Text

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)
	v • d • e

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 to NL-08-144 Unit No. 1 and 2 10 CFR 50.54(bb) Program for Irradiated Fuel Maintenance of 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 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 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 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 Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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 I I 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 Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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 2004 0

0 0

0 2005 0

0 0

0 2006 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

Ent ergy Nuclear Northeast Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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 Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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 2044 1,577 1,581 201 202 0

0 0

0 933 936 2,711 2,718

Eritergy Nuclear Northeast Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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 2047 0

0 0

0 2048 0

0 0

0 2049 0

0 0

0

___0 0

2050 0

0 0

0 2051 0

0 0

0 2052 0

0 0

0 2053 0

0 0

0 2054 0

0 0

0 2055 0

0 0

0 2056 0

0 0

0 2057 0

0 0

0-0 0

2058 0

0 0

0 2059 0

0 0

0 2060 0

0 0

0 2061 0

0 0

0 2062 0

0 0

0 2063 0

0 0

0 2064 0

0 0

0 2065 0

0 0

0 2066 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 Indian Point Energy Center, Units I and 2 Letter Number: NL-08-144 DOCKET NOS. 50-3 & 50-247 TABLE 5 Indian Point Energy Center, Unit 2 Significant Cost Contributors SpentFuel Management - Direct Expenditures Spent Fuel Transfer Facility.

Capital Costs of ISFSI MPCs and Overpack

'M P C Li oadaing -Costs..........................

MPC Transfer. Costs from Pool to DOE MPC Transfer Costs from Pool to ISFSI C T ransf.-er C.osts from IF..i. o DOE

........ (

7...

..........0do

.ars _*

1,884,954 35,711,J3-33

............ J,179,417 3,042,034 3.,96....

9838,

, 9 Total 59,085,429_1

Contingency has been added to all costs (15%)

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

Fuel Transfer Pool to DOE Loading Pool to DOE Transfer ISFSI Cask Costs Pool to ISFSI Loading Pool to ISFSI Transfer ISFSI to DOE Transfer Total

($2007)

Year w

2013 0

-0 0

0l 0

0 0

0 2014 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 2020 0

649,750 471,239 0

0 0

~

0 1,120,989

..2 0..............................

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

--,.2.....

3 *.. 2 P. _ *.............

.R.

2021 0

866,333 628,318 0

0 0

0 1,494,651 2023 0

0 0

0 314,159 314,159 2024 0

0 0

0[

157,080 157,080 2025 0

0 0

0 157,080 157,080 2026 0

0 0

0 157,080 157,080 2027 0

0 0

0 235,619 0___

2028.

0.

.0 0

0 0

0.

035 235,619 2029 0

0 0

0, 235,619 235,619 12030 0

0 0

oF 0

0 2031 0

0 0

0 157,080 157,080 20.......

2p3 0......

0 0 o o J 0..

.o..

0.........

{2032 0

0 0

0~

0 0

20o33 0

0 0

00 9L[157,080 157,080 2038 0

0 0

0 0O0 0

0

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

2039 0

0 0

0 235,619 235,619 2040 2041 0

0 0

0 2

._4........................................

2043 0

0 0

0 235,619 0

235,619 0

157,08Q 863,937 0

0 0

0 0-Q 157,080

-0 863,937 4 ------

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

......... 2,81..5,5. 83..........

2.04.2.,...34..

35,71 1,333. 7,363,833 1 5,340,703.

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 Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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]

[2]

[31 Extended use to support Indian Point 3 fuel transfer ISFSI operational until Indian Point 3 fuel transfer complete ISFSI decontaminated and dismantled in conjunction with decommissioning of the three nuclear units on site

Entergy Nuclear Northeast Indian Point Energy Center, Units I and 2 Letter Number: NL-08-144 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 0.00%

Annual Earnings F 2.00%}11 I

Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 A

B C

D E

F G

IP-1 License Termination Cost Estimate (millions)

$105.900 million spent and budgeted through 3rd quarter of 2013 funded by operations 1.059 4.236 4.236 2.656 IP-2

