ML082170672

Report, E11-5690-003, Preliminary Decommissioning Cost Analysis for the Pilgrim Nuclear Power Station.

ML082170672
Person / Time
Site:	Pilgrim
Issue date:	07/16/2008
From:	TLG Services
To:	Entergy Nuclear Operations, Office of Nuclear Reactor Regulation
References
2.08.034, FOIA/PA-2009-0026, TAC MD8205, FOIA/PA-2013-0151 E11-5690-003
Download: ML082170672 (56)

Text

Document Ell-5690-003 PRELIMINARY DECOMMISSIONING COST ANALYSIS for the PILGRIM NUCLEAR POWER STATION preparedfor Entergy Nuclear preparedby TLG Services, Inc.

Bridgewater, Connecticut July 2008

PilgrimNuclearPower Station DocumentEll-5690-003 PreliminaryDecommissioningCostAnalysis Pageii of v APPROVALS Project Manager 1DtTIa William A. Cloutier, Jr. Date Project Engineer Thomas J./Garre Date Geoffr M ifih Technical Manager Date Quality Assurance Manager Jr JA

' r

• TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page iii of v TABLE OF CONTENTS SECTION PAGE

1. DECOMMISSIONING COST ANALYSIS............................................................ 1 1.1 Decommissioning Alternatives .................................. 2 1.2 Regulatory Guidance ......................... ................ 2 1.3 B asis of Cost E stim ate ............................................................................. ............. 3

.1.4 M ethodology ............................. ....................................................................... 4 1.5 Impact of Decommissioning Multiple Reactor Units .................................. 5 1.6 Financial Components of the Cost Model ..................................................... 6 1.6.1 C ontin gency ........................................................................................... 6 1.6.2 Financial Risk ....................................................................................... 7 1.7 Site-Specific Considerations ....... *............................. 8 1.7.1 Spent Fuel D isposition ......................................................................... 8 1.7.2 Reactor Vessel and Internal Components ....................................... 12

.1.7.3 Primary System Components ............................................................ 12 1.7.4 R etired Com ponents ........................................................................... 13 1.7.5 Main Turbine and Condenser ............................................................ 13 1.7.6 Transportation M ethods .................................................................... 13 1.7.7 Low-Level Radioactive Waste Conditioning and Disposal .............. 14 1.7.8 Site Conditions Following Decommissioning ................................... 16 1.8 A ssumption s .................................................................................................... 17 1.8.1 Estimating Basis ...................................... 17 1.8.2 Site Contamination .................................... 17 1.8.3 Release Criteria .................................................................................. 17 1.8.4 Labor Costs .......................................... 18 1.8.5 D esign C onditions ........................................................................... ........ 18 1.8.6 G eneral ................................................................................................. 19

2. R E S U L TS ................................................................................................................... 22 2.1 Escalation of the 2005 Costs to 2007 Dollars ....................... 23 2.2 Financial A ssurance ....................................................................................... 23 FIGURE Decom m issioning Tim eline ............................................................................. 25 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page iv of v TABLE OF CONTENTS SECTION PAGE TABLES 1 Low-Level Radioactive Waste Disposition ....................................................... 26 2 Summary of M ajor Cost Contributors ............................................................ 27 3 Schedule of Annual Expenditures, Total Decommissioning Cost .......... 28 4 Schedule of Annual Expenditures, License Termination Allocation ............. 30 5 Schedule of Annual Expenditures, Spent Fuel Management Allocation ........... 32 6 Schedule of Annual Expenditures, Site Restoration Allocation .................... 34 7 Schedule of Annual Expenditures, License Termination and Spent Fuel Management Allocations (from Tables 4 and 5)............................................. 36 8 Funding Requirements to Equal Expected Expenditures ............................ 38 APPENDIX A. 2005 Detailed Cost Analysis .............................................................................. A -1 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690.003 PreliminaryDecommissioning Cost Analysis Page v of v REVISION LOG No. jCRA No. Date Item Revised,: Reason f6rRevision 07-16-2008 TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page I of 39

1. DECOMMISSIONING COST ANALYSIS This document presents the cost to decommission the Pilgrim Nuclear Power Station (Pilgrim) assuming a cessation of operations after a nominal 40-year operating life in 2012. In accordance with the requirements of 10 CFR 50.75(f)(3), the cost estimate includes an assessment of the major factors that could affect the cost to decommission the Pilgrim nuclear unit.

The costs (presented in 2007 dollars) are based upon a site-specific estimate originally prepared in 2005 for Entergy Nuclear. The 2005 estimate reflected a 60-year operating life scenario, with shutdown in 2032 followed by prompt decommissioning. The scenario was revised in 2006 for a 40-year operating life and deferred decommissioning. The revised estimate was used as the basis for the Company's spent fuel management plan filed in 2007 (in accordance with 10 CFR 50.54(bb)).[1 ]

The estimate presented in this document escalates the 2006 cost estimate to 2007 dollars for consistent year comparison with the Company's latest filing on'the status of the Pilgrim Station decommissioning trust fund. [21 The current cost to decommission Pilgrim is estimated at $914.4 million (in 2007 dollars). The cost includes the monies anticipated to be spent for operating license termination, spent fuel storage and site restoration activities. The cost is based on several key assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, performance uncertainties (contingency) and site restoration requirements. Many of these assumptions are discussed in more detail in this document.

It is the current plan, based on the growth of the funds in the Pilgrim decommissioning trust, to fund the expenditures for license termination and spent fuel management from the currently existing decommissioning trust fund and from proceeds from spent fuel litigation against the Department of Energy (DOE).

Expenditures from the trust fund for the management of the spent fuel, until it can be transferred to the DOE, will not reduce the value of the decommissioning trust fund to below the amount necessary to place and maintain the reactor in safe storage and will not adversely affect the licensee's ability to ultimately release the site and terminate the license. The licensee acknowledges that it may be necessary to request an exemption pursuant to 10 CFR 50.12(a) to use trust funds for anything beyond decommissioning activities as defined in 10 CFR 50.2.

1 Entergy Nuclear Operations submittal of its "Sprent Fuel Management Plan" to the Nuclear Regulatory Commission, Letter No. 2.07.055, dated June 7, 2007 2 Entergy Nuclear Operations submittal of its "Decommissioning Fund Status Report" to the Nuclear Regulatory Commission, Letter No. ENOC-08-00018, dated March 26, 2008 TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page2 of 39 1.1 DECOMMISSIONING ALTERNATIVES The Nuclear Regulatory Commission (NRC) provided general decommissioning guidance in a rule adopted on June 27, 1988.[31 In this rule, the NRC set forth technical and financial criteria for decommissioning licensed nuclear facilities.

The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB.

DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations."[4]

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 5

decontamination) to levels that permit release for unrestricted use."[ ]

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."[6] As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

1.2 REGULATORY GUIDANCE In 1996, the NRC published revisions to its general requirements for decommissioning nuclear, power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in 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.

4 Ibid. Page FR24022, Column 3 5 Ibid.

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

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 3 of 39 the decommissioning process.[7] The amendments allow for greater public participation and better define the transition process from operations to decommissioning. Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures that are acceptable to the NRC staff for implementing the requirements of the 1996 revised rule that relate to the initial activities and the major phases of the decommissioning process. The Pilgrim cost estimate follows the general guidance and sequence presented in the amended regulations.

1.3 BASIS OF COST ESTIMATE For the purpose of the analysis, Pilgrim is assumed to cease operations in June 2012 after 40 years of operations. The unit would then be placed in safe-storage

'(SAFSTOR), with the spent fuel relocated to an Independent Spent Fuel Storage Installation (ISFSI) to await the transfer to a Department of Energy (DOE) facility. Based upon a 2017 start date for the pickup of spent fuel from the commercial industry, Entergy anticipates that the removal of the Pilgrim fuel from the site could be completed by the year 2042. At that time, the plant would be decommissioned and the site released for alternative use without restriction.

This sequence of events is delineated in Figure 1 along with major milestone dates.

The 2005 estimate was developed using the site-specific, technical information relied upon in the decommissioning assessment prepared in 2002.[8] The site-specific considerations and assumptions used in the previous evaluation were revisited. Modifications were incorporated where new information was available or experience from recent decommissioning projects provided viable alternatives or improved processes.

The 2005 estimate evaluated a scenario based upon renewal of the operating license with operations continuing through 2032. At that time the unit would be promptly decommissioned. In 2006, the estimate was revised to reflect its current operating license (without license renewal) and a 2012 shutdown date.

Economic components of the estimate were escalated to 2006 dollars and the spent fuel management plan modified for an earlier shutdown date. The current estimate escalates the 2006 base year estimate to 2007 dollars. No other changes were made to the 2006 estimate for purposes of this analysis.

7 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.

8 TLG Document No. E11-1430-002, December 19, 2002 TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page4 of 39

• 1.4 METHODOLOGY The methodology used to develop the estimate, followed the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[9] and the DOE "Decommissioning Handbook."[110 These documents present a unit cost factor method for estimating decommissioning activity costs that simplifies the 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 then estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures relied upon information available in the industry publication, "Building Construction Cost Data," published by R.S.

Means. [11]

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.

This analysis reflected lessons learned from TLG's involvement in the Shippingport Station decommissioning, 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, Connecticut Yankee, and San Onofre-t1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

Work Difficulty Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment. WDFs T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986 10 W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980

• "Building Construction Cost Data 2005," Robert Snow Means Company, Inc., Kingston, Massachusetts TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 5 of 39 are assigned to each unique set of unit factors, commensurate with the working conditions. The ranges used for the WDFs were as follows:

• Access Factor 0% to 30%

• Respiratory Protection Factor 0% to 50%

• Radiation/ALARA Factor 0% to 100%

• Protective Clothing Factor 0% to 50%

• Work Break Factor 8.33%

The factors and their associated range of values were originally developed in conjunction with the AIF/NESP-036 study.

Scheduling Prog-ram Durations Activity durations are used to develop the total decommissioning program schedule. The unit cost factors, adjusted for WDFs as described above, are applied against the inventory of materials to be removed. The work area (or building area) is then evaluated for the most efficient number of workers/crews for the identified decommissioning activities. The adjusted unit cost factors are then compared against the available manpower so that an overall duration for removal of components and piping from each work area can be calculated.

The schedule is used to assign carrying costs, 'Which include program management, administration, field engineering, equipment rental, and support services such as quality control and security.

1.5 IMPACT OF DECOMMISSIONING MULTIPLE REACTOR UNITS In estimating the near simultaneous decommissioning of similar and regional reactor units there can be opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities.

The Entergy Northeast fleet currently consists of three Mark I design BWRs (Pilgrim, Vermont and FitzPatrick) with shutdown dates of 2012, 2012 and 2014, respectively.

The cost model assumes that Entergy will manage the decontamination and dismantling of Pilgrim, directly supervising the field crews. Specialty contractors would be engaged as needed to support the project or to provide project critical skills. As part of a fleet of reactors in the northeast, it was also assumed that Pilgrim would benefit from certain synergies (planning, engineering, contracting, and administration). As such, the program management labor costs (excluding security) were reduced 5% to reflect such anticipated savings.

TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page6 of 39 1.6 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 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.

1.6.1 Contingency Consistent with standard cost estimating practices, contingencies were applied to the decontamination and dismantling costs developed as a "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."[121 The cost elements in the estimate were based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, were 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 remaining operating life of the nuclear unit.

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 the detailed estimate. The composite contingency value reported for the SAFSTOR scenario, and as shown in the detail table in Appendix A, was 17.34%.

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

TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 7 of 39 1.6.2 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:

Transition activities and costs: ancillary expenses associated with eliminating 50% to 80% of the site labor force shortly after the cessation of plant operations, added cost for worker separation packages throughout the decommissioning program, national or company-mandated retraining, and retention incentives for key personnel.

Delays in approval of the decommissioning plan due to intervention, 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).

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

Pricing changes for basic inputs,' such as labor, energy, materials, and burial.

