ML030930548

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PGE-1061, Trojan Nuclear Plant Decommissioning Plan & License Termination Plan (PGE-1078), Revision 16
ML030930548
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 03/27/2003
From: Quennoz S
Portland General Electric Co
To:
Document Control Desk, NRC/FSME
References
+sunsi/sispmjr=200603, -RFPFR, PGE-1078, VPN-022-2003
Download: ML030930548 (19)


Text

PG Portland General Electric Company Trojan Nuclear Plant 71760 Columbia River Hzvy Rainier, OR 97048 March 27, 2003 (503) 556-3713 VPN-022-2003 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 PGE-1061, "Trojan Nuclear Plant Decommissioning Plan and License Termination Plan (PGE-1078)," Revision 16 The Enclosure to this letter provides Revision 16 to Portland General Electric Company's PGE-1061, "Trojan Nuclear Plant Decommissioning Plan and License Termination Plan (PGE-1078)." The Decommissioning Cost Estimate and Funding Plan in Section 5 are updated to include actual expenditures during 2002 and adjustments based on work performed and projected work schedules. Sections 1, 2, and 4 are revised to reflect current projected work schedules for decommissioning and site restoration. The changes were evaluated and determined to not require prior NRC approval pursuant to 10 CFR 50.59.

Revised portions of the Decommissioning Plan and License Termination Plan are denoted by sidebars.

Any questions concerning this revision can be directed to Mr. Lansing G. Dusek, of my staff, at (503) 556-7409.

Sincerely, Stephen M. Quennoz Vice President, Power Supply/Generation Enclosure fn550 \

c: Director, NRC, Region IV, DNMS S. W. Brown, NRC, NMSS, DWM D. Stewart-Smith, OOE A. Bless, OOE

/4S~ ~~I W$l$lA Connecting People, Power and Possibilities 0

PGE-1061, "Trojan Nuclear Plant Decommissioning Plan and License Termination Plan (PGE-1078)"

Revision 16 Pages to your Controlled Copy of PGE-1061, "Trojan Nuclear Plant Decommissioning Plan and License Termination Plan (PGE-1078)," are to be replaced as indicated below:

Remove Insert Pages xiv and xv Pages xiv and xv Pages 1-3 and 1-4 Pages 1-3 and 1-4 Page 2-2 Page 2-2 Page 4-24 Page 4-24 Page 5-1 Page 5-1 Page 5-3 Page 5-3 Pages 5-6 through 5-8 Pages 5-6 through 5-8 Tables 5-1 through 5-6 Table 5-1 through 5-6

TROJANDECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN LIST OF EFFECTIVE PAGES Section/Page Revised Date Revision Number Title Page March 2001 Revision 9 Pages i and ii March 2001 Revision 9 Pages iii through v March 2002 Revision 13 Page vi March 2001 Revision 9 Page vii October 2002 Revision 14 Page viii March 2002 Revision 13 Pages ix through xii March 2001 Revision 9 Page xiii March 2002 Revision 13 Pages xiv and xv March 2003 Revision 16 Page xvi October 2002 Revision 15 Section 1 Pages 1-1 and 1-2 March 2001 Revision 9 Pages 1-3 and 1-4 March 2003 Revision 16 Pages 1-5 through 1-10 March 2001 Revision 9 Section 2 Page 2-1 March 2001 Revision 9 Page 2-2 March 2003 Revision 16 Pages 2-3 through 2-14 March 2001 Revision 9 Page 2-15 March 2002 Revision 13 Pages 2-16 through 2-24 March 2001 Revision 9 Page 2-25 March 2002 Revision 13 Pages 2-26 and 2-27 March 2001 Revision 9 Page 2-28 March 2002 Revision 13 Page 2-29 October 2002 Revision 15 Page 2-30 March 2001 Revision 9 Pages 2-31 through 2-37 October 2001 Revision 12 Table 2-1 March 2001 Revision 9 Table 2-2 March 2002 Revision 13 Table 2-3 October 2002 Revision 15 Table 2-4 March 2001 Revision 9 Figures 2-1 through 2-9 March 2001 Revision 9 Figure 2-10 October 2001 Revision 12 Figure 2-11 March 2001 Revision 9 Section 3 Pages 3-1 and 3-2 March 2001 Revision 9 Pages 3-3 through 3-5 October 2002 Revision 14 Pages 3-6 through 3-10 March 2001 Revision 9 Pages 3-11 through 3-13 March 2002 Revision 13 Page 3-14 October 2002 Revision 15 xiv Revision 16

