ML050380143

(TMI-2). Use of TMI-2 Decommissioning Trust Fund

ML050380143
Person / Time
Site:	Crane
Issue date:	02/01/2005
From:	Byrne J GPU Nuclear
To:	Document Control Desk, NRC/FSME
References
+sispmjr200504, 5928-05-20049
Download: ML050380143 (124)

Text

GPU Nuclear, Inc.

kG P U Three Mile Island Nuclear Station NUCLEAR Route 441 South Post Office Box 480 Middletown, PA 17057-0480 Tel 717-948-8461 February 1, 2005 1 OCFR50.75/1 OCFR50.82 5928-05-20049 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Possession Only License No. DPR-73 Docket Nos. 50-320

Subject:

Use of TMI-2 Decommissioning Trust Fund Based on discussions with Ms. Kristina Banovac of your staff this letter is being provided to document GPU Nuclear's justification to use the TMI-2 Decommissioning Trust Fund for disposal of three Submerged Demineralizer System (SDS) CUNO-Filters presently stored at the Idaho National Laboratory.

The SDS CUNO-filters were utilized as pre-filters in the SDS. The SDS was used to process the highly contaminated water in the TMI-2 containment basement following the TMI-2 1979 accident. These filters were used with the initial batch of water in 1981 and were replaced by sand filters in later batches. Under a 1982 agreement with the Nuclear Regulatory Commission and the Department of Energy (DOE) GPU Nuclear was able to ship "abnormal" radioactive waste, that is waste not suitable for commercial disposal, from TMI-2 to the DOE for storage, research and ultimate disposal. GPU Nuclear however remained responsible for the disposal costs. With the exception of these three pre-filters all other TMI-2 "abnormal" waste under the GPU Nuclear contract with the DOE have been dispositioned. The DOE is currently completing clean-up of the site on which these filters are stored, and thus disposal of these filters at this time is appropriate.

GPU Nuclear in establishing the TMI-2 Decommissioning Trust Fund recognized that some of the cost of decommissioning TMI-2 is a result of the accident and therefore partially funded the trust fund from GPU, not ratepayer money. These filters were generated as a direct result of accident cleanup and thus are eligible for funding from this source.

The relevant NRC Regulation IOCFR50.82 (aX8) with justification is provided below.

(8)(1) Decommissioning trust funds may be used by licensees if:

A) The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in Sec. 50.2; 10 CFR 50.2 defines decommissioning to mean to remove a facility or site safely from service and reduce residual radioactivity to a level that permits- (1) Release of the property for unrestricted use and termination of the license; or (2) Release of the property under restricted conditions and termination of the license. These filters needed to be removed from site in order to be able to Pk]55

release the site and as they still need to be properly disposed. Therefore funding this disposal from the trust fund is appropriate.

B) The expenditure would not reduce the value of the decommissioning trust below an amount necessary to place and maintain the reactor in a safe storage condition if unforeseen conditions or expenses arise and; TMI-2 is already in a safe storage condition and disposal of these filters is a specific line item in the latest Site Specific Decommissioning Cost Study for TMI-2. Therefore we satisfy this condition.

C) The withdrawals would not inhibit the ability of the licensee to complete funding of any shortfalls in the decommissioning trust needed to ensure the availability of funds to ultimately release the site and terminate the license.

As this item is a specific line item in the cost estimate and represents less than I/l0h of I % of the cost estimate withdrawal of these funds will not inhibit FirstEnergy's ability to fund any shortfalls.

(ii) Initially, 3 percent of the generic amount specified in Sec. 50.75 may be used for decommissioning planning. For licensees that have submitted the certifications required under Sec. 50.82(aXl) and commencing 90 days after the NRC has received the PSDAR, an additional 20 percent may be used. A site-specific decommissioning cost estimate must be submitted to the NRC prior to the licensee using any funding in excess of these amounts.

(iii) Within 2 years following permanent cessation of operations, if not already submitted, the licensee shall submit a site-specific decommissioning cost estimate.

(iv) For decommissioning activities that delay completion of decommissioning by including a period of storage or surveillance, the licensee shall provide a means of adjusting cost estimates and associated funding levels over the storage or surveillance period.

TMI-2 was a permanently shutdown facility prior to issuance of the final decommissioning rule in July 1996 and was maintained in Post-Defueling Monitored Storage, a term specific to the unique conditions at TMI-2, in accordance with the TMI-2 License, Technical Specifications and Safety Analysis Report. As the TMI-2 Safety Analysis Report was an NRC approved document and was the basis for maintaining TMI-2 in Monitored Storage it is the equivalent of a approved decommissioning plan under the rule. Thus TMI-2 was considered grandfathered under the provisions of the rule.

Additionally a 1995 TMI-2 site specific decommissioning cost estimate forms the basis for the annual certification to the NRC. This cost study was updated in 2004, a copy of which is attached, and includes specific provision for disposal of this waste. On this basis GPU Nuclear believes it has access to the decommissioning trust fund to fund these activities.

Additionally IOCFR50.75 (hXlXiv) states:

Except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, no disbursement or payment may be made from the trust, escrow account, Government fund, or other account used to segregate and manage the funds until written notice of the intention to make a disbursement or payment has been given to the Director, Office of Nuclear Reactor Regulation, or the Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the date of the intended disbursement or payment. The disbursement or payment from the trust, escrow account, Government fund or other account may be made following the 30-working day notice period if the person responsible for managing the trust, escrow account, Government fund, or other account does not receive written notice of objection from the Director, Office of Nuclear Reactor Regulation, or the Director, Office of Nuclear Material Safety and Safeguards, as applicable, within the notice period. Disbursements or payments from the trust, escrow account, Government fund, or other account used to segregate and manage the funds, other than for payment of ordinary administrative costs (including taxes) and other incidental expenses

of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, are restricted to decommissioning expenses or transfer to another financial assurance method acceptable under paragraph (e) of this section until final decommissioning has been completed. After decommissioning has begun and withdrawals from the decommissioning fund are made under 10 CFR 50.82(aX8), no further notification need be made to the NRC.

As this withdrawal is being made in compliance with IOCFR50.82(aX8), as demonstrated above, no prior NRC notification is required. However as this is the first time the TMI-2 Decommissioning Trust Fund is being accessed for purposes other than decommissioning planning GPU Nuclear believes it is appropriate to provide the NRC with a notification of this activity under the provision of IOCFR50.75 (h)(lXiv).

Sincerely

/1aims J.Byrne Vice President, TMI-2 cc:

USNRC Director, Office of Nuclear Material Safety and Safeguards USNRC Director, Division of Waste Management and Environmental Protection USNRC TMI-2 Senior Project Manager USNRC TMI-2 Regional Inspector File 05021

Document F07-1476-002, Rev. 0 DECOMMISSIONING COST ANALYSIS for THREE MILE ISLAND UNIT 2 prepared for FirstEnergy Corporation prepared by TLG Services, Inc.

Bridgewater, Connecticut September 2004

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Page ii of xv APPROVALS President/

Quality Assurance Manager Project Manager Project Engineer Technical Manager as S. LaGuqd' FrnisWRV Seizr 1t

/Z /Vy Date 9,22.c9 Date Date Mark S. -*I 'ghton William A. Cloutier,x-TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page iii of xv TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

vii-xv

1.

INTRODUCTION................................................................................................... 1-1 1.1 Objectives of Study........................................................

1-1 1.2 Site Description........................................................ 1-1 1.3 Regulatory Guidance........................................................

1-8 1.3.1 Nuclear Waste Policy Act....................................

.................... 1-9 1.3.2 Low-Level Radioactive Waste Acts.................................................. 1-10 1.3.3 Radiological Criteria for License Termination...............

................. 1-10

2.

DECOMMISSIONING ALTERNATIVES.

2-1 2.1 DELAYED DECON........................................................

2-2 2.1.1 Period 2 - Dormancy........................................................

2-2 2.1.2 Period 3 - Preparations........................................

............. 2-3 2.1.3 Period 4 - Decommissioning Operations............................................ 2-4 2.1.4 Period 5 - Site Restoration........................................................

2-8 2.2 CUSTODIAL SAFSTOR........................................................

2-9 2.3 HARDENED SAFSTOR........................................................ 2-9

3.

COST ESTIMATE.........................................................

3-1 3.1 Basis of Estimate........................................................

3-1 3.2 Methodology........................................................

3-1 3.3 Financial Components of the Cost Model.....................................................

3-3 3.3.1 Contingency........................................................ 3-4 3.3.2 Financial Risk........................................................ 3-6 3.4 Site-Specific Considerations........................................................

3-7 3.4.1 Spent Fuel Management.................................

....................... 3-7 3.4.2 Reactor Vessel and Internal Components........................

................. 3-8 3.4.3 Steam Generators...................

..................................... 3-10 3.4.4 Other Primary System Components................................................ 3-11 3.4.5 Other Systems Known to Contain High Levels of Radioactivity... 3-12 3.4.6 Reactor Building Structures Decontamination................................ 3.12 3.4.7 Demolition of Other Contaminated Structures............................... 3-13 3.4.8 Main Turbine and Condenser........................................................

3-13 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page iv of xv TABLE OF CONTENTS (continued)

SECTION PAGE 3.4.9 Transportation Methods.....................................................

3-14 3.4.10 Low-Level Radioactive Waste Disposal

............................ 3-15 3.4.11 Additional Decommissioning Facilities

........................... 3-15 3.4.12 Remediation of Soil and Underground Piping

...................... 3-16 3.4.13 Site Conditions Following Decommissioning

....................... 3-16 3.5 Assumptions.....................................................

3-16 3.5.1 Estimating Basis.....................................................

3-17 3.5.2 Labor Costs.....................................................

3-17 3.5.3 Design Conditions.....................................................

3-18 3.5.4 General.....................................................

3-18 3.6 Cost Estimate Summary.....................................................

3-20

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.....................................................

6-1

7.

REFERENCES.....................................................

7-1 TABLES Summary of Decommissioning Cost Elements, Delayed DECON.........

....... xiii Summary of Decommissioning Cost Elements, Custodial SAFSTOR........... xiv Summary of Decommissioning Cost Elements, Hardened SAFSTOR............. xv 1.1 Inventory of Spent Fuel, Auxiliary and Fuel Handling Buildings................. 1-4 1.2 Inventory of Spent Fuel, Reactor Building..................................................... 1-6 1.3 Inventory of Spent Fuel, Reactor Coolant System.......................................... 1-7 3.1 Schedule of Annual Expenditures, Delayed DECON................................... 3-21 3.2 Schedule of Annual Expenditures, Custodial SAFSTOR............................. 3-22 3.3 Schedule of Annual Expenditures, Hardened SAFSTOR............................. 3-23 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Page v of xv SECr 5.1 5.2 5.3 5.4 6.1 6.2 6.3 TABLE OF CONTENTS (continued)

[ION PAGE TMII-2 Waste Streams Summary.....................................................

5-3 Decommissioning Waste Summary, Delayed DECON................................... 5-4 Decommissioning Waste Summary, Custodial SAFSTOR............................. 5-5 Decommissioning Waste Summary, Hardened SAFSTOR............................. 5-6 Summary of Decommissioning Cost Elements, Delayed DECON................. 6-3 Summary of Decommissioning Cost Elements, Custodial SAFSTOR........... 6-4 Summary of Decommissioning Cost Elements, Hardened SAFSTOR........... 6-5 FIGURES K-)

4.1 4.2 4.3 4.4 Delayed DECON Activity Schedule......................................

4-3 Decommissioning Timeline, Delayed DECON......................................

4-5 Decommissioning Timeline, Custodial SAFSTOR......................................

4-6 Decommissioning Timeline, Hardened SAFSTOR......................................

4-7 APPENDICES A.

B.

C.

D.

E.

Unit Cost Factor Development.........................

A-1 Unit Cost Factor Listing.................

B-1 Detailed Cost Analysis, Delayed DECON..................................

C-1 Detailed Cost Analysis, Custodial SAFSTOR..................................

D-1 Detailed Cost Analysis, Hardened SAFSTOR.................................... E-1 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Page vi of xv REVISION LOG No.