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 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page8 of 39 the cost of labor (both craft and staff). This cost study, however, does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities.

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

1.7 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 impacts of the considerations identified below were included within the estimate.

1.7.1 Spent Fuel Disposition Congress passed the "Nuclear Waste Policy Act"[131 (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high-level radioactive waste and utilities would pay the cost of the disposition services for that material. NWPA, along with the individual contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

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

Operation of DOE's yet-to-be constructed repository is contingent upon the review and approval of the facility's license application by the NRC, the successful resolution of pending litigation, and the development of a national transportation system. The DOE submitted its license application to the NRC on June 3, 2008, seeking authorization to construct the repository at Yucca Mountain, Nevada. Assuming a timely review, DOE expects that receipt of fuel could begin as early as 2017,[14] depending upon the level of funding appropriated by Congress.

13 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982.

14 "DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's TLG Services, Inc.

PilgrimNuclear Power Station Document E11-5690-003 PreliminaryDecommissioningCost Analysis Page 9 of 39 It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. The NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the DOE, pursuant. to 10 CFR Part 50.54(bb).[15 1 This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, costs associated with the isolation and continued operation of the spent fuel pool and construction and operation of an ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over a period of five and one-half years following shutdown, the assemblies are packaged into multipurpose canisters for transfer to the ISFSI. It is assumed that this period provides the necessary cooling for the final core to meet the design requirements for decay heat.

DOE's contracts with utilities generally order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. For purposes of this. analysis, acceptance of commercial spent fuel by the DOE was 'expected to begin in 2017. The first assemblies removed from the Pilgrim site are assumed to be in 2019. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year, completion of the removal of fuel from the site is projected to be in the year 2042.

An ISFSI, which can be operated under the Station's general license, is assumed to be constructed to permit post-shutdown dry fuel storage. Once the pool is emptied, the spent fuel storage and handling facilities are placed into safe-storage.

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

Office of Public Affairs, Press Release July 19, 2006

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

TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 10 of 39 ISFSI In the assumed scenario, 3,594 assemblies are generated through the.

end of currently licensed operations in 2012. An ISFSI is constructed within the owner controlled area to permit post-shutdown dry fuel storage. The assemblies stored in the reactor building's spent fuel storage pool at the time of shutdown are loaded into multi-purpose canisters (MPCs) and moved into storage casks on the new pad by late 2017. The MPCs are periodically off-loaded into a DOE transport cask such that all canisters are removed from the site by the year 2042.

Entergy Nuclear's analysis assumes, for purposes only of this report, that Entergy Nuclear does not employ DOE spent fuel disposal contract allowances for up to 20% additional fuel designation for shipment to DOE each year.

The estimate includes the cost to build the ISFSI pad, transporter' path, and security systems and support facilities. Once completed, Entergy anticipates loading 53 MPCs with the assemblies stored in the reactor building's spent fuel pool. The MPCs will then be placed in storage casks on the ISFSI.

In the absence of identifiable DOE transport cask requirements, the design and capacity of the new ISFSI is based upon a commercial dry cask storage system. It should be noted that Entergy's contract with the DOE requires DOE to provide transport canisters to Entergy, but for present purposes, this estimate includes this cost.

Storage Canister Design The design and capacity of the ISFSI is based upon the Holtec. HI-STORM dry cask storage system. The Holtec multi-purpose canister or MPC has a capacity of 68 fuel assemblies.

Canister Loading and Transfer The estimate includes the costs to purchase, load, and transfer the MPCs from the pool to the ISFSI. Costs are also included for the transfer of the fuel at the ISFSI into a DOE transport cask.

TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 11 of 39 Operations and Maintenance The estimate includes costs for the operation of the spent fuel pool until it is emptied and the operation of the ISFSI until the spent fuel is transferred to the DOE.

The ISFSI operating duration is based upon the previously stated assumptions on fuel transfer schedule expectations.

ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a vertical, reinforced concrete storage silo is used as a basis for this cost analysis. Approximately 50% of the silos are assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel (i.e., to levels exceeding free-release limits). Approximately 10%

of the concrete and steel is assumed to be removed from the overpacks for controlled disposal. The cost of the disposition of this material, as well as the demolition of the ISFSI facilities, is reflected within the estimate.

Greater-than-Class C (GTCC)

The dismantling .of the reactor internals generates radioactive waste considered unsuitable for shallow land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the -

limits established by the NRC for Class C radioactive waste (GTCC)).

The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the Federal Government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the Federal Government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the estimate to decommission Pilgrim included an allowance for the disposition of GTCC material.

For purposes of the study, GTCC was packaged in the same canisters used for spent fuel. The GTCC material is assumed to be shipped directly 'to a DOE facility as it is, generated (since the fuel has been removed from the site prior to the start of decommissioning and the ISFSI deactivated).

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PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 12 of 39 1.7.2 Reactor Vessel and Internal Components The reactor pressure vessel and reactor internal components were assumed to be segmented for disposal in shielded transportation casks.

Segmentation and packaging of the internals would be performed in the dryer-separator pool 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 well. Transportation cask specifications and Department of Transportation (DOT) regulations dictate segmentation and packaging methodology (i.e., packaging will meet the current physical and radiological limitations and regulations). Cask shipments are made in DOT-approved, currently available truck casks.

As stated previously, the dismantling of reactor internals at the Pilgrim reactor will generate radioactive waste considered unsuitable for shallow land disposal (i.e., GTCC). For purposes of this study, the GTCC radioactive waste was packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

Intact disposal of the reactor vessel and internal components can provide savings- in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package. However, the location of the Trojan Nuclear Plant on the Columbia River simplified the transportation analysis.

It is not known whether this option will be available when Pilgrim ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will be segmented, as a bounding condition.

1.7.3 Primary System Components-The current scenario defers decommissioning for approximately 30 years (until the spent fuel is removed from the site). The delay will result in lower working area dose rate (from. natural decay of the radionuclides produced from plant operations). As such, decontamination of the reactor recirculation system components and associated reactor water TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 13 of 39 cleanup systems is not anticipated to be necessary and no allowance is included for this activity within the estimate.

Reactor recirculation piping is cut from the reactor vessel once the water level in the vessel (used for personnel shielding during dismantling and cutting operations in and around the vessel) drops below the nozzle zone. The piping is boxed and shipped by shielded van. The reactor recirculation pumps and motors are lifted out intact, packaged, and transported for processing or disposal.

1.7.4 Retired Components This estimate assumes that any waste stored on site as a result of operations will be dispositioned as an operating expense. Therefore, the estimate did not include any costs for components that could be in storage at the site upon the cessation of plant operations.

1.7.5 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. Decontamination, if needed, will be limited due to the delay in the start of decommissioning and the resulting natural decay of the radionuclides produced from plant operations.

The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled demolition.

The main condensers are also disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it will be surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.

1.7.6 Transportation Methods It is expected that most of the contaminated piping, components, and structural material, other than the highly activated reactor vessel and internal components, will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.[161 The contaminated material is packaged in Industrial Packages (IP-1, IP-2, or 16 U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 2006 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 14 of 39 IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with

§71, as Type B. It is conceivable that the reactor may qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.

Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of long-lived isotopes (e.g., 137Cs, 90 Sr, or transuranics) has not reached levels exceeding those that permit the major reactor components to be shipped under current . transport regulations requirements.

Transport of the highly activated ig ......

• metal, produced in the segmentation .  :......

of the reactor vessel and internal components, is by shielded truck cask. Cask shipments may exceed !dmha'K,,

95,000 pounds, including vessel SW-Od ef ....

segment(s), supplementary shielding, Sogt cask tie-downs, and tractor-trailer. Brockton The maximum level of activity per Center, P- Soh ,uxb,~y shipment assumed permissible is Nq.o based upon the license limits of the Ihi::-:::

available shielded transport casks. Tn.. ,*,

The segmentation- scheme for the , *,.

vessel and internal segments is designed to meet these limits.

For estimating purposes, costs to transport low-level radioactive waste were developed from published tariffs from Tri-State Motor Transit[17]

with Energy-Solutions' facility in Clive, Utah as the destination.

Memphis, Tennessee was used as the destination for off-site processing.

1.7.7 Low-Level Radioactive Waste Conditioning and 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 v Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC),

Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, Februfary 2006.

TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page15 of 39 is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,['8] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation. After little progress, the "Low-Level Radioactive Waste Policy Amendments Act of 1985,"[191 extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. Subsequent court rulings have substantially diluted those sanctions and, to date, no new compact facilities have been successfully sited, licensed and constructed.

At the time this analysis Was prepared, Pilgrim was able to dispose of Class A, B or C low-level radioactive waste [201 at the licensed commercial low-level radioactive waste disposal facility in Barnwell, South Carolina.

In June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. Current South Carolina legislation requires South Carolina to gradually limit disposal capacity at the Barnwell facility through mid-2008. As of June 30, 2008, access to the Barnwell Low-Level Radioactive Waste Disposal Facility is available only to generators located in states affiliated with the Atlantic Compact.

However, Pilgrim is still able to dispose of Class A material at EnergySolutions' facility in Clive, Utah.

The EnergySolutions' disposal facility was used as the destination for the majority of the waste volume generated by decommissioning (98%).

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C) generated in the dismantling of the reactor. As such, the disposal costs for this material (representing approximately 1.8% of the waste volume) were 'based upon Barnwell disposal rates as a proxy.

Material exceeding Class C limits (limited to material closest to the reactor core and comprising approximately 0.2% of the total waste volume) is generally not suitable for shallow-land disposal. This 18 "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980 19 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public'Law 99-240, 1986.

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

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 16 of 39 material is packaged in the same multipurpose canisters used for spent fuel storage/transport and designated for geologic disposal. [21]

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

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

Disposition of the low-level -radioactive waste generated from decommissioning operations (and cost basis) is summarized in Table 1.

1.7.8 Site Conditions Following Decommissioning The NRC will terminate (or amend) the site license if it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. The NRC's involvement in the decommissioning process ends at this point.

Building codes and state environmental regulations dictate the next step in the decommissioning process, as well as the owner's own future plans and commitments for the site.

Only existing site structures were considered in the dismantling cost.

The electrical switchyard was assumed to remain after Pilgrim was decommissioned in support of the regional transmission and distribution system. The intake and discharge canals were abandoned. The large underground tunnels between the cooling water intake and turbine building and discharge structure were assumed to be isolated, backfilled, and abandoned in place. Site utility and service piping were also abandoned. Electrical manholes were backfilled with suitable earthen material. Asphalt surfaces in the immediate vicinity of site buildings 21 Pursuant to the Low-Level Radioactive Waste Policy Act Amendments of 1985, Congress clarified that the Federal Government remains responsible for the disposal of Greater-Than-Class C waste.

TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 17 of 39 were broken up and the material used for fill, as required. The site access road remained in place.

1.8 ASSUMPTIONS The following assumptions were made in the development of the estimate for decommissioning the Pilgrim nuclear unit.

1.8.1 Estimating Basis Decommissioning costs are reported in the year of projected expenditure; however, the values Were provided in 2007 dollars. Costs were not inflated, escalated, or discounted over the periods of performance.

The estimate relied upon the physical plant inventory that was the basis for the 2002 analysis. There were no physical changes to the station since 2002 that would measurably impact decommissioning.

The study followed 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.

1.8.2 Site Contamination Plant personnel reviewed the records of information important to the safe decommissioning of the facility (as maintained under 10 CFR 50.75(g)). The records did not indicate any areas of significant site contamination (specifically soil, groundwater and surface water) that needed to be addressed in the financial planning for decommissioning, at this time.

1.8.3 Release Criteria The estimate assumed that the site would be remediated to the levels specified by the Nuclear Regulatory Commission for terminating the operating license. As such, levels of radioactivity would not exceed 25 mrem/yr total effective dose equivalent (TEDE) and would be as low as TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 18 of 39 reasonably achievable (ALARA).[ 221 Regulatory criteria established by the Massachusetts State Department of Public Health (10 mrem/yr) would also be met before the property would be transferred.