TROJANDECOMMISSIONING PLAN AND LICENSE TERMINATIONPLAN LIST OF EFFECTIVE PAGES (Continued)

Section/Page Revised Date Revision Number Pages 3-15 through 3-29 March 2002 Revision 13 Page 3-30 October 2002 Revision 15 Pages 3-31 through 3-58 March 2002 Revision 13 Appendices 3-1 and 3-2 March 2001 Revision 9 Tables 3-1 through 3-9 March 2001 Revision 9 Figures 3-1 through 3-37 March 2001 Revision 9 Figure 3-38 March 2002 Revision 13 Section 4 Pages 4-1 through 4-3 March 2002 Revision 13 Pages 4-4 through 4-6 March 2001 Revision 9 Page 4-7 October 2002 Revision 14 Pages 4-8 through 4-10 March 2001 Revision 9 Page 4-11 March 2002 Revision 13 Page 4-12 March 2001 Revision 9 Pages 4-13 through 4-23 October 2002 Revision 14 Page 4-24 March 2003 Revision 16 Pages 4-25 and 4-26 March 2002 Revision 13 Pages 4-27 and 4-28 October 2002 Revision 14 Pages 4-29 and 4-30 March 2002 Revision 13 Page 4-31 March 2001 Revision 9 Pages 4-32 through 4-49 March 2002 Revision 13 Pages 4-50 through 4-52 March 2001 Revision 9 Pages 4-53 through 4-56 March 2002 Revision 13 Pages 4-57 and 4-58 October 2002 Revision 14 Page 4-59 March 2001 Revision 9 Appendix 4-1, Page 1 March 2002 Revision 13 Appendix 4-1, Page 2 March 2001 Revision 9 Appendix 4-1, Page 3 March 2002 Revision 13 Appendices 4-2 and 4-3 March 2001 Revision 9 Tables 4-1 and 4-2 March 2001 Revision 9 Table 4-3 March 2002 Revision 13 Tables 4-4 through 4-9 March 2001 Revision 9 Section 5 Page 5-1 March 2003 Revision 16 Page 5-2 March 29, 2001 Revision 10 Page 5-3 March 2003 Revision 16 Page 5-4 March 29, 2001 Revision 10 Page 5-5 March 2001 Revision 9 Pages 5-6 through 5-8 March 2003 Revision 16 Page 5-9 March 2001 Revision 9 Tables 5-1 through 5-6 March 2003 Revision 16 xv Revision 16

TROJANDECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN 1.3

SUMMARY

OF MAJOR ACTIVITIES AND SCHEDULE TNP decommissioning is divided into two broad periods: a Transition Period and a Decontamination and Dismantlement Period. Decommissioning will be followed by site restoration. This section provides a brief description of these activities. Details are provided in Sections 2.2 and 2.3.

1.

3.1 DESCRIPTION

OF MAJOR ACTIVITIES The Transition Period began with permanent plant shutdown in January 1993 and will continue until spent fuel is transferred to an Independent Spent Fuel Storage Installation (ISFSI). The Decontamination and Dismantlement Period will begin once the spent fuel is transferred to the ISFSI. Site restoration will begin following termination of the 10 CFR 50 license and involves the final disposition of structures, systems, and components.

Storing fuel at TNP during and after plant decommissioning significantly impacts both the process and costs associated with decommissioning. The TNP contract with DOE, "Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste," provides the basis for the schedule forecast in DOE's annual acceptance priority ranking for receipt of spent fuel and/or high level waste. The published schedule specifies the first TNP shipment to be in 2002, and the final shipment is projected for 2018. Recognizing the uncertainty, but with no better formal estimate, the contract dates for fuel shipment are currently being used for planning purposes. The spent fuel management plan is discussed in Section 3.3.