CRA No.

Date Item Revised Reason for Revision I

0 22 Si TLG Services, Inc.

Three AMile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page vii of xv EXECUTIVE

SUMMARY

This report presents estimates of the cost to decommission the Three Mile Island, Unit 2 nuclear unit (TMII-2) for the selected decommissioning scenarios following the scheduled cessation of plant operations at the adjacent Unit 1 reactor. The analysis relies upon site-specific, technical information, originally developed in an evaluation for the GPU Nuclear Corporation in 1995-96,[11 updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The updated estimates are designed to provide the FirstEnergy Corporation with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear unit.

The decommissioning of TMI-2 is a continuation of the decontamination efforts started in the 1980s, following its accident.

The ultimate goal of the decommissioning is to remove the radioactive material from the site that would preclude its release for unrestricted use.

The estimates are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, radioactive waste disposal options, and site remediation requirements. The estimates also include the dismantling of non-essential structures and limited restoration of the site.

Alternatives and Regulations The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.12] 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 ENTOMIB.

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 "Decommissioning Cost Estimate for the Three Mile Island, Unit 2," Document No. GO1-1196-003, TLG Services, Inc., February 1996.

2 U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 7 0 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988.

TLG Services, Inc.

C Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page viii of xv 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."[l4 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."[ 5 1 As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

The 60-year restriction has limited the practicality of 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, e.g., on engineered barriers.

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. 631 The amendments allow for greater public participation and better define the transition process firom 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 3

Ibid. Page FR24022, Column 3.

Ibid.

Ibid. Page FR24023, Column 2.

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.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476.002, Rev. 0 Decommissioning Cost Analysis Page ix of xv decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations.

Decommissioning Scenarios Three decommissioning scenarios were evaluated for the nuclear unit. In all cases, there was some consideration of the decommissioning activities planned at the adjacent unit. However, the scenarios selected are representative of alternatives available to the owner and are defined as follows:

1.

Delayed DECON: One of the decommissioning alternatives for Unit 1 is to defer decommissioning until the spent fuel has been removed from the site.17]

This scenario assumes that the decontamination and dismantling activities at TMI-2 are synchronized with the adjacent unit such that the operating licenses for both units are terminated concurrently.

2.

Custodial SAFSTOR: In the second scenario, TMII-1 is placed into long-term storage. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit 1. As with the first scenario, termination of the operating licenses is coordinated.

3.

Hardened SAFSTOR: This scenario assumes that Unit 1 is promptly decommissioned when it ceases operations in 2014. In coordination with the Unit 1 activities, the TMI-2 reactor building is reconfigured for long-term, passive storage. Site structures and facilities, with the exception of the reactor building, are decontaminated and dismantled. The reactor building and its contents are secured and the site is reconfigured for monitored surveillance.

Decontamination and final dismantling of the reactor building is deferred for approximately 100 years (from Unit 1 shutdown).

Methodology The methodology used to develop the estimates described within this document follows the basic approach originally presented in the cost estimating guidelines!8]

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.

7 Timelines for the Unit 1 decommissioning scenarios are included in Section 4 of this report.

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

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Three AMile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page x of xv An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.

Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur."[9] The cost elements in the estimates 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 time intervals identified for each scenario.

The use and role of contingency within decommissioning estimates is not a safety factor issue. Safety factors provide additional security and address situations that may never occur. Contingency funds, by contrast, are expected to be fully expended throughout the program. 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 1980,1101 and its Amendments of 1985,111] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engi-K.

neers, Marcel Dekker, Inc., New York, New York-, p. 239.

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

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

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Three Mfile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page xi of xv TMI-2 is currently able to access the disposal facility in Barnwell, South Carolina.

However, in June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation allows South Carolina to gradually limit access to the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. 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 proxy for future disposal facilities, waste disposal costs are generated using available pricing schedules for the currently operating facilities, i.e., at Barnwell and the Envirocare facility in Utah.

Fuel-Bearing Waste Management There will be some wastes generated in the decommissioning of TMI-2 that are not suitable for shallow land burial and therefore cannot be shipped for disposal to either Barnwell or Envirocare. This material, primarily associated with systems and structures contaminated with fuel debris, requires greater isolation from the environment. For estimating purposes, a geologic waste repository, or some interim storage facility, is assumed to be available by 2015 for the disposal of this material.

This timetable is consistent with the findings of an evaluation issued to Congress by the Government Accounting Office for the geologic repository at Yucca Mountain.[12]

Site Restoration The efficient removal of the contaminated materials at the site may result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities will substantially damage power block structures, potentially weakening the footings and structural supports. Prompt demolition once the license is terminated 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 is more efficient and less costly than if the process were deferred. Experience at shutdown generating stations has shown that plant facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force.

Consequently, this analysis assumes that non-essential site structures within the restricted access area are removed. The site is then backfilled, graded and stabilized.

KU 12 "Technical, Schedule, and Cost Uncertainties of the Yucca Mountain Repository Project," GAO-02-191, December 2001.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Page xii of xv Summary The costs to decommission TMII-2 are evaluated for three decommissioning scenarios.

Regardless of the timing of the decommissioning activities, the estimates assume the eventual removal of all the contaminated and activated plant components and structural materials, such that the facility operator may then have unrestricted use of the site with no further requirement for an operating license.

The scenarios analyzed for the purpose of generating the estimates are 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 Appendices C, D, and E. Cost summaries for the various scenarios are provided at the end of this section for the major cost components.

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Three AMile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Page xiii of xv

SUMMARY

OF DECOMMISSIONING COST ELEMENTS DELAYED DECON (Thousands of 2003 Dollars)

Activity Total [1]

Decontamination Removal Packaging Transportation Waste Disposal Off-site Waste Processing Program Management [2]

Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment Site O&M 32,555 111,729 17,017 8,725 179,451 9,837 318,039 13,997 8,815 6,128 19,576 3,157 Total [3]

729,026 NRC License Termination Site Restoration 705,400 23,625 II] Includes dormancy costs following TMI-1 shutdown in 2014 (2] Includes engineering and security

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

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Page xiv of xv

SUMMARY

OF DECOMMISSIONING COST ELEMENTS CUSTODIAL SAFSTOR (Thousands of 2003 Dollars)

Activity Total [1]

Decontamination Removal Packaging Transportation Waste Disposal Off-site Waste Processing Program Management 12]

Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment Site O&M 32,518 116,450 17,191 8,714 179,716 9,966 335,630 26,339 17,748 6,128 26,209 3,157 Total 13]

779,764 NRC License Termination Site Restoration II] Includes dormancy costs following TMI-1 shutdown in 2014 121 Includes engineering and security 131 Columns may not add due to rounding 756,139 23,625 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Page xv of xv

SUMMARY

OF DECOMMISSIONING COST ELEMENTS HARDENED SAFSTOR (Thousands of 2003 Dollars)

Activity Total [I]

Decontamination Removal Packaging Transportation Waste Disposal Off-site Waste Processing Program Management 12]

Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment K>

Site O&M Off-site Monitoring & Security Services 33,306 121,156 17,052 8,836 179,144 10,655 407,918 40,155 10,432 6,660 27,219 2,927 45,965 Total [3]

911,425 NRC License Termination Site Restoration I[l Includes dormancy costs following TMI-1 shutdown in 2014 121 Includes engineering and security 131 Columns may not add due to rounding 877,525 33,899 TLG Services, Inc.

Three Mlile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 1 of 11

1. INTRODUCTION This report presents estimates of the cost to decommission the Three Mile Island Unit 2 nuclear unit (TAIII-2) for the scenarios described in Section 2. The analysis is designed to provide the FirstEnergy Corporation with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear unit. 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 objective of this study was to prepare estimates of the cost, schedule, and waste volumes generated to decommission TMI-2, including all areas affected by the March 1979 accident.

.Three scenarios were evaluated.

Each scenario is coordinated with decommissioning activities at the adjacent operating unit (TMI-1 or Unit 1).

The base scenario assumes that TMI-1 is decommissioned following the removal of spent fuel from the site. The decommissioning program for TMI-2 runs concurrently with the TMI-1 decommissioning effort and concludes with the termination of both operating licenses. This scenario is subsequently referred to as "Delayed DECON." The second scenario assumes that TMI-1 is placed into safe-storage with decommissioning deferred 60 years. TMII-2 remains in storage with decommissioning deferred until it can be sequenced with TMII-1.

This scenario is subsequently referred to as "Custodial SAFSTOR."

The final scenario assumes that TMI-1 is promptly decommissioned upon the scheduled cessation of operations in 2014. The reactor building at TMI-2 is modified for long-term, passive storage with all other Unit 2 facilities decontaminated and dismantled. Remediation of the reactor building is deferred for a period of approximately 100 years at which time it is decontaminated and dismantled. This scenario is subsequently referred to as "Hardened SAFSTOR."

1.2 SITE DESCRIPTION TAII-2 is located on the northern-most section of Three Mile Island near the east shore of the Susquehanna River in Dauphin County, Pennsylvania. The station is comprised of two pressurized water reactors. This study specifically addresses the decommissioning requirements for Unit 2, although the timing of each scenario is dependent upon the associated activities at the adjacent unit.

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Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 2 of 11 The nuclear steam supply system (NSSS) consists of a pressurized water reactor rated at a core thermal power level of 2772 MWth with a corresponding turbine-generator gross output of 959 MNVe. The NSSS consists of the reactor with two independent primary coolant loops, each containing two reactor coolant pumps and a steam generator. An electrically heated pressurizer and connecting piping complete the system. The system is housed within a steel-lined, post-tensioned concrete structure (reactor building) in the shape of a right, vertical cylinder with a hemispherical dome and a flat, reinforced concrete basemat. A welded steel liner plate, anchored to the inside face of the reactor building, serves as a leak-tight membrane.

Heat produced in the reactor was converted to electrical energy by the turbine generator system. This system converted the thermal energy of the steam into mechanical shaft power and then into electrical energy. The turbine-generator is a tandem-compound design, consisting of one double-flow, high pressure turbine and two double-flow, low-pressure turbines driving a directly coupled generator at 1800 rpm. The turbine operated in a closed feedwater cycle where steam was condensed; feedwater heated, and ultimately returned to the steam generators. Heat rejected in the main condensers was removed by the condenser circulating and river water systems.

The condenser circulating water was cooled in two hyperbolic natural draft cooling towers located to the east of the station. The towers provided the heat sink required for removal of waste heat in the power plant's thermal cycle.

Cooling tower blowdown was discharged to the Susquehanna River.

TMI-2's operating license was issued on February 8, 1978, with commercial operation declared on December 30, 1978. On March 28, 1979, the unit experienced an accident initiated by interruption of secondary feedwater flow.

The steam generator boiled dry, resulting in the reduction of primary-to-secondary heat exchange. This caused an increase in the primary coolant temperature, creating a surge into the pressurizer, and an increase in system pressure. The pilot operated relief valve (PORV) opened to relieve the pressure, but failed to close when the pressure decreased. The reactor coolant pumps were turned off and a core heat-up began as the water level decreased to uncover the top of the core. The melting temperature of the zircaloy fuel cladding was exceeded, resulting in relocation of the molten zircaloy and some liquefied fuel to the lower core regions, solidifying near the coolant interface.

Based on the end-state core and core support assembly configuration and supporting analysis of the degraded core heat-up, it is believed that as the crust failed, molte'n core material migrated to the lower internals. The majority of the molten material flowed down through the region of the southeastern TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 3 of 11 assemblies and into the core bypass region. A portion of the molten core material flowed around the bypass region and migrated down into the lower internals and lower head region. Limited damage to the core support assembly occurred as the core material flowed to the lower plenum. It is estimated that about 17 - 20 tons of material relocated to the lower internals and lower head region. Several in-core instrument guide tubes were melted but overall vessel integrity was maintained throughout the accident.

