NL-08-144, Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in Accordance with 10 CFR 50.54 (Bb) and 10 CFR 50.75(f)(3)

Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in Accordance with 10 CFR 50.54 (Bb) and 10 CFR 50.75(f)(3)

ML083040378
Person / Time
Site:	Indian Point
Issue date:	10/23/2008
From:	Joseph E Pollock Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2009-0026, NL-08-144
Download: ML083040378 (128)

Text

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 r-f-- Buchanan, N.Y. 10511-0249 ILtfl ( Tel (914) 734-6700 J. E. Pollock Site Vice President October 23, 2008 Re: Indian Point Units 1 & 2 Docket Nos. 50-3 & 50-247 License Nos. DPR-5 & DPR-26 NL-08-144 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Unit 1 & 2 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3)

Reference Entergy letter NL-08-147 to NRC, "Notification of Delay of Submittal for Unit 1 & 2 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3)," dated September 29, 2008

Dear Sir or Madam:

Pursuant to 10 CFR 50.54(bb) licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit to the NRC the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor facility following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U. S. Department of Energy for ultimate disposal. The Program for Maintenance of Irradiated Fuel at the IPEC Unit 1 & 2 nuclear units is included as .

Pursuant to 10 CFR 50.75(f)(3), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit a preliminary decommissioning cost estimate to the NRC. The cost estimates to decommission the IPEC Unit 1 & 2 nuclear units are included as Enclosures 1 and 2 respectively.

Docket Nos. 50-3 & 50-247 NL-08-144 Page 2 of 2 It should be noted that this letter is delayed one month as explained in the referenced letter.

Additionally it should be noted that IP2 has submitted an application for License Renewal pursuant to 10 CFR 54. IP2 operating license is scheduled to expire on Sept 28, 2013. Based on this, Entergy requests that the NRC schedule the review of this information following a final decision on the License Renewal application.

There are no commitments in this submittal.

In accordance with 10 CFR 50.91(b), a copy of this application, with the associated attachments, is being provided to the designated New York State official.

Should you have any questions concerning this submittal, please contact Mr. Robert Walpole at 914-734-6710.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the Z-i day of October, 2008.

Sincerely, Site Vice President Indian Point Energy Center

Attachment:

1. Unit No. 1 and 2 10 CFR 50.54(bb) Program for Maintenance of Irradiated Fuel

Enclosures:

1. Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 1

2. Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 2 cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 Mr. John P. Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspectors Office, Indian Point 2 & 3 Mr. Paul Eddy, NYS Department of Public Service Mr. Robert Callender, Vice President, NYSERDA

Attachment 1 to NL-08-144 Unit No. 1 and 2 10 CFR 50.54(bb) Program for Maintenance of Irradiated Fuel ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 1 AND 2 DOCKET NOS. 50-3 & 50-247

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units I and 2 Attachment I DOCKET NOS. 50-3 & 50-247 10 CFR 50.54(bb) Program for Maintenance of Irradiated Fuel

1. Background and Introduction Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Operations, Inc. (Entergy) are seeking. renewal of the operating license for the Indian Point Energy Center, Unit 2 (IP-2), currently set to expire on Sept. 28, 2013. However, pursuant to 10 CFR 50.54(bb),

licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit written notification to the Nuclear Regulatory Commission (NRC) for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title, to the irradiated fuel and possession of the fuel is transferred to the U.S. Department of Energy (DOE) for ultimate disposal. Since Entergy has submitted an application for License Renewal pursuant to 10 CFR 54, Entergy requests that the NRC schedule the review of this information following a final decision on the License Renewal application.

This document also addresses the management of the spent fuel from Unit 1 (IP-1). The IP-1 spent fuel has been transferred from the wet storage pool to an Independent Spent Fuel Storage Installation (ISFSI) located on the IPEC site. The 160 IP-1 spent fuel assemblies are stored in five (5) multi-purpose canisters (MPCs). The ISFSI is operated and maintained by IP-2.

2. Spent Fuel Management Strategy Completion of the decommissioning process is highly dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was removed from service. The Entergy's current spent fuel management plan for the IP-1 and IP-2 spent fuel is based in general upon: 1) a 2017 start date for repository operations and 2) expectations for spent fuel receipt by the DOE. The Company projects that the IP-1 and IP-2 fuel could be removed from the site as early as 2043, if the oldest fuel allocation receives the highest priority and the geologic repository is able to achieve the DOE' s stated annual rate of transfer (3,000 metric tons of uranium year).

The NRC requires (in 10 CFR 50.54(bb)) that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. The IP-1 fuel has been relocated to the ISFSI. Interim storage of the IP-2 spent fuel, until the DOE takes receipt, will be in the IP-2 fuel storage building's storage pool and/or at the ISFSI.

IP-2 is projected to generate 1,672 spent fuel assemblies through the end of its currently

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment I DOCKET NOS. 50-3 & 50-247 licensed operations in 2013. An ISFSI has been constructed to support plant operations within the owner controlled area. This facility will also be used for post-shutdown dry fuel storage. The majority of the assemblies stored in the IP-2 fuel storage building's spent fuel storage pool at the time of shutdown are loaded into MPCs and moved into storage casks on the ISFSI pad by 2019. The remaining assemblies are transferred from the pool directly to the DOE in DOE-provided Transport, Aging and Disposal (TAD) canisters. Over the next 24 years, the MPCs are periodically off-loaded into a DOE transport cask such that all IP-2 canisters (and the five IP-1 canisters) are removed from the site by the year 2043. The Company's analysis conservatively assumes, for purposes only of this report, that the Company does not employ DOE spent fuel disposal contract allowances for up to 20% additional fuel designation for shipment to DOE each year.

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

3. Cost Considerations The total costs to 'decommission IP- 1 and IP-2 are delineated in the "Preliminary Decommissioning Cost Analysis" (References 1 and 2). In these documents, decommissioning costs are allocated into the three major categories of license termination, spent fuel management and site restoration. The allocations are reproduced in Tables 1 ,and 3 (Summary of Major Cost Contributors) for IP-1 and IP-2, respectively.

All costs are reported in 2007 nominal dollars.

The timing of the spent fuel management expenditures ($15.929 million for IP-1 and

$178.256 million for IP-2) are shown in Tables 2and 4. The expenditures include direct costs (e.g., for handling, packaging, storing and transferring the spent fuel) as well as indirect cost such as program management and oversight, security, pool and ISFSI operating costs, fees, insurance, etc., projected to be incurred over the post-operations storage period.

The significant contributors to the direct cost of IP-2 spent fuel management (the majority of the costs for IP-1 have already been expended) are identified in Table 5. As shown, 'costs are included for the procurement of multi-purpose storage canisters as well as the loading and transfer costs associated with transferring the spent fuel from the pool to the ISFSI pad or into a DOE transport cask and the eventual transfer of the fuel at the ISFSI to the DOE. The direct cost of $59.085 million is a subset of the $178.256 million shown in Tables 3 and 4. The timing of the direct spent fuel management expenditures

($59.085 million) is shown in Table 6.

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units I and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 It must also be noted that these figures will vary based on actual DOE performance, including the actual cask provisions and requirements that DOE settles upon. At this time, DOE has not identified any transport casks or requirements. Therefore, there is considerable uncertainty as to the actual costs that may have to be incurred; and uncertainty as to whether the DOE will agree to bear certain of those costs. Major scheduling milestones are identified in Table 7.

At shutdown, the IP-2 spent fuel pool is expected to contain freshly discharged assemblies from the most recent refueling cycles. Over the next eight years (the IP-2 pool is also used to support Unit 3) the assemblies are packaged into TADs for transfer to the DOE or MPCs for transfer to the ISFSI. It is assumed that this time period is sufficient to meet the decay heat requirements for both transport and storage.

The decommissioning scenario assumes that the existing ISFSI can accommodate the spent fuel remaining in the IP-2 pool at shutdown that (it is assumed for purposes of this report) cannot be transferred directly to the DOE. To support decommissioning operations, Entergy anticipates loading 34 MPCs with the assemblies stored in the IP-2 fuel building's spent fuel pool. The MPCs will then be placed in storage casks on the ISFSI.

In the absence of identifiable DOE cask requirements, the design and capacity of the MPCs is based upon a commercial dry cask storage system (Holtec HI-STORM). The Holtec multi-purpose canister has a capacity of 32 fuel assemblies at a unit cost of approximately $720,700. An additional cost of $329,700 is allocated for the concrete storage overpack. It should be noted that Entergy's contract with the DOE requires DOE to provide transport casks to Entergy, but for present purposes, this estimate includes those costs.

An average unit cost of $373,700 was estimated for the labor and equipment to load, seal and transfer each MPC from the storage pool into a DOE transport cask or to the ISFSI.

A unit cost of $78,500 was estimated for the final transfer of the MPC at the ISFSI into a DOE transport cask (50% of the cost incurred for transferring the spent fuel from the pool).

Operation of the IP-2 spent fuel pool is discontinued in 2021 once the fuel from both IP-2 and IP-3 has been transferred to dry storage. ISFSI operations continue until such time that the. DOE is able to complete the transfer of, the fuel from all three units to a federal repository (currently anticipated to be in 2045 for IP-3).

4. ISFSI Decommissioning With the spent fuel removed from the site, the ISFSI is available for decommissioning. It is assumed that once the MPCs containing the spent fuel assemblies have been removed, any required decontamination performed on the storage modules and the license for the facility terminated, the modules can be dismantled using conventional techniques for the

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 demolition of reinforced concrete. The concrete storage pad can then be removed and the area regraded. The cost estimated to decontaminate the ISFSI to the extent necessary to release the facilities for conventional demolition is estimated at $1.8 million.

Conventional demolition of the remaining overpacks and pads and restoration of the affected area of the site is estimated at $1.3 million.

5. Financial Assurance As of the year ending December 31, 2007, the trust fund balance for IP-i was approximately $271.19 million. The IP-2 decommissioning trust fund balance, including the provisional fund, was approximately $347.20 million (Reference 3) for a total of

$618.39 million.

As shown in Reference 1, the cost to decommission IP-1 is estimated at approximately

$590.930 million (in 2007 dollars). The estimate was based upon a scenario under which the unit would remain in safe-storage until decommissioning operations commence on IP-2 (after being placed in safe-storage for a period such that decommissioning of both IP-1 and IP-2 is complete no later than 60 years after cessation of permanent operations of the last operating unit on the site). Approximately 93% of the total or $547.458 million is estimated to be required to terminate the provisional operating license and 3% of the total or $15.929 million to transfer of the spent fuel to the ISFSI (the remaining 4% is associated with site restoration activities). Costs spent to date and forecasted amounts through the 3d quarter of 2013 (current license expiration of IP-2) are assumed to be funded from operations, as is currently being done. As shown in Table 8,- this amounts to

$105.9 million for costs associated with maintaining the unit in safe-storage, performing necessary repairs and facility upkeep and supporting the groundwater investigation, and

$12.917 million for containerizing, relocating the spent fuel from the wet pool to the ISFSI, and for IP-I's share of the costs for emergency planning.

As shown in Reference 2, the cost to decommission IP-2 is estimated at approximately

$920.5 million (in 2007 dollars). The estimate was based upon a scenario under which the unit would cease operating in 2013, be placed into long-term storage (such that decommissioning is complete no later than 60 years after cessation of permanent operations of the last operating unit on the site) and ultimately decommissioned in conjunction with the two other units at the site. Approximately 72% of the total or

$659.351 million is estimated to be required to terminate the operating license and 19%

of the total or $178.256 million to manage the spent fuel until such time that it can be transferred to the DOE (the remaining 9% is associated with site restoration activities).

The decommissioning funding plan is shown in Table 8. It uses a 2% real growth in the trust funds over time to demonstrate that the identified scenario is financially viable (i.e.,

that a surplus is shown in the fund at the completion of decommissioning). Although the decommissioning trust fund is for radiological decommissioning cost only, to the extent that the trust fund balance exceeds costs required for radiological decommissioning, these funds would be available to address costs incurred by the licensee including spent fuel

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units I and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 management costs. The licensee acknowledges the need for an exemption pursuant to 10 CFR 50.12(a) to use radiological decommissioning trust funds for anything beyond decommissioning activities as defined in 10 CFR 50.2. The licensee further acknowledges the need for Commission approval pursuant to 10 CFR 50.82(a)(3) for completion of decommissioning beyond 60 years for earlier-shutdown reactors on the site.

It should be noted that the projected expenditures for spent fuel management identified in the decommissioning cost'analysis do not consider the outcome of the litigation (including compensation for damages) with the DOE with regards to the delays incurred by Entergy in the timely removal of the spent fuel from the site. Entergy views the extended spent fuel management costs to be damages that should be paid by the government because of the Department of Energy's breach of the spent fuel disposal contract.

6. References

1. "Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 1," Document No. E11-1583-004, TLG Services, Inc., October 2008

2. "Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 2," Document No. E11-1583-003, TLG Services, Inc., October 2008

3. Entergy Letter ENOC-08-00028, dated May 08, 2008, "Decommissioning Fund Status Report"

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 1 Indian Point Energy Center, Unit 1 Summary of Major Cost Contributors (thousands, 2007 dollars)

License Spent Fuel Site Termination Management Restoration Total Decontamination 8,442 - 8,442 Removal 81,600 20,195 101,794 Packaging 26,806 - 26,806 Transportation 39,940 - - 39,940 Waste Disposal 88,373 - - 88,373 Off-site Waste Processing (off-site) 14,031 - 14,031 Program Management II 77,872 - 6,917 84,789 Corporate A&G - -_ ___

Site O&M 10,622 - - 10,622 Spent Fuel Management 2- 15,756 - 15,756 Insurance and Regulatory Fees 34,881 173 - 35,054 Energy 14,627 - 431 15,058 Radiological Characterization 11,764 - 11,764 Property Taxes - - _ _ _

Miscellaneous Equipment 14,058 - 14,059 Environmental 33,464 - - 33,464 IP-l Project/Recurring Costs 90,978 - - 90,978 Total 547,458.1 15,929 27,543 590,930 111 Includes security and engineering 121 Includes costs spent to date and an allocation of site emergency planning fees through 2015 (IP-3 shutdown)

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment I DOCKET NOS. 50-3 & 50-247 TABLE 2 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Spent Fuel Management Cost

-(thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other

• Totals 2001-2003 0 0 0 0 0 0 2004 0 0 0 0 0 0 2005 0 0 0 0 0 0 2006 0 0 0 0 0 0 2007 1,187 3,860 0 0 0 5,047 2008 0 0 0 0 1,512 1,512 2009 0 0 0 0 1,339 1,339 2010 0 0 0 0 1,339 1,339 2011 0 0 0 0 1,339 1,339 2012 0 0 0 0 1,339 1,339 2013 0 0 0 0 1,339 1,339 2014 0 0 0 0 1,339 1,339 2015 0 0 0 0 '1,339 1,339 Total 1,187 3,860 0 0 10,882 15,929

• Prorated share of site Emergency Planning Fees

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 3 Indian Point Energy Center, Unit 2 Summary of Major Cost Contributors (thousands, 2007 dollars)

License Spent Fuel Site Termination Management Restoration Total Decontamination 13,539 - - 13,539 Removal 86,741 2,058 45,099 133,898 Waste Packaging 13,502 3 - 13,505 Transportation 21,005 119 - 21,124 Waste Disposal 63,760 107 - 63,867 Waste Conditioning (Off-site) 32,441 - - 32,441 Program Management i 246,534 73,658 36,506 356,698 Corporate A&G 33,688 - - 33,688 Site O&M 22,246 3,709 - 25,955 ISFSI Related 121 - 95,895 - 95,895 Spent Fuel Pool Isolation 10,503 - - 10,503 Insurance and Regulatory Fees 47,813 742 - 48,555 Energy 31,888 1,966 1,260 35,114 Radiological Characterization 17,072 - - 17,072 Property Taxes __- _ -_

Miscellaneous Equipment 15,098 - 4 15,102 Environmental 3,521 - - 3,521 Total 659,351 178,256 82,869 920,477 H1 Includes security and engineering 121 Includes capital costs for multi-purpose storage containers, packaging and handling (transfer pool to ISFSI or DOE and ISFSI to DOE)

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment I DOCKET NOS. 50-3 & 50-247 TABLE 4 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2013 0 0 0 0 514 514 2014 0 0 0 0 1,974 1,974 2015 6,025 4,762 238 0 2,255 13,279 2016 7,989 6,314 315 0 2,352 16,971 2017 7,968 6,297 314 0 2,345 16,924 2018 7,968 6,297 314 0 2,345 16,924 2019 7,968 6,297 314 0 2,345 16,924 2020 7,989 6,314 315 0 2,352 16,971 2021 4,728 3,207 155 0 1,629 9,720 2022 1,577 201 0 0 933 2,711 2023 1,577 201 0 0 933 2,711 2024 1,581 202 0 0 936 2,718 2025 1,577 201 0 0 933 2,711 2026 1,577 201 0 0 933 2,711 2027 1,577 201 0 0 933 2,711 2028 1,581 202 0 0 936 2,7181 2029 1,577 201 0 0 933 2,711, 2030 1,577 201 0 0 933 2,711 2031 1,577 201 0 0 933 2,711 2032 1,581 202 0 0 936 2,718 2033 1,577 201 0 0 933 2,711 2034 1,577 201 0 0 933 2,711 2035 1,577 201 0 0 933 2,711 2036 1,581 202 0 0 936 2,718 2037 1,577 201 0 0 933 2,711 2038 1,577 201 0 0 933 2,711 2039 1,577 201 0 0 933 2,711 2040 1,581 202 0 0 936 2,718 2041 1,577 201 0 0 933 2,711 2042 1,577 201 0 0 933 2,711 2043 1,577 201 0 0 933 2,711 2044 1,581 202 0 0 936 2,718

Eritergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 4 (continued)

Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2045 1,503 192 0 0 889 2,585 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 _ ___0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 2055 0 0 0 0 0 0 2056 0 0 0 0 0 0 2057 0 0 0 0- 0 0 2058 0 0 0 0 0 0 2059 0 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0 2062 0 0 0 0 0 0 2063 0 0 0 0 ____ 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 423 191 0 81 666 1,361 2068 137 68 0 26 215 446 2069 32 280 0 -0 6 318 2070 32 280 0 0 6 318 2071 32 280 0 0 6 318 2072 31 276 0- 0 6 314 Total 89,115 45,689 1,966 107 41,379 178,256

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units I and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 5 Indian Point Energy Center, Unit 2 Significant Cost Contributors SpentFuel Management - Direct Expenditures ........( .........

7....0do

.ars _*

Spent Fuel Transfer Facility. 1,884,954 Capital Costs of ISFSI MPCs and Overpack 35,711,J3-33

'M PC Lioadaing -Costs........ .................. ..... ............J ,179,417 MPC Transfer. Costs from Pool to DOE 3,042,034

..MPC Transf.-er Costs C Transfer from Pool C.osts from to oISFSI IF..i. DOE .. ....... ...... .............................................

. 9 ....

3.,96....

, 9838, Total 59,085,429_1

• Contingency has been added to all costs (15%)

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 6 Indian Point Energy Center, Unit 2 Estimated Expenditures for Spent Fuel Packaging Storage and Canister Transfer

• ISFSI to Pool to Pool to ISFSI Pool to Pool to DOE Fuel DOE DOE Cask ISFSI ISFSI Transfer Total Year Transfer Loading Transfer Costs Loading -- Transfer - w ($2007) 2013 0 -0 0 0l 0 0 0 0 2014 0 0 0 0 0 01 0 0 K2015 0 _0 0 _ 0 0 01 0 0 2016 0 0 0 14,704,667 0 0 0 14,704,667 2017 0 0 0 19,956,333 3,032,167 2,199,113 0 25,187,613 2018 0 649,750 471,239 1,050,333 4,115,083 2,984,511 0 9,270,916 2019 0 649,750 471,239 0 216,583 157,080 0 1,494,651 22020

..0 . . . .........................

. 00 .................

--,.2.....

649,750 3*..2P. _ *............. 0 -!............. .. 0 . .....

• 471,239 .....

. . . 0. . ................................

~ 0 * .R._

1,120,989............

2021 0 866,333 628,318 0 0 0 0 1,494,651 2023 0 0 0 0 0 0 314,159 314,159 2024 0 0 0 0 0 0[ 157,080 157,080 2025 0 0 0 0 0 0 157,080 157,080 2026 0 0 0 0 0 0 157,080 157,080 2027 2028.

.0 00. 0 00 00 0 0. 235,619035 235,6190___

2029 0 0 0 0 0 0, 235,619 235,619 12030 0 0 0 0 0 oF 0 0 2031 0 0 0 0 0 0 157,080 157,080 20 .......

2p3 0...... 0 0o oJ 0 .. ....o .. 0 .........

{2032 20o33 00 00 00 000 0 0~

9L[157,080 0 157,0800

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

2038 0 0 0 0 0O0 0 0 2039 0 0 0 0 0 0 235,619 235,619 2040 0 0 0 0 0 0 235,619 235,619 2041 0 0 0 0 0 0 0 0

._4 2043 2 ...

. 0 0

0 0 0 0-Q 157,080 157,08Q 0 0 0 -0 863,937 863,937

____________ __________ 4 ------

1,884.. 954.............

....... ... 2,81..5,5.83 .......... 34.. 35,71 1,333 . 7,363,833 1 5,340,703 .

