization and Licensing Surveys 8,276 9,713 17,989 1.2%

Property Taxes 21,069 19,904 40,973 2.7%

Miscellaneous Equipment 6,228 6,250 12,478 0.8%

Total (3) 719,795 793,894 1,513j689 100.0%

(1) Includes engineering and security costs (2) Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees (3) Column may not add due to rounding (a) Section 3, TLG Services, Inc. Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant.

August 2008.

Page 7 of 8

Table 3 (a)

PINGP Unit I & Unit 2 Summary of DECON Cost Estimate by Period Cost and Activity Cost (thousands, 2008 dollars)

NRC Irradiated Fuel Total License Management Site Restoration Unit I Contingency Total Costs Term Costs Costs Costs Period 1: Transition &

Preparations 17,282 127,053 106,917 18,791 1,345 Period 2: Decontamination 72,434 472,934 370,363 98,385 4187 Period 3b: Site Restoration 4,398 34,228 195 7,851 26181 Period 3c: Fuel Storage Operation/Shipping 8,231' 67,570 0 67,570 0 Period 3d: GTCC Shipping 1,396 10,785 10,514 271 0 Period 3e: ISFSI Decon 1,108 6,474 0 6,474 0 Period 3f: ISFSI Site Restoration 98 752 0 752 0 (b) 104,947 719,795 487,988 200,095 31,712 NRC Irradiated Fuel Total License Management Site Restoration.

Unit 2 Contingency Total Costs Term Costs Costs Costs Period 1: Transition &

Preparations 15,188 112,796 93,430 18,791 576 Period 2: Decontamination 82,997 536,375 433,957 97,666 4753 Period 3b: Site Restoration 7,647 59,142 83 12,437 46621 Period 3c: Fuel Storage Operation/Shipping 8,231 67,570 0 67,570 0 Period 3d: GTCC Shipping 1,396 10,785 10,514 271 0 Period 3e: ISFSI Decon 1,108 6,474 0 6,474 0 Period 3f: ISFSI Site Restoration 98 752 0 752 0 (b) 116,665 793,894 537,983 203,961 51,950 (a) Section 3, TLG Services, Inc. Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant. August 2008.

(b) Columns may not add due to rounding.

Page 8 of 8

Attachment 1 to Enclosures I and 2 Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant August 2008 by TLG Services, Inc.

109 pages follow

Document X01-1586-002, Rev. 0 DECOMMISSIONING COST ANALYSIS for the PRAIRIE ISLAND NUCLEAR GENERATING PLANT preparedfor Xcel Energy Services, Inc.

preparedby TLG Services, Inc.

Bridgewater, Connecticut August 2008 TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentX01-1586-002, Rev. 0 Decommissioning CostAnalysis Pageii of xv APPROVALS Project Manager Date Date Project Engineer Date Technical Manager ok/0S/0 William A. Cloutier, Jr. Date 4

Quality Assurance Manager (acting) Adle Dat-e

/JophJ TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCostAnalysis Page iii of xv TABLE OF CONTENTS SECTION PAGE EXECUTIVE SUM M ARY .................................................................................................... vii-xv

1. INTRODUCTION ....................................................................................................................... 1-1 1.1 Objectives of Study .................................................................. :1........................................ 1-1 1.2 Site Description ................................................................................................................. 1-1 1.3 Regulatory Guidance .......................................................................................................... 1-2 1.3.1 Nuclear W aste Policy Act ................................................................................ 1-4 1.3.2 Low-Level Radioactive W aste Acts ..................................................................... 1-5 1.3.3 Radiological Criteria for License Term ination ..................................................... 1-6

2. 'DECOMMISSIONING ALTERNATIVE DESCRIPTION ........................... 2-1 2.1 Period 1 - Preparations ...................................................................................................... 2-1 2.1.1 Engineering and Planning ................................................................................ 2-1 2.1.2 Site Preparations ....................... :............................................................................. 2-2 2.2 Period 2 - Decomm issioning Operations ........................................................................... 2-3 2.3 Period 3 - Site Restoration ................................................................................................. 2-6 2.4 ISFSI Operations and Decomm issioning .......................................................................... 2-6

3. COST ESTIM ATE ...................................................................................................................... 3-1 3.1 Basis of Cost Estimate ....................................................................................................... 3-1 3.2 M ethodology .................................................................................................................. *....3-1 3.3 Impact of D ecomm issioning M ultiple Reactor Units ....................................................... 3-3 3.4 Financial Components of the Cost M odel ............. ........................................................... 3-4 3.4.1 Contingency .................................................................................................... 3-4 3.4.2 Financial Risk ........................................................................................................ 3-6 3.5 Site-Specific Considerations .............................................................................................. 3-7 3.5.1 Spent Fuel Management ....................................................................................... 3-7 3.5.2 Reactor Vessel and Internal Components............................................................ 3-9 3.5.3 Primary System Large Components .................................................................. 3-11 3.5.4 Main Turbine and Condenser ............................................................................. 3-12 3.5.5 Transportation M ethods ..................................................................................... 3-12 3.5.6 Low-Level Radioactive W aste Disposal ........................................................... 3-13 3.5.7 Site Conditions Following Decomm issioning ................................................... 3-14 3.6 Assumptions ..................................................................................................................... 3-14 3.6.1 Estimating Basis ....................................... 3-14 3.6.2 Labor Costs ......................................................................................................... 3-15 TLG Services, Inc.

PrairieIsland Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Page iv of xv TABLE OF CONTENTS (continued)

SECTION PAGE 3.6.3 Design Conditions .................................................................. 3-15 3.6.4 General............................................................................... 3-16 3.7 Cost Estimate Summary .................................................................... 3-18

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

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

6. RESULTS ............................................................................................ 6-I

7. REFERENCES....................................................................................... 7-1 TABLES Cost Summary, Decommissioning Cost Elements........................................... xv 3.1 Schedule of Total Annual Expenditures, Unit I ........................................... 3-19 3.1a Schedule of License Termination Expenditures, Unit 1 ......................... 3-21 3.1lb Schedule of Spent Fuel Management Expenditures, Unit 1 ..................... 3-23 3.1c Schedule of Site Restoration Expenditures , Unit 1 ............................... 3-25 3.2 Schedule of Total Annual Expenditures, Unit 2 ........................................... 3-27 3.2a Schedule of License Termination Expenditures, Unit 2.......................... 3-29 3.2b Schedule of Spent Fuel Management Expenditures, Unit 2...................... 3-31 3.2c Schedule of Site Restoration Expenditures, Unit 2............................... 3-33 5.1 Decommissioning Waste Summary .......................................................... 5-3 6.1 Cost Summary, Decommissioning Cost Elements.......................................... 6-3 FIGURES 4.1 Activity Schedule .............................................................................. 4-3 4.2 Decommissioning Timeline .................................................................. 4-5 TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCostAnalysis Pagev of xv TABLE OF CONTENTS (continued)

SECTIION PAGE APPENDICES A. Unit Cost Factor Development ...................................... A-I B. Unit Cost Factor Listing .................................................................................................. B-1 C. D etailed Cost T ables ............................................................................................................... C-1 TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Pagevi of xv REVISION LOG No. CRA No. Date Item Revised Reason for Revision 0 08-05-08 Original Issue TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Pagevii of xv

'EXECUTIVE

SUMMARY

This report presents an estimate of the cost to promptly decommission the Prairie Island Nuclear Generating Plant (Prairie Island) following the scheduled cessation of plant operations. The prompt decommissioning, or DECON method, as described below, was selected as it is the most cost-effective of the alternatives (in current dollars) to achieve the objectives of decommissioning. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,11] updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects.

The current estimate is designed to provide the plant's owners, with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear units.

The primary goal of decommissioning is the removal and disposal of the contaminated systems and structures so that the plant's operating licenses can be terminated. This analysis recognizes that spent fuel will be stored at the site in the plant's storage pool and/or in an independent spent

-fuel storage installation (ISFSI) until such time that it can be transferred to a U.S. Department of Energy (DOE) facility. Consequently, the estimate also includes those costs to manage and subsequently decommission these storage facilities.

The Prairie Island site currently consists of two operating pressurized water reactors, and Units I and 2 are each nominally rated to produce approximately 529 megawatts of electricity (MW).

The currently projected cost to decommission the station is estimated at $1,514 million, as reported in 2008 dollars. The estimate is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. *The estimate incorporates a minimum cooling period for the spent fuel that resides in the storage pool when operations cease. Any residual fuel remaining in the pool after the cooling period is relocated to the ISFSI to await transfer to a DOE facility. The estimate also includes the dismantling of site structures and non-essential facilities and the limited restoration of the site.

An ISFSI is currently operating on the Prairie Island site. The facility will contain 29 Transnuclear dry storage casks after 40 years of operation. The casks are single-purpose and the stored assemblies will be relicensed to meet transport regulations in support of final transferfto a DOE repository. An additional 39 Transnuclear casks will be purchased to accommodate all residual fuel remaining in the pool after final shutdown. Transfer of all spent fuel post-shutdown will require 15 years to allow for radioactive decay to decrease heat loading. Spent fuel is expected to be completely removed from the site by 2053.

"Decommissioning Cost Analysis for the Prairie Island Nuclear Generating Plant," Document No.

X01-1526-002, TLG Services, Inc., October 2005.

TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant Document XOI-1586-002, Rev. 0 DecommissioningCostAnalysis Page viii ofxv Alternatives and Regulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material so that the license(s) can be terminated. The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.[21 In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB.

DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations." [3]

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."'4a 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."'51 As 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 long-lived radioactive material.

In 1997, the Commission directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations; however, rulemaking has been deferred pending the completion of additional research studies, for example, on engineered barriers.

2 U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988 Ibid. Page FR24022, Column 3 4 Ibid.

5 Ibid. Page FR24023, Column 2 TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Pageix ofxv In 1996, the NRC published revisions to the general requirements .for decommissioning nuclear power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.161 The amendments allow for greater public participation and better define the transition process from operations to decommissioning.

Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. The format and content of the estimate is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.71' Methodology The methodology used to develop the estimate described within this document follows the basic approach originally presented in the cost estimating guidelines181 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 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big. Rock Point, Maine Yankee, Humboldt Bay-3, Connecticut Yankee and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and technical challenges of decommissioning commercial nuclear units.

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.

Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual 6 U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors,"

39 2 7 8 Nuclear Regulatory Commission, Federal Register Volume 61, (p et seq.), July 29, 1996 7 "Standard Format and Content of Decommissioning Cost Estimates of Decommissioning Cost Estimates for Nuclear Power Reactors," Regulatory Guide 1.202, U.S. Nuclear Regulatory Commission, February 2005 8 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986 TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentXOI-1586-002, Rev. 0 Decommissioning Cost Analysis Pagex of xv costs has shown that unforeseeable events which will increase costs are likely to occur."19' The cost elements in this estimate are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the projected 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 1980,110] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation.

After little progress, the "Low-Level Radioactive Waste Policy Amendments Act of 1985,"1'"'1 extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. Subsequent court rulings have substantially diluted those sanctions and, to date, no new compact facilities have been successfully sited, licensed and constructed.

In the interim, and as a proxy, the EnergySolutions' disposal facility in Clive, Utah is used as the destination for the lowest level, Class A,1 121 radioactive waste. EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C) generated in the dismantling of the reactor. The rates are comparable with those offered by the Barnwell facility in South Carolina which currently does accept Class B and C material, but which in the future would not be available to Xcel Energy under current South Carolina law. Despite the closing of one of the two currently accessible commercial disposal sites, it is reasonable to assume that additional disposal capacity will be available to support reactor decommissioning, particularly for the isolation of the more highly radioactive material that is not suitable for disposal elsewhere. For estimating purposes, and as a 9 Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239

'0 "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 12 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Pagexi of xv proxy for future disposal facilities, waste disposal costs are estimated using available pricing schedules for the currently operating facilities, i.e., Barnwell and. EnergySolutions.

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery.

Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Prairie Island reflects the savings from waste recovery/volume reduction.

High-Level Radioactive Waste Management 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 NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high-level radioactive waste and utilities would ,pay the cost of -the disposition services for that material.

NWPA, along with the individual contracts with the utilities, specified that -the DOE was to begin accepting spent fuel by January 31, 1998.

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

Operation of DOE's yet-to-be constructed repository is contingent upon the review and approval of the facility's license application by the NRC and the successful resolution of pending litigation. The DOE submitted its license application in June 2008. Assuming a timely review, DOE expects that receipt of fuel could begin as early as 2017,1143 although 2020 may be more likely according to the director of the DOE's waste program.[15]

It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb). 1 161 This funding 13 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982.

14 "DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's Office of Public Affairs, Press Release July 19, 2006.

'5 Remarks of OCRWM Director Ward Sproat to the National Academy of Science, November 2006.

16 U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities,"

Subpart 54 (bb), "Conditions of Licenses."

TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCostAnalysis Pagexii of xv requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the following fifteen years the assemblies are packaged into casks and transferred to dry storage at the ISFSI. It is assumed that this period provides the necessary cooling for the final core to meet the storage canister requirements for decay heat.

DOE's contracts with utilities generally order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. For purposes of this analysis, acceptance of commercial spent fuel by the DOE is expected to begin in 2025. The first assemblies removed from the Prairie Island site are assumed to be in 2028. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year, completion of the removal of fuel from the site is projected to be in the year 2053.

The existing ISFSI, which operates under the Station's general license, is expanded to support decommissioning. As such, the facility will be modified to accommodate the additional dry storage casks needed to off-load the wet storage pool so that dismantling activities can proceed.

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

Site Restoration Prompt dismantling of site structures (once the facilities are decontaminated) is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process is deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force. Consequently, this study assumes that site structures are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then to be graded and stabilized.

Summary The cost to promptly decommission the Prairie Island units assumes the removal of all contaminated and activated plant components and structural materials such that the owner(s) may then have unrestricted use of the site with no further requirements for an operating license. Low-level TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCostAnalysis Pagexiii of xv radioactive waste, other than GTCC waste, is sent to a commercial processor for treatment/conditioning or a controlled disposal facility.

Decommissioning is accomplished within the 60-year period required by current NRC regulations.

In the interim, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility is complete. Once emptied, the storage facilities are also decommissioned.

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

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

The "Spent Fuel Management" subcategory contains costs associated with the construction of an ISFSI, the containerization and transfer of spent fuel to the ISFSI that is not transferred directly to the DOE over the five and one-half years of post-shutdown pool operations, and the management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g.,

geologic repository) is complete. The estimate also includes spent fuel management expenses incurred prior to the cessation of plant operations.

"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, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCostAnalysis Pagexiv of xv The estimate presented in this document reflects the total cost (100%) to decontaminate the nuclear units, manage the spent fuel until the DOE is able to complete the transfer to a federal facility, dismantle the plant and restore the site for alternative use.

As noted within this document, the estimate was developed and costs are presented in 2008 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 reactors or during the decommissioning period.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Pagexv ofxv COST

SUMMARY

DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)

Cost Element Unit I Unit 2 Decontamination 8,873 14,101 Removal 71,116 91,943 Packaging 18,148 18,447 Transportation 6,828 7,411 Radioactive Waste Disposal 48,983 50,257 Off-site Waste Processing 13,211 15,534 Program Management [' 334,149 381,084 Spent Fuel Pool Isolation 5,911 5,911 Spent Fuel Management (direct costs) [2] 128,061 127,342 Insurance and Regulatory Fees 24,638 22,277 Energy 24,306 23,721 Characterization and Licensing Surveys 8,276 9,713 Property Taxes 21,069 19,904 Miscellaneous Equipment 6,228 6,250 Total [3] 719,795 793,894 Cost Element Unit 1 Unit 2 License Termination 487,988 537,983 Spent Fuel Management 200,095 203,961 Site Restoration 31,713 51,950 Total [3] 719,795 793,894 t' Includes engineering and security costs

[2] Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging/spent fuel pool O&M and EP fees 131 Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page I of 7

1. INTRODUCTION This report presents an estimate of the cost to promptly decommission the Prairie Island Nuclear Generating Plant (Prairie Island) following the scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,ý11 updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects. The current estimate -is designed to provide the plant's owners, with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear units. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning.

1.1 OBJECTIVES OF STUDY The objectives of this study are to prepare a comprehensive estimate of the cost to decommission the Prairie Island nuclear units, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.

For the purposes of this study, final shutdown dates (license expiration) for Unit 1 and Unit 2 are August 2013 and October 2014, respectively. Assuming a scheduled cessation of operations, these dates approximate a forty-year operating life.

1.2 SITE DESCRIPTION Prairie Island is located on the west bank of the Mississippi River, approximately 26 miles southeast of the Twin City Metropolitan Area and within the city limits of Red Wing. The site is in Goodhue County, Minnesota.

The Nuclear Steam Supply System (NSSS) consists of a pressurized water reactor and a two-loop reactor coolant system. The system is comprised of the reactor vessel and two closed reactor coolant loops connected in parallel to the reactor vessel, each containing a reactor coolant pump and a steam generator. An electrically heated pressurizer is connected to one of the loops. The components were supplied by the Westinghouse Electric Corporation, with the reactor rated at a net core power output of 1650 MW(t). The steam and power conversion equipment, including the turbine-generator, has the capability to generate a gross unit output is 592 MW(e).

The system is housed within the reactor containment vessel, a free-standing cylindrical steel shell with a hemispherical dome and ellipsoidal bottom designed to withstand the internal pressure accompanying a loss-of-coolant accident., The reactor containment vessel TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. O Decommissioning CostAnalysis Section 1, Page2 of 7 is surrounded by a cylindrical shield building constructed of reinforced concrete, -which serves as a radiation shielding for normal operations and for the loss-of-coolant condition.

Heat produced in the reactor is converted to electrical energy by the plant's power conversion system. A turbine-generator converts the thermal energy of steam produced in the steam generators into mechanical shaft power and then into electrical energy. The turbine-generator consists of one high-pressure, double-flow and two low-pressure, double-flow elements driving a direct-coupled generator at 1800 rpm. The turbines are operated in a closed feedwater cycle in which the steam is condensed and returned to the steam generators by the feedwater system.

Heat rejected in the main condensers is removed by the circulating water system, which provides the heat sink for the removal of the waste heat in the power plant's thermal cycle.

The majority of the heat is removed through dilution with river water in the discharge canal. Forced draft cooling towers provided supplemental heat removal.

1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[2] This rule set forth financial criteria for decommissioning licensed nuclear power facilities. The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose. Subsequent to the rule, the NRC issued Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"'[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 this deferred option is 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 TLG Services, Inc;

PrairieIslandNuclearGeneratingPlant DocumentX01-1586-002, Rev. 0 Decommissioning CostAnalysis Section 1, Page3 of 7 ENTOMB if the NRC approves such a, case), the site would still require significant remediation to meet the unrestricted release limits for license termination.

The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. With rulemaking permitting the controlled release of a site,[4] 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 considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombmentsJ 51 At this time, however, the NRC's staff has recommended that rulemaking be deferred, based upon several factors including that no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRC's current priorities, at least until after the additional research studies are complete. The Commission concurred with the staff's recommendation.

In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.16] When the decommissioning regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facility's operating licensed life. Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process'from operations to decommissioning.

Under the revised regulations, licensees will submit written ceirtification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel. Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Within two years of submitting notice of permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequence and schedule, and an estimate of expected costs. Prior to completing decommissioning, the licensee is required to submit an application to the NRC to terminate the license, which will include a license termination plan (LTP).

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 1, Page4 of 7 1.3.1 Nuclear Waste Policy Act Congress passed the "Nuclear Waste Policy Act"I71 (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high level waste, and utilities would pay the cost of the disposition services for that material. NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

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

Operation of DOE's yet-to-be constructed repository is contingent upon the review and approval of the facility's license application by the NRC and the successful resolution of pending litigation. The DOE filed the license application in June 2008. Assuming a timely review, DOE expects that receipt of -fuel could begin as early as 2017,[8]

although 2020 may be more likely according to the director of the DOE's waste program.[9]

It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).t'°' This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the next fifteen years the assemblies are packaged into multipurpose canisters for transfer to DOE from the ISFSI. It is assumed that this period provides the necessary cooling for the final core to meet storage canister requirements for decay heat.

DOE's contracts with utilities generally order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. The contracts also provide for exchanges of acceptance allocations among utilities, priority acceptance of spent fuel from permanently shutdown reactors and emergency acceptance of spent TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 1, Page 5 of 7 fuel. In addition, DOE has discussed the development of new contracts that would address acceptance of spent fuel from new plants. For purposes of this analysis, the acceptance of commercial spent fuel by the DOE is expected to begin in 2025. The first assemblies removed from the Prairie Island site are assumed to be in 2028. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year, completion of the removal of fuel from the site is projected to be in the year 2053.

An ISFSI, which Xcel Energy operates under a site-specific license, is currently in operation to support plant operations and decommissioning. As such, the facility will be modified to accommodate the dry storage casks needed to off-load the wet storage pool so that dismantling activities can proceed.

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

1.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,1"1 the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation. After little progress, the "Low-Level Radioactive Waste Policy Amendments Act of 1985,'[12] extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. Subsequent court rulings have substantially diluted those sanctions and, to date, no new compact facilities have been successfully sited, licensed and constructed.

In June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation allowed South Carolina to gradually limit access to. the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. Therefore, Prairie Island is no longer able to access the disposal facility in Barnwell, South Carolina. Prairie Island still has access to the EnergySolutions facility in Clive Utah (for 10 CFR 61 Class A waste only). It is TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Secion 1, Page6 of 7 reasonable to assume that additional disposal capacity will be developed to support reactor decommissioning, particularly for the isolation of the more highly radioactive material that is not suitable for disposal elsewhere.

In the interim, and as a proxy, the EnergySolutions' disposal facility in Clive, Utah is used as the destination for the lowest level, Class A,[131 radioactive waste.

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C) generated in the dismantling of the reactor. As such, the disposal costs for this material are based upon the last published rate schedule for non-compact waste.for the Barnwell facility.

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

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination,"['14] amending 10 CFR Part- 20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).

The decommissioning estimate for the Prairie Island site assumed that it will be remediated to a residual level consistent with the NRC-prescribed level.

It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity 'considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).1 151 An additional and separate limit of14 millirem per year, as defined in 40 CFR Part 141.16, is applied to drinking water.[ 6]

On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCostAnalysis Section 1, Page 7 of 7 Memorandum of Understanding (MOU)1171provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.

The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning.

Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees.

The present study does not include any costs for this occurrence.

TLG Services, Inc.

I PrairieIslandNudcearGeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning CostAnalysis Sedion Z Page I of 7

2. DECOMMISSIONING ALTERNATIVE DESCRIPTION A detailed cost estimate was developed to promptly decommission the Prairie Island nuclear units, (i.e., the DECON decommissioning alternative). 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."

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 conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e.,

power production) to facility de-activation and closure. During the first phase, notification is provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee is then prohibited from reactor operation.

The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimate developed for Prairie Island 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 rate of expenditure.

2.1 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 organization 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 applicable to the operating conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.