License, Termination Cost Estimate (millions) 11.164 49.271 25.307 3.711 IP-1 Spent Fuel Cost Estimate (millions)

$12.917 million spent and budgeted through 3 rd quarter of 2013 funded by operations 0.335 1.339 1.339 IP-2 Spent Fuel Cost Estimate (millions)

Total Cost Estimate (millions)

Total Cost Escalated at 0%

(millions) 0.514 1.974 13.279 16.971 16.924 13.07 56.82 44.16 23.34 23.27 13.072 56.820 44.161 23.338 23.274 Decommissioning Trust Fund Escalated at 2%

(minus expenses)

(millions) 618.383 630.751 643.366 656.233 669.358 682.745 618.383 630.751 643.366 656.233 669.358 682.745 683.328 640.174 608.817 597.655 586.334 574.787 563.008 550.931 545.892 547.774 549.694 551.627 553.624 555.660 557.738 559.832 561.993 564.197 566.445 2.649 2.649 3.701 3.701 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2.649 2.656 2.649 2.649 2.649 2.656 2.649 2.649 2.649 2.656 2.649 2.649 2.649 3.701 3.711 3.688 3.676 3.676 3.686 3.676 3.676 3.676 3.686 3.676 3.676 3.676 16.924 16.924 16.971 9.720 2.711 2.711 2.718 2.711 2.711 2.711 2.718 2.711 2.711 2.711 23.27 23.27 23.34 16.06 9.04 9.04 9.06 9.04 9.04 9.04 9.06 9.04 23.274 23.274 23.338 16.057 9.036 9.036 9.060 9.036 9.036 9.036 9.060 9.036 9.036 9.036 2030 2031 9.04 9.04

Entergy Nuclear Northeast Indian Point Energy Center, Units I and 2 Letter Number: NL-08-144 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) 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 2060 2061 2062 1.831

___1.826 3.668 3.678 3.668 5.49 5.51 5.49 5.49 5.494 5.509 5.494 5.494 707.999 716.650 725.489 734.505 1.826 3.668

Entergy Nuclear Northeast Indian Point Energy Center, Units 1 and 2 Letter Number: NL-08-144 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) 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 37.885 441.55 659.36 301121 178.26 103.087 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) 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 prepared for Entergy Nuclear prepared by TLG Services, Inc.

Bridgewater, Connecticut October 2008

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis APPROVALS Document Eli-1583-004 Page ii of v 64,4L al 6?n-,I Q-C Project Manager Project Engineer Technical Manager Quality Assurance Manager William A. Cloutier, Jr.

Thomas JYGarrett Geoffrey Griffitliub

/a

°o=

Date

/10ate Date Date/

i D aeZ L t

Dalte TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning Cost Analysis Page iii of v TABLE OF CONTENTS SECTION PAGE

1.

DECOMMISSIONING COST ANALYSIS............................................................

1 1.1 Decommissioning Alternatives......................................................................

2 1.2 Regulatory Guidance.......................................................................................

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 R isk.......................................................................................

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 R elease 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 U L T S.................................................

I................................................................. 2 1 2.1 Decommissioning Trust Fund........................................................................

22 2.2 Financial A ssurance.......................................................................................

23 FIGURE 1

SAFSTOR Decommissioning Timeline...........................................................

23 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis Document Ell-1583-004 Page iv of v TABLE OF CONTENTS SECTION PAGE TABLES 1

2 3

4 5

6 7

Low-Level Radioactive W aste Disposition.......................................................

24 Summary of M ajor Cost Contributors............................................................ 25 Schedule of Annual Expenditures, Total Decommissioning Cost................. 26 Schedule of Annual Expenditures, License Termination Allocation............. 29 Schedule of Annual Expenditures, Spent Fuel Management Allocation.....

32 Schedule of Annual Expenditures, Site Restoration Allocation.................... 33 Funding Requirements for License Termination............................................ 34 APPENDIX A.

2007 Detailed Cost Analysis............................................................................

A-1 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis REVISION LOG Document Ell-1583-004 Page v of v Noo.CRA No.

Date,,

iie-Item Revised Reason for Revision 0

10-22-2008 Original TLG Services, Inc.