2 .04.2., ... 3,926,988 59,085,429

• A 15% contingency factor has been applied to all spent fuel related costs

• • Includes the cost to transfer six casks containing IP- I spent fuel

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 7 Indian Point Energy Center, Unit 2 Projected Schedule and Milestones Major Milestones and Fuel-Related Events Currently scheduled cessation of plant operations September 2013 ISFSI available Pre-shutdown First MPC transferred post-shutdown from pool to ISFSI 2017 Last MPC transferred post-shutdown from pool to ISFSI 2019 End of wet storage pool operations t'j 2021 DOE begins to receive commercial spent fuel 2017 1st fuel assembly removed from site 2018 Last Indian Point-2 fuel assembly leaves site 2043 Last year of ISFSI operations [2] 2045 ISFSI decommissioned [3] 2067 - 2068 ISFSI demolition tJJ 2069 - 2072

[I]

Extended use to support Indian Point 3 fuel transfer

[2]

ISFSI operational until Indian Point 3 fuel transfer complete

[31 ISFSI decontaminated and dismantled in conjunction with decommissioning of the three nuclear units on site

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units I and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 8 Decommissioning Funding Plan IP-1 Coordinated with IP-2, 2013 Shutdown and 60-Year SAFSTOR Basis Year 20071 Fund Balance $618.383 (millions)

Annual Escalation Annual Earnings

_______ I ________

A F 0.00%

2.00%}11 B C D E F G IP-1 IP-2 License License, IP-1 IP-2 Decommissioning Termination Termination Spent Fuel Spent Fuel Total Total Cost Trust Fund Cost Cost Cost Cost Cost Escalated at Escalated at 2%

Estimate Estimate Estimate Estimate Estimate 0% (minus expenses)

Year (millions) (millions) (millions) (millions) (millions) (millions) (millions) 2001 618.383 2002 630.751 2003 $105.900 $12.917 643.366 2004 million million 656.233 2005 spent and spent and 669.358 budgeted budgeted 2006 682.745 through 3rd through 3 rd 2007 quarter of 618.383 quarter of 2008 2013 funded 2013 630.751 2009 by funded by 643.366 2010 operations operations 656.233 2011 669.358 2012 682.745 2013 1.059 11.164 0.335 0.514 13.07 13.072 683.328 2014 4.236 49.271 1.339 1.974 56.82 56.820 640.174 2015 4.236 25.307 1.339 13.279 44.16 44.161 608.817 2016 2.656 3.711 16.971 23.34 23.338 597.655 2017 2.649 3.701 16.924 23.27 23.274 586.334 2018 2.649 3.701 16.924 23.27 23.274 574.787 2019 2.649 3.701 16.924 23.27 23.274 563.008 2020 2.656 3.711 16.971 23.34 23.338 550.931 2021 2.649 3.688 9.720 16.06 16.057 545.892 2022 2.649 3.676 2.711 9.04 9.036 547.774 2023 2.649 3.676 2.711 9.04 9.036 549.694 2024 2.656 3.686 2.718 9.06 9.060 551.627 2025 2.649 3.676 2.711 9.04 9.036 553.624 2026 2.649 3.676 2.711 9.04 9.036 555.660 2027 2.649 3.676 2.711 9.04 9.036 557.738 2028 2.656 3.686 2.718 9.06 9.060 559.832 2029 2.649 3.676 2.711 9.04 9.036 561.993 2030 2.649 3.676 2.711 9.04 9.036 564.197 2031 2.649 3.676

-- -- --------- 2.711 9.04 9.036 566.445

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units I and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 8 (continued)

Decommissioning Funding Plan IP-1 Coordinated with IP-2, 2013 Shutdown and 60-Year SAFSTOR Basis Year 2007 Fund Balance $618.383 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C D E F G IP-I IP-2 License License IP-1I IP-2 Decommissioning Termination Termination Spent Fuel Spent Fuel Total Total Cost Trust Fund Cost Cost Cost Cost Cost Escalated at Escalated at 2%

Estimate Estimate Estimate Estimate Estimate 0% (minus expenses)

Year (millions) (millions) (millions) (millions) (millions) (millions) (millions) 2032 2.656 3.686 - 2.718 9.06 9.060 568.714 2033 2.649 3.676 - 2.711 9.04 9.036 571.052 2034 2.649 3.676 - 2.711 9.04 9.036 573.437 2035 2.649 3.676 - 2.711 9.04 9.036 575.870 2036 2.656 3.686 - 2.718 9.06 9.060 578.327 2037 2.649 3.676 - 2.711 9.04 9.036 580.858 2038 2.649 3.676 - 2.711 9.04 9.036 583.439 2039 2.649 3.676 - 2.711 9.04 9.036 586.072 2040 2.656 3.686 - 2.718 9.06 9.060 588.733 2041 2.649 3.676 - 2.711 9.04 9.036 591.472 2042 2.649 3.676 - 2.711 9.04 9.036 594.265 2043 2.649 3.676 - 2.711 9.04 9.036 597.114 2044 2.656 3.686 - 2.718 9.06 9.060 599.997 2045 2.611 3.675 - 2.585 8.87 8.871 603.126 2046 1.826 3.668 - 5.49 5.494 609.694 2047 1.826 3.668 - - 5.49 5.494 616.394 2048 1.831 3.678 -- 5.51 5.509 623.213 2049 1.826 3.668 - - 5.49 5.494 630.183 2050 1.826 3.668 - - 5.49 5.494 637.293 2051 1.826 3.668 - - 5.49 5.494 644.545 2052 1.831 3.678 - - 5.51 5.509 651.927 2053 1.826 3.668 - 5.49 5.494 659.471 2054 1.826 3.668 5.49 5.494 667.167 2055 1.826 3.668 - 5.49 5.494 675.016 2056 1.831 3.678 - 5.51 5.509 683.007 2057 1.826 3.668 - 5.49 5.494 691.173 2058 1.826 3.668 - 5.49 5.494 699.503 2059 1.826 3.668 5.49 5.494 707.999 2060 1.831 3.678 5.51 5.509 716.650 2061 ___1.826 3.668 5.49 5.494 725.489 2062 1.826 3.668 5.49 5.494 734.505

Entergy Nuclear Northeast Letter Number: NL-08-144 Indian Point Energy Center, Units 1 and 2 Attachment 1 DOCKET NOS. 50-3 & 50-247 TABLE 8 (continued)

Decommissioning Funding Plan IP-1 Coordinated with IP-2, 2013 Shutdown and 60-Year SAFSTOR Basis Year 2007 Fund Balance $618.383 (millions)

Annual Escalation 0.00%-

Annual Earnings 2.00%

A B C D E F G IP-I IP-2 License License IP- I IP-2 Decommissioning Termination Termination Spent Fuel Spent Fuel Total Total Cost Trust Fund Cost Cost Cost Cost Cost Escalated at Escalated at 2%

Estimate Estimate Estimate Estimate Estimate 0% (minus expenses)

Year (millions) (millions) (millions) (millions) (millions) (millions) (millions) 2063 1.826 3.668 - 5.49 5.494 743.701 2064 1.831 24.751 - 26.58 26.582 731.993 2065 1.826 55.625 - 57.45 57.451 689.182 2066 18.899 168.560 - 187.46 187.459 515.506 2067 68.313 71.834 - 1.361 141.51 141.508 384.308 2068 148.490 25.113 - 0.446 174.05 174.049 217.946 2069 17.216 6.046 - 0.318 23.58 23.580 198.725 2070 17.216 6.046 - 0.318 23.58 23.580 179.119 2071 17.216 6.046 - 0.318 23.58 23.580 159.121 2072 17.235 6.547 - 0.314 24.10 24.096 138.208 2073 11.400 26.485 37.89 37.885 103.087 441.55 659.36 301121 178.26 1,282.17 1,282.17 Notes:

1 Does not include the $105.900 million funded by operations

[21 Does not include the $12.917 million funded by operations Calculations:

Column E =A +B + C +D Column F = (E)*(1 +0%)A(current year - 2007) or for 0%, F = E Column G = (Previous year's fund balance) * (1 + .02) - F (current year's decommissioning expenditures)

Enclosure 1 to NL-08-144 Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 1 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 1 DOCKET NO. 50-3

Document Ell-1583-004 PRELIMINARY DECOMMISSIONING COST ANALYSIS for the INDIAN POINT ENERGY CENTER, UNIT 1 preparedfor Entergy Nuclear preparedby TLG Services, Inc.

Bridgewater, Connecticut October 2008

Indian PointEnergy Center, Unit 1 Document Eli-1583-004 PreliminaryDecommissioningCost Analysis Page ii of v APPROVALS Project Manager al 64,4L 6?n- ,I Q-C /a °o=

William A. Cloutier, Jr. Date Project Engineer /10ate Thomas JYGarrett Date Technical Manager Geoffrey Griffitliub Date/

Quality Assurance Manager i aeZ D L t Dalte '

TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioningCost Analysis Page iii of v TABLE OF CONTENTS SECTION PAGE

1. DECOMMISSIONING COST ANALYSIS ............................................................ 1 1.1 Decommissioning Alternatives ...................................................................... 2 1.2 Regulatory Guidance ....................................................................................... 3 1.3 Basis of Cost Estimate .................................................................................... 4 1.4 M ethodology ............................ ........................................................................ 4 1.5 Impact of Decommissioning Multiple Reactor Units ................................... 6 1.6 Financial Components of the Cost Model .................................. ........................ 6 1.6.1 C ontin gency ........................................................................................... 7 1.6.2 Financial Risk ....................................................................................... 7 1.7 Site-Specific Considerations ............................................................................ 8 1.7.1 Spent Fuel Disposition ......................................................................... 8 1.7.2 Reactor Vessel and Internal Components ...................................... 11 1.7.3 Primary System Components ............................................................ 12 1.7.4 Main Turbine and Condenser ............................................................ 12 1.7.5 Transportation Methods ..................................................................... 13 1.7.6 Low-Level Radioactive Waste Conditioning and Disposal .............. 14 1.7.7 Site Conditions Following Decommissioning ................................... 16 1.7.8 Site Contamination ........................................................................... 16 1.8 A ssum ptions ................................................................................................. 17 1.8.1 Estim ating Basis ................................................................................ 17 1.8.2 Release Criteria .................................................................................. 18 1.8.3 L abor C osts ......................................................................................... 18 1.8.4 Design Conditions .............................................................................. 19 1.8 .5 G en eral .................................................................................. .................. 19

2. R E S UL T S ................................................. I................................................................. 2 1 2.1 Decommissioning Trust Fund ........................................................................ 22 2.2 Financial Assurance ....................................................................................... 23 FIGURE 1 SAFSTOR Decommissioning Timeline ........................................................... 23 TLG Services, Inc.

IndianPoint Energy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioningCost Analysis Page iv of v TABLE OF CONTENTS SECTION PAGE TABLES 1 Low-Level Radioactive Waste Disposition ....................................................... 24 2 Summary of M ajor Cost Contributors ............................................................ 25 3 Schedule of Annual Expenditures, Total Decommissioning Cost ................. 26 4 Schedule of Annual Expenditures, License Termination Allocation ............. 29 5 Schedule of Annual Expenditures, Spent Fuel Management Allocation ..... 32 6 Schedule of Annual Expenditures, Site Restoration Allocation .................... 33 7 Funding Requirements for License Termination ............................................ 34 APPENDIX A. 2007 Detailed Cost Analysis ............................................................................ A-1 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Page v of v REVISION LOG Noo.CRA No. Date,, Item Revised iie- Reason for Revision 0 10-22-2008 Original TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document El-1i583-004 PreliminaryDecommissioning Cost Analysis Page1 of 36

1. DECOMMISSIONING COST ANALYSIS Unit 1 at the Indian Point Energy Center (IP-1) was shutdown in October of 1974 after 12 years of operation. The former owner (Consolidated Edison) suspended operation because the plant's emergency core cooling system did not satisfy the criteria that had come into effect after its start up. Since that time, the unit has remained in protective storage with the spent fuel stored in one of the wet pools. Recent concerns of pool integrity prompted a decision to relocate the spent fuel to an on-site dry storage facility. The transfer process has been completed. The pool is expected to be drained by the end of the year (2008). The estimate for IP-1 represents the cost to decommission the unit, including the costs spent to date (since acquisition by Entergy) to maintain the facility, needed repairs, and for capital improvements to minimize long-term caretaking costs.

For purposes of this analysis, IP-1 is expected to remain in dormancy until the adjacent units are decommissioned. In 2003, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment No- 52 to the Provisional Operating License for IP-1.

Included within the amendment was a change to expiration date of the IP- 1 license to be consistent with that of IP-2 (currently September 28, 2013).

Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Operations, Inc. (Entergy) is seeking renewal of the operating license for IP-2. However, pursuant to 10 CFR 50.75(f)(3), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit a preliminary decommissioning cost estimate to the NRC for its review. An estimate has been submitted for IP-2. [11 Under the assumption that IP-2 would cease operation in 2013, the unit would then enter decommissioning. Due to the proximity of IP-1 and facilities shared by the two units, the decommissioning of IP-2 is expected to impact IP-1. As such, this analysis has been prepared assuming that status of IP-1 could significantly change with the shutdown of IP-2. As such, this estimate is intended to meet the 50.75(f)(3) requirement for IP-1.

The scenario evaluated in Reference 1 assumed that IP-2 would cease operation in 2013. It would then be placed into safe storage for a period up to 60 years, at which time the unit would be decontaminated and dismantled. This estimate assumes that the decommissioning of IP-1 would be coordinated with the decommissioning of IP-2 (and IP-3) as an integrated site activity. In accordance with the requirements of 10 "Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 2,"

Document No. El1-1583-003, prepared by TLG Services, dated.October 2008 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Eli-1583-004 PreliminaryDecommissioningCost Analysis Page2 of 36 CFR 50.75(f)(3), this cost estimate includes an assessment of the major factors that could affect the cost to decommission the IP-1 nuclear unit.

The cost to decommission IP-1 is estimated at $590.930 million. The cost is presented in 2007 dollars for consistent year comparison with the Company's latest filing on the status of the IP-1 decommissioning trust fund. [2]

The estimate for IP-1 assumes that it is decommissioned in conjunction with the two adjacent units. As such, there are savings as well as additional costs that are reflected within the estimate from the synergies of site decommissioning and the constraints imposed in working on a complex and congested site. In apportioning site decommissioning costs by unit, not all common costs are shared equitably and some costs elements are impacted by activities or previous operations at adjacent units.

The cost includes the monies anticipated to be spent for operating license termination, spent fuel storage and site remediation 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 remediation and restoration requirements. Many of these assumptions are discussed in more detail in this document.

Entergy intends to fund the expenditures for license termination (comprising approximately 93% of the total cost) from site operations and/or the currently existing decommissioning trust fund. Any surplus in the fund may be used to offset the cost of spent fuel management and/or site restoration, recognizing that :the licensee would need to make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

Expenditures from the trust fund for non-license termination activities 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 may require an exemption under 10 CFR 50.12(a).

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 2 Entergy Nuclear Operations' submittal of its "Decommissioning Fund Status Report" to the Nuclear Regulatory Commission, Letter No. ENOC-08-00028, dated May 8, 2008 3 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, TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El-1i583-004 PreliminaryDecommissioning Cost Analysis Page 3 of 36 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 51 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."[61 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 the decommissioning process.[71 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 Number 123 (p 24018 et seq.), June 27, 1988 4 Ibid. Page FR24022, Column 3 Ibid.

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

Indian PointEnergy Center, Unit 1 Document E1l-1583-004 PreliminaryDecommissioning Cost Analysis Page 4 of 36 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 cost estimate for IP-1 follows the general guidance and sequence presented in the amended regulations.

1.3 BASIS OF COST ESTIMATE IP-1 is already in decommissioning (safe-storage). For the purpose of this analysis, it is assumed to remain in storage until IP-2 is decommissioned (in 2064).[8] The sequence of events is delineated in Figure I along with major milestone dates.

The decommissioning estimate was developed using the site-specific, technical information relied upon in the decommissioning assessments prepared in 2000

.and 2002.[911101 This information was reviewed for the current analysis and updated to reflect any significant changes in the plant configuration over the past five years. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from recent decommissioning projects provided viable alternatives or improved processes. On site interviews were conducted between August and November 2007 to assist in obtaining current site specific conditions as well as collect financial data.

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,"["1 ] and the DOE "Decommissioning Handbook."[121 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 8 "Preliminary Decommissioning Cost Analysis for Indian Point Energy Center, Unit 2," prepared by TLG Services, Document No, El1-1583-003, October 2008 9 Decommissioning Cost Evaluation Due Diligence Estimate for the Indian Point 1 & 2 Nuclear Generating Stations Document No. El1-1395-002, September 2000.

10 TLG Document No. El1-1449-002, December 19, 2002 11 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986 12 W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980 TLG Services, Inc.

IndianPoint Energy Center, Unit I Document E1l-1583-004 PreliminaryDecommissioning Cost Analysis Page5 of 36 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.[13]

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-1 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 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%

" RadiationlALARA Factor 0% to 10%

" Protective Clothing Factor 0% to 30%

" 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 Program Durations Activity durations are used to develop the total decommissioning program schedule. The unit cost factors, adjusted for WDFs as described above, are 13 "Building Construction Cost Data 2007," Robert Snow Means Company, Inc., Kingston, Massachusetts TLG Services, Inc.

Indian Point Energy Center, Unit I Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page 6 of 36 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 three co-located reactor units there can be opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities.

There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitations on when final status surveys can take place. The estimate for IP-1 considered:

Savings in program management, in particular costs associated with the more senior positions, from the sequential decommissioning of multiple reactors. The estimate assumes that IP-2 is the lead unit in decommissioning through the disposition of the reactor vessel and primary system components, at which time IP-3 assumes the lead. Costs for the senior staff positions are only included for the lead unit.

The confines of a congested site and the need to coordinate dismantling operations. Demolition and soil remediation, following the primary decommissioning phase (removal of major source terms and radiological inventory), are conducted as a site-wide activity.

Sharing of station costs such as ISFSI operations, emergency response fees, regulatory agency fees, corporate overhead, and insurance.

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 TLG Services, Inc.

IndianPointEnergy Center, Unit 1 Document El-1i583-004 PreliminaryDecommissioning Cost Analysis Page 7 of 36 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."[14] 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 extended storage period.

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, is 14.6%. This does not include contingency on the costs reported for Period Oa (expenditures and budgeted items through year 2015).

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

TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document E1l-1583-004 PreliminaryDecommissioning Cost Analysis Page 8 of 36 types of costs under the broad term "financial risk." Included within the category of financial risk are:

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

" 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 cost study, however, does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk should be revisited periodically and addressed through 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"[151 (NWPA) in 1982, assigning the federal government's long-standing responsibility for 15 "Nuclear Waste Policy Act of 1982 and Amendments," U.S. Department of Energy's Office of Civilian Radioactive Management, 1982 TLG Services, Inc.

Indian PointEnergy Center, Unit I Document E1l-1583-004 PreliminaryDecommissioning Cost Analysis Page 9 of 36 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,[16, depending upon the level of funding appropriated by Congress.

The NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[171 This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, costs associated the relocation of the spent fuel to the ISFSI.

The assemblies stored in the IP- 1 spent fuel pool have been transferred to the ISFSJ. The 160 assemblies are stored in five (5) dry storage casks. The pool is expected to be drained by the end of the year (2008).

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 16 "DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's Office of Public Affairs, Press Release July 19, 2006 17 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.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page 10 of 36 IPEC site was assumed to be in 2018. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year for the commercial industry, completion of the removal of all fuel from the site was projected to be in the year 2045 assuming the shutdown of IP-2 in 2013 and IP-3 in 2015.

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.

Entergy Nuclear's position is that the DOE has a contractual obligation to accept IPEC 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.

ISFSI The IP-1 spent fuel has been relocated to an ISFSI constructed within the protected area (PA) to support IP-2 plant operations. Operation and maintenance costs for the ISFSI are included in the IP-2 estimate.

Storage Canister Design The IP-1 fuel (160 assemblies) is stored in a Holtec HI-STORM dry cask storage system. The Holtec multi-purpose canister or MPC has a capacity of 32 fuel assemblies.

Canister Loading and Transfer The estimate includes the costs spent to date to purchase, load, and transfer the MPCs from the pool to the ISFSI. Costs to transfer the spent fuel from the ISFSI to the DOE at some time in the future are included within the estimate for IP-2.

ISFSI Decommissioning The cost for the eventual decontamination and demolition of the five storage casks for IP-1 spent fuel are included in the estimate for IP-2.

TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioningCost Analysis Page 11 of 36 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 IP-1 includes an allowance for the disposition of GTCC material.

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).

1.7.2 Reactor Vessel and Internal Components The reactor pressure vessel and reactor internal components are segmented for disposal in shielded transportation casks. Segmentation and packaging of the internals are performed in the refueling canal where a turntable and remote cutter are installed. The vessel is segmented in place using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor 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 IPEC reactors will generate radioactive waste considered unsuitable for shallow land disposal (i.e., GTCC). For purposes of this study, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

Intact disposal of 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 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioningCost Analysis Page 12 of 36 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 since.

It is not known whether this option will be available when the IPEC units cease 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 50 years after IP-2 ceases operations. 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 coolant system components and associated reactor water cleanup systems is not anticipated to be necessary and no allowance is included for this activity within the estimate.

Reactor coolant 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 reactor coolant pumps and motors are lifted out intact, packaged, and transported for processing or disposal.

The generators are rigged for removal, disconnected from the surrounding piping and supports, and maneuvered into the open area for extraction from containment. Each generator is removed from containment and placed onto a multi-wheeled vehicle for transport to an on-site preparation area. Disposal costs are based upon the displaced volume of the steam generators.

1.7.4 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. The turbine rotors ana 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 TLG Services, Inc.

IndianPointEnergy Center, Unit I Document E1l-1583-004 PreliminaryDecommissioning Cost Analysis Page 13 of 36 either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.

1.7.5 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.[18] The contaminated material is packaged in Industrial Packages, 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, 9 0Sr, 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 metal, produced in the segmentation of the A reactor vessel and internal components, is ,

by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per ,,3 .:  :

shipment assumed permissible is based,:

upon the license limits of the available 7, ....

shielded transport casks. The  ;

• segmentation scheme for the vessel and i r internal segments is designed to meet these limits. *v> ,

18 U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 2007 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioningCost Analysis Page 14 of 36 Considering the location of IPEC (see map) and potential for restricted road use, it is assumed that transportation of materials requiring controlled disposal will utilize the Hudson River via barge shipment to the nearest transfer point for rail or trucking to the Energy-Solutions' facility in Clive, Utah. However, for estimating purposes, costs to transport the majority of the low-level radioactive waste were based upon truck transport costs developed from published tariffs from Tri-State Motor Transit.[ 191 Memphis (TN) was used as -the destination for off-site processing.

1.7.6 Low-Level Radioactive Waste Conditionina 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 is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,[201 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,[211 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, IP-1 was able to dispose of Class A, B or C low-level radioactive waste[221 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. 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 19 Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC),

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

20 "Low Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980 21 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, January 15, 1986 22 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" TLG Services, Inc.

IndianPointEnergy Center, Unit 1 Document El-1i583-004 PreliminaryDecommissioning Cost Analysis Page 15 of 36 Low-Level Radioactive Waste Disposal Facility is available only to generators located in states affiliated with, the Atlantic Compact.

However, IP- 1 is still able to dispose of Class A material at EnergySolutions' facility in Clive, Utah.

The costs reported for direct disposal (burial) in the estimate are based upon Entergy Nuclear Operations, Inc. current Life of Plant Disposal Agreement with EnergySolutions.[ 231 This facility was used as the destination for the majority of the waste volume generated by decommissioning (99.9%). 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 0.1% 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 <0.1% of the total waste volume) is generally not suitable for shallow-land disposal. This material is packaged in the same multipurpose canister used for spent fuel storage/transport and designated for geologic disposal.

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.

23 General Services Agreement 10160239 between Entergy Nuclear Operations and EnergySolutions, June 2007 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Page16 of 36 1.7.7 Site Conditions Following Decommissioning The NRC will terminate (or amend) the site license when it determines that site remediation has been performed in accordance with the license termination plan, and that the final status 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 24 and commitments for the site.[ 1 Only existing site structures are considered in the dismantling cost. The current analysis includes all structures as defined in the provided site plot plans.[251 The electrical switchyard remains after Indian Point is decommissioned in support of the regional transmission and distribution system. The Generation Support Building and IPEC Training Center remain in place for future use. Clean non-contaminated structures are removed to a nominal depth of three feet below grade. The voids are backfilled with clean debris and capped with soil. The site is then re-graded to conform to the adjacent landscape. Vegetation is established to inhibit erosion. These "non-radiological costs" are included in the total cost of decommissioning.

Site utility and service piping are abandoned in place. Electrical manholes are backfilled with suitable earthen material. Asphalt surfaces in the immediate vicinity of site buildings are broken up and the material used for fill, as required. The site access road remains in place.

1.7.8 Site Contamination 26 As indicated by the IPEC Groundwater Investigation Project,[ 1 it is likely that radionuclides in the soil has contaminated portions of the subsurface power block structures. As such, sub-grade surfaces of the following IP-1 structures were determined to be impacted by the contamination and removed:

o Reactor Containment 24 "Entergy is committed to returning the Indian Point Unit 1, 2 and 3 facilities and the surrounding site to a "Greenfield" condition." Letter from Michael R. Kansler to Westchester County Attorney Alan D. Scheinkman, March 16, 2001 25 Entergy Nuclear Northeast "Buildings and Structures Identification Plan" ER-04-2-012, Rev. 01.

26 "Hydrogeologic Site Investigation Report," GZA GeoEnvironmental, Inc., January 2008 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page 17 of 36

• Service & H.T. Switchgear

• Underground Utility Tunnel (included in Turbine Building activities) o Chemical Systems

• Fuel Handling o Nuclear Services

" Superheater, and

" Turbine Building All other structures or buildings severely impacted in the decontamination process are removed to a nominal depth of three feet below grade.

Site remediation costs include the removal and disposition of approximately 1.26 million cubic feet of potentially contaminated soil within the boundaries of the IP-I site.

1.8 ASSUMPTIONS The following assumptions were made in the development of the estimate for decommissioning IP- 1.

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

The estimates rely upon the physical plant inventory that was the basis for the 2002 analysis (updated to reflect any significant changes to the plant over the past five years).

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

TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Page 18 of 36 1.8.2 Release Criteria This estimate assumes that the site will be remediated to the levels specified by the NRC and the State of New York. Specifically, "the total effective dose equivalent to the maximally exposed individual of the general public, from radioactive material remaining at a site after cleanup, shall be as low as reasonably achievable and less than 10 mrem above that received from background levels of radiation in any one year."[27]

1.8.3 Labor Costs Entergy will 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 will 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 are based upon average salary information made available by Entergy. Overhead costs are included for site and corporate support, reduced commensurate with the staffing levels envisioned for the project.

Severance and retention costs are not included in the estimates.

Reduction in the decommissioning 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, with one exception, is provided by IP-2. Costs for maintaining one security post at IP-1 are included until 2015 when IP-3 ceases operation. After that time, IP-2 andlor IP-3 will provide any coverage required for the IP- 1 portion of the site.

27 NYSDEC Division of Solid & Hazardous Materials, Bureau of Hazardous Waste Radiation Management: Cleanup Guidelines for Soils Contaminated with Radioactive Materials (DSHM-RAD-05-01)

TLG Services, Inc.

IndianPointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page 19 of 36 1.8.4 Design Conditions Activation levels in the vessel and internal components are modeled using NUREG/CR-3474.[ 28 ] Estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the IPEC components, its reduced operating life, and anticipated period of decay.

Additional short-lived isotopes were derived from CR-0130[ 291 and CR-0672,1301 and benchmarked to the long-lived values from CR-3474.

Activation of the reactor building structures was assumed to be confined to the biological shield.

1.8.5 General 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 (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.

It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimates do not include the additional cost for size reduction and preparation to meet "furnace ready" 28 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 29 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 30 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.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page20 of 36 conditions. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material.

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.

Energy For estimating purposes, the plant is assumed to be de-energized with temporary power 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 There is no separate budget item for insurance for IP-1. Continuing coverage (nuclear liability and property insurance) is provided by IP-2 policies.