1.8.4 Labor Costs Entergy was assumed to manage the decontamination and dismantling of the nuclear unit in addition to maintaining site security, radiological health and safety, quality assurance and overall site administration during the decommissioning. Entergy would 'provide the supervisory staff needed to oversee the labor subcontractors, consultants, and specialty contractors engaged to perform the field work associated with the decontamination and dismantling efforts.

Personnel costs were based upon average salary information made available by Entergy. Overhead costs were included for site and corporate support, reduced commensurate with the staffing levels envisioned for the project.

Severance and retention costs were not included in the estimate.

Reduction in the operating organization is assumed to be handled through normal staffing processes (e.g., reassignment and outplacement).

The craft labor required to decontaminate and dismantle the nuclear unit is acquired through standard site contracting practices. The current cost of site labor is used as an estimating basis.

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

1.8.5 Design Conditions Activation levels in the vessel and internal components were modeled using NUREG/CR-3474.[231 Estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Pilgrim components, projected operating life(s), and different periods of 22 Code of Federal Regulations, Title 10, Section 20.1402, "Radiological Criteria for Unrestricted Use" 23 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.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 19 of 39 decay. Additional short-lived isotopes were derived from CR-0130[2 4] and CR-0672,[251 and benchmarked to the long-lived values from CR-3474.

The disposal cost for the control blades removed from the vessel with the final core load is included within the estimate. Disposition of any blades stored in the pools from operations were considered an operating expense and therefore not accounted for in the decommissioning estimate.

For purposes of the estimate, activation of the reactor building structures was assumed to be confined to the area around the sacrificial shield.

1.8.6 General Transition Activities Existing warehouses are assumed to be cleared of non-essential material and remain for use by Entergy and its subcontractors. The plant's operating staff performs the following activities during the transition period.

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

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

" Process operating waste inventories. Disposal of operating wastes during this initial period is not considered a decommissioning expense.

Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Entergy will make economically reasonable efforts to salvage equipment following final plant shutdown.

However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required for salvage 24 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 25 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 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page20 of 39 (resale) of equipment. Experience has indicated that buyers prefer equipment stripped down to very specific requirements before they would consider purchase. This can require expensive rework after the equipment had been removed from its installed location. Since placing salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall cost of decommissioning, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts, and does not include any salvage credit.

It is assumed, for purposes of this analysis, that any value received from the sale of clean scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the-decommissioning estimates do not include the additional cost for size reduction and preparation to meet "furnace ready" conditions. With, a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. Therefore clean scrap is disposed of at no cost or credit to the project.

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

Spent Fuel Pool Isolation The decommissioning "cost estimate for Pilgrim assumes that the reactor building will be used for the interim storage of spent fuel once plant operations cease until the fuel can be relocated to the ISFSI (a minimum of five years based upon the heat load criteria of the dry storage system).

Therefore, so that the adjacent power block structures can be de-energized and configured for long-term storage, the reactor building, and in particular the spent fuel storage area, will be isolated, creating a spent fuel island. This process can involve; establishing a local control area, installing in-situ pool cooling and water cleanup systems, establishing and routing independent power and control systems, redesigning the heating and ventilation systems, reconfiguring the area monitoring systems and relocating the security boundary. Costs for these activities are based upon experience at plants that have undergone decommissioning and, in the process, isolated their spent fuel pool operations.

TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page21 of 39 Eneray For estimating purposes, the plant was assumed to be de-energized, with the exception of those facilities associated with spent fuel storage (temporary power is run throughout the plant, as needed). Replacement power costs are used to calculate the cost of energy consumed during decommissioning for tooling, lighting, ventilation, and essential services.

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are consistent with the guidance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."[ 26 1 The NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.

Property Tax Property taxes or fees in lieu of taxes were not included within the estimate.

Site Modifications The perimeter fence and in-plant security barriers are moved, as appropriate, to conform to the site security plan in force during the various stages of the project.

26 "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 TLG Services, Inc.

PilgrimNuclearPower'Station Document E11-5690-003 PreliminaryDecommissioningCost Analysis Page22 of 39

2. RESULTS The proposed decommissioning scenario, major cost contributors and schedule of annual expenditures are summarized in Figure 1 and Tables 2 and 3. The summaries are based upon the 2005 detailed cost estimate provided in Appendix A (escalated to 2007 dollars). The cost elements are assigned to one of three subcategories: NRC License Termination, Spent Fuel Management, and Site Restoration. The subcategory "NRC License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in its financial assurance regulations (i.e., 10 CFR §50.75). In situations where the long-term. management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.

The "Spent Fuel Management" subcategory contains costs associated with the construction of an ISFSI, the containerization and transfer of spent fuel to the ISFSI over the first 5! years of pool operations, and the management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g., geologic repository) is complete. It does not include any spent fuel

-management expenses incurred prior to the cessation of plant operations.

"Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination.

This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to the local grade.

It should be noted that the costs assigned to these subcategories are allocations.

Delegation of costs is for the purposes of comparison (e.g., with NRC financial

.guidelines) or to permit specific financial treatment (e.g., ARO determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity.

However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

For purposes of this study, GTCC is packaged in the same canisters used for spent fuel. The GTCC material is assumed to be shipped directly to a DOE facility as it is generated (since the fuel has been removed from the site prior to the start of decommissioning and the ISFSI deactivated). While designated for disposal at the TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page23 of 39 geologic repository along with the spent fuel, GTCC waste is still classified herein as 16w-level radioactive, waste and, as such, included as a "License Termination" expense.

2.1 Escalation of the 2005 Costs to 2007 Dollars For purposes of escalation, TLG allocates its costs for decommissioning into categories (similar to the NRC, except that the NRC's labor category is further subdivided into "labor" and "equipment and materials," and an "other" category added for miscellaneous fees, taxes and other unique or one-time expenditures).

The 2005 cash flows were escalated to year-end 2007 dollars using indices provided by Global Insight (Global Insight is a privately held company formed from the two leading economic and financial information companies, DRI (Data Resources, Inc.) and WEFA (Wharton Econometric Forecasting Associates)). The results are shown in Tables 3 through 6. The following table identifies the Global Insight forecast data sets used for the five cost categories.

Global Insight Forecast Total Escalation (%)

Database (2005 to 2007) TLG Cost Categorv ECI Total Compensation (ECIPCTNS) _ 6.1 Labor Producer Price Index, Machinery & Equipment (WPIP 11) 2.9 Equipment/Material Producer Price Index, Fuels and Related Products and Power (WP*P* 0) ............ 13.6 4E n ergy............. .........

Consumer Price Index, Services (CUSASNS) 7.3 Other Consumer Price Index, 7.3 .uriala Recycling 2.2 Financial Assurance It is the current plan, based on the growth of the funds in the Pilgrim decommissioning trust, to fund the expenditures for license termination and spent fuel management from the currently existing decommissioning trust fund and from proceeds from spent fuel litigation against the DOE.

Table 7 combines the projected expenditures for license termination and spent fuel management (from Tables 4 and 5). As shown in Table 8, based on a 3%

TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page24 of 39 annual inflation, the real rate of return required to fund the evaluated scenario, placing Pilgrim into safe-storage at the, conclusion of its current licensed operating life in 2012 until the spent fuel could be removed from the site (estimated to be in the year 2042 based upon a 2017 startup of DOE's geologic repository) with subsequent decommissioning of the nuclear unit, is approximately 1.471%. This is less than the 2% real rate of return identified in 10 CFR 50.75. With these criteria, the. scenario of funding both license termination and spent fuel management from the existing trust fund is financially viable.

Pursuant to 10 CFR 50.75(f)(4), the licensee states that it plans to review the adequacy of decommissioning funds on an* annual basis throughout the decommissioning process. If costs have exceeded estimates, or if fund performance has not met the assumptions used in financial adequacy calculations, the licensee will either extend the period of SAFSTOR (not to exceed 10 CFR 50.82(a)(3) limits without Commission approval) to allow for more fund growth, or will supplement the fund (or otherwise directly pay decommissioning-related expenses) as necessary.

TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 25 of 39 FIGURE 1 DECOMMISSIONING TIMELINE Shutdown: June 8, 2012 Period 1 Transition and Period 2 Period 3 Decommissioning Preparations Safe-Storage Preparations I Operations 06/2012 12/2013 07/2044 12/2048 03/2050 ISFSJ Construction Canister and overpack fabrication DOE License Fuel Pickup Terminated Fuel to ISFSI 12/2017 Storage Pool Empty ISFSI Operations N

All Spent Fuel Off Site TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page26 of 39 TABLE 1 Pilgrim Nuclear Power Station Low-Level Radioactive Waste Disposition Waste Volume Mass Waste Cost E Class [1] (cubic feet) . (pouds)

Low-Level Radioactive Waste (near_-surface disposal1) _* EnergySolutions A 194,998 12,864,971 I' Barnwell B 3,313 . _ 402,190 Barnwell C 287 36,625 Greater than Class C Spent Fuel (geologc "repository)

Equivalent GTCC 480 82,000 Processed/Conditioned Recycling off-site recy g ter........ Vendors A 408 531 17,934,830 Total [2] 607,609 31,320,616 L'] Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55

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

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis . Page27 of 39

\

TABLE 2 Pilgrim Nuclear Power Station Summary of Major Cost Contributors (thousands, 2007 dollars)

License Spent Fuel Site

. .. .... __ Termination Management Restoration Total Decontamination 20,831 0 0 20,831 Removal 76,730 2,783 17;969 97,482 Waste Packa ing 10,069 12 0 10,081 Transportation -9,732 338 0 10,071 Waste Disposal 61,331 1,377 0 62,708 Waste Conditioning (Off-Site) 48,678 0 0 48,678 Program Management [1] 225,787 164,840 15,357 405,984 Property Taxes 0 0 0 0 Insurance 4,853 16,977 0 21,831 Spent Fuel Management [21 0 125,401 0 125,401 Regulatory Fees 10,704 0 0 10,704 Energy 13,227 3,356 271 16,853 Other 67,858 13,615 2,322 83,796 Total 549,800 328,701 35,918 914,419

[1] Includes security and engineering

[2] Includes capital costs for ISFSI construction, multi-purpose storage containers, packaging and handling (transfer pool to ISFSI or DOE and ISFSI to DOE)

TLG Services, Inc.

Pilgrim Nuclear Power Station Document Ell-5690-003 Preliminary Decommissioning Cost Analysis Page 28 of 39 TABLE 3 Pilgrim Nuclear Power Station Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials En2erg Burial Other Totals 2012 22,596 474 1,226 20 11,007 5,323 3..

2013 54,427 11,881 2,058 932 18,605 87,903 2014 11,340 2,936 433 35 21,619 36,361 2015 11,340 2,936 433 35 21,619 36,361 2016 11,371 2,944 434 35 21,678 36,461 2017 10,924 2,769 408 35 20,302 34,438 2018 5,023 399 65 35 1,589 7,111 2019_ 5,023 399 65 35 1,589 7,111 2020 5,036 401 65 35 1,594 7,130 2021 5,023 . 399 65 35 1,589 7,111 2022 5,023 399 65 35 1,589 7,111 2023 5,023 399 65 35 1,589 . 7,111 2024 5,036 401 65 35 1,594 7,130 2025 5,023 399 65 35 1,589 .7,111 2026 5,023 399 65 . 35 1,589 7,111 2027 . 5,023 399 65 35 1,589 7,111 2028_ 5,036 401 65 35 1,594 7,130 2029 5,023 .399 65 35 1,589 7,111 2030 5,023 399 65 35 1,589 7,111 2031 5,023 399 65 .35 1,589 7,111 2032 5,036 401 65 35 1,594 7,130 2033 5,023 399 65 35 1,589 7,111 2034 5,023 399 65 35 1,589 7,111 2035 5,023 399 65 35 1,589 7,111 2036 5,036 401 65 35 1,594 7,130 2037 5,023 399 65 35 1,589 7,111 2038 5,023 399 65 35 1,589 7,111 2039 5,023 399 65 35 1,589 7,111 2040 5,036 401 65 35 1,594 7,130 2041_ 5,023 399 65 35 1,589 7J111 2042 5,103 402 71 35 1,596 7,206 2043 34,380 1,273 2,163 .35 4,062 41,913 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell.5690-003 PreliminaryDecommissioningCost Analysis Page29 of 39 TABLE 3 (continued)

Pilgrim Nuclear Power Station Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

".Equip.& Yearly Year Labor Materials Energy Burial Other Totals 2044 44,036 12,801 2,115 28,981 14,559 102,492 2045 44,818 9,903 1,734 28,859 11,723 97,036 2046 42,636 6,038 1,622 18,575 7,240 76,110 2047 42,636 6,038 1,622 18,575 7,240 76,110 2048 27,473 3,101 712 4,453 4,610 40,349 2049 18,798 7,469 216 0 2,503 28,987 2050 4,275 1,698 49 0 569 6,591 Total 506,777 82,255 16,853 101,436 207,098 914,419 TLG Services, Inc.