As a result of this accident, small quantities of core debris and fission products were transported through the RCS, and the reactor building as a result of the coolant flow through the PORV and the makeup and purification system (MU&P) during the accident. In addition, a small quantity of core debris was transported to the auxiliary and fuel handling buildings (AFHB) via the MU&P. Further spread of the debris also occurred as part of the post-accident water processing cleanup activities.

GPU Nuclear has since conducted a substantial program to defuel the reactor vessel and decontaminate the facility. As a result, TMI-2 has been placed in a safe, inherently stable condition suitable for long-term management, and any threat to the public health and safety has been eliminated. Fuel and core material removed in the defueling has been shipped off site. The current long-term management condition is termed Post-Defueling Monitored Storage (PDMS).

Substantial contaminated areas still exist under the PDMS, as well as trace quantities of spent nuclear fuel (SNF). Several cubicles in the auxiliary and fuel handling buildings remain locked, and the basement of the reactor building has been uninhabitable since the accident. The quantity of fuel remaining at TMI-2 is a small fraction of the initial fuel load; approximately 99% was successfully removed in the defueling. Additionally large quantities of radioactive fission products were released into various systems and structures. Most of this radioactivity was removed as part of the waste processing activities during the TMI-2 Clean-up Program which concluded with entry into Post-Defueling Monitored Storage in December 1993.

Significant quantities of radioactive fission products were removed from the reactor coolant system in preparation for the PDMS. However, the remaining 1% of the fuel and the remaining fission products pose unique problems in completing the decommissioning of TMI-2. A summary of the quantity and suspected location of the remaining fuel debris is provided in Tables 1.1 through 1.3.

TLG Services, Inc.

-I Three AMile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 4 of 11 TABLE 1.1 INVENTORY OF SPENT FUEL AUXILIARY AND FUEL HANDLING BUILDINGS SNF Cubical Location Quantity (g)

AX004 Seal Injection Valve Room 30 AX006 Make-up Pump 1B 70 AX007 Make-up Pump 1A 230 AX015a Cleanup Filters 50 AX015b Cleanup Filters 50 AX114 MU&P Demineralizer 1A 1,060 AX115 MU&P Demineralizer 1B 130 AX019 Waste Disposal Liquid Valve Room 10 FH001 MU Suction Valve Room 460 AX012 AB Sump Tank Room 100 AX020 Reactor Coolant Bleed Tank 1B 1,750 AX020 Reactor Coolant Bleed Tank 1C 1,750 AX021 Reactor Coolant Bleed Tank 1A 310 AX024 AB Sump Filters 20 AX102 RB Sump Pump Filter Room.

AX112 Seal Return Coolers and Filter Room 300 AX116 Makeup Tank Room 310 AX117 MU&P Filter Room 60 AX131 Miscellaneous Waste Tank Room 100 AX134 Miscellaneous Waste Tank Pumps AX128 Instrument and Valve Room 10 AX218 Concentrated Waste Storage Tanks 10 AX501 RB Spray Pump 1A 10 AX502 RB Spray Pump 1B 10 AX503 DHR Pump 1A 10 AX504 DHR Pump 1B 10 FH002 Access Corridor FH003a MU Discharge Valves 10 FHO03b MU Discharge Valves 100 FH004 Westinghouse Valve Room 160 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 1, Page 5 of 11 TABLE 1.1 (continued)

INVENTORY OF SPENT FUEL AUXILIARY AND FUEL HANDLING BUILDINGS SNF Cubical Location Quantity (g)

FH101 FH112 FHO14 FH109 MU&P Valve Room Annulus Annulus Spent Fuel Pool "A" 320 10 3,800 Embedded Valves & Piping (MU System)

Embedded Valves & Piping (WDL System) 170 40 TOTAL 11,460 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 6 of 11 TABLE 1.2 INVENTORY OF SPENT FUEL REACTOR BUILDING SNF Area/Component Quantity (g)

Reactor Vessel 925,000 RV Head Assembly 1,300 RV Upper Plenum Assembly 2,100 Fuel Transfer Canal 18,900 Core Flood System 4,900 "A" D-ring 21,000 Upper Endfitting Storage Area 5,900 Reactor Coolant Drain Tank 100 Letdown Coolers 3,700 RB Basement and Sump 1,300 Tool Decontamination Facility (347')

100 Defueling Water Cleanup System 3,700 Defueling Tool Rack 600 Temp React Vessel Filtration System 4,400 RB Drains 5,100 Total 998,100 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 7 of 11 TABLE 1.3 INVENTORY OF SPENT FUEL REACTOR COOLANT SYSTEM SNF Component Quantity (g)

Pressurizer (including surge line) 500 Decay Heat Drop Line 1,500 "A" SIDE OTSG Upper Tubesheet 1,400 Tube Bundle 1,700 Lower Head and J-legs 4,000 Hot Legs 900 Cold Legs 7,200 Core Flood Line 600 "B" SIDE OTSG Upper Tubesheet 36,000 Tube Bundle 9,100 Lower Head and J-legs 10,100 Hot Legs 1,800 Cold Legs 2,400 Core Flood Line 400 RCS Surface Films 4,600 Reactor Coolant Pumps 6,200 Total 88,400 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 8 of 11 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.[11 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,"[2] 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 ENTOlVIB. The DECON alternative, the option evaluated for this analysis, assumes that any contaminated or activated portion of the plant's systems, structures, and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations. The rule also placed limits on the time allowed to complete the decommissioning process.

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

The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with recent rulemaking permitting the controlled release of a site, the NRC has re-evaluated this alternative.[3] The resulting feasibility study, based upon an

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

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 9 of 11 assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most, reactors.[41 However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. Rulemaking has been deferred pending the completion of additional research studies, e.g., on engineered barriers. However, this study assumes that the ENTOMB alternative is a viable option for TMI-2 and that a storage period of 100 years would be acceptable.

The NRC published revisions to the general requirements for decommissioning nuclear power plants in 1996.[5] When the 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 new amendments allow for greater public participation and better define the transition process from operations to decommissioning.

1.3.1 Nuclear Waste Policy Act Congress passed the Nuclear Waste Policy Act[6] (NWPA) in 1982, assigning the responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the U.S.

Department of Energy (DOE). Two permanent disposal facilities and an interim storage facility were envisioned. To recover the cost, the legislation created a Nuclear Waste Fund through which money is collected from the sale of electricity generated by the power plants. The NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

After pursuing a national site selection process, the NWPA was amended in 1987 to designate Yucca Mountain, Nevada, as the only site to be evaluated for geologic disposal of high-level waste. For estimating purposes, this facility, or some interim storage facility, is assumed to be available by 2015 for the disposal of systems and TLG Services, Inc.

I Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 10 of 1l structures contaminated with fuel debris that require greater isolation from the environment.

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. Congress passed the "Low-Level Radioactive Waste Policy Act" in 1980,17[

declaring the states as being 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,"[8] extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. However, to date, no new compact facilities have been successfully sited, licensed, and constructed.

TMI-2 is currently able to access the disposal facility in Barnwell, South Carolina. However, in June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation allows South Carolina to gradually limit access to the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. 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 proxy for future disposal facilities, waste disposal costs are generated using available pricing schedules for the currently operating facilities, i.e., at Barnwell and at Envirocare's facility in Utah.

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination,"[9] amending 10 CFR §20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 11 of 11 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 estimates for TMI-2 assume that the site will be remediated to a residual level consistent with the NRC-prescribed level.

It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).110l An additional limit of 4 millirem per year, as defined in 40 CFR

§141.16, is applied to drinking water.1'"]

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

The Memorandum of Understanding (MOU)

[12]

provides that EPA will defer exercise of authority under CERCLA for K) 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.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page I of 10

2. DECOMMISSIONING ALTERNATIVES Detailed cost estimates were developed to decommission TMI-2 for three scenarios.

Although the alternatives differ with respect to technique, process, cost, and schedule, they attain the same result: the ultimate release of the site for unrestricted use.

Three decommissioning scenarios were evaluated for the nuclear unit. The scenarios are defined as follows:

1.

Delayed DECON: One of the decommissioning alternatives for Unit 1 is to defer decommissioning until the spent fuel has been removed from the site.

This scenario assumes that the decontamination and dismantling activities at TMI-2 are synchronized with the adjacent unit such that the operating licenses for both units are terminated concurrently.

2.

Custodial SAFSTOR: In the second scenario, TMI-1 is placed into long-term storage. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit 1. As with the first scenario, termination of the operating licenses is coordinated.

3.

Hardened SAFSTOR: This scenario assumes that Unit 1 is promptly decommissioned when it ceases operations in 2014. In coordination with the Unit 1 activities, the TMI-2 reactor building is reconfigured for long-term, passive storage. Site structures and facilities, with the exception of the reactor building, are decontaminated and dismantled. The reactor building and its contents are secured and the site is reconfigured for monitored surveillance.

Decontamination and final dismantling of the reactor building is deferred for approximately 100 years (from Unit 1 shutdown).

For each of the three scenarios described above, dormancy costs are accrued from the cessation of TMI-1 operations. This means that the current PDMS costs are not included within the reported decommissioning costs.

The following sections describe the basic activities associated with each alternative.

The first two scenarios are essentially identical. The technical assumptions are unchanged with the only difference in the second scenario being the delay in start of decommissioning expenditures and the additional storage cost during the delay period. The third scenario reduces the controlled area to the reactor building, similar to that envisioned for an entombment alternative, without the extensive engineered barriers.

TLG Services, Inc.

Three AMile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 2 of 10 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 addresses the transition of reactor operations (i.e., power production) to facility de-activation and closure. 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 estimates developed for TMI-2 are also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures.

2.1 DELAYED DECON The TMI-2 plant has effectively been placed in a SAFSTOR condition since the completion of the spent fuel removal activities and beginning of the PDAIS.

However, the engineering and planning requirements for completing the decommissioning process are similar to those for a DECON alternative. Unit 2 decommissioning operations are integrated with Unit l's spent fuel transfer campaign such that the operating (Part 50) licenses are terminated concurrently.

2.1.1 Period 2 - Dormancy The dormancy costs included in this estimate are limited to monitoring activities only. Although TMI-2 has been in a dormant condition since entry into Post-Defueling Monitored Storage in December 1993, this estimate only includes those costs for maintaining the unit subsequent to the currently scheduled cessation of operations at Unit 1 in April of 2014, i.e., current costs are not included.

Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public fiom the consequences of its own actions. Security is provided by fences, sensors, alarms, and other surveillance equipment. Fire and radiation alarms are also monitored.

TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 3 of 10 2.1.2 Period 3 - Preparations Preparations include the planning for the removal of the remaining fuel-bearing components, decontamination of the structures and the dismantling of the remaining equipment and facilities. Typically, the process is described within a Post-Shutdown Decommissioning Activities Report (PSDAR) or a Decommissioning Plan (DP). Although the exact format and content of the decommissioning planning document has not been identified, as a minimum Technical Specification 3.2.1.1 requires NRC approval prior to removal of greater than 42 kilograms of fuel from the reactor vessel. Thus in addition to the planning document, changes may be required to the existing technical specifications prior to the start of major decommissioning activities.

Engineering and Planning The decommissioning program outlined in the PSDAR or DP will be designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR §20) for protection of personnel from exposure to radiation hazards. It will also address the continued protection of the health and safety of the public and the environment during the dismantling activity. Consequently, with the development of the decommissioning plan, activity specifications, cost-benefit and safety analyses, and work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities.

The estimate assumes that FirstEnergy will provide project oversight.

However, the majority of the professional, managerial, technical and administrative support staff will be provided by a decommissioning operations contractor (DOC).

Site Preparations In preparation for active decommissioning, the following activities are initiated:

Characterization of the site and surrounding environs. This includes radiation surveys of the reactor building including: the basement and elevator block wall area, areas surrounding major components (including the reactor vessel and its internals, steam generators),

internal piping, and primary shield cores. Surveys of the auxiliary and fuel handling building with emphasis on areas with known and TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 4 of 10 potential alpha contamination and know fission products. Surveys and sample analysis will also be performed on exterior buildings, land areas surrounding the facility, subsurface soil and groundwater.

Specification of transport and disposal requirements for highly radioactive materials and/or hazardous materials, including shielding and waste stabilization.