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

Emergency Planning Fees Emergency planning costs are estimated from FEMA, state, and local fees, as provided in the IPEC budget accounts. Maintenance and service costs are included with the annual fees.

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.

TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document E1l-1583-004 PreliminaryDecommissioning Cost Analysis Page21 of 36

2. RESULTS The proposed decommissioning scenario, major cost contributors and schedule of annual expenditures are summarized in Figure 1 and in Tables 2 and 3. The summaries are based upon the 2007 detailed cost estimate provided in Appendix A.

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). The cost reported for this subcategory is generally sufficient to terminate the unit's operating license, recognizing that there may be some additional cost impact from spent fuel management. The cost for license termination is shown in Table 4.

The "Spent Fuel Management" subcategory contains costs associated with the containerization and transfer of spent fuel to the ISFSI. Costs for monitoring and eventual transfer of the 5 casks are included in the estimate for IP-2. The cost for spent fuel management is shown in Table 5.

"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. Non-contaminated structures are removed to a depth of three feet and backfilled to conform to the local grade. Contaminated foundations are removed to bedrock. The cost for site restoration is shown in Table 6.

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., Asset Retirement Obligation 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 canister used for spent fuel. The GTCC material is assumed to be shipped directly to a DOE facility as it is TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page22 of 36 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 geologic repository along with the spent fuel, GTCC waste is still classified herein as low-level radioactive waste and, as such, included as a "License Termination" expense.

2.1 Decommissioning Trust Fund The decommissioning trust fund, as reported in Entergy's latest status report (dated May 8, 2008) was $271.186 million, as of December 31, 2007.

2.2 Financial Assurance Costs since Entergy has acquired IP-1 for maintaining the plant in safe-storage, performing necessary repairs and facility upkeep, supporting the groundwater investigation and containerizing the spent fuel and moving the spent fuel to the ISFSI have been paid for by site operations (i.e., there have been no disbursements from the decommissioning trust for IP-1 related site work).

Operational funding of IP-1 related costs is expected to continue through 2013, the currently scheduled shutdown of IP-2.

Table 4 identifies the cost estimated for license termination in accordance with 10 CFR 50.75 (totaling approximately $547.457 million). The costs spent to date (from 2001) and budgeted through the 3rd quarter of 2013 is approximately

$105.900 million. This cost is to be funded by operations. The remaining cost through 2073 (approximately $441.558 million) will be funded from the decommissioning trust.

Table 7 provides the details of the proposed funding plan for decommissioning IP-1 based on a 2% real rate of return on the decommissioning trust fund. As shown in Table 7, the current trust fund (as of December 31, 2007) is sufficient to accomplish the intended tasks and terminate-the operating license for IP-1. The analysis also shows a surplus in the fund at the completion of decommissioning.

This surplus could be made available to fund other activities at the site (e.g.,

spent fuel management and/or restoration activities), recognizing that the licensee would need to make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page23 of 36 FIGUREI1 SAFSTOR DECOMMISSIONING TIMELINE (not to scale)

IP-1 Shutdown: October 31, 1974 Period 4 Period 5 Period 2 Period 3 Decommissioning Site Safe-Storage Preparations I Operations Remediation 6

06/2067 09/2069 09/2073 12/2045 06/2066 ISFSI Construction Canister and overpack 09/2013 fabrication IP-2 Shutdown License Terminated Fuel to ISFSI

. 09/2008 Storage Pool Empty ISFSI Operations All Spent Fuel Off Site TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document El1-1583-004 PreliminaryDecommissioning Cost Analysis Page24 of 36 TABLE 1 Indian Point Energy Center, Unit 1 Low-Level Radioactive Waste Disposition Waste Cost Basis I_Class_[1.Waste Volume (cubic feet)

Mass (pounds Low-Level Radioactive Waste tions A 2,296,075 196,605,692

.(near-surface disposal _ EnerUyolu Barnwe.11 B 1,740 176,728 Barnwe 11 C 115

1. 10,390 Greater than Class C Spent Fu el

_Agologicrepository) Equivale nt GTCC 471 19,440 9

Recyclin Processed/Conditioned foff-site recych'ng center) __ Vendor s A 157,755 6,559,670 Total [2]

[1W 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.

IndianPointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Page25 of 36 TABLE 2 Indian Point Energy Center, Unit 1 Summary of Major Cost Contributors (thousands, 2007 dollars)

License Spent Fuel Site Termination Management Restoration Total Decontamination 8,442 - 8,442 Removal 81,600 20,195 101,794 Packaging .26,806 - 26,806 Transportation 39,940 39,940 Waste Disposal 88,373 88,373 Off-site Waste Processing (off-site) 14,031 - 14,031 Program Management [1] 77,872 6,917 84,789 Corporate A&G _ _ _

Site O&M 10,622 10,622 S - 15,756 15,756 Insurance and Regulatory Fees 34,881 173 - 35,054 Energy 14,627 - 431 15,058 Radiological Characterization 11,764 - 11,764 Property Taxes . ................ __ __ __ __ _ __ __ __

Miscellaneous Equipment 14,058 1 14,059 Environmental 33,464 - 33,464 IP-1 Project/Recurring Costs 90,978 - - 90,978

-I-Total 547,458 j 15,929 27,543 590,930

[11 Includes security and engineering

[21 Includes costs spent to date and an allocation of site emergency planning fees through 2015 (IP-3 shutdown)

TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document Ell-1583-004 Preliminary Decommissioning Cost Analysis Page 26 of 36 TABLE 3 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Enrg Burial Other Totals 2001-2003 0 0 0 0 11,836 11,836 2004 0 0 0 0 9,450 9,450 2005 0 0 0 0 10,290 10,290 2006 0 0 0 0 20,630 20,630 2007 1,187 3,860 0 0 22,761 27,808 2008 2,716 0 180 0 9,430 12,326 2009 2,599 492 180 229 2,075 5,574_

2010 .2,599 492 180 229 2,075 5,574 2011 2,599 492 180 229 2,075 5,574 2012 2,599 492 180 229 2,075 5,574 2013 2,5999 492 180 229 2,075 5,574 2014 2,599 492 180 229 2,075 5,574 2015 2,599 492 180 229 2,075 5,574 2016 461 270 227 21 1,676 2,656 2017 460 270 227 21 1,672 2,649 2018 460 270 227 21 1,672 2,649 2019 460 270 227 21 1,672 2,649 2020 461 270 227 21 1,676 2,656 2021 460 270 227 21 1,672 2,649 2022 460 270 227 21 1,672 2,649 2023 460 270 227 21 1,672 2,649_

2024 461 270 227 21 1,676 2,656 2025 460 270 227 21 1,672 2,649_

2026 460 270 227 21 1,672 2,649 2027 460 270 227 21 1,672 2,649 2028 461 270 227 21 1,676 2,656_

2029 460 270 227 21 1,672 2,649 2030 460 270 227 21 1,672 2,649 2031 460 270 227 21 1,672 2,649 2032 ___ 461 270 227 21 1,676 2,656 2033 460 270 227 21 1,672 2,649 2034 4601 270 11227 121 1, 672j_ 2,649]

TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioningCost Analysis Page27 of 36 TABLE 3 (continued)

Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2035 460 270 227 21 1.672 2.649 2036 461 270 227 21 1,676 2,656 2037 460 270 227 21 1,672 2,649 2038 460 270 227 21 1,672 2,649 2039 460 270 227 21 1,672 2,649 2040 461 270 227 21 1,676 2,656 2041 460 270 227 21 1,672 2,649 2042 460 270 227 21 1,672 2,649 2043 460 270 227 21 1,672 2,649 2044 461 270 227 21 1,676 2,656 2045 460 270 227 21 1,634 2,611 2046 460 270 227 21 849 1,826 2047 460 270 227 21 849 1,826 2048 461 270 227 21 852 1,831 227 849 2049 460 270 21 1,826 227 2050 460 270 21 849 1,826 227 2051 460 270 21 849 1,826 227 2052 461 270 21 852 1,831 227 2053 460 270 21 849 1,826 227 2054 460 270 21 849 1,826 227 2055 460 270 21 849 1,826 227 2056 461 270 21 1,831 2057 460 270 227 21 849 1,826 2058 460 270 227 21 849 1,826 2059 460 270 227 21 849 1,826

---

1ý-

2060 461 270 227 21 852 1,831 2061 460 270 227 21 849 1,826 2062 460 270 227 21 849 1,826 2063 460 270 227 21 849 1,826 2064 461 270 227 21 852 1,831 2065 460 270 227 21 849 1,826 TLG Services, Inc.

Indian PointEnergy Center,Unit 1 Document Eli-1583-004 PreliminaryDecommissioningCost Analysis Page28 of 36 TABLE 3 (continued)

Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2066 15,659 2,146 227 32 1,101 19,165 2067 32,638 20,681 630 9,179 6,251 69,379 2068 40,433 35,867 820 48,098 24,092 149,310 2069 3,006 4,284 108 10,334 5,854 23,585 2070 3,006 4,284 108 10,334 5,854 23,585 2071 3,006 4,284 108 10,334 5,854 23,585_

2072 .3,022 4,241 110 10,195 5,950 23,519_

2073 2,592 683 159 16 7,950 11,400 Total. 148,459 97,267 15,058 101,167 228,979 590,930 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document Ell-i1583-004 Preliminary Decommissioning Cost Analysis Page 29 of 36 TABLE 4 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures License Termination Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Enerz Burial Other Totals 2001-2003 0 0 0 0 11,836 11,836 2004 0 0 0 0 9,450 9,450 2005 0 0 0 0 10,290 10,290 2006 0 0 0 0 20,630 20,630 2007 0 0 0 0 2__2,761 2___2,761 2008 2,716 0 0 0 8,098 10,814 2009 2,599 492 206 229 711 4,236 2010 2,599 492 206 229 711 4,236 2011 2,599 492 206 229 711 4,236 2012 2,599 492 206 229 711 4,236 2013 2,599 492 206 229 711 4,236 2014 2,599 492 206 229 711 4,236 2015 2,599 492 206 229 711 4,236_

2016 461 270 227 21 1,676 ,656 2...

2017 460 270 227 21 1,672 2,649 2018 460 270 227 21 1,672 2,649 2019 460 270 227 21 1,672 2,649 2020 461 270 227 21 1,676 2,656 2021 460 270 227 21 1,672 2,649 2022 460 270 227 21 1,672 ,649 2..

2023 460 270 227 21 1,672 2,649_

2024 461 270 227 21 1,676 2,656 2025 460 270 227 21 1,672 2,649 2026 460 270 227 21 1,672 2,649_

2027 460 270 227 21 1,672 2,649 2028 461 270 227 21 1,676 2,656 2029 460 270 227 21 1,672 2,649 2030 460 ý270 227 21 1,672 2,649 2031 460 270 227 21 1,672 2,649 2032 461 270 227 21 1,676 2,656 2033 460 270 227 21 1,672 2,649_

2034 460 270 227 21 1,672 2,649 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document Ell-1583-004 Preliminary Decommissioning Cost Analysis Page 30 of 36 TABLE 4 (continued)

Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures License Termination Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2035 460 270 227 21 1,672 2,649 2036 461 270 227 21 1,676 2,656 2037 460 270 227 21 1,672 2,649 2038 460 270 227 21 1,672 2,649 2039 460 270 227 21 1,672 2,649 2040 461 270 227 21 1,676 2,656 2041 460 270 227 21 1,672 2,649 2042 460 270 227 21 1,672 2,649 2043 460 270 227 21 1,672 2,649 2044 461 270 227 21 1,676 2,656 2045 460 270 227 21 1,634 2,611 2046 460 270 227 21 849 1,826 2047 460 270 227 21 849 1,826 2048 461 270 227 21 852 1,831 2049 460 270 227 21 849 1,826 2050 460 270 227 21 849 1,826, 2051 460 270 227 21 849 1,826J 2052 461 270 227 21 852 1,831 2053 460 270 227 21 849 1,826 2054 460 270 227 21 849 1,826_

2055 460 270 227 21 849 1,826_

2056 461 270 227 21 852 1,831 2057460 70 27 21849 ,82 2058 460 270 227 21 849 1,826 2059 460 270 227 21 849 1,826 2060 461 270 227 21 852 1,831 2061 460 270 227 21 849 1,826 2062 460 270 227 21 849 1,826 2063 460 270 227 21 849 1,826 2064 1461 270 227 2182 1,831 2065 460 270J227j211 49~ 1,826 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document E1l-1583-004 Preliminary Decommissioning Cost Analysis Page31 of 36 TABLE 4 (continued)

Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures License Termination Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2066 15,393 2,146 227 32 1,101 18,899 2067 31,608 20,646 630 9,179 6,251 68,313 2068 39,716 35,767 818 48,098 24,092 148,490 2069 560 468 0 10,334 5,854 17,216 2070 560 468 0 10,334 5,854 17,216 2071 560 468 0 10,334 5,854 17,216 2072 609 477 3 10,195 5,950 17,235 2073 2,592 683 159 16 7,950 11,400 Total 135,507 78,060 14,627 101,167 218,096 547,457 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document E1l-1583-004 PreliminaryDecommissioningCost Analysis Page 32 of 36 TABLE 5 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other

• Totals 2001-2003 0 0 0 0 0 0 2004 0 0 0 0 0 0 2005 0 0 0 0 0 0 2006 0 0 0 0 0 0 2007 1,187 3,860 0 0 0 5,047 2008 0 0 0 0 1,512 1,512 2009 0 0 0 0 1,339 1,339 2010 0 0 0 0 1,339 1,339 2011 0 0 0 0 1,339 1,339 2012 0 0 0 0 1,339 1,339 2013 0 0 0 0 1,339 1,339 2014 0 0 0 0 1,339 1,339 2015 0 0 0 0 1,339 1,339 TotEIl 1,187 3,860 0 10,882 1 15,929

• Prorated share of site Emergency Planning Fees TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Page33 of 36 TABLE 6 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Site Restoration Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2001-2065 0 0 0 0 0 0 2066 266 0 0 0 0.0 266 2067 1,030 36 0 0 0.0 1,066 2068 717 100 2 0 0.0 820 2069 2,446 3,816 108 0 0.2 6,369 2070 2,446 3,816 108 0 0.2 6,369 2071 2,446 3,816 108 0 0.2 6,369 2072 2,413 3,764 106 0 0.2 6,284 2073 0 0 0 0 0 0 Total 11,764 15,347 431 0 0.85 27,543 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document Eli-1583-004 PreliminaryDecommissioningCost Analysis Page 34 of 36 TABLE 7 Funding Requirements for License Termination Coordinated with IP-2 2013 Shutdown and 60-Year SAFSTOR Basis Year 2007 Fund Balance $271.186 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Escalated License Decommissioning License Termination Trust Fund Termination Cost Escalated Escalated at 2%

Cost at 0% (minus expenses)

Year (millions) (millions) (millions) 2001 2002 2003 2004 2005 ________

$105.900 million spent to date 2006 and budgeted through 3rd 2007 quarter of 2013 (currently scheduled date for shutdown 2008 of IP-2) funded by operations 276.610 2009 282.142 2010 287.785 2011 293.540 2012 299.411 2013 1.059 1.059 304.340 2014 4.236 4.236 306.191 2015 4.236 4.236 308.079 2016 2.656 2.656 311.585 2017 2.649 2.649 315.167 2018 2.649 2.649 318.822 2019 2.649 2.649 322.549 2020 2.656 2.656 326.344 2021 2.649 2.649 330.222

/ 2022 2.649 2.649 334.177 2023 2.649 2.649 338.212 2024 2.656 2.656 342.320 2025 2.649 2.649 346.518 2026 2.649 2.649 350.799 2027 2.649 2.649 355.166 2028 2.656 L-2.656 1 359.613 TLG Services, Inc.

Indian PointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Page35 of 36 TABLE 7 (continued)

Funding Requirements for License Termination Coordinated with IP-2 2013 Shutdown and 60-Year SAFSTOR Basis Year 2007 Fund Balance $271.186 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Escalated License Decommissioning License Termination Trust Fund Termination Cost Escalated Escalated at 2%

Cost at 0% (minus expenses)

Year (millions) (millions)__ (millions) 2029 2.649 2.649 364.157 2030 2.649 2.649 368.791 2031 2.649 2.649 373.518 2032 2.656 2.656 378.332 2033 2.649 2.649 383.250 2034 2.649 2.649 388.266 2035 2.649 2.649 393.382 2036 2.656 2.656 398.593 2037 2.649 2.649 403.916 2038 2.649 2.649 409.346 2039 2.649 2.649 414.884 2040 2.656 2.656 420.525 2041 2.649 2.649 426.287 2042 2.649 2.649 432.163 2043 2.649 2.649 438.158 2044 2.656 2.656 444.265 2045 2.611 2.611 450.539 2046 1.826 1.826 457.724 2047 1.826 1.826 465.052 2048 1.831 1.831 472.523 2049 1.826 1.826 480.147 2050 1.826 1.826 487.924 2051 1.826 1.826 495.856 2052 1.831 1.831 503.943 2053 1.826 1.826 512.195 2054 1.826 1.826 520.613 2055 1.826 1.826 1 529.200 2056 1.831 1.831 537.953 TLG Services, Inc.

IndianPointEnergy Center, Unit 1 Document El-1i583-004 PreliminaryDecommissioning Cost Analysis Page36 of 36 TABLE 7 (continued)

Funding Requirements for License Termination Coordinated with IP-2 2013 Shutdown and 60-Year SAFSTOR Basis Year 2007 Fund Balance $271.186 (millons....

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Escalated License Decommissioning License Termination Trust Fund Termination Cost Escalated Escalated at 2%

Cost at 0% (minus expenses)

Year (millions) .. .(milons) (millions 2057 1.826 1.826 546.886 2058 1.826 1.826 555.997 2059 1.826 1.826 565.291 2060 1.831 1.831 574.766 2061 1.826 1.826 584.435 2062 1.826 1.826 594.298 2063 1.826 1.8216 604.358 2064 1.831 1.831 614.614 2065 1.826 1.826 625.081 2066 18.899 18.899 618.683 2067 68.313 68.313 562.744

+

2068 148.490 148.490 425.509 2069 17.216 17.216 416.803 2070 17.216 17.216 407.923 2071 17.216 17.216 398.865 2072 17.235 17.235 389.608 2073 11.400 11.400 386.000 441..

. 549....[1]. ........ 4......

Notes:

Does

[M1 not include the $105.900 million funded by operations Calculations:

Column B = (A)*(l+.00)^(current year - 2007) or for 0%, B = A Column C = (Previous year's fund balance) * (1 + .02) - B (current year's decommissioning expenditures)

TLG Services, Inc.

IndianPointEnergy Center, Unit 1 Document Ell-1583-004 PreliminaryDecommissioning Cost Analysis Appendix A, Page 1 of 9 APPENDIX A 2007 DETAILED COST ANALYSIS TLG Services, Inc.

DodurnentEl1-1583-004 Indian Point Energy Center, Unit I Appendix A, Page 2 of 9 DecomnanissioningCost Analysis Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Bureal Volumes Burial I UtIity end I Volume Class A Class B Class C GTCC Processed Craft Contractor SActivity Declon Removal Packaging Transport Processing Disposal Other Total Total LIC.Teem. Management Restoration CoaI Cost Costs Costs Costs Costs Cast. Contingency Costs Costs Costs Costs Cu. Feet Cu. Feat Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours I Inodex Activity Description PERIOD ta - Pre.Shutdown Early Planning Period Oa Direct Decommissioning Activities Perod Oa Additional Costs 0a.2.1 P1 Projects 2000-2007 51.123 51,123 51.123 0a.2.2 pI Recurnng Costs 2000-2007 23.844 23.844 23,844 0a.2.3 I11 Projects 2008 - 6.647 6,647 6.647 0a.2.4 P 1 RecuncingCosts 2008-License Termination 200 3.967 4,167 4.167 0

0a.2.5 IP1 Recurrig Costs 2 08-Spent Fuel Mgent - 1.512 1,512 1.512 0a.2.6 :PEC Dry Cask Infrastructure - 5.047 5,047 8,236 5,047 0a.2.7 P1 Recurring Costs 2009-2015 1.400 6.836 8.236 0..2.8 IP1 Ground Water Program 2009-201t5 3.222 3.222 3,222 0..2.9 Emergency Planning 2009-2005 9.370 9,370 9,370 0a.2.10 Utity, Staffing2009-2015 18-191 18,191 18,191 0a.0 TOTALPERIODDa COST 1.600 129.760 131,359 115,430 15.929 PERIOD 2b -SAFSTOR Dormancy with Dry Spent Fuel Storage Period 2b Direct Decommissioning Activities 2b.1.1 Quarterly Inspection a 2b.1.2 Semi-annual environmental survey 2b. 1.3 Prepare reports 2b.1.4 Bituminous nofreplacement 180 27 206 206 2b. 1.5 Maintenance supplies 3,768 942 4,710 4.710 21.1 Subtotal Period 2b ActivityCosts 3,948 969 4,917 4.917 Peoa 21bAdditionalCosts 2b.2.1 Emergency Planning Fees 22,414 2.241 24,655 24.655 2b.2 Subtotal Period 2b Additional Costs 22,414 2.241 24.655 24,65S Period 2b Period-Dependent Costs 2b.4.1 Insurance 2b.4.2 Property taxes 2b.4.3 Health physics supplies 2.622 656 3,278 3,278 2b.4.4 Disposal of DAWgenerated 51 34 501 - 135 722 722 11,086 221,729 88 2b.4.5 Plant energy budget - 5.913 687 6,800 6.800 5.183 518 5,701 5.701 2b.4.6 NRC Fees 21.4.7 Site O&M 3.480 522 4,002 4.002 2b.4.8 Environmental 13,644 2.047 15,690 15,690

- - 250,103 2b.4.9 Uttily Staff Cost - 11.861 1,779 13.640 13,640 51 34 501 40,081 6.544 49,833 11,086 221,729 88 250,103 20.4 Subtotal Period2b Perod-Depandent Costs 2,622 49.833 2,622 51 34 501 66,442 9,754 79,405 79.405 11,086 221,729 88 250,103 2b.0 TOTALPERIOD 2b COST PERIOD2c - SAFSTOR Dormancy without Spent Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 OuarrerlyInspection aa 2c.1.2 Semi-annual environmental survey 2c.1.3 Prepare r"po ns 2c. 1.4 Bituminousrost replacement 123 18 141 141 2..1.5 Maintenance supplies 2,582 645 3,227 3,227 2c.1 Subtotal Period 2c ActivityCosts 2,705 664 3,369 3.369 Period 2c Period-Dependent Costs 2c.4.1 Insurance 2c.4.2 Property taxes TLG Services, Inc.

Document Ell-1583-004 Indian Point Energy Center, Unit I Appendix A, Page3 of 9 DecommissioningCost Analysis Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

NRC Spent Fuel sto FPrOCeSSed 0B0uralvolumes bural i utility and Off-Oto LLKW GTCC Processed Craft Contractor Disposal Other Total Total LUc.Ton*. Management Restoration Volume Class A Class B Class C Decon Removal Packaging Transport Processiog ActivIty ACt*I* U*SCM *tlon Costs Cos. cu Fast Cu Feet Cu Feet Cu Fast Cu Foot Wt Lbs Manhou Manhours I In*x Cast Cost Costs Costs Costs Costs Costs Comtrue Costs debt Index -avily uas,, ,on Period 2c Pehiod-Oependent Costs (continued)

Health physics supplies 1,797 - - 449 2,246 2.246 2c.4.3 60 35 23 343 - 93 494 494 7,596 151,919 2c.4.4 Disposal of DAWgenerated 2c.4.5 Plant energy budget - 4.052 608 4,659 4.659 2c.4.6 NRC Fees 3,551 355 3,906 3.906 2c.4.7 Site O&M 2.384 358 2.742 2,742 2c.4.8 Ervironmental 9,348 1,402 10.750 10.750

- 8,127 1.219 9.346 9,346 - - 171.360 2c.4.9 UtilityStaff Cost - -

35 23 343 27,462 4,484 34,144 34,144 7,596 151,919 60 171.360 2c.4 Subtotal Period 2c Pehod-Depeedent Costs 1,797 30,167 5,148 37,913 37,913 7.596 151,919 60 171,360 2c.0 TOTALPERIOD 2c COST 1,797 35 23 343 14.902 116,918 116,918 18.682 373,648 148 421,463 PERIOD 2 TOTALS 4.419 85 58 1144 96,609 PERIOD 3a - Reactivate Site Following SAFSTORDormancy Period 3a Direct Decomrrissioning Activities 928 3a.1.t Prepare preliminary decoarnIssioning cost 61 9 70 70 214 32 246 246 3.214 3a.1.2 Review plant dwgs & speos.