Pilgrim Nuclear Power Station Document Ell-5690-003 Preliminary Decommissioning Cost Analysis Page 30 of 39 TABLE 4 Pilgrim Nuclear Power Station Schedule of Annual Expenditures License Termination Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Enrg Burial Other Totals-2012 22,596 474 1,226 20 3,804 28,119 2013 53,747 11,720 2,032 932 6,747 75,178 2014 57 '269 0 35 294 655 2015 57 269 0 35 294 655 2016 57 270. 0 35 295 657 2017 57 269 0 35 294 655 2018 57 269 0 35 294 655 2019 57 269 0 35 294 655 2020 57 270 0 35 295 657 2021 57 269 0 35 294 655 2022 57 269 0 35 294 655 2023 57 269 0 35 294 655

.2024 57 270 0 35 295 657 2025 57 269 0 35 294 655 2026 57 269 0 35 294 655 2027 57 269 0 35 294 655 2028 57 270 0 35 295 657 2029 57 269 0 35 294 655 2030 57 269 0 35 294 655 2031 57 269 0 35 294 655 2032 57 270 0 35 295 657 2033 57 269 0 35 294 655 2034 57 269 0 35 294 655 2035 57 269 0 35 294, 655 2036 57 270 0 35 295 657 2037 57 269 0 35 294 655 2038 57 269 0 35 294 655 2039 57 269 .0 35 294 655 2040 57 270 0 35 295 657 2041 57 269 0 35 294 655 2042 *150 272 6 35 304 767 L 2043 33,920 1,273 2,163 35 4,062 41,452 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 31 of 39 TABLE 4 (continued)

Pilgrim Nuclear Power Station Schedule of Annual Expenditures License Termination Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2044 43,603 12,790 2,115 28,981 14,559 102,047 2045 43,929 9,694 1,734 28,517 :11,639 95,513 2046 41,485 5,764 1,622 18,112 7,126 74,110 2047 41,485 5,764 1,622 18,112 7,126 74,110 2048 26,739 2,852 707 4,343 4,537 39,177 2049 144 0 0 0 654 798 2050 33 0 0 0 149 182 Total 309,433 58,139 13,227 100,058 68,942 549,800 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page 32 of 39 TABLE 5 Pilgrim Nuclear Power Station Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2012 0 0 0 0 7,203 7,203 2013 680 161 26 0 11,858 12,725 2014 11,283 2,667 433 0 21,325 35,706 2015 11,283 2,667 433 0 21,325 35,706 2016 11,314 2,674. 434 .0 21,383 35,804 2017 10,867 2,500 408 0 20,008 33,783 2018 4,965 130 65 0 1,295 6,456 2019 4,965 130 65 0 1,295 6,456 2020 4,979 131 65 0 1,299 6,474 2021 4,965 130 65 0 1,295 6,456 2022 4,965 130 65 0 1,295 6,456 2023 4,965 130 65 0 1,295 6,456 2024 4,979 131 65 0 1,299 6,474 2025 4,965 130 65 0 1,295 6,456 2026 4,965 130 65 0 1,295 6,456 2027 4,965 130 65 0 1,295 6,456 2028 4,979 131 65 0 1,299 6,474 2029 4,965 130 65 0 1,295 6,456 2030 4,965 130 65 0 1,295 6,456 2031 4,965 130 65 0 1,295 6,456 2032 4,979 131 65 0 1,299 6,474 2033 4,965 130 65 0 1,295 6,456 2034 4,965 130 65 0 1,295 6,456 2035 4,965 130 65 0 1,295 6,456 2036 4,979 131 65 0 1,299 6,474 2037 4,965 130 65 0 1,295 6,456 2038 4,965 130 65 0 1,295 6,456 2039 4,965 130 65 0 1,295 6,456 2040 4,979 131 65 .0 1,299 6,474 2041 4,965 130. 65 0 1,295 6,456 2042 4,952 130 65 0 1,292 6,438 2043 0 0 0 0 0 0 TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 33 of 39 TABLE 5 (continfued)

Pilgrim Nuclear Power Station Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars),

Equip & Yearly Year Labor Materials Burial Other Totals 2044 0 0' 0 *0 0 0 2045 4 618 4 201 4 0 +

342 4 84 1,246 2046 836 272 0 462 114 1,684 2047 836 272 - 0 462 114 1,684 2048 204 85 0 110 27 426 2049 182 831 0 0 0 1,013 2050 41 189 0 01 0 230 Total 172,346 15,782 3,356 1,377 135,841 328,701 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 34 of 39 TABLE 6 Pilgrim Nuclear Power Station Schedule of Annual Expenditures Site Restoration Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2012 0 0 0 0 0 0 2013 0 0 0 0 0 0 2014 0 0 0 0 0 0 2015 0 0 0 0 0 0 2016 0 0 0 0 0 0 2017 0 0 0 0 0 0 2018 0 0 0 0 0 0 2019 0 0 0 0 0 0 2020 0 0 0 0 0 0 2021 0 0 0 0 0 0 2022,- 0 0 0 0 0 0 2023 0 0 0 0 0 0 2024 0 0 0 0 0 0 2025 0 0 0 0 0 0 2026 0 0 0 0 0 0 2027 0 0 0 0 0 0 2028 0 0. 0 0 0 0 2029 0 0 0 0 0 0 2030 0 0 0 0 0 0 2031 0 0 0 0 0 0 2032 0 0 0 0 0 0 2033 0 0 0 0 0 0 2034 0 0 0 0 0 0 2035 0 0 0 0 0 0 2036 0 0 0 0 0 0 2037 0 0 0 0 0 0 2038 0 0 0 0 0 0 2039 0 0 0 0 0 0 2040 0 0 0 0 0 0 2041 0 0 0 0 0 0 2042 1 0 0 0 0 1 2043 460 0 0 0 0 460 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page.35 of 39 TABLE 6 (continued)

Pilgrim Nuclear Power Station Schedule of Annual Expenditures Site Restoration Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2044 433 12 0 0 0 445 2045 271 7 4 0 4 0 4 0 4 278 2046 315 2 0 0 0 317 2047 315 2 0 0 0 317 2048 531 164 5 0 46 746 2049 18,472 6,638 216 0 1,849 27,175 2050 S4,200 1,509 49 0 421 6,180 Total 24,998 8,334 271 0 2,315 35,918 TLG Services, Inc.

Pilgrim Nuclear Power Station Document Ell-5690-003 Preliminary Decommissioning Cost Analysis Page 36 of 39 TABLE 7 Pilgrim Nuclear Power Station Schedule of Annual Expenditures License Termination and Spent Fuel Management Allocations (from Tables 4 and 5)

(thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2012 22,596 474 1,226 20 11,007 35,323 2013 54,427- 11,881 2,058 932 18,605 87,903 2014 11,340 2,936 433 35 21,619 36,361 2015 11,340 2,936 433 35 21,619 36,361 2016 ,-11,371 2,944 434 35 21)ý678 36,461 2017 10,924 2,769 408 -35 20,302 34,438 2018 5,023 399 65 35 1,589 7,111 2019 5,023 399 65 35 1,589 7,111 2020 5,036 401 65 35. 1,594 7,130 2021 5,023 399 65 35 1,589 7,111 2022 5,023 399 65 35 1,589 7,111 2023 5,023 399 65 35 1,589 7,111 2024 5,036 401 65 35 1,594 7,130.

2025 5,023 399 65 35 1,589 7,111 2026 5,023 399 65 35 1,589 7,111 2027 5,023 399 65 35 1,589, 7,111 2028 5,036 401 65 35 1,594 7,130 2029 5,023 ' 399 65 35 1,589 7,111 2030 5,023 399 65 35 1,589 7,111 2031 5,023 399 65 35 1,589 7,111 2032 5,036 401 65 35 1,594 7,130 2033 5,023 399 65 35 1,589 K7,111 2034 5,023 399 65 35 1,589 7,111 2035 5,023 399 65 35 1,589 7,111

'2036 5,036 401 65 35 1,594 7,130 2037 5,023 399 65 35 1,589 7,111 2038 5,023 399 65 35 1,589 7,111 2039 5,023 399 65 35 1,589 7,111 2040 5,036 401 65 35 1,594 7,130 2041 5,023 399 65 35 1,589 7,111 2042 5,102 402 71 35 1,596 7,205 2043 33,920 1273 21335 4,062 41,452 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Page 37 of 39 TABLE 7 (continued)

Pilgrim Nuclear Power Station Schedule of Annual Expenditures License Termination and Spent Fuel Management Allocations (from Tables 4 and 5)

(thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2044 43,603 12,790 2,115 28,981 14,559 102,047 2045 44,547 9,895 1,734 28,859 11,723 96,758 2046 42,321 6,036 1,622 18,575 7,240 75,794 2047 42,321 6,036 1,622 18,575 7,240 75,794 2048 26,943 2,937 707 4,453 4,564 39,604 2049 327 831 0 0 654 1,812 2050 /74 189 0 0 149 412 Total 481,779 73,921 16,583 101,436 204,783 878,501 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page38 of 39 TABLE 8 Pilgrim Nuclear Power Station Funding Requirements to Equal Expected Expenditures (millions, dollars)

Basis Year 2007 Fund Balance $621.74 (millions)

Annual Escalation 3.00%_

Annual Earnings 4.471%__

License Termination and Spent Fuel Costs Projected Fund Balance (2007 Present Year (2007 $'s) (2007 $'s) (Nominal $) Value $)

2007 621.74 2008 649.54 2009 678.58 2010 708.92 2011 740.62 2012 732.79 35.32 40.95 32.91 2013 660.59 87.90 104.96 80.73 2014 645.41 36.36 44.72 32.92 2015 628.21 36.36 46.06 32.46 2016 608.72 36.46 47.57 32.09 2017 589.66 34.44 46.28 29.88 2018 606.18 7.11 9.84 6.08 2019 623.15 7.11 10.14 6.00 2020 640.54 7.13 10.47 5.93 2021 658.42 7.11 10.76 5.83 2022 676.78 7.11 11.08 5.75 2023 695.63 7.11 11.41 5.67 2024 714.95 7.13 11.79 5.60 2025 734.81 7.11 12.11 5.51 2026 755.20 7.11 12.47 5.43 2027 776.12 7.11 12.84 5.36 2028 797.56 7.13 13.26 5.29 2029 819.60 7.11 13.63 5.21 2030 842.21 7.11 14.03 5.13 2031 865.41 7.11 14.46 5.06 2032 889.18 7.13 14.93 5.00 2033 913.60 7.11 15.341 4.92 2034 938.65 7.11 15.80 4.85 2035 964.35 7.11 16.27 4.78 2036 990.67 7.13 16.80 1 4.73 TLG Services, Inc.