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

2.1.3 Period 4 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and highly radioactive components and structures, including the successful termination of the operating license. Significant decommissioning activities in this phase include:

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

Refurbishment of the containment air control envelope building located outside the reactor building equipment hatch.

A prefabricated metal containment building located on the 305' level of the reactor building will be required for the handling of highly contaminated material being removed from the basement or the operating deck elevations.

• Modification of the containment structure to facilitate handling of large equipment. This will include an evaluation to determine whether a temporary crane should be installed or whether the existing polar crane should be refurbished (the reactor vessel head will be the heaviest lift under the current removal scenario with the in-situ segmentation of the reactor vessel and steam generators).

TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 5 of 10

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

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

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

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

Decontamination of the reactor building so as to reduce working area K) dose rates and improve working conditions. The reactor building basement is known to be highly contaminated and will require remote operations and tooling for the initial decontamination effort.

Inventory, decontamination and removal of legacy equipment inventory left over from the defueling campaign.

• Installation of a water processing system to filter and treat water from the reactor coolant system and fuel handling pool.

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

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

• Segmentation of the upper internals assemblies. The plenum is currently stored in the fuel transfer canal. 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.

TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 6 of 10

• Disassembly and segmentation of the remaining reactor internals, including the core former and lower core support assembly. All internals components below the top of the fuel are expected to exceed Class C disposal requirements due to fuel contamination. As such, the segments will be packaged in modified fuel storage canisters for geologic disposal.

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

• Removal of the steam generators and pressurizer for material recovery and controlled disposal. Due to the high internal and external radioactivity, these components can not serve as their own shipping containers. The steam generators are assumed to be segmented in-place. The pressurizer is assumed to be cut in half and shipped in a sealed and shielded shipping and burial container. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations.

• Removal of free standing concrete structures in the reactor building.

Removal of the remaining internal structures within the reactor building including: the polar crane, inner pools and wall liners, biological shield, D-rings, floors and walls.

At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) is required. Submitted as a supplement to the FSAR or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including:

TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 7 of 10

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

• Processing of the structural material in the reactor, auxiliary and fuel handling buildings. Approximately 90% of the concrete removed is assumed to meet free release criteria. The remainder is sent to a waste processor. The free-released concrete is available as fill. Excess concrete and scrap metals are disposed of in an industrial landfill.

• Removal of contaminated yard piping and any contaminated soil.

• Transfer of greater-than-Class C (GTCC) material to the DOE.

• Surveys of the decontaminated areas not. designated for complete removal and disposal.

Remediation and removal of the contaminated equipment and material from the auxiliary and fuel buildings and any other contaminated facility. Certain areas in the auxiliary and spent fuel handling buildings contain very high contamination and radiation levels and will require additional resource and increased radiological protection to complete the decontamination.

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

• Material that is designated as scrap or general disposal (survey and release) is transferred to a designed waste processing vendor for a confirmatory survey and, if permitted, released for unrestricted disposition. 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.

TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 8 of 10 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)."[13] This document incorporates the statistical approaches to survey design and data interpretation used by the EPA. It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the survey is complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on final termination of the license.

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

2.1.4 Period 5 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the remaining structures. Prompt dismantling of remaining site structures is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers.

Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.

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

Foundations and 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 TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 9 of 10 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.

2.2 CUSTODIAL SAFSTOR The decontamination and dismantling activities in this scenario are identical to those described in Section 2.1 for Delayed DECON. However, the start of active decommissioning is deferred to coordinate with the timing of the Unit 1 SAFSTOR scenario. As such, the duration of the dormancy period is significantly longer and the storage costs correspondingly greater.

While it is expected that radiation dose levels will decrease by 80% to 90% over the duration of the longer dormancy period, the nature of radionuclides involved and the difficulties in working in plant areas contaminated with these radionuclides will require similar operational and radiological controls to those envisioned for earlier scenario. As such, there have been no changes incorporated into the costs to perform the field decommissioning activities identified in Section 2.1 for this scenario.

2.3 HARDENED SAFSTOR This scenario is similar to what has been generally described as the ENTOMB option. The NRC has defined the ENTOMB option 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." As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years. However, durations of up to 100 years may be considered where there are demonstrated benefits to the safety and health of the public.

This option reduces the long-term radiological footprint on the site by t-.

contracting the controlled area to the reactor building. Contamination outside this area is removed in the early stages of Hardened SAFSTOR decommissioning, concurrent with the decommissioning of Unit 1. Removal activities are performed in a similar fashion to their counterparts in the TLG Services, Inc.

Three Mile Island, Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 10 of 10 Delayed DECON scenario. Upon completion of the process, the reactor building is sealed with appropriate security and monitoring measures installed.

As in the Delayed DECON and Custodial SAFSTOR dormancies, the purpose of the dormancy period is to isolate the contamination on site, and to protect the public from the consequences of their own actions. The difference between the Hardened SAFSTOR dormancy and the other two scenarios is that generally the site is uninhabited; security and radiation monitoring are performed remotely.

Following the end of the Hardened SAFSTOR dormancy period, the reactor building and its contents are removed and disposed of in a similar fashion as discussed in the Delayed DECON scenario. Following the termination of the license and the limited restoration of the affected area, the site is available for unrestricted, alternative use.

While it is expected that radiation dose levels will decrease by more than 90%

over the duration of the longer dormancy period, the nature of radionuclides involved and the difficulties in working in plant areas contaminated with these radionuclides will require similar operational and radiological controls to those envisioned for earlier scenario. As such, there have been no changes incorporated into the costs to perform the field decommissioning activities identified in Section 2.1 for this scenario.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 1 of23

3. COST ESTIMATE The cost estimates prepared for decommissioning TMI-2 consider the radiological status, unique conditions of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimates, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.

3.1 BASIS OF ESTIMATE The estimates rely upon site-specific, technical information originally developed in an evaluation prepared for the GPU Nuclear Corporation in 1995-96.14] The information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated

.where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.

Some of the technical assumptions that were used are due to the unique nature and characteristics of the plant as a result of the March 1979 accident.

Following the accident, TMI-2 was defueled and extensive decontamination activities were performed. This successfully removed approximately 99% of the original fuel and resulting fuel debris. Removal of the residual 1% was neither cost. effective nor warranted due to the high radiation fields in the reactor building and adjoining auxiliary and fuel handling buildings. The remaining equipment and components containing spent nuclear fuel (SNF) will be removed, sealed and/or encapsulated in preparation for disposal during the decommissioning program.

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,"[15 1 and the DOE "Decommissioning Handbook."[i 6]

These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) were developed using local labor rates. The activity-dependent costs were estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 2 of23 the conventional disposition of components and structures relied upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.i' 7 1 This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail 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.

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

The WDF sets were developed considering the extremely difficult working conditions associated with working in high radiation areas and in areas with high alpha particle contamination. The same work difficulty factor sets were used for all three scenarios. This assumption was based upon the relatively high levels of long-lived radioactivity that exists today plus the high levels of alpha contamination.

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. Given the radiological status of some areas at TMI-2, the range of the WDF's was increased. The ranges used for the WDFs are identified in the following table.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 3 of23 Work Difficulty Factors Other Fuel/Aux Reactor NSSS Power Block Buildings Building Components Access 20%

40%

30%

40%

Respiratory Protection 0-25%

200%

50%

200%

Radiation/ALARA 10-25%

40%

40%

100%

Protective Clothing 0-30%

50%

50%

50%

Work Break 8.33%

8.33%

8.33%

8.33%

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

As shown above, higher WiDF's sets were assigned to systems located in the reactor building and to systems which contain SNF and/or high levels of radioactive materials. The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities are based upon productivity information available from the "Building Construction Cost Data" publication.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.

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

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In the TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 4 of23 DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.

3.3.1 Contingengv 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"[18] as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, a contingency factor has been applied. 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 time intervals identified for each scenario.

The use and role of contingency within decommissioning estimates is not a "safety factor issue." Safety factors provide additional security and address situations that may never occur. Contingency funds are expected to be fully expended throughout the program. They also provide assurance that sufficient funding is available to accomplish the intended tasks. An estimate without contingency, or from which contingency has been removed, can disrupt the orderly progression of events and jeopardize a successful conclusion to the decommissioning process.

For

example, the most technologically challenging task in decommissioning a commercial nuclear station is the disposition of the reactor vessel and internal components, highly radioactive following the accident. The disposition of these components forms the basis of the critical path (schedule) for decommissioning operations. Cost and schedule are interdependent, and any deviation in schedule has a significant impact on cost for performing a specific activity.

TLG Services, Inc.

Three M11ile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 5 of23 Disposition of the reactor vessel internals involves the underwater cutting of complex components that are highly radioactive. Costs are based upon optimum segmentation,

handling, and packaging scenarios. The schedule is primarily dependent upon the turnaround time for the heavily shielded shipping casks, including preparation, loading, and decontamination of the containers for transport. The number of casks required is a function of the pieces generated in the segmentation activity, a value calculated on optimum performance of the tooling employed in cutting the various subassemblies. The expected optimization, however, may not be achieved, resulting in delays and additional program costs. For this reason, contingency must be included to mitigate the consequences of the expected inefficiencies inherent in this complex activity, along with related concerns associated with the operation of highly specialized tooling, field conditions, and water clarity.

Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a (9_

successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 10% to 75%, depending on the degree of difficulty judged to be appropriate from TLG's actual decommissioning experience. The contingency values used in this study are as follows:

Decontamination 50%

Contaminated Component Removal 25%

Contaminated Component Packaging 10%

Contaminated Component Transport 15%

Low-Level Radioactive Waste Disposal 25%

Reactor Segmentation 75%

NSSS Component Removal 25%

Reactor Waste Packaging 25%

Reactor Waste Transport 25%

Reactor Vessel Component Disposal 50%

GTCC Disposal 15%

Non-Radioactive Component Removal 15%

Heavy Equipment and Tooling 15%

Supplies 25%

TLG Services, Inc.

Three Mile Island Unit 2 Document P07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 6 of23 Engineering 15%

Energy 15%

Characterization and Termination Surveys 30%

Construction 15%

Taxes and Fees 10%

Insurance 10%

Staffing 15%

The contingency values are applied to the appropriate components of the estimates on a line item basis. A composite value is then reported at the end of each estimate. For example, the composite contingency value reported for the Delayed DECON alternative is 19.6%. Values for the other alternatives are delineated within the detailed cost tables in Appendix D and E.

3.3.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk.

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

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

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

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

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

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 7 of23

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

• Pricing changes for basic inputs, such as labor, energy, materials, and burial. Some of these inputs may vary slightly, e.g. -10% to

+20%; burial could vary from -50% to +200% or more.

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

3.4 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study. Unless otherwise noted, these assumptions are applicable to all three scenarios.

3.4.1 Spent Fuel Management The cost to dispose of spent fuel generated fiom plant operations is not reflected within the estimates to decommission the TMI-2 site. The majority of the spent fuel was removed during the TMI-2 Clean-up Program's reactor vessel defueling effort which concluded in January 1990. Title to the spent fuel that was removed was transferred to the DOE.

The remainder of the fuel (about 1%) is dispersed within the primary system and to a lesser extent in other systems and structures. This TLG Services, Inc.

Three AMile Island Unit 2 Document F07-1476.002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 8 of23 residual material will be removed as radioactive waste and is included in the waste disposal volumes discussed in Section 5.

Repository Availability There will be some wastes generated in the decommissioning of TMI-2 that are not suitable for shallow land burial and therefore cannot be shipped for disposal to either Barnwell or Envirocare. This material, primarily associated with systems and structures contaminated with fuel debris, requires greater isolation from the environment. For estimating purposes, a high-level waste repository, or some interim storage facility, is assumed to be available by 2015 for the disposal of this material. This timetable is consistent with the findings of an evaluation recently issued to Congress by the Government Accounting Office for the geologic repository at Yucca Mountain.

3.4.2 Reactor Vessel and Internal Components The majority of the reactor internal components have already been removed as a result of the accident recovery effort in the 1980's. These components are currently being stored within the reactor building.