1.3.1.1 Transition Period The Transition Period of TNP decommissioning is nearing completion. PGE continues to maintain systems and components required to support decommissioning and spent fuel storage in accordance with the Facility Operating (Possession Only) License NPF-1 and administrative procedures. The facility currently is maintaining its spent fuel in the spent fuel pool (SFP) and undergoing active decontamination and dismantlement and activities in accordance with the approved TNP DSAR and this Decommissioning Plan and License Termination Plan. Final survey of areas for which remediation has been completed may also begin towards the end of the Transition Period.

Fuel transfer to the ISFSI began in late 2002. The completion of fuel transfer to the ISFSI will allow the removal or decontamination in place of systems and components that support the SFP or wet fuel storage, including the SFP itself.

1.3.1.2 Decontamination and Dismantlement Once the spent fuel is transferred to the ISFSI, the Transition Period ends and the Decontamination and Dismantlement Period begins. Major activities planned during the Decontamination and Dismantlement Period include removing the remaining contaminated 1-3 Revision 16 l

TROJAN DECOMMISSIONING PLANAND LICENSE TERMINATION PLAN systems and components, and continuing the decontamination of structures and final radiation surveys. The final survey, described in Section 4, is performed to demonstrate that radiological conditions at TNP satisfy the final site release criteria of 10 CFR 20.1402 (Reference 1-15) to support unrestricted release of the TNP site and license termination. Upon completion of the final survey, a final survey report will be submitted to the NRC.

Site Restoration Nonradiological site remediation activities are scheduled to be completed following termination of the Facility Operating (Possession Only) License NPF-1. The primary nonradiological site remediation effort is scheduled to begin around 2018 and conclude in 2019. Some site restoration activities have been completed, and some may continue to be conducted during the Transition and Decontamination and Dismantlement Periods of decommissioning.

A listing and schedule of remaining major license termination activities is provided in Sections 2.2 and 2.3. According to this schedule, PGE anticipates the completion of decommissioning activities, including the final survey and license termination, by mid 2005.

1.3.2 FINAL RELEASE CRITERIA TNP decommissioning will safely reduce radioactivity at the site to levels meeting the unrestricted release criteria of 10 CFR 20.1402. The TNP final survey plan provided in Section 4 describes the scope and methodology of the final survey process, quality assurance measures, access control procedures, and how implementation of the plan will demonstrate that the plant and site will meet the 10 CFR 20.1402 criteria for unrestricted release of the site.

1.3.3 SCHEDULE FOR DECOMMISSIONING/SITE RESTORATION ACTIVITIES A detailed schedule for decommissioning/site restoration activities is discussed in Section 2.2.

The following is an overview of the current TNP decommissioning/site restoration project schedule.

January 1993 - Mid 2003 Transition Period Late 1994 - Late 1995 Large Component Removal Project Late 1996 - Mid 2002 Complete planning/building an ISFSI Early 1997 - Late 1999 Reactor Vessel and Internals Removal Late 2002 - Late 2003 Transfer spent nuclear fuel to the ISFSI Late 2003 - Mid 2005 Decontamination and Dismantlement Period Early 2005 Complete final radiation survey Early 2005 Submit application for license termination Mid 2005 License Termination Mid 2005 - Mid 2018 Caretaking Mid 2018 - Late 2019 Demolish buildings 1-4 Revision 16

TROJANDECOMMISSIONING PLANAND LICENSE TERMINATIONPLAN 2.2 DECOMMISSIONING ACTIVITIES, TASKS. AND SCHEDULES 2.

2.1 INTRODUCTION

In accordance with 10 CFR 50.82(a)(9)(ii)(B), this section identifies the major dismantlement and decontamination activities that remain at TNP as of early-I 999. This information details those areas and equipment that need further remediation to allow an estimation of the radiological conditions that may be encountered during remediation. Included herein are schedules for implementation of decommissioning and dismantlement activities, estimates of associated occupational radiation dose, and projected volumes of radioactive waste.

TNP decommissioning is divided into two broad periods: a Transition Period and a Decontamination and Dismantlement Period. Figure 2-11 illustrates how these periods are incorporated into the overall decommissioning schedule. This schedule was used in the preparation of the decommissioning cost estimate and funding plan discussed in Section 5. More detailed scheduling is prepared as part of pre-job planning.