PilgrimNuclearPower Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Page39 of 39 TABLE 8 (continued)

Pilgrim Nuclear Power Station Funding Requirements to Equal Expected Expenditures (millions, dollars)

Basis Year 2007 Fund Balance $621.74 m s _

Annual Escalation 3.00%

Annual Earning. 4.471% _

License Termination and Spent Fuel Costs Projected Fund Balance (2007 Present Year (2007 $'s) (2007 $'s) (Nominal $) i Value $)

2037 1,017.70 7.11 17.26 J 4.65 2038 1,045.43 7.11 17.78 j 4.58 2039 1,073.86 7.11 18.31 [ 4.52 2040 1,102.96 7.13 18.91 4.47 2 1,132 ...-............. ........

7.11.

1 ...................................

.19.43 . 4.39 2042 1,163.23 7.21 20.27 4.39 2043 1,095.10 41.45 120.14 24.88 2044 839.44 102.05 304.63 I 60.38 2045 579.46 96.76 297.51 56.45 2046 365.33 75.79 240.04 43.59 2047 134.42 75.79 247.24 42.98 2048 7.36 39.60 133.07 22.14 2049 1.42 1.81 6.27 1.00 2050 0.02 0.41 1.47 0.22 878.50 621.74 TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Appendix A, Page 1 of 12 APPENDIX A 2005 DETAILED COST ANALYSIS TLG Services, Inc.

Pilgrim Nuclear Power Station Document E l-5690-O03 Preliminary DecommissioningCostAnalysis Appendix A, Page2 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Ofif-Sito LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Teom. Management Restoration Volume Class A Class 8 Class C GTCC Processed Craft Contractor deDescription Cost . Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt.. Lbs. Manhours Manhours PERIOD la -Shutdown through Transition Period ia Direct Decommissioning Activities la.1 I SAFSTOR site characterization survey 112 487 487 la. .2 Prepare preliminary decommissioning cost 19 142 142 1,235 tat.3 Notsficaton of Cessation of Operations a 1a.4 Remove fuel &source material 1a.1.5 Notification of Permanent Defueling n1.1.6 Deactivate plant systems & process waste la.1.7 Prepare and submit PSOAR 29 219 219 1,900 la.1.8 Review plant dwgs & specs. "19 142 142 1,235 1a 1.9 Perform detailed red sunnay a la .10 Estimate by-product inventory 95 950 14 109 109 ia 1.11 End product description 95 950 14 109 109 la,1.12 Detailed by-product inventory 143 21 164 164 1,425 ia,1.i3 Define major work sequence 95 14 109 950 109 1a.1.14 Psrform SER and EA - - 295 44 339 339 2,945 la,1.15 Perform Site-Specific Cost Study 475 71 546 546 4,750 ActivitySpecifications la 116.1 Prepare plant and facilities ftr SAFSTOR 467 70 538 538 4,674 1a.1.16.2 Plant systems 396 59 455 455 3,958 1o.

.16.3 Plant structures and buildings 296 44 341 341 2,964 na.1.16.4 Waste management 190 29 219 219 1,90 la.i.16.5 Facility and site dormancy 190 29 219 219 1,900 la.1i16 Total 1,540 231 1,771 1,771 15,396 Detailed Work Procedures ia.1.17.1 Plant systems - .- -. - 112 17 129 129 1,124 1a.t.17.2 Facility closeout &dormancy -S - . - , 114 17 131 131 1,140 la,17 Total 226 34 260 260 2,264 l,1:.18 Procure vacuum drying system 10 1 11 11 - - 95 la.1 9 Drain/de-energize nov-cont, systems 1a.i120 Drain &dry NSSS la.1.21 . Drairvlde-nergize contaminated systems la.1.22 Deconlsecure contaminated systems a iaAi Subtotal Pedod 1a Actvity Costs A 3,7a4 624 4,408 4.408 34,095 Period la Collateral Costs ta.3.1 ISFSI Capital Expenditures 7,217 1,083 . 8,299 8,299 la.3 Subtotal Period la Collateral Costs 7,217 1,083 8,299 8,299 Period 1a Period-Dependent Costs la.4.1 Insurance - - 869 87 956 956 la 4.2 Property taxes 1a.4.3 Hearth physics supplies 257 64 321 321 1a.4.4 Heavy equipment rental 336 -- - . -. . . 50 386 386 no.4.5 Disposal of DAWgenerated - 6 5 26 - 8 45 45 404 8,103 99 la.4.6 Plant energy budget 1,655 248 1,904 1,904 l.d.7 NRC Fees - -- 265 27 292 292 la.4.8 Emergency Planning Fees -- - - 2,089 209 2,297 - 2,297 lu.4.9 Site O&M 2,847 427 3,275 3,275 1a4.10 Spent Fuel Pool O&M 978 147 1,125 - 1,125 lae4.1 l SFSt OperatingCosts - 103 15 118 - 118 -

la.4.12 Corporate Overhead - 1,499 225 1,724 1,724 TLG Services, Inc.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioning Cost Analysis Appendix.A, Page 3 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

I Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and l IActiity Decon Removal Packaging Transport Processing Disposal Other Total Total Lbc. Tem. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor I INNAX ACt*1* UA*N*t IOn ndex A-ury uescnption Cast Cost costs Costs Costs Costs Costs Cim-geric Costs costs Costs costs Cu Feet Cu Feet Cu Period ia Period-Dependent Costs (continued) 1.4.13 Security StlaffCost - -5,621 843 6,464 6,464 156,429 ia.4.14 UtilityStaff Cost - 23,276 3,491 26,767 26,767 - - - 435,914 la.4 Subtotal Period ia Period-Dependent Costs 593 5 26 39,202 5.842 45,674 42,134 3,540 404 8,103 99 592.343 1a.0 TOTALPERIOD 1a COST 593 5 26 50,203 7.548 58.382 46.542 11.840 S404 8,103 99 626,438 PERIOD lb - SAFSTOR Limited DECON Activities Period 1 b Direct Decommissioning Activities Decontamination of Site Buildings 1b.1.1.1 Reactor 4,057 2,029 6,086 6.086 80,991 1I.1.1.2 AOG Rentention 44 22 66 66 945 1b.1.1.3 Condenser Retube 57 28 85 85 1,236 1 b.1.1.4 Main Stack & Filter 12 6 18 18 268 1 .1 .1.5 Radwsste 168 S3,655 84 253 253 lb.1.1.6 Turbine 428 214 642 642 9,310 1b.1.1,7 Spent Fuel Pool Area 226 113 339 339 4,471 1b.1.1 Totals 4,993 2,496 7,489 7,489 100,875 1b.1 Subtotal Period I b ActivityCosts 4,993 2,496 7.489 7,489 100,875 Period lb Collateral Costs 1 b.3.1 Decon equipment 731 - - 110 841 841 1 b.3.2 proaess liquid waste 98 - 37 36 248 120 539 539 675 85,100 133 11b.3.3 Small tola alltoance 86 - 13 99 99 lb.3.4 ISFS1Capital Expenditures - 1.269 190 1,460 1,460 1b.3 Subtatal Period l b Colateral Costs 830 86 37 36 248 1.269 433 2,939 1,479 1.460 675 85,100 133 Period lb Pedod-Dependent Costs 1b.4.1 Decon supplies 865 216 1,081 1,081 1b.4.2 Insurance 219 22 241 241 1 b.4.3 Property taxes 1 b.4.4 Health physics supplies 421 105 526 526 1b.4.5 Heavy equipment rental 85 13 97 97 lb.4.6 Disposal of DAWgenerated 8 7 33 10 57 57 514 10,292 126 lb.4.7 Plant energy budget 417 63 480 480' lb.4.8 NRC Fees 67 7 74 74 1b.4.9 Emergency Planning Fees 526 53 579 - 579 1b.4.10 Site O&M 718 108 825 825 1 b.4.11 Spent Fuel Pool O&M 246 37 283 283 1 b.4.12 ISFSI Operating Costs 26 4 30 - 30 1b4.13 Corporate Overhead 378 57 434 434 Ib.4.14 Security Staff Cost 1,417 213 1,629 1,629 39,429 1 b.4.15 UtilityStaff Cost 5,867 880 6,747 6,747 10,874 l,

15.4 Subtotal Period Ib Period-Dependent Costs 865 505 8 7 33 9,881 1,786 13,084 12,192 892 514 - 10,292 126 149.303 1b.0 TOTALPERIOD 1b COST 6,688 591 45 42 281 11,151 4,715 23,512 21,160 2.352 514 675 95,392 101,134 149,303 PERIOD 1c - Preparations for SAFSTOR Dotmancy Period 1c Direct Decommissioning Activities 1c.1.1 Prepare support equipment for storage - 404 61 465 465 - 3,000 -

lc.1.2 Install containment pressur equal. lines - 35 - 5 41 41 700 lc.1.3 Interimsurvey prior to dormancy 733 220 953 903 14.369 TLG Services, In.

Pilgrim Nuclear PowerStation Document E1I-5690-003 PreliminaryDecommissioning Cost Analysis Appendix A, Page 4 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Sits LLRW , NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Teem. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingensv Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhoors Manhours Ic.1.4 Secure building accesses 1c.1.5 Prepare &submit interim report 55 8 64 64 - 554 1c.1 Subtotal Period c Activity Costs 439 788 294 1,522 1,522 18.069 554 Period 1c AdditionalCosts 1c.2.1 Spent Fuel Pool Isolation 8,609 1,291 9,900 90900 1 .2.2 Site Characterization Survey - 1,801 540 2,341 2,341 42,600 49.870 1c.2.3 Asbestos Remediation -3,gsO 39 276 122 - '30 4,325 4,325 27,995 nc.2 Subtotal Period ic Additional Costs - 3,050 39 276 122 10,410 2,670 16,567 16,567 27,995 42,600 49.870 Period Ic ColtateralCosts tc.3.1 Process liquid waste 108 - 41 "40 273 132 593 593 - 743" 93,678 146 1c.3.2 Small tool atoreanc- - 42 - 6 49 49 lc.3.3 ISFSI Capital Expenditures - 1,283 192 1,476 - 1,476 1c.3 Subtotal Period 1c Cotlateral Costs 108 42 41 40 273 1,283 331 2,117 641 1,476 743 - 93,678 146 Period ic Period-DepeondentCosts 1c.4.1 Insurance 221 22 244 244 1c.4.2 Property taxes 1c.4.3 Health physics supplies 305 76 382 382 1c4.4 Heavy equipment rental 86 13 98 90 c,.4.5 Disposal of DAW generated 2 1 - 7 - 2 11 11 103 2,065 25 Io.4.6 Plant energy budget 422 63 485 485 1c.4.7 NRC Fees 68 7 74 74 1o 4.8 Emergency Planning Fees 532 53 585 - 585 nc.4.9 Site O&M 715 107 822 822 1c.4.10 Spent Fuel Pool O&M 249 37 287 - 287 o.4.11 ISFSI Operating Costs 26 4 30 - 30 1c.4.12 Corporate Overhead 382 57 439 439 lc.4.13 Security Staff Cost 1,432 215 1,647 1.647 - - 39,857 nc.4.14 UtilityStaff Cost 5.827 874 6.701 6.701 109,474 lc4 Subtotal Period tc Period-Dependent Costs 391 2 1. 7 9.875 1.531 11,807 10,904 902 103 - 2,065 25 149,331 lc.0 TOTALPERIOD tc COST 108 3.922 82 316 401 22,356 4,826 32,012 29,634 2,378 28.098 743 138.342 68,110 149.886 PERIOD 1 TOTALS 6,795 5,107 133 364 708 83.710 17,089 113.906 97,337 16,570 29.016 1.418 241,837 169,344 925,627 PERIOD 2a -SAFSTOR Dormancy with Wet Spent Fuel Storage Period 2a Direct Decommissioning Activities 2a.1.1 QuaDrtodyInspection 2a.t .2 Semi-annual environmental sunrey 2a. .3 Prepare reports 2a.1.4 Bituminous roofreplacement 284 43 326 326 2a.1.5 Maintenance supplies 502 126 628 620 2a.1 Subtotal Period 2a ActivityCosts 7a6 168 954 954 Period 2a Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 12,008 1.801 13,810 13,810 2a.3.2 ISFS1Capital Expenditures 53,042 7,056 60,9M - 60,999 2a.3 Subtotal Period 2a Collateral Costs 65,051 9.758 74,808 74,808 Period 2a Period-Dependent Costs 2a.4.1 Insurance 2,010 201 2,212 2,212 2a.4.2 Property taxes 2a.4.3 Health physics supplies 257 64 321 321 TLG Services, Inc.