This estimate assumes that these components are segmented and shipped in shielded, reusable transportation casks commensurate with the start of major reactor vessel removal activities, e.g., Period 4A of the Delayed DECON scenario.

The reactor pressure vessel and remaining internal components (essentially the core barrel, core former, thermal shield, and flow distributor) are segmented and packaged for disposal in shielded, reusable transportation casks. Segmentation of the remaining internal components is performed in the refueling canal, where a turntable and remote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor cavity.

Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.

It is anticipated that all neutron-activated components in the reactor vessel and internals would meet existing disposal requirements as delineated in 10 CFR §61, due to the short operating history. However, the fission products and transuranic material present on all surfaces in the vessel and internals are expected to exceed Class C limits, in particular for those components located below the top of the core. The TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 9 of 23 reactor vessel and the upper portions of the internals are assumed to meet Class A limits following decontamination.

The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal, i.e., GTCC. Although the material is not classified as high-level waste, the DOE has indicated it will accept this waste for disposal at the future high-level waste repository.119] However, the DOE has not been forthcoming with an acceptance criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and waste form requirements. As such, for purposes of this study, the GTCC has been packaged and disposed of as high-level waste, at a cost of $25,000 per cubic foot. It is also assumed that the DOE will accept the GTCC material in a timely manner so as not to affect the TMI-2 decommissioning schedule. No additional costs are included for the temporary storage of GTCC material.

Intact disposal of the reactor vessel and internal components can Ir 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. 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 for TMI-2. 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 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 10 of23 highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition.

3.4.3 Steam Generators With the high levels of radioactivity and contamination both in the reactor building and within the steam generators, this estimate assumes that the steam generators will be segmented in place instead of one piece removal.

The removal sequence assumed for the estimate is as follows:

• Remove the upper steam generator channel head by wire sawing the shell and tubes immediately below the upper tube sheet.

Segment and decontaminate the upper channel head in the fuel transfer pool.

• Install a steam generator work platform to allow in-place underwater segmentation of the steam generator internals.

• Remove the steam generator tubing and associated shroud and support plates.

• Remove the steam generator cylindrical shell.

• Remove the lower steam generator channel head.

• Segment and decontaminate the lower channel head in the fuel transfer pool.

The steam generator tubing is packaged and shipped and buried as Class B waste. Steam generator tube support plates, shrouds, and shell plates are transported and buried as Class A waste. The estimate assumes that the steam generator channel heads will be decontaminated using a combination of machining and ultra high pressure (UHP) water sprays such that the components can be shipped and buried as Class A waste.

Waste that is generated as a result of the machining and normal filtering of the water in the steam generators and the fuel transfer pool is assumed to be highly radioactive and is packaged and transferred to the DOE as GTCC waste.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476.002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 11 of23 3.4.4 Other Primary System Components The following discussion deals with the decontamination, removal and disposition of the pressurizer, reactor coolant piping, reactor coolant pumps and motors, and the core flood tanks.

A combination of in-place decontamination, and remote decontamination of components in the fuel transfer pool was assumed in the estimate.

The pressurizer and the core flood tanks are decontaminated in-place using UHP. Once decontaminated, the pressurizer is cut in half, removed from the reactor building, grouted, and packaged in a shielded container for rail shipment and burial as Class A waste. The core flood tanks are assumed to be segmented, packaged and shipped as Class A waste.

Hot leg piping is accessed by cutting a hole in the core barrel. A combination of underwater remote retrieval and vacuuming is used to remove fuel and fission product material. Hot and cold leg piping and fittings are removed and placed in the fuel transfer pool for additional decontamination. Hydrolasing is used to remove radioactive materials.

Removed material is collected using filters and demineralizers,

packaged, and transferred to the DOE as GTCC material.

Decontaminated piping is packaged, shipped and buried as Class A material.

The reactor coolant pump motors are removed intact and placed in shielded containers for rail transport and burial as Class A material.

Reactor coolant pumps are disassembled and placed in the fuel transfer pool for decontamination.

Pump components are decontaminated using UHP to remove the majority of the radioactive material. Following decontamination, the components are packaged in shielded containers for rail transport and buried as Class A material.

Material removed as a result of the decontamination process is collected using filters and shipped as GTCC material. The estimates also assume that process water used for reactor coolant system decontamination and in the fuel transfer pool is processed using cesium/strontium preferential cation demineralizers. The resin waste C )

is processed and buried as Class C radioactive waste.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 12 of23 3.4.5 Other Systems Known to Contain High Levels of Radioactivity Systems in the reactor building and portions of systems in the auxiliary and fuel handling buildings are known to contain high levels of radioactivity and potentially spent fuel material from the accident.

The estimates recognize the difficulty in removing these components by increasing the work difficulty factors associated with removal of these systems. The estimates also assume that these components will be packaged for direct disposal (no recycling). The disposal costs of these waste streams were also adjusted, as appropriate, to include curie surcharges commensurate with the higher radioactivity levels.

These systems and components will be decontaminated with UHP sprays to removal fuel solids and sludge from fuel bearing components in the fuel and auxiliary buildings. Solids and sludge resulting from the UHP process will be transferred to the reactor building to be packaged in canisters used for NSSS decontamination.

3.4.6 Reactor Building Structures Decontamination Significant radioactive contamination exists throughout the TMI-2 reactor building. This contamination is due to fission products (90Sr and 137Cs in particular) released from the failed fuel. The radiation levels are not expected to decrease significantly from current levels due to the long half lives of these elements. The dispersion of spent fuel within the reactor building includes alpha-decaying isotopes in addition to the beta and gamma radiation normally encountered during decommissioning. These unusual conditions require additional controls and more engineered decommissioning methods to perform the structure decontamination and demolition.

Based upon these conditions, the estimates assume that the entire interior structure of the reactor building is removed and disposed as potentially contaminated material.

The lower elevations of the reactor building are highly contaminated.

This contamination is present on the lower level concrete and steel walls. Significant activity has been absorbed in the concrete block walls, in the four foot thick D-ring concrete walls, and on the lower level concrete floors. Initial decontamination of this area (Period 4A) is assumed to be performed using remotely-operated machines (BROIKS or equivalent). Surface material will be bulk removed from the TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476.002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 13 of23 concrete walls, packaged in shielded casks and buried as Class B waste.

Once the highly contaminated surfaces are decontaminated, free standing concrete walls will be removed (in Period 4B using more conventional means) and shipped to a waste processor as radioactive material.

The upper portion of the containment inner steel liner and the entire polar crane will be removed using conventional radioactive demolition techniques (in Period 4B) and packaged, shipped and buried as radioactive material. Following liner removal, the outer reactor building concrete walls will be removed using hydraulic excavation hammers. Reactor building structural material will be processed with 90% of the concrete volume assumed to meet free release criteria. The remaining 10% is sent to a waste processor. The fiee released concrete is acceptable for use as fill. Excess material and scrap metals will be sent to an industrial landfill.

3.4.7 Demolition of Other Contaminated Structures Significant contamination exists within the auxiliary and fuel buildings. Similar to the reactor building, locations within these buildings will require special engineered methods to safely decontaminate and dispose of the structures.

The estimate assumes that the entire auxiliary and fuel building structures (all walls and floors down to the footings) will be removed and the resultant structural material monitored and processed with the same criteria as the reactor building.

Selected areas of the buildings will require remote operated machines and dedicated engineered ventilation systems and enclosures to allow decontamination and material removal.

3.4.8 Main Turbine and Condenser The main turbine will be dismantled using conventional maintenance procedures. The remaining turbine internals will be removed to a laydown area. The lower turbine casings will be removed from their

'I) anchors by controlled demolition. This study recognizes that one of the low pressure turbine rotors has already been removed from the site.

The main condensers will also be disassembled and moved to a TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 14 of23 laydown area. Material is then prepared for transportation to an off-site recycling facility where it will be surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components will be packaged and readied for transport in accordance with the intended disposition.

3.4.9 Transportation Methods Contaminated piping, components, and structural material other than the highly contaminated reactor coolant system components and reactor building structures will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.120]

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. It is anticipated that the reactor, due to its limited operating lifetime, will qualify as LSA II or III. The reactor vessel internal components are expected to be transported to the DOE's geologic repository in spent fuel casks by rail.

Waste resulting from filtering and demineralization of the reactor coolant system, and processing the fuel transfer pool water is assumed to require shipment in shielded truck casks. Transport of other highly radioactive material such as reactor coolant system components, and waste from the decontamination of the reactor building basement are by shielded truck cask. Truck cask shipments may exceed 95,000 pounds, including payload, supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per shipment assumed permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits.

The transport of large intact components, e.g., large heat exchangers and other oversized components are by a combination of truck, rail, and/or multi-wheeled transporter.

Truck transportation costs are estimated using published tariffs from Tri-State Motor Transit.[2 11 The low-level radioactive waste requiring controlled disposal will be sent to the Envirocare facility in Clive, Utah. Memphis, Tennessee, is used as the destination for off-site processing. Bulk material shipped off site to TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 15 of23 the waste processor or to Envirocare is primarily moved via gondola railcars.

3.4.10 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is treated to reduce the total volume requiring controlled disposal. The treated material, meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning and recovery of the waste stream is performed off site at a licensed processing center.

Very low-level radioactive

material, e.g.,

structural steel and contaminated concrete, is sent to a waste processing facility. More highly contaminated and activated material is sent to Envirocare.

Disposal fees are based upon current charges for operating waste. Since Envirocare does not currently have a license to handle and dispose of Class B and C wastes, Barnwell rates were used as -a surrogate.

Surcharges were added for the highly activated components, e.g.,

generated in the segmentation of the reactor vessel. A nominal fee of

$25,000 per cubic foot was assumed for the disposal of GTCC material at a federal repository.

The Idaho National Engineering and Environmental Laboratory (INEEL) is currently storing waste from the TMII-2 defueling operation.

Costs have been included in this estimate to pay INEEL for the final disposal of this waste; the timing of when this payment occurs will be dependent upon the DOE's schedule for cleanup of INEEL. This estimate assumes that the payment occurs during Period 4 of each cost scenario.

This study assumes that most of the concrete resulting from the demolition of the reactor, auxiliary and fuel handling buildings can be surveyed and released on site for fill of below grade voids, or shipped off site to a local construction debris landfill. Should there be restrictions to this approach; the cost impact on the decommissioning program could become quite large, potentially up to tens of millions of dollars.

3.4.11 Additional Decommissioning Facilities Additional specialized facilities are required in support of the decommissioning. These include refurbishment of the containment air control envelope building located outside the reactor building equipment TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 16 of23 hatch, and the contamination control cubicle located outside the other personnel airlock, for reactor building radiological control and access.

Construction of a prefabricated metal enclosure at 305 elevation within the reactor building for the handling of highly-contaminated material. A radioactive material packaging and processing facility will also be required (Note that such a facility already exists on site, but will require refurbishment.)

3.4.12 Remediation of Soil and Underground Piping The estimates include the cost to remove certain underground piping.

An allowance is also included for the removal, packaging, transportation and disposal of approximately 49,000 cubic feet of contaminated soil.

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

Non-essential structures or buildings severely damaged in decontamination process are removed to a nominal depth of three feet below grade. Concrete rubble generated from demolition activities is processed and made available as clean fill. The excavations will be regraded such that the power block area will have a final contour consistent with adjacent surroundings.

This estimate assumes the reactor, auxiliary, fuel buildings will be removed completely, i.e., to their foundations and basemats. Concrete from these buildings will be surveyed on-site using conventional monitoring equipment; concrete which meets the release criteria will be disposed of either on site as fill, or in an off-site landfill.

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

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476.002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 17 of23 3.5.1 Estimating Basis The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.

All costs are reported in 2003 dollars.

No costs have been included for the preparation of an environmental impact statement, should it be required.

3.5.2 Labor Costs The craft labor required to decontaminate and dismantle the nuclear units will be acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis. Costs for site administration, operations, construction, and maintenance personnel are based upon average salary information provided by FirstEnergy or from comparable industry information.