The Transition Period began with permanent plant closure in January 1993 and will continue until the spent fuel is transferred to the ISFSI. Decontamination and dismantlement of the remaining facility radioactive systems, components, and structures are scheduled to be conducted upon completion of the transfer of spent fuel to the ISFSI, which is currently scheduled for around late 2003. Some decontamination and dismantlement activities have occurred and will continue to occur during the Transition Period. Major activities completed or planned during the Transition Period are described in Section 0.

Following the Transition Period, the remaining decontamination and dismantlement activities are expected to last from late 2003 through mid 2005. Major activities planned during the Decontamination and Dismantlement Period are discussed in Section 2.2.2.

Nonradiological site restoration activities involving the final disposition of structures, systems, and components are scheduled to be completed following the termination of Facility Operating (Possession Only) License NPF-1. Some site restoration activities have been completed and others may continue to be conducted during the Transition and Decontamination and Dismantlement Periods.

2.2.2 TRANSITION PERIOD Plant closure activities were initiated following the decision to permanently cease TNP power operations in January 1993. These activities culminated with the plant in a safe transition state awaiting decontamination and dismantlement. Detailed project planning and engineering activities for the Decontamination and Dismantlement Period, as discussed in Section 2.2.2.2, will continue during the Transition Period. Plant activities will continue to be implemented in compliance with the existing possession-only license and other regulatory requirements.

2-2 Revision 16

TROJAN DECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN

1. Overview and objectives of this plan;
2. Procedures governing the conduct of the final survey;
3. Operation of the appropriate field and laboratory instrumentation;
4. Collection of final survey measurements and samples; and
5. Survey data evaluation.

The extent of training and qualifications is commensurate with the education, experience, and proficiency of the individual and the scope, complexity, and nature of the activity. Records of training are maintained in accordance with approved plant procedures.

4.2.6.7 Schedule Final survey activities are planned, scheduled, and tracked as a part of the overall decommissioning planning process. The schedule is dependent upon the progress and completion of several decommissioning activities. Presently, survey data collection is estimated to be completed in early 2005. Final survey activities are planned and discussed with the NRC and the OOE sufficiently in advance to allow the scheduling of inspection activities.

4-24 Revision 16

TROJANDECOMMISSIONING PLANAND LICENSE TERMINATION PLAN

5. UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS In accordance with Paragraphs (a)(4) and (a)(9)(ii)(F) of 10 CFR 50.82 (Reference 5-1), and consistent with the guidance of Regulatory Guide 1.179 (Reference 5-2), the TNP-specific cost estimate and funding plan as incorporated into this section provides:
1. An updated estimate of total and remaining TNP decommissioning costs;
2. A comparison of the estimated costs with present funds set aside for decommissioning; and
3. The plan for assuring the availability of adequate funds for completion of decommissioning and release of the TNP site for unrestricted use.

5.1 DECOMMISSIONING COST ESTIMATE This section provides the results of and basis for a cost estimate prepared by PGE with assistance from TLG for the decommissioning of TNP. Incorporated into this cost estimate are costs of activities involved in radiological decommissioning necessary for termination of TNP's Part 50 license, as well as expenditures necessary to complete nonradiological site restoration activities.

The costs of removal and disposal of nonradioactive structures and materials beyond that necessary for license termination have been identified separately from radiological decommissioning costs.

Also separately identified are cost projections and funding requirements for the onsite management of irradiated fuel until possession and title of the irradiated fuel is transferred to DOE for ultimate disposal. The description of the spent fuel management costs and associated funding plan provided in this section, together with the description of the spent fuel management program in Section 3.3.1, fulfill the requirements of 10 CFR 50.54(bb).

5.1.1 COST ESTIMATE RESULTS Summarizing the results of the TNP cost estimate, Table 5-1 provides estimates of total decommissioning costs as well as decommissioning costs that remain as of January 1, 2003. As indicated in Table 5-1, the costs (in 1997 dollars) for the selected decommissioning alternative are estimated to total approximately $238,957,000 for radiological decommissioning activities, approximately $42,263,000 for nonradiological decommissioning activities (site restoration), and approximately $146,985,000 for dry spent fuel storage. Costs associated with securing and maintaining decommissioning financial assurance and bridging funds are projected to total approximately $1,514,000. A detailed schedule of TNP's decommissioning and spent fuel management costs, totaling approximately $429,719,000 of decommissioning fund-related expenditures, is provided in Table 5-2 and described in Section 5.1.2.