2.1.1 Engineering and Planning 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 TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 2, Page2 of 7 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 Part 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 Part 61. Major components are further defined as comprising the reactor vessel and internals, steam generators, large bore reactor coolant system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the Part 50.59 process in decommissioning. The proposed activity must not:

o foreclose release of the site for possible unrestricted use, o significantly increase decommissioning costs, o cause any significant environmental impact, or o violate the terms of the licensee's existing 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, a licensee is not allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously evaluated environmental assessments or impact statements. In this instance, the licensee must submit a license amendment for the specific activity and update the environmental report.

The decommissioning program outlined in the PSDAR is designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR Part 20) for protection of personnel from exposure to radiation hazards. It also addresses 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, work packages, and procedures are assembled to support the proposed decontamination and dismantling activities.

2.1.2 Site Preparations Following final plant shutdown, and in preparation for actual decommissioning activities, the following activities are initiated:

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCostAnalysis Section 2, Page3 of 7

• Characterize the site and surrounding environs. This includes radiation surveys and sampling of the work areas, major components (including the reactor vessel and its internals), internal piping, and biological shield.

• Isolate 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 to optimize the overall project schedule. The fuel is transferred -from the pool once it decays to the point that it meets the heat load criteria of the storage/transport containers. Consequently, it is assumed that the fuel pool will remain operational for approximately fifteen years following the cessation of plant operations while the residual inventory is transferred to the ISFSI.

• Specify of transport and disposal requirements .for activated materials and/or hazardous materials, including shielding and waste stabilization.

. Develop 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.

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 Part 50 operating license. Significant decommissioning activities in this .phase include:

• Construct 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.

• Reconfigure and modify site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on- and off-site) to facilitate hauling and transport. Modifications may be required to the 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 fabricate temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

• Procure (lease or purchase) of shipping canisters, cask liners, and industrial packages.

" Decontaminate components and piping systems as required to control (minimize) worker exposure.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document XO I-1586-002, Rev. 0 DecommissioningCost Analysis Section 2, Page4 of 7 o Remove piping and components no longer essential to support decommissioning operations.

• Remove control rod drive housings and the head service structure from reactor vessel head. Segment the vessel closure head.

" Remove and segment the upper internals assemblies. Segmentation will maximize the loading of the shielded transport casks (i.e., by weight and activity). The operations are conducted under water using remotely operated tooling and contamination controls.

o Disassemble and segment the remaining reactor internals, including the core former and lower core support assembly. Some material is expected to exceed Class C disposal requirements. That material will be packaged in a modified spent fuel storage canister for geologic disposal.

o Segment 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.

o Remove activated portions of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the associated cubicles necessary for access and component extraction are removed.

o Remove the steam generators and pressurizer for controlled disposal. The steam domes are removed for off-site processing. The lower shell is sealed and the nozzles and other openings welded closed. These components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized. Steel shielding is added, as necessary, to those external areas of the steam generators to meet transportation limits and regulations.

o Transfer any remaining spent fuel from the storage pool to the ISFSI.

At least two years prior to the anticipated date of license termination, a LTP is required.

Submitted as a supplement to the FSAR, or equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the.

site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including:

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning CostAnalysis Section 2, Page 5 of 7

• Remove 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).

" Remove steel liners from refueling canal, disposing of the activated and contaminated sections as radioactive waste. Remove any remaining activated/ contaminated concrete.

• Survey decontaminated areas of the containment structure.

• Remediate and remove the contaminated equipment and material from the mechanical and electrical auxiliary and fuel handling buildings and any other contaminated facility.

Radiation and contamination controls are utilized until residual levels indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems and components (both clean and contaminated) located within these buildings.

This activity facilitates surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.,

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

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

Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)."I'181 This 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 final termination of the license.

The NRC will terminate the operating license(s) 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 Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCostAnalysis Section 2, Page6 of 7 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 may 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, fuel handling and mechanical and electrical auxiliary buildings. Verifying that subsurface radionuclide concentrations meet NRC site release requirements may require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity is 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 option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.

This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity. Foundations and exterior walls are removed to a nominal depth of three feet below grade. The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.

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 materials are trucked to an off-site area for disposal as construction debris.

2.4 ISFSI OPERATIONS AND DECOMMISSIONING The ISFSI will continue to operate under a site-specific license as authorized by 10 CFR Part 72. Assuming the DOE begins to remove fuel from the Prairie Island site in 2028, the process is not expected to be completed until 2053. Any delay in the transfer process, for example, due to a delay in the scheduled opening of the geologic repository, a slower acceptance rate, or a combination of a delayed start date and lower transfer rate, can result TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentX01-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 2, Page 7 of 7 in a longer on-site residence time for the fuel discharge from the reactors, as well as additional caretaking expenses.

At the conclusion of the spent fuel transferprocess, the ISFSI will be decommissioned. The Commission will terminate the license, when 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.

The assumed design for the ISFSI is based upon the use of the TN-40 cask from Transnuclear. The Prairie Island ISFSI already contains twenty-four TN-40 casks, and Xcel Energy has indicated that the remainder of the Prairie Island spent fuel will be loaded into TN-40 casks as well. Therefore the TN-40 is used as a basis for this cost analysis. For purposes of this cost analysis, it is assumed that the spent fuel is shipped to DOE within the TN-40 casks. The concrete storage pad will then be removed, and the area graded and landscaped to conform to the surrounding environment. Once the spent fuel has been removed from the casks by DOE at the geologic repository, the TN-40 casks will be disposed of as low-level waste.

TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page I of 34

3. COST ESTIMATE The cost estimate prepared for decommissioning the Prairie Island units considers the unique features of the plant, including the nuclear steam supply system, power generation systems, support services, plant structures, 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 COST ESTIMATE The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,E11 updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects. This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluations 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 estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[1 9] and the DOE "Decommissioning Handbook.",1 20 1 These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations.

Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs

($/inch) 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. [21]

The unit factor method provides a demonstrable basis for establishing a reliable cost estimate. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.

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 TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 2 of 34 Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-I nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

Work Difficulty Factors The estimate follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures.

Changes to worker exposure limits may impact the decommissioning cost and project schedule.

Work difficulty adjustment factors (WDFs) account for the inefficiencies in working in a power plant environment. The factors are assigned to each unique set of unit cost factors, commensurate with the inefficiencies associated with working in confined, hazardous environments. The ranges used for the WDFs are as follows:

• Access Factor 10% to 20%

• Respiratory Protection Factor 10% to 50%

• Radiation/ALARA Factor 10% to 37%

• Protective Clothing Factor 0% to 30%

• Work Break Factor 8.33%

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

Scheduling Program Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiological controlled areas. The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is based upon productivity information available from the "Building Construction Cost Data" publication.

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

PrairieIsland Nuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCostAnalysis Section 3, Page3 of 34 program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the result.

3.3 IMPACT OF DECOMMISSIONING MULTIPLE REACTOR UNITS In estimating the near simultaneous decommissioning of two co-located reactor units there can be opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities. There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitations on when final status surveys can take place. For purposes of the estimate, Units 1 and 2 are assumed to be essentially identical. Common facilities have been assigned to Unit 2. A summary of the principal impacts are listed below.

• The sequence of work generally follows the principal that the work is done at Unit 1 first, followed by similar work at Unit 2. This permits the experience gained at Unit 1 to be applied by the workforce at the second ,unit. It should be noted however, that the estimate does not consider productivity improvements at the second unit, since there is little documented experience with decommissioning two units simultaneously. The work associated with developing activity specifications and procedures can be considered essentially identical between the two units, therefore the second unit costs are assumed to be a fraction of the first unit (- 40%).

o Segmenting the reactor vessel and internals will require the use of special equipment.

The cost of procuring that equipment is assumed to be shared on an equal basis between the two units. In addition, the decommissioning project will be scheduled such that Unit 2's reactor internals and vessel are segmented immediately after the activities at Unit I have been completed.

o Some program management and support costs, particularly costs associated with the more senior positions, can be avoided with two reactors undergoing decommissioning simultaneously. As a result, the estimate is based on a "lead" unit that includes these senior positions, and a "second" unit that excludes these positions. The designation as lead is based on the unit undertaking the most complex tasks (for instance vessel segmentation) or performing tasks for the first time.

• The final radiological survey schedule is also affected by a two-unit decommissioning schedule. It would be considered impractical to try to complete the final status survey of Unit 1, while Unit 2 still has ongoing radiological remediation work and waste handling in process. As a result, Unit I is assumed to enter a delay period after completion of radiological remediation, such that the final status survey can be completed for the station. During this delay, program management costs are reduced accordingly.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 4 of 34

• The final demolition of buildings at Units 1 and 2 are considered to take place concurrently. This is considered a reasonable assumption since. access to the buildings is considered good at the station.

• Unit 1, as the first unit to enter decommissioning, incurs the majority of site characterization costs.

" Shared systems and structures are generally assigned to Unit 2.

• Station costs such as ISFS1 operations, emergency response fees, regulatory agency fees, and insurance are generally allocated on an equal basis between the two units.

3.4 ,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 (license termination and site restoration).

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

3.4.1 Contingency

'The activity- and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study.

"Contingencies" are defined in the American Association of Cost Engineers "Project and Cost Engineers' Handbook"' 221as "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 anticipated operating life of the station.

TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 5 of 34 Contingency funds are an integral part of the totalý cost to complete the decommissioning process. Exclusion of this component puts at risk a successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 0% to 75%, depending on the degree of difficulty judged to be appropriate from TLG's actual decommissioning experience. The contingency values used in this study are consistent with those developed in the AIF/NESP-036 study and are as follows:

• Decontamination 50%

• Contaminated Component Removal 25%

" Contaminated Component Packaging 10%

• Contaminated Component Transport 15%

" Low-Level Radioactive Waste Disposal 25%

• Reactor Segmentation 75%

• Nuclear Steam Supply System Component Removal 25%

• Reactor Waste Packaging 25%

• Reactor Waste Transport 25%

• Reactor Vessel Component Disposal 50%

• Greater-than-Class C Disposal 15%

" Non-Radioactive Component Removal 15%

• Heavy Equipment and Tooling 15%

• Supplies 25%

• Engineering 15%

" Energy 15%

• Characterization and Termination Surveys 30%

• Construction 15%

• Property Taxes 0%

• Fees 10%

• Insurance 10%

• Staffing 15%

The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of each detailed estimate as provided in Appendix C.

TLG Services, Inc.

-PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 6 of 34 3.4.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk. Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur. Consideration is sometimes necessary to generate a level of-confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term "financial risk." Included within the category of financial risk are:

" 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 plant drawings.

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

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

• Pricing changes for basic inputs such as labor, energy, -materials, and disposal.

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

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

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 7 of 34 3.5 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study.

3.5.1 Spent Fuel Management The cost to dispose the spent fuel generated from plant operations is not reflected within the estimate to decommission the Prairielsland units. 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 (the disposal cost is financed by a 1 millikWhr surcharge paid into the DOE's waste fund during operations). However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimate, as described below.

Operation of the DOE's yet-to-be constructed geologic repository is contingent upon the review and approval of the facility's license application by the NRC, the successful resolution of pending litigation, and the development of a national transportation system. The timetable issued by the DOE in 2006 is based upon submittal of the license application in mid-2008 (The application was submitted to the NRC in June 2008). Assuming a timely review (the application for the Private Fuel Storage's facility on the Goshute reservation took 8'/2 years), the DOE expects that receipt of fuel could begin as early as 2017. However, for purposes of this estimate, full scale operations at the repository are not expected to commence before 2025.

Spent Fuel Management Model Completion of the decommissioning process is highly dependent upon the DOE's ability to remove spent fuel from the site. The timing for removal of spent fuel from the site is based upon the DOE's most recently published annual acceptance rates of 400 MTU/year for year 1, 3,800 MTU total for years 2 through 4 and 3,000 MTU/year for year 5 and beyond.[ 231 The DOE contracts provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst utilities and the option of providing priority acceptance from permanently shutdown nuclear reactors. Because it is unclear how these mechanisms may operate once DOE begins accepting spent fuel from commercial reactors, this study assumes that DOE will accept spent fuel in an oldest fuel first order.

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning CostAnalysis Section 3, Page 8 of 34 ISFSI This analysis assumes that the existing ISFSI is modified at the cessation of plant operations to facilitate the decommissioning of the two nuclear units. The storage facility is sized to accommodate the fuel present in the storage pool at shutdown that cannot be transferred directly to the DOE.

Construction, operation and maintenance costs for the 1SFSI are included within the estimate and address the costs for staffing the facility, as well as security, insurance, and licensing fees. The estimate also includes the costs to purchase, load, and transfer the Transnuclear TN-40 metal cask storage system spent fuel storage canisters from the pool to the 1SFSI. Costs are also provided for 'the final disposition of the facilities once the transfer is complete.

Storage Canister Design The design and capacity of the ISFSI is based upon the TN-40 dry cask storage system. A capacity of 40 fuel assemblies is used, at a unit cost of approximately

$4,095,000 per cask.

Canister Loading and Transfer A cost of $100,000 is used for the labor and equipment to load each TN-40 onto a DOE-provided railcar for transport of the spent fuel to the DOE.

Operations and Maintenance An annual cost (excluding labor) of approximately $746,000 and $87,000 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles). Over the next fifteen years the assemblies are packaged into TN-40s -for transfer to the ISFSI for transfer to the DOE. It is assumed that the fifteen years also provides the necessary cooling period for -the final core to meet transport system requirements for decay heat and/or the dry cask storage vendor's system. Once the pool is emptied, the spent fuel storage and handling facilities are available for decommissioning.

ISFSI Design Considerations The TN-40° is an ultra-high capacity vertical storage system with self-contained steel and borated resin shielding. Borated aluminum plates and stainless steel tubes form the basket assembly. The Prairie Island ISFSI already contains twenty-four TN-40 casks, and Xcel Energy has indicated that the remainder of the Prairie Island TLG Services, Inc.

2 PrairieIslandNuclear GeneratingPlant Document XOI-1586-002, Rev. 0 Decommissioning CostAnalysis Section 3, Page 9 of 34 spent fuel will be loaded into TN-40 casks as well. Therefore the TN-40 is used as a basis for this cost analysis. While it is expected that surface contamination within the TN-40 casks could be removed to levels that meet the site release criteria, it is also expected that the casks will have some level of neutron-ihduced activation as a result of the long-term storage of the fuel (i.e., to levels exceeding free-release limits). The cost of the disposal of this material, as well as the demolition of the ISFSI, is reflected within the estimate.

GTCC The dismantling of the reactor internals generates radioactive waste considered unsuitable for shallow land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the Federal Government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. Although there are strong arguments that GTCC waste is covered by the spent fuel contact with DOE and the fees being paid pursuant to that contract, DOE has taken the position that GTCC waste is not covered by that contract or its fees and that utilities, including Xcel Energy, will have to pay an additional fee for the disposal of their GTCC waste. However, to date, the Federal Government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the estimate to decommission the Prairie Island units includes an allowance for the disposition of GTCC material.

For purposes of this study, GTCC is packaged in the same canisters used to store 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 remains in storage with the spent fuel at the ISFSI.

3.5.2 Reactor Vessel and Internal Components The reactor vessel internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed underwater when practical where a remote cutter is installed. Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.

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

As stated previously, the dismantling of reactor internals will generate radioactive waste considered unsuitable for shallow land disposal (i.e., GTCC). Although the material is not classified as high-level waste by the NRC, DOE at one time TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant DocumentXO)-1586-002, Rev. 0 DecommissioningCost Analysis Secion 3, Page 10 of 34 indicated it would accept title to this waste for disposal at the future high-level waste repository. [24] However, the current DOE position is unclear, and DOE Ihas not been forthcoming with an acceptance. criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and waste form requirements. As such, for purposes of this study, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites recently decommissioned. Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel. Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (including the internals).

However, its location on .the Columbia River simplified the transportation analysis since:

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

• there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and transport speeds were very low, limited by the overland transport vehicle and the river barge.

As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State. The characteristics of this arid site proved favorable in demonstrating compliance with land disposal regulations.

,It is not known whether this option will be available when the Prairie 'Island units cease 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. As such, the estimate assumes segmentation of the reactor vessel, 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.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning CostAnalysis Section 3, Page)) of 34 3.5.3 Primary System Large Components The reactor coolant system components are assumed to be decontaminated using chemical agents prior to the start of cutting operations. This type of decontamination can be expected to have a significant ALARA impact in the DECON scenario, since in this scenario the removal work is done within the first few years of shutdown. It should be noted that if the decommissioning work is significantly delayed, chemical decontamination might not be necessary. 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 techniques involved are also applicable to other large radioactively-contaminated components, such as heat exchangers and the pressurizer. The steam generators' size and weight, their location within the reactor building, as well as the disposal facility waste acceptance criteria, and access to transportation will ultimately determine the removal, transportation, and disposal strategy.

A crane is set up for the removal of the generators. It can also be used to move portions of the steam generator cubicle walls and floor slabs from the reactor building to a location where they can be decontaminated and transported to the material handling area. Interferences within the work area, such as grating, piping, and other components are removed to create sufficient lay-down space for processing these large components.

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

Disposal costs are based upon the displaced volume and weight of the primary side portions of the steam generators. Each component is then loaded onto a rail car for transport to the disposal facility. The secondary side is assumed to be sent to an off-site waste processor.

Reactor coolant piping is cut from the reactor once the water level (used for personnel shielding during dismantling and cutting operations in and around the reactor) is dropped below the elevation of associated nozzle(s). The piping is boxed and transported by shielded van. The reactor coolant pumps and motors are lifted out intact, packaged, and transported for disposal.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentXOI-1586-002, Rev. 0 DecommissioningCost Analysis Secion 3, Page 12 of 34 3.5.4 Main Turbine and Condenser The main turbine and condenser are assumed to have only minor levels of contamination. As such, the components are 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 surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.

This estimate assumes that the components can meet free-release limits and ultimately dispositioned as scrap metal.

3.5.5 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I, .11 or III or Surface Contaminated Object, SCO-I or 1I, as described in Title 49.[251 The contaminated material will be packaged in Industrial Packages (IP-1, .IP-2, or IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.

Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.

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

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 3, Page 13 of 34 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 Classes A, B and C material requiring controlled disposal are based upon the mileage to the EnergySolutions facility in Clive, Utah. The existing Barnwell facility rate schedule for non-Atlantic Compact members is used as the cost estimating basis for disposal of the Class B and C material.

Transportation costs for off-site waste processing are based upon the mileage to Memphis, Tennessee. Truck transport costs are estimated using published tariffs from Tri-State Motor Transit.[26 ]

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

The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in the detailed Appendix C, and summarized in Table 5.1. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. The volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

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

Disposal fees are based upon estimated charges, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the majority of the material generated from TLG Services, Inc.

(

PrairieIsland NuclearGeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning CostAnalysis Section 3, Page 14 of 34 the decontamination and dismantling activities is based upon Xcel Energy's current cost for disposal at EnergySolutions facility in Clive, Utah. Disposal costs for the higher activity waste (Class B and C) were estimated using the last available Barnwell rate structure for non-Atlantic Compact members.

3.5.7 Site Conditions Following Decommissioning The NRC will terminate (or amend) the site license(s) 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 typically ends at this point. Building codes and state environmental regulations dictate the next step in the decommissioning process, as well as the owner's future plans for the site.

There are varying degrees to which the Prairie Island site can be restored following the decommissioning of the two nuclear units. The estimate presented herein includes the dismantling of the major structures to just below ground level, backfilling and the collapsing of below grade voids, and general terra-forming such that the site upon which the power block and supplemental structures are located is transformed into a "grassy plain." Certain facilities, which have continued use or value (e.g., the switchyard) are left intact.

3.6 ASSUMPTIONS The following are the major assumptions made in the development of the estimate for decommissioning Prairie Island.

3.6.1 Estimating Basis The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning-cost and project schedule.

TLG Services, Inc.

PrairieIslandNuclear Generating Plant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 15 of 34 3.6.2 Labor Costs The craft labor required to decontaminate and dismantle the Prairie Island units will be acquired through standard site contracting practices. Craft labor costs were based upon information from Xcel Energy. Craft labor costs include applicable overheads and profit.

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

Utility labor costs were provided by Xcel Energy. Average costs were provided by department or' work group and included payroll overheads. Decommissioning Operations Contractor (DOC) labor costs were based on utility labor costs with modified markups to account for employee benefits, DOC overhead and profit.

Severance costs were included as a separate expenditure within the estimate.

Based upon site overhead costs provided by Xcel Energy, an administrative and general cost (A&G) is included. This cost is based on the average annual A&G per person applied to each of the utility staffing positions (number of utility personnel assigned to the project). The A&G cost includes: site overhead costs directly required to support the site decommissioning staff.

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

3.6.3 Design Conditions Activation levels in the vessel and internal components are modeled using NUREG/CR-3474.[27 I Estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Prairie Island components, projected operating life(s), and different periods of decay. Additional short-lived isotopes were derived from CR-0130 [28] and CR-0672 [29j and benchmarked to the long-lived values from CR-3474.

The control elements are disposed of along with the spent fuel (i.e., there is no additional cost provided for their disposal). Disposition of any control elements TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002,Rev. 0 DecommissioningCost Analysis Secion 3, Page16 of 34 stored in the pool from operations is considered an operating expense and therefore not accounted for in the decommissioning estimate.

Activation of the reactor building is confined to the area around the 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 sending it to a landfill. The ultimate disposition of the material removed from the reactor building will depend upon the site release criteria applied, as well as the designated end use for the site.

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

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

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

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

Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Xcel Energy will make economically reasonable efforts

!to salvage equipment following final plant shutdown. However, dismantling techniques assumed for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document XOI-1586-002, Rev. 0 DecommissioningCost Analysis Secion 3, Page17 of 34 It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimate do not include the additional cost for size reduction and preparation to meet "furnace ready" conditions. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. An allowance has been included for the survey and release of all metallic material released from the site.

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

The concrete debris resulting from building demolition activities is crushed on site to reduce the size of the debris. The resulting crushed concrete is used to backfill below grade voids, with the excess assumed to be removed from the site as recycled material at no cost or credit to the decommissioning program. The rebar removed from the concrete crushing process is disposed of as scrap steel in a similar fashion as other scrap metal as discussed previously.

Energ.

For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage (temporary power is run throughout the plant, as needed). Replacement power costs are used to calculate the cost of energy consumed during decommissioning for tooling, lighting, 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 guidance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."' 30° The NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning'CostAnalysis Section 3, Page18 of 34 Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the site security plan in force during the various stages of the project.

3.7 COST ESTIMATE

SUMMARY

Schedules of expenditures are provided in Tables 3.1 and 3.2. The tables delineatethe cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).

The cost elements are also assigned to one of three subcategories: "License Termination,"

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

The "Spent Fuel Management" subcategory contains costs associated with the containerization and transfer of spent fuel to the ISFSI, and ýthe management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g.,

geologic repository) is complete. It also includes spent fuel management expenses incurred prioruto the cessation of plant operations.

"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 3.5.1, 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, GTCC waste is still classified as low-level radioactive waste and, as such, included as a "License Termination" expense.