3a.1.3 Perform detaileid red surey 714 3a. 1.4 End product de:scippon 47 7 54 54 61 6 70 70 928 3a.1.5 Detailed by-product inventory 349 52 402 402 5,355 3a.1.6 Define major work sequence 2,213 Perntro SER and EA 144 22 166 166 3a.1.7 3,570 3a.1.8 Perform Site-Specific Cost Study 233 35 268 268 191 29 219 219 2.925 3a.1.9 Preparetsubmit License Termination Plan 3a.1.10 Receive NRC approval of terninabon plan ActivitySpecificadons 343 51 395 355 39 5,262 3a.1.11.1 Re-acgvate plant & temporary facifies 194 29 223 201 22 2.975 3a.1.11.2 Plant systems 5,069 3a.1.11.3 Reactar internals 331 50 380 380 303 45 348 348 4,641 3a.1.11.4 Reactor vessel 357 Sa.t.1t.5 Biological shield 23 3 27 27 145 22 167 167 2,228 33.111.6 Steam generators 1.142 74 11 86 43 43 3a.1.11.7 Reinforced concrete 286 19 3 21 - 21 3a..t11.8 Main Turbine 19 3 21 - 21 286 3a.1,1.9 Main Condensers 145 22 167 M4 84 2,228 3a,1.1t.t1 Plant structures & buildings 3,284 3a.1.t11.t Waste management 214 32 248 246 42 6 48 24 24 643 3a.1.11.12 Facility & site closeout 1,852 278 2.130 1,975 255 28,401 3t.1.1 Total Planning & Site Preparations 1,714 112 17 129 129 -

Sa.1.12 Prepare dismanoing sequence 3at1.1 3 Plant prep. & temp. soces 2,419 363 2.782 2.782 65 10 75 75 1,080 3a4.1.14 Design water clean-up system 3a1.15 RigginglCont.Cntd Envlpsotioingletc. 2,048 307 2.355 2.355 57 9 66 66 - 878 3sa.1.16 Procure casksiners & containers 7,852 1,178 9.030 6,7-75 255 51,910 3..1 Subtotl Petiod 3a ActivityCosts Period 3a AdditionalCosts 3a.2.1 Site Characterization 2.218 665 2,883 2,683 3a.2 Subtotal Period 3a AdditionalCosts 2,218 665 2,883 2,883 Period 3a Perdod-Dependent Costs 3a.4.1 Insurance 3a.4.2 Prmpertytaoes TLG Services, Inc.

Document Eli-1583-004 Indian PointEnergy Center, Unit I Appendix A, Page 4 of 9 Decommisioning Cost Analysis Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Silt LLRW NRC Spent Fuoe Sit Processed Buocal V.1o..s Buoral) W 9 and Utlt Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Tetm. Management Restoration Volume Class A Closn B Class C GTCC Processed Craft Censotorn Index Activity Description Cost Cost Costs Costs Costs Costs Cents Continoency Costs Costs Coets Costs Cu. Font Cu. Feet Cu. Foot Cu. Feet Cu. Feat Wt.. Lbs. Manhours Manhors Period 3a Perion-Depeodent Costs (coeinued) 3o.4.3 Health physics supplies 198 50 248 248 3a4.44 Heavy equipment rental 237 - - 36 273 273 3a.4.5 Disposal of DAWgenerated 10 - 3 15 15 226 4,518 3a.4.6 Plant energy budget 101 15 116 116 3a.4.7 NRC Fees 88 9 97 97 237 35 272 272 3a.4.8 Site O&M 3a.4.9 Environmental 232 35 267 267 3a.4.10 Utlity StaffCost 4J127 619 4,746 4,746 - - 69,086 435 1 10 4.784 801 6,032 6,032 226 4.518 2 69,086 3a.4 Subtotal Period 3a Period-Dependent Costs 435 1 1 10 14.854 2,644 17.945 17,690 255 226 4,518 2 120,995 3a.0 TOTALPERIOD 3a COST PERIOD31 - Decommissioning Preparations Peded 3b Direct Decommissioning Activities DetailedWork Procedures 336 50 387 34o 39 - - 3,379 3b.1.1.1 Plant systems 3b.1.1.2 Rsactor internals 178 27 204 204 1,785 3b.1.1.3 Remaining buildings 96 14 110 28 83 964 3b.1.1.4 CR0 cooling assembly 71 11 82 82 714 3b.1.1.5 CR0 housings & ICltubes 71 11 82 82 714 3b.1.1.6 Incore instrumentation 71 11 82 82 714 3b.1.1.7 Reator vessel 258 39 297 297 2,592 3b.l.1.8 Facility closeout 85 13 98 49 49 857 3b.1.1.9 Missile shields 32 5 37 37 321 85 13 98 98 857 3b.1.1.t0 Biological shield 327 49 376 376 3 3,294 3b.S1.1l1 Steam generator 3b.1,..12 Reinforced concrete 71 11 82 41 41 714 11 17 127 1,114 3b.1.1.13 Main Turbine -111 17 127 - 127 127 1,114 3b.1.1.14 Main Condenser 3b.1.1.15 Auxiliorybuilding 194 29 223 201 22 1,949 3b.1.1.16 Reactor building 194 29 223 201 22 1,949 3b.1.1 Total 2,291 344 2,635 2,124 511 23,022 3b. 1 Subtotal Period 3b ActivityCosts 2,291 344 2,635 2,124 511 23,022 Period 3b Additional Costs 3b.2.1 Asbestos Abatement 1.915 1 124 326 - 579 2,944 2,944 11,087 144,131 20,864 3b.2.2 Staff relocations expenses . . .. 1,639 246 1,885 1.885 3b.2 Subtotal Period 3b Audito.aI Costs 1.915 1 124 326 1,639 825 4,829 4,829 11,087 164,131 20.864 Period 3b Collateral Costs 3b.3.1 Decon equipment 959 - 144 1.103 1,103 3b.3.2 Small tool aliowaoce 33 5 38 38 3b.3.3 Pipe cutting equipment - 957 143 1.100 1,100 .7-30.3 Subtotal Period 3b Collateral Costs 959 . 989 292 2,241 2,241 Period3b Period-Dependent Costs 3b.4.1 Decon supplies 30 7 37 37 3b.4.2 Insurance 31.4.3 Property toxes 3b.4.4 Health physics supplies 292 73 365 365 3b.4.5 Heavy equipment rental 235 35 270 270 3b.4.6 Disposal of DAWgenerated 10 3 15 15 223 4,469 3b.4.7 Plant energy budget 99 15 114 114 3b.4.8 NRC Fees 87 9 96 96 3b.4.9 Site O&M 234 35 269 269 TLG Services, Jnc.

Document Ell.1583-004 Indian Point Energy Center, Unit)

Appendix A, Page 5 of 9 DecommissioningCost Analysis Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Sito LLRW NRC Spent Fuel Sits Procosood Burial Volumes Burialt tiliy antI Packaging Transport Processing Disposal Other Total Total Lc. Tenm. Management Restoration Volume Class A Class B Class C GTCC Processed Craft ContratoI Activity Decon Removal Costs Costs Costs Costs Contin-en Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Ca. Feet Wt., Lbs., Mainooms Manhrours index Activity Description Cost Cost Costs Period 3b Period-Dependent Costs (continued) 3b.4.10 Environmental 229 34 264 264

- 4,082 612 4,695 4,695 - 68.343 3b.4.11 Utility StaffCost 1 1 10 4,732 824 6.125 6.125 223 4,469 2 68,343 3b.4 Subtotal Period 3b Period-Dependent Costs 30 527 2 336 8.663 2,285 15,829 15,319 511 11,310 148.600 20,866 91,364 3b.0 TOTALPERiOD 3b COST 989 3.431 124 3 346 23,517 4,929 33,775 33,009 766 11,536 153.118 20,860 212,360 PERIOD 3 TOTALS 989 3.867 125 PERIOD 4a - Large Component Removat Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 232 53 51 260 372 238 1,275 1,275 1,260 1,260 292.298 4,535 4a.1.1.1 Reactor Coolant Piping 69 4a.1.1.2 Pressurizer Relief Tank 9 107 53 16 100 114 83 483 483 070 753 100,540 2.035 4a.1.1.3 Reactor Coolant Pumps & Motors 4a.1.1.4 Pressurizer 4a.1.1.5 Steam Generators 115 223 52 156 129 785 785 753 2,415 91,841 2,222 4a.1.1.6 CRDMs/lClosServiceStncture Removal 42 68 1.531 121 2,958 8.731 8,731 411 501 115 78,135 13.300 664 41.1.1.7 Reactor Vessel Intemais 35 2,270 "-1,523 293 1,075 161 1,237 1.237 47 19,440 4a.1.1.8 VesselS Internals GTCC Disposal 648 4.391 121 6.828 18,129 18,129 - 5,337 1,239 654.068 13,300 664 4a.1.1.9 Reactor Vessel 5.1335 306 412 7.640 241 10,397 30,642 30.642 2,884 10.177 1.740 115 47 1.236.322 35.392 1.328 4a.1.1 Totals 156 8,560 2,501 734 Removal of MajorEquipment Main TurbieelGenerator 188 52 17 208 86 851 551 2,481 111.651 2,692 4a. 1.2 465 16 6 70 130 689 689 840 37.821 6.671 4a.1.3 Main Condensem Cascading Costs from Clean Building Demolition 10,115 1,517 11.632 11,632 106.763 4a.1.4.1 Reactor Containment 4a.1.4.2 Chemical Systems Bullding 3.632 545 4,177 4,177 34.588 207 31 230 230 1.S39 4a.1.4.3 Fuel Handling Building 692 104 796 796 6.599 4a.1.4.4 Nuclear Service Building 14.647 2.197 160,44 16,844 149,788 4a.14 Totals Disposal of Plant Systems 20 155 - 155 - - 1,981 4a.1.5.1 Electtdal - Clean 135 4a.1.5.2 Plant Air 92 81 36 218 218 - 1,075 43,674 1,370 56 - 56 726 4a.1.5.3 Plant Heating 48 7 18 141 141 - 1,831 4a.1, 5.4 River Water 123 4a.1.5.5 Sevice Water 24 4 27 - 27 .31 355 4a.1,5.6 Turbine 89 3 13 161 49 315 315 - 2,131 - - 860.26 1,290 38 289 - 289 . - 3,667 4a. 1.5.7 Well Water 252 4ad1.5 Totals 762 5 19 242 172 1,201 533 668 3,206 130.200 11,222 4a. 1.6 Scaffolding in support of decommissioning 1.357 17 6 62 10 354 1,805 1,005 739 46 37,366 21.936 783 994 7,650 241 13,336 51.732 51.063 660 10,150 10,223 1.740 115 47 1,553,359 227,702 1,328 4a.1 Subtotal Peiod 4a ActivityCosts 156 25,980 2,593 Period4a Collateral Costs

- 3 15 10 7 40 40 37 2,235 7 4a.3.1 Process liquid waste 5 4a.3.2 Small too] allowance 338 51 389 350 4a.3.3 Survey and Release o1Scrap Metal 086 296 1,282 1.202 3 15 806 354 1.711 1,672 39 37 2,235 7 4a.3 Subtotal Period4a Collateral Costs 5 338 10 Period 4a Period.Dependent Costs 4a.4.1 Decon supplies 37 9 46 46 4a.4.2 Insurance TLG Services, 1se.

Documenealt1-1583-004 Indian Point Energy Center, Unit 1 Appendix A, Page6 of9 Destomi.sioningCost Analysis Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

LLRW NRC Spont Fuol Sits Processed Burial Volumes Burial I Utility and Off-Site Removal Packaging Transport Processing Disposal Other Total Total Lic. Toem. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Decon ctiv Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Foot Cu. Foot Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours o cdtio Cost Period 4a Period-Dependent Costs (continued) 4..4.3 Property toxes 4a.4.4 Health physics supplies 1,313 328 1.642 1,642 40.4.5 Heavy equipment rental 1,439 216 1.655 1,655 5 75 - 20 108 108 1,658 33.169 13 4a.4.8 Disposal oa DAWgenerated 64* 646 646 562 4a.4.7 Plant energy budget 4.A4.8 NRC Fees 109 11 120 120 4a.4.9 Site O&M 294 40 338 338 4a.4.10 Rsadwaste Processing Equipment/Senricesc 235 35 271 271 4a.4.1 1 Environmental 288 43 331 331 126,060 4a.4.12 UtilityStaff Cost - - 7,561 1.134 8,695 8,695 9.050 1,926 13,853 13.a53 1,658 - 33,169 13 126.060 40.4 Subtotat Period 4a Period-Dependent Costs 37 2.752 8 5 - 75 994 7,735 10.277 15,615 67,295 66.587 707 10.150 11,919 1.740 115 47 1,588,763 227,723 127,388 40.0 TOTALPERIOD 4a COST 198 29.070 2,603 802 PERIOD 41 - Site Decontamination Period 4b Direct Decommissioning Activities 603 313 36 96 43 338 266 1.092 1,092 - 1.546 138,718 4b.1.1 Remove spent fuel racks Disposal of Plant Systems 182 3 11 137 68 400 400 1,810 - 73,494 2.593 4b.1.2.1 Cleanup &Condensate Demineralizer 71 399 399 1.249 50,719 2,937 4b.t.2.2 Coentrl Rod HydraulicSystem 224 2 8 94 285 8 29 .359 130 811 011 4.759 193,258 4,093 4b.1.2.3 Cooling Water 1 19 105 105 342 13,892 838 4b.1.2.4 Electrical- Contaminated 58 2 26 934 20 73 810 383 2,320 " 2,320 - 12.048 489,258 13.381 4bti1.2.5 Electdral - RCA -

4b.1.2.6 Fire Protection 52 8 60 - 60 - 778 0 21 9 53 53 274 11.122 290 4". 1.2.7 Fire Protection - RCA 21 2 962 4b.1.2.8 FloorDroat Tank &LaundryWaste 94 2 6 73 35 209 209 39,087 1,328 191 6 89 560 560 - 3,361 136,476 2.734 4b. .2.9 Fuel &Luhe Oil 20 254 4b.1.2.10 Fuel Oil Tanks 412 62 473 - 473 5,920 0 1 - S - 9 4b.1.2.1 1 Improvements Radiation Detecton Unit 886 107 38 218 218 35,976 1,483 4b.1.2.12 LiquidWaste Storage & Hold-UpTanks 5 67 1,492 87 329 4,110 1,048 7,066 7,066 - 54,411 2,209,667 21,743 4b.1.2.13 Main Steam & Coedensate -

4b.1.2.14 Misc Serice Piping 5 1 6 - 78 198 8 387 113 738 738 5,130 200.325 2,912 4h.1.2.1S Nuclear Steam Supply 31 382 8 154 931 931 4.746 192,742 5,375 4b..1.2.16 Plant Heating - RCA 29 359 131 2 98 49 287 287 1,299 52,747 1,715 4b.1.2.17 Plant Heating Contaminated 8 4b.1.2.1 8 REDT& Fuel Handling Water Treatnent 230 5 20 248 98 601 601 3,282 133.264 3.312 4b.1.2.19 Radwaste & Waste Dentin Tanks 487 7 27 339 158 939 939 4,491 182,398 5.806 4b.1,2.20 Service Water- RCA 188 7 25 318 99 638 638 4,213 171,087 2,691 3 1,863 75,143 2,206 4b1.1.2.21 Sludge Handling Resin Star &Waste Conc 154 11 141 61 370 370 4b.1.2.22 Waste Neutralizer &Waste Collectar Tank 110 2 9 107 45 273 273 1.415 57,471 1,598 4b.1.2.23 Waste Treament 1.289 37 140 1,749 609 3,825 3,825 - 23.157 940,414 18,680 7,144 210 784 9,797 3,347 21.283 20,744 539 129,696 - 5,267,039 102.498 4b.1.2 Totals 4b.1.3 Scaftolding in support ofdecommissioning 2,035 25 9 93 15 830 2,708 2,708 - 1,108 69 56,049 32,904 Decontamination of Site Buldings 4b.1.4.1 Reactor Contalement 1,336 3.434 5,873 4,576 669 7,263 4.716 27.867 27.867 8,859 277,680 28,116,760 68,101 4b.1.4.2 Chemical Systems Building 771 2.146 4,178 3.234 92 5.152 3.126 18.899 18,699 1.223 197,917 19,839,890 41,698 109 1,850 3,985 3,082 27 4,912 2,610 16.976 16,576 362 188.869 18.901,140 28,298 4b.1.4.3 Fuel Handling Building 4b.1.4.4 Nuclear Senvice Building 270 656 1,284 994 26 1,583 977 5,791 5.791 346 60,836 6,097,243 13,247 41.1.4.5 Service Buiding &H. T. Switchgear - 169 368 285 454 235 1.910 1.510 - 17,456 1.745,550 2,436 4b. 1.4.6 Superheater Building 482 888 1,940 1.499 2.390 1,479 8.678 8,678 91,935 9,193,00 19,903 4b.1.4.7 Turbine Building 260 1,329 2,904 2,245 - 3.579 1,984 12,302 12,302 - 137.660 13.765.950 23,032 4b.1.4 Totss 3,229 10.471 20,532 15,916 815 25,334 15,128 91,424 91,424 - 10.790 972,352 97,660,020 196,715 4b.1 Subtotal Period 48 ActivityCosts 3.542 19,867 20,862 16,752 10,794 25.687 19,272 116.507 110,968 039 141,594 973,967 103,121,800 332,720 TLG Services, In,.

Document EI1-1593o004 Indian Point Energy Center, Unit 1 Decsommissioning Cost Analysis Appendix A, Page 7 of9 Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel sits Processed Burial Volumes Burial I Utility ands Doecon Removal Packaging Transport Processing Disposal Other Total Total LIc. Tosm. Management Restoration Voiume Class A Class B Class C GTCC Processed Craft Contractor Activity Cost Cost Costs Costs Costs Costs Costs Continsnc Costs Costs Costs Costs Cu. Feet CU. Feet Cu. Foot Cu. Foot Cu. Foot Wt.. Lins. Mashoors MaohocursI Index Activitt Description Period 4b AdditionalCosts 652 196 848 548 - - 6,240 4b.2.1 Final Site Survey Program Management 12,181 1.280,000 320 -

4b.2.2 AOC PCB SoilRemediaton 37 12 76 218 - 76 420 420 218 652 272 1.267 1,267 12,181 1,280,000 320 6,240 4b.2 Subtotal Period 4b AdditionalCosts 37 12 76 Period 4b CollateIraCosts 4b.3.1 Provess liquidwaste 24 - 13 72 51 37 198 198 185 11,098 36 4b.3.2 Small tooi aottoc. 443 -. .. 66 599 509 4L.33 Decommissioning EquipmentOisposition - 135 59 . 502 82 - 110 896 896 6,000 373 303,507 88

.- - . . 966 290 1,255 1,255 4b.3.4 Survey and Release of Scrap Metal 4b.3 Subtotal Peorod4rbCollateral Costs 24 443 148 132 502 133 965 511 2,859 2.859 6,000 558 314,605 124 Period 4b Peioo-Dependent Costs 4b.4.1 Deon suppiies 1.333 333 1,666 1,666 4b.4.2 Insurance 4b.4.3 Property taxes Health physics supplies 1,863 466 2,329 2,329 4b.4.4

- -- - 289 2,218 2,218 -

4b.4.5 Heavy equipment rental 1,929 4b.4.6 Disposal of DAWgenerated 21 14 204 - 55 293 293 4,503 90,057 36

- 599 90 689 689 -

4b.4.7 P Plant energy budget 4b.4.8 NRC Fees 148 15 163 163 4b.4.9 Site O&M 397 60 456 456 4b.4.10 Radwaste Processing EquipmentoSerlces 318 48 365 , 365 389 58 447 447 4b.4.11 Environmental 5,331 800 6.131 6.131 -

- 95,383 4b.4.12 UtilitySlaff Cost 4b.4 Subtotal Period 41bPerod-tepesdent Costs 1,333 3,792 21 14 - 2G4 7,182 2,213 14.759 14,759 4,503 90.057 36 95.383 4b.0 TOTALPERIOD4b COST 4,898 23,959 21,043 16.974 11.207 26,243 8,800 22,269 135,392 134.853 539 147,594 991.209 104.806.500 333.200 101.623 PERIOD 4o - License Termination Period 4e Direct Decommissioning Activities 4e.1.1 ORISE confionatorysurvey 152 46 198 198 4e.1.2 Terminate Olense 4e.1 Subtotal Period 4e ActivityCosts 152 46 196 198 Perod 4d AdditionalCosts 4e.2.1 Final Site Survey 4,076 1,223 5,298 5.298 56,068 3,120 4e.2.2 Staff relocationsexpenses 1.639 246 1.685 1,005 4e.2 Subtotal Period 4e Additional Costs 5,715 1.469 7,184 7.184 56,068 3,120 Period 4e Period-Dependent Costs 4e.4.1 Insurance 4e.4.2 Property taxes 4e.4.3 Health physics supplies 526 - - 131 657 657 - -

- 1 1 13 - 4 19 19 294 5,881 2 4e.4.4 Disposal of DAWgenerated 141 21 162 162 - -

4e.4.5 Plant energy budget 130 13 143 143 4e.4.6 NRC Fees 4e.4.7 Site O&M 350 52 402 402 4e.4.0 Environmental 343 51 394 394

- - 2,165 325 2.490 2,490 - --- 33,000 4e.4.9 UtilityStaff Cost -

4a.4 Subtotal Period 4e Pnri*-Dependent Costs 526 1 1 13 3,129 596 4.268 4.268 294 5,881 2 33.000 526 1 1 - 13 8,997 2,112 11,650 11,650 - 294 5,881 56,070 36,120 4e.0 TOTALPERIOD4e COST 5.096 53.555 23.647 17,777 12.201 33.991 28,074 39,997 214.337 213.091 1,246 157,744 1,003,422 1.740 115 47 106,401.100 616,993 265,131 PERIOD4 TOTALS TLG Services, Ine.

Documoent EII-1583-004 Indian Point Energy Center, Unit I Appendix A, Page 8 of 9 Decommissioning Cost Analysis Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

NRC Spent Foei sine Processed ButialVolouees BurialI Utility and Ott-Site LLRW Craft Contractor Processing Disposal Other Total Total LIc. Teem. Management Restoration Volume Class A Class B Class C GTCC Processed Activity Decon Removal Packaging Transport Costs Consneenct ' Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Index Activit Description Cost Cost Costs Costs Coons Costs PERIOD5b - Site Restoration Period 5b Direct Decommissioning Activities Demolitionof Remaining Site Buildings 116 1 10 10 51,1.1.1 Reactor Costaironont a 4 375 50.1.1.2 Chemical Systems Building 24 27 27 16 21 289 5b01.1.3 Fuel Handling Building 3 21 39 297 297 2,721 5b.1.1.4 Fuel Oil Tank Farn 259 3 20 20 209 5b.11.5 Gas BottleStorage 17 3 168 21 24 24 5b.1.1.6 Gas Turbine 1,127 15 112 112 5.1.1.7 Sornenwell H-ouse 98 38 2.865 5b. 1.1.8 Service Building&H. T. Siltchgear 252 289 289 154 1,184 1,194 12,177 5b.1.1.9 Superheater Building 1.030 5 435 40 40 5b.1 .1.10 Transformer Area 35 13.445 Sb.1.1.11 Turbine Building 1,267 190 1,457 1,457 60 462 462 3,289 5b.1.1.12 Turbine Pedestal 401 37,215 5b.1.1 Totals 3.429 514 3,944 3,944 Site Closeout Activities 3,990 520 3,990 8.904 5b.1.2 BackFillSite 3,469 12 89 89 168 5b.1.3 Grade &landscape site 77 1.114 50.1.4 Final report to NRC 111 17 127 127 1,063 8.150 127 8,022 46,288 1,114 5b.1 Subtotal Pesod 5b ActivityCosts 6.976 111 Pesod 5b AdditionalCosts 104 434 5b.2.1 Concrete Crushing - 1 16 120 120 33,139 - 11,551 64,645 64,645 1,262,434 96.444.000 25,372 5b.2.2 Unit 1 Legacy Soil Remediaono 2.898 33B 16,719 1 11.567 64,765 64,645 120 1,262,434 96,444,000 25,806 5b.2 Subtotal Pesod 5b AdditionalCosts 3.002 339 16,719 33,139 Petiod 5b Collateral Costs 5b.3.1 Small tOOlallowance 106 16 122 122 5b.3 Subtotal Period 51 Collateral Costs 106 16 122 122 Period 5b Pediod-Depeodnnl Costs 504.1 insurance 5b.4.2 Property taxes 50.4.3 Heavy equipment rental 9,291 1.394 10,684 10,684 375 56 431 431 5b.4.4 Plant energy budget 2,140 1.861 279 2,140 50.4.5 Site O&M 1.824 274 2,098 2,098 5b.4.6 Environmental 6.151 79,420 5b.4.7 UtilityStaff Cost - 55349 802 6,151 9.409 17.266 79,420 5b.4 Subtotal Period 5b Pedod-Dependent Costs 9,291 2.805 21,504 4,238 33,139 9.520 15,450 94,542 69,010 25.531 1.262,434 96.444,000 72,094 80,534 50.0 TOTAL PERIOD5b COST 19,375 338 16.719 19.375 338 16.719 33,139 9.520 25.531 96,444,000 72,094 80,534 PERIOD 5 TOTALS 15,457 94,542 69,010 1,262,434 34,678 12,201 69.920 287,479 75,278 547,458 15.929 27.543 157,744 2,296,075 1,740 115 47 203,371,900 710.102 979,487 TOTALCOST TO DECOMMISSION 6.085 81,216 24,073 590,930 TLG Services, Ine.