Indian Point Energy Center, Unit 1 Document El-1i583-004 Preliminary Decommissioning Cost Analysis Page 1 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 Point Energy Center, Unit 1 Document Eli-1583-004 Preliminary Decommissioning Cost Analysis Page 2 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 Point Energy Center, Unit 1 Document El-1i583-004 Preliminary Decommissioning 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 decontamination) to levels that permit release for unrestricted use."[51 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 Point Energy Center, Unit 1 Document E1l-1583-004 Preliminary Decommissioning 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.

Indian Point Energy Center, Unit I Document E1l-1583-004 Preliminary Decommissioning Cost Analysis Page 5 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 Preliminary Decommissioning 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.

Indian Point Energy Center, Unit 1 Document El-1i583-004 Preliminary Decommissioning 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 Preliminary Decommissioning 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 Point Energy Center, Unit I Document E1l-1583-004 Preliminary Decommissioning 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 Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning 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 Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning Cost 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 Preliminary Decommissioning Cost 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.

Indian Point Energy Center, Unit I Document E1l-1583-004 Preliminary Decommissioning 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, 90Sr, 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 Point Energy Center, Unit 1 Document Ell-1583-004 Preliminary Decommissioning Cost 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.

Indian Point Energy Center, Unit 1 Document El-1i583-004 Preliminary Decommissioning 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 Point Energy Center, Unit 1 Document Ell-1583-004 Preliminary Decommissioning Cost Analysis Page 16 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 and commitments for the site.[241 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 As indicated by the IPEC Groundwater Investigation Project,[261 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 Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning 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 Point Energy Center, Unit 1 Document Ell-1583-004 Preliminary Decommissioning 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.

Indian Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning 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 Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning Cost Analysis Page 20 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 Point Energy Center, Unit 1 Document E1l-1583-004 Preliminary Decommissioning Cost Analysis Page 21 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 Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning Cost Analysis Page 22 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 Point Energy Center, Unit 1 Document El1-1583-004 Preliminary Decommissioning Cost Analysis Page 23 of 36 FIGUREI1 SAFSTOR DECOMMISSIONING TIMELINE (not to scale)

IP-1 Shutdown: October 31, 1974 Period 2 Safe-Storage Period 4 Period 3 Decommissioning Preparations I Operations Period 5 Site Remediation 12/2045 06/2066 6

06/2067 09/2069 09/2073 License Terminated ISFSI Construction Canister and overpack fabrication Fuel to ISFSI 09/2013 IP-2 Shutdown 09/2008 Storage Pool Empty ISFSI Operations All Spent Fuel Off Site TLG Services, Inc.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis Document El1-1583-004 Page 24 of 36 TABLE 1 Indian Point Energy Center, Unit 1 Low-Level Radioactive Waste Disposition Waste Cost Bas Low-Level Radioactive Waste

.(near-surface disposal Greater than Class C

_Agologicrepository)

Processed/Conditioned foff-site recych'ng center) __

Total [2]

EnerUyolu Barnwe.

Barnwe Spent Fu Equivale Recyclin Vendor Waste Volume Mass is I_Class_[1.

(cubic feet)

(pounds tions A

2,296,075 196,605,692 11 B

1,740 176,728 11 C

115

1.

10,390 el nt GTCC 471 19,440 9

s A

157,755 6,559,670

[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.

Indian Point Energy Center, Unit 1 Document Ell-1583-004 Preliminary Decommissioning Cost Analysis Page 25 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 Preliminary Decommissioning Cost Analysis TABLE 3 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Total Decommissioning Cost (thousands, 2007 dollars)

Document Ell-1583-004 Page 26 of 36 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 Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis TABLE 3 (continued)

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

Document Ell-1583-004 Page 27 of 36 Equip &

Materials Year Labor Energy 227 Burial 21 Other 1.672 Yearly Totals 2.649 2035 460 270 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 2049 2050 2051 461 460 460 460 270 270 270 270 2052 2053 2054 2055 2056 2057 2058 2059 461 460 460 460 461 460 460 460 270 270 270 270 270 270 270 270 270 270 270 270 270 270 227 227 227 227 227 227 227 227 227 21 21 21 21 852 849 849 849 852 849 849 849 1,831 1,826 1,826 1,826 1,831 1,826 1,826 1,826 21 21 21 21 21 1,831 227 21 227 21 849 849 227 21 1ý-