5.1.2 COST ESTIMATE DESCRIPTION The initial Decommissioning Plan decommissioning cost estimate was based largely on the TNP-specific cost estimate performed for PGE by TLG Services, Inc. in May 1994. The methodology used to develop the cost estimate followed the approach presented in 5-1 Revision 16

TROJANDECOMMISSIONING PLANAND LICENSE TERMINATION PLAN Decommissioning Plan and License Termination Plan are submitted for reimbursement from the decommissioning trust. Periodically, variances between the estimate and actual costs will be KU reviewed as they relate to the total cost estimate to provide assurance that the cost estimate continues to be reasonable. This complies with 10 CFR 50.82(a)(8)(i)(A). In addition, PGE corporate finance personnel review the TNP co-owners' trust fund activity and balance periodically, as applicable. Any significant activity which is inconsistent with this Decommissioning Plan and License Termination Plan would be brought to the attention of TNP management.

The decommissioning cost estimate reflects costs in 1997 dollars, and has been updated to account for work performed through 2002 where TNP expended funds for decommissioning activities. The decommissioning cost estimate reflects updated staffing requirements and work/activity schedules, remaining scheduled decommissioning equipment removal efforts, and adjustments for radioactive waste disposal volumes and costs.

Costs required to maintain spent fuel in a safe storage condition are funded by Operation and Maintenance (O&M) funds rather than by decommissioning funds while the spent fuel remains in wet storage. Once the spent fuel is transferred to dry storage, there are sufficient decommissioning fund annual contributions to cover annual costs. This is described in Sections 5.2 and 5.3.2 and Table 5-2. This complies with 10 CFR 50.82(a)(8)(i)(B).

In accordance with 10 CFR 50.82(a)(8)(i)(C) and 10 CFR 50.75(e) (Reference 5-5), the TNP co-owners periodically assess the financial assurance amount required to complete radiological decommissioning. The established financial assurance mechanisms (e.g., external trust fund and/or letter of credit) are adjusted as necessary to ensure the completion of radiological decommissioning. Financial assurance is described in Section 5.3. "Bridge" funds are also described in Section 5.3.

5.1.2.2 Nonradiological Decommissioning Costs Although not required by NRC regulations, the decommissioning cost estimate for TNP incorporates nonradiological decommissioning costs, as indicated in Table 5-2. The TNP decommissioning cost estimate considers nonradiological decommissioning costs to be those costs associated with site remediation and demolition and removal of uncontaminated structures.

The decommissioning cost estimate does not include in nonradiological decommissioning costs those costs associated with spent fuel management or radiological decommissioning activities.

5.1.2.3 Spent Fuel Management Costs Implementation costs associated with spent fuel management are reflected in the projected cost schedule for the onsite management of irradiated fuel detailed in Table 5-2. Spent fuel management costs begin with ongoing spent fuel pool operation, surveillance, and maintenance activity costs, and continue through ISFSI planning, construction, and operation until possession and title of the irradiated fuel is transferred to the DOE for ultimate disposal (assumed in this estimate to be completed in 2018). As indicated in Table 5-2, spent fuel pool operation expenditures are projected to end upon transfer of the spent fuel pool contents to the ISFSI.

Costs associated with onsite management of the spent fuel will then involve ISFSI operation, maintenance, and surveillance expenditures. Finally, upon transfer of the ISFSI contents to an 5-3 Revision 16

TROJAN DECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN

5.3 DECOMMISSIONING FUNDING

PLAN 5.3.1 CURRENT DECOMMISSIONING FUNDING CAPABILITIES Each of the TNP co-owners separately collect through rates the funds for the decommissioning of TNP and the Trojan ISFSI. PGE and PP&L deposit these funds in external trust funds in accordance with 10 CFR 50.75(e), while the BPA provides EWEB's portion of TNP and Trojan ISFSI decommissioning funds as necessary as described in Section 5.3.2.2. Because the TNP was shut down prematurely, the external trust funds established by PGE and PP&L currently contain only a portion of the total amount needed for site radiological decommissioning.

Table 5-3 summarizes the status of PGE's and PP&L's decommissioning trust funds as of December 31, 2002.