Pilgrim Nuclear PowerStation Document EII-5690-003 PrelimieiaryDecommissioningCost Analysis Appendix A, Page 5 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Teom. Management Restoration Volume Class A Class B Class C GTCC Processed - Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Perod 2a Period-Dependent Costs (continued) 2a.44 Disposal of DAWgenerated - - 25 20 103 31 180 180 - 1,616 32,390 397 2a.4.8 - Plant energy budoget - 1,323 198 1,522 1,522 2s.4.6 NRC Fees - 936 94 1,029 1,029 -

2as4.7 Emergency Planning Fees 8,349 835 9,183 - 9,183 2a.4.8 Site O&M 1,223 183 1,406 1,406 2a.4.9 Spenl Fuel Pool O&M 3,909 586 4,495 4,495 2a.4.10 ISFSI Operating Costs 411 62 473 473 2a.4.11 Corporate Overhead 599 90 689 689 2a.4.12 Socority StaiffCost 14,979 2,247 17,226 17,226 416,857 2:.4.13 UtilityStaff Cost 18,971 2,846 21,817 21,817 350,160 2s.4 Subtotal Period 2a Period-Dependent Costs 257 25 20 103 02,711 7,438 60,554 1,530 59,023 32,390 397 757,017 2a.0 TOTALPERIOD 2a COST 257 , 25 20 103 118,548 17,363 136,316 2,485 133,832 1-616 32,390 397 767,017 PERIOD 25 - SAFSTOR Dormancy with Dry Spent Fuel Storage Penod 25 Direct Decommissioning Activities 2b 1.1 Quartery Inspection 201.2 Semi-annual environmental survey 201.3 Prepare reports 2b.1.4 Bituminous roof replacement 1,780 267 2,047 2,047 2b.1.5 - Maintenance supplies 3,152 788 3,941 3,941 2b.1 . Subtotal Period 2c Activity Costs 4,932 1,055 5,988 5,988 Period 2b Collateral Costs 20.3,1 Spent Fuel Capital and Transfer 3,686 553 4,239 4,239 2b.3 Subtotal Perod 2b Collateral Costs 3,686 553 4,239 4,239 Period 2b Period-Dependent Costs 2b4.1 Insurance 12,376 1,238 13,614 13,614 20.4.2 Property Iases 2b.4,3 . Health physics supplies 1,612 403 2,015 2,015 2b.4.4 Disposal of DAWgenerated 155 129 649 187 1.130 1,130 10,141 203,219 2,490 2b.4.5 Plant energy budget 1,245 187 - 1,432 1,432 2b,4.6 NRC Fees 5,870 587 6,457 6,457 2b4.7 Emergency Planning Fees 4,323 432 4,756 4,756 2b4.8 Site O&M - 4,018 603 4,621 4,621 204.9 ISFSI Operating Costs 2,581 2 387 2,96 2,969 2b.4.10 Corporate Overhead 3,759 564 4,323 4,323 2b.4.1 1 Security Staff Cost 37,593 50639 43,232 43,232 1,046,171 2b.4.12 UtilityStaff Cost - 63,520 9,528 73,048 73,048 1,180,789 2b.4 Subtotal Period 2b Period-Dependent Costs 1,612 155 129 649 135,286 19,765 .157.596 9,601 147,994 10,141 203,219 2,490 2,196,960 2b.0 TOTALPERIOD 20 COST 1,612 .105 129 649 143,905 21,373 167,823 15,589 152,234 10,141 203,219 2,490 2,196,960 PERIOD 2 TOTALS 1,869 180 149 752 262,453 38,736 304,139 18,074 286.065 11,757 235,609 2,887 2,963,977 PERIOD 3a -Reactivate Site Following SAFSTOR Dormancy Pereid 3a OrienDconmnissioning Aotivitbis 3a.1.1 Prepare preliminary decommissioning cost 124 19 . 142 142 1,235 3a.1.2 Reoiew plant dwgs & specs. 437 66 503 503 4,370 3.1 .3 Perform detailed rod survey a 3a, 1.4 End product description 95 14 1099 109 950 3a1. 5 Detailed by-product inventory 124 19 142 142 1,235 3a1 .6 Define major work sequence 713 107 820 820 -7,125 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E71-5690-003 Preliminary DecommissioningCost Analysis Appendix A, Page 6 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Oecon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs . Cotinnenc Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Foot Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours 3a.1.7 Perform SER and EA 295 44 339 339 - 2,945 3a.1.6 Perform Site-Specific Cost Study 475 71 546 546 4,750 3a.1 .9 Prepare/submit License Termination Plan 389 58 448 448 - 3,891 3a.1.10 Receive NRC approval of (ermination plan Activity Specifications 3a.1.11.1 Re-activate plant &temporary facilities 700 105 805 725 81 7,002 3a.1.11.2 Plant systems 396 59 455 410 46 3,958 3a.1.11.3 Reactor internals 675 101 776 776 6.745 3a.1. 11.4 Reactorvessel 618 93 71S 710 6,175 3a.1.11.5 Sacrificial shield 48 7 55 55 475 3a.1.11.6 Moissure separatorstnvheaters 95 14 109 109 950 3a.1.11.7 Reinforced concrete 152 23 175 87 87 1,520 3a.1.11,8 Main Turbtine 198 30 228 228 1,984 3a.1.11.9 Main Condensers 198 30 228 228 1,98-4 190 1.900 3a. 1.11.10 Prs"ur, suppression structure 29 219 219 152 1,520 3s.1.11.11 DrywUet 23 175 175 2,964 3a.1.11.12 Plant structures & buildings 296 44 341 170 170 3n.1.11.13 Waste management 437 66 503 503 4,370 3a.1.11.14 Facility& site closeout 86 13 98 49 49 855 3s.1.11 Total 4,241 636 4,877 4,444 433 42,401 Planning &Site Preparations 3a.1.12 Prepare dismantling sequence 228 34 262 262 2,280 3a.1.13 Plant prep. &temp. svces S2.419 363 2,792 2,782 3'.1.14 Design water clean-up syslem 133 20 153 153 1,330 3a.1.15 RiggingiCont. CntldEnvtpsJtooting/etc. 2, 048 307 2,355 2,355 3ao1i16 Procure casksdfiners &containers 117 18 134 134 1,169 3s.1 Subtotal Period 3a ActivityCosts 11,836 1,775 13,612 13,179 433 73,681 Period 3a Period-Depondent Costs 3a.4.1 Insurance 468 47 515 515 3a.4.2 Property taxes 3a.4.3 Health physics supplies 257 64 321 321 3a.44 Heavy equipment rental 336 - - 50 386 386 3..4.5 Disposal of DAWgenerated - 6 5 26 - a 45 45 404 8,103 99 3a.4.6 Plant energy budget 1,655 248 1,904 1,904 3a.4.7 NRC Fees 265 27 292 292 3a.4.8 Silo O&M 1,085 163 1,248 1,248 3a.4.9 Corporate Overhead 1,499 225 1,724 1,724 3-14.1S Secudty Staff Cost 1,874 281 2,155 2,155 52,143 3 n4.11 UtilityStaff Cost S- 14,900 2,235 17,135 17.135 269.579 3a.4 Subtotal Perod 3a Period-Dependent Costs 593 6 5 26 21,747 3,348 25,726 25,726 404 8.103 99 321.721 3a.0 TOTALPERIOD 3a COST 593 6 5 26 33,584 5,123 39,337 38,904 433 4G4 8,103 99 395,402 PERIOD 3b - Decommissioning Preparations Period 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems 450 67 517 465 52 - 4,496 3b.1.1.2 Reactor internals 380 57 437 437 3,900 31,1.1.3 Remaining buildings 128 19 148 37 l1t-1 1,283 3b. 1.1.4 CRD housings &NIs 95 14 109 109 950 3b.1.1.5 Incore instrnmentation 95 14 109 109 950 TLG Se-rices Inc.

PilgrimNuclear Power Station Document Eli-5690-003 PreliminsaryDecomissaioningCost Analysis Appendix A, Page 7 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Sits LLRW NRC Spent Fuel site Processed Busal Volumes Burial I Utility and Oscun Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contrator' IB Activi..ty Inlay A*t h*i* []*rint4*n Cost Cot Costs Coots lost. Costs Costs Cootioo'en Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours I In ex ivi Descr Detailed Work Procedures (continued) 3b.1.1.6 Removal primary containment 190 29 219 219 1,900 3h. 1.1.7 Reactor vessel 345 52 397 397 3,449 3b.1 1.8 Facilitycloseout 114 17 131 66 66 1,140

- - 1,140 31.1 1.9 Sacrificial shield 114 17 131 131 95 14 109 55 55 950 3b.1.1.10 Reinforced concrete 3b.1.1.11 Main Turbine S 198 30 227 227 1,976 198 30 228 228 1,984 3b.1.1.12 Main Condensers 3b.1.1.13 Moisture separators & reheaters S 190 29 . 219 219 1,900 3b.1.1.14 Radwante building 259 39 298 268 30 2,594 3b1 .1.15 Reactor building 259 39 298 268 30 2,594 3b.1.1 Total 3,111 467 3,578 3,235 - 342 31,104 3.111 467 3,578 3,235 - 342 31,104 3o.1 Subtotal Period 3b ActivityCosts Pevod 3b Collateral Costs 3b.3.1 Decon equipment 731 - " 110 841 841 3b.3.2 . Pipe cutting equipment 957 143 1.190 1,100 393 Subtotal Period 3b Collateral Costs 731 957 253 1.941 1,941 Period 3b Period-Dependent Costs 394.1 Decon supplies 23 - 6 28 28 3b.4.2 Insurance 237 24 261 261 3b.4.3 Property taxes 3b.4A Health physico supplies 130 33 163 163 3b.4.5 Heavy equipment rental 170 26 196 196 13 - 4 23 23 205 4,107 50 3b.4.6 Disposal of DAWgenerated 3b.4.7 Plant energy budget 839 126 965 965 3b.4.8 NRC Fees 134 13 148 148 3b.419 Site O&M 805 121 926 926 3.,4.10 Corporate Overhead 760. 114 874 874 950 142 1,092 1,092 26,429 3b 4.11 Security Staff Cost 3b94.12 UtilityStaff Cost 11.260 1,689 12,949 12,949 200.064 3b.4 Subtotal Period 39 Period-Dependent Costs 23 301 3 3 13 14,985 2,297 17,625 17,625 205 4,107 50 226,493 39.0 TOTALPERIOD 3b COST 754 1,257 3 3 13 18,097 3,017 23,144 22,802 342 205 4,107 50 257,597 PERIOD 3 TOTALS 754 1,850 9 8 39 51,680 8,140 62,481 61,706 775 609 12,210 150 652,999 PERIOD 4a - Large Component Rernoval Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1 .1.1 Recirculation System Piping &Valves 15 57 10 19 20 259 94 474 474 82 737 - 98,221 1 ,585 4a.1 A2 Recirculation Pumps &Motors 8 36 14 39 45 264 93 499 499 360 1,609 ,.- 111,100 1,082 4a. 1.1.3 CROMs & Nis Removal 31 120 243 105 321 166 .986 986 - . -4,306 - - 1103309 '3,458 4a.1.1.4 Reactor Vessel Internats 84 1,444 3,297 1.032 3.332 142 3,894 .13,226 13,226 751 1,628 287 - 297,675 17,759 842 4a.1.1.5 Vessel & Inteals GTCC Disposal 30 - 1,240 9,605 9,605 - - 480 82,00 8,065

- 3,483 795 496 - 6,490 142 6,202 17,609 17,609 - 12,390 - - - 1,261,718 17,759 942 4a.1.1.6 Reactor Vessel 138 5,141 4,659 1,692 65 18,732 285 11,688 42,399 42,399 441 19,794 1,628 287 480 1,961,021 41,643 1,685 4a,1.1 Totals Removal of Major Equipment 4a.1.2 Main Turbine/Generator. 231 860 334 4,875 359 1,015 7,675 7,675 26,071 1,452 2,346,289 4,901 4a.1.3 Mein Condensers 459 459 279 3,683 286 826 5,993 5,993 37,201 1,987 1,772,471 9,789 TLG Services, InJ.