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

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis TABLE 3 (continued)

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

Document Eli-1583-004 Page 28 of 36 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 Preliminary Decommissioning Cost Analysis TABLE 4 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures License Termination Allocation (thousands, 2007 dollars)

Document Ell-i1583-004 Page 29 of 36 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 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

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 Preliminary Decommissioning Cost Analysis TABLE 4 (continued)

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

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

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

Document E1l-1583-004 Page 31 of 36 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 Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis TABLE 5 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Document E1l-1583-004 Page 32 of 36 Equip &

Yearly Year Labor Materials Energy Burial Other

Totals 2001-2003 0

0 0

0 2004 0

0 0

0 2005 0

0 0

0 2006 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 Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis TABLE 6 Indian Point Energy Center, Unit 1 Schedule of Annual Expenditures Site Restoration Allocation (thousands, 2007 dollars)

Document Ell-1583-004 Page 33 of 36 Equip &

Yearly Year Labor Materials Energy Burial Other Totals 2001-2065 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 Total 11,764 15,347 431 0

0.85 27,543 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis Document Eli-1583-004 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 2026 2.649 2.649 2.649 2.649 2.649 346.518 350.799 355.166 2027 2028 2.649 2.656 L-2.656 1

359.613 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis Document Ell-1583-004 Page 35 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 2056 1.826 1.831 1.826 1 529.200 1.831 537.953 TLG Services, Inc.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis Document El-1i583-004 Page 36 of 36 TABLE 7 (continued)

Funding Requirements for License Termination Coordinated with IP-2 2013 Shutdown and 60-Year SAFSTOR Basis Year Fund Balance Annual Escalation Annual Earnings A

Year 2057 2058 2059 2060 2061 License Termination Cost (millions) 1.826 1.826 1.826 1.831 1.826 1.826 1.826 1.831 1.826 18.899 68.313 148.490 17.216 17.216 2007

$271.186 0.00%

2.00%

B Escalated License Termination Cost Escalated at 0%

...(milons) 1.826 1.826 1.826 1.831 1.826 1.826 1.8216 1.831 1.826 18.899 68.313 148.490 17.216 (millons....

C Decommissioning Trust Fund Escalated at 2%

(minus expenses)

(millions 546.886 555.997 565.291 574.766 584.435 594.298 604.358 614.614 625.081 618.683 562.744 2062 2063 2064 2065 2066 2067 2068 2069 2070

+

425.509 416.803 407.923 398.865 17.216 2071 17.216 17.216 2072 2073 17.235 11.400 441..

549....[1].

17.235 11.400 4......

389.608 386.000 Notes:

[M1 Does 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.

Indian Point Energy Center, Unit 1 Preliminary Decommissioning Cost Analysis APPENDIX A 2007 DETAILED COST ANALYSIS Document Ell-1583-004 Appendix A, Page 1 of 9 TLG Services, Inc.

Indian Point Energy Center, Unit I Decomnanissioning Cost Analysis Dodurnent El1-1583-004 Appendix A, Page 2 of 9 Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

SActivity Decl Inodex Activity Description Coa PERIOD ta - Pre.Shutdown Early Planning Period Oa Direct Decommissioning Activities Perod Oa Additional Costs 0a.2.1 P1 Projects 2000-2007 0a.2.2 pI Recurnng Costs 2000-2007 0a.2.3 I11 Projects 2008 0a.2.4 P 1 Recuncing Costs 2008-License Termination 0a.2.5 IP1 Recurrig Costs 2 0 08-Spent Fuel Mgent 0a.2.6