The NRC's general policy requires, prior to the start of the Decontamination and Dismantlement Period, either funds needed for decommissioning (as the term "decommission" is defined in 10 CFR 50.2, "Definitions") to be available or an appropriate financial vehicle to be secured and maintained that will assure the availability of adequate funds for completion of radiological decommissioning. As indicated above, the trusts established by PGE and PP&L for decommissioning will not contain the funds necessary for completion of radiological decommissioning prior to the start of the Decontamination and Dismantlement Period. Thus prior to commencing this period, PGE and PP&L are required to secure an additional financial assurance mechanism allowed by 10 CFR 50.75(e). This financial assurance must be maintained until termination of TNP's Part 50 license. Furthermore, during the Decontamination and Dismantlement Period, a decommissioning trust fund balance may be reduced to a point where it will be necessary in certain instances to borrow or otherwise provide "bridging" funds to complete decontamination activities and allow scheduled collections to restore the decommissioning trust fund balance.

5.3.2 TNP CO-OWNERS' DECOMMISSIONING FUNDING PLANS Each of the TNP co-owners has established a program in conjunction with specified goals for the collection of funds for the decommissioning of TNP. Each TNP co-owner maintains a decommissioning fund collection schedule which ensures that each co-owner's portion of the decommissioning activity expenditures will be fully funded. These funding schedules are based on funding requirements for both radiological and nonradiological decommissioning costs, as well as financing costs and specific spent fuel management costs including planning, design, construction, O&M, and decommissioning of an ISFSI. These collection schedules do not include funding for spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning funds. The decommissioning funding cash flow for each of the TNP co-owners, based on the expenditure schedule in Table 5-2 and the co-owner contribution schedules, is described below.

5.3.2.1 PGE Funding Table 5-4 provides PGE's decommissioning funding cash flow in nominal dollars (2.79% escalation) during decommissioning. Funded from an external trust fund, the expenditures described in this table are PGE's share (67.5%) of the expenditures described in Table 5-2, with the exception of spent fuel pool O&M costs since these costs are being paid with 5-6 Revision 16

TROJAN DECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN O&M budget funds rather than decommissioning funds. The funding schedule described in Table 5-4 ensures that PGE's portion of the decommissioning activity expenditures will be fully funded.

Projected requirements for bridging funds have been incorporated into PGE's decommissioning funding cash flow. As previously discussed, PGE's external trust fund currently contains only a portion of the total amount needed for PGE's share of site radiological decommissioning costs.

Based on the decommissioning fund cash flow analysis presented in Table 5-4, bridging funds are anticipated to be required in the year 2004 to complete decontamination activities and allow scheduled collections to restore the decommissioning trust fund balance. Projected interest on bridging funds has been incorporated into PGE's decommissioning funding cash flow as indicated in Table 5-4.

In addition, because the trust established for decommissioning will not contain the funds necessary for completion of radiological decommissioning prior to the start of the Decontamination and Dismantlement Period, PGE must secure an additional financial assurance mechanism allowed by 10 CFR 50.75, and maintain this assurance until termination of TNP's Part 50 license. Therefore, upon commencement of the Decontamination and Dismantlement Period, PGE's financial assurance mechanism will consist of the decommissioning trust fund balance together with a letter of credit. Because financial assurance will be maintained only for radiological decommissioning activities, the methodology used to determine the size of the letter of credit ensures that if a given amount of the decommissioning trust fund is used for purposes other than radiological decommissioning activities during a current year, the portion of the financial assurance provided by the letter of credit must be increased by the same amount. This methodology can be summarized as follows:

Lfa= TI - T2 + T3 where L& = Letter of Credit Portion of Financial Assurance Needed for Current Year T1 = Total costs of remaining radiological decommissioning activities T2 = Current decommissioning trust fund balance T3 = Portion of trust balance planned for non-radiological costs during current year Financial assurance for remaining radiological decommissioning activities will be calculated at the beginning of each year and will be periodically reviewed during each year to ensure that an adequate level of financial assurance is maintained.