Decommissioning costs are reported in 2008 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 Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 19 of 34 TABLE 3.1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2013 18,730 3,838 1,168 21 4,071 27,827 2014 54,479 13,925 4,108 3,012 11,618 87,143 2015 57,610 29,919 3,123 22,490 7,706 120,848 2016 42,606 18,193 2,433 12,694 4,973 80,899 2017 33,917 10,326 2,205 5,624 3,731 55,802 2018 15,258 5,605 1,009 1,472 2,584 25,928 2019 8,692 3,944 588 11 2,181 15,416 2020 8,716 3,955 590 11 2,187 15,459 2021 8,692 3,944 588 11 2,181 15,416 2022 8,692 3,944 588 11 2,181 15,416 2023 8,692 3,944 588 11 2,181 15,416 2024 8,716 3,955 590 11 2,187 15,459 2025 8,692 3,944 588 11 2,181 15,416 2026 8,692 3,944 588 11 2,181 15,416 2027 8,692 3,944 588 11 2,181 15,416 2028 8,716 3,955 590 11 2,187 15,459 2029 10,302 3,968 692 607 2,377 17,947 2030 13,819 2,577 893 1,775 5,234 24,299 2031 9,409 3,420 374 10 2,566 i5,779 2032 9,393 4,359 295 0 778 14,825 2033 6,451 2,577 208 0 776 10,011 2034 2,363 96 88 0 775 3,322 2035 2,363 96 88 0 775 3,322 2036 2,369 96 88 0 777 3,331 2037 2,363 96 88 0 775 3,322 2038 2,363 96 88 0 775 3,322 2039 2,363 96 88 0 775 3,322 2040 2,369 96 88 0 777 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant .DocunentX01-1586-002,Rev. 0 DecommissioningCostAnalysis Section 3, Page20 of 34 TABLE 3.1 (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2041 2,363 96 88 0 775 3,322 2042 2,363 96 88 0 775 3,322 2043 2,363 96 88 0 775 3,322 2044 2,369 96 88 0 777 3,331 2045 2,363 96 88 0 775 3,322 2046 2,363 96 88 0 775 3,322 2047 2,363 96 88 0 775 3,322 2048 2,369 96 '88 0 777 3,331 2049 2,363 96 88 0 775 3,322 2050 2,363 96 88 0 775 3,322 2051 2,363 96 88 0 775 3,322 2052 2,369 96 88 0 777 3,331 2053 2,356 313 89 34 11,078 13,869 2054 527 1,070 146 4,054 1,375 7,173 406,770 141,387 24,306 51,900 95,432 719,795 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page21 of 34 TABLE 3.1a PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2013 17,424 591 1,168 21 3,760 22,964 2014 50,558 5,028 4,108 3,012 10,838 73,544 2015 53,047 20,321 3,123 22,490 6,926 105,907 2016 39,046 11,179 2,433 12,694 4,310 69,663 2017 30,956 4,878 2,205 5,624 3,142 46,805 2018 13,540 1,348 1,009 1,472 1,996 19,365 2019 7,413 106 588 11 1,592 9,710 2020 7,433 106 590 11 1,597 9,736 2021 7,413 106 588 11 1,592 9,710 2022 7,413 106 588 11 1,592 9,710 2023 7,413 106 588 11 1,592 9,710 2024 7,433 106 590 11 1,597 9,736 2025 7,413 106 588 11 1,592 9,710 2026 7,413 106 588 11 1,592 9,710 2027 7,413 166 588 11 1,592 9,710 2028 7,433 106 590 11 1,597 9,736 2029 9,234 763 692 607 1,865 13,162 2030 13,737 2,330 893 1,775 5,074 23,810 2031 2,625 195 159 10 1,957 4,945 2032 84 0 0 0 0 84 2033 49 0 0 0 0 49 2034 0 0 0 0 0 0 2035 0 0 0 0 0 0 2036 0 0 0 0 0 0 2037 0 0 0 0 0 0 2038 0 0 0 0 0 0 2039 0 0 0 0 0 0 2040 0 0 0 0 0 0 Note: Columns may not add dueto rounding TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page22 of 34 TABLE 3.1a (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT,, UNIT 1

,SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2041 0 0 0 0 0 0 2042 0 0 0 0 0 0 2043 0 0 0 0 0 0 2044 0 0 0 0 0 0 2045 0 0 0 0 0 0 2046 0 0 0 0 0 0 2047 0 0 0 0 0 *0 2048 0 0 0 0 0 0 2049 0 0 01 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 220 0 0 10,294 10,514 2054 0 0 0 0 0 0 304,487 47,913 21,677 47,812 66,098 487,988 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page23 of 34 TABLE 3.1b PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2013 1,082 3,246 0 310 4,639 2014 2,966 8,897 0 781 12,644 2015 3,191 9,574 0 609 13,374 2016 2,332 6,995 0 590 9,917 2017 1,811 5,434 0 589 7,834 2018 1,418 4,254 0 589 6,260 2019 1,279 3,838 0 589 5,707 2020 1,283 3,849 0 590 5,722 2021 1,279 3,838 0 589 5,707 2022 1,279 3,838 0 589 5,707 2023 1,279 3,838 0 589 5,707 2024 1,283 3,849 0 590 5,722 2025 1,279 3,838 0 589 5,707 2026 1,279 3,838 0 589 5,707 2027 1,279 3,838 0 589 5,707 2028 1,283 3,849 0 590 5,722 2029 1,068 3,205 0 512 4,785 2030 82 247 0 160 489 2031 1,754 165 64 608 2,592 2032 2,387 148 88 777 3,401 2033 2,373 126 88 775 3,362 2034 2,363 96 88 775 3,322 2035 2,363 96 88 775 3,322 2036 2,369 96 88 777 3,331 2037 2,363 96 88 775 3,322 2038 2,363 96 88 775 3,322 2039 2,363 96 88 775 3,322 2040 2,369 96 88 777 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

.PrairieIslandNudear GeneratingPlant Document X01-1586-002,Rev. 0 Decommissioning CostAnalysis Secion 3, Page 24 of 34 TABLE 3.1b (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2041 2,363 96 88 0 775 3,322 2042 2,363 96 88 0 775 3,322 2043 2,363 96 88 0 775 3,322 2044 2,369 96 88 0 777 3,331 2045 2,363 96 88 0 775 3,322 2046 2,363 96 88 0 775 3,322 2047 2,363 96 88 0 775 3,322 2048 2,369 96 88 0 777 3,331 2049 2,363 96 '88 0 775 3,322 2050 2,363 96 88 0 775 3,322 2051 2,363 96 88 0 775 3,322 2052 2,369 96 88 0 777 3,331 2053 2,356 93 89 34 784 3,355 2054 527 1,070 146 4,054 1,375 7,173 81,073 83,694 2,152 4,088 29,087 200,094 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis i Section 3, Page 25 of 34 TABLE 3.1c PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2013 224 0 0 0 224 2014 955 0 0 0 955 2015 1,371 24 0 171 1,567 2016 1,229 18 0 73 1,320 2017 1,150 13 0 0 1,163 2018 299 3 0 0 303 2019 0 0 0 0 0 2020 0 0 0 0 0 2021 0 0 0 0 0 2022 0 0 0 0 0 2023 0 0 0 0 0 2024 0 0 0 0 0 2025 0 0 0 0 0 2026 0 0 0 0 0 2027 0 0 0 0 0 2028 0 0 0 0 0 2029 0 0 0 0 0 2030 0 0 0 0 0 2031 5,031 3,060 150 1 8,242 2032 6,922 4,210 206 1 11,340 2033 4,028 2,450 120 1 6,600 2034 0 0 0 0 0 2035 0 0 0 0 0 2036 0 0 0 0 0 2037 0 0 0 0 0 0 0 0 0 0 2038 2039 0 0 0 0 0 2040 0 0 0 0 0 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document XOl-1586-002, Rev. 0 DecommissioningCostAnalysis Section 3, Page26 of 34 TABLE 3.1c (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy 'Burial Other Total 2041 0 0 0 0 0 0 2042 0 0 0 0 0 0 2043 0 0 0 0 0 0 2044 0 0 0 0 0 0 2045 0 0 0 0 0 0 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0' 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 21,210 9,780 476 0 247 31,713 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page27 of 34 TABLE 3.2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2014 7,510 1,689 516 8 1,751 11,474 2015 44,360 11,510 3,456 1,370 9,742 ,70,437 2016 56,365 28,466 3,816 19,135 7,414 115,195 2017 56,382 23,703 2,548 17,218 5,536 105,387 2018 53,429 11,639 2,205 6,749 3,746 77,769 2019 34,256 8,540 1,509 3,851 3,067 51,222 2020 8,877 4,445 590 11 2,173 16,096 2021 8,853 4,433 588 11 2,168 16,052 2022 8,853 4,433 588 11 2,168 16,052 2023 8,853 4,433 588 11 2,168 16,052 2024 8,877 4,445 590 11 2,173 16,096 2025 8,853 4,433 588 11 2,168 16,052 2026 8,853 4,433 588 11 2,168 16,052 2027 8,853 4,433 588 11 20168 16,052 2028 8,877 4,445 590 11 2,173 16,096 2029 13,330 4,526 691 747 2,325 21,619 2030 28,047 3,233. 896 2,223 7,473 41,872 2031 19,269 4,650 374 11 3,906 28,210 2032 18,641 5,901 295 0 779 25,617 2033 11,832 3,474 208 0 776 16,291 2034 2,363 96 88 0 775 3,322 2035 2,363 96 88 0 775 3,322 2036 2,369 96 88 0 777 3,331 2037 2,363 96 88 0 775 3,322 2038 2,363 96 88 0 775 3,322 2039 2,363 96 88 0 775 3,322 2040 2,369 96 88 0 777 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNudear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page 28 of 34 TABLE 3.2 (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2041 2,363 96 88 0 775 3,322 2042 2,363 96 88 0 775 3,322 2043 2,363 96 88 0 775 3,322 2044 2,369 96 88 0 777 3,331 2045 2,363 96 88 0 775 3,322 2046 2,363 96 88 0 775 3,322 2047 2,363 96 88 0 775 3,322 2048 2,369 96 88 0 777 3,331 2049 2,363 96 88 0 775 3,322 2050 2,363 96 88 0 775 3,322 2051 2,363 96 88 0 775 3,322 2052 2,369 96 88 0 777 3,331 2053 2,356 313 89 34 11,078 13,869 2054 527 1,070 146 4,054 1,375 7,173 470,976 150,471 23,721 55,497 93,229 793,894 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant Document XO)-1586-002, Rev. 0 Decommissioning CostAnalysis Section 3, Page 29 of 34 TABLE 3.2a PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2014 6,990 256 516 8 1,614 9,385 2015 41,214 3,018 3,456 1,370 8,961 58,018 2016 51,793 18,669 3,816 19,135 6,631 100,043 2017 52,342 15,913 2,548 17,218 4,835 92,856 2018 50,503 6,469 2,205 6,749 3,157 69,083 2019 31,967 3,732 1,509 3,851 2,478 43,538 2020 7,431 106 590 11 1,583 9,721 2021 7,411 106 588 11 1,579 9,694 2022 7,411 106 588 11 1,579 9,694 2023 7,411 106 588 11 1,579 9,694 2024 7,431 106 590 11 1,583 9,721 2025 7,411 106 588 11 1,579 9,694 2026 7,411 106 588 11 1,579 9,694 2027 7,411 106 588 11 1,579 9,694 2028 7,431 106 590 11 1,583 9,721 2029 12,124 908 691 747 1,811 16,282 2030 27,964 2,986 896 2,223 7,313 41,382 2031 5,728 304 159 11 3,296 9,499 2032 36 0 0 0 0 36 2033 21 0 0 0 0 21 2034 0 0 0 0 0 0 2035 0 0 0 0 0 0 2036 0 0 0 0 0 0 2037 0 0 0 0 0 0 2038 0 0 0 0 0 0 2039 00 0 0 0 0 0 2040 0 0 0 0 0 Note:, Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0

-DecommissioningCostAnalysis Section 3, Page 30 of 34 TABLE 3.2a (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2041 0 0 0 0 0 0 2042 0 .0 0 0 0 0 2043 0 0 0 0 0 0 2044 0 "0 0 0 0 0 2045 0 0 0 0 0 0 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 220 0 0 10,294 10,514 2054 0 0 0 0 0 0 347,441 53,427 21,092 51,409 64,614 537,983 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page31 of 34 TABLE 3.2b PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars) '

Equipment &

Year Labor Materials Energy Burial Other Total 2014 478 1,433 0 137 2,047 2015 2,831 8,492 0 781 12,104 2016 3,258 9,775 0 653 13,687 2017 2,588 7,765 0 589 10,942 2018 1,719 5,157 0 589 7,464 2019 1,600 4,800 0 589 6,989 2020 1,446 4,339 0 590 6,376 2021 1,442 4,327 0 589 6,358 2022 1,442 4,327 0 589 6,358 2023 1,442 4,327 0 589 6,358 2024 1,446 4,339 0 590 6,376 2025 1,442 4,327 0 589 6,358 2026 1,442 4,327 0 589 6,358 2027 1,442 4,327 0 589 6,358 2028 1,446 4,339 0 590 6,376 2029 1,206 3,618 0 513 5,337 2030 83 248 0 160 490 2031 3,198 165 64 608 4,035 2032 4,373 148 88 777 5,387 2033 3,529 126 88 775 4,518 2034 2,363 96 88 775 3,322 2035 2,363 96 88 775 3,322 2036 2,369 96 88 777 3,331 2037 2,363 96 88 775 , 3,322 2038 2,363 96 88 775 3,322 2039 2,363 96 88 775 3,322 2040 2,369 96 88 777 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentXOl-1586-002, Rev. 0 DecommissioningCostAnalysis Secion 3, Page32 of 34 TABLE 3.2b (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES

,(thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2041 2,363 96 88 0 775 3,322 2042 2,363' 96 88 0 775 3,322 2043 2,363 96 88 0 775 3,322 2044 2,369 96 88 0 777 3,331 2045 2,363 96 88 0 775 3,322 2046 2,363 96 88 0 775 3,322 2047 2,363 96 88 0 775 3,322 2048 2,369 96 88 0 777 3,331 2049 2,363 96 88 0 775 3,322 2050 2,363 96 88 0 775 3,322 2051 2,363 96 88 0 775 3,322 2052 2,369 96 88 0 777 3,331 2053 2,356 93 89 34 784 3,355 2054 527 1,070 146 4,054 1,375 7,173 85,659 83Y694 2,152 4,088 28,368 203,961 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentXO)-1586-002, Rev. 0 Decommissioning CostAnalysis Section 3, Page33 of 34 TABLE 3.2c PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2014 42 0 0 0 42 2015 315 0 0 0 315 2016 1,314 22 0 129 1,465 2017 1,452 25 0 112 1,589 2018 1,208 14 0 0 1,221 2019 688 8 0 0 696 2020 0 0 0 0 0 2021 0 0 0 0 0 2022 0 0 0 0 0 2023 0 0 0 0 0 2024 0 0 0 0 0 2025 0 0 0 0 0 2026 0 0 0 0 0 2027 0 0 0 0 0 2028 0 0 0 0 0 2029 '0 0 0 0 0 2030 0 0 0 0 0 2031 10,343 4,181 150 2 14,676 2032 14,232 5,753 206 2 20,193 2033 8,283 3,348 120 1 11,752 2034 0 0 0 0 0 2035 0 0 0 0 0 2036 0 0 .0 0 0 2037 0 0 0 0 0 2038 .0 0 0 0 0 2039 0 0 0 0 0 2040 0 0 0 0 0 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 3, Page34 of 34 TABLE 3.2c (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Year Labor Materials Energy Burial Other, Total 2041 0 0 0 0 0 0 2042 0 0 0 0 0 0 2043 0 0 0 0 0 0 2044 0 0 0 0 0 0 2045 0 0 0 0 0 0 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 37,877 13,350 476 0 247 51,950 Note: Columns may not add due to rounding TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 4, PageI of 5

4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follows the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan described in Section 3.5.1.

A schedule or sequence of activities for the DECON alternative is presented in Figure 4.1. The scheduling sequence assumes that fuel is removed from the spent fuel pool approximately five and one-half years following the permanent cessation of plant operations. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost table, but reflect dividing some activities for clarity and combining others for convenience.31 The schedule was prepared using the "Microsoft Project Professional 2003" computer software.[ ]

4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique)

Software Package. The work activity durations used in the precedence network reflect the actual 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:

o The fuel handling area of the Auxiliary Building is isolated until such time that all 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 is complete.

o 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.

o 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.

o 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.

o For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activity.

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 4,Page 2 of 5 4.2 PROJECT SCHEDULE The period-dependent costs presented in Appendix C are based upon the durations developed -in the schedules for decommissioning. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is shown for the spent fuel storage period, which determines the release of the auxiliary building for final decontamination. A project timeline is provided in Figure 4.2.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document Xfl-1586-002, Rep. 0 DecommissioningCost Analysis Sedion 4, Page 3of 5 FIGURE 4.1 ACTIVITY SCHEDULE Task Name 42 2016 013214 9015 201712018 1 2 0.90 12021 12021 4 1 .5 12 72 0120, 2912030 2031 2032 2033 PmrbWahid Unit1 &2*lardk 11~i o+UII+F+III++

im iim m+ * +@+ ii i- om* ++++

iiiN +i+++ ++++++l

+t+g++t+

- - t+ -+++**+[*@

- +++

IM++J~$

Shutdownni I Wi PeriodIsaUit I -Shisin timpghlruaniton Certificateofpermanent ressatron ofope.rtions submitted Fuelstorae pooloperations peconfisour plant Po epecifarstino actwiviy Perform soecharaltenrimon 7L UL ttritiencertificate ofpernonent removaloffuelsubmitted Sitesiecific rust decomiuounisionmop estoulate submilted lofr'rt mobi 2i Perd lb UnilI-Ieoommisseio gpreparations Fuelstorage pooloperainos 7I ReeonioPw plant oimuedi Prepare setaiedworkprocedures Decon NSSS E

LIoatespntfuelpool Period 2a Utni -Imp component removal Fuelstoraste poolopprotious Preparatson forreacor ceslolrinoral Re oar vessel& mitrnul Remainino l]rmeNSSStoonpuinent diposainot Non-esoential systems Main tarlinetenerator Mainoondenser hLene terrmatouu plansubmitted Pernod Unit - Ncontaimmanuon (wetfuel)

Fuelstorsgepoolopsratioi.a Remuve si"eitenotsupporting wetfueleore Decon notsuppoDrfi bsooliage w*tfuelstorage leonee i rrouoatuon planapproved ehrd f. I-Dlay beforepoolDWJON .. . .. . a.. . . .. .. .. . . . . . .

• I I -

Delay perndpor topoolDECONX PeriodZiUnitI- Demotaminamon ofpool Remove remmiorna systems Derunwetfuelstorage area Ulo2 'peratonE u Unit2 Shutiwn PeriodlaUrnit2-*Shutdown Iluol tr-asition Certifate ofpeom entresoqtin ofoperationsoubmiirfd TLG Services, Inc.

PrarieIsiad Nudear Gemewng Plant Documeuu XE1-1586-002, Rev. 0 De Cost Andysis Seclk 4, Poe 4 of5 FIGURE 4.1 ACTIVITY SCHEDULE (continued)

Task Name 2013 Fuelgarage Poolo eaueuý Reconiuarep p Ir Wuue scsi mit.ofprMauetiremoa ffuel4binitted Site5pes ur Ccsteetiatesubmited3

"~meioa Period bUnd 2-Nxawsoi prepmaonat Fuelgaurage pol upratioos RtofmasPlntfei one At Dyfuelstraietopranon Prewptakad work e rita prcs~

DItmNzlrSSS orcun~ i W*Spent fuetil Poolm Per~Uiod21d -Lacotmpone~n~t remoa Fuelqrsrgrpoolopeaiucs Pireaaion sot k pslemo fr rem aul Ltsp slterup conitwriars*& -aýtFe.s~

No"eou Sytemaopa s e Maicndg.Iehiefrnpo~

Remuve vqmo!nost upoan;les ue>org NiDMODu bwa.DI Suppotingt atnfueal 5ra Foroniterauneeopnapri

\1(reoa&-Dly bfre o O Litiesa terminartapedlP r377 Perid PUnit I A&2-Phdhomtergtant.

TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 4, Page5 of 5 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale)

Unit 1 Shutdown Period 1 Period 3 Transition and Period 2 Site ISFSI ISFSI Preparations Decommissioning Restoration Operations D&D I.......................................................................................................................................................................................

I ........................................... ................................................................... .....................I 1 4 08/2013 08/2013 02/2015 04/2031 12/2053 07/2054 08/2033 ISFSI expansion Cask installation Spent fuel campaigns -*

Storage Pool Empty 10/2029 Unit 2 Shutdown Period 1 Period 3 Transition and Period 2 Site ISFSI' ISFSI Preparations Decommissio Restoration Operations I D&D 10/2014 10/2014 04/2016 04/2031 08/2033 12/2053 07/2054 TLG Services, Inc.

PrairieislandNuclear GeneratingPlant Document X01-)1586-002, Rev. 0 DecommissioningCostAnalysis Section 5, Page I of 3

5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination ofthe NRC license. This currently requires the-remediation of all radioactive material at the site in excess of applicable legal limits.

Under the Atomic Energy Act,[321 the NRC is responsible for :protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.

Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR Parts 173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in 10 CFR § 173.411). For this study, commercially available steel' containers are presumed to be used for the disposal of piping, small components, and concrete.

Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.

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

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

No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone (i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides). While the dose rates decrease with time, radionuclides such as 137Cs will still control the disposition requirements.

The waste material produced in the decontamination and dismantling of the nuclear units 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 TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 5, Page 2 of 3 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 facility was used as a proxy for future disposal facilities. Separate rates were used for containerized waste and large components, including the steam generators and reactor coolant pump motors.

Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste.

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 available published disposal rates for Barnwell for non-Atlantic Compact members. Additional surcharges were included for activity, dose rate, and/or handling added as appropriate for the particular package.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentXO)-1586-002, Rev. 0 DecommissioningCost Analysis Setion 5, Page3 of 3 TABLE 5.1 DECOMMISSIONING WASTE

SUMMARY

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

Low-Level Radioactive Waste EnergySolutions A 47,143 4,696,459 (near-surface disposal) EnergySolutions B 4,938 608,324 EnergySolutions C 1;837 224,252 Greater than Class C Spent Fuel GTCC 1,024 211,190 (geologic repository) Equivalent Processed/Conditioned Recycling A 1-1,646,327 (off-site recycling center) Vendors Low-Level Radioactive Waste EnergySolutions Containerized 104,031 16,103,225 Low-Level Radioactive Waste EnergySolutions Bulk/ DAW 61,298 2,000,870 Total [2] 220,271 35,490,647

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

[2]

'Columns may not add due to rounding.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentXOI-1586-002, Rev. 0 DecommissioningCost Analysis Section 6, Page I of 3

6. RESULTS The cost projected to promptly decommission the two Prairie Island nuclear units is estimated to be $1,514 million. The estimate is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, and low-level radioactive waste disposal practices and high-level waste management considerations.