PEC Dry Cask Infrastructure 0a.2.7 P1 Recurring Costs 2009-2015 0..2.8 IP1 Ground Water Program 2009-201t5 0..2.9 Emergency Planning 2009-2005 0a.2.10 Utity, Staffing 2009-2015 0a.0 TOTAL PERIOD Da 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 nof replacement 2b. 1.5 Maintenance supplies 21.1 Subtotal Period 2b Activity Costs Peoa 21b Additional Costs 2b.2.1 Emergency Planning Fees 2b.2 Subtotal Period 2b Additional Costs Period 2b Period-Dependent Costs 2b.4.1 Insurance 2b.4.2 Property taxes 2b.4.3 Health physics supplies 2b.4.4 Disposal of DAW generated 2b.4.5 Plant energy budget 2b.4.6 NRC Fees 21.4.7 Site O&M 2b.4.8 Environmental 2b.4.9 Uttily Staff Cost 20.4 Subtotal Period 2b Perod-Depandent Costs 2b.0 TOTAL PERIOD 2b COST PERIOD 2c - SAFSTOR Dormancy without Spent Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 Ouarrerly Inspection 2c.1.2 Semi-annual environmental survey 2c.1.3 Prepare r"po ns 2c. 1.4 Bituminous rost replacement 2..1.5 Maintenance supplies 2c.1 Subtotal Period 2c Activity Costs Period 2c Period-Dependent Costs 2c.4.1 Insurance 2c.4.2 Property taxes Off-Site LLRW on Removal Packaging Transport Processing Disposal Other Total I

Cost Costs Costs Costs Costs Cast.

Contingency NRC Spent Fuel Site Processed Bureal Volumes Burial I UtIity end I Total LIC. Teem.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Costs Costs Costs Costs Cu. Feet Cu. Feat Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.

Manhours Manhours I 51.123 23.844 6.647 200 3.967 1.512 5.047 1.400 6.836 3.222 9.370 18-191 1.600 129.760 51,123 23.844 6,647 4,167 1,512 5,047 8.236 3.222 9,370 18,191 131,359 51.123 23,844 6.647 4.167 8,236 3,222 18,191 115,430 1.512 5,047 9,370 15.929 a

180 27 206 3,768 942 4,710 3,948 969 4,917 206 4.710 4.917 22,414 2.241 24,655 24.655 22,414 2.241 24.655 24,65S 2.622 2,622 2,622 51 34 51 34 51 34 501 5.913 5.183 3.480 13,644 11.861 501 40,081 501 66,442 656 135 687 518 522 2.047 1,779 6.544 9,754 3,278 722 6,800 5,701 4,002 15,690 13.640 49,833 79,405 3,278 722 6.800 5.701 4.002 15,690 13,640 49.833 79.405 11,086 11,086 11,086 221,729 88 250,103 221,729 88 250,103 221,729 88 250,103 aa 123 18 141 2,582 645 3,227 2,705 664 3,369 141 3,227 3.369 TLG Services, Inc.

Indian Point Energy Center, Unit I Decommissioning Cost Analysis Document Ell-1583-004 Appendix A, Page 3 of 9 Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

ActivIty Off-Oto LLKW NRC Spent Fuel sto FPrOCeSSed 0B0ural volumes bural i utility and Decon Removal Packaging Transport Processiog Disposal Other Total Total LUc. Ton*.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor I

In*x ACt*I*

U*SCM

tlon Index

-avily uas,,

,on Cast Cost Costs Costs Costs Costs Costs Comtrue Costs debt Costs Cos.

cu Fast Cu Feet Cu Feet Cu Fast Cu Foot Wt Lbs Manhou Manhours Period 2c Pehiod-Oependent Costs (continued) 2c.4.3 Health physics supplies 2c.4.4 Disposal of DAW generated 2c.4.5 Plant energy budget 2c.4.6 NRC Fees 2c.4.7 Site O&M 2c.4.8 Ervironmental 2c.4.9 Utility Staff Cost 2c.4 Subtotal Period 2c Pehod-Depeedent Costs 2c.0 TOTAL PERIOD 2c COST PERIOD 2 TOTALS PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decomrrissioning Activities 3a.1.t Prepare preliminary decoarnIssioning cost 3a.1.2 Review plant dwgs & speos.