5.3.2.2 EWEB/BPA Funding BPA is obligated through Net Billing Agreements to pay costs associated with EWEB's share of TNP, including decommissioning and spent fuel management costs. BPA fulfills the decommissioning funding obligations of EWEB, including providing financial assurance for EWEB's portion of decommissioning costs in a manner stipulated in 10 CFR 50.75(e)(1)(iv) for Federal government licensees as detailed further below. Table 5-5 provides BPA/EWEB's decommissioning funding cash flow in nominal dollars (2.79% escalation) during decommissioning. The expenditures described in this table are BPA/EWEB's share (30%) of the expenditures described in Table 5-2, with the exception of spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning funds. The funding 5-7 Revision 16

TROJANDECOMMISSIONING PLANAND LICENSE TERMINATION PLAN schedule described in Table 5-5 ensures that BPA/EWEB's portion of the decommissioning activity expenditures will be fully funded.

As allowed by 10 CFR 50.75(e)(1)(iv), BPA, as a Federal government entity fulfilling the decommissioning funding obligations of EWEB, a licensee, provides financial assurance in the form of a statement of intent. The statement of intent contains a reference to the TNP decommissioning cost estimate described in Section 5.1, indicating that funds for radiological decommissioning of the TNP and Trojan ISFSI will be obtained when necessary.

5.3.2.3 PP&L Funding Table 5-6 provides PP&L's decommissioning funding cash flow in nominal dollars (2.79% escalation) during decommissioning. Funded from an external trust fund, the expenditures described in this table are PP&L's share (2.5%) of the expenditures described in Table 5-2, with the exception of spent fuel pool O&M costs since these costs are being paid with O&M budget funds rather than decommissioning funds. The funding schedule described in Table 5-6 ensures that PP&L's portion of the decommissioning activity expenditures will be fully funded.

Based on the decommissioning funding cash flow analysis presented in Table 5-6, PP&L's decommissioning trust balance will remain adequately funded during decommissioning such that bridging funds will not be required. However, because the trust established for decommissioning will not contain the funds necessary for completion of radiological decommissioning prior to the start of the Decontamination and Dismantlement Period, PP&L must secure an additional

_ ) tfinancial assurance mechanism allowed by 10 CFR 50.75, and maintain this assurance until termination of TNP's Part 50 license. Therefore, upon commencement of the Decontamination and Dismantlement Period, PP&L's financial assurance mechanism will consist of the decommissioning trust fund balance together with a letter of credit. The methodology for determining the size of the letter of credit is as described in Section 5.3.2.1, "PGE Funding."

5-8 Revision 16

TROJAN DECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN Table 5-1 Estimate of Decommissioning Costs (1997 dollars)

Total Total Costs (Start-to-Finish) Remaining As of Costs January 1, 2003 l Radiological (NRC) Decommissioning Costs Reactor Vessel and Internals Removal and Disposal 21,495,000 0 Dismantlement, Decontamination, and Remediation 162,828,000 46,837,000 l Waste Disposal 41,878,000 9,059,000 l Final Survey 12,756,000 8,784,000 l Total 238,957,000 64,680,000 Nonradiological Decommissioning Costs Site Restoration 42,263,000 39,253,000 Total 42,263,000 39,253,000 Dry Spent Fuel Management Costs ISFSI Construction and Decommissioning 86,683,000 23,407,000 ISFSI Operation and Maintenance 60,302,000 58,170,000 l Total 146,985,000 81,577,000 l Financing Costs Financial Assurance 209,000 209,000 Decommissioning Bridge Loans 1,305,000 1,305,000 Total 1,514,000 1,514,000 Total Decommissioning Expenditures $ 429,719,000 $ 187,024,000 I Revision 16

TROJAN DECOMMISSIONING PLAN AND LICENSE TERMINATION PLAN Table 5-3 Status of Decommissioning Trust Funds as of December 31, 2002 I Trojan Co-Owner Fund Balance as of 12/31/02 I Portland General Electric (PGE) $27,941 ,OOOa I Eugene Water & Electric (EWEB)! N/Ab Bonneville Power Administration (BPA)

Pacific Power & Light (PP&L) $1,734,000a Total $29,675,000 aThe 2002 end-of-year trust fund balance includes an adjustment for trust expenditures incurred in November and December 2002 that were not paid out of the trust in 2002. I

_ K> b BPA provides decommissioning funding from its operating budget as such funds are needed. Financial assurance is provided by a Statement of Intent, dated March 21, 2001. Therefore, no external trust fund is required.