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

As described in this report, the spent fuel pool will remain operational for fifteen years following the cessation of operations. The pool will be isolated to allow decommissioning operations to proceed in and around the pool area. Over the fifteen year period, the spent fuel will be packaged for transfer 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 low-level radioactive material requiring controlled disposal is at the EnergySolutions facility in Clive, Utah. Highly activated components, requiring additional isolation from the environment, are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.

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

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of3 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 (labor and fuel) of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck.

Decontamination is used to reduce the plant's radiation fields and minimize worker exposure.

Slightly Contaminated material or material located within a contaminated area is sent to an off-site processing center (i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for uncontrolled release in-situ). Centralized processing centers have proven to be a more economical means of handling the large volumes 'of material produced in the dismantling of a nuclear unit.

License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings.

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

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 6, Page3 of 3 TABLE 6.1 COST

SUMMARY

DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)

Cost Element Unit 1 Unit 2 Total Percentage Decontamination 8,873 14,101 22,974 1.5 Removal 71,116 91,943 163,059 10.8 Packaging 18,148 18,447 36,595 2.4 Transportation 6,828 7,411 14,238 0.9 Waste Disposal 48,983 50,257 99,240 6.6 Off-site Waste Processing 13,211 15,534 28,745 1.9 Program Management Il 334,149 381,084 715,233 47.3 Spent Fuel Pool Isolation 5,911 5,911 11,822 0.8 Spent Fuel Management (direct costs) [2] 128,061 127,342 255,402 16.9 Insurance and Regulatory Fees 24,638 22,277 46,914 3.1 Energy 24,306 23,721 48,027 3.2 Characterization and Licensing Surveys 8,276 9,713 17,989 1.2 Property Taxes 21,069 19,904 40,973 2.7 Miscellaneous Equipment 6,228 6,250 12,478 0.8 Total [3] 719,795 793,894 1,513,689 100.0 Cost Element Unit 1 Unit 2 Total Percentage License Termination 487,988 537,983 1,025,971 67.8 Spent Fuel Management 200,095 203,961 404,056 26.7 Site Restoration 31,713 51,950 83,662 5.5 Total [3] 719,795 793,894 1,513,689 100.0

[I] Includes engineering and security costs

[2] Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees

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

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCostAnalysis Section 7, Page I of 3

7. REFERENCES I. "Decommissioning Cost Analysis for the Prairie Island Nuclear Generating Plant," TLG Services Document No. XO I- 1526-002, Rev. 0, October 2005

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

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 Rulemaking, 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 and Amendments," U.S. Department of Energy's Office of Civilian Radioactive Management, 1982

8. "DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's Office of Public Affairs, Press Release July 19, 2006

9. Remarks of OCRWM Director Ward Sproat to the National Academy of Science, November 2006

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

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

12. "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986 TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Section 7, Page2 of 3

7. REFERENCES (continued)

13. U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste"

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

15. "Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination,"

EPA Memorandum OSWER No. 9200.4-18, August 22, 1997

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

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

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

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

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

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

21. "Building Construction Cost Data 2008," Robert Snow Means Company, Inc., Kingston, Massachusetts

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

PrairieIslandNudear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCost Analysis Section 7, Page3 of 3

7. REFERENCES (continued)

23. Civilian Radioactive Waste Management System Waste Acceptance System Requirements Document, Revision 5" (DOE/RW-035 1) issued May 31, 2007

24. "Strategy for Management and Disposal of Greater-Than-Class C Low-Level Radioactive Waste," Federal Register Volume 60, Number 48 (p 13424 et seq.), March 1995

25. U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 2006

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

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

28. R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," NUREG/CR-0130 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1978

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

30. "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors,"

10 CFR Parts 50 and 140, Federal Register Notice, Vol. 62, No. 210, October 30, 1997

31. "Microsoft Project Professional 2003," Microsoft Corporation, Redmond, WA.

32. "Atomic Energy Act of 1954," 42 U.S.C 2001 et seq.

TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant DocumentXOI-1586-O02, Rev. 0 DecommissioningCost Analysis Appendic A, Page I of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 Decommissioning CostAnalysis AppendixA, Page2of4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example: Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1. SCOPE Heat exchangers weighing < 3,000 lbs. will be removed in one piece using a crane or small hoist.

They will be disconnected from the inlet and outlet piping. The heat exchanger will be sent to the waste processing area.

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

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

+ Radiation/ALARA adjustment (37.08% of critical duration) 95 Adjusted work duration 478

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

+ Work break adjustment (8.33 % of productive duration) 52 Total work duration (minutes) 673 Total duration = 11.217 hours0.00251 days <br />0.0603 hours <br />3.587963e-4 weeks <br />8.25685e-5 months <br /> TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentXOI-1586-002, Rev. 0 DecommissioningCost Analysis Appendix A, Page 3 of 4 APPENDIX A (continued)

3. LABOR REQUIRED Duration Rate Crew Number (hr) ($/hr) Cost Laborers 3.00 11.217 $42.06 $1415.36 Craftsmen 2.00 11.217 $58.49 $1312.16 Foreman 1.00 11.217 $58.53 $656.53 General Foreman 0.25 11.217 $60.53 $169.74 Fire Watch 0.05 11.217 $42.06 $23.59 Health Physics Technician 1.00 11.217 $46.21 $518.34 Total labor cost $4095.72

4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs Gas torch consumables 1 @ $8.36/hour x 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> il $8.36 Blotting paper 50 @ $0.46 square foot [2] $23.00 Plastic sheets/bags 50 @ $0.14/square foot [3] $7.00 Subtotal cost of equipment and materials $38.36 Overhead & sales tax on equipment and materials @ 16.50 % $6.33 Total costs, equipment & material $44.69 TOTAL COST: Removal of contaminated heat exchanger <3000 pounds: $4,140.41 Total labor cost: $4,095.72 Total equipment/material costs: $44.69 Total craft labor man-hours required per unit: 81.88 TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 4.of 4 APPENDIX A (continued)

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

References for equipment & consumables costs:

1. R.S. Means (2008) Division 01 54 33, Section 40-6360, Reference-10.

2. McMaster-Carr, Item 7193T88, Spill Control.

3. R.S. Means (2008) Division 01 56 13.6-0200, page 20.

Material and consumable costs were adjusted using the regional indices for Minneapolis, Minnesota.

TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant Document X01-1586-002, Rev. 0 DecommissioningCost Analysis Appendix B, Page) of 7 APPENDIX B UNIT COST FACTOR LISTING TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 DecommissioningCostAnalysis Appendix B, Page2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.46 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.92 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 7.03 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 13.99 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 26.91 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 34.90 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 51.37 Removal of clean pipe >36 inches diameter, $/linear foot 61.08 Removal of clean valve >2 to 4 inches 91.15 Removal of clean valve >4 to 8 inches 139.89 Removal of clean valve >8 to 14 inches 269.13 Removal of clean valve >14-to 20 inches 349;02 Removal of clean valve >20 to 36 inches 513.72 Removal of clean valve >36 inches 610.77 Removal of clean pipe hanger for small bore piping 29.53 Removal of clean pipe hanger for large bore piping 107.73 Removal of clean pump, <300 pound 234.09 Removal of clean pump, 300-1000 pound 658.66 Removal of clean pump, 1000-10,000 pound 2,603.35 Removal of clean pump, > 10,000 pound 5,028.11 Removal of clean pump motor, 300-1000 pound 277.67 Removal of clean pump motor, 1000-10,000 pound 1,085.16 Removal of clean pump motor, >10,000 pound 2,441.63 Removal of clean heat exchanger <3000 pound 1,391.64 Removal of clean heat exchanger >3000 pound 3,493.88 Removal of clean feedwater heater/deaerator 9,893.65 Removal of clean moisture separator/reheater 20,397.87 Removal of clean tank, <300 gallons 301.33 Removal of clean tank, 300-3000 gallon 953.77 Removal of clean tank, >3000 gallons, $/square foot surface area 8.05 TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentXO)-1586-002, Rev. 0 DecommissioningCost Analysis Appendix B, Page3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean electrical equipment, <300 pound 128.66 Removal of clean electrical equipment, 300-1000 pound 452.07 Removal of clean electrical equipment, 1000-10,000 pound 904.14 Removal of clean electrical equipment, >10,000 pound 2,143.14 Removal of clean electrical transformer < 30 tons 1,488.39 Removal of clean electrical transformer > 30 tons 4,286.30 Removal of clean standby diesel generator, <100 kW 1,520.27 Removal of clean standby diesel generator, 100 kW to 1 MW 3,393.32 Removal of clean standby diesel generator, >1 MW 7,024.86 Removal of clean electrical cable tray, $/linear foot 11.96 Removal of clean electrical conduit, $/linear foot 5.22 Removal of clean mechanical equipment, <300 pound 128.66 Removal of clean mechanical equipment, 300-1000 pound 452.07 Removal of clean mechanical equipment, 1000-10,000 pound 904.14 Removal of clean mechanical equipment, >10,000 pound 2,143.14 Removal of clean HVAC equipment, <300 pound 128.66 Removal of clean HVAC equipment, 300-1000 pound 452.07 Removal of clean HVAC equipment, 1000-10,000 pound 904.14 Removal of clean HVAC equipment, >1I0,000 pound 2,143.14 Removal of clean HVAC ductwork, $/pound 0.49 Removal of contaminated instrument and sampling tubing, $/linear foot 1.44 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 18.86, Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 33.26 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 53.69 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 106.01 Removal of contaminated pipe >14 to 20 inches diameter, $/Iinear foot 127.76 Removal of contaminated pipe >20 to 36 inches diameter, $/Iinear foot 177.76 Removal of contaminated pipe >36 inches diameter, $/linear foot 210.56 Removal of contaminated valve >2 to 4 inches 409.55 Removal of contaminated valve >4 to 8 inches 500.28 TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document XOI-1586-002, Rev. 0 DecommissioningCostAnalysis Appendix B, Page4 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 1 025.15 Removal of contaminated valve >14 to 20 inches 1,305.51 Removal of contaminated valve >20 to 36 inches 1,742.61 Removal of contaminated valve >36 inches 2,070.70 Removal of contaminated pipe hanger for small bore piping 99.30 Removal of contaminated pipe hanger for large bore piping 327.77 Removal of contaminated pump, <300 pound 889.22 Removal of contaminated pump, 300-1000 pound 2,084.98 Removal of contaminated pump, 1000-10,000 pound 6,863.28 Removal of contaminated pump, >10,000 pound 16,718.32 Removal of contaminated pump motor, 300-1000 pound 874.87 Removal of contaminated pump motor, 1000-1 0,000 pound 2,781.86 Removal of contaminated pump motor, >10,000 pound 6,245.52 Removal of contaminated heat exchanger <3000 pound 4,140.41 Removal of contaminated heat exchanger >3000 pound 11,957.46 Removal of contaminated tank, <300 gallons 1,475.45 Removal of contaminated tank, >300 gallons, $/square foot 29.47 Removal of contaminated electrical equipment, <300 pound 696.17 Removal of contaminated electrical equipment, 300-1000 pound 1,702.11 Removal of contaminated electrical equipment, 1000-10,000 pound 3,276.66 Removal of contaminated electrical equipment, >10,000 pound 6,394.12 Removal of contaminated electrical cable tray, $/linear foot 33.58 Removal of contaminated electrical conduit, $/linear foot 15.31 Removal of contaminated mechanical equipment, <300 pound 775.13 Removal of contaminated mechanical equipment, 300-1000 pound 1,882.27 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,617.63 Removal of contaminated mechanical equipment, >10,000 pound 6,394.12 Removal of contaminated HVAC equipment, <300 pound 775.13 Removal of contaminated HVAC equipment, 300-1000 pound 1,882.27 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,617.63 TLG Services, Inc.

PrairieIslandNuclearGeneratingPlant Document XOI-1586-002, Rev. 0 Decommissioning CostAnalysis 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 6,394.12 Removal of contaminated HVAC ductwork, $/pound 1.97 Removal/plasma arc cut of contaminated thin metal components, $/linear in. 3.73 Additional decontamination of surface by washing, $/square foot 7.49 Additional decontamination of surfaces by hydrolasing, $/square foot 34.48 Decontamination rig hook up and flush, $/ 250 foot length 6,585.18 Chemical flush of components/systems, $/gallon 13.23 Removal of clean standard reinforced concrete, $/cubic yard 128.23 Removal of grade slab concrete, $/cubic yard 172.13 Removal of clean concrete floors, $/cubic yard 329.05 Removal of sections of clean concrete floors, $/cubic yard 993.82 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 217.92 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,986.01 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 275.54 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,629.56 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 428.01 Removal of below-grade suspended floors, $/cubic yard 329.05 Removal of clean monolithic concrete structures, $/cubic yard 845.27 Removal of contaminated monolithic concrete structures, $/cubic yard 1,985.44 Removal of clean foundation concrete, $/cubic yard 662.49 Removal of contaminated foundation concrete, $/cubic yard 1,849.43 Explosive demolition of bulk concrete, $/cubic yard 28.88 Removal of clean hollow masonry block wall, $/cubic yard 90.72 Removal of contaminated hollow masonry block wall, $/cubic yard 301.40 Removal of clean solid masonry block wall, $/cubic yard 90.72 Removal of contaminated solid masonry block wall, $/cubic yard 301.40 Backfill of below-grade voids, $/cubic yard 23.09 Removal of subterranean tunnels/voids, $/linear foot 106.43 Placement of concrete for below-grade voids, $/cubic yard 123.82 Excavation of clean material, $/cubic yard 2.63 TLG Services, Inc.

PrairieIslandNuclear GeneratingPlant DocumentX01-1586-002, Rev. 0 Decommissioning Cost Analysis 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 38.21 Removal of clean concrete rubble (tipping fee included), $/cubic yard 20.56 Removal of contaminated concrete rubble, $/cubic yard 23.37 Removal of building by volume, $/cubic foot 0.28 Removal of clean building metal siding, $/square foot 1.08 Removal of contaminated building metal siding, $/square foot 3.74 Removal of standard asphalt roofing, $/square foot 2.17 Removal of transite panels, $/square foot 2.05 Scarifying contaminated concrete surfaces (drill.& spall), $/square foot 12.82 Scabbling contaminated concrete floors, $/square foot 7.48 Scabbling contaminated concrete walls, $/square foot 19.52 Scabbling contaminated ceilings, $/square foot 66.76 Scabbling structural steel, $/square foot 6.32 Removal of clean overhead crane/monorail < 10 ton capacity 636.59 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,767.18 Removal of clean overhead crane/monorail >10-50 ton capacity 1,527.80 Removal of contaminated overhead crane/monorail > 10-50 ton capacity 4,240.55 Removal of polar crane > 50 ton capacity 6,352.78 Removal of gantry crane > 50 ton capacity 26,789.34 Removal of structural steel, $/pound 0.20 Removal of clean steel floor grating, $/square foot 4.50 Removal of contaminated steel floor grating, $/square foot 12.90 Removal of clean free standing steel liner, $/square foot 12.07 Removal of contaminated free standing steel liner, $/square foot 34.53 Removal of clean concrete-anchored steel liner, $/square foot 6.04 Removal of contaminated concrete-anchored steel liner, $/square foot 40.23 Placement of scaffolding in clean areas, $/square foot 14.41 Placement of scaffolding in contaminated areas, $/square foot 24.36 Landscaping with topsoil, $/acre 21,043.22 Cost of CPC B-88 LSA box & preparation for use 1,537.33 TLG Services, Inc.

PrairieIsland Nuclear GeneratingPlant Document XO1-1586-002, Rev. 0 DecommissioningCostAnalysis 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 1,356.59 Cost of CPC B-12V 12 gauge LSA box & preparation for use 1,328.96 Cost of CPC B-144 LSA box & preparation for use 8,033.36 Cost of LSA drum & preparation for use 134.03 Cost of cask liner for CNSI 14 195 cask 165.72 Cost of cask liner for CNSI 8 120A cask (resins) 6,461.28 Cost of cask liner for CNSI 8 120A cask (filters) 1,078.13 Decontamination of surfaces with vacuuming, $/square foot 0.65 TLG Services, Inc.

PrairieIsland NuclearGeneratingPlant Document XO)-1586-002, Rev. 0 DecommissioningCost Analysis Appendix C, Page.] of 21 APPENDIX C DETAILED COST TABLES Table Paae C-1 Unit 1 DECON Decommissioning Cost Estimate .......................................................... 2 C-2 Unit 2 DECON Decommissioning Cost Estimate ............................................................ 11 TLG Services, Inc.

Pre.1rk IslandNootoo Gooostiag Ptooti Dorooooot XD1-1086-002. NRv. 0 Doeooosinialioto Cost A.oo~ai.. Appenodix C, Pagr 2 sf21 Table C-i Prairie Island Nuclear Generating Plant, Unit 1 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

OW-Sbft 1100 NMC Speot FusM sit PusoOroist Vole-. Belief540 Acvity D.00e Rioool Packaging Transport Processing Disposed Other Total To:t Us. Term. Uonogeslat Restoration Votum Class A CUSSB C"Is. C GTCC P0o0.50se CroS CoorMI.

Ind.. A80t0 0.5 p5d0 Cost Cost costs Costs Costs Costs Costs Csnency costs Costs Costs Costs Cs. Feet Cu. Foat Cu. Foot Cu. Faot Cu. Feet W., Lbs. Monhtt- Maoollhrs PERIODIs -S8hunoos, Seough Transtion Pedod Is Direct DoeonnsoroningAct00es

'a.1.1 pindmavy d prepare 1cormin0sioning cost 141 21 162 162 1,300 1I.1.2 Nob0ficatonof Cessaton of Operators 10.A.3 Renno. 1.5 & sofull t-rihal 1:.1.4 No f-tion o fpenlannt Dfloling 10.1.5 DOs=lvn plantsylones & process wast 10.1.6 Prepar, and Wa1nP6DAR 217 33 250 250 2,000 499 75 574 574 4,600 1.1.7 Roow plato dwgs &qiecs 1:.1.8 Parlor. detailedred l -ey I .1.9 Estoina by-produ0 inoonry 106 16 12 125 1.000 1E.1.1604nd podict descripton I09 10 125 125 1 .1.11 on04sadbylodit i-nO1ory 141 21 162 162 1,300 7.500 1.1.12 D.:: r01*01or wqu0ro0 814 122 930 930 1:.1.13 P01foorSER "nd EA 337 50 387 387 3.100 1I,1.14 Performs01-Specsc Cost S"udy 543 01 624 624 5.000 445 67 511 511 4.096 1:.1.15 Prnparl/subrit Licerse Ternination Plan 1 .1.16 Raer,.0 NRC ppr100oof bernsnsot plan AcbvdySpecifictions, l:.1.17.1 Plant& tanporary foies 534 00 614 503 4.920 452 68 520 468 52 "- 4,167 1J.17P2 Plantsypnms 10,1,17,3 Ne6ss 0.oslanlat n Flosh 54 a 62 62 10.1.17.4 ReactorL'rna0 s 771 116 886 886 7.100 700 106 e11 011 6.500 la.1.17.5 Reactor0e1 el lo.A.17.6 BiotogiIl shield 54 0 62 62 5w2 Ia.1.17.7 Stam P ert-or 339 51 390 390 3,120 la.1.17.8 R00fonfed co0co're 174 26 200 100 100 1.6O0 ta.1.17.9 MainTsttso 43 7 50 50 40D) 43 7 50 - 50- - - 400 1.1.17.10 MainCondensers 1.1.17.11 Plaint ar nuadiS& ngs 339 51 390 195 195 3,120 10.1.17.12V.A0 mnglenment 499 75 574 574 4,620 1.1.17.13 Facility& adostoo 98 15 112 56 56 900 1a.1.17 Tota 4.108 616 4,722 4,158 564 37,827 P nIn--g & Sh Preparaorknt 10.1.18 Props. d atilg s*oqoorn 261 39 362 362 1 Plan tpop.&lolop1,s os P.1.10 2.700 405 3,162 3,106 1,400 1,.A.. Design -fatr ckaw- systmn 2 3152 175 175 1:1..21 RigginWCont colEn1ftos .oofotgfo 2.100 2 315 2,415 2.415 134 25 154 154 1.230 1I.122 Pro-iica salrme rs&confisne 10.1 04Subeo Perod Is A801101 Costs 12.807 1.921 14,725 14.163 564 73,753 Perod Is Addnonal Cosks 1:.2.1 SpentFuelPool isolato* 9,140 771 5.911 5,911 10.2 Suboll Period1.0AdditionalCosts 5,140 771 5.911 5.911 Period 11 CollaorolCosts 1:.3.1 Spnlt FuolCapitaland Transt- 9,475 1,421 10.896 10.806 I1.3 Subtta1 PeriodI. Coliateol Costs 9,475 1,421 10,896 10,809 Period1. Piriod--Dpenden Costs 1:.4.1 1--ran 775 77 852 852 1 .4.2 Property0U.0 1,745 174 1,919 1,919 Ia.4.3 He.h phyo sopplos 386 97 483 483 Is.4.4 qivaen en

.eW 387 - - 58 445 445 1.4.5 Dispos of DAWgeneraed 9 6 41 - 12 69 69 610 12.190 22 1.4.6 Plaino -nWly budget 2,557 383 2,940 2,940 1I.4,7 NRCFm 706 71 776 770 1.4.0 onenrgency PlanningFees 275 27 302 - 302 TLG S-krtoso, 10-.

P-boill. Wood AN..4our Gasdesutisg P0.04 Da~ooe4 XOJI.1586-002, Reo. 0 D.coomed-icaulag Cost Adjyori. Appjoll.t C, Pam. 2 fj'l Table C-1 Prairie Island Nuclear Generating Plant, UnitI DECON Deconms asioning Cost Estimnate (MFousaudo of 2098Dollars)

I Asboffty 0.60. Revemsid Posbaglaig Tomsoport Pro0005mg Disposal Other Total Total UsG.

I-. Maramiled-It R..ketist Volum. ClassA Ci.. B Class C GTCC Processed Craft Cosivedoar col costs Costs Come Cns C010CoCos C~o.. ts CO. costs Co. Fast Co. Fes C o.Fst Co. Fent

o. FeelC~ho WVE.Lbs. 2b.1000Ws MmnhOOW Period 1. Paricod.O.pao4.nlCosts (-nobud) 1:.4.9 Sp~otFoelPool 051M 373 56 429 429 1 4.10 ISF01Operatingco 44 7 5o 56 2,276 341 2.618 2,018 - 46,678 1.4.11 Samm~ystaff o10 . . - 423.400 l..4 12 UtsO1Staffcost - - 24.026 3,604 27,630 27.630 773 9 6 41 32.17*5 4,906 38,513 37,732 781 610 12.190 22 470.078 1.4 Subtsotal Coost Period1. P-oo1-Dpdeo,dm 773 9 6 41 60.196 9.021 70,047 57.106 11,677 564

• 610 - . . - 12J190 22 543.831 1.0o TOTALPERIODIs COST PERIO It lb .Datuarithselooao1 Re~pulsed-Period1 lb Direc Datosoo04ooOiche A*.bot.