Documoent E1I14583-004 Indian Pointt Ener-gy Center, Unit I Appensdix A, Page 9 of 9 DercommissiaoningCast A..tyoio Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Sito Processed Burlal Volumes Burial I Utilityand Decon Removal Packaging Transport Processing Disposal Other Total Total LIc. Teno. Managenent Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Activity Costo Costs Costs Costs Costs Continh0nc Costs Costs Costs Costs Cu. Feet Cu. Foot Cu. Feet Cu. Feet Cu. Foot Wt., Lbs. Manhours Manhours index Activit Description Cost Cost TOTALCOST TO DECOMMISSIONWITH14.6% CONTINGENCY: $590,930 thousands of 2007 dollars TOTALNRC LICENSETERMINATIONCOST IS 92.64% OR: $547,458 thousands of 2007 dollars SPENTFUEL MANAGEMENT COST IS 2.7% OR: $15,929 thousands of 2007 dollars NON-NUCLEAR DEMOLITIONCOST is4.66% OR: $27,543 thousands of 2007 dollars TOTALLOW-LEVELRADIOACTIVE WASTEVOLUMEBURIED (EXCLUDINGGTCC): 2,297,929 cubic feet OTAL GREATERTHANCLASS C RADWASTEVOLUMEGENERATED 47 cubic feet TOTALSCRAP METALREMOVED: 26,675 tons TOTALCRAFT LABORREQUIREMENTS: 710,102 man-hours End Notes:

ria - indicates that this activitynot charged as decormmissioningexpense.

a - Indicates that this activityperformed by decommissioning staff.

0 indicates that this value is less than 0.5 but is non-zero.

a co1 containing -- indicates a zeo value TLG Services, Inc.

Enclosure 2 to NL-08-144 Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 2 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 2 DOCKET NO. 50-247

Document Ell-1583-003 PRELIMINARY DECOMMISSIONING COST ANALYSIS for the INDIAN POINT ENERGY CENTER, UNIT 2 preparedfor Entergy Nuclear preparedby TLG Services, Inc.

Bridgewater, Connecticut October 2008

IndianPoint Energy Center,Unit 2 Document Eli-1583-003 PreliminaryDecommissioningCost Analysis Page ii of v APPROVALS Project Manager /0/?atle.

William A. Cloutier, 6 r. Date Project Engineer Thomas e Garrett Date Technical Manager Geoff e". Griffit hs Date Quality Assurance Manager Jeh J. Adled Dateý TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page iii of v TABLE OF CONTENTS SECTION PAGE L. DECOMMISSIONING COST ANALYSIS ............................................................ 1 1.1 Decommissioning Alternatives ....................................................................... 2 1.2 Regulatory Guidance ....................................................................................... 2 1.3 Basis of Cost Estimate ..................................................................................... 3 1.4 M ethodology .................................................................................................... 3 1.5 Impact of Decommissioning Multiple Reactor Units ................................... 5 1.6 Financial Components of the Cost Model 6 6..........................

1.6.1 C ontingency ........................................................................................... 6 1.6.2 Financial Risk ....................................................................................... 7 1.7 Site-Specific Considerations ............................................................................ 8 1.7.1 Spent Fuel Disposition ......................................................................... 8 1.7.2 Reactor Vessel and Internal Components ....................................... 12 1.7.3 Primary System Components ............................................................ 13 1.7.4 Retired Components ............................................................................ 14 1.7.5 Main Turbine and Condenser ............................................................ 14 1.7.6 Transportation Methods ..................................................................... 14 1.7.7 Low-Level Radioactive Waste Conditioning and Disposal .............. 15 1.7.8 Site Conditions Following Decommissioning ................................... 17 1.7.9 Site Contamination ........................................................................... 18 1.8 A ssumptions .................................................................................................. 18 1.8.1 E stim ating B asis ................................................................................ 18 1.8.2 Release Criteria .................................................................................. 19 1.8.3 Labor Costs ......................................................................................... 19 1.8.4 Design Conditions .............................................................................. 20 1.8.5 G eneral ................................................................................................ 20

2. RE S U L TS ................................................................................................................... 24 2.1 Decommissioning Trust Fund ........................................................................ 25 2.2 Financial A ssurance ....................................................................................... 25 FIGURE 1 SAFSTOR Decommissioning Timeline ........................................................... 26 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page iv of v TABLE OF CONTENTS SECTION PAGE TABLES 1 Low-Level Radioactive Waste Disposition ....................................................... 27 2 Summary of M ajor Cost Contributors ............................................................ 28 3 Schedule of Annual Expenditures, Total Decommissioning Cost ................. 29 4 Schedule of Annual Expenditures, License Termination Allocation ............. 31 5 Schedule of Annual Expenditures, Spent Fuel Management Allocation ..... 33 6 Schedule of Annual Expenditures, Site Restoration Allocation .................... 35 7 Funding Requirements for License Termination ........................................... 36 APPENDIX A. 2007 Detailed Cost Analysis ............................................................................ A-1 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page v of v REVISION LOG No 1 *R o Date Item Revised !, Reason for Revision 0 10-22-2008 Original Issue TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Eli-1583.003 PreliminaryDecommissioning Cost Analysis Page 1 of 38

1. DECOMMISSIONING COST ANALYSIS This document presents the cost to decommission the Indian Point Energy Center, Unit 2 (IP-2) assuming a cessation of operations after a nominal 40-year operating life in 2013. 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 IP-2 nuclear unit.

The cost to decommission IP-2 is estimated at $920.5 million. The cost is presented in 2007 dollars for consistent year comparison with the Company's latest filing on the status of the IP-2 decommissioning trust fund.[1]

The estimate for IP-2 assumes that it is decommissioned in conjunction with the two adjacent units (the shutdown IP-1 and the currently operating IP-3). As such, there are savings as well as additional costs that are reflected within the estimate from the synergies of site decommissioning and the constraints imposed in working on a complex and congested site. In apportioning site decommissioning costs by unit, not all common costs are shared equitably (e.g., due to the offset in shutdown dates) and some costs elements are impacted by activities or previous operations at adjacent units.

The cost includes the monies anticipatedto be spent for operating license termination, spent fuel storage and site remediation 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 remediation and restoration requirements. Many of these assumptions are discussed in more detail in this document.

Entergy intends to fund the expenditures for license termination (comprising approximately 72% of the total cost) from the currently existing decommissioning trust fund. The management of the spent fuel, until it can be transferred to the DOE, may be funded from excess trust fund earnings 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 will not reduce the value of the decommissioning trust fund to below the amount necessary to place and maintain the reactor in safe storage to place and maintain the reactor in safe storage. The licensee would make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

1 Entergy Nuclear Operations' submittal of its "Decommissioning Fund Status Report" to the Nuclear Regulatory Commission, Letter No. ENOC-08-00028, dated May 8, 2008 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page2 of 38 1.1 DECOMMISSIONING ALTERNATIVES The Nuclear Regulatory Commission (NRC) provided general decommissioning guidance in a rule adopted on June 27, 1988.[21 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 3

of operations."[ ]

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[4]

Decommissioning is to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety.

ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."[5] 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 2 U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988

.* Ibid. Page FR24022, Column 3 4 Ibid.

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

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page 3 of 38 the decommissioning process.[6] 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 cost estimate for IP-2 follows the general guidance and sequence presented in the amended regulations.

1.3 BASIS OF COST ESTIMATE For the purpose of the analysis, IP-2 was assumed to cease operations in September 2013, 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 transfer to a DOE facility. Based upon a 2017 start date for the pickup of spent fuel from the commercial nuclear power generators, Entergy anticipates that the removal of spent fuel from the site could be completed by the year 2043. However, for purposes of this analysis, the plant will remain in storage until 2064, at which time it will 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 decommissioning estimate was developed using the site-specific, technical information relied upon in the decommissioning assessments prepared in 2000 and 2002.[71[81 This information was reviewed for the current analysis and updated to reflect any significant changes in the plant configuration over the past five years. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from recent decommissioning projects provided viable alternatives or improved processes. On site interviews were conducted between August and November 2007 to assist in obtaining current site specific conditions as well as collect financial data.

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 6 U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61, (p 39278 et seq.), July 29, 1996 7 Decommissioning Cost Evaluation Due Diligence Estimate for the Indian Point 1 & 2 Nuclear Generating Stations Document No. El1-1395-002, September 2000.

s TLG Document No. E11-1449-002, December 19, 2002 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page4 of 38 Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[19 and the DOE "Decommissioning Handbook."[o1 0 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.["1 ]

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-1 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 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%

o Respiratory Protection Factor 0% to 50%

9 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 11 "Building Construction Cost Data 2007," Robert Snow Means Company, Inc., Kingston, Massachusetts TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page5 of 38 e Radiation/ALARA Factor 0% to 37%

o Protective Clothing Factor 0% to 50%

o 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 Program 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 three co-located reactor units there can be opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities.

There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitations on when final status surveys can take place. The estimate for IP-2 considered:

Savings in program management, in particular costs associated with the more senior positions, from the sequential decommissioning of two, essentially identical reactors. The estimate assumes that IP-2 is the lead unit in decommissioning through the disposition of the reactor vessel and primary system components, at which time IP-3 assumes the lead. Costs for the senior staff positions are only included for the lead unit.

" The current need by IP-3 to use the IP-2 spent fuel pool to transfer spent fuel to the ISFSI. As such, the estimate for IP-2 includes an extended period of spent fuel pool operations.

o The confines of a congested site and the need to coordinate dismantling operations. Demolition and soil remediation, following the primary TLG Services, Inc.

Indian PointEnergy Center, Unit2 Document El1-1583-003 PreliminaryDecommissioning Cost Analysis Page 6 of 38 decommissioning phase (removal of major source terms and radiological inventory), are conducted as a site-wide activity.

Sharing of station costs such as ISFSI operations, security, emergency response fees, regulatory agency fees, corporate overhead, and insurance.

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."[12] 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 or during the extended storage period.

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 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.

IndianPoint Energy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioningCost Analysis Page 7 of 38 end of the detailed estimate. The composite contingency value reported for the SAFSTOR scenario, and as shown in the detail table in Appendix A, is 17.26%.

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).

o 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 TLG Services, Inc.

IndianPoint Energy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioningCost Analysis Page 8 of 38 is a low probability, and the chances that the estimate is too low is a higher probability. This cost study, however, does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk should be revisited periodically and addressed through 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"[1 31 (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 13 "Nuclear Waste Policy Act of 1982 and Amendments," U.S. Department of Energy's Office of Civilian Radioactive Management, 1982 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page9 of 38

.review, DOE expects that receipt of fuel could begin as early as 2017,[141 depending upon the level of funding appropriated by Congress.

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 site until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[151 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 ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the next eight years, the assemblies are packaged into multipurpose canisters for transfer directly to the DOE or for interim storage at the ISFSI. It is assumed that this period provides thenecessary cooling for the final core to meet the design requirements for decay heat for either the transport or storage systems (the eight-year period also considers the use of the IP-2 pool by IP-3).

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 IPEC site was assumed to be in 2018. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year for the commercial industry, completion of the removal of all fuel from the site was projected to be in the year 2045 assuming shutdown of IP-2 in 2013 and IP-3 in 2015. 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.

Entergy Nuclear's position is that the DOE has a contractual obligation to accept IPEC 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 14 "DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's 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.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioningCost Analysis Page10 of 38 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, theDOE has not performed earlier.

ISFSI This analysis assumes that an ISFSI has been constructed within the protected area (PA) to support continued plant operations. The estimate further assumes that this facility is expanded (to a total capacity of 96 casks) to support decommissioning and accommodate the additional dry storage casks needed to off-load the IP-2 wet storage pool (the facility may need to be further expanded for IP-3 spent fuel storage). Once the IP-2 pool is emptied, the spent fuel storage *and handling facilities are available for decommissioning or readied for long-term storage.

Operation and maintenance costs for the ISFSI are included within the estimate and address the costs for staffing the facility, as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the multi-purpose spent fuel storage canisters (MPCs) directly from the pool to the DOE or to the ISFSI for interim storage. Costs are also provided for the final disposition of the facilities once the transfer is complete.

In the absence of identifiable DOE transport cask requirements, the design and capacity of the 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.

Storaae 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 32 fuel assemblies.

Canister Loading and Transfer The estimate includes the costs to purchase, load, and transfer the MPCs from the pool into a DOE-provided transport cask or to the ISFSI.

Costs are also included for the transfer of the fuel at the ISFSI to the DOE.

TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page11 of 38 For fuel transferred directly from the pool to the DOE, the DOE is assumed to provide the canister at no additional cost to the owner. It should be noted that, in this analysis, DOE is assumed to use its own Transport, Aging and Disposal (TAD) canister with a capacity of 21 assemblies for wet pool pickup.

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 Desian 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.

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 IP-2 includes an allowance for the disposition of GTCC material.

TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page 12 of 38 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).

1.7.2 Reactor Vessel and Internal Components The reactor pressure vessel and reactor internal components are segmented for disposal in shielded transportation casks. Segmentation and packaging of the internals are performed in the refueling canal where a turntable and remote cutter are installed. The vessel is segmented in place using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor 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 IPEC reactors will generate radioactive waste considered unsuitable for shallow land disposal (i.e., GTCC). For purposes of this study, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

Intact disposal of 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 since.

It is not known whether this option will be available when the IPEC units cease 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.

TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioningCost Analysis Page13 of 38 1.7.3 Primary System Components The current scenario defers decommissioning for approximately 50 years. 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 coolant system components and associated reactor water cleanup systems is not anticipated to be necessary and no allowance is included for this activity within the estimate.

Reactor coolant 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 coolant pumps and motors are lifted out intact, packaged, and transported for processing or disposal.

The following discussion deals with the removal and disposition of the steam generators, but the techniques involved are also applicable to other large radioactively-contaminated components, such as heat exchangers and the pressurizer. The steam generators' size and weight, their location within the reactor building, as well as the disposal facility waste acceptance criteria, and access to transportation will ultimately determine the removal, transportation, and disposal strategy.

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

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

Disposal costs are based upon the displaced volume and weight of the primary side. portions of the steam generators. Each component is then TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page 14 of 38 loaded onto a barge for transport to a rail head and the disposal facility.

The secondary side is assumed to be sent to an off-site waste processor.

1.7.4 Retired Components The estimate includes the cost to dispose of the retired steam generators currently stored on site. Transportation and disposal will occur following the removal of the installed steam generators.

1.7.5 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled demolition. The main condensers are also disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it 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 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., 137 Cs, 90Sr, or transuranics) has not reached levels exceeding those that permit the major reactor 16 U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 2007 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document El1-1583-003 PreliminaryDecommissioningCost Analysis Page 15 of 38 components to be shipped under ,;

current transport regulations  !.:*'

requirements. 0 Transport of the highly activated R 4c metal, produced in the segmentation .

of the reactor vessel and internal : $4 components, is by shielded truck cask. * ,, ,

Cask shipments may exceed 95,000 "

pounds, including vessel segment(s), *' F Z supplementary shielding, cask tie- i"Y downs, and tractor-trailer. The "p maximum level of activity per C  ;!

shipment assumed permissible is based upon the license limits of the 4:: "-

available shielded transport casks. ,

The segmentation scheme for the vessel and internal segments is designed to meet these limits.

Considering the location of IPEC (see map above) and the potential for restricted road use, it is assumed that transportation of materials requiring controlled disposal will utilize the Hudson River via barge shipment to the nearest transfer point for rail or trucking to the Energy-Solutions' facility in Clive, Utah. However, for estimating purposes, costs to transport the majority of the low-level radioactive waste (excluding large components) were based upon truck transport costs developed from published tariffs from Tri-State Motor Transit.[17]

Memphis (TN) 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 is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,[18] the states became ultimately responsible for the disposition oflow-level radioactive waste generated within their own borders.

17 Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC),

Docket No. MC-427719 Rules TariffMarch 2004, Radioactive Materials Tariff, February 2006.

18 "Low Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 ' Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page 16 of 38 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, IP-2 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. 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, IP-2 is still able to dispose of Class A material at EnergySolutions' facility in Clive, Utah.

The costs reported for direct disposal (burial) in the estimate are based upon Entergy Nuclear Operations, Inc. current Life of Plant Disposal Agreement with EnergySolutions.[211 This facility was used as the destination for the majority of the waste volume generated by decommissioning (99.3%). EnerxgySolutions 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 0.6% 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 0.1% of the total waste volume) is generally not suitable for shallow-land disposal. This material is packaged in the same multipurpose canisters used for spent fuel storage/transport and designated for geologic disposal.

19 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, January 15, 1986 20 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" 21 General Services Agreement 10160239 between Entergy Nuclear Operations and EnergySolutions, June 2007 TLG Services, Inc.

IndianPoint Energy Center, Unit 2 Document El1-1583-003 PreliminaryDecommissioningCost Analysis Page 17 of 38 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 when it determines that site remediation has been performed in accordance with the license termination plan, and that the final status 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 2 21 and commitments for the site.[

Only existing site structures are considered in the dismantling cost. The current analysis includes all structures as defined in the site plot plan.[23] The electrical switchyard remains after Indian Point is decommissioned in support of the regional transmission and distribution system. The Generation Support Building and IPEC Training Center remain in place for future use. Clean non-contaminated structures are removed to a nominal depth of three feet below grade. The voids are backfilled with clean debris and capped with soil. The site is then re-graded to conform to the adjacent landscape. Vegetation is established to inhibit erosion. These "non-radiological costs" are included in the total cost of decommissioning.

22 "Entergy is committed to returning the Indian Point Unit 1, 2 and 3 facilities and the surrounding site to a "Greenfield" condition." Letter from Michael R. Kansler to Westchester County Attorney Alan D. Scheinkman, March 16, 2001 23 Entergy Nuclear Northeast "Buildings and Structures Identification Plan" ER-04-2-012, Rev. 01 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document El1-1583-003 PreliminaryDecommissioningCost Analysis Page18 of 38 Site utility and service piping are abandoned in place. Electrical manholes are backfilled with suitable earthen material. Asphalt surfaces in the immediate vicinity of site buildings are broken up and the material used for fill, as required. The site access road remains in place.

1.7.9 Site Contamination As indicated by the IPEC Groundwater Investigation Project,[241 it is likely that radionuclides in the soil has contaminated portions of the subsurface power block structures. As such, sub-grade surfaces of the following IP-2 structures are designated for removal:

o Discharge Canal

" Fuel Storage Building, and o Turbine Building (approximately 50%).

All other structures or buildings expect to be impacted in the decontamination process are removed to a nominal depth of three feet below grade.

Site remediation costs include the removal and disposition of 379,000 cubic feet of potentially contaminated soil on the IP-2 site. This volume includes soil contaminated by IP-1 located within the boundaries of the IP-2 site.

1.8 ASSUMPTIONS The following assumptions were made in the development of the estimate for decommissioning IP-2.

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

The estimates rely upon the physical plant inventory that was the basis for the 2002 analysis (updated to reflect any significant changes to the plant over the past five years).

24 "Hydrogeologic Site Investigation Report," GZA GeoEnvironmental, Inc., January 2008 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Ell-1583-003 PreliminaryDecommissioning Cost Analysis Page 19 of 38 The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.

1.8.2 Release Criteria This estimate assumes that the site will be remediated to the levels specified by the NRC and the State of New York. Specifically, "the total effective dose equivalent to the maximally exposed individual of the general public, from radioactive material remaining at a site after cleanup, shall be as low as reasonably achievable and less than 10 mrem above that received from background levels of radiation in any one 25 year."[ ]

1.8.3 Labor Costs Entergy will 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 will 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 are based upon average salary information made available by Entergy. Qverhead costs are included for site and corporate support, reduced commensurate with the staffing levels envisioned for the project.

Severance and retention costs are not included in the estimates.

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

25 NYSDEC Division of Solid & Hazardous Materials, Bureau of Hazardous Waste Radiation Management: Cleanup Guidelines for Soils Contaminated with Radioactive Materials (DSHM-RAD-05-01)

TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document El1-1583-003 PreliminaryDecommissioning Cost Analysis Page20 of 38 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, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel. A full-time security force is assigned to the nuclear unit. With one exception, IP-2 is also assumed to provide for any IP-1 security requirements. IP-1 specific security requirements are addressed in the IP-1 estimate.

1.8.4 Design Conditions Activation levels in the vessel and internal components are modeled using NUREG/CR-3474.[ 261 Estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the IPEC components, projected operating life, and different period of decay.

Additional short-lived isotopes were derived from CR-0130[ 271 and CR-0672,[28] and benchmarked to the long-lived values from CR-3474.

The control elements are disposed of along with the spent fuel (i.e., there is no additional cost provided for their disposal). Disposition of any control elements stored in the pools from operations is considered an operating expense and therefore not accounted for in the decommissioning estimates.

Activation of the reactor building structures was assumed to be confined to the biological shield.

1.8.5 General Transition Activities Existing warehouses are cleared of non-essential material and remain for use by IPEC and its subcontractors. The plant's operating staff 26 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 27 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 28 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.

Indian Point Energy Center, Unit2 Document El1-1583-003 PreliminaryDecommissioning Cost Analysis Page21 of 38 performs the following activities at no additional cost or credit to the project during the transition period.

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

o 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; however, the estimate does include the disposition of the retired steam generators currently in storage.

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 (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.

It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning 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.

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.

TLG Services, Inc.

IndianPointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page22 of 38 Spent Fuel Pool Isolation The decommissioning cost estimate for IP-2 assumes that the spent fuel building will be used for the interim storage of spent fuel once plant operations cease until the fuel can be either transferred directly to the DOE or relocated to the ISFSI. Therefore, so that the adjacent power block structures can be de-energized and configured for long-term storage, the spent fuel -handling 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.

Energy For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage (temporary power is run throughout the plant, as needed). Replacement power costs are used to calculate the cost of energy consumed during decommissioning for tooling, lighting, ventilation, and essential services.

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are 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."[ 29] The NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.

29 "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.

IndianPointEnergy Center, Unit2 Document El1-1583-003 PreliminaryDecommissioning Cost Analysis Page23 of 38 Property Tax Property taxes or fees in lieu of taxes are not included within the estimate.

Emeraency Planning Fees Emergency planning costs are estimated from FEMA, state, and local fees, as provided in the IPEC budget accounts. Maintenance and service costs are included with the annual fees.

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.

TLG Services, Inc.

IndianPointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioningCost Analysis Page24 of 38

2. RESULTS The proposed decommissioning scenario, major cost contributors and schedule of annual expenditures are summarized in Figure 1 and in Tables 2 and 3. The summaries are based upon the 2007 detailed cost estimate provided in Appendix A.

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). The cost reported for this subcategory is generally sufficient to terminate the unit's operating license, recognizing that there may be some additional cost impact from spent fuel management. The costs for license termination are shown in Table 4.

The "Spent Fuel Management" subcategory contains costs associated with post-shutdown spent fuel pool operations, the containerization and transfer of spent fuel to the DOE or ISFSI, 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. The costs for spent fuel management are shown in Table 5.

"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. Non-contaminated structures are removed to a depth of three feet and backfilled to conform to the local grade. Contaminated foundations are removed to bedrock. The costs for site restoration are shown in Table 5.

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., Asset Retirement Obligation determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page25 of 38 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 geologic repository along with the spent fuel, GTCC waste is still classified herein as low-level radioactive waste and, as such, included as a "License Termination" expense.

2.1 Decommissioning Trust Fund The decommissioning trust fund, as reported in Entergy's latest status report (dated May 8, 2008) was $347.20 million, as of December 31, 2007.[301 This includes the money available from the Provisional Trust.

2.2 Financial Assurance It is the current plan, based on the growth of the funds in the IP-2 decommissioning trust, to fund the expenditures for license termination from the currently existing decommissioning trust fund.