3a.1.3 Perform detaileid red surey 3a. 1.4 End product de:scippon 3a.1.5 Detailed by-product inventory 3a.1.6 Define major work sequence 3a.1.7 Perntro SER and EA 3a.1.8 Perform Site-Specific Cost Study 3a.1.9 Preparetsubmit License Termination Plan 3a.1.10 Receive NRC approval of terninabon plan Activity Specificadons 3a.1.1 1.1 Re-acgvate plant & temporary facifies 3a.1.11.2 Plant systems 3a.1.11.3 Reactar internals 3a.1.11.4 Reactor vessel Sa.t.1t.5 Biological shield 33.111.6 Steam generators 3a.1.11.7 Reinforced concrete 3a..t11.8 Main Turbine 3a. 1,1.9 Main Condensers 3a,1.1t.t1 Plant structures & buildings 3a.1.t11.t Waste management 3a.1.11.12 Facility & site closeout 3t.1.1 Total Planning & Site Preparations Sa.1.12 Prepare dismanoing sequence 3at1.1 3 Plant prep. & temp. soces 3a4.1.14 Design water clean-up system 3a1.15 RigginglCont. Cntd Envlpsotioingletc.

3sa. 1.16 Procure casksiners & containers 3..1 Subtotl Petiod 3a Activity Costs Period 3a Additional Costs 3a.2.1 Site Characterization 3a.2 Subtotal Period 3a Additional Costs Period 3a Perdod-Dependent Costs 3a.4.1 Insurance 3a.4.2 Prmperty taoes 1,797 449 2,246 2.246 35 23 343 93 494 494 4.052 608 4,659 4.659 3,551 355 3,906 3.906 2.384 358 2.742 2,742 9,348 1,402 10.750 10.750 8,127 1.219 9.346 9,346 1,797 35 23 343 27,462 4,484 34,144 34,144 1,797 35 23 343 30,167 5,148 37,913 37,913 4.419 85 58 1144 96,609 14.902 116,918 116,918 7,596 7,596 7.596 18.682 151,919 60 171.360 151,919 60 171.360 151,919 60 171,360 373,648 148 421,463 61 9

70 70 214 32 246 246 47 7

54 54 61 6

70 70 349 52 402 402 144 22 166 166 233 35 268 268 191 29 219 219 343 51 395 355 39 194 29 223 201 22 331 50 380 380 303 45 348 348 23 3

27 27 145 22 167 167 74 11 86 43 43 19 3

21 21 19 3

21 21 145 22 167 M4 84 214 32 248 246 42 6

48 24 24 1,852 278 2.130 1,975 255 112 17 129 129 2,419 363 2.782 2.782 65 10 75 75 2,048 307 2.355 2.355 57 9

66 66 7,852 1,178 9.030 6,7-75 255 928 3.214 714 928 5,355 2,213 3,570 2.925 5,262 2.975 5,069 4,641 357 2,228 1.142 286 286 2,228 3,284 643 28,401 1,714 1,080 878 51,910 2.218 665 2,883 2,683 2,218 665 2,883 2,883 TLG Services, Inc.

Indian Point Energy Center, Unit I Decommisioning Cost Analysis Document Eli-1583-004 Appendix A, Page 4 of 9 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)