0.01.M4WkI P-da.s lb.1.1.l Pliall Yetsol 514 77 591 . 532 59 4,733 S19 16 125 125 1,000 1.1..2 NSSSDnoosrtsmlkationFlush 2,50) 1011.3 Reactorifllellols 271 41 312 312 147 22 169 42 1,350 lb1.114 Re "Its' buidt". 1,000 109 16 125 125 109 16 125 125 1,000 lb10110 CRSIIO-so &OICItubn. 1,000 109 10 125 125 394 59 453 453 3,630 lb.1.18 Reactlor aas.I 1,2D0 130 20 150 75 75 49 7 56 56 450 11,11'0 M140000145 1,200 lb.i1. IlBiological "d 130 29 150 150 499 75 574 574 1111.111OlO= g.1.m11 109 16 125 62 62 1,000

.16 25 198 195 1,560 b11 114 M6in1oTrbin 1,560 169 25 195 - 195 lb.1IllS Mos Ca04001 296 44 341 307 34 2,730 lb101.11 A.04ooylsbdo ibi1.17 Racmturuidog 296 44 341 307 34 3S6A 541 4.150 3.370 780 33,243 Ibi I1 Toad lb102 D.-0 p10109loop

- 190 570 570 380 3,609 731 4.720 3,940 782 1.067 33.243 lb.I SubtotalPeriodlb,A.6,*~ Comss Period1ItAdditc0l~oCosts

- 3.290 987 4,277 4.277

ý1,.2.1 Si.0Chimson1loboln 11 53 946 - 151 1.161 1.161 1b.22 Mixed hM Ib.2,3 RCRAV82O. 6 4 21 - 4 35 35 1.50 103 - 88 - 437 2.227 2,227 - 12.043 166,959 18,667 Ib.2.4 Aab.IWnAbt. M00 1 16.,959 18.667 1820* 17 159 968 82 3.290 1,5I6 7,701 7.701 - 12.543 lb.2 SubbalolPeriodlb,Add.60,1 Co.-

Periodlb, CollateralCosts lb.31 743 111 085 859 D-60 S63t10011 lb 3 2 D0C staf relocaboo exoesses~ 912 137 1.04 9 1.949 27 - 40 225 557 2,872 2.872 174 565 73.114 144 1 3.3 Pln ssiqd -see 22.023 21 3 25 25 l03.4 S0004110W0al15

- 1.666 -O 10 1.150 1.150 b3.5 P 0 .Oftv0g-qPo82 1.4 .00 210 1 '610 1.610 lb 3.6 0.60rig lb.3.7 SpareFoolCapoita and Trsoolbr 877 6.720. - 6.720 2.170 1,021 40 225 2,023 0.756 2,045 14.280 7,560 6.720 174 565 73.114 144 lb.3 Subtota PeriodlbI0II Colltra

. dts PeriodIt Parod-O.Pel.M14nts Co 23 6 29 29 11,41.1 no0--*Pbol 391 39 430 430 I ba.2 1-150 800 88 966 968 lb.4.3 Propay ou0.5 I1b44 HealthPhysicssupplies 285 71 356 356

- 195 - 29 224 224 I1,4.5 H~avy.qupniwd Ioo 5 4 24 7 41 41 360 7,197 13 lb. 4.6 DisposaoI DAWgennlsbd 2,578 387 2,964 2,824 We.7 Paidl51lnlWbudget nlo sanmi-, Im.

Prairie Island Nucear Generating plant Document X01-158-002, t*e. 0 Deco-soeftoting Ced Anoodtin" Appendix C, Page 4 afR2 Table C-i Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (Thousands af 2008 Dollars)

I Off-11,6 LLRW NRC SpentFuod sit. Processed Burdal olumes - lB I osd UlftMy Transport ProcessingDisposal D tto Toni Toee Us. Ton. Muoagoo*ol Restoaoton Volume Class A Class B Class C GTCC Processed Craft Cosoossor IActiy Decon Removal Packaging Cost Cost Cost Costs Costs Costs Costs Co0osnon Costs COSTS Costs Coosp Cu. Faot Ca. Fust Cu. Fust Cu. Feos Cu. Fast WL,Lbs. Moohosro MolhorssI lodex Period lb Period-"OpendentCosts (Wonbesd)

Wb,4.R NRCFoes 350 36 391 391 lb.4.9 EmergencyPlaning Foos 139 14 . 152 152 lb.4.10 Spe*dFuooPool O&M 188 28 216 216 1b,4,11ISFSI Opeatng Costs 22 3 25 - 25 4,083 612 4.695 4.695 - - 79.313 lb.4.12 SeourityStaffCost 5.055 758 5,813 5.813 64,137 lb,4.13 DOCSffCos 12.173 1.020 13.999 13.099 - - 214.491 lb.4.14 U atsyStoffCost 23 480 5- 4 - 24 25,803 3.9D5 30.304 29.910 394 360 - 7.197 13 358.011 lb.4 Sb!t5 Pust lb Ponod-DOplndet Coos 2.573 3.10D 63 388 968 2.136 39,518 8,260 57.005 49.111 7,114 780 13.377 565 247,270 19,891 391.254 1b.0 TOTAL PERIOD1t COST PERIODI TOTALS 2,573 3,873 72 394 968 2.177 90,714 17,282 127.053 108.917 10,791 1.345 13,988 505 259.460 19.913 935.015 PERIOD2a - Large Component Removal Period 2a DrecoD nnriodong Actrooes NUdoanShoan SupplySystem Removal 55 34,807 1,414 2a.1.1.1 Reactor Coolant Pip'ig 41 34 4 7 45 187 187 288 18 15 . 3 5 - 34 22 97 97

• 192 21.280 625 2a.112 Prsuner Reulief Tank 41 46 20 84 40 909 303 1.539 1.539 132 1,701 325,380 1,785 2.1.13 Resctor CoolantPumps & Motos 36 58 492 306 - 671 309 1,903 1.063 - 2.450 202.122 2,282 2o.1.1.4 Prssurizerr 2..1.115 Stam Generators 181 Z513 1.739 1.330 1.149 3.088 2,037 12.038 12.036 18.M72 11.318 1.68.341 11,617 2,875 84 115 531 531 2.404 53,072 3.225 2.1.1.6 CRDMstChuSoese- St-t-nr R-romol 128 55 110 34 00 1.777 9,.77 908 9.331 174 8,795 31,061 31.001 501 527 918 219,145 21,733 1,001 2a1.1.7 R eo Ves eal lnlorala 2a.1.1.5 RetoronVososl 459 - 4.410 174 5,217 14.790 14.790 4.319 1,377 619.525 21.733 1,001 58 3.450 1.022 599 7.949 13.375 3,223 1.190 18.673 349 16,843 62.205 62.205 18.804 23.180 1,904 918 3.143.000 64.414 4,878 2.,1.1 Totals Remonvlof MajorEquipment MainTuitsnGenoaien 245 130 51 357 100 170 1.12D 1.1250 2.131 1.107 287,637 4,667 2a.1.2 2%.1.3 MainCondenses 2.045 56 35 253 120 590 3.099 3.099 2.851 941 203,723 39.151 Ca.s-*dns Cost fromCloanBuildingD foinono 2.1.41 RIector 862 12M 992 992 11.415 882 129 992 992 11.415 2..1.4 Toads Disposalof PtantSystems 2.1,51 AirRrnnodl - 22 - 3 25 - 25 452 70 2a. .52 AuxilaryoFeesitfr 3`1 - 5 36 36

-30 0 1 17 10 59 59 215 - ,722 575 2.1 .53 AudloaryFeedwaler - RCA 9 73 - 73 - - 1,335 2.1.54 Eled Stearn - 3 25 0 1 19 9 55 55 233 9,453 443 2a. 5.5 CausscAddon - RCA 14 2 16 - 16 - - 304 2.1.50 Chnol Foed 1 0 0 0 0 1 1 243 12 2a,1.5,7 Chuncal Fe.d - RCA 29 4 34 34 619 2..1.508 CiondsngoWater 8,837 336 S0 307 387 2a.1.5.9 Condensate 2.1.510 Conde"sa" Poshing 165 25 190 - 190 - 3,419 125 2 364 04,395 2,299 2.1.511 Condernslo Poialsngi- RCA 12 166 50 364 - 2,078 6 1 7 7 -- 127 2..1.5.12 "I.nJyora-lko 108 - 2,215 2a.1,5,13 Fuodnoato 16 124 - 124 -

133 4 19 257 75 488 488 - 3,208 130.294 2,604 2a.1.5.14 Fen-doss-FRCA 24 4 27 27 505 2.,15 1 Glad

- Sea 2..1516 Heaetr Drain 282 42 324 324 - - - 5.1181 19 3 21 21 S389 2..1.5.17 IntenalCiu Water& CDSR

- 0 - 0 0 0 5 2..1,518 MostGOurdoran/Tnand.onmn Of 30 1 2.15..19 Man Slan 12 93 93 251 6 30 404 125 819 019 5,044 204.R25 4,871 2..1.5,20 MainSeam - RCA 314 12 21 162 69 124 703 703 - 2.031 40 125.865 6.152 2.1.5.21 Staeorn bondewn

-ereoforstro 1 4 - 4 75 2a.l,22 S:m 4 41 3106 20.1.5.23 Turbine& MosntesSeparatons 2.1 5,24 Turbine Oi Prficatbon 275 50 7 57 316 57 - 1.003 M1GServieso, Inc.

Doooxeral XD1-1586-00, ft.Rn.0 PrairdeLidd ANuclear Generatnsg Plant APinnaL. C, Page 5 of*1 D..onounia.olmit.CostAa.LyoI.

Table C-I Prairie Island Nuclear Generating Plant, Unit 1 DECON Decommissioning Cost Estimate (Thousands of 2008 Doilars) i I Asfiotri Dessn, Renewal P.s.kglo

~ ~ ~~

Teospod P~os...15g 19.Po4 C-2 at Oth.,

~ Total

~

~ Total UsTos, ~

ot ~

Manaoqnownt Rioddratis ah ~

SoiW-,

~

iedC.FdCCoa Cod Fa ~

C616A Cl. B CI...C Coot..O col ~GTCC P--.5.0 s

ClaS ContractorI ie I Inda.

2.38 25 a5 1,025 69 632 4,225 2.490 1.734 12.815 495 563,797 48,090 2.1.5 ToBIO 1 179 904 804 - 138 9 - -" 6,982 6,073 2a.1.5 Scffoking,inReppoeof doeumewasmnog 708 2 1 12 72.544 70,809 1,734 36,739 25.711 1,904 918 4,205.820 173.810 4.878 599 14.197 13,589 3.395 2,842 19,023 349 18,590 2.1 SubtotalP.004 2. Ach*l Coee Period2. CottonedCoate 57 - 21 114 108 74 374 374 387 23.216 75

2. 31- P-0. liquidosoBe 142 - 21 164 . 147

2. 32 -010love--- , on, 1

- 14,038 2.105 16,141 16,141 2.3.3 Some0Fuel Cao ar6 Traoneo 16,141 16 387 23,216 75 57 142 21 114 108 14.036 2.201 16,679 521 2..3 Suttee0 Perid a4 4awra08. Co Period2. P. d-epandeent 0010.

58 14 72 72 2..4.1 Deon tuppIl.o B51 52 570 570 2..42 1- 244 2,218 222 2,440 2.196 2..4.3 Propertytooo 1.125 281 1,406 1.406 2.4. 51160185610 2.363 355 2,718 2,718 2..5 Henry quio~learental 59,306 108 44 29 202 - 59 334 334 2..4.a Disposalof DAWg.n10o0 3.087 463 3,551 3,551 2o4.7 Plantenergy budge1 837 *4 920 920 2..4.8 NRC F... - 140 F.. 127 13 140 2..4.9 E-e..soy Plarunng 545 474 71 545 2,90O 2.. 4,10 Speo9Fool Pool051M 64 55 8 64 -

2. 4.11 ISI'SI0p068n9Code. 162,294 8,427 1,264 9,691 9,691 2..4.12 eou" StaffCast 201,509 15,540 2,331 17,871 17,871 2M.4.13 DOCStaffCoal S- 374,673 21,968 3,295 25263 25,253 20.4.14 UOiftyStiff Coal 748 244 59,308 10o 738,476 Cool.

2. Po.do4Opandanoo 56 3,488 44 29 202 53.252 8.512 65,585 64,563 2..4 Soei pandod 17.827 13,654 3.539 2.842 19.333 67,636 29,263 154,807 135,923 16.889 1,995 35,739 29.064 1,304 918 4268,343 173.93 743.354 2.0 TOTAL. PERIOD2. COST 713 PIERIOD th - 8160D~so.nUM00OM P.erid21,Drec Dooonerawwon~og ASOSO..a Diq.WofoioPlar,By-0 2 3 140 22 -

I 0 0 0 0 2 2.1.1.1. Am~8lq NooraIVeoation0 0 Ventlation 0 0 0 2b.1.1.2 Battery Ro Spacdo 0 4 - 4

- 65 2b .1.3 Buldingso 5100 - 3 926 51 65 308 286 788 3.307 3,307 4,490 2,214 - 363,748 33,361 -

2b 11.4 ChernacaI &Volurn*Control 832 10,93 574 15 74 308 1.962 1,062 12,427 504,675 2b.1.1.5 Comlponent CooIhlg-FICA 904 -

0 59 59 * - 1,0632 2b.1.,.6 C'"'0io,6l Cooling 51 3,400 136,090 3,641 209 4 20 272 97 602 602 2b.1.1.7 Crn10.oo, Cooling -RICA 36 105 4,278 36O 21 o 1 8 7 36 2b.1.1.8 Conounto.o HtydrogenConal FICA 868 35,249 1,195 63 1 5 69 27 1G 108 2b.1.1.9 CkoolooooonfSpray-5CRA 4,951 520 247,736 3,661 184 13 39 396 74 131 838 838 2b.1110 ContaireeneV"'e.Snn - 130 - 2,398 113 17 130 2b.1.1.11CocangVAl( Ole 211 1,327 1,327 7,728 313,832 8,397 2.1, 1.;2 cooling VWW FI-CA 442 9 46 5 41 - 41 730 2b.I1113 DI Emergency Diool 35 4 29 29 522 2bI1114 D2EnorgancyO~ Deia 26 68' 1 7 7 113 2b1.1115DWW oRoon Verbatiom - 26,081

- 1,356 204 1,563 1,563 2bI.116 Electricl-Clean 142 801 601 2,527 67 108,671 8,376 2b.1.1.17Eloobrxidl Cor10o..olod 427 4 16 202 10 25 140 1. 884 949 5,572 5,572 23,561 959,401 49,378 2b.I1I I Eleticals- Dooorearni.l 2.571 S 89 8 73 22 40 235 235 96m 154 A50677 1,782 21,1 19 FueIlHeeling 3 S 86 13 99 - 1,697 21,11.20 Fue Od 99 - 1,861 -

84 13 97 97 2.,1 1.21 HVAC-Clean 3,261 87 140.234 5,031 275 5 21 251 12 115 688 one 21,1.122 HVAC- Coolooninat.4 40 40 60 40 6,015 424 25 1 1 5 6 8 2.,1 1.23 5100,.Inianarnooubor, 390 363 48,363 3.008 162 a 9 31 52 60 322 322 2b.I1124 Mi- Dr- & V.nIs 568 344 548 63.108 5,963 112 192 12 13 28 78 131 566 2.1125 Rea=l,CooSlan Be 241 24,259 3.940 110 G4 7 5 5 34 08 344 344 2.,1 1.28 Reo90rHe Sarnplkog 30 S&rkoe. ln-.

PrairieIsland Nuclear GeneratingPlant Doattmsent X0.1586-002,Rev. 0 Deca*noelsatontng Coal Analysis Appendix C, Page 6 oaf2 Table C-I Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) on-at.s uLtoW NRC Spiol Pool site Prosssd BomstVo.sta Bntal I and 11111ty AcStvlty Oecon flOaosal Packiglng Transport Processing Disposal Other Total Tomt c. TaLr- Manageent Rastanson Volune Claus A Class a Class C GTCC Processed Crat Contractor Index Actvity Descripion Cast Cost Casts Costs Costs Casts Costs Contisnog* Casts Ceats Costs Casts Cu. Fast Cu. Foot Cu. Feet Cu. Feet Cu. Feet WtL,Lbs. Moalthors Manhours Sisposa at PlantSystems (on"rond) ab.1.1.27 Reactor Makeup - 52 - a 60 - 60 - - - 1.D42 2at1120 Reactr Veassal 7 11 0 0 2 1 7 29 29 260 1 1,090 367 2a.1 2. RoiduoalHast Reosoval 234 274 46 61 232 327 316 1.490 1,490 - 2.895 2.295 323,397 7.114 2b.t11.30 SafeguardsCrtulde Wter 13 - 2 14 - 14 - - 259 2b.1.1.31 Safet Iniection 61- 24 56 543 116 275 1,630 1,630 6,788 855 3480.07 12.044 2b t.1a. 2 Sttyipcsl o 5 1, 42 2 2 14 75 75 59 76 9.163 809 2b.1 1 33 ShieldBl5g Ventolabor 100 7 19 172 49 67 415 415 2.102 346 118,482 2.015 t.1.1.34 Sut-snlsIruinrm Air 14 - - 2 16 - 1i - - 300 2b.1.1.3a Staaion t I InttumentAi - RCA 56 0 2 27 IS 104 104 332 13,496 1.053 2a.1.1.36 Tubine Bdg Trapi& Di 35 5 40 - 40 - 767 29 - -

2a.1.1.37 UnitCoors 4 33 - 33 - - 611 36 0 1 18 2b.1.1.38 Ui Coom-RCA 12 68 68 - 230 - 9,348 657 2a.1.1 Totals 1,294 9,291 241 606 8.206 1OOt 4.095 22,813 20,621 2.192 77,571 7.816 3.829.133 2D2.380 2at1 2 Scaffolding in supportof decatoranm.moog 885 3 1 IS 2 - 224 1.130 1.130 173 11 8.728 7.591 Deconasrnnaton of St. Builings 21t13.1 Rancor see 771 00 140 178 540 830 3,443 3.443 2,230 5, 6-7,193 30,a45 -

2a. .3 2 Bsk-usbh WanaR wivnlg Tank 23 7 10 - 23 14 78 78 - 439 43.896 311 2a.1.3 Totls B0B 794 07 150 178 569 844 3,521 3,521 - 2.230 6,388 701,089 31,155 2at SubotolPeriod2b Acdy Cost. 2.183 10.970 341 757 8,400 1,650 5,163 27.464 25,272 2.192 79,974 14,215 4,538,050 241,127 Period2a Cosateal Coos 2b.3.1 Prs*60dho s 139 - 96 537 6-5 334 1,801 1,801 1.73 - - 140.807 348 2b.3.2 Soot too aIlnda nI - 189 - - 28 217 217 2a,3.3 SpentFuiaCapitaland!Tnsat-r - - - 1-176 1,781 13,57 - 13,w57 2a 3 Subtotal Period2b Collaterl Costs 139 189 96 537 695 11.076 2.143 15,676 2.019 13,657 1.783 149,807 348 Period2b Peod-ODepindintCoos 21,.4.1 D-o nuppins, 345 - 86 431 431 264.2 1-,ieain 768 77 845 845 2a.43 Propertyfares 1,615 162 1,777 1,77 2b44 H0alh phycs supplies 1.536 - 304 1,920 1,920 2b,4.5 Heavy Wo*rnt nasnal 3,479 - - - 522 4,001 4,001 26.4.8 Disposal of DAWgrratsd - 55 36 248 - 73 411 411 3,640 72.790 133 2a 4.7 Plantoerergybudget 3,614 542 4,156 4,156 2b 4.8 NRCFees 1,241 124 1,365 1,365 2a.4.9 Emtrgescy PlanningFees 188 19 207 2W7 21,l10 SpentFuelPaul OSM 703 105 am 808 2b.4.11 LiquidRadwants Proceosng EqoitprnntServicas 354 02 407 407 2b.4.12 ISFSIOperatingCosts 82 12 - 4 94 ba4.13 Seurity StaffCo 2,061 309 2,371 2,371 42263 2b.4.14 DOCStaffCos 15,392 2.309 17.701 17,701 212,297 2bl4.15o uStytff Cost 22,210 3,333 25,550 25,550 - - 395,109 2a4 Subli Period2P a Panod-OependontCons 345 5,015 55 36 248 48,236 8,110 62,044 O0,934 1,100 3,640 72,796 133 649,609 atb. TOTALPERIODabCOST 2,687 10.174 492 1,330 6.400 2,593 60,112 15.416 105,184 88,*.5 14.707 2192 79,974 19,637 4.761,552 241,607 640,069 PERIODZe - DelayBsdres End Of WMFldd Sloarg Pernod2c Direct os ig Activiti Period2. CodlataalCosts 26.3.t SpentFuelCapitaland Trennd 5-1,490 7,723 59,213 59,213 26.3 SubtotalPeriod a6 Collast-alCosts 51,490 7,723 59.213 59,213 Perod 2c Period-Dependnt Cots 2.4.1 Insurance 4,704 470 5,174 5,174 2aA.2 Propenty taxs 9,918 992 10,910 10,910 2e.4.3 Hoath phyics supplies 963 241 1,203 1,203 TLG S-r-r , lve.

Prairie[Wn4Nooc8or 2.ratiog PleadI Dwromeot XD1-1588-OO2 Reov.o

-dooooidunfeoolgCbefAay.1.oi Appendix C, PGV~ 7 orfl Table C-i Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (rihousands of 2008 Dollars)

I VOofIBM Clan A Cloan8 CIM C GTCC Pr00.0009 Craft C008010.

I A."tir 0.000 t00 8.0,0.01 C~od Packaging Tiewsopr Proaoololln0,.on.oo Cuml Coeur Caiot Con lin Coeur T

C0.=oo~

TOWi U, Turn, Cooe. Coon Mangernwit C.ot.

R-oron.0 Costs Cu. Feet Cu.Foot CU.Ford CU.Fort Cu. Fewt WI..180. Manourso Moithooto tonn. "elf ve-o"Peore Peiod 2c Pernd0-opendeor Cows (nansued) 2.4.4 Depen of1DAW8 W100 22 14 99 - 29 160 105 1.460 29,205 53 2c,4.5 PFat energy budget 5,917 888 8.805 . 6.85 2c.4.6 NRCFeeo 2,112 211 2,323 2.323

- - . - - - 1.150 116 1,272 1,272 20.4.7 EmergencyPtlnmoogF..