Table 4 identifies the cost projected for license termination (in accordance with 10 CFR 50.75). Table 7 provides the details of the proposed funding plan for decommissioning IP-2 based on a 2% real rate of return on the decommissioning trust fund. As shown in Table 7, the current trust fund (as of December 31, 2007) is sufficient to accomplish the intended tasks and terminate the operating license for IP-2. The analysis also shows a surplus in the fund at the completion of decommissioning. This surplus could be made available to fund other activities at the site (e.g., spent fuel management and/or restoration activities), recognizing that the licensee would need to make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

10 Entergy Nuclear Operations' submittal of its "Decommissioning Fund Status Report" to the Nuclear Regulatory Commission, Letter No. ENOC-08-00028, dated May 8; 2008 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioningCost Analysis Page26 of 38 FIGURE 1 SAFSTOR DECOMMISSIONING TIMELINE (not to scale)

Shutdown: September 28, 2012 IP-3 Shutdown 12/2015

. Period 1 Period 4 Period 5 Transition and Period 2 Period 3 Decommissioning Site SPreparations Preparations Safe-Storage Operations Remediation 1 2 I22 2 09/2013 03/2015 12/2045 06/2064 12/2065 09/2069 09/2073 ISFSI Expansion Canister and overpack fabrication License Terminated Fuel to ISFSI 06/2021 Storage Pool Empty ISFSI Operations All Spent Fuel Off Site TLG Services, Inc.

IndianPointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page 27 of 38 TABLE 1 Indian Point Energy Center, Unit 2 Low-Level Radioactive Waste Disposition Waste Volume Mass Waste Cost Basis Class [1I (cubic feet) (pounds)

Low-Level Radioactive Waste near-surface disposal) EnrgSolutions - A 620,166 53,686,179 Barnwell B 3,330 352,433 Barnwell C 501 45,688 Greater than Class C Spent Fuel Equivalent GTCC 496 104,146 Processed/Conditioned Recycling off-site recyeh'ng center _ Vendors A 381,062 15,069,040 Total [21 1,005,554 69,257,486 Ill 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.

Indian PointEnergy Center, Unit 2 Document El1-1583-003 PreliminaryDecommissioningCost Analysis Page28 of 38 TABLE 2 Indian Point Energy Center, Unit 2 Summary of Major Cost Contributors (thousands, 2007 dollars)

License Spent Fuel Site Termination Manae*ment Restoration Total Decontamination 13,539 - - 13,539 Removal 86,741 2,058 45,099 133,898 Waste Packagin 13,502 3 - 13,505 Tran.sortation 21,005 119 21,124 Waste Disposal 63,760 107 - 63,867 Waste Processing (Off-site) 32,441 - 32,441 Program Management [1] 246,534 73,658 36,506 356,698 ate. .... 33,688 - - _33,688 Site O&M 22,246 3,709 25,955 Spent Fuel Management [2) 95.895 95,895 S pent Fuel Pool Isolation 10,503 10,503 Insurance and Regulatory Fec 47,813 742 48,555 Energy 31,888 1,966 1,260 35,114 Radiological Characterization 17,072 17,072 Pro Taxes 4 4 +

Miscellaneous Equpment 15,098 4 15,102 Environmental 3,521 3,521 4 I Total 659,351 178,256 82,869 920,477

[1] Includes security and engineering

[21 Includes capital costs for ISFSI expansion, multi-purpose dry storage containers and storage overpacks, packaging and handling (transfer pool to ISFSI or DOE and ISFSJ to DOE)

TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Eli-i1583-003 Preliminary Decommissioning Cost Analysis Page 29 of 38 TABLE 3

-Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Eeg~y Burial Other Totals 2013 7,993 452 818 75 2,340 11,678 2014 33,286 4,337 3,143 644 9,834 51,245 2015 15,243 6,087 1,242 450 15,563 38,585 2016 9,844 6,624 630 23 3,560 20,682 2017 9,817 6,606 629 23 3,550 20,625 2018 9,817 6,606 629 23 3,550 20,625 2019 9,817 6,606 629 23 3,550 20,625 2020 9,844 6,624 630 23 3,560 20,682 2021 6,577 3,504 469 23 2,835 13,408 2022 3,426 487 314 22 2,138 6,387 2023 3,426 487 314 22 2,138 6,387 2024 3,435 488 315 22 2,144 6,404 2025 3,426 487 314 22 2,138 6,387 2026 3,426 487 314 22 2,138 6,387 2027 3,426 487 314 22 2,138 6,387 2028 3,435 488 315 22 2,144 6,404 2029 3,426 487 314 22 2,138 6,387 2030 3,426 487 314 22 2,138 6,387 2031 3,426 487 314 22 2,138 6,387 2032 3,435 488 315 22 2,144 6,404 2033 3,426 487 314 22 2,138 6,387 2034 3,426 487 314 22 2,138 6,387 2035 3,426 487 314 22 2,138 6,387 2036 3,435 488 315 22 2,144 6,404 2037 3,426 487 314 22 2,138 6,387 2038 3,426 487 314 22 2,138 6,387 2039 3,426 487 314 22 2,138 6,387 2040 3,435 488 315 22 2,144 6,404 2041 3,426 487 314 22 2,138 6,387 2042 3,426 487 314 22 2,138 6,387 2043 3,426 487 314 22 2,138 6,387 2044 3,435 488 315 22 2_,144 L__6,404J TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document E1l-1583-003 PreliminaryDecommissioning Cost Analysis Page30 of 38 TABLE 3 (continued)

Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2045 3,352 477 314 22 2,095 6,260 2046 1,849 278 314 21 1,205 3,668 2047 1,849 278 314 21 1,205 3,668 2048 1,854 279 315 21 1,209 3,678 2049 1,849 278 314 21 1,205 3,668 2050 1,849 278 314 21 1,205 3,668 2051 1,849 278 314 21 t 1,205 3,668 4

2052 1,854 279 315 21 1,209 3,678 2053 -. 4 1.849 4. 278 314 4 21 4- 1,205 3,668 2054 1,849 278 314 21 1,205 3,668 2055 1,849 278 314 21 1,205 3,668 2056 1,854 279 315 21 1,209 3,678 2057 1,849 278 314 21 1,205 3,668 2058 1,849 278 314 21 1,205 3,668 2059 1,849 278 314 21 1,205 3,668 2060 1,854 279 315 21 1,209 3,678 2061 1,849 278 314 _- 21 1,205 , 3,668 1

2062 1,849 278 314 21 1,205 3,668 2063 1,849 278 314 21 1,205 3,668 2064 18,046 1,528 1,904 26 3,390 24,894 2065 33,595 5,569 3,135 2,703 11,377 56,378 2066 59,374 30,267 2,986 48,793 29,516 170,936 2067 36,100 8,503 2,366 16,144 12,189 75,302 2068 12,254 2,813 965 + 5,036 4 5,579 26,647 2069 13,376 6,018 314 2,089 3,732 25,529 2070 13,376 6,018 314 2,089 3,732 25,529 2071 13,376 6,018 314 2,089 3,732 25,529 2072 13,368 5,960 320 2,061 4,059 25,767 2073 7,802 1,03*9-4 463 4 18 4 17.162 26,485 Total...... 448,403 137,873 35,114 83,259 215,828 920,477 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Eli-i1583-003 Preliminary Decommissioning Cost Analysis Page 31 of 38 TABLE 4 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures License Termination Allocation

.(thousands, 2007 dollars)

Equip & Yearly Year Labor Materials _Kj~g Burial Other Totals 2013 7,993 452 818 75 1,826 11,164 2014 33,286 4,337 3,143 644 7,860 49,271 2015 9,218 1,326 1,004 450 13,309 25,307 2016 1,854 310 315 23 1,209 3,711

-.2017 1,849 309 314 23 1,205 3,701 2018 1,849 309 314 23 1,205 3,701 2019 1,849 309 314 23 1,205 3,701 2020 1,854 310 315 23 1,209 3,711 2021 1,849 297 314 23 1,205 3,688 2022 1,849 285 314 22 1,205 3,676 2023 1,849 285 314 22 1,205 3,676 2024 1,854 286 315 22 1,209 3,686 2025 1,849 285 314 22 1,205 3,676 2026 1,849 285 314 22 1,205 3,676 2027 1,849 285 314 22 1,205 3,676 2028 1,854 286 315 22 1,209 3,686 2029 1,849 285 314 22 1,205 3,676 2030 1,849 285 314 22 1,205 3,676 2031 1,849 285 314 22 1,205 3,676 2032 1,854 286 315 22 1,209 3,686 2033 1,849 285 314 22 1,205 3,676 2034 1,849 285 314 22 1,205 3,676 2035 1,849 285 314' 22 1,205 3,676 2036 1,854 286 315 22 1,209 3,686 2037 1,849 285 314 22 1,205 3,676 2038 1,849 285 314 22 1,205 3,676 2039 1,849 1285 314 22 1,205 3,676 2040 1,854 286 315 22 1,209 3,686

• 2041 1,849 285 314 22 1,205 3,676 2042 1,849 285 314 22 1,205 3,676 2043 1,849 285 314 22 1,205 3,676 2044 1,854 286 315 22 1,209 3,686 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Eli-i1583-003 Preliminary Decommissioning Cost Analysis Page 32 of 38 TABLE 4 (continued)

Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures License Termination Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2045 1,849 285 314 22 1,205 3,675 2046 1,849 278 314 21 1,205 3,668 2047 1,849 278 314 21 1,205 3,668 2048 1,854 279 315 21 1,209 3,678 2049 1,849 278 314 21 1,205 3,668 2050 1,849 278 314 21 1,205 3,668 2051 1,849 278 314 21 1,205 3,668 2052 1,854 279 315 21 1,209 3,678 2053 1,849 278 314 21 1,205 3,668 2054 1,849 278 314 21 1,205 3,668 2055 1,849 278 314 21 1,205 3,668 2056 1,854 279 315 21 1,209 3,678 2057 1,849 278 314 21 1,205 3,668 2058 1,849 278 314 21 1,205 3,668 2059 1,849 278 314 21 1,205 3,668 2060 1,854 279 315 21 1,209 3,678 2061 1,849 278 314 21 1,205 3,668 2062 1,849 278 314 21 1,205 3,668 2063 1,849 278 314 21 1,205 3,668 2064 17,902 1,528 1,904 26 3,390 24,751 2065 32,847 5,564 3,135 2,703 11,377 55,625 2066 57,084 30,181 2,986 48,793 29,516 168,560 2067 33,597 8,285 2,366 16,063 11,523 71,834 2068 11,168 2,613 958 5,010 5,364 25,113 2069 138 95 0 2,089 3,724 6,046 2070 138 95 0 2,089 3,724 6,046 2071 138 95 0 2,089 3,724 6,046 2072 308 116 10 2,061 4,051 6,547 2073 7,802 1,039 463 18 17,162 26,485 Total 300,431 69,436 3188 83,151 174,445 659,351 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Ell-1583-003 Preliminary Decommissioning Cost Analysis Page.33 of 38 TABLE 5 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials _K~t Burial Other Totals 2013 0 0 0 0 514, 514 2014 0 0 0 0 1,974 1,974 2015 6,025 4,762 238 0 2,255 13,279 2016 7,989 6,314 315 0 2,352 16,971 2017 7,968 6,297 314 0 2,345 16,924 2018 7,968 6,297 314 0 2,345 16,924 2019 7,968 6,297 314 0 2,345 16,924 2020 7,989 6,314 315 0 2,352 16,971 2021 4,728 3,207 155 0 1,629 9,720 2022 1,577 201 0 0 933 2,711 2023 1,577 201 0 0 933 2,711 2024 1,581 202 0 0 936 2,718 2025 1,577 201 0 0 933 2,711 2026 1,577 201 0 0 933 2,711 2027 1,577 201 0 0 933 2,711 2028 1,581 202 0 0 936 2,718 2029 1,577 201 0 4, 0 933 2,711 2030 1,577 201 0 0 933 2,711 2031 1,577 201 0 0 933 2,711 2032 1,581 202 0 0 936 2,718 2033 1,577 201 0 0 933 2,711 2034 1,577 201 0 0 933 2,711 2035 1,577 201 0 0 933 2,711 2036 1,581 202 0 0 936 2,718 2037 1,577 201 0 0 933 2,711 2038 1,577 201 0 0 933 2,711 2039 1,577 201 0 0 933 2,711 2040 1,581 202 0 0 936 2,718 2041 1,577 201 0 0 933 2,711 2042 1,577 201 ___ 0 0- 933 2,711 2043 1,577 201 0 0 933 2,711 2044 1,581 202 0 0 936 2,718 TLG Services, Inc.

Indian PointEnergy Center, Unit2 Document Ell-1583-003 PreliminaryDecommissioning Cost Analysis Page34 of 38 TABLE 5 (continued)

Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Energ Burial Other Totals 2045 1,503 192 0 0 889 2,585 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0~ 0 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 2055 0 0 0 0 0 2056 0 0 0 0 0 0 i 4 -t +

2057 0 0 0 0 0 0 2058 0 0 0 0 0 0 2059 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0

+

2062 0 0 0 0 0 0 2063 0 0 0 0 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 423 191 0 81 666 1,361 2068 137 68 0 26 215 446 2069 32 280 0 0 6 318 2070 32 280 0 0 6 318 2071 32 280 0 0 6 318 2072 31 276 0 02 6 314 4 4-Total 89,115 45,689 1,966 107 41,379 178,256 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Ell-1583-003 Preliminary Decommissioning Cost Analysis Page 35 of 38 TABLE 6 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Site Restoration Allocation (thousands, 2007 dollars)

Equip & Yearly Year Labor Materials Enry Burial Other Totals 2013-2063 0 0 0 0 0 0 2064 143 0 0 0 0 143 2065 748 5 0 0 0 753 2066 2,290 86 0 0 0 2,376 2067 2,080 27 0 0 0 2,107 2068 950 132 7 0 0 1,088

- 2069 13,206 5,643 314 0 1 19,165 2070 13,206 5,643 314 0 1 19,165 2071 13,206 5, 643 314 0 1 19,165 2072 13,028 5,568 310 0 1 18,907 Total 1 58,857 1 22,748 1 1,260 0 4 82,869 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page 36 of 38 TABLE 7 Funding Requirements for License Termination 2013 Shutdown, 60-Year SAFSTOR Basis Year 2007 Fund Balance $347.20 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 2%

Cost Escalated at 0% (minus expenses)

Year (millions) (millions (millions) 2007 347.200 2008 354.144 2009 361.227 2010 368.451 2011 375.820 2012 383.337 2013 11.164 11.164 379.840 2014 49.271 49.271 338.165 2015 25.307 25.307 319.622 2016 3.711 3.711 322.303 2017 3.701 3.701 325.048 2018 3.701 3.701 327.848 2019 3.701 3.701 330.704 2020 3.711 3.711 333.607 2021 3.688 3.688 336.591 2022 3.676 3.676 339.647 2023 3.676 3.676 342.764 2024 3.686 3.686 345.933 2025 3.676 3.676 349.176 2026 3.676 3.676 352.484 2027 3.676 3.676 355.857 2028 3.686 3.686 359.288 2029 3.676 3.676 362.798 2030 3.676 3.676 366.378 2031 3.676 3.676 i 370.030 2032 3.686 3.686 373.744 2033 3.676 3.676 377.543 2034 3.676 3.676 381.418 TLG Services, Inc.

Indian PointEnergy Center, Unit2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Page 37 of 38 TABLE 7 (continued)

Funding Requirements for License Termination 2013 Shutdown, 60-Year SAFSTOR Basis Year 2007 Fund Balance $347.20 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 2%

Cost Escalated at 0% (minus expenses)

Year (millions) (millions) (millions)_

2035 '3.676 3.676 385.370 2036 3.686 3.686 389.392 2037 3.676 3.676 393.504 2038 3.676 3.676 397.698 2039 3.676 3.676 401.976 2040 3.686 3.686 406.329 2041 3.676 3.676 410.780 2042 3.676 3.676 415.319 2043 3.676 3.676 419.950 2044 3.686 3.686 424.663 2045 3.675 3.675 429.481 2046 3.668 3.668 434.403 2047 3.668 3.668 439.423 2048 3.678 3.678 444.533 2049 3.668 3.668 449.756 2050 3.668 3.668 455.083 2051 3.668 3.668 460.517 2052 3.678 3.678 466.049 2053 3.668 3.668 471.702 2054 3.668 3.668 477.468 2055 3.668 3.668 483.349 2056 3.678 3.678 489.338 2057 3.668 3.668 495.457 2058 3.668 3.668 501.698 2059 3.668 3.668 508.064 2060 3.678 3.678 514.547 2061 3.668 3.668 521.170 2062 3.668 3.668 527.926 TLG Services, Inc.

Indian PointEnergy Center, Unit 2 Document El1-1583-003 PreliminaryDecommissioning Cost Analysis Page38 of 38 TABLE 7 (continued)

Funding Requirements for License Termination 2013 Shutdown, 60-Year SAFSTOR Basis Year 2007 Fund Balance $347.20 (millions)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 2%

Cost Escalated at 0% (minus expenses)

Year millions) millions) (millions) 2063 3.668 3.668 534.816 2064 24.751 24.751 520.762 2065 55.625 55.625 475.552 2066 168.560 168.560 316.503 2067 71.834 71.834 250.999 2068 25.113 25.113 230.906 2069 6.046 6.046 229.478 2070 6.046 6.046 228.022 2071 6.046 6.046 226.536 2072 6.547 6.547 224.520 2073 26.485 26.485 202.525 659.355 659.355 Calculations:

Column B = (A)*(1+.00)A(current year - 2007) or for 0%, B = A Column C = (Previous year's fund balance) * (1 + .02) - B (current year's decommissioning expenditures)

TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Eli-1583-003 PreliminaryDecommissioning Cost Analysis Appendix A, Page 1 of 14 APPENDIX A 2007 DETAILED COST ANALYSIS TLG Services, Inc.

DoeuntentE1-1583-003 Indian Point Energy Center, Unit 2 Appendix A, Page2 of 14 Decommissioning Cost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommnissioning Cost Estimate (thousands of 2007 dollars)

I Off-Site LLRW NRC Spent Fuel Site Processed Bural Volumes Burial I Utility and Processing Disposal Other Total Toti Us. Term. Management Restotion Volue Class A Class B Ctass C GTCC Processed ' Craft Cantrator Dncon Removal Packaging Transport Coats Costs Costs Coats C,,- Feat C,,- Feet Cs. Feet Cu.-Foot C,,- Feet Wit, tn. Mootnh,,rMsnho,,rI A'tiorty Cost Coat Casts Costs Costs Costa Casts Continoeonv Costs ýora's Costs Costs Cu Feet Cu Feet Cu Feet Cu Feet Cu Feet Wt Lh- Ma-h-um d ex - I ý.... Cost osts Costs Cost. Costs Costs Conting-ey PERIOD Ia -Shutdown through Transition Period Ia Direct Decommissioning Activities la.1o1 SAFSTOR site characterization survey 493 148 641 641 928 l ai1.2 Prepare preliminarydecommissioning cost 61 9 70 70 la.1.3 Noblication of Cessation of Operations We it 1.4 Remove fuel &source material 1 .1 .5 Nolification of Permanent Defueling as.1,6 Deactivate plant systems & process waste 93 14 107 107 1.428 la.t.7 Prepare and submit PSDAR 61 9 70 70 928 1a.1.8 Review plant dwgs &specs.

la.1.9 Performdettsled rad survey a 47 77 54 54 714 la.t.t0 Estimate by-product inventtory 54 5 47 714 lath. 1,1 Endproduct description 70 10 80 80 1,071 la.1.12 Detaited by-product inventory 714 la.1.13 Define majororc sequence 47 7 54 54 144 22 166 166 2.213 ild.4 Portorn SER and EA 233 35 268 268 3,570 la.1.15 Perform Sito-Specibc Cost Study ActivitySpecifications 3.513 la.1.16.1 Prepare plant and facilities for SAFSTOR 229 34 263 263 194 29 223 223 2,975 la1.16.2 Plant systems 145 22 167 167 2,228 la.1.16.3 Plant structures and buildings 93 14 107 107 1,428 lai.116.4 Waste management 14 107 107 1,428 la.1.16.5 Facilityand site dormancy 93 755 113 868 868 11,572 la.1.6 Total Datailed Work Procedures 55 8 63 63 845 la.t.17.1 Plantsystems 56 8 64 64 857 1a.1.17.2 Facilitycloseout &dormancy 111 17 128 128 1,702 la.1.17 Total 5 1 5 5 71 la.1.18 Procure vacoum drying system lai11 Drain/de-eonrgize con-cant, systems a la.1.20 Drain &dry NSSS a la.1.21 Drainlde-energize contaminated systems la.1.22 DOcon/secora contaminated systems 2,164 398 2,562 2,562 25,625 lo. Subtotal Period ia ActivityCosts Period ta Additional Costs 87 202 350 1,783 1,783 6,880 89,440 11,698 1 a.2.1 Asbestos Abatement 1,144 0 1a.2 Subtotal Period 1a Additional Costs 87 202 350 1,783 1,783 6,880 89,440 11,698 1,144 6 Period 1i Callateral Costs la.3.1 Small tool allowance 19 - 3 22 22 t .. 3 Subtotal Period 1 a Collateral Costs 19 3 22 22 Period la Pedod-Dependent Costs la.4.I Insurance 1,051 105 1,156 1,156 1a.4.2 Property taxes 1a.4.3 Health physics supplies 553 -- 138 691 691 la.4.4 Heavy equipment rental 466 70 536 536

-25 12,190 S5 la.4.5 Disposal of DAWgenerated 7 40 40 610 1 a.4.6 Plant energy budget - 2,733 410 3,143 3.143 lad.7 NRC Fees 258 26 264 284 la.4.8 Emergency Planning Fees 981 98 1,079 - 1,079 TLG Services, Into.

Document El1-153l-003 Indian Point Energy Center, Unit 2 Appendix A, Page 3 of 14 DecommissioningCost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility snd Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume ClassA Class B Class C GTCC Processed Craft Contrastor index Activity Description Cost Cast Costs Cosost s ss Costost s ss Cooti encc Cosost s sts Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 1o Period-Dependent Costs (continued) ls4.9 Site OM& 2,848 427 3,275 3,275 lsa4.1O Spent Fuel Pool O&M 738 111 849 - 549 la.411 ISFSIOperating Costs 41 6 47 - 47 la.4.12 Groundwater Monitoring 51 8 59 59 ta.4. 3 Corporate A&G 1,862 279 2,141 2,141 1,648 247 1,895 1,898 46,678 1a.4.14 Security Staff Cost

- 22,005 3,301 25,306 25.306 - 423,400 l.a4.15 Utiity Staff Cost 2 28 34,217 5,233 40,500 38,526 1,974 610 12,190 5 470,078 la.4 Subtotal Period 1a Period-Dependent Costs 1,018 3 88 230 38,380 5,984 44,867 42.893 1,974 7.490 101.630 11,703 495.704 la.0 TOTAL PERIOD to COST 2,181 3 PERIOD lb - SAFSTOR Limited DECON Activities Period lb Direct Decommissioning Activities Decontamination of Site Buildings lb.1.1.1 Reactor Containment 1,594 797 2.391 2,391 - . - - - 22,977 -

Sb.1.1.2 Fuel Storage Building 506 203 759 759 - .- - - 6,818

, b.1.1 3 Maintainance &Outage Buiding 31 15 46 46 1 b.1.1A4 Primary AuxiliaryBuilding 219 109 328 328 - - - - 3,200 1 b.1.1.5 Waste Holdup Tank Pit 42 21 63 63 - -- . - 612 -

1b.1.1 Totals 2,391 1,196 3,587 3,587

- -- - - 34.0866 1b.1 Subtotal Peniod 1 b Activity Costs 2,391 1,196 3,587 3,587 Period lb Collateral Costs lb.3.1 Decon equipment 959 - 144 1,103 1,103 1 b.3.2 Process liquid maste 165 - 80 440 313 235 1,232 1,232 1,123 67,402 219 1b.3.3 Smal tool allowance - 50 8 58 58 Ib.3 Subtotal PeFod l b Collateral Costs 1,124 50 80 440 313 386 2,393 2,393 1,123 67.402 219 Period lb Period-Dependent Costs lb.4.1 Deounsupplies 713 - - 178 892 892 1b.4.2 Insurance 265 26 291 291 1 b.4.3 Property taxes -

1 b.4.4 Health physics supplies 284 71 355 355 10o4. Heavy equipment rental 117 - - 18 135 130 10b4.6 Disposal of DAWgenerated 2 1 21 - 6 30 30 467 9,349 4 1 4.7 Plant energy budget 689 103 792 792 10 4.8 NRC Fees 65 7 72 72 1 b.4.9 Emergency Planning Fees 247 25 272 - 272 1 b04.10 Site O&M 718 108 826 826 10.4.11 Speot Fuel Pool O&M 185 28 214 - 214 1b4.12 ISFSI Opealing Costs 10 2 12 - 12 lb.4.13 Groundwater Monitoring 13 2 15 15 10.4.14 Corporate A&G 469 70 540 540 1 b,4.15 Security Staff Cost 415 .. 62 478 478 11,765 lb.4.16 Utiity Staff Cost - - 5,547 . 832 6,379 6,379 - - 106,720 1 b.4 Subtotal Period 1 b Period-Dependent Costs 713 401 2 1 21 8,624 1,538 11,302 10,804 498 467 9,349 4 118,4B6 1b.0 TOTAL PERIOD 1b COST 4,229 451 82 442 334 8,624 3,119 17,261 16.784 498 1.591 76,751 34,288 118,486 TLG Sercices, Ine.