PilgrimNuclear Power Station Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Appendix A, Pages of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Site . LLRW NRC " Spent Fuel Site Processed Burial Volumes Burial I Utility anod Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Teem. Management Restoration Volume Class A Class B 6 Class C GTCC Protessed Craft Castrato redox Activito Description Cost Cost Costs Costs Costs Casts Costs Costs Cu. Feot Cu. Feet Co. Foot Cu. Foot Co. Feet Wt. Lbs. Manhours Manhours Cascading Cosls from Clean Building Demolition 4o...4.1 Reactor 478 72 . 549 549 7,024 4 2T 27 304" 4a.142 AOG Renlention 24 4a.1 4.3 Condenser Resube. 4 1 5 5 72 4a.1 4.4 Main Slack & Filter 4 1 5 5 61 -

4a.1.4.5 Turbine 210 31 241 241 3.354 4a.1.4 Totals 719 108 827 827 10,816 Disposal of Plant Systems 4a.1A.5.1 CIRCULATINGWATER 72 11 a3 - 83 - - 1,585 -

4a.1.52 CIRCULATINGWATER (RCA) 58 5 25 361 73 520 520 4,035 163,883 1.249 4a.1.5 3 CONDENSATE 250 7 37 543 150 987 967 6,077 246,780 5,295 4a.1.54 CONDENSATE (RCA) .414 20 103 1,505 347 2,389 2,389 16,a43 684,008 8,719 4as1 5.5 CONDENSATE DEMINERALIZER 237 11 31 268 134 139 820 820 - 2,996 522 167,700 4,992 4a 1 5.6 DEMINERALIZEDWATER &STORAGE 19 3 21 - 21 - - - '409 4o.1.5.7 DEMINERALIZEDWATER &STORAGE (RCA) 162 3 14 210 - 74 464 464 2,348 - 95,351 3,404 4a.1:5.8 EXTRACTIONSTEAM 16s1 10 34 298 147 128 776 778 3,332 564 165,891 3,471 4a.t .5.9 FEEDWATER 282 27 93 920 315 304 1,940 1,940 10,295 1,207 - 526,325 6,095 4a..5.1 0 FEEDWATER HEATERS 233 25 69 330 488 243 1,387 1,387 3,694 1,867 317,533 5,075 4a.1.5. GENERATOR GASCONTROL 16 0 1 11 - 6 34 34 122 - - 4,969 327 4a.f.5 12 HEATER DRAIN 193 9 28 232 128 120 710 710 2.598 490 - 149,407 4,103 4a. .5 13 LUBE OIL PURIFICATION&TRANSFER 162 4 "20 265 - 87 557 557 3,193 - 129,653 3,421 4a.1.5.14 MAIN STEAM 389 20 65 559 281 263 1;577 1,577 6,262 1,075 350,759 8,301 4a.1.515 MAINSTEAM MOISTURESEPARATORS 203 61 165 792 1,1701 493 2,665 2,885 8,865 4,481 - 762,080 4,586 4a,1 5.16 MECHANICALVACUUM 49 2 9 136 - 34 231 231 1,521 - 61,779 1,044 5 25 25 1 40 20 3,381 244 -

4as S.17 NEUTRON MONITORING 11 0 1 4 5 4a 1.5.18 OFFGAS &AUGMENTEDOFFGAS 327 27 89 764 383 308 1,899 1,899 8,555 1,468 479,185 7,093 4a 1.5f19 OFFGAS &AUGMENTEDOFFGAS (RCA) 469 34 94 742 452 359 2,150 2,150 8,303 1,756 492,482 9,846 -

4a.1.5.20 POST ACCIDENT SAMPLING 7 0 0 2 2 3 13 13 18 8 1,441 144 4a.1.5.21 REACTOR CORE ISOLATIONCOOLING 62 4 10 40 72 41 229 229 449 275 42,890 1,338 ,

4a.1 .522 SEAL OIL 22 0 2 25 10 59 59 280 . 11,370 . 456 4a.1.5 23 STATOR COOLING 40 0 2 31 15 88 86 348 14,124 834 4a.1 .5 24 TURBINE BUILDINGCLOSED COOLINGWATER 241 3 14 200 93 . 550 550 2,236 _90,795 5,066 4a.1.6 Totals 4,080 274 904 8,256 3,576 3,306 20,396 20,292 104 92,409 13,733 4,981,785 87,098 4a.1 .6 Scaffolding in support ofdecommissioning -- 1,829 . 14 9 110 4 - 477 2.443 2,443 - 1,154 55 50,391 21,971 4a.1 Subtotal Period 4a ActivityCosts 138 12,458 6,266 3,219 16,989 22,958 285 17,422 79,734 79,630 104 157,231 36,131 1,628 267 480 11,116,960 176,217 1,685 Period 4a Additional Costs 4a.2.1 Curie Surcharge (excluding RPV) 146 36 182 152 4a.2 Subtotal Period 4a AddiuionalCosts 146 36 182 182 Period 4adCotlateral Costs 4a.3.1 Process liquid waste 20 6 38 38 55 6,901, 11 4a.3.2 Small tool allow-nce 143 21 164 148 16 29 202 186 55 6,901 11 4a.3 Subtotal Period 4a Collateral Costs 4 143 20 16 Period 4a Period-Dependent Costs 4a.4.1 Decon supplies 34 - 8 42 42 4aA4.2 Insurance 356 36 391 391 4a.4.3 Property taxes 4a.4.4 Health physics supplies 816 204 1,020 1,020 4a.4.5 Heavy equipment rental 1.242 - - - 166 1,429 1,429 4a.4.6 Disposal of DAWgenerated 53 44 221 - 67 365 385 3,452 69,176 848 4a.4.7 Plant energy budget -- 1,193 179 1,372 1,372 4a.48 NRC Fees 249 25 273 273 TLG Services, Inc.

PilgrimNuclear PowerStation Document Eli-5690-003 PreliminaryDecommissioningCost Analysis Appendix A, Page 9 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR"Decommissioning Cost Estimate(

(thousands of 2005 dollars)

" Off-Site LLRW NRC , Spent Fuel Site Processed BurialVolumes Burial I - Utility and Activity Oncon Removal Packaging Transport Processing Disposal Other Total Total Lic. Tenm. Management Restoration Volume Class A GClssB Class C GTCC Processed Craft Contractor index Activity Description Cost Cost Costs Costs Costs Costs Cosls Contin enc Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt.. Lbs. Manhours Manhours Period 4a Period-Dependent Costs (continued) 4a.4.9 Site O&M 1,589 238 1,828 1,828 4a.4,10 Radwaste Processing Equipment/Services 281 42 323 323 4a.4.11 Corporate Overhead 1,138 171 1,308 1,308 4a,412 Security Staff Cost 1,422 213 1,635 1,635 - " 39,571 4a.4.13 UtilityStaff Cost S - - - 18,722 2,808 21,530 21,530 S - - 339,523 4a.4 Subtotal Period 4a Period-Dependent Costs 34 2,058 53 44 - 221 24,949 4,178 31,537 31,537 - - 3,452 - - - 69,176 848 379,094 4a.. TOTALPERIOD 4a COST 176 14,659 6.321 3,265. 16,989 23,344 25,234 21,665 111,655 111,534 121 157,231 39,583

• 1,682 287 480 11,193,030 177,075 380,779 PERIOD 4b - Site Decontamination Period 4b Direct Decommissioning Activities 4bh1.1 Remove spent fuel rocks 659 67 107 230 - 2,433 1,000 4,498 4,498 9,319 836,155 1,563 Disposal of Plant Systems 4b.1.2.1 CONTAINMENTATMOSPHERIC CONTROL 122 9 29 275 113 105 654 654 3,076 , 436 163,649 2,622 4b.1.22 CONTROL ROD DRIVEHYDRAULIC - 538 32 55 158 463 - 285 1,531 1,531 1,766 1,775 230,804 10,790 4b.1.2.3 CORE SPRAY 110 4 13 119 50 60 356 356 1,330 192 71,209 2,361 40.1.24 DIESEL FUEL OIL STORAGE &TRANSFER 28 4 32 - 32 S- 603 4b.1.2.5 DIESEL FUEL OIL STORAGE &TRANSFER (RCA) 12 0 1 19 6 38 38 208 8,428 255 4b.1 2.6 DIESEL GENERATOR &AUXILIARIES 5 1 6 6 -- 118 4b.1.2.7 ELECTRICAL CLEAN 336 50 386 - 7,450 4b.1.2.8 ELECTRICALCONTAMINATED 79 2 9 25 37 34 183 183 285 141 24,237 1,706 4b.1.2.9 ELECTRICALRCA 2,914 30 160 2,330 1,105 6,539 6,539 - 26,081 - 1,059,160 62,880 4b.1.2.10 FIRE PROTECTION 16 2 18 - - 18 - - 351 4b.1.2.11 FIRE PROTECTION (RCA) 92 I 7 108 40 250 250 1,211 49,177 1,882 4b.1.2.12 FUEL POOL COOLING & DEMINERALIZER 604 15 29 91 244 231 1,214 - 1,214 1,024 934 125,357 13,265 4b.1.2.13 HIGH PRESSURE COOLANTINJECTION 158 12 38 338 160 137 844 844 -

S 3,787 . 614 208,894, 3,408 4,1r2.14 HVACDIESEL GENERATOR 3 0 3 - 56 4b.1,2.15 HVACOFF GAS RENTENTION 530 380 595 26 72 337. 1,940 1,940 3 5,930 1,456 371,375 12.580 4b.1.2.16 HVACOTHER 337 51 387 - 387 - .- - 7,683 4b.1.2.17 HVACRADWASTE 520 23 48 137 407 262 1,396 1,396 - 1,528 1.558 201.755 10,896 4b.1.2.18 HVACREACTOR 3,561 196 565 4,640 2,616 2,345 13,923 13,923 51,939 10,025 3,008,290 74,852 4b 1.2.19 HVACTURBINE 3,214 190 584 5,038 2,522 2,296 13,844 13,944 56,387 9,664 3,156,705 68,040 411.2.20 INSTRUMENTAIR 140 2 8 121 55 325 325 1,356 - 55,057 2,754 4b..2.21 NUCLEARBOILER 125 33 71 295 530 223 1,281 1,281 3,297 2,049 317,636 2,793 4b.1.2.22 POTABLEWATER 1)5 2 9 130 - 47 293 293 1,457 59,155 2,153 4b.1.2.23 RADWASTECOLLECTION 3,677 104 213 497 1,895 1,510 7,896 7,896 5,559 7.780 877.051 80,526 4b.1.2.24 REACTOR BUILDINGCLOSED COOLINGWATER 265 15 40 313 198 170 " 1,001 1,001 3,507 759 210,433 5,570 4b.1.2.25 REACTOR WATER CLEANUP 129 11 24 78 200 99 541 541 875 768 104,158 2,739 4b.12.26 RESIDUAL HEAT REMOVAL 394 34 .88 433 612. 333 1,894 1,894 4,848 2,346 407,296 8,591 4b.1 2.27 ROOF DRAINS 8 1 9 9 - - 190 4b.1.2.28 RX RECIRC MOTORGENERATORAUXILIARIES 94 3 14 204 57 372 372 2,284 - 92,751 2.032 4b.1.2.29 SERVICEAIR 231 3 15 212 92' 552 552 S- 2,371 96,288 4.801 4b 1.2.30 SERVICE WATER 41 6 48 - 48 - - 933 461.2,31 SERVICE WATER (RCA) 527 15 75 1,089 308 2,013 2,013 12,187 494,923 10,678 40.1.2.32 STANDBY GAS TREATMENT 90 4 14 128 56 58 351 351 1,433 214 77.361 1,897 4b.1.2.33 STANDBY LIQUIDCONTROL 47 2 6 70 17 28 170 170 - 784 66 37.553 1,001 4b.1.2 Totals 19,118 765 2,184 17,378 10,504 10,339 60,289 59,400 889 194,507 40,778 11,508,700 408,455 4b.1.3 Scaffolding in support of decommissioning - 2,743 21 14 165 6 716 3,665 3,665 - 1,662 83 83,086 32,956 Decontamination of Site Buildings 4b.1.4.1 Reactor 3,594 2.331 126 414 4,582 357 3,231 14,634 i4,634 51,283 4,745 2,551,935 120,649 45 1 4.2 AOG Rentension 41 33 3 7 - 22 15 37 159 159 247 208 30,337 1,501 41.1.4.3 Condenser Relube 53 23 -' 4 10 3 24 40 157 157 32 317 - 32,928 1,518 TLG Services, Inc.