2v.4.8 Spent FuelPool O&M 4,313 647 4.808 4,960 2c.4.9 ISFS Opera Cooe Guin 504 76 579 - 579 5.514 42.275 42,275 706,011 204.10 Sonly Stlff Coid 36,761 2c,4.11 tialy Stun Codr 37,813 5.672 43,485 43.485 2.4 Sbtol Period 20P.1reI0 .pn.dent Covr 963 22 14 99 103,158 14,855 119.151 112,339 a.812 1.460 29,205 53 1,405.959 20.0 TOTAL PERIOD20 COST 963 22 14 09 154,688 23,578 178,364 112,339 66,0235 1,460 29,205 53 1,405,911 PERIOD2d - Dworauotin*dot F011040gWet Fuo St aobo Period2d Dirct Deoornrynelaug So so 2d.1.1 R.n-o speet fuolrok. 249 26 65 28 211 - 194 773 773 - 1.477 - 132.519 576 P1arSy0000 DOtposidola 2.1.2.1 Electical - Codnoumnated - Fuel Pool 102 1 4 49 2 35 197 197 . 15 16 26,444 2,077 2d.. 2.2 Eloomoal- D-noodnaotd - Ful Pool 642 7 35 471 -237 1.393 1.393 5,893 - 239,377 12.340 2d.1.2.3 HVAC - Comunewtad -Fuel Pool 118 2 5 112 5 49 295 295 1.358 37 60.100 2.15-2¢1.1.2.4 S.I Puird.ChWod otl-RCA 58 1 3 40 21 122 122 495 - 20,100 1.019 2d.1.2.5 Spalt FuelPool Cooing 209 240 18 23 84 133 213 881 001 806 935 116.589 7,358 2d.1.82. Stalton& InwomlovAw".RCAFuelPool - 14 0 0 7 - 5 29 29 . 83 - 3,374 253 2d.1.2 Tonle 209 1.178 29 74 743 141 560 2,935 2,935 9,290 989 465.935 25212 2d.1.4 Scaffolding . sop,,l of ¢oooosolboo., 177 1 0 3 0 45 228 229 35 2 1.746 1.518 2d.1 SubtotalPeriod 2dAc"0ty Coot, 458 1.381 00 103 746 352 799 3.934 3,934 9,325 2.468 6808.19 27.307 Perod 2d Codeotto Cons 2d.3.1 FP-o fiq id -noto 49 - 34 153 252 135 840 840 640 54.310 125 2d.3.2 0m,0tooooonoo 259 - 4 29 29 96 55 532 53 - 111 848 948 6,O0 373 303,.507 8s 2d.3.3 De-omnktog Eqo1 io t Ditpooono 2d.3A4 Sper FuelCapiti and4TTorevdet - - 227 34 261 261 49 25 131 245 532 309 227 269 1.786 1.524 261 .008 1014 357,817 213 2d.3 Sutol Pe.,0od2dCollolotolCoon Period2d Priod-O.epenent Cootn 2d.4.1 Don. oRppb.o 32 - - - 8 40 40 2d4.2 Insur-nc 285 29 313 313 2d.4.3 Prop" a01 0 - 599 08 659 659 2d.4.4 No.18Phyolooon0o 323 . . - . - 81 403 403

,t90l

- 1.288 - - 153 1.483 1,483 2d,4.5 Hooy oinpnerot, 1 a 52 - 15 99 88 785 15.294 28 2d.4.6 1lol of DAWgomo80d 24.4.7 PFirt 00,0 budget 714 107 822 822 24.4.8 NRCFee. 460 46 508 5w6 2d.4.9 E-ooonvy PIWto,4 Fe 70 7 77 - 77

- .262 24.4.10 Liqui RadoooO P00noW EqxooWSot1km 39 301 301 2d4.4.11 ISFSIOpe01i0g Coot, 30 5 35 35 2d.4.12 0Se0ity Stff Cout 213 32 245 245 4.371 S01 4.458 4.456 53,186 2d.4.13 DOCstn" Coot 3,875 2d.4.14 U01 Staff Cor0 - 4.900 735 5.635 5,635 88,157 2d.4 Su0t00 Period 2d Peo4-ODepeuentco00 32 1.612 I1 6 52 11.408 1.938 15.081 14.949 112 - 765 15.294 20 145,714 2d4. TOTAL PERIOD2d COST 538 3,018 237 35 1.278 709 11.635 3,05 20.780 20.407 373 15,325 4,240 973.310 27,540 145,714 PERIOD2. - ULcene Trmiative Period2. Died D-.ooono Aoo 2@1.1 ORIbSE confolulaoryue y 148 44 193 193 20.12 Tomitatt b-3742 se-k.o, boa.

Pre~d~t.1.1-d N-ledo, C20s,.tisg Moot4 Dovsssvoot XOI1586002, Rev. 0 A~pp.sdio C,,Pog 8of 21 Dooo.-de.doialigCos A.,sl~wi.

Table C-i Prairie Island Nuclear Generating Plant, Unit I DECON Deconiissioning Cost Estimate (Thoosoadsof 2008 Dollars)

Off-Wito LLRW NRC 8lpent Fuel sit Pm .s~l Burial Volurnes BurialI Utiliy aridl Decow Reibovt Packaging Transport Prtovsso Disposal 0.

Other To:I Totsl U*TTe Maa.lsemt R.st-ltkot Volume Class A Cie. B CUs. C GTCC P1.0.ssad Craft CooBaoto I Actlylty Cost Cost Como Cos" t cot.

C Coots coots Co.m Cost. Cot.s Cost. Costs Co. Feet Co. Foot CO.Feet Cu. Fast Cu. Feet WI, Lbs. Mhobso ManhOrlsI too..

2e.1 WartatdPeriod2. A4c0ty Coost 148 44 193 193 Period20 Addr1oo Coast 2.928 878 3,800 3.806 49.489 20.2.1 L-oe. T.rn*oore Stoosy 49.489 2.28 870 3,806 3.806 20.2 Subtotal Period2. 44,50a1 Costs Period2. Colateral Cots.

912 137 1.049 1.049 20.3.1 DOC stff rloca. .one4oo 1.184 20 211 - 211 23.3.2 SpenoFuelCap" aridTransfer 1.096 164 1.261 1.049 211 20.3 Subtoal Period20 CollateraCosts Perod 2. Perod-D.p-nd MCoost 20.4.1 Inl[-r.o - - - - . - 274 27 301 301 . - - - - ----

204.2 Property Oarm 641 04 705 705 395 - - - .99 403 493 - " "

20.4.3 Healh Physicssupplie

- 5 3 22 - 6 36 6 316 6,325 12 20.4.4 DlrodoflDAWINelvraed 382 57 440 440 -

20 4.5 Rontoenergybudget 528 53 581 581 20.4.0 NRC Fees 75 7 82 82 20.4.7 Eesrgency PlanningFm 33 5 37 -37 20.4.0 ISFSIOperatg Cost.

2.4.9 S-onty Stff Coo 228 34 263 263 4000 2,591 389 2,979 2.979 35,00 20.4.10 DOCSaff Cost 2..4.11 U0f1tyStaffCost - - - 2,200 342 2.622 2.622 -0 39:00 20.4 SubtotalPeriod2s period-Oepond.rt Costs 395 5 3 22 7,032 1.014 8,540 8.420 120 316 6,325 12 79,560 205 5 3 22 11,204 2,171 13,799 13,4O8 331 316 6,325 49.501 79.560 20.0 TOTAL PERIOD2. COST 3,919 38.377 14,410 5,245 10,520 22,755 305.275 72,434 472.934 370,363 98,385 4.187 132.037 54,724 1,904 918 10.058.730 492,701 3,024,285 PERIOD2 TOTALS0 PERIOD3b0-aSmBRst..owloo Period30 DirectD0.omn-.osib Acsieso Dern0it0n of Re.m.ong Sit BOodoos 4.001 - 749 5.740

• 5.740 . - 60.349 30.i.1.1 Reactor 1 7 -7 - . -

3S.1.1.2 Contso ase Stompg.Tonk Foondtion Z65 34.340 Turbine Z235 340 2,605 - 2,an05 3,1.13 7,580 3b.1.1.4 Turbinie Pedestal 103 788 - 700.

685 108,365 201 30.11 Totats 50.0 I 4 Tobss 7.948 1.192 9.140 S .14M ACtOs Site CloCseovt 316 310.12 Grade&landscape aft 126 - 10 145 105 1.560 169 25 195 So.1.3 Findlreport 0NRC 10.,680 1.560

- 0.74 109 1.236 9.480 195 9 .2B5 30.1 SbtoatalPeriod31,ActivtyCost.

Perlod 31Addition Cost.

210 2 32 244 - 244 1.126 30,2.1 Cono'ate Cooruing 1.128 210 2 32 244 - 244 30.2 Sttothl Period31 AddsorialCos.

Period 30 CokatiedCoots 92 14 105 100 31.3.1 0 S0aU oo aslosanlo 303.2 SpentFuelCsp*WJ and Trasdw 397 00 450 458 -

92 397 73 562 40 105 303 Sub5,0 PFod 31Col-tsad Coot.

Period31,PsoOd-0pold. Cost.

3b.4.1 tnsoo.0 847 as 932 032 - -

30.4.2 Fropetly0 153 15 168 5.726 000 6,585 - 0.505 - - . -

3S.4.3 HeavyequiprentrrnaI 3b.4.4 Plantsenrgy b1.dget 592 0 6811 204 476 . - - -

294 20 322 323 3b.4.5 NRCISFSIFees 3b.4.0 Emo*.e-' Pltonig Fm 231 23 254 254 - - -

101 15 116 lie.- .

3b.4.7 ISFSIOperatin Coots TLG1Sarvioi. Zoo.

PrairieIsland Nuclear,GeneratingPlont D-nioeall XDI.1586-002, Ret.. 0 DoooooauiooiooiogCad Anaolysis Appendix C, Page 9 of~i Table C-1 Prairie Island Nuclear Generating Plant, Unit 1 DECON Decommissioning Cost Estimate (TIhousands of 2008 Dollors)

I off-mt. LLRW - NIRC hoot Foo sit. P-00000 Burial Voluesse s10011I Ulft.00 Actoivty 00.0. Raoiovdl Packaging Transport Proessing Disosaol Other Toni Toen Lin.Tern. M08en0t Restoration Volur0e Clasi A CUaSSB Class C 0TCC 8000.4d craft Con0arto0r Cost Coa COsts Coot. Coots Coost Costs Contingency Cols Coot. Costs Costs Cu. Feet Cu. Foot Cou.Feel C. Feet Co. Foot Wt, Lee. Ma04o0n, Mohtno kid.

Period3b Poood-OependerdCons (corsnued) 35.4. Securty Staf Cost 4.458 669 5.127 0 4,204 923 81.506 6,669 1,004 7,699 - - 7,599 81.743 3b4.9 DOC S~tECost 1,788 268 2.056 0 1,193 864 31.386 3b,4.10 U"tyStaff Coa 5.726 - 15.159 , 3,057 23,942 0 7.395 16,547 204,635 3b.4 Subtotal Period31 pariod-Depnd.MCosts 3b.0 TOTALPERIOD31 COST 14.102 15.725 4,398 34,228 195 7,851 26,151 109,806 206,195 PERIOD3; - File$41t"o. Operoso.to ppig Period 3c Donot Doead ronog/ohoabs period3c CollateralCoosts 30.3.1 Spent FuolCapitaland Transfer 2,263 339 2,602 2,602 30.3 Subtotal Period3 ColIateralCosts 2,263 339 2.602 2,602 Period o3Penod-DependnrdCosts 30.4.1 1ns-no. 7,446 745 8,191 8.191 30*4.2 Propertytoes 1,346 135 1,480 1,480 30.4.3 otoy Plant bdgiet 1,560 234 1,794 1,784 30.4.4 NRC ISFSIFees 2,582 258 2,840 2.840 3X.4.5 E PlonnrogFees 0Merency 2,033 203 2,236 2,236 30.4.6 ISFS1OperatingCosts 585 133 1.018 1,018 32,189 4,828 37.017 37,017 572,786 3c.4.7 Sownty Staff Cost 9.023 1,356 10,392 10,392 143,409 30.4.8 Uiy StnffCost 7.891 64,968 64.968 716,194 3.4 SublomtlPeriod3c Penod-OependentCosts 57,977 59.339 8.231 87.570 67,570 715.194 30.0 TOTALPERIOD3. COST PERIOD3d -GTCCSlhpping Perio 3d DirectDecornmouioningAcivties NuclebrSt.-a SupplySystamn Remov, 35.1,1.1 V..et&sInt*.nolRGTCC Dioslal 290 8,851 1.363 10,514 10,514 512 105.595 3d.1.1 Totals 200 8,951 1,363 10,514 10,514 512 105.595 3d.1 Subtotal Perod5 3d Ac" Costs 210 8,951 1,363 10,514 10,514 512 105,595 Period 3d Perio-D4epende COcT" 3S.4.1 1- - 31 3 34 _ 34 34d4.2 Proper tyoxo 6 1 8 6 7 1 7 7 WA4*.3 Plantener0y budget

- . . 11 1 12 12 3d4.4 NRC ISFSIFees

- - 8 1 9 9 WAS4.5 Emergency Pl0ann Fee.

4 1 4 4 3W.4.R ISFSIOperatng Coot.

344.7 Secury SDUIT Cost 134 20 155 105 2.391 398 6 43 43 599 34.48 UilitySaff Cost 34.4 SubtotalPeiod 3d Period0-epodent Cost 238 33 271 271 2,800 2.990 34.0 TOTALPERIOD3d COST 200 8.951 23B 1.396 10,785 10,514 271 - .- - 512 105,500 PERIO0D13-ISFt Deov 8 o1 o Perod 3. DirectDebomrnieboning AOOides Period 3. AddihoealConts 3a.2.1 ISFSILicenseTernwnaton(TN-40) 5 317 177 3.271 827 1,001 5,599 5,598 - 31.862 6,429.376 2,909 1.12D 5 317 177 3,271 827 1,01 5.59B 5,580 31.862 6.42&.376 2.909 1.12D 3..2 SubtotalPeriod3. AddiionalCost.

Period 3o Pe.od-)SPandend Costs 3.4.1 W0 121 12 133 133 3.42 Propero tyooo 22 2 24 24 T"/,0 ts-roo, la0.

Prairie IslaondoNooOdo-Generating P1000t Dricapeen X01.1586-002, Rev. 0 DeeooooiooondiagCo.$ Analysis App-ra.l C, Patge10 of21 Table C-I Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

O-U. LLRW NRC SpentFuel sit. 604a Procraw Rott1900u0 r44 u as IUdfy aod Activity 04,00M Reovooal Packaging Trospoot Processing Disposa Other. Total Tosts Uc. Tero. Management Restoration Voluate Class A CiosSB Clas. C GTCC Processed Craft CodtoIt Index Activt 0escr0p1on Cost Coot Costs ots ts Cosot Coots Costs Coooa Costs Coot. Cost. Cosot Cu. Fet Cu. Foot Cu. Foot Cu. Foot Cu. Feet W, Lbs. Machoors Manhours PeriodS3 Period-DepeodontCostns(cnrnued) 30.4.3 Heavy Wqiptnent l 244 - * - 37 281 281 3e.4.4 Ploteerrogy budget 85 13 97 97 3S.4.5 NRCISFS1 Foeo 33 3 36 36 146 22 167 167 2,510 30.4.0 Secuity Staff Cost

- 119 Is 137 137 1,901 3n4.7 UtUtyStaff Cost 244 - 525 107 876 876 4,411 30.4 Subtotl Period39 Period-Opendent Coas 30.0 TOTALPERIOD3. COST 249 317 177 3,271 1,353 1.10S 6,474 6.474 31,862 6,426,376 2,909 5.531 PERIOD31f- tSSSit.a Restoration Period3f DirectDecSmrssiooningAc0v0es.

Period3f Addi0ona0 Costs 372 - 23 59 454 454 - 1.591 80 3Y.2.1 ISFSIDemoliton& SitnRestoraton (TN-40) 372 23 59 454 454 - 1,591 0 3f.2 Subt0ta Penod 3f AckOOiboalCosts Perid 3f CoatotarlCosts 31.3.1 S-lI tol W .1I00n 1 0 1 I 31.3 SubtotalPeriod3f Collateral Cost. 1 0 1 I Period3f Perind-DepeodentCosts 3f.4.1 1oo--ano.

3f.4.2 Propertytae 11 1 12 12 3f,4.3 Heavy Wqopment rental a,1 - - 12 94 94 31.44 Plant eny budget 43 6 49 49 -

3f.4.5 Security *untCoot 73 11 84 84 - 1,205 3W.4.0 Si Sotr Cost . 49 7 57 57 784 31.4 1 Period3f P.id-Deperndnt Costs Subtt0 81 177 38 296 296 2.050 455 19. 98 752 752 1,591 2,130 31.0 TOTALPERIOD 3fCOST PERIM 3 TOTALS 14,806 517 177 12.222 76,858 15.230 119.80) 10,708 82,919 26.181 31,802 - 512 6,531,971 114,306 933,040 TOTALCOSTTODECOMMISSION 6,492 57,055 14.998 5,816 11,488 37,154 481.A47 104.946 710,795 487,988 200.095 31,713 132.037 100,572 2,469 B18 512 16,800.170 626,920 4.892.411 rOTALCOSTTO DECOMMISSION WITH1,07% CONTINGENCY: $719,799 thousand of 208 dollars, rOTALNRC UCENSETERMINATION COST I 67.0%OR: 5437,988 thousandsof 28080do0lar IPENTFUELMANAGEMENT COST IS 27.8%OR: $200,094 thousands of 2898 dollars ON-NUCLEAR DEMOUTIONCOSTIS 4.41%OL $31,713 thousonds of 2008 dooa00 rOTALLOW4.EVELRADIOACTIVE WASTEVOLUMEBURIED(EXCLUDING GTCC): 103,959 cubic fedt tOTALGREATERTHANCLASSC RADWASTE VOLUMEGENERATED: 512 cubic teot tOTALSCRAP METALREMOVED. 27,00 tons rOTALCRAFTLABORREQUIREMENTS: 026,920.a0-Eons End140t0s:

We0- inlals 01.0 ha tisa0ivt deonrussionirig0 00p000.

chage as.5001,..

a _Indicates.trot 00001010porkarnOd by atf.

stbooool o - Indicatesthe: 0011. 8hsvau 1s0esta 0.5butd isrin-,.o

. -0 consinrog" - indicates .n - valu 3LG sr*ico, Ino,.

Pnioki blond Noolear, Genratrinog Stoutioo Doeonteng XOI.158.O-00, Rem. 0 DecouenodionioddgCost Annilysis Appendix C, Page II of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Off-aSt, LLRW URC Spent Fuel Site Proceesed o-lalVolumel Burial UtIty Attty Icn RemovedPackaging Transuport Processlng Disposal OUter Total Told Uc. Teem. Mauagemnent Restoraton Volume Class A Clases Class C GTCC ProCnssed Craft Corrautor dex Actviy Descipt Cost Cost Coats Costs Costs Coat. Coot, ConS Cost. Costs Cost. Costs Cu. Feet Cu. Feel Cu. Feel Cu. Feet Cu. Feet Wt Lbs. Manors M0ort PEROD1a - Shutdown throughTransiton Period la Direct Decomrissioning Act-res 1:.1.1 Prepare prel*ssry d o cost 60 9 69 69. 556 10.1 2 Notificationof Cessato *O1perations 1a.013 Remove tuel & source mate1al tra 1a.1.4 Notificationof PermanenlDefeelg la.1.5 Deactvate plant systerms & process waste a Ia.1.6 Prepare aod subst PSDAR 93 14 107 107 a56 214 2 246 246 1,969 la.1.7 Review plant dwgs &specs.

Ia.1.8 Perform detailed rod survey 46 7 53 53 . 428 la.1.9 Estimate by-product invetory 46 7 53 53 428 1a.1.10 End prodc desiphor .

60 9 69 69 556 la.1.11 Detailed by-product inventory 348 52 401 401 3,210 la.1.12 Definmmaim worksequence 144 22 166 166 1.327 la.1.13 Perform SER and EA 232 35 267 267 2.140 1a.1.14 Perform Sit~epecdc Cost Study 190 29 219 219 1,753 la.1.15 Prepare/submtLiUcenseTermination Plan 1a.1.16 Receive NRC approval of termination plan a Actvty Specifcations 229 34 263 237 26 2,106 10.1.1,721Plant & temporaryfoerifiee 194 29 223 200 22 1,783 1011.72 Plunssystems 214 la.1.17.3 NSSSDeontaminationFsh 23 3 27 27 3.30 49 379 379 3,039 U..1174 Reactor intemals 302 45 347 347 2,782 la.1.17.5 Reactor vessel 23 3 27 27 214 a.01176 Biological shield 145 22 167 167 1,335 11.117.7 Steam generators 685 la.1.178 ReMifonrced conreto 74 11 85 43 43 19 3 21 21 171 la.1.179 MsnTurbine 19 3 21 21 171 la.1017.10 Main Condenser 145 22 167 83 83 1,335 la.1.17,11 Plant strsctures & buSldings 1,969 la.1.17.12 Waste mnnagement 214 32 246 246 42 6 48 24 24 385 la.1.17.13 Faciity & site closeot 1,758 264 2,021 1.780 241 16,190 la.1.17 Total Plani0ng &Site Preparations 17 128 128 112 1,027 la.1.18 Prepare dismatlmingsequene la.1.19 Ptant prep. &temp. ovoes 2.700 405 3,105 3,105 65 10 75 75 599 Ia.1.20 Design water dea-up systemn la.1.21 Riging/Cont. Cr01 Envlpsftooing/etc. 2,100 315 2,415 2,415 1a.1.22 Procure caskstliners &containers 57 9 66 66 31526 8,227 1,234 9,461 9,219 241 - 31.566 1a.1 Subtotal Period 1a ActivityCosts Period 1a AdditionalCosts la2.1 Spent Fuel Pool Isolation * - - - 5.140 771 0,911 5,911 la.2 Sutotarl Period 1aAdditionalCosts - - - - 5,140 771 0,911 5,911 Perod 1a Colaterl Costs 1a.3.1 Spent Fuel Capital and Transfer - - 9,475 1.421 10,898 10.89 -

1a.3 Suototal Period 1aCollateral Costs * - 9,475 1,421 10,8986 Period 1a Period-Dependent Costs 1a.4.1 Insurance 775 77 852 852 10.4.2 Property taes 1,745 174 1,919 1,919 la.4.3 Healtr physics supplies 363 91 454 454 TLG Servies, lne.

Prairie I0sland Nearteer Genear~ling Station Docusenes XOI.1588d-OORaev.0 Deeoeasd-i-ing Cost Analysis Appeadia' C, Page 12 or~l Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Off-Sit8 LLRW NRC Spent Fuea Star PrOCessed Buruta voitures B*uriali ullthin. l IlActivity Decon Cost Removal Cost Packaging Costs Transport Costs Processing Costs Disposal Costs Other Costs Total Continsency Total Costs Uc. Term.

Costs Managernet Costs ROestataon Costs Volu-e Cu. Fast Class A Cu. Fast Class B Class C Cu. Feet Cu. Feet GTCC Cu. Feet PressedP Wt, 1.6.