Document E11-1583-003 Indian Point Energy Center, Unit 2 Appendix A, Page4 of 14 Deeoemmisoioniog Cost Anialysi Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars) m Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burialt Utility and Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor flnort floor flnoet Cvest. Coots floeste tosrts fContinsoenc Coot. Coot. Cosrts floor C,, F.et Cu. C.t C. Foot fIJ, Faat C,,P.

F r he.

wt Marnhooue Manhtnlre.

Activity F t ..

m InQ*

R A*IVI* U*CrlD[LOn Cost .... ..... ..... ..... ........ ...osts Costs

. .. Cost

. ..... Cost ..

Cu.. eet C. .Fas.. Fee"t Inde ...... ..... ......

PERIOD tc -Preparations for SAFSTOR Dormancy Period 1c Direct Decommissioning Activities 73 552 552 3,000 1 c.1.1 Prepare support equipment for storage 480 1c.1.2 Installcontainment pressure equal, lines 8 y1 61 700 53 733 220 953 953 10.582 c.1.3 Interim survey prior to dormancy 1c.1.4 Secure building accesses 1c.1.5 Prepare &submit interim report 27 4 31 31 - 2- 416 tc.1 Subtotal Period 1 c ActivityCosts 533 760 304 1.596 1,596 - l,282 416 Period lc AdditionalCosts lc.2.1 Spent Fuel Pool Isolation 9,133 1,370 10,503 10,503 l c.2 Subtotal Period 1c AdditionalCosts 9,133 1,370 10,503 10,503 Period Ic Collateral Costs 351 263 1,382 1,382 1.260 75,615 246 lv.3.1 Process liquid waste 185 - 89 494 rc.3.2 Small tool allowance - 6 - - 1 7 7 1 v.3 Subtotal Period lc Collateral Costs 6 89 494 351 264 1.389 1,389 1,260 75,615 246 15 Period le Period-Dependent Costs lc,4.1 Insurance - 265 26 291 291 1c.4.2 Property taxes 1c.4.3 Health physics supplies 193 48 241 241 I c4.4 Heavy equipment rental 1l 135 135 1 7 z 10 10 154 3,073 1 1 c.4.5 Disposal of DAWgenerated 689 103 792 792 lv.4.6 Plant energy budgel 65 7 72 72 lc.4.7 NRC Fees lc.4.8 Emergency Planning Fees 247 2S 272 - 272 718 108 826 826 lcA.9 Site O&M 185 29 214 - 214 l c4.10 Spent Fuel Pool O&M I c,4.11 ISFS1Operating Costs 10 12 - 12 lc.4.12 Groundwater Monitoring 13 15 15 lc.4.13 Corporate A&G 469 T0 540 540 415 62 478 478 11,765 lC.4.14 Secutly Staff Cost lvc4.15 UtilityStaff Cost - 5.547 833 6,379 6,379 106,720 Ic4 Subtotal Period 1c Period-Dependent Costs - 310 1 0 7 8.624 1,332 10,275 9,778 498 154 3,073 1 118,486 lc.0 TOTALPERIOD lc COST 849 90 494 358 10,518 3,270 23,764 23,267 498 1,414 78,687 14,529 118,902 185 3,481 175 1,025 921 630523 12,374 85,913 82.943 2,970 10,494 257,068 60,520 733,091 PERIOD I TOTALS 4,414 PERIOD 2a -SAFSTOR Dormancy with Wet Spent Fuel Storage Period 2a Direct Decommissioning Activities 2a.1,1 Quarterly Inspection 2a.1.2 Semi-annual environmental survey 2a.t .3 Prepore reports 2a.1 .4 Bituminousroof replacement 134 20 154 154 2'.1.5 Maintenance supplies 786 197 983 983 2a.1 Subtotal Period 2a ActivityCosts 920 21? 1,137 1,137 Period 2. Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 45,666 6,850 52,516 - 52,516 2u.3 Subtotal Period 2a Collateral Costs 45,666 6,850 52,516 - 52,516 TLG Sereices,Ioe.

Document E11-1583-003 Indian PointEnergy Center, Unit 2 Appendix A, Page5 of 14 Decommissioning Cost Analysis Table A Indian Point Energy Center, Unit-2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Oft-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Removal Packaging Transport Processing Disposal Other Total Total Lic. Tenm. Managemeot Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Activity Decon Coot Costs Costs Costs Costs Costs Continoency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Fent Cu. Feet Wt.i Lbs. Manhours Manhours index Activi Descrition Cost Period 2a Period-oependenl Costs 2a:4.1 Insurance 3,783 378 4,161 3,771 390 Property Waxs - - - - -

2 .4.2 724 - - - 181 905 905 - - - - -

2a.4.3 Health physics supplies

- 12 8 117 - 32 168 168 - 2,581 51,612 20 2a.4.4 Disposal o of AW generated -

- 3.419 513 3,932 1,966 1,966 -

2a.4.5 Plant energy budget 2a.4.6 NRC Fees 1.349 135 1,4114 1,484 -

2a.4.7 Emergency Planning Fees 6:133 653 6,746 - 6746 2a.4.8 Site OM 2,155 323 2,478 549 1,929 2a.4.9 Spent Fuel Pool O&M 4,615 692 5.308 - 5,308 2a.4.10 ISFSIOperating Costs 257 39 295 - 295 2a.4.11 Groundwater Monitoring 319 48 367 367 -

2a.4,12 Corporate A&G 1,165 175 1.339 1,339 -

14,276 2,141 16.418 4,897 11,521 381,587 2a.4.13 Security Staff Cost 27,611 4,142 31.752 6,566 25,186 - 515,306 2a.4.14 UtilityStaff Cost 724 12 9 117 65,082 9,411 75.353 22,012 53,341 2,581 -1.612 20 896,893 2a.4 Subtotal Period 2a Pehod-Dependent Costs 724 12 8 117 111,668 16,478 129,006 23,149 105.857 2,581 51,612 20 896,893 2a.0 TOTALPERIOD 2. COST PERIOD 2b - SAFSTOR Dormancy with Dry Spent Fuel Storage Period 2b Direct Decommissioning Activities 2b.1.1 Quarterly Inspection 2b.1.2 Semi-annual environmental survey 2b.1,3 Prepare reports 2b.1.4 Bituminous reof reptacement 524 79 603 603 2b.1.5 Maintenance supplies 3,077 769 3,846 3,846 2b. 1 Subtotal Period 25 ActivityCosts 3.601 848 4,449 4,449 -

Period 20 Colatenal Costs 2b.3.1 Spent Fuel Capital and Transfer 5,713 857 6,570 - 6.570 2b.3 Subtotal Period 2b Collateral Costs 5,713 857 6,570 - 6,570 Period 20 Period-Dependent Costs 2b.4.1 Insurasce 13,736 1,374 15,110 14,758 352 2b.4.2 Propertly s- - - - - -

2b.4.3 Health physics supplies 2,375 594 2,968 2,968

- 43 29 425 - 115 612 612 9,406 188,114 74 2b.4.4 Disposal ofDAW generated Plant energy budget 6,691 1,004 7,694 7,694 - -

2b.4.5 2b.4.6 NRC Fees 5,278 528 5,806 5,806 -

2b.4.7 Emergency Planning Fees 17,771 1,777 19,548 - 19,548 2b.4.8 Site O&M 3,415 512 3,928 2,148 1,780 2b.4.9 ISFSIOperating Costs 1,009 151 1,106 - 1,156 2b.4.10 Grondwater Monitoring 1,248 187 1,435 1.435 -

2b.4.11 Corporte A&G 4,558 684 9,242 5,242 -

27,478 4,122 31,600 19,163 12,437 689,194 2b.4.12 Securty Staff Cost 43,660 6,549 50,210 25,696 24,514 816,823 2b64.13 Itility Staff Cost 2,375 43 29 425 124,841 17,596 145,309 85,522 59,787 9,406 198,114 74 1,506,017 2b.4 Subtotal Period 2b Period-Dependent Costs 2,375 43 29 425 134,155 19,300 156,327 89,971 66,356 9,406 188,114 74 1,506,017 2b.0 TOTAL PERIOD 2b COST PERIOD 2c - SAFSTOR Dormancy without Spent Fuel Storage Period 2c Dined Decommissioning Activities 2c.1.1 Quarverly Inspection 2c.1.2 Semi-annual environmental survey 2c.1.3 Prepare reports TLG Services, Ion.

Document El-1583-003 Indian Point Energy Center, Unit 2 Appendix A, Page6 of 14 DecommissioningCost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumn.s BurialI Utility and Transport Processing Disposal Other Total Total Lie. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Activity Decon Removal Packaging Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt.. Lbs. Manhouos Manhours Index Activity Description Cost Cost Costs 2c.1.4 Biturmjous roof replacement 396 59 455 455 2c3.5 Maintenance supplies 2,325 581 2,907 2,907 2,721 641 3,382 3,362 2c. Subtotal Period 2c Activiy Costs Period 2c Period-Dependenl Costs 2c4.1 inscrance 10,139 1,014 11,153 11,153 2c 4.2 Property taxes

- 1,686 - - 422 2,110 2,110 2c4.3 Health physics supplies 556 32 21 314 65 452 452 - - 6,947 - 138,939 2c.4.4 Disposal of DAWgenerated 2c.4.5 Plant energy budget - 5,057 758 5,815 5,815 2c,4.6 NRC Fees 3,989 399 4,388 4,388 2c.4.7 Site O&M 1,412 212 1.623 1,623 2c.4.8 Grundwaler Monitoring 943 142 1.085 1,085 2c4.9 Corporate A&G 3,445 517 3,961 3,961 12,594 1,889 14,483 14,483 289,371 2c4.10 Secupty Staff Cost 337,600 2c4.11 UtilityStaff Cost - 16,887 2,533 19,420 19,420 21 314 54,465 7,970 64,491 64,491 - - 6,947 138,939 55 626,971 2c4 Subtotal Period 2c Perod-Oepeodent Costs 1,688 32 32 21 314 .57,187 8.611 67,653 67,853 - 6,947 138,939 55 626,971 2c.0 TOTAL PERIOD 2. COST 1,688 87 59 856 303,009 44,389 353,186 180,972 172,213 18,933 378,665 150 3,029,881 PERIOD 2 TOTALS 4,786 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 61 9 70 70 - - - - 928 3o.1.1 Prepare preliminarydeoommissioning cost 214 32 246 246 3,2124 3a.1.2 Review plant dwgs &specs.

3a.1.3 Perform detailod rod s"'oep 7 54 47 7 54 714 3a.1.4 En6 product description 61 9 70 70 928 3a.1.5 Oetauiedby-produd inventory 349 52 402 402 5,355 3a.1.6 Define major work sequence 144 22 166 166 2,213 3..1.7 Perform SER and EA 233 35 268 268 3,570 3a.1.8 Perform Site-Specific Cost Study 191 29 219 219 2,925 3a.1.9 Prepare/submit License Termination Plan a

3..1.10 Receive NRC approval of termination plan ActivitySpecifications 343 51 395 355 39 5,262 3a.1.11.1 Ro-activate plant &temporary facilities 3a.1.11.2 Plant systems 194 29 223 201 22 2,975 331 50 380 365 5,069 3a.ll11.3 Reactor internals 303 45 348 348 4,641 3a. 1.11.4 Reactor vessel 3a 1.11.5 Biological shield 23 3 27 27 357 145 22 167 167 2,228 3a.1.11.6 Steam genorators 74 11 86 43 43 1,142 3a.l.l1.7 Reinforced concrete 3a.1.11.8 Main Turbine 19 3 21 - 21 286 19 3 21 - 21 2a6 3a.1.11.9 Main Condensers 145 22 167 54 84 2,228 3a.1.11.10 Plant structures & buildings 3a.1.11.11 Waste management 214 32 246 246 3,284 3a.1.11.12 Facility &site doseut 42 6 48 24 24 643 1,852 278 2,130 1,875 255 28,401 3a.1.11 Total Planning &Site Preparations 1,714 3a.1.12 Prepare dismanding sequence 112 17 129 129 3a.1.13 Plan' prep. &temp. svces 2,419 363 2,782 2,782 3a.1.14 Designwater dlean-up system 65 10 75 75 1,000 Rigging/Cont. Cntd Envtps/toolingleto. 2,048 307 2,355 2,355 3a.1.15 TLG Services, Ine.

Document E11-1583-003 Indian Point Energy Center, Unit 2 Appendix A, Page 7 of 14 t

Decommnivs ioning Coast Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

NRC Spent tuel Site Processed Bunal volumes Burial i Utirity anrt iff-ýtie LLRW Class B Class C GTCC Processed Craft Contractor Transport Processing . Disposal Other Total Total Lic. Term. Management Restoration Volume Class A I Activi Decon Removal Packaging A*t IVi* I ]eI*MNrlnR .......ngency Cost . .. .. . .

cos"ts .Cu... Ft.. .. ... .......... ......

I In*n*

In a Cast. Cost cost.... ..... ..... ..... .....

57 9 86 66 878 3a.1.16 Procure casks/liners & containers 51,910 3a.1 Subtotal Period 3a Activity Costs 7,852 1.178 9,030 8,775 255 Peorid 3a Additional Costs 3a.2.1 Site Characterization 2,218 665 2,183 2,883 3a.2 Subtotal Period 3a Additional Costs 2,216 665 2,683 2,883 Period is Pedod-Oependenl Costs 3a.4.1 Insurance - - - 546t 55 603 603 3a.4 2 Properly taxes 3a.4.3 Health physics supplies 436 109 54w 545 466 70 536 536 3a.44 Heavy equipment rental 4 2 23 - 6 33 33 - - 514 10,287 3a4.5 Disposal of DAWgenerated 3a.4.6 Plant energy budget 2,733 410 3,143 3,143 3a,4.7 NRC Fees 258 26 284 284 3a 4.8 Sit O&M 1,740 261 2,0f1 2.001 3a.4.9 GroUndwater Monitoring 51 8 59 59 3aA4.10 Corporate A&G 1,862 279 2,141 2,141 2,558 384 2,942 2,942 65,179 3a 4.1 1 Security Staff Cost 258.629

- - 14,994 2,249 17,243 17,243 -

3a.4.12 UtilityStaff Cost 901 23 24.745 3,856 29,530 29,530 - - 514 10,287 4 323,807 3a4 Subtotal Period 3a Period-Dependent Costs 2 2 901 2 23 34,815 5,700 41,443 41,188 255 514 10,287 4 375,717 3a.0 TOTAL PERIOD 3S COST PERIOD 31, - Decommissioning Preparations Period 3b Direct Decommissiooing Activities Detailed Work Procedures 3.379 336 50 387 348 39 3b.1 1.1 Plant systems t1,785 3b.l.1 2 Reactor inlemals 178 27 264 204 28 83 964 3ib.1.13 Remaining buildings 96 14 110 71 11 82 f2 714 3b. 1.1 A CRD cooling assembly 71 11 82 82 714 3b.1l1.5 CRD housings & ICltubes 71 11 82 82 714 3b.1.1.6 Incore instrumentation 258 39 297 297 2,592 3b.1.1.7 Reactor vessel 85 13 98 49 49 857 3b.1.1 8 Facility closeout 32 5 37 37 321 3b..t.f9 Missile shields 85 13 98 98 857 3b.1.1.10 Biological shield 327 49 376 376 3,284 3b.1.1.11 Steam generators 71 11 82 41 41 714 3b.1.1.12 Reinforced concrete 111 17 127 - 127 1,114 3b,1.1.13 Main Turbine 17 127 - 127 1,114 3b.1 1.14 Main Condensers 194 29 223 201 22 1,949 3b.1.1.15 Auxiliary building 194 29 223 201 22 1,949 3b.I.1.f16 Reactor building 2,291 344 2,635 2,124 511 23,022 3b.1.1 Total 2,291 344 2,635 2,124 - 511 - - - - - 23,022 3b.1 Subtotal Period 3b ActivityCosts Period 3b Additional Costs 3b.2.1 Staff relocations expenses 3,935 590 4,525 4,525 3b.2 Subtotal Period 3b Additional Costs 3,935 590 4,525 4,525 Period 3b Collateral Costs 3b.3,1 Decon equipment 959 - - 144 1,103 1,103 3b.3.2 Pros cutting equipment 957 143 1,100 1,100 3b.3 Subtotal Period 3b Collutoral Costs 959 .957 287 2,203 2,203 TLG Serrices,Inc.

Document EI1-1583-003 Indian PointEnergy Center,Unit 2 Appendix A, Page 8 of14 Decommnissioning Cost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Deconmmissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Foot Site Processed Burial Volumes Burial I Utility and Processing Disposal Other Total Total Lic. Tem. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Decon Removal Packaging Transport Acvity Activity Description Cost Cost Costs Costs Costs Casts Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhouts I Index Period 3b Period-Dependent Costs 30 - 7 37 37 3b4.1 Decon supplies 3b 42 Insurance 307 31 337 337 3043 Property taxes 3b.4.4 Health physics supplies 240 60 300 300 3b4.5 Heavy equipment rental 236 - 35 271 271 13 - 4 19 19 290 5,800 2 304.6 Disposal of DAWgenerated 3b.4.7 Plant energy budget 1,385 208 1.593 1,593 3b48 NRC Fees 131 13 144 144 3b.4.9 Site OM 1,223 183 11407 1,407 3b.4.1t Groundwater Monitoring 26 4 30 30 3h.4.11 Corporate A&G 944 142 1,085 1,085 1,297 194 1,491 1,491 33,036 3b.4.12 Security Staff Cost 11,102 1,685 12,768 12,768 181,829 3b.4.13 UtilityStaff Cost 476 13 18.415 2,547 19.483 19,483 290 5,800 2 214,864 3o.4 Subtotal Period 3b Period-Dependent Costs 30 989 1,433 13 22,640 3,768 28,845 28,334 511 290 5,800 2 237,886 3b.0 TOTAL PERIOD 3b COST 989 2.334 4 2 36 57,455 9,468 70,288 89,522 766 804 16,087 6 613,603 PERIOD 3 TOTALS PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 74 314 32 31 158 226 204 1,040 1,040 766 766 177,710 5,523 4a.1.t11 Reactor Coolant Piping 4a.t.1.2 Pressurizer Relief Tank 2 8 2 2 9 12 8 42 42 43 43 9,557 153 4a. 1.1.3 Reactor Coolant Pumps &Motors 28 123 53 214 170 1,135 391 2,115 2,115 336 4,324 1.274,302 3,631 11 76 354 556 - 617 ,297 1,911 1,911 - 2,349 258.971 1,805 -

4a.1.1.4 Pressurizer 4a.1.1.5 Steam Generators 95 4,780 1,955 3,067 2,175 4.279 3,294 19,645 19,645 37.344 16,301 3,111.893 20:108 2,850 4a.1.1.6 Retired Steam Generator Units - - 1.955 3,067 2,175 4,279 2,051 13,527 13,527 18,381 " 3,111.93 337,344 10,800 2,850 179 53 52 131 114 681 681 753 2,947 81,668 2,120 -

4a.1.1t.7 CRDMstlCtslSeroice Stmcture Removal 40 f1l 4a.1.1.8 Reactor Vessel Internals 61 2,444 3,674 513 - 3,178 146 4,521 14,536 140536 - 2,312 376 501 - 324.059 16,767 803 11,347 - 1,702 13,049 13.049 - - 496 104,146 - -

4a.1.1.9 Vessel & IntermalsGTCC Disposal - - -

6,008 902 439 - 6.382 148 8,054 21.931 21,931 - 6,481 2,955 - - 954,563 , 16,767 803 4a.1.1.10 Reactor Vessel-312 13.864 9,106 7,943 4,738 31,585 292 20.637 88,476 88.476 76,586 51,823 3,330 501 496 9.408,359 78,073 7,305 4a.1.1 Totols Removal of Major Equipment 4a.1.2 Main Turbine/Gonerator 500 236 55 692 261 1,743 1,743 4,374 371,814 7,141 4a.1.3 Main Condensers 1,914 141 45 560 583 3,243 3,243 6,687 300,932 27,443 Cascading Costs from Clean Building Demolition 234 1,791 1,791 - 14,977 4.,1.4.1 Reactor Containment 1,557 4a.1.4.2 Fuel Storage Building 47 7 54 54 422 4a.1.4.3 Primary AuxiliaryBuilding 76 11 88 88 758 4a.1.4.4 Turbine Buiding 892 104 796 796 7,864 4a.1.4.5 Waste HoldupTank Pit 14 2 16 16 . 142 4a.1.4 Totals 2.387 358 2,745 2.745 24,163 Disposal of Plant Systems 4a.1.5.1 Aoo Steam &Air Remova. 377 5 17 216 130 744 744 2,856 115,977 5,429 4a.1.5.2 Auo Steam &Air Removal (RCA) - 73 1 4 47 26 151 151 624 25,326 1,040 4a.1.5.3Aux Steam-Primary Plant 44 1 2 26 15 88 88 347 14,081 628 4a.1.5.4 Aux Steam-Primary Plant (RCA) - 65 1 3 33 22 123' 123 - 431 17,506 909 43 330 - 330 - - 4,420 4a.1.5.5 BearingCooling Water 287 4a.1.5.6 Chemical Cleaning 607 91 699 699 9,466 4a.1.5.7 Chemical Feed 10 1 11 11 155 TLG Services, Im.