Pilgrim NuclearPower Stalion Doomeael E11-5905-003 Preliminary DecommissioningCostAnalysis Appendix A, Page 10 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Site LLRW NRC Spent Fuea Site Processed Buras Volumes Burial I Utility aneo Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Ceetactor index Activity Description Cost COst Costss ts ts Costs Cs.ts Centingen Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt, Lbs. Manhours Manheurs Decontamination of Site Buildings (continued) 4b.1.4.4 Main Stack &Filter 12 11 1 3 5 7 12 53 53 60 100 12,256 469 4b.1.4.5 Radwasta 157 110 16 36 51 81 141 592 592 567 1,204 130,144 5.373 4b.1,4.6 Turbine 397 244 30 81 188 175 347 1,463 1,463 2,102 2,328 315,404 12,39 4b.1.4.7 Spent Fuel Pool Area 199 1,198 330 775 75 5,850 1,822 0,448 9,448 840 28.318 2,700,126 26,317 4b.1.4 Totals 4,453 3,951 510 1.326 4,926 5,710 5,630 26,505 26,505 55,131 37.219 5,778,131 168,667 4b.1 Subtotal Period 45 Activity Costs 5,112 25.881 1,404 3,754 22.468 18,653 17.686 94,957 94,068 889 251,300 87,399 18.206,070 611,640 Period 4b Additional Costs 4b12.1 ISFSILicense Termination 1,193 11 274 1,027 1,417 810 4,732 - 4,732 11,609 1,136,593 17,786 2,560 41,2.2 AOG Filter Media Disposal - 50 66 140 - 50 305 305 - 4,060 48,720 380 -

41.2 Subtotal Period 45 Additional Costs 1,193 60 340 1,167 1,417 859 5,036 305 4,732 - 15,669 1,185,313 18,166 2,560 Period 4b Collateral Costs 4b.3.1 Process tiquid waste 16 - 12 11 78 30 147 147 213 26,811 42 -

45.3.2 Small Ioolallowance - 501 75 576 576 4b.3 Subtotal Period 4b Collateral Costs 16 501 12 11 78 105 723 723 213 26,811 42 Period 4b Period-Dependent Costs 404.1 Decon supplies 987 - 247 1,234 1,234 41b4.2 Insurance 1,395 140 1,535 1,535 4b.4.3 Property taxes 4b.4.4 Health physics supplies 2,984 746 3,730 3,730 4b.4.5 Heavy equipment rental 4,905 736 5,640 5,640 4b.4.6 Disposal of DAWgenerated 163 135 - 207 1,188 1,198 10.666 213,733 2,619 683 4b.4.7 Plant energy budget 3,697 555 4,252 4,252 45.4.8 NRC Fees 976 98 1,073 1,073 41.4.9 Site O&M 5,401 810 6,211 6,211 41.4.10 Radwaste Processing EquipmentServices 1,104 166 1,269 1,269 414.11 Corporate Overhead 4.464 670 5,134 5,134 4i4.12 Security Staff Cost 5,580 837 6,417 6.417 -- 155,286 4b4.13 UtilityStaff Cost 64,896 9,734 74,630 74.630 - 1,153,773 4b.4 Subtotal Period 4b Period-Dependent Costs 987 7,889 163 135 683 87,512 14,944 112,313 112.313 10,666 213,733 2,619 1,309.059 4b.0 TOTALPERIOD 4b COST 6,115 35,463 1,639 4,240 22,468 20.581 88,929 33,595 213,030 207,409 4,732 889 251,300 113,734 213 19,631,930 632,466 1,311.619 PERIOD 4e - License Termination Period 4e Direct Decommissioning Activities 4e.1.1 ORISE corinfratory survey 123 37 160 160 4e.1.2 Terminate license a 4e.1 Subtotal Period 4e ActivityCosts 123 37 160 160 Period 4e Additional Costs 4e.2.t License Termination Survey 5,347 1,604 6,951 6,951 105,930 4e.2 Subtotal Pedod 4e Additional Costs - 5,347 1,604 6,951 6,951 105930 -

Period 4e Perod-Dependent Costs 4e.4.1 Insurance 347 35 381 381 4e.4.2 Properly taxes 4e.4.3 Health physics supplies 563 - - 141 704 704 6 33 33 299 5,994 73 40.4.4 Disposal of DAW generated 19 -

4e.4.5 Plant energy budget 245 37 282 282 4e.4.6 NRC Fees 242 24 267 267 4e.4.7 Site O&M 612 92 704 704 4e.4.8 Corporate Overhead 1,109 166 1,275 1,275 TLG Scrvices, Inc.

Pilgrim Nuclear PowerStation Document Ell-5690-003 PreliminaryDecommissioningCost Analysis Appendix A, Page11 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

Off-Site LLRW NRC - Spent Fuel Site Processed BurbialVolores Burial I utiity and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total LID.Term. Management Restoration Volume Class A Closs B Class C GTCC Processed Croft Contracton index Activity Descrption Cost Cas Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet We, Lbs. Machours Manhours Period 4e Period-Dependent Costs (continued) 4e.4.9 Security Staff Cost - -499 75 574 574 13,986 4el4.10 UtilityStuff Cost S - - 7,754 1,163 8,917 8,917 -- - 130,757 4e.4 Sobtotal Period 4e Poriod-Dependent Costs 563 4 19 10,807 1,738 13,136 13,130 299 5,994 73 144,643 4e.0 TOTALPERIOD 4o COST 563 5 4 19 16,277 3,379 20,247 20.247 - - 299 5,994 106,003 144,643 PERIOD 4 TOTALS 6,291 50,686 7,965 7,509 39,457 43,944 130,441 58,639 344,932 339,190 4,732 1,010 408,531 153,616 1,895 287 480 30,83M,960 915,545 1,037,040 PERIOD 5b -Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b,1.1.1 Reactor 2,785 410 3,203 3,203 41,618 '

5b.1.1.2 AOG Rentention 218 33 250 250 2,846 5b.1,..3 Condenser Relobe 48 7 55 55 641 51h1.1,4 Contractor Office -Warehouse 113 17 130 130 1,661 5b.1.1.5 Diesel Generator 159 24 183 183 2,594 5b.1.1.6 Discharge Structure &Channels 2 0 3 3 18 5b.1.1.7 Engineering & Plant Support 282 42 324 324 4,131 5b.1.t.8 Fencing &Pavement 801 120 921 921 12,411 51b1.1,9 Intuko Strcctare 171 26 197 197 2.336 35 5 41 41 850 5b.1.1.10 Main Stack & Filter 0.,1.11 Miscltaneous Site Structures 2,029 304 2,333 2,333 29,121 Sb.1.1.12 Radweuste 475 71 546 546 7,651 5b.t.1.13 SSW Pipe Vault 5 1 5 5 68 5b.1.1.14 Switchyard 13 2 15 15 245 51b.1.15 Transformer Pads 34 5 39 39 556 5b.1.l.t1 TotInn 1t,976 296 2,272 2,272 32,182 5b.1.1.17 Turbine Pedestal 500 75 575 575 6,128 5b.1.t Totals 9,647 1,447 11,094 11,094 144,957 Site Closeout Activilies 5b.1.2 BackFill Site 697 105 801 801 2,627 5b.1.3 Grade & landscape site 53 - 8 60 60 185 170 5b,1.4 Final report to NRC 148 22 170 - 1,482 3b.1 Subtotal Period 5b ActivityCosts 10,396 148 1,582 12,126 170 - 11,955 147,769 1,482 Period 5b Additional Costs 3b.2.1 JSFSJDemolition 1,025 41 160 1,226 - 1,226 4.128 160 5b.2.2 Intake and Discharge Cofferdam 377 - 57 433 433 4,572 -

50.2.3 Concrete Crushing 330 6 50 387 387 1,952. -

47 267 2.046 1,226 020 10,652 160 5b.2 Subtotal Period 5b Additional Costs 1,732 Period 5b Collateral Costs 5b.3.1 Small too(auloanme 126 19 145 - 145 5b.3 Subtotal Period 5b Collateral Costs 126 19 145 - 145 - - - - - - - -

Period 50 Period-Dependent Costs 5b.4,1 Insurance 5b.4.2 Property taxes 5.4.3 Heavy equipment rontal 2,829 424 3,253 3.253 5b4.4 Plant energy budget 207 31 238 238 5b.4.5 Site O&M 664 100 763 763 51b4.6 Corporate Overhead 1,077 202 2,158 2,158 51.4.7 Security Staff Cost 845 127 971 971 23,503 TLG Services, Inc.

PilgrimNuclear PowerStation Document Ell-5690-003 PreliminaryDeeemnmissioning CostAnalysis Appendic4, Page 12 of 12 Table A Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2005 dollars)

-Off-Site - LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Teom. Management Restoration Volume classA Claus B Class C GTCC Processed Craft Contractor Index Activi Description Cool Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt. Lbs. Manhairs Manhours Period 5b Period-Dependent Costs (continued) 5b148 UtilityStaff Cost - - 11,064 1,660 12,724 12,724 185,411 5b.4 Subtotal Period 5b Pevod-Dependent Costs 2,829 14,656 2,623 20,108 763 19,344 208,914 5b.0 TOTALPERIOD 5b COST 15,083 14,852 4,490 34,424 934 1,226 32,265 158,421 210,556 PERIODS TOTALS 15,083 14,852 4,490 34,424 934 1.226 32,265 158,421 210,556 TOTALCOST TO DECOMMISSION 13,841 74,595 8,286 8,030 - 39,457 45,443 543,135 127,095 859,883 - 517,240 308,593 34,050 408,531 194,998 3,313 287 480 31,320,610 1,246,346 6,590,199 TOTAL COST TO DECOMMISSIONWITH 17.34%CONTINGENCY: $859,l83 thousands of 2005 dollars TOTALNRC LICENSE TERMINATIONCOST IS 60.15% OR: $517.240 thousands of 2005 dollars SPENT FUEL MANAGEMENTCOST IS 35.89% OR: $308,593 thousands of 2005 dollars ION-NWUCLEAR DEMOLITIONCOST IS 3.96% OR: $34,050 thousands of 2005 dollars TOTALLOW-LEVELRADIOACTIVEWASTE VOLUME BURIED (EXCLUDINGGTCC: 198,599 cubic feet -

TOTALGREATER THAN CLASS C VOLUMEGENERATED: 4W0 cubic feet TOTAL SCRAP METALREMOVED: 14,569 tons TOTAL CRAFTLABOR REQUIREMENTS: 1,246,346 man-hours End Notes n/a - indicates that Ibis activity not charged as decommissioning expense.

a - indicates that this activity performed bydecommissioning staff.

S - indicates that this value is less than 0.5 but is noo-zero.

a cell containing - indicates a zero value TLG Services, oac.