Utlt 9 and W

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 3a4.44 Heavy equipment rental 3a.4.5 Disposal of DAW generated 3a.4.6 Plant energy budget 3a.4.7 NRC Fees 3a.4.8 Site O&M 3a.4.9 Environmental 3a.4.10 Utlity Staff Cost 3a.4 Subtotal Period 3a Period-Dependent Costs 3a.0 TOTAL PERIOD 3a COST PERIOD 31 - Decommissioning Preparations Peded 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems 3b. 1.1.2 Rsactor internals 3b.1.1.3 Remaining buildings 3b.1.1.4 CR0 cooling assembly 3b.1.1.5 CR0 housings & ICl tubes 3b.1.1.6 Incore instrumentation 3b.1.1.7 Reator vessel 3b.l.1.8 Facility closeout 3b.1.1.9 Missile shields 3b.1.1.t0 Biological shield 3b.S1.1l1 Steam generator 3b.1,..12 Reinforced concrete 3b.1.1.13 Main Turbine 3b.1.1.14 Main Condenser 3b.1.1.15 Auxiliory building 3b.1.1.16 Reactor building 3b.1.1 Total 3b. 1 Subtotal Period 3b Activity Costs Period 3b Additional Costs 3b.2.1 Asbestos Abatement 3b.2.2 Staff relocations expenses 3b.2 Subtotal Period 3b Audito.aI Costs Period 3b Collateral Costs 3b.3.1 Decon equipment 3b.3.2 Small tool aliowaoce 3b.3.3 Pipe cutting equipment 30.3 Subtotal Period 3b Collateral Costs Period 3b Period-Dependent Costs 3b.4.1 Decon supplies 3b.4.2 Insurance 31.4.3 Property toxes 3b.4.4 Health physics supplies 3b.4.5 Heavy equipment rental 3b.4.6 Disposal of DAW generated 3b.4.7 Plant energy budget 3b.4.8 NRC Fees 3b.4.9 Site O&M 198 237 435 1

435 1

1 50 248 248 36 273 273 10 3

15 15 101 15 116 116 88 9

97 97 237 35 272 272 232 35 267 267 4J127 619 4,746 4,746 10 4.784 801 6,032 6,032 10 14.854 2,644 17.945 17,690 255 226 226 226 4,518 336 50 387 34o 178 27 204 204 96 14 110 28 71 11 82 82 71 11 82 82 71 11 82 82 258 39 297 297 85 13 98 49 32 5

37 37 85 13 98 98 327 49 376 376 71 11 82 41 11 17 127

-111 17 127 194 29 223 201 194 29 223 201 2,291 344 2,635 2,124 2,291 344 2,635 2,124 1.915 1

124 326 579 2,944 2,944 1,639 246 1,885 1.885 1.915 1

124 326 1,639 825 4,829 4,829 39 83 49 41 127 127 22 22 511 511 69,086 4.518 2

69,086 4,518 2

120,995 3,379 1,785 964 714 714 714 2,592 857 321 857 3 3,294 714 1,114 1,114 1,949 1,949 23,022 23,022 11,087 11,087 144,131 20,864 164,131 20.864 959 33 957 959 989 144 1.103 1,103 5

38 38 143 1.100 1,100 292 2,241 2,241

.7-30 292 235 7

37 37 73 365 365 35 270 270 10 3

15 15 99 15 114 114 87 9

96 96 234 35 269 269 223 4,469 TLG Services, Jnc.

Indian Point Energy Center, Unit )

Decommissioning Cost Analysis Document Ell.1583-004 Appendix A, Page 5 of 9 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 Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lc. Tenm.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft ContratoI index Activity Description Cost Cost Costs Costs Costs Costs Costs Contin-en Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Ca. Feet Wt., Lbs.,

Mainooms Manhrours Period 3b Period-Dependent Costs (continued) 3b.4.10 Environmental 3b.4.11 Utility Staff Cost 3b.4 Subtotal Period 3b Period-Dependent Costs 3b.0 TOTAL PERiOD 3b COST PERIOD 3 TOTALS PERIOD 4a - Large Component Removat Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.1.1 Reactor Coolant Piping 4a.1.1.2 Pressurizer Relief Tank 4a.1.1.3 Reactor Coolant Pumps & Motors 4a.1.1.4 Pressurizer 4a.1.1.5 Steam Generators 4a.1.1.6 CRDMs/lClosService Stncture Removal 41.1.1.7 Reactor Vessel Intemais 4a.1.1.8 VesselS Internals GTCC Disposal 4a.1.1.9 Reactor Vessel 4a.1.1 Totals Removal of Major Equipment 4a. 1.2 Main TurbieelGenerator 4a.1.3 Main Condensem Cascading Costs from Clean Building Demolition 4a.1.4.1 Reactor Containment 4a.1.4.2 Chemical Systems Bullding 4a.1.4.3 Fuel Handling Building 4a.1.4.4 Nuclear Service Building 4a.14 Totals Disposal of Plant Systems 4a.1.5.1 Electtdal - Clean 4a.1.5.2 Plant Air 4a.1.5.3 Plant Heating 4a.1, 5.4 River Water 4a.1.5.5 Sevice Water 4a.1,5.6 Turbine 4a. 1.5.7 Well Water 4ad1.5 Totals 4a. 1.6 Scaffolding in support of decommissioning 4a.1 Subtotal Peiod 4a Activity Costs Period 4a Collateral Costs 4a.3.1 Process liquid waste 4a.3.2 Small too] allowance 4a.3.3 Survey and Release o1 Scrap Metal 4a.3 Subtotal Period 4a Collateral Costs Period 4a Period.Dependent Costs 4a.4.1 Decon supplies 4a.4.2 Insurance 30 527 989 3.431 989 3.867 1