Revision 16

C CiROJANDECOMMISSIONING PLANAND LICENSE TERMINA TIONQ ,

Table 5-4 Portland General Electric Decommissioning Funding Cash Flow (Nominal $ x 1000)

PGE PGE PGE Bridge Letter of PGE Trust Fund Trust Fund Bridge Funds Letter of Credit Trust Fund Trust Fund Net Earnings EOY Balance Funds Interest Credit Fee Year Expenditures Contributions B C D E F G H A

1996 _ _ _ _ _ _ _ _ _ _ _ __

1997 _ _ _ _ _ _ _ _ _ _ _ __

1998__ _ _ _ _ __

1999 2000 2001 __ _

2002 27,941 14,041 387 10,516 _

2003 (31,853) 14,041 0 0 8,913 314 31,844 (175) 2004 (33,295) 14,041 0 0 (1,530) 651 12,443 (68) 2005 (12,443) 2006 (3,273) 14,041 93 2,513 (8,348) 589 (3,340) 14,041 487 13,112 (589) 41 2007

. (3,277) 14,041 923 24,758 (41) 3 2008 2009 (3,323) 14,041 1,375 36,848 (3) 2010 (3,371) 14,041 1,844 49,362 2011 (3,409) 13,924 2,324 62,201 2012 (3,513) _ 2,265 60,953 2013 (3,602) 2,200 59,551 ,

2014 (3,7031 2,135 57,983 2015 (3,806) 2,071 56,248 _

2016 (3,884) 2,002 54,366 2017 (4,021 _ 1,925 52,270 2018 (33,303) 725 19,692 2019 (19,692) 0 2020 .

2021 .

2022 .

2023)

(173,1-08)[ -126,252 20,756 1,598 __243____

Total ______(1,598) flow out of trust fund.

NOTE 1: Positive numbers indicate cash flow into trust fund; negative numbers indicate cash

+ C + E + H. Revision 16 NOTE 2: Current EOY balance = previous year EOY balance + current year A + B

(l OJAIVDECOMMISSIONING PLANAND LICENSE TERAMINA TION .N 0

Table 5-5 EWEBIBPA Decommissioning Funding Annual Cash Obligations (Nominal $ x 1000)

Eugene Water and Electric Board /

Bonneville Power Administration Year Decommissioning Obligations 1996 1997 1998 1999 2000 2001 2002 2003 14,157 2004 14,798 2005 5,530 2006 1,454 2007 1,485 2008 1,456 2009 1,477 2010 1,498 2011 1,515 2012 1,562 2013 1,601 2014 1,646 2015 1,691 2016 1,727 F 2017 1,787 2018 14,801 2019 8,752 2020 2021 2022 2023 Total 76,937 NOTE 1: BPA provides decommissioning funding from its operating budget as such funds are needed.

Financial assurance is provided by a Statement of Intent, dated March 21, 2001.

Therefore, no external trust fund is required. Revision 16

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Table 5-6 Pacific Power & Light Decommissioning Funding Cash Flow (Nominal $ x 1000)

PP&L Bridge Letter of PP & L I PP &L PP&L Credit Trust Fund Bridge Funds Letter of Trust Fund Trust Fund Trust Fund Fee EOY Balance Funds Interest Credit Year Expenditures Contributions Net Earnings H D E F G A B C l

1996 1997 _ _ _ _ _ _ _ _ _ _ _

1998 1999______

2000 2001 1,734 2002 1,034 2003 (1,179) 438 41 (5) 254 535 2004 (1,232) 438 19 209 (2)

(462) 438 7 235 _

2005 2006 (121) 438 12 564 .-

2007 (124) 438 22 900 (121 438 32 1,249 2008 2009 (123) 438 42 1,606 (125) 438 53 1,972 2010 2011 (126) 437 64 2,347 68 2,285 2012 (130) .

2013 (134) 67 2,218 64 2,145 .

2014 (137) .

2015 (141) 62 2,066 2016 (144) . 60 1,982 2017 (149) 57 1,890 (1,234) 38 694 2018 (704) 10 0 2019 2020 _

22021 ______,_

2023 (7)

Total 6,386 3,941 718 numbers indicate cash flow out of trust fund.

NOTE 1: Positive numbers Indicate cash flow into trust fund; negative + B + C.

Revision 16 NOTE 2: Current EOY balance = previous year EOY balance + current year A