Doenment El1.1583-003 Indian Point Energy Center, Unit2 AppendixA, Page9 of 14 DecommissioningCost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Activity Cost Cost Costs Cosost s ss Costost s ss Contin enc Costs Costs Costs Costs Cu. Fant Cu. Fost Cu. Faot Cu. Feet Cu. Foot Wt., Lbs. Manhours ManhoursI Index Activity Description Disposal of Plan( Systems (continued) 292 6 2 22 - 17 93 93 11,867 671 4a.1.5.8 Chemical Food (RCA) 52 4a.t.5.9 Chemistry Monitoring 3 O 0 1 5 1 5 5 7 1 384 45 4a.1.5.10 Circulabng & Service Water 1,548 65 244 3.051 888 6 ,796 5,796 40,386 1,640,086 22,748 66 2 9 ill 35 222 222 S- 1,464 59,459 967 4a.1 5.11 Circuloaing& Service Water (RCA) -

115 17 133 - 133 - 1,791 4a.1.5.12 Compressed Air 4a.1.5.13 Condensate 2,158 62 235 2,934 1,021 6,410 6,410 - 38,847 1,577,580 31,510 16 92 92 289 11,751 706 4a.1.5.14 Oeminereiizsr Regeneratlon 51 0 2 22 4a.1.5.15 Electro Hydraulic Fluid 0 0 5 3 18 18 71 2,899 127 4a.1.5.16 extraclionStlam 7089 21 80 999 341 2,150 2,150 13,226 537,096 10,471 1.104 45 91 625 321 . 468 2,654 2,654 8-,272 1,485 467,630 16,058 4a.1.5.17 Feeodater -

4a.1.5.18 Feedwater Emergency Make-Up 11 87 - 87 - 1,129 76 37 287 - 287 - - - - 3,663 4a,15.19 Flosh Evaprator 250 4a.1.5.20 HVAC- Clean 974 21 67 751 58 383 2,254 2,254 - 9,948 265 427,750 13,262 4a.1.5.21 Heating Soam &Condensate 233 2 9 117 78 440 440 1,555 63,162 3,337 4:.1.5.22 Heating Stlam &Condensate (RCA) 29 O 1 16 10 "57 57 209 8,489 411 4a.1.5.23 Hoating Steam &Condensate - FHB 105 1 3 39 32 179 179 S- 510 20,715 1,391 1 4 4 - - 57 4a.1 .5.24 Helium &Vacuum Drying 4 4a.1.5.25 Hypechiorita Feed - 1 0 1 15 25 193 - 193 - 2,430 4a.1.5.26 IP2 Petroleum Storage Tanks 168 4a.1.5.27 LP Heater Drains &Vents 729 10 37 458 257 1,491 1.491 - 6,067 246,398 10,548 15 18 - 18 - - 230 4a.1.5.28 Low LovonIntake Fish Screen Wash 2 4 47 4a.1.5.29 Low Level Vacuum Priming House 3 0 4 4a.1.5.30 Lube Oil 10 S 2 12 12 165 305 4a.1.5.31 Lube Oil Lines 20 3 23 23 38 8 3 - 3 4a.1.5.32 Main Gen Hydrogen Gas 3 4a.1.5.33 Main Stean 1,154 28 105 1,309 503 3,099 3,099 - 17,328 703,710 16,938 4a.1.5.34 Main Steam (RCA) 286 7 26 322 124 765 765 4,261 173,056 4,205 1 4 4 9 352 31 4a.l.5.35 Misr. Drains-Secondary Plant 2 0 0 1 4a.1 .5.36 Moisture Separator &HP HTR DR &V 1,577 58 219 2,739 844 5,437 5,437 - 36,260 1,472,533 23,061 I - 16 4a.1.5.37 Polymer Food I 0 1 -

6 4a.1.5.38 Rod MonilorCirc &Ser WIr 2 0 0 - 1 3 3 249 30 0 2 2 3 125 15 4a.1.5.39 Red MoniltorCont Particulate 1 0 0 0 14 110 110 - 1,467 4a.1 .5.40 River Water Filtration 96 4a.1.5 41 Serice Water Fuel Oil 21 3 24 24 307 4a.1.5 42 St Gen Fd Pmp Lube Oil & Seal Water 23 4 27 27 344 4a.1.5.43 Sloan GOnNitrogen Conn 9 1 10 - 10 - -- 140 4a.1.5 44 Steam Generator Siowdown 42 0 2 23 14 82 82 310 12,591 575 4aiS545 Stlam Generator Blowdown (RCA) 2 0 0 1 1 4 4 13 525 29 4a.1.5.46 SteaGenerator Blowdown Recrc & Xfer 403 3 12 148 125 691 691 S- 1,957 79,489 5,622 1 7 7 - 688 4a.1.5.47 Turbine Generator Seal Oil 6 4a.1.5A8 Turbine Gland Steam 45 7 52 52 715 4a.1.5.49 Vacuum Priming 1694 29 223 - 223 - 2,990 4a.1.5,50 Waste HoldupTank Pit 314 28 44 291 166 173 1,017 1,017 - 3,855 994 224,597 4,578 197 30 227 - 227 - - - 2,834 4a.1.5.51 Water Tank 4..1.5 Totals 14,273 363 1,214 14.307 546 5,853 36,556 34,071 2,485 189,404 2,744 - 7,915,381 208,356 4a.1.6 Scaffolding in support of decommissioning 511 8 3 32 5 - 135 695 695 S- 377 23 19,059 8,247 4a.1 Subtotal Period 4a Activity Costs 312 33,449 9,854 9,260 20,328 32,135 292 27,827 133,458 130,973 2,485 277,429 54,590 3.330 501 496 18,015,550 353,423 7,305 Period 4a Collateral Costs 20 110 78 56 299 299 - - 280 - - - 16,780 55 -

4:.3.1 Process liquid waste 36 -

4a.3.2 Small tool allowance 472 71 543 488 54 111 33 144 144 4a.3.3 Survey and Release of Scrap Metal 111 160 985 931 54 280 16,780 55 4a.3 Subtotal Period 4a Collateral Costs 36 472 20 110 78 TLG Services, Inn.

Document Eil-1583-003 Indian Point Energy Center, Unit 2 Appendix A, Page 10 of 14 DecommissioningCost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and i Off-Site LLRW Activity Decon 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 Cootinensy Costs Costs Costs Costs Cu. Feet Cu. Feet Co. Font Cu. Feet Cu. Feet Wt. Lbs. Manhours Manhours Period 4a Period-Dependent Cosls 4a41 Decon supplies 63 16 78 78 4a4.2 Insurance 646 65 711 711 4a.4.3 Property taxes 4..4A Health physics supplies 2,148 537 2,686 2,686 4..4.5 Heavy equipment rental 2,430 364 2,794 2,794

- 16 228 - 62 329 329 5,048 100,961 40 4a.4.6 Disposal of DAWgenerated 23 4a.4.7 Plant energy budg-t - 2,776 416 3.191 3,191 368 37 404 404 4a.4.8 NRC Fees 4a.4.9 Site O&M 3,073 461 3,534 3.534 4.A10 Radwaste Processing EquipmentvServices 397 60 457 457 54 8 63 63 4,4.11 Groundwater Monitoring 4s.4.12 Corporate A&- 1,990 298 2,288 2,288 2,733 410 3,143 3,143 69,643 4.4..13 Security Staff Cost 24,803 3,720 28,524 28,524 407,829 4,4.14 Utlity Staff Cost 4,578 6,454 48,201 48,201 - - 5,048 - - 100,961 40 477,471 4a.4 Subtotal Period 4a Period-Dependenl Costs 63 23 16 228 36,839 410 38,499 9,385 20,328 32,441 37,241 34.441 182,644 180,105 2,539 277.429 59,918 3,330 991 496 18,133,290 353,517 484,777 4..6 TOTALPERIOD 4a COST 9,897 PERIOD 4b -Site Decontamination Period 46 Direct Decommissioning Activities 60 158 71 562 442 1,812 1,812 2,565 230,191 1,001 4b.1.1 Remove spent fuel racks 519 Disposal of Plant Systems 36 80 693 192 416 2,410 2,410 9,177 959 451,542 14.292 4b.1.2.1 Borov Recovery 992 508 20 31 148 153 194 1,055 1,055 1,961 710 142,481 7,226 40.1.22 Cheorical &Volume Control 468 35 72 563 212 269 1,619 1,619 7,455 971 389,526 6,872 46.1.2.3 Component Cooling Water 64 119 714 489 599 3,365 3,365 9,452 2,236 584.390 19,968 4b.1.2.4 Component CootingWater (RCA) 1,380 109 5 7 39 32 43 235 235 519 147 34,230 1,972 40.1.2.5 Component CooingWaeter-FHB 1 3 38 38 205 205 501 - 20,360 1,774 4b.1.2.6 Compressed Air (RCA) 126 65 14 0 0 5 4 23 23 2.637 180 4b.1.2.7 Containment Hydrogen Analyzer (RCA) 4b,1.28 Containment Instrument Air 15 2 17 17 - - 233 4b.1.2.9 Containment Instrument Air (RCA) 0 1 10 7 42 42 - - 130 5,274 298 23 -

4b.1.2.10 Corlairmerl Sprny 28 215 - 215 2,790 187 2 107 60 348 348 - - 1,412 57,345 2,357 4b.1.2.11 Containrmor Spray (RCA) 170 9 46.1.2.12 Containmoen Vacuum & Leakage Monior 62 33 21 118 118 431 17,512 850 4b.1.2.13 Decontamination 1 19 10 60 60 - - 246 10,000 384 29 262 2,011 - 2,011 - 25,964 4b.1,2.14 Electrical - Clean Nov RCA -1.749 -

4b.1.2,15 Electrical -Clean RCA 2,991 46 165 2,058 1,066 6,345 6,345 - 27,243 1,106,350 42,545 4b.1.2.16 Electrical - Corlaminated 432 6 20 218 17 149 842 842 2,891 77 124,323 6.225 4b.1.2.17 Elecltcal - FHB 29 0 1 11 1 9 52 52 - 149 4 6,410 420 2 26 201 - - 2,619 4b.1.2.18 Fire Protecton &Domestic Wtoar 174 201 -

4b.1.2.19 Fire Protecton &Domeisc Water (RCA) 1S 3 33 13 81 81 - 431 17,501 448 32 14 31 247 89 113 683 683 3,273 408 169,518 2,720 4b.1.2.20 Fuel Pit (RCA) 189 S 4b.1.2.21 Fuel Pit- FH3 2 2 3 10 I0 54 54 38 47 5,790 363 27 4b.1.2,22 Gaseous W.ste Disposal 53 2 5 40 14 24 138 138 525 67 27,151 778 4b.1.2.23 Gaseous Wasle Disposal (RCA) 60 2 4 20 18 23 128 128 265 82 18,116 870 4b.1.2.24 Gaseos Waste Disposal - FHB 2 0 1 0 1 4 4 18 1 812 25 0

4b.1.2.25 HVAC- RCA (FH8) - 8 0 7 3 19 19 87 3,526 110 4b.1.2.26 HVAC- RCA (Other) 260 6 256 107 649 649 3,386 137,500 3,176 20 3 46.1.2 27 Hydraulic Fluid -Personnel Hatch 1 0 0 1 1 125 11 0

4b.1.2.28 Oxy9en (RCA) 0 1 1 5 5 19 767 36 2 0 4b.1.2 29 Rsdislion Monitoring 0 2 2 13 13 28 1,152 116 8 0 4b.1.2.30 Rediation Monitoring (RCA) 5 2 2 9 9 26 1,061 73 4b.1.2.31 Reactor Cavity Purification 30 4 8 24 23 121 121 106 108 13,973 814 60 4b.1.2.32 Reactor Coonant 22 35 121 201 132 737 737 1,607 920 147,766 3,319 226 TLG Servicea, Inc.

Document El1-1583-003 Indian Point Energy Center, Unit2 Appendix A, Page11 of 14 Decommissioning Cost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Sits Prosessed Burial Volumes Burial I Utility and Decon Removal Packaging Transport Processing Dispossi Other T=tot Total Lic. Term. Management Restoration Votlme Class A Class B Class C GTCC Processed Craft Contractor]

Activity Costs Costs Costs Ctstsiens Costs Cssts Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours endox Activity Description Cost Cast Disposal of Plant Systems (continued) 9,746 1,038 488,849 4,882 4b.1 2.33 Recirculating Spray

• 340 41 88 736 227 269 1,701 1,701 13 50 628 - 207 1,312 1,312 - 8,313 - 337,582 . 6,055 4b.1.2 34 Residual Heat Removal 414 -

39 299 - 299 4,011 4b.1.2.35 Safety Injetone 260 4 9 46 46 - 40 19" 3,369 449 4b.1.2.36 Sampling 30 1 1 3 14 26 131 131 23 63 6,598 1,301 4b.1.2.37 Sampling (RCA) 86 2 2 2 8 2 14 14 103 4,184 48 41b1.2.38 Service Air -Station Btack Out 3 5 1 33 - 24 135 , 135 442 - 17,945 1,031 4b.1.2.39 Vent & Drain 74 1 3 4 13 11 57 57 49 58 7,169 367 4b.1.2.40 Vevt & Drain (RCA) 27 1 2 12 17 58 96 76 418 418 762 458 70,158 2,271 4b.1,2.41 Waste Disposal 160 16 18 15 132 91 477 477 200 605 62,389 2,713 40.1.2.42 Waste Disposet (RCA) 205 3 34 - 21 122 122 448 - 18,194 854 4b.1.2.43 Waste Neutralization 63 1 356 799 6.917 1,939 4,453 26,516 23,775 2.743 91.572 8,978 4,513,573 173,408 4b.1.2 Totals 12.053 767 13 5 47 6 203 1,042 1,042 - 565 35 26,588 12,370 4b.1.3 Scaffolding insupport of decommissioning Decontamination of Site Buildings 938 43 138 233 543 1,138 4,448 4,448 3,084 10,190 921,883 32,755 4b.1.4.1 Reactor Containment 1,415

- 275 - 406 188 1,091 1,091 - 15.633 1,563,309 1,796 4b.1,.4.2 Discharge Canal 151 72 14 145 27 376 1,504 1,504 1,924 647 141,972 13,098 4b.1 .4.3 Fuel Storage Building 445 490 8 3 0 3 17 55 55 S- 119 11,909 483 4bt.4.4 Maintainance & Outage Building 31 1

- 36 137 - 203 78 466 466 - 7,803 780,300 173 4b.1 4.5 Petroleum Tank Excavation 12 10 33 57 153 564 564 434 2,122 229,089 4,203 4b.1.4.6 Primary AuxiliaryBuilding 226 75 11 402 909 431 1,655 - 2.448 1,332 7,177 7,177 - 94,163 9,416,250 16,710 4b.1,4,7 Turbine Building 12 2 2 4 11 28 102 102 54 404 42,501 770 4b.1.4.8 Waste Holdup Tank Pit 43 602 2,231 415 3,699 3,310 15,407 15,407 - 5,496 131,080 13,107,200 69,989 4b1.4 Totals 2,581 2,589 15,468 1,130 3,106 7,379 6,207 8,407 44,779 42,036 2.743 97,633 142,659 17,879,560 256,768 4b.1 Subtotal Period 4b Activity Costs 3,081 Period 41bAdditional Costs 6,240 4b1,21 Final Site Survey Program Management - 652 196 848 a48 647 103 86 663 298 1,800 - 3,189 382,518 8.165 1,280 4b.2.2 ISFS5 License Termination 2 285 93 622 1,781 - 619 3.399 3.399 99.394 10.436,000 2,331 4b.2.3 AOC PCBSoil Remediation 7 323 643 - 228 1,272 1,272 24,481 1,860,556 604 4b.2.4 AOC Soil Remediation 72 1,800 2,509 1,315 1,341 7.318 5,518 127.064 12,679,070 11,100 7,520 4b.2 Subtotal Period 41bAdditional Costs 1,004 101 1,048 Period 4b Collateral Costs 68 - 38 209 148 - 106 569 569 533 31,991 104 4b.3.1 Process liquid waste 4b.3.2 Small tool atowance 390 59 449 449 135 59 502 82 - 118 896 896 6,000 373 303,507 88 4b.3.3 Decommissioning Equipment Disposition 45.3.4 Survey and Release of Scrap Metal - . - 894 268 1,162 1.162 502 230 894 551 3,077 3,077 6,000 907 335,498 - 192 4b.3 Subtotal Period 4rb Collateral Costs 66 390 173 268 Period 4b Period-Dependent Costs 4b.4.1 Dacwn supplies 775 - 194 969 969 4b.4.2 Insurance 789 79 868 868 4b.4.3 Property taxes 4b.4.4 Health physics supplies 1,806 452 2,258 2,258 4b.4.5 Heavy equipment rental 2,943- 441 3,3a4 3,384 40.4.6 Disposal sf DAWgenerated 17 12 173 - 47 248 248 3,817 76,334 30 4b.4.7 Plant energy budget 2,674 401 3,075 3,075 4b.4.8 NRC Fees 449 45 493 493 4b.4.9 Sits O&M 2,541 381 2,922 2,922 4b.4.10 Radwaste Processing EqaipmenoSeices 485 73 557 557 4b.4.11 Grousdwatcr Monitoring 67 10 76 76 4b.4.12 Curporate A&G 2,428 364 2,793 2.793 1,032 155 1,187 1,187 29,240 4b.4.13 Security Staff Cost TLG Services, Inc.

Docurment E11-1583-003 Indian PointEnergy Center,Unit 2 Appendix A, Page 12 of 14 Decommissioning Cost Anotlyis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Decon Remonal Packaging Transport Processing Disposal Other Total Total LiU, Tesm. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor e

Inden Activito Description Cost Cost Costs Cos Cos ts Cos tos Costs Contincec Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 4b Period-Dependenl Costs (continued)

- - - - - 19,535 2,930 22,485 22,485 - - 337,280 44b..14 UtilityStaff Cost 4,749 17 12 173 29.9999 5,571 41,297 41,297 - 3,817 76,334 30 366,520 4b.4 Subtotal Period 4b Period-Dependent Costs 775 3,924 21,612 1,421 4.435 7,882 9,119 32,208 15,870 96,470 91,928 1,800 2,743 103,633 274,446 30,970,460 268,090 374,040 4b.0 TOTALPERIOD 41 COST PERIOD 4d -Delay before License Termination Period4d Period-Dependent Costs 4d.4.1 Insuranco - - - - - - -

4d.4.2 Propertytaxes 4d.4.3 Health physics supplies 60 - - - 15 74 74 3 - 1 4 4 66 1.322 1 -

4d.4.4 Disposal of DAWgenerated 4d.4.5 Plant energy budget 181 27 208 208 4d4.6 NRC Fees 143 14 157 157 4d.47 Site O&M 73 11 84 84 4d.4.8 Groundwater Moniolorsg 34 5 39 39 4d.4.9 CorposatoA&G 1,235 185 1,420 1,420 8 1 9 9 4,149 4d.4,10 Security Staff Cost 4d.4.11 UtilityStaff Cost - - 506 76 582 582 - 9,680 4d.4 Subtotal Period 4d Period-Dependent Costs 60 8 3 2,179 335 2,578 2,578 66 1,322 1 13,829 4d.0 TOTAL PERIOD 4d COST 50 0 0 3 2,179 335 2,578 2,578 66 1,322 1 13,829 PERIOD 4e- License Termination Period 4e Direct Decommissianing Actiilties 4e.1.1 ORISE confltrntory survey 152 46 198 198 4e.1.2 Terminate license 4e.1 Subtotal Period 4e ActivityCosts 152 46 198 198 Period 4e Additional Costs 4a,2.1 Final Sitl Survey 7.880 2,364 10,243 10,243 113,935 3,120 4e.2.2 Staff relocations expenses 3,935 590 4,525 4,525 11,814 2,954 14,768 14,768 113,935 3,120 4e.2 Subtotal Period 4a Additional Costs Period 4e Perod-Dependent Costs 4o.4.1 Insuranco 4..4.2 Property taxes 4e.4.3 Health physics supplies 817 - - - 204 1.021 1,021 4a.4.4 Disposal of DAW generated - 2 1 15 - 4 21 21 330 6.603 3 4e.4.5 Plant energy budget 412 62 474 474 4e.4.6 NRC Fees 259 26 285 285 4.4.7 Site O&M 719 1098 827 827 4e.4.

A Grondwater Monitoring 38 6 44 44 4e4.9 Corporat.A& 1,403 210 1,613 1,613 4e.4.10 Security Staff Cost 476 71 548 548 11.786 4o.4.11 UtilityStaff Cost - 6,319 948 7,267 7,267 95,494 4e.4 Subtotal Period 4e Perod-Dependenl Costs 817 2 1 15 9,827 1,639 12,100 12,100 330 6,603 3 107,250 4e.0 TOTAL PERIOD 4. COST 817 2 1 15 21.594 4,639 27,067 27,067 330 6,603 113,938 110,370 PERIOD 4 TOTALS 4,334 60,988 11,320 13,821 28,209 41,578 93,223 55,286 308.759 301,677 1,800 5.282 381.062 334,761 3,330 501 496 49,111,670 735,546 983,015 TLG Services, Inr.

Docment El1-1583-003 Indian PointEnergy Center, Unit2 Appendix A, Page 13 of 14 Decomeisiuoining Cost Analysis Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommirssioning Cost Estimate (thousonds of 2007 dollars)

E LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Off-Site Class C GTCC Processed Craft Contractor Decor Remooat Psclaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B IActivity toots tests Costo tu Feat Cu. Feat CuoFot C, Feet to. Fit Wt. Lbs. Uaohoum MunhoomU Cost Cot Coots tosto toots Costs CostF Contineono tosto Lbs. Uarthours;Uanhoum I IN*X A*t IVI* u*scno[lon Costs Costs Costs Costs Costs Contingency Costs Costs Cast. Costs Cu Fast Cu Fast Cu Fast Cu isat Ind.. -norv u...11 oun PERIOD Sb- Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 1,325 10,158 - 10,158 114,987 5b.1.1.1 Reactor Containment 8,833 5 1 5 50 51b1.12 Buried Fuel Oil Tanks 4 4 30 30 335 5b1.1.3 Control Building 26 21 160 160 1,688 5b1.1.4 Diesel Generator Building 139 184 1.487 5b.1.1.5 Electrical Penetrations Building 160 24 184 50 58 507 5bt1.1.6 Electrical Tunnel &Retaining Walls 8 58 5 41 41 325 51b.11.7 Equipment Hatch Enclosure 36 1682 27 209 209 1,656 5b.1.1.8 Fan House 47 363 363 3,147 5b,1.1.9 Fuel Storage Building 316 5b.1.1.10 Maintainance &Outage Building 42 320 320 3,353 -

279 795 6,097 6,097 57,848 b.t..l 11 Misc Structures 5,302 2 17 17 154 51b.11 2 Petroleum Tank Excavation 15 107 820 820 7,190 5b.1.1.13 Primary AuxtiaLryBuslding 713 5b.1.1.14 Screenwelt Structure 184 1,412 1,412 9,322 1,228 5b 1.1.l5 Steam Generator Storage Facility 106 816 816 7,951 709 23 179 179 1,814 51b.11.16 Tank Pads & Foundations 156 1,382 51..1.1.7 Transformer Pad 119 18 137 137 122 936 936 9,792 S lS.1.16 Turbine Building 814 1,254 1.091 164 1,254 8,915 5b.1.1.19 Turbine Pedestal 5b.1.1.20 Waste Holdup Tank Pit 81 12 93 93 806 5b.1.1.21 Water Tank and Meter House 4. 30 30 281 26 3.042 23,320 23,320 202,992 5b.I.1 Totals 20,278 Site Closeout Activities 634 4,860 4,860 10,846 51.1.2 BackFill Site 4,226 8 1 0 - 27 5S.1.3 Grade & landscape site 7

- 111 17 127 127 5b.1.4 Final repeI to NRC 21 - 6 1,114 1,114 3,693 28,315 127 28,188 - - 213,864 5b.1 Subtotal Period 5b Activity Costs 24.511 Period 5b Additional Costs - 563 5b2.1 Concrete Crushing 486 3 73 563 - 2,031 5b.2.2 ISF15 Demolition and Restoration 1,086 22 166 1.274 - 1,274 - - 1,590 80 5b.2.3 Unit 1 Legacy Soil Remediation 586 68 3,379 6,698 2.335 13,066 13,066 255,173 19,494.000 5,12 5b.2 Subtotal Period 5b Additional Costs 2,158 68 3,379 6,698 25 2,574 14,903 13,066 1,274 563 255,173 - 19,464,000 8,749 80 Penod 5b Collateral Costs Sc3.1 Small tool allomance 338 50 387 - 387 387 5b.3 Subtotal Period 5b Collateral Costs 336 50 387 Period 5b Period-Dependent Costs 5b.4.1 insurance 51b.42 Property taxes 5b.4.3 Heavy equipment rental 9,291 1,394 10,604 10,6a4 5b.4.4 Plant energy budget 1,096 164 1,260 1.260 Sb.4.6 Site O&M 1,935 290 2,225 2,225 5b.4.6 Groindwater Monitorng 204 31 235 235 51b.4. Corporate A&G 7,464 1,120 8,583 6,583 5b.4.8 Security Staff Cost 2,276 341 2,617 - 2,617 55,427 5b4.9 UtilityStaff Cost 28,802 4,320 33,122 - 33,122 426,360

- 41,777 7.660 58,727 11,044 47,684 481,787 5b4. Subtotal Period 5b Period-Dependent Costs 9,291 5o.0 TOTAL PERIOD 5b COST 6B 3,379 6,698 41,913 13,979 102,332 24,237 1,274 76,821 255,173 19,494,000 222,613 482,981 36,296 TLG Services, IJe.

Indian Point Energy Center, Unit 2 Dosesment E1l-1583-003 Decommissioning Cost Analysis Appendix A, Page 14 of14 Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Aclivity Decon Removal Packaging Transport Processing Disposal Other Total Total Lc. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor index ActivitDescri tin Cost Cst Costs Costs Costs Costs Costs Contingency Costs Costs Costs Cssts Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Maohours PERIOD 5 TOTALS - 36,296 68 3,379 - 6,698 41,913 13,978 102,332 24,237 1,274 76,821 - 255,173 - - - 19,494,000 222,613 482,981 TOTALCOST TO DECOMMISSION 9,737 107,885 11,653 18,286 28,209 50,090 559,122 135,494 920,477 659,351 178,257 82,869 381,062 620,166 3,330 501 496 69,257,500 1,018,835 5,842.571 TOTALCOST TO DECOMMISSIONWITH 17.26% CONTINGENCY: $920,477 thousands of 2007 dollars TOTALNRC LICENSE TERMINATIONCOST IS 71.63% OR: $659,351 thousands of 2007 dollars SPENT FUEL MANAGEMENTCOST IS 19.37% OR: $178,256 thousands of 2007 dollars NON-NUCLEARDEMOLITIONCOST IS9% OR: $82,869 thousands of 2007 dollars TOTALLOW-LEVELRADIOACTIVEWASTE VOLUMEBURIED (EXCLUDING GTCC): 623,997 cubic fast TOTALGREATER THANCLASS C RADWASTE VOLUMEGENERATED: 496 cubic feet TOTALSCRAP METAL REMOVED: 37,492 tnns TOTALCRAFT LABOR REQUIREMENTS: 1,018,835 mfn-booms End Notes:

n/a - indicates that this acticity nol changed as decommissioning expense.

a - indicates that this alivily performed by decommissioning staff.

0 - indicales that Ibis value is less than 0.5 but is non-zero.

a crll containing - . indicates a -erovalue TLG Sercices, Inc.