Craft Manhours ContractorI Manhours Period 1a Peniod-Dependent Costs (continued) la.4.4 Heavy equipment rental 387 58 445 445 la.4.5 Disposal of DAWgenerated 8 6 "38 11 64 64 11,299 21 la.4.6 Plant energy budget 2,557 383 2,940 2,940 la.4.7 NRC Fees 471 47 518 518 la.4.8 Emergency Planrnrg Fees 275 27 302 - 302 la.4.9 Spent Fuel Pool O&M 373 56 429 429 la.4 10 ISFSI Operating Costs 44 7 50 50 la.4 11 Security Staff Cost 8,099 1.215 9,314 9,314 157,471 la.4.12 LUUtyStaff Cost - 19.030 2,855 21,885 21,885 - 346,229 565 11.299 21 503,700 la.4 Subtotal Period Ia Period.Oependent Costs 750 8 6 38 33.368 5,002 39.172 38,391 78 2 750 8 6 38 56.209 8,428 65.440 53,522 11,677 241 11.299 21 535,266 la.0 TOTAL PERIOD la COST PERIOD lb - Oecommissioning Preparations Period lb Direct DeconnmissionongActvities Detailed Work Procedures lb.1.1.1 Planlt systems 220 33 253 228 25 2,026 lb.1.1.2 NSSS Decooitamirntion Rush 46 7 53 53 428 lb 1.1.3 Reactor internals 116 17 134 134 1,070 lb 1.1.4 Remianong buildings 63 9 72 18 54 578 46 7 53 53 428 lb 1.15 CR0 cooing assembly lb.1.1.6 CRD hoimngs & ICItubes 46 7 53 53 428 lb.1.1.7 ncoe instrumentation 46 7 53 53 428 169 25 194 194 1,554 lb.1.18 Reactor vessel 56 8 64 32 32 514 lb 1.1.9 Facility closeout lb 11.10 Msosle shields 21 3 24 24 193 56 8 64 64 514 lb,1.111 Biological slheld 214 32 246 246 1,969 lb.1.112 Steam generatots lb.1113 Reilforced 0o0rete 46 7 53 27 27 428 lb1114 Main Turbine

• 72 11 63 - 83 668 72 11 63 - 83 668 lb.1.1.15 Main Conderriss lb.1.1.16 Aunxilarybuilding 127 19 146 131 15 1,168 15 1,168 lb.1.1.17 Reactor building 127 19 146 131 lb,1.1 Total 1,545 232 1.776 1,442 334 - 14,228 lb.1.2 Decon primary loop 380 190 570 570 1,067 lb.1 Subtotal Period lb ActivityCosts 380 1,545 422 2.346 2,012 334 - - 1.067 14,228 Period lb Additional Costs lb.21 Site Characteration S . - - 1,407 422 1.829 1,829 1b.22 MixedWaste 11 53 989 - 157 1.209 1.209 lb.2,3 Asbestas Abatement 1,598 1 103 - as 437 2,227 2.227 12,843 166,959 18.667 lb.2,4 RCRA Waste 2 4 19 4 28 28 1b.2 Subtotal Period lb AdditionalCosts 1.598 13 159 1,008 88 1.407 1,020 5,294 5.294 12.643 166,959 18,667 Period lb Collateral Costs lb6.31 Decon equipment 743 111 855 855 16b.32 DOC staff relocation espenses 912 137 1,049 1,049 lb.33 ProcessLiquid "ante 27 40 225 2,023 - 557 2,872 2,972 174 565 73,114 144 lb.3.4 Smau tool allowance 21 3 25 25 lb.3.5 Pipe cutting equipment 1,000 150 1,150 1,150 lb.3.6 Decon ng 1,400 210 1,610 1,610 lb.3.7 Spent Fuel Capital and Transfer 5,a44 677 6.720 6.720 TLG Services, lna.

ftui~ sleWod Nucelaar (Itnwrastlg Station Doncee-s XOI14586-002, RZe.0 Desrueiaadootg Cos"A.as.Ia Appensdiv C, Page 13 of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) 011-564 " LLRW NRC Spent Fuel Site Processed BMWVoluamts Bural Utilityand Act6viy Damon Rormal Packaging Transport Processing Disposa Oth. Total Total Lic.Tram. Managerst Restoration Vofeln, Class A Class B Clue. C GTCC Prosessed Craft ContractI Index ActlvityDesclption Cost Cost Costs Costa Costs Costs Costs Cotln Costa Costs Costs Costs Cu. Feet Cu. Feet Cu. Feel Cu.Feet Cu.Feet Wt, LIs. Manhours Mahlours 1b.3 SubtotalPeriodlb CollateralCosts 2,170 1.021 40 225 - 2,023 6,756 2,045 14,280 7.560 6,720 174 565 73,114 144 -

Period IlbPeW6-ependent Costs 1b.4.1 Decon supplies 23 6 29 29 15.4.2 Irsurance 391 39 430 430 lb.4.3 Property tames 880 88 968 968 1b.4.4 Health physics supplies 268 67 335 335 lb.4.5 Heavy equipment rental 195 29 224 224 5 3 223 7 37 37 327 6,541 12 1b.4.6 Disposal of DAWgenerated lb.4.7 Plait energy budget 2,578 387 2,964 2.964 Ib.4.8 NRC Fees 237 24 261 261 lb.4.9 Emergency Planning Fees 139 14 152 - 152 lb.4.10 Spent Foot Pool O&M 188 28 216 216 1b.4.11 ISFSIOperating Costs 22 3 25 25 4,0B3 612 4.695 4,695 79.383 1b.4.12 Secuity Staff Cost 3,536 530 4,066 4,065 47.314 1b54.13 DOCStaffCost 9.593 1,439 11,032 11,032 174,537 lb.4.14 UtiftyStaff Cost 12 301,234 23 463 5 3 22 21,645 3.273 25.435 25,G41 394 327 6,541 1b.4 SubtotalPeriod 1b Pernod-ODpendert Costs 1b.0 TOTAL PERIOD lb COST 2,573 3.083 56 388 1,008 2.134 31,353 6,760 47,356 39.908 7,114 334 13,344 565 246,614 19,889 315,462 2,573 3,833 66 393 1.008 2,172 87,562 15,188 112.796 93,430 18.791 576 13,909 565 257,913 19.910 850.728 PERIOD1 TOTALS PERtOD 2o - LargeCosiponasi Reetoval Period 2a Direct Decorrnmjssiortng Activities Nuclear Steam Supply System Rernoval 2a.1,1 Reactor Coolant Piping 41 34 4 7 55 45 187 187 288 34,807 1,414

22. 97 97 292 1- 21,288 625 2a.1.1.2 Pressurizer Relief Tank 18 15 3 5 34 303 1,539 1,539 41 46 999 132 1,701 325,380 1,785 2a. 1.1.3 Reactor Coolant Pumps &Motors 20 84 .46 36 58 492 396 - 671 309 1,963 1,963 . 2,460 202,122 2.202 -

2a.1.1.4 Pressurizer 181 2.513 1.739 1.330 1.149 3.088 2,037 12.036 12,036 18,672 11,316 1,668,341 11,617 2,875 2a.1 1.5 Steam Generators 2a.1.1.6 CRDMs IClsIService Structure Rerocal 126 55 118 34 - 84 115 531 531 - 2,404 53,072 3.225 -

98 1.777 9,977 908 9.334 174 8.756 31,065 31,065 501 527 918 219,145 21.733 1.001 2a.1.1.7 Reactor Vessel Internals 1,022 459 - 4.412 174 5.216 14.793 14.793 4,319 1.377 - 619,525 21.733 1.001 2a.1.1.8 Reactor Vessel 58 3.450 13,375 3,223 1,195 18,677 349 16,845 62,212 62.212 18.804 23,180 1.904 918 3,143,680 64.414 4.878 2a.1.1 Totals 599 7,949 Reoanl of Major Equipment Main Turbine/Generator 245 130 51 357 160 176 1.120 1,120 2,131 1,187 - 287.637 4.667 -

2a.1.2 2,045 56 35 253 120 590 3,099 3,099 2,851 841 203,723 39.151 -

2a.1.3 Main Conrdensers Cascading Costs fror Clean BuildingDerolition 862 129 992 992 11.414 2a.1.4.1 Reactor 357 54 411 411 4,945 2a,1.4.2 A 'xrlaoy 13 2 15 15 179 2a.1.4.3 Radwaste 1,233 15 1,417 1.417 16.538 2a.1.4 Totals Disposal of PlantSystte 2a.1.5.1 Admri Bldg Ventilatior 4 1 4 4 76 20 3 23 23 422 2a.1.5.2 Air Rerosal 32 5 36 36 - 676 2 ..1.5.3 Auxiiary Foe t r 25 0 14 8 48 48 178 7,214 466 2a.1.54 Aualiary Feedwate -RCA 63 9 73 73 - 1,331 2a.15.5 Bleed Stean CauOricAddition -RCA 27 0 19 10 57 57 240 9.761 466 2a.1.56 12 2 14 14 - 2m1 2a.1.57 Chtrcal Feed 2 0 0 1 1 4 4 16 634 31 2a.1.5.8 Crerko Feed -RCA TL/ Sedicea,lie.

Prairie Islandi Nefear Genrooating Station Docasreoro XOI-ISS&.062, Bes. 0 D4aronuiaaiordng Cost Analysis ApPendixn C, Page 14 oral Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) off-at. LLRW NRC Spent Fuel Site Processed Burial Volumes BurialI Utility end Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Uc. Term. Management Restoration Volme Class A Class B Class C GTCC Processed Craft Contractor loden Activity Description Cost Cost Costs Costs Costs Costs Cots ContCnen.C osts C Costs Costs Costs Cu. Feet Cu. Feet Cu. Foot Cu. Feet Cu. Feet Wt. Los. Manhoure Mantomrs Disposal of Plant Systems (cotinued)

• 19 3 22 22 401 2a.1.5.9 Circulating Water 2a.1.5*10 Condt e 373 56 429 429 7,537 2a.1.5 11 Condensate Poiishing 146 22 168 - 168 2,987 2a.1.5.12 Condensate Polishing - RCA 26 1 3 39 13 81 01 - 4483 19.616 486 2a.1.5.13 Eleeto-Hydraulic 7 1 a - - 143 S19 3 21 - 21 - 385 2a.1.5.14 External Cirslating Water -58 2a.1.5.15 External Circulating Water - RCA 50 1 4 22 134 134 - 721 29.264 927

• 90 13 103 - 103 - - 1,840 2a.1.5.16 Feedowter 170 .5 25 332 96 628 628 - 4,147 168.414 3,319 2a.1.5 17 Feedwater - RCA 2a.1.5.18 Gland Seal 23 4 27 27 - * - - 504 -

2a.1.5.19 Heater Drain 270 41 311 311 5,638 4 1 5 - 6 2a.1.5.20 Hypobromous Acid Feed 1 0 o 0 0 1 1 2 100 11 2a.1.5 21 Hypotoomoos Acid Feod - RCA 2a.1.5.22 Internal CiroWater &CDSR 3 20 20 - - 366 0 0 0 5 2a.1.5.23 Main GentExcter/Transformer - 0

`71 11 81 - 81 - 1,482 2a.1.5.24 Main Steam 260 6 31 413 132 843 643 5,166 209.799 5,061 2a.1.5.25 Main Steam - RCA 2a.1.5.25 Repairable Spare Snubbers 4 0 0 1 - 1 6 6 - 12 490 75 1 0 2 - 2 - 32 2a.1.5.27 Steam E2uesol 3 0 0 2 1 6 6 24 966 47 2a.1.5.28 Steam Exclusion - RCA 2a.1.5.29 Steam Generator Slowdowno 277 11 20 153 64 112 636 636 - 1,906 457 117,369 5,408 4 1 4 4 S- 75 2,a.1.5.30 Steam Ge*n"Waon 268 40 308 308 5,472 2a.1.5.31 Turbine & Moisture Separatots 37 6 43 43 757 2a.1.5.32 Turbine Oil Puttcaton 364 -

316 47 364 - - 6,676 2a.1.5.33 Water Treament 14 0 1 9 5 29 29 - 115 4,652 250 2a.1.5.34 Water Treatment -RCA 2,654 25 86 1.041 64 671 4,540 2,473 2.067 13,010 457 568,299 53,692 2a.1.5 Totals 2a.1.6 Scaffolding insupport of decommissioning - 2,304 16 6 90 9 - 595 3,022 3,022 - 1,012 63 - 51,199 25,908 2a.1 Subtotal Period 2a ActivityCosts 599 16,430 13,603 3,403 2,935 19,030 349 19,061 75,410 73.343 2,067 37,809 25,727 1,904 918 4.254,538 204,371 4,878 Period 2a Collateral Costs 59 - 22 118 111 77 386 386 23.991 78 -

2a.3.1 Process liquid waste - 400 2a.3.2 Sinai tlol allowance 165 25 190 171 - 19 2a.3 3 Spent Fuel Capital and Transfer -

S 14,036 2,105 16.141 - 16,141 165 22 118 111 14.036 2,207 16,718 558 16,141 19 400 23,991 78 2a.3 Subtotal Period 2a Collateral Costs 59 Period 2a Period-Dependent Costs 2a.4.1 Decon supplies 57 14 71 71 2a.4.2 Insurance 513 51 564 564 2a.4.3 Property taxes 2.194 219 2,414 2,172 241 2a34.4 Health physics supples 1,.229 307 1,536 1,536 2a.4.5 Heavy equipment rental 2,338 351 2,689 2,689 54 36 246 72 409 409 3,621 72,430 132 2a.4.6 Disposal of DAWgeneratod 34.4.7 Plant energy budget - 3,054 458 3,512 3,512 2a.4.8 NRC Fees 567 57 623 623 2a,4.9 Emergency Planning Fees 126 13 138 138 2a.4.10 Spent Fuel Pool O&M 469 70 539 539 2e.4.11 JSFS1Operating Costs 55 8 63 - 63 8,617 1,293 9,910 9,910 165,896 23.4.12 Security Staff Cost 15,373 2,306 17,679 17,679 199.337 2a.4.13 DOCStaff Cost 3.266 25,038 25,038 371,134 2a.4.14 UtilityStaff Cost 21,772 57 3.567 54 36 246 52.739 8.485 65,184 64,203 740 241 3.621 - 72,430 132 736,367 23.4 Subtotal Period 2a Period-Dependent Costs 715 20,162 13,678 3,556 2,935 19,388 67.123 29.754 157,312 138,103 16,881 2,327 37,809 29,749 1,904 918 4,350,959 204,580 741,245 2a.0 TOTALPERIOD 2a COST TLG Services, lac.

PrairieIstand Nwleloo Generating Sta.tion Documaent XOI.1586-00, Ram'0 lleconnsasisoiaingCost Analysis Appendio C, Page 15 of 21 Table'C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) mmlotImp Utiit an ClassmalB Volume; I

Otm-Sit LLRW Total NR; Lic. Term. S:pent Fuel Managenenst sit Restowratll Processed Volrm Clars A Class C GTCC Processed Craft Contra Decon Removal Packaging Tran s port Processing Disposal Other Total I Activity Cat C,.st Cats C.,.. C,... costs Cart. Cano,,o- Cal.m Cal.t Cotl. C.,. Cu Fee C., Feel Cu Feel CU. F..t Cu Foo WI IbOs rfi,, Man~hooos

- 'ry- P- Cast Cast costs costs Costs Costs costs Cost. Cu Feet Cu Feet Cu Feel Cu Feel Cu Feet WL Lbs. Manhours PERIOD 2b- Site Decontminaton Period 2b Diect Decommissionng Acivates Disposal of Pant Systems 2b,1.1.1 ADT& Mist Ventilation 18 0 1 12 1 7 40 40 153 7 6,793 363 2b.1.1.2 Aux Bldg Normal Ventilation 51 1 5 55 4 - 23 139 139 692 27 30,558 1,012 2b.1.1.3 AuxBldg Special Ventlation 10 0 0 6 1 4 20 20 - 70 4 3,225 197 2b.1.1.4 Battely RFl Special Ventilation 1 0 I - S- 20 0 3 0 0 0 1 1 5 5 3 6 680 50 2b.1.1.5 Boron Recyde 2b 1.1.6 Chemical & Volume Control 553 622 35 41 .189 199 520 2.158 2,158 - 2,356 1,485 220,756 22,365 0 0 - 0 -

• 8 2b 1.1.7 Cold Chemical Lab Vrrtiaon 0 2b 1.1.8 Component Cooling - RCA 442 14 71 960 266 1.753 1,753 11.996 487,169 8,420 24 4 27 - 27 - - 477 2b 1.1.9 Containment Cooling 16 219 87 529 529 2,743 111.390 3,872 21.1.1.10 Containment Cooaing- RCA 2D4 3 2b.1.1.11 Conta fnentHydrogen Control - RCA 25 0 1 11 8 46 46 141 5.742 487 127 2 9 116 - 51 305 305 1,453 59,019 Z507 2b,1.1.12 Conti;mre Spray - RCA 2b.1.1.13 ContainmendVesilation 169 13 38 378 73 124 794 794 4.721 509 237,445 3,366 1 2 21 2 10 58 58 - 260 14 11,856 454 2bI..114 Cor~trl/Relay/Cnqr RemVert 23 2b.1.I.15 CoolingWater 112 17 129 - 129 - - Z344 29.1.1.18 CoolingWater - RCA 329 10 50 675 192 1.256 1,256 -S .8442 342.822 6,243 2b..1.1.17 CranesHolatslevatoas - RCA 2 0 1 a 2 13 13 - 103 . 4,184 48 2b.1.1.18 D3 Emergency Diesel 7 1 8 140 7 1 8 140 2b.1.1.19 D4 Ernergency Diesel 0 0 0 0 5 2b1.1.20 D5 Emergency Diesel 2b.1.1.21 Electrical -Clean 1,222 183 1,405, - - 1.405 - - 24,276 2b.1.1.22 Electrical - Contaminated 332 3 13 100 a 111 620 626 - 1,997 53 85,872 6,502 1,500 745 4,382 4,382 18,753 761,569 38,423 2b.1.1.23 Electrical - Decontaminated 2,003 22 - 111 3 0 0 2 0 1 7 7 - 24 1 1.017 69 2b.1.1.24 Filter Rm Ventilaton 21 163 - 163 - 3,009 2b.1.1.25 Fire Protection & Detection 142 164 2 11 146 65 388 388 -

S 1,828 74,245 3,057 2b.1.1.26 Fire Protection & Detection-RCA 54 . 16 5 18 96 96 - 200 35 11,259 1,101 2b.1.1.27 Fuel Handling 1 0 0 1 1 9 2b.1.1.28 Fuel Oil 2b9.1.1.29 HVAC- Clean 106 16 122 122 - - 2,373 905 16 69 860 41 377 2.268 2.268 - 10,745 286 462,026 16,575 2b91.130 HVAC- Contamnated 224 34 257 - 257 - - - 4,804 2b 1.1.31 Healing 224 2 11 153 81 471 471 1.907 - 77,458 4,028 29..132 Heating - RCA 14 0 1 9 0 5 29 29 107 3 4.621 285 2b9.11.33 Hot Lab & Sample Rm Ventilaton 0 22 1 1 5 6 8 43 43 .- 60 41 6.097 457 2b. 1 1.34 Incore Instumentagto 157 7 8 37 43 57 309 309 458 302 45.599 3,050 2b 1.1.35 MiscDrains &Vents 90 5 5 30 24 34 189 189 - 370 172 30,430 1.709 2b.1.1.36 Misc Lab &Serios Areas Vent 49 7 57 - 57 - - - 1,073 2b.1.1.37 Miscelianeoxs Gas 88 1 4 48 30 170 170 -S 600 24.378 1,593 29.1.1.38 MisceLaneoxs Gas - RCA - - 111 2b 1,.39 Radiation Monftonng 5 1 6 - 6 -

44 0 2 25 15 87 87 316 12,826 782 2b.1,1.40 Radiaior" Morarorig - RCA 120 152 11 11 18 73 122 507 507 229 516 55,497 5,247 29 .1.1.41 Reactor Coolant 2b.1.1.42 Reactor Hot Sampng 103 87 6 5 4 31 83 319 319 54 220 21,920 3,680 2b.1.1.43 Reactor Makeup 29 4 33 - 333 - - 583 3 0 0 2 1 6 6 28 1,148 47 2b91.1.44 Reactor Makeup- RCA 7 10 o 0 2 1 7 27 27 22 10 1,781 337 2b9..1.45 Reactor Vessel 2b.1.1.46 ResidualHeat Removal 227 260 46 61 228 327 308 1,457 1,457 - 2.853 2,290 321,222 6,693 2b91,.47 Safeguards Chilled Water 3 1 4 - -. 4 - - - 75 605 24 55 534 117 271 1,606 1,606 S 6.676 857 344,588 11,818 2b.1.1.48 Safety injection 36 2 1 3 9 12 64 64 - 37 66 7,398 712 2b.1.1.49 Sampling 2b.1.1.50 Seravce Bldg & New Cmpt" Vent 0 0 0 - 0 - S- 0-85 7 19 162 45 61 383 383 - 2,028 342 113,039 1,717 2b1 1 51 Shield Bldg Ventilation 112 17 129 - 129 - - - 2,424 2b.1.1 52 Station &Instrument Air 210 se-kie'%, La..

Praiie Is lood Nuclear Generidiiog Station Docooooot XOI-1586002OZ Rev. 0 Doooosesions~oig Cost Aoolyoi. Appendix C, Page 16 of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

NRC Spent Foel alto Processed Burial Volomnes Burial I Utily and Off'S". 1RW Contoract Activity Decon Reaoval Packaging Transport Proossing Dlsposal Other Total Total UL. Term. Management Restoation Volumne Class A Class B Class C GTCC Pocessed Craft Indes Actvity Description Cost Cost Costs Costs Costs Cost Cofl Cos C*ts Costs Costs Cu. Foot Cu. Feet Cu. Feet CU.Feet Cu. Feot WL. Lbso Maohors Motro D0sposal of Plant Systems (continued) 2b.1.1.53 Station I Instrumert Air -RCA 203 2 10 130 72 416 416 1,625 65.986 3,626 2b.1.1.54 Turbine Bldg Taps ItDr s 21 3 24 24 - 462 2b.1.1.55 Turbine Bldg Traps &Drains - RCA 20 0 1 14 7 43 43 180 7,321 342 2b.1.1.56 Turbine Bldg Ventaton 28 4 32 32 547 2b.1.1.57 Unit Cooles 16 2 1i 18 - 332 2b.1.1.58 UntCoo-le0RCA 36 0 1 19 12 69 69 232 9,413 665 2b.1.1.59 Wasteoas Dposal 414 340 25 33 196 137 363 1.509 1.509 2,453 1,086 185,530 14,293 2b.1.1.60 WstesLquid Disposal 1.061 1.167 65 70 292 361 973 3,990 3.990 3,655 2,677 375.774 42,536 2b.1.1.61 Waste Solid Disposal 84 100 6 8 31 40 84 353 353 389 288 40.666 3,429 2b.1.1 Total 2,569 11,339 335 749 7,277 1,552 5.534 29.356 26.930 2,426 90,963 11,297 4,670,322 265,371 2b.1.2 Scaffoldingin support of decommissioning 2,880 20 10 112 11 743 3,777 3,777 1.265 79 63,999 32,385 Decontamiation of Site Buldtngs 2b.1.3.1 Reactor 888 772 90 140 178 546 830 3,444 3,444 2.230 5,953 657.547 30,856 2b.1.3.2 Auxiliary 929 326 45 73 85 156 613 2,228 2,228 1.060 2.911 332,476 23,88W 20 .1 3.3 Bodrash Woase ReceivLngTank - 23 7 10 23 14 78 78 - 439 43.896 311 2b 1.34 Drum Transfer &TruckLoading Enclosure 13 7 1 2 1 3 10 37 37 19 64 7.118 370 2b.1.3.5 LLRWStorage Enclosure 89 42 7 10 23 63 237 237 38 435 44.969 2,436 2b.1.3*6 Radwoste 39 19 3 5 10 29 108 108 42 196 21.136 1,087 2b.1.3.7 Resin Disposal 12 9 1 2 7 3 10 44 44 83 60 9.271 384 2b.1.3 Total 1.970 1.198 154 242 278 766 1'569 6,176 6.176 3.471 10.058 1.116,412 59.330 2b. 1 Subtotal Period 2b Acivity Costs 4.539 15,417 510 1.801 7,667 2,329 7,846 39,309 36.883 2,426 95.7D0 21.434 - 5.850.732 357.087 Period 2b Collateral Costs 2b.3.1 Process liquid vste 213 - 137 768 973 479 2,570 2,570 2.552 209,631 498 20.3.2 Small tool allowance - 276 41 318 318 20.3.3 Spent Fuel Capital and Transfer - 11,876 1,781 13,657 13,657 -

2b.3 Subtotal Period 2b Collateral Costs 213 276 137 768 973 11.876 2,302 16.545 2,888 13,657 2.552 209,631 498 Period 2b PeriodDependent Costs 21,.4.1 Decon supplies 777 194 971 971 2b.4.2 Insurance 810 81 891 891 2b.4.3 Property taxes 1.702 170 1,873 1,873 2b.4.4 Health physics supplies 2.054 513 2,567 2.567 2b04.5 Heavy equipment rental 3.667 550 4,217 4.217 2b.4.6 Disposalof DAWgenerated 81 53 369 108 612 612 5,422 108,444 198 2b.4.7 Plant energy budget - 3,809 571 4.380 4.380 2b.4.8 NRC Fees 895 90 985 985 20.4.9 Emergency Planrnig Fees 198 20 218 218 2b.4. 10 Spent Fuel Pool O&M 740 111 851 - 851 2b04.11 LiquidRod te Processulg Equipment/Services 373 56 428 428 20.4.12 ISFS1Operating Costs 86 13 99 - 99 20.4.13 Security Staff Cost 13,611 2,042 15,653 15,653 * *

• 26Z036 20.4.14 DOCStaff Coast 23.389 3,508 26,897 26,897 302429 2b.4.15 USltyStaff Cost 33.023 4,953 37,976 37,976 561,357 2b.4 Subtotal Period 2b Perod-Dnpencent Costs 777 5.720 81 53 369 78,636 12,981 98,618 97,449 1.169 5,422 108,444 198 1,125,821 2b.0 TOTALPERIOD 2b COST 5,529 21,414 728 1,822 7,667 3,670 90,512 23,129 154,472 137,220 14,827 2,426 95,700 29,408 6,168,807 357,782 1,125,821 TLO roie-., Ine.