FirstEnergy will provide limited oversight support staff in the areas of overall management, licensing, radiological and industrial safety and engineering. It will also hire a DOC to provide the balance of the professional, management, administrative and physical staff.

This study assumes that there is some sharing of administrative staffing positions with the adjacent Unit 1 (owned and operated by AmerGen Energy, LLC, a wholly-owned subsidiary of Exelon Generation, LLC).

This has the effect of slightly lowering site utility and contractor staffing costs.

The staffing levels for the Hardened SAFSTOR scenario were adjusted (reduced) during decommissioning periods to reflect the two phase approach.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 18 of23 3.5.3 Design Conditions Fuel cladding failure as a result of the accident will most likely prevent shipment of untreated major NSSS components under current transportation regulations and disposal requirements. Therefore, this estimate assumes that aggressive mechanical decontamination of reactor coolant system components is required prior to shipment.

The curie contents of the vessel and internals are activation products derived from those listed in NUREG/CR-3474.[22] Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the TMI-2 components, the 95 effective full-power days, and different periods of decay. Additional short-lived isotopes were derived from CR-0130123] and CR-0672.[ 24] and benchmarked to the long-lived values from CR-3474. The activation products present in the reactor vessel base metal are assumed to be the controlling factor in their disposal, following surface decontamination of fuel debris.

Reactor vessel internals whose elevation in the reactor places them at or below the original top of the fuel assemblies are assumed to be both sufficiently geometrically complex to preclude effective decontamination and contaminated with spent fuel so as to require disposal as GTCC material.

Control elements and incore detector assemblies are assumed to have been removed with the damaged fuel.

Activation of the reactor building structure and the biological shield is considered minimal due to the short operating life of TMI-2.

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

q

~

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

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 19 of23

• Process defueling waste inventories, i.e., the estimates include costs for the removal of lead shielding and spent fuel handling equipment that has remains in the reactor building.

Scrap and Salvage Material located within the radiation controlled area, and not shipped for direct disposal, is sent off-site for survey and release.

Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property owned by FirstEnergy (and outside the radiation controlled area) is removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts are also available for alternative use.

Energv For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with long term dormancy.

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

Insurance Costs for continuing coverage (nuclear liability and property insurance) during dormancy and 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."[ 25]

The NRC's financial protection requirements are based on various reactor configurations.

Taxes Property taxes are not included.

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.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 20 of 23 3.6 COST ESTIMATE

SUMMARY

A schedule of expenditures for each scenario is provided in Tables 3.1 through 3.3. Decommissioning costs are reported in the year of projected expenditure; however, the values are provided in thousands of 2003 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure. The annual expenditures are based upon the detailed activity costs reported in Appendices C through E, along with the schedule discussed in Section 4.

TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 3, Page 21 of23 TABLE 3.1 SCHEDULE OF ANNUAL EXPENDITURES DELAYED DECON (thousands, 2003 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 319 453 454 453 453 453 454 453 453 453 21,433 41,479 35,070 35,070 35,166 35,070 35,070 31,920 31,245 31,160 24,456 12,892 7,280 88 126 126 126 126 126 126 126 126 126 475 3,030 10,330 10,330 10,358 10,330 10,330 9,333 9,117 9,092 6,774 4,078 2,832 162 230 230 230 230 230 230 230 230 230 464 669 669 669 671 669 669 532 501 499 402 130 41 14 20 20 20 20 20 20 20 20 20 20 4,549 13,708 13,708 13,746 13,708 13,708 20,422 22,104 22,044 15,346 9

0 344 489 491 489 489 489 491 489 489 489 8,039 8,062 9,668 9,668 9,694 9,668 9,668 4,193 2,878 2,870 4,386 3,828 230 928 1,318 1,322 1,318 1,318 1,318 1,322 1,318 1,318 1,318 30,430 57,789 69,445 69,445 69,635 69,445 69,445 66,400 65,845 65,665 51,364 20,937 10,384 381,711 97,628 8,815 153,269 87,602 729,026 f-j TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 22 of23 TABLE 3.2 SCHEDULE OF ANNUAL EXPENDITURES CUSTODIAL SAFSTOR (thousands, 2003 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2014 319 88 162 14 344 928 2015 453 126 230 20 489 1,318 2016 454 126 230 20 491 1,322 2017 453 126 230 20 489 1,318 2018 453 126 230 20 489 1,318 2019 453 126 230 20 489 1,318 2020 - 2060 18,597 5,151 9,430 825 20,072 54,076 2061 453 126 230 20 489 1,318 2062 453 126 230 20 489 1,318 2063 27,812 580 534 20 10,333 39,279 2064 40,790 4,601 671 6,788 7,276 60,126 t

2065 35,070 10,327 669 13,649 9,664 69,378 2066 35,070 10,327 669 13,649 9,664 69,378 2067 35,070 10,327 669 13,649 9,664 69,378 2068 35,166 10,355 671 13,687 9,690 69,569 2069 35,070 10,327 669 13,649 9,664 69,378 2070 31,277 9,121 505 21,769 3,067 65,740 2071 31,159 9,084 499 22,021 2,862 65,626 2072 31,245 9,109 501 22,082 2,870 65,806 2073 20,832 5,518 349 11,714 5,201 43,614 2074 14,025 4,860 115 6

2,621 21,626 2075 4,649 1,809 26 0

147 6,631 399,325 102,464 17,748 153,663 106,565 779,764 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 23 of 23 TABLE 3.3 SCHEDULE OF ANNUAL EXPENDITURES HARDENED SAFSTOR (thousands, 2003 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2014 319 88 162 14 344 928 2015 453 126 230 20 489 1,318 2016 6,552 257 318 20 1,663 8,811 2017 30,224 1,558 669 1,301 5,450 39,202 2018 28,879 6,775 551 15,191 2,767 54,164 2019 29,556 7,710 499 19,072 3,179 60,016 2020 26,834 6,876 457 1G,515 3,828 54,510 2021 11,269 3,280 144 12 6,216 20,922 2022 9,260 3,851 60 2,532 15,703 2023 241 11 875 1,127 2024 242 12 877 1,131 2025 - 2101 18,564 885 67,421 86,870 2102 14,758 345 301 9

6,906 22,319 2103 33,476 2,373 669 876 8,831 46,224 2104 29,339 9,503 671 9,402 8,535 57,449 2105 28,934 9,834 669 9,897 8,998 58,331 2106 28,934 9,834 669 9,897 8,998 58,331 2107 28,934 9,834 669 9,897 8,998 58,331 2108 29,013 9,861 671 9,924 9,022 58,491 2109 27,506 6,917 547 12,791 4,325 52,087 2110 26,945 5,770 499 13,929 2,488 49,632 2111 26,945 5,770 499 13,929 2,488 49,632 2112 23,168 4,604 429 10,842 2,314 41,357 2113 9,021 1,792 114 6

475 11,408 2114 2,459 648 25 3,132 471,824 107,608 10,432 153,543 168,018 911,425 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page I of 7

4. SCHEDULE ESTIMATE The schedules for the decommissioning scenarios considered in this study follow the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints.

A schedule or sequence of activities is presented in Figure 4.1 through 4.3 for the three decommissioning scenarios. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project 2002" computer software.[26]

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 tables, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:

The dormancy period for each scenario begins on the TMI-1 shutdown date of April 19, 2014. The decommissioning preparation period for each scenario begins on the TMI-1 operating license termination date.

For the Custodial SAFSTOR

scenario, onset of delayed decommissioning activities is commensurate with the termination of the TMI-1 operating license, following its 60 year SAFSTOR scenario.

Therefore, the custodial dormancy period ends, and delayed decommissioning activities begin at TMI-2 in 2074.

For the Hardened SAFSTOR scenario, final site restoration is completed 100 years after termination of the TMI-1 operating license.

All work (except vessel and internals removal and some of the decontamination of NSSS components in the refueling canal) is per-formed during an 8-hour workday, 5 days per week, with no overtime.

There are eleven paid holidays per year.

Steam generator removal activities are performed on multiple shifts TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page 2 of 7 with limited parallel work on the A and B steam generators.

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

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

For all scenarios, reactor building basement decontamination using remote equipment will occur prior to the start of reactor coolant system component removal.

4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based upon the durations developed in the schedule for decommissioning TMI-2.

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.

Project timelines are provided in Figures 4.4 through 4.6.

TLG Services, Inc.

Three AMile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 4, Page 3 of 7 FIGURE 4.1 DELAYED DECON ACTIVITY SCHEDULE li:31: 1:014 =e 1:.,s 1:,=, ;=.,, 1.,:,4
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TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 4, Page 4 of 7 FIGURE 4.1 DELAYED DECON ACTIVITY SCHEDULE (continued)

'1a xace I I.

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cide L t Pen SSite ReslorasIon rec~e Rrmoh; i.& yj&;s cfeve as'irs.; Cc~vvetel TLG Services, Inc.

Three AMile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 4, Page 5 of 7 FIGURE 4.2 DECOMMISSIONING TIMELINE DELAYED DECON (not to scale)

TMI-1 (Shutdown April 19, 2014)

Spent Fuel Storage 04/2 Period 1 Transition and Preparations

.1.0.....2........5.....

2014 10/2015 Period 2 Dormancy Period 3 Delayed Preparations I

Period 4 Decommissioning Period 5 Site Restoration*1 07/2031 12/2032 06/2035 06/2037 Storage Pool Empty 12/2032 TAI1-2 Period 3 Transition and Preparations Period 4 Decommissioning Period 5 Site Restoration 0612024 12/2025 I

I I

06/2035 05/2036 08/2027 0412030 03/2031 NSSS Removal RPV Removal RX Bldg Removal TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 4, Page 6 of 7 FIGURE 4.3 DECOMMISSIONING TIMELINE CUSTODIAL SAFSTOR (not to scale)

TMI-1 (Shutdown April 19, 2014)

Spent Fuel Storage Period 1 Period 2 Period 3 Period 4 Transition and Dormancy Delayed Decommissioning Preparations I I Preparations I Period 5 Site Restoration 04/2014 10/2015 Storage Pool Empty 10/2019 07/2070 01/2072 04/2074 04/2076 ISFSI Empty 12/2032 TMI-2 Period 3 Transition and Preparations Period 4 Decommissioning 04/20G3 Period 5 Site Restoration 1 -- --.........- -

04/2074 0.

I.... -..... -. -. -

F-....-- -

1/2075 10/2064 12/2070 RX Bldg Removal TLG Services, Inc.

Three Mfile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 4, Page 7 of 7 FIGURE 4.4 DECOMMISSIONING TIMELINE HARDENED SAFSTOR (not to scale)

TMI-1 (Shutdown April 19, 2014)

..... ~

Pool and ISFSI Operations ISFSI Operations Period 1 Transition and Preparations.I..

Period 2 Decommissioning Period 3 Site Restoration ISFSI Operations ISFSI D&D

• I.

04120 14 10/2015 05/2021 05/2023 12/2032 07/2033 Storage Pool Empty 10/2019 TMI-2 Period 2 Period 3 Dormancy Transition and Pri-naratinn~q Period 4 Decommissioning (excluding Reactor Building)

Period 5 Interim Site Restoration 04i

.1...-*

'2014 10/2016 04/2018 08/2021 08lf

[Period 6 - Hardened SAFSTOR Dormancy 80 Years]

Period 7 Period 8 Seite Reactivate Site Decommissioning (Reactor Building)

RSitorto

......-..I......................

~....

.............. I.......................................

.....~...J............... -..........

!022 07/2 102 0I20 I

04I1 I421 04/2109 Reactor Building Rpmnval TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 1 of 6

5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[27] 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, §71 defines radioactive material as it pertains to packaging and transportation and §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 §173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in subpart 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.

Table 5.1 summarizes the categories of radioactive waste streams, the disposal rate, and the conditions which applied to each category.

The volumes of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in Appendices C, D, and E and summarized in Tables 5.2 through 5.4. The quantified waste volume summaries shown in these tables are consistent with §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, internals, other reactor coolant system components, and certain structural materials are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners or LSA boxes shipped within shielded vans. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload.