PrairieIsln Nuclear Generating Stration D-oe.-.$ XO1-15863-002,Bet. 0 Deoueeadario..ingCost Analysis Appendixs C, Page 17 ot~l Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

IAc~t Off-Sits LLRW NRC Spent Fuel " Site Prosassed Burial Vofums Burld I Utility and Decon Retoreval Packaging Transport Processing Disposal Other Total Total Uc. Terom M.Iagernt Restoatreon Volume Class A Class B Class C GTCC Processed Craft Contractor l Cost Cost Costs Costs Costs Costs Costs Continaencv Costs Casost s sts Costs Cu. Feet Cu: Feet Cu. Feet Cu. Feet Cu. Feet Wt. Lbs. Manhours Manhours I PERIOD Z. - Delay Before End Of Wet Fuee Storage Period 2c Direct Dewornursioning Aobmfes Petiod 2c Collateral Costs 2c.3.1 Spent Fuel Capital and Transfer S -. 51,490 7,723 59,213 59,213 2c.3 Subtotal Period 2c Collateral Costs 51.490 7,723 59,213 59,213 Period 2c Period-Depndent Costs 2c.4.1 insurance 4,171 417 4,589 4,589 2c.4.2 Property taxes 8,796 880 9,675 9,675 2C.4.3 Health physios supplies 654 - 213 1.067 1,067 2c.4.4 Disposal of DAWgenerated 19 13 88 - 26 146 146 1,295 25,900 47 2c04.5 Plant energy budget 5,248 787 6,035 6,035 2c.4.6 NRC Fees 1,751 175 1,926 1,926 2c,4.7 Entergency Planning Fees 1,026 103 1.128 - 1,128 4,309 - -- -

2C.48 Spent Fuel Pool O&M 3,925 574 4,399 2c.4.9 ISFSJOperating Costs 447 67 514 - 514 2C.4.10 Seuity Staff Cost 32,601 4,890 37.491 37,491 - 626,117 2c.4.11 LJtity Staff Cost 33,534 5,030 38,564 38,564 - 620,766 2C4 Subtotal Period 2c Pernol-Oependent Costs 854 19 13 88 91,398 13.162 105,533 99.493 6,041 1.295 25,900 47 1.246.883 854 19 13 88 142.888 20,885 164,747 99,493 65,254 1,295 25,900 47 1,246,883 2c.0 TOTALPERIOD 2c COST PERIOD 2d - Decontainnation Folowing Wet Fuel Storage Period 2d Direct Deconrrissaninog Activies 249 26 65 28 211 194 773 773 1.477 - 132519 576 2d.1.1 Remove spent fuel racks Disposal of Plant System 142 1 6 69 3 48 269 269 864 23 37,160 2,783.

2d 1.2.1 Electrical - Contaninated - Fuel Pool 860 10 48 646 320 1,8w3 1,883 8,069 327,668 16,495 2d 1.22 Elecbical - Deortan*iratod - Fuel Pool 286 25 0 2 23 10 60 60 11,622 464 24:1.2.3 Fire Protection & Detection - RCA Fuel Pool 2d 1.2.4 HVAC- Cofarinsatod - Fuel Pool 407 7 31 386 13 170 1,019 1,019 4,828 128 207,577 7,447

- 3 0 0 2 1 6 6 26 - 1,045 51 2d.1.25 Safeguards Chilled Water -RCA 11 878 23 25 2 2 3 - 21 87 87 39 75 8,311 2d.126 Spent Fuel Pool Cooling 394

- 20 0 2 21 1 - 9 53 53 265 8 11,500 2d.1.27 Spent Fuel Pool Normal Ventislstn 33 23 1,481 21 90 1.150 -

578 3,377 3.377 14,376 235 604,883 28,512 24.1.2 Totals Decontaminamon of S0e Buildings 777 846 16 31 193 647 2,559 2,559 48 2,417 806 177.542 30,420 2d.1.3.1 Fuel Handling ofAur Building 77-7 846 16 31 193 48 647 2,559 2.559 2,417 806 177,542 30,420 2d.13 Totals

- 576 4 2 22 2 149 755 755 253 16 126800 6,477 2d5.14 Scaffolding in support of deosrmmassioning 2d.1 Subtotal Period 24 Ac"oolyCosts 1,049 2,929 106 151 1,366 295 1,569 7,464 7,464 17,046 2,533 927.744 65,985 Period 2d Collateral Costs Process Ipkid waste 62 24 130 125 84 426 426 440 27,040 86 2d.3.1 24.3.2 Smars tool etlowa.',ro - 57 9 65 65 55 532 53 111 848 848 - 6,000 373 303,507 88 2d.3.3 Deconnisssorarg Equopment Disposion 96 24.3.4 Spent Fuel Capital and Transfer 227 34 261 - 261 62 57 120 185 532 179 227 238 1,600 1,339 261 6,000 813 330,547 174 213 Subtotal Period 2d Collateral Costs TLG Seroi"e4, Ino.

PrairieIsland NuclearGeneratingStation Docnument X01-158&-002, Rev. 0 Desoommissnnsing Cosl Analysis Appendix AZ Page 1 ofs21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Off-tsts LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utilityand Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Uc. Term. Management Restoration Volume Class A Class B Clans C GTCC Processed Craft Contractor Index ActivityDescription Cast Cost Costs Costs Costs Costs Costs Conteninnca Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu.Feet Cu. Feet WtLLbs. Manhours Manhours Period 2d Penod-Oependent Costs 2d.4.1 Decon supplies 139 - 35 173 173 2d.4.2 Insurance 285 28 313 313 2d.4.3 Property taxes - 599 60 659 659 2d.4.4 Health physics supples 482 - 120 602 602 21.4.5 Heavy equipment rental 1,290 - - - 193 1,483 1,483 2d.4.6 Oispe1 of DAWgenerated . 30 19 135 - 40 223 223 1.980 39,595 72 2d.4.7 Plant energy budget 714 107 822 822 2d,48 NRC Fees 315 31 346 346 2d.4.9 Emergency Planning Fees 70 7 77 - 77 2d.4. 10 Liquid Radwasta Processlng Equipment/Services 262 39 301 301 2d.4.11 ISFSIOperating Costs 30 5 35 - 35 2d.4.12 Security Staff Coot 2,655 398 3,053 3,053 48,450 2d.4.13 DOC Staff Coot 5.684 853 6,536 6,536 72,857 21.4 14 ULiltyStaff Cost 8.439 1,266 9,706 9,705 - 139,157 2d.4 Subtotal Period 2d Period-Dependent Costs 139 1,772 30 19 135 19,053 3,183 24.329 24.218 112 1.980 39.595 72 260,464 21.0 TOTAL PERIOD2d COST 1,250 4,757 255 356 1.898 608 19,280 4,989 33,393 33,020 373 23.046 5.326 1,297,688 66,231 280,464 PERIOD 2S - Licerme Termination Period 2e Direct Deoommissioning Activies 2e. 11 ORISE confirmatorysurvey . . . - - 148 44 193 193 2e 1.2 Tenninate license a 2e. 1 Subtotal Period 2e ActiviyCosts 148 44 193 193 Period 2e Additional Costs 2e 2.1 LicenseTernnnaton Survey 5,916 1,775 7.691 7.691 111.889 2e.2 Subtotal Period 2e AdditionalCosts 5,916 1,775 7,691 7.691 111.889 Period 2e Collateral Costs 2e.3 1 DOC staff relocaton expenses 912 137 1,049 1.049 2e.32 Spent Fuel Capital and Transfer 184 28 211 - 211 2e.3 Subtotal Period 2e Collateral Costs 1,096 164 1,261 1,049 211 Period 2e Period-Dependernt Costs 2e4 1 Insurance 274 27 301 301 2e.42 Properlty taxes . 641 64 705 705 2e.4.3 Health physics supplies 636 - - - 159 795 795 2e.4.4 Disposal of DAWgenerated 5 3 24 - 7 40 40 352 7,046 13 2e.4.5 Plant energy budget 382 57 440 440 2e.4.6 NRC Fees 352 35 388 388 2e.4.7 Emergency Planning Fees 75 7 82 82 2e.4.8 ISFSIOperating Costs 33 5 37 - 37 2e.4.9 Security Staff Cost -2786 418 3,203 3.203 50,700 2e.4.10 DOC Staff Cost 4,604 691 5,294 5,294 56,940 2e.4.11 irtyStaff Cost 5,236 785 6,022 6,022 - 80,340 2e.4 Subtotal Period 2e Period-DependrentCosts 636 5 3 24 14.382 2,256 17,307 17,188 120 352 7,046 13 187,980 2e.0 TOTAL PERIOD2e COST 636 5 3 24 21.543 4,240 26.452 26,121 331 352 7,046 111,902 187,980 PERIOD 2 TOTALS 7.494 47.823 14,687 5.750 12,500 23.778 341,346 .82.997 536.375 433,957 97.666 4.753 156.555 66.130 1.904 918 11.850,600 740,542 3.562.393 TLG Services, aIn.

Prairie Isanad Nuclear Generating Station Doeoosea XOI-1.586-OM, Be'. 0 Diecoesesasioning Cand Analyijsl Appendix 4i Page 19 ofj21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Ont-Smte LLRW NRC Spent Fuel Site Procas Bural Volumes BurialI Utilityand Activity Deon Removal Packaging Transpost Processing Disposal OUter Total Total Uc. Tem ManagementRestaration Volume Class A Class B Class C GTCC Processed Craft Contractor lnds Actlvit Desciption Cost Cost Costs Costs Costs Costs Costs Coatis Costs Costs Costs Costs Cu. Feet Cu. Fast Cu. Feet Cu. Feet Cs. Feet Wt.,Lbs Manhours Manhours PERIOD 3b - Site Restoration Period 3b Diect Decortmissuning Actmvres Demolition of Remaining Site Buildings 3b.1.1 1 Reactor 4,992 749 5,740 5,740 66,359 31b.112 AuWilary 3.223 483 3,706 3.706 44.627 13 2 14 14 193 3b 1 1.3 Condensate Storage Tank Foundation 31b1.1.4 Construcion Warehouse &Fab Shop 141 21 162 162 2,477 24 4 27 27 371 31b1.1.5 D3lD4 Emergency Generator 20 3 24 24 361 3b.1.1.6 Drum Transfer &Truck Loading Endosure .153 3b.1.1.7 Hydrogen House 10 2 12 12 188 28 216. 216 2,776 3b.1.1.8 LLRWStorage Enclosure 3b.1.1.9 Radaste 253 38 291 291 3.555 4 28 28 383 3b.11.10 Resi Disposal 24 3 *0 4 4 54 3b.1.1.11 Soturic Acd Tank Enclo*ure 3b.1.1,12 Turbine 2,266 340 2.606 2,606 34.352 6815 788 7.580 3b11.1.13 Turbine Pedestal 103 768 28 4 32 32 457 3b1,1144Warehouse 02 11 2 12 12 165 3b, I1.15 Waste Neutralizing Tank House 14 2 16 16 225 3b.1.1.16 Waste O Storage 433 65 498 498 6.498 3b.1.1.17 Water Treat ment 1,633 245 1,877 1,877 21.027 3b,1.1.18 Fuel Handling of Am Building 13.959 2.094 16,052 16,052 191,613 3b.1.1 Totals Saie Closeout Actvites 1,599 240 1,838 1,838 10,653 3b.1.2 Remove Rubble

• 126 19 145 - 145 316 3b,1.3 Grade &landscape site 72 11 83 83 668 3b.1.4 Final report to NRC 3b.1 Subtotal Period 3b Ac-tiity Costs 15.684 72 2.363 18.119 83 18,036 202,582 668 Period 3b Additina Costs 509 5 76 591 591 2.731 31,21 Concrete Crusnhin 3b.2 Subtotal Perod 3b Additional Costs 509 5 76 591 591 Z731 Period 3b Colateral Costs 3b.3.1 Small ed aloweance 171 26 197 - 197 3b,.32 Spent Fuel Capital and Transfer 397 so 456 456 -

171 397 85 653 456 197 31b.3 Subtotal Period 35 Collateral Costs Period 3b Period-Dependent Costs 31b4.1 Insurance 847 85 932 932 3b.4.2 Property tbas 153 15 168 168 5736 31b,4,3 Heavy equipment rental 859 6,585 -

3b.4.4 Plant energy budget 592 89 681 0 2D4 476 - -

3b.4.5 . NRC ISFSI Fees 294 29 323 323 3b.4,6 Emergergcy Planrmg Fees 231 23 254 254 101 15 116 116 3b54,7 ISFS0Operating Casts 4,458 669 5.127 0 4,204 923 81.506 3b.4.8 Secuity Stan Cost 13,590 2.039 15,629 15,629 - - 164,171 3b.4.9 DOCStaff Cost 8,664 1,300 9.963 0 5,779 131,579 34.10 uSity Staff Cost 5,726 28,930 5,122 39.779 0 11.981 27.798 377.256 3b.4 Subtotal Period 3b Period-Depencent Costs 22,090 12.437 46,621 205,313 377.924 3b.0 TOTAL PERIOD 3b COST 29.405 7.647 59,142 83 T=03 Sen*re zoo.

PrairieladndNues, GeneratingSation Doiennae XO-1l5S0-0, Rev. 0 Deemnan.niaoaning Coat A*ael-i. Appendi- C, Page 20 of21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

E ott-,ite LLRW NRC Spent Fuel SR. P-rocessed Burial Volumes - uorial I Utiliy and Pakagilng Other Total Total Uic. Term. Management RestoratIon Volume Class A Class B Class C GTCC Processed Crat5 ContractorI O

IActivity I*v A*vJ* *ln*

Decon Cast Reroat rCsta costs Transport Costs Processing t

Disposa cos - Ct - fre cots costs e cots cos. Cu, Fast Cu Feet Cu Feel Cu Feet Co Feet Wt Lb. Manhours Manhours I Activity M Penn, PERIOD 3c - Fuea Storage OperafioesiShIpplng Period 3c Direct Deonnmissioning Actvites Period 3c Collateral Costs 3cX3.1 Spent Fuel Capital and Transfer 2,263 339 2,602 2,602 3c.3 Subtotal Period 3c Collateral Costs 2,263 339 2,602 2,602 -

Period 3c Period-Dependern Costs 3c.4.1 Insurance 7,446 745 8.191 8,191 -

3c.4.2 Property taxes 1,346 135 1,480 1,480 3c.4.3 Plant energy budget 1,560 234 1,794 1,794 3c.4.4 NRC ISFSIFees 2,582 258 2.840 2,840 3c.4.5 Emergency Planning Fees 2,033 203 2,236 2,236 3cW4S ISFS Operating Costs 885 133 1.018 1,018 32,189 4,828 37,017 37,017 572,786 3C.4.7 Security Staff Coast 9,026 1,355 10,392 10,392 143,409 3C.4,8 Utity Staff Cost 57,077 7,891 64.968 64,968 716,194 3&4 Subtotal Period 3c Period-Dependent Costs 59,339 8,231 67,570 67.570 716,194 3c.0 TOTAL PERIOD3c COST PERIOD 3d -GTCC shipping Period 3d Direct Deosmmissioning AcvitSes Nuclear Steam Supply System Renroval 3d.1.1.1 Vessel & Internals GTCC Disposal 209 - 8,951 1.363 10,514 10,514 512 105,595 250 8,951 1,363 10,514 10,514 512 - 105,595 3d.1.1 Totals 255 8,951 1,363 10,514 10.514 512 105,595 3d.1 Sulbotal Period 3d Adctity Costs Period 3d Period Dependent Costs 3M.4.1 Insurnce 31 3 34 34 3d.4.2 Property taxes 6 1 6 6 3d.4.3 PMantenergy biudget 7 1 7 7 3M.4.4 NRC ISFSI Fees 11 1 12 12 3d.4.5 Emergency Planning Fees - - 8 1 9 - 9 3d.4.6 ISFS Operating Costs 4 1 4 4 134 20 155 155 2,391 3d.4.7 Security Staff Cost UtilityStaff Cost 38 6 43 43 599 3d.4.8 3d.4 Subtotal Period 3d Period-Dependent Costs 238 33 271 271 2,990 200 8,951 238 1,396 10,785 10,514 271 512 105,595 2,990 3d.0 TOTAL PERIOD 3d COST PERIOD 3e - ISFSJDecontandrulon Period 3e Direct Deosmrnssioning Actvites Period 3e Additional Costs 3e.2 1 ISFSI ULoense Terrinration (TN-40) 5 317 177 3,271 827 1,001 5,598 5,598 31,862 6,426,376 2,909 1.120 5 317 177 3,271 827 1,001 5,598 5,598 31,862 6,426,376 2,909 1,120 3e.2 Subtotal Period 3a AdditionalCosts Pesod 3e Period-Dependent Costs 3e.4,1 Insurance -. - 121 12 133 133 3e.4.2 Property taxes 22 2 24 24 3e.4.3 Heavy eqwipmret rental 244 37 281 281 3e.4.4 Plant energy budget 85 13 97 97 3e.4.5 NRC ISFSI Fees - - - 33 3 36 36 TLG Services, Ine.

Prairie IslandNodoor Generating Station DaesmenteX01-1586-002, Be.. 0 Deceommissioning CodgAnaleisi. Appendiov Cý Page 21 of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

I Docon Removal Packaging Transport Processing Disposal Other Total Total UC. Term. Management Restoratlon Volume Class A Clahn B Class C GTCC Processed Craft Contractor IActity Ct CP1t C-.b C-*t Ct. t,... Coot. C b, C-oto . ot. Coot. Cu Foot C,, Foo Cu Fot Cu-Fot Cu Fot Wet.b. Maohor. MnhS I Period 3e Period-Dependent Costs (continued) 3e.4.6 Security Staff Cost 146 22 167 167 2,510 30.4.7 Utilty Staff Cost 119 18 137 137 1,901 3e.4 Suteotal Period 3e Period-Dependent Costs 244 525 107 876 876 4,411 3c0( TOTALPERIOD 3e COST 249 317 177 3.271 1,353 1,108 6,474 6,474 31.862 6,426.376 2,009 5,531 PERIOD 3I.NISFS Site Restoretln Period 3f Direct DecommissiosingActivities Period 3f Addtion'alCosts 31.211 ISFSI Demolition S Site Restoration (TN-40) 372 - - 23 59 454 454 -- - - - 1,591 80 31.2 Subtotat Period 3/Addtiafnal Costs 372 23 59 454 454 - . - - 1,591 s0 Period 3f Colsateal Costs 31.3.1 Smat tool allovance 1 0 1 - 454 31.3 Subtotal Period 3f Ctlateral Costs 0 1 Period 3f Period-Dependent Costs 3f.4.1 Insurance 31.4.2 Property taxes 11 1 12 12 3t.4.3 Heavy equipment rental 81 12 94 94 31.4.4 Plant energy budget -43 6 49 49 374.5 Security Staff Cost 73 11 94 84 1,265 31.4.6 UtilityStaff Cost - 49 7 57 57 784 3t.4 Subtotal Period 3f Perod-Dependent Costs 81 177 38 296 296 2,050 3t.0 TOTAL PERIOD3f COST 455 199 98 752 752 1.591 2,130 PERIOD 3 TOTALS 22.794 517 177 - 12,222 90,535 16.479 144,723 10,597 87.505 46,621 - 31,862 512 6.531,971 209,813 1,104.769 TOTALCOST TO DECOMMISSION 10,067 74.450 15.270 6,320 13,.08 38,172 519,443 116.,64 793,B94 537,983 203.961 51.950 156,555 111,901 2.469 819 512 18.640,480 970,260 5,517,691 TOTALCOST TO DECOMMISSIONWITH17.23% CONTINGENCY: 6793*94 thousands of 2008 dollars TOTALNRC LICENSE TERMINATIONCOST IS 67.TT%OR: $037,983 theosands of 2008 dollars SPENTFUEL MANAGEMENTCOST IS 25.69% OR: 9203.961 ttlousands of 2008 dollar NON-NUCLEARDEMOLITIONCOST IS 6.54% OR: $51.950 thousands of 2068dollars TOTALLOW-LEVELRADIOACTIVEWASTE VOLUME BURIED(EXCLUDING GTCC): 115= cubic fast OTAL GREATER THANCLASS C RADWASTEVOLUME GENERATED 512 cubic faet OTAL SCRAP METALREMOVED: 34,995 tons IOTALCRAFT LABORREQUIREMENTS: 970.35 man-hours End Notes:

n/a - indicates that Itis activitynot charged as decomminssioningexpense.

a - indicates Stattims actrity performed by deosniansiosing staff.

0- indicates tat Otisvalue is less than 0.5 but is mn-ozes.

a cellocntaining - intdicates a zero value ThG ts-&cea, rboo.