No process system containing/handling radioactive substances at the time of decommissioning is presumed to meet material release criteria by decay alone, i.e.,

systems radioactive in 2003 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.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 2 of 6

\\

~

The waste material generated in the decontamination and dismantling, of TMI-2 is primarily generated during Period 4 of the defined alternatives.

For purposes of constructing the estimates, the rate schedule for the Barnwell facility was used as a proxy for Class B and Class C waste. This schedule was used to estimate the disposal fees for plant components and concrete which are considered highly radioactive (unsuitable for processing or recovery).

TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 5, Page 3 of 6 TABLE 5.1 TMI-2 WASTE STREAM1S

SUMMARY

DELAYED DECON CUSTODIAL SAFSTOR CATEGORY HARDENED SAFSTOR Greater Than Class C (GTCC),

Selected RPV Internals and filters generated during RCS decon

($25,000/CF) activities.

Primary Waste, Class C, ($5.17ILB)

Demineralizer resins generated during RCS decon activities, (Barnwell non-Atlantic compact rate) block wall from basement dose reduction.

plus applicable administrative fees, millicurie surcharges and dose rate multipliers Primary Waste, Class B, ($5.17ILB)

Systems in the reactor building, concrete and liner from (Barnwell non-Atlantic compact rate) basement dose reduction, segmented S/G tubing, process of plus applicable administrative fees, liquid waste.

millicurie surcharges and dose rate multipliers Primary Waste, Class A, ($5.17ILB)

All other systems components.

(Barnwell non-Atlantic compact rate) plus applicable administrative fees, millicurie surcharges and dose rate multipliers Secondary Waste, Class A, ($3.21/LB)

Spent fuel racks, turbine, condenser, scaffolding, siding &

Containerized (Envirocare) roofing, cranes and structural steel.

Tertiary Waste, Class A, ($1.00/LB)

Contaminated soil, concrete scabble & rubble, concrete block.

Bulk sent for processing at Tennessee (excluding RB basement).

Tertiary Waste, DAW ($1.991LB)

All dry active waste (DAWN)

Processed Waste (off-site) ($1.99/LB)

Systems designated for recycling.

sent to Tennessee Construction Debris Exterior reactor, auxiliary and fuel handling building concrete (S50.00/TON) and structural steel (not including scabble and drill & spall concrete rubble) not utilized for backfill.

TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 5, Page 4 of 6 TABLE 5.2 DECOMMISSIONING WASTE

SUMMARY

DELAYED DECON Volume (cubic feet)

Weight (pounds)

Class Geologic Repository GTCC 1,252 166,120 Primary Waste Stream[']

C B

A 3,364 19,578 87,837 269,715 1,860,997 7,781,924 4,399,190 Secondary Waste Streaml2j A

58,836 Tertiary Waste Stream[3]

Concrete Soil DAW A

A A

341,878 48,992 18,352 35,969,146 3,723,414 367,755 Survey & Release[4]

850,136 Total 580,088 55,388,397 4,298,378 Processed Waste (Off-Site) 71,277 Scrap Metal 59,388,000 II] Primary waste buried at E-Care with Barnwell price structure 121 Secondary waste buried at E-Care with containerized rates 13] Tertiary waste sent to LLRW processor 141 Systems scrap sent to E-Care for survey and release TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 5, Page 5 of 6 TABLE 5.3 DECOMMISSIONING WASTE

SUMMARY

CUSTODIAL SAFSTOR Volume (cubic feet)

Weight (pounds)

Class Geologic Repository GTCC 1,252 166,120 Primary Waste Stream[']

C B

A 3,364 19,422 87,195 Secondary Waste Streamf2l Tertiary Waste Stream[31 Concrete Soil DAW A

58,836 269,715 1,841,367 7,721,561 4,399,190 35,969,146 3,723,414 682,662 A

A A

341,878 48,992 34,066 Survey & Release[4]

850,136 Total 595,005 55,623,311 4,354,639 Processed Waste (Off-Site) 71,919 Scrap Metal 59,388,000 II] Primary waste buried at E-Care with Barnwell price structure 121 Secondary waste buried E-Care with containerized rates 131 Tertiary waste sent to LLRW processor 141 Systems scrap sent to E-Care for survey and release TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 5, Page 6 of 6 TABLE 5.4 DECOMMISSIONING WASTE

SUMMARY

HARDENED SAFSTOR Volume (cubic feet)

Weight (pounds)

Class (ions Geologic Repository GTCC 1,252 166,120 Primary Waste Stream[']

C B

A 3,364 19,518 86,845 Secondary Waste Stream[2]

Tertiary Waste Stream 13 ]

Concrete Soil DAW A

59,210 269,715 1,853,394 7,688,252 4,432,697 35,969,146 3,723,414 329,754 850,136 A

A A

341,878 48,992 16,455 Survey & Release[4]

Total 577,513 Processed Waste (Off-Site) 78,268 55,282,628 4,655,897 59,388,000 Scrap Metal I[] Primary waste buried at E-Care with Barnwell price structure 121 Secondary waste buried at E-Care with containerized rates 131 Tertiary waste sent to LLRW processor 141 Systems scrap sent to E-Care for survey and release TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page I of5

6. RESULTS The analysis to estimate the costs to decommission TMI-2 relied upon the site-specific, technical information developed for a previous analysis prepared in 1995-

96. While not an engineering study, the estimates provide FirstEnergy with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The estimates described in this report are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, radioactive waste disposal options, and site remediation requirements. The decommissioning scenarios assume that the remainder of the spent fuel Oess than 1%), which is dispersed throughout the reactor coolant and support systems, is packaged, shipped and buried as radioactive waste. Some of the waste that is generated is assumed to be GTCC. This waste is assumed to be transferred to the DOE at the time that it is processed and collected during the decommissioning. No costs have been included for the temporary storage of GTCC material.

The cost projected to decommission TMI-2, i.e., by the Delayed DECON alternative, is estimated to be $729.0 million. The majority of this cost (approximately 97%) is associated with the physical decontamination and dismantling of the nuclear unit so that the license can be terminated. The remaining 3% is for the demolition of the designated structures and limited restoration of the site. The costs for the deferred decommission alternatives, Custodial SAFSTOR and Hardened SAFSTOR, are estimated at $779.8 million and $911.4 million, respectively.

The primary cost contributors, identified in Tables 6.1 through 6.3, 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 FirstEnergy will oversee the decommissioning program, using a DOC to manage the decommissioning labor force and the associated subcontractors. The size and composition of the management organization varies with the decommissioning phase and associated site activities.

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

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 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of5 material, filters, resins and dry-active waste. As described in Section 5, disposal of the lower level material, including concrete and structural steel, is at the Envirocare facility. The more highly radioactive material is sent to the Envirocare facility but using surrogate Barnwell waste burial rates. Highly contaminated components, requiring additional isolation from the environment, are packaged for geologic disposal. The cost of geologic disposal is assumed to be $25,000 per cubic foot.

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

Decontamination and packaging costs also have a large labor component that is based upon prevailing union wages. Non-radiological demolition is a natural extension of the decommissioning process.

The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage.

With a work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license.

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

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

Due to the complete removal of the reactor, auxiliary and fuel buildings, the final termination survey effort is reduced.

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.

TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 6, Page 3 of 5 TABLE 6.1

SUMMARY

OF DECOMMISSIONING COST ELEMENTS DELAYED DECON (thousands of 2003 dollars)

Work Category Cost IIl o

Decontamination Removal Packaging Transportation Waste Disposal Off-site Waste Processing Program Management [2]

Insurance and Regulatory Fees Energy Characterization and Licensing Surveys U

Property Taxes Miscellaneous Equipment Site O&M 32,555 111,729 17,017 8,725 179,451 9,837 318,039 13,997 8,815 6,128 19,576 3,157 4.5%

15.3%

2.3%

1.2%

24.6%

1.3%

43.6%

1.9%

1.2%

0.8%

0.0%

2.7%

0.4%

Total 13]

NRC License Termination Site Restoration 729,026 100.0%

96.8%

3.2%

705,400 23,625

[1] Includes dormancy costs following TMI-1 shutdown in 2014 121 Includes engineering and security

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

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 6, Page 4 of 5 TABLE 6.2

SUMMARY

OF DECOMMISSIONING COST ELEMENTS CUSTODIAL SAFSTOR (thousands of 2003 dollars)

Wtork Category Cost [I Decontamination Removal Packaging Transportation Waste Disposal Off-site Waste Processing Program Management [2]

Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment Site O&M 32,518 116,450 17,191 8,714 179,716 9,966 335,630 26,339 17,748 6,128 26,209 3,157 4.2%

14.9%

2.2%

1.1%

23.0%

1.3%

43.0%

3.4%

2.3%

0.8%

0.0%

3.4%

0.4%

Total [3]

NRC License Termination Site Restoration 779,764 100.0%

97.0%

3.0%

756,139 23,625

[11 Includes dormancy costs following TMI-1 shutdown in 2014 121 Includes engineering and security

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

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Section 6, Page 5 of 5 TABLE 6.3

SUMMARY

OF DECOMMISSIONING COST ELEMENTS HARDENED SAFSTOR (thousands of 2003 dollars)

Work Category Cost [i]

0/

Decontamination Removal Packaging Transportation Waste Disposal Off-site Waste Processing Program Management 12]

Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment Site O&M Off-site Monitoring & Security Services 33,306 121,156 17,052 8,836 179,144 10,655 407,918 40,155 10,432 6,660 27,219 2,927 45,965 3.7%

13.3%

1.9%

1.0%

19.7%

1.2%

44.8%

4.4%

1.1%

0.7%

0.0%

3.0%

0.3%

5.0%

Total 13]

NRC License Termination Site Restoration 911,425 100.0%

96.3%

3.7%

877,525 33,899

[1] Includes dormancy costs following TMI-1 shutdown in 2014 121 Includes engineering and security 13] Columns may not add due to rounding TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 1 of3

7. REFERENCES

1.

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

2.

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

3.

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

4.

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

5.

U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors,"

Nuclear Regulatory Commission, Federal Register Volume 61 (p 39278 et seq.), July 29, 1996.

6.

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

7.

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

8.

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

9.

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.

10.

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

11.

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."

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 2 of3

7. REFERENCES (continued)

12.

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

13.

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

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

14.

"Decommissioning Cost Estimate for the Three Mile Island, Unit 2," Document No. G01-1196-003, TLG Services, Inc., February 1996.

15.

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

16.

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

Department of Energy, DOEJEV/10128-1, November 1980.

17.

"Building Construction Cost Data 2003," Robert Snow Means Company, Inc.,

Kingston, Massachusetts.

18.

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

19.

"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.

20.

U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 1996.

21.

Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-109397 and Supplements, 2000.

22.

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.

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 3 of3

7. REFERENCES (continued)

23.

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.

24.

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.

25.

"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.

26.

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

27.

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

TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Appendix A, Page I of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 2 of4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example:

Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1.

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

2.

CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes)

(minutes)*

a Remove insulation 60 (b) b Mount pipe cutters 60 60 c

Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e

Cap openings 20 (d) f Rig for removal 30 30 g

Unbolt from mounts 30 30 h

Remove contamination controls 15 15 i

Remove, wrap, send to waste processing area 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):

+ Respiratory protection adjustment (25% of critical duration) 64

+ Radiation/ALARA adjustment (25% of critical duration) 64 Adjusted work duration 383

+ Protective clothing adjustment (30% of adjusted duration) 115 Productive work duration 498

+ Work break adjustment (8.33 % of productive duration) 42 Total work duration (minutes) 540

• • • Total duration = 9.0 hr ***

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

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Appendix A, Page 3 of4 APPENDIX A (continued)

3.

LABOR REQUIRED Crew Number Duration (hours)

Rate

($/hr)

Cost Laborers Craftsmen Foreman General Foreman Fire Watch Health Physics Technician 3.00 2.00 1.00 0.25 0.05 1.00 9.00 9.00 9.00 9.00 9.00 9.00

$22.16

$37.95

$38.31

$39.39

$22.16

$36.12

$598.32

$683.10

$344.79

$88.63

$9.97

$325.08 Total labor cost

$2,049.89

4.

EQUIPMENT & CONSUMABLES COSTS U Equipment Costs none Consumables/Materials Costs

-Absorbent sheets 50 @ $0.37 sq ft {2}

$18.50

-Plastic sheets/bags 50 @ $0.09/sq ft {3}

$4.50

-Gas torch consumables 1 @ $3.66/hr x 1 hr {1}

S3.66 Subtotal cost of equipment and materials

$26.66 Overhead & profit on equipment and materials @ 16.00 %

$4.27 Total costs, equipment & material

$30.93 TOTAL COST:

Removal of contaminated heat exchanger <3000 pounds:

$2,080.82 Total labor cost:

Total equipment/material costs:

Total craft labor man-hours required per unit:

$2,049.89

$30.93 65.700 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 4 of4

5.

NOTES AND REFERENCES

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

• References for equipment & consumables costs:

1. www.mcmaster.com online catalog, item 7193785

2. R.S. Means (2003) Section 01540-800-0200, page 17

3. R.S. Means (2003) Section 01590-400-6360, page 25

• Material and consumable costs were adjusted using the regional indices for Harrisburg, Pennsylvania.

TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Appendix B, Page 1 of 8 APPENDIX B UNIT COST FACTOR LISTING (SAFSTOR: Power Block Structures Only)

TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476.002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 2 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.44 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 3.79 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 5.42 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 11.99 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 21.58 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 28.00 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 41.03 Removal of clean pipe >36 inches diameter, $/linear foot 49.04 Removal of clean valves >2 to 4 inches 80.25 Removal of clean valves >4 to 8 inches 119.89 Removal of clean valves >8 to 14 inches 215.80 Removal of clean valves >14 to 20 inches 280.01 Removal of clean valves >20 to 36 inches 410.30 Removal of clean valves >36 inches 490.35 Removal of clean pipe hangers for small bore piping 25.99 Removal of clean pipe hangers for large bore piping 82.71 Removal of clean pumps, <300 pound 200.32 Removal of clean pumps, 300-1000 pound 544.34 Removal of clean pumps, 1000-10,000 pound 1,933.01 Removal of clean pumps, >10,000 pound 3,731.22 Removal of clean pump motors, 300-1000 pound 234.55 Removal of clean pump motors, 1000-10,000 pound 807.83 Removal of clean pump motors, >10,000 pound 1,816.10 Removal of clean heat exchanger <3000 pound 1,090.00 Removal of clean heat exchanger >3000 pound 2,731.25 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 3 of 8 APPENDIX B (continued)

Unit Cost Factor CostlUnit($)

Removal of clean tanks, <300 gallons 258.11 Removal of clean tanks, 300-3000 gallon 813.01 Removal of clean tanks, >3000 gallons, $/square foot surface area 6.51 Removal of clean electrical equipment, <300 pound 113.98 Removal of clean electrical equipment, 300-1000 pound 378.88 Removal of clean electrical equipment, 1000-10,000 pound 751.81 Removal of clean electrical equipment, >10,000 pound 1,727.99 Removal of clean electrical transformers < 30 tons 1,220.25 Removal of clean electrical transformers > 30 tons 3,456.01 Removal of clean standby diesel-generator, <100 kW 1,226.98 Removal of clean standby diesel-generator, 100 kW to 1 MW 2,736.78 Removal of clean standby diesel-generator, >1 MW 5,664.58 Removal of clean electrical cable tray, $/linear foot 10.17 Removal of clean electrical conduit, $/linear foot 4.34 Removal of clean mechanical equipment, <300 pound 113.98 Removal of clean mechanical equipment, 300-1000 pound 378.88 Removal of clean mechanical equipment, 1000-10,000 pound 751.81 Removal of clean mechanical equipment, >10,000 pound 1,727.99 Removal of clean HVAC equipment, <300 pound 113.98 Removal of clean HVAC equipment, 300-1000 pound 378.88 Removal of clean HVAC equipment, 1000-10,000 pound 751.81 Removal of clean HVAC equipment, >10,000 pound 1,727.99 Removal of clean HVAC ductwork, $/pound 0.47 Removal of contaminated instrument and sampling tubing, $/linear foot 0.74 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 10.23 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07.1476-002, Rev. 0 Appendix B, Page 4 of 8 APPENDIX B (continued)

Unit Cost Factor Cost/Unit($)

Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 17.14 28.56 55.09 66.22 91.11 Removal of contaminated pipe >36 inches diameter, $/linear foot Removal of contaminated valves >2 to 4 inches Removal of contaminated valves >4 to 8 inches Removal of contaminated valves >8 to 14 inches I, Removal of contaminated valves >14 to 20 inches 108.23 216.80 262.46 524.24 665.85 Removal of contaminated valves >20 to 36 inches Removal of contaminated valves >36 inches Removal of contaminated pipe hangers for small bore piping Removal of contaminated pipe hangers for large bore piping Removal of contaminated pumps, <300 pound 884.46 1,055.67 57.86 178.72 456.75 Removal of contaminated pumps, 300-1000 pound Removal of contaminated pumps, 1000-10,000 pound Removal of contaminated pumps, >10,000 pound Removal of contaminated pump motors, 300-1000 pound Removal of contaminated pump motors, 1000-10,000 pound 1,078.72 3,502.62 8,509.97 465.25 1,424.97 Removal of contaminated pump motors, >10,000 pound Removal of contaminated heat exchanger <3000 pound Removal of contaminated heat exchanger >3000 pound Removal of contaminated feedwater heater/deaerator Removal of contaminated moisture separator/reheater 3,217.15 2,080.82 6,026.77 15,056.14 26,111.62 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 5 of8 APPENDIX B (continued)

Unit Cost Factor CostlUnit($)

Removal of contaminated tanks, <300 gallons 763.75 Removal of contaminated tanks, >300 gallons, $/square foot 15.47 Removal of contaminated electrical equipment, <300 pound 358.79 Removal of contaminated electrical equipment, 300-1000 pound 870.49 Removal of contaminated electrical equipment, 1000-10,000 pound 1,671.71 Removal of contaminated electrical equipment, >10,000 pound 3,354.84 Removal of contaminated electrical cable tray, $/linear foot 17.45 Removal of contaminated electrical conduit, $/linear foot 7.98 Removal of contaminated mechanical equipment, <300 pound 403.95 Removal of contaminated mechanical equipment, 300-1000 pound 984.71 Removal of contaminated mechanical equipment, 1000-10,000 pound 1,894.16 Removal of contaminated mechanical equipment, >10,000 pound 3,354.84 Removal of contaminated HVAC equipment, <300 pound 403.95 Removal of contaminated HVAC equipment, 300-1000 pound 984.71 Removal of contaminated HVAC equipment, 1000-10,000 pound 1,894.16 Removal of contaminated HVAC equipment, >10,000 pound 3,354.84 Removal of contaminated HVAC ductwork, $/pound 1.66 Removal/plasma arc cut of contaminated thin metal components, $/linear in.

1.96 Additional decontamination of surface by washing, $/square foot 3.82 Additional decontamination of surfaces by hydrolasing, $/square foot 19.04 Decontamination rig hook-up and flush 3,412.11 Chemical flush of components/systems, $/gallon 9.35 Removal of clean standard reinforced concrete, $/cubic yard 64.56 Removal of grade slab concrete, $/cubic yard 153.84 Removal of clean concrete floors, $/cubic yard 245.31 TLG Services, Inc.

Three Mile Island Unit 2 Document F07-1476-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 6 of 8 APPENDIX B (continued)

Unit Cost Factor Cost!Unit($)

Removal of contaminated standard rein concrete floors, $/cubic yard 742.72 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 165.67 Removal of contaminated heavily rein concrete w/9 rebar, $/cubic yard 1,020.68 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 209.75 Removal of contaminated heavily rein concrete wlM18 rebar, $/cubic yard 1,346.38 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cu yd 317.36 Removal of below-grade suspended floors, $/cubic yard 245.31 Removal of clean monolithic concrete structures, $/cubic yard 607.24 Removal of contaminated monolithic concrete structures, $/cubic yard 1,019.30 Removal of clean foundation concrete, $/cubic yard 482.21 Removal of contaminated foundation concrete, $/cubic yard 948.21 Explosive demolition of bulk concrete, $/cubic yard 22.42 Removal of clean hollow masonry block wall, $/cubic yard 74.53 Removal of contaminated hollow masonry block wall, $/cubic yard 132.12 Removal of clean solid masonry block wall, $/cubic yard 74.53 Removal of contaminated solid masonry block wall, $/cubic yard 132.12 Backfill of below-grade voids, $/cubic yard 13.58 Removal of subterranean tunnels/voids, $/linear foot 112.56 Placement of concrete for below-grade voids, $/cubic yard 79.53 Excavation of clean material, $/cubic yard 2.32 Excavation of contaminated material, $/cubic yard 20.19 Excavation of submerged concrete rubble, $/cubic yard 10.75 Removal of clean concrete rubble (tipping fee included), $/cubic yard 74.99 Removal of contaminated concrete rubble, $/cubic yard 16.10 Removal of building by volume, $/cubic foot 0.20 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Appendix B, Page 7 of 8 APPENDIX B (continued)

Unit Cost Factor CostfUnit($)

Removal of clean building metal siding, $/square foot Removal of contaminated building metal siding, $/square foot Removal of standard asphalt roofing, $/square foot Removal of transite panels, $/square foot Scarifying contaminated concrete surfaces (drill & spall)

Scabbling contaminated concrete floors, $/square foot Scabbling contaminated concrete walls, $/square foot Scabbling contaminated ceilings, $/square foot Scabbling structural steel, $/square foot Removal of clean overhead cranes/monorails < 10 ton capacity 1.27 2.25 1.71 1.94 7.23 3.89 4.36 39.25 3.46 556.60 Removal of contaminated overhead cranes/monorails < 10 ton capacity Removal of clean overhead cranes/monorails >10-50 ton capacity Removal of contaminated overhead cranes/monorails >10-50 ton capacity Removal of polar cranes > 50 ton capacity, each Removal of gantry cranes > 50 ton capacity, each Removal of clean structural steel, $/pound Removal of clean steel floor grating, $/square foot Removal of contaminated steel floor grating, $/square foot Removal of clean free-standing steel liner, $/square foot Removal of contaminated free-standing steel liner, $/square foot Removal of clean concrete-anchored steel liner, $/square foot Removal of contaminated concrete-anchored steel liner, $/square foot Placement of scaffolding in clean areas, $/square foot Placement of scaffolding in contaminated areas, $/square foot Landscaping with topsoil, $/acre 952.25 1,337.28 2,773.71 4,857.02 19,694.14 0.27 2.83 5.01 9.88 17.96 4.88 20.87 10.80 13.70 13,678.47 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Appendix B, Page 8 of 8 APPENDIX B (continued)

Unit Cost Factor Cost/Unit($)

Cost of CPC B-88 LSA box & preparation for use Cost of CPC B-25 LSA box & preparation for use Cost of CPC B-12V 12 gauge LSA box & preparation for use Cost of CPC B-144 LSA box & preparation for use Cost of LSA drum & preparation for use Cost of cask liner for CNSI 14-195 cask Cost of cask liner for CNSI 8-120A cask (resins)

Cost of cask liner for CNSI 8-120A cask (filters)

Decontamination of surfaces with vacuuming, $/square foot 935.30 747.84 644.26 3,529.49 111.66 7,258.27 5,078.59 5,078.59 0.59 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev.0 Appendix C, Page 1 of 8 APPENDIX C DETAILED COST ANALYSIS DELAYED DECON TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 Appendix D, Page 1 of 9 APPENDIX D DETAILED COST ANALYSIS CUSTODIAL SAFSTOR (9.1 TLG Services, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1476-002, Rev. 0 AppendixE, Page 1 of 12 APPENDIX E DETAILED COST ANALYSIS HARDENED SAFSTOR 0,

TLG Services, Inc.