2 3

1 124 125 229 4,082 10 4,732 336 8.663 346 23,517 69 232 53 51 260 372 9

107 53 16 100 114 42 115 35 2,270 5.1335 156 8,560 223

"-1,523 648 2,501 68 293 306 734 52 156 1.531 121 1,075 4.391 121 412 7.640 241 34 264 264 612 4,695 4,695 824 6.125 6.125 2,285 15,829 15,319 4,929 33,775 33,009 238 1,275 1,275 83 483 483 129 785 785 2,958 8.731 8,731 161 1,237 1.237 6.828 18,129 18,129 10,397 30,642 30.642 86 851 551 130 689 689 1,517 11.632 11,632 545 4,177 4,177 31 230 230 104 796 796 2.197 160,44 16,844 20 155 36 218 218 7

56 18 141 4

27 49 315 315 38 289 172 1,201 533 354 1,805 1,005 13,336 51.732 51.063 1,260 1,260 070 753 753 2,415 411 501 115 5,337 1,239 2,884 10.177 1.740 115 511 766 223 11,310 11,536 68.343 4,469 2

68,343 148.600 20,866 91,364 153.118 20,860 212,360 292.298 4,535 100,540 2.035 91,841 2,222 78,135 13.300 664 47 19,440 654.068 13,300 664 47 1.236.322 35.392 1.328 188 52 17 208 465 16 6

70 2,481 840 111.651 2,692 37.821 6.671 10,115 3.632 207 692 14.647 106.763 34.588 1.S39 6.599 149,788 135 92 48 123 24 89 252 762 1.357 156 25,980 5

338 5

338 81 3

13 5

19 17 6

2,593 783 3

15 3

15 161 242 62 10 994 7,650 241 155 1,075 56 141 27

.31 2,131 289 668 3,206 739 46 660 10,150 10,223 1.740 115 1,981 43,674 1,370 726 1,831 355 860.26 1,290 3,667 130.200 11,222 37,366 21.936 47 1,553,359 227,702 1,328 2,235 7

2,235 7

10 7

40 40 51 389 350 086 296 1,282 1.202 10 806 354 1.711 1,672 39 37 37 37 9

46 46 TLG Services, 1se.

Indian Point Energy Center, Unit 1 Destomi.sioning Cost Analysis Documenealt1-1583-004 Appendix A, Page 6 of9 Table A Indian Point Energy Center, Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spont Fuol Sits Processed Burial Volumes Burial I Utility and Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Toem.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Cost 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 ctiv o

cdtio Period 4a Period-Dependent Costs (continued) 4..4.3 Property toxes 4a.4.4 Health physics supplies 40.4.5 Heavy equipment rental 4a.4.8 Disposal oa DAW generated 4a.4.7 Plant energy budget 4.A4.8 NRC Fees 4a.4.9 Site O&M 4a.4.10 Rsadwaste Processing Equipment/Senricesc 4a.4.1 1 Environmental 4a.4.12 Utility Staff Cost 40.4 Subtotat Period 4a Period-Dependent Costs 40.0 TOTAL PERIOD 4a COST PERIOD 41 - Site Decontamination Period 4b Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks Disposal of Plant Systems 4b.1.2.1 Cleanup & Condensate Demineralizer 4b.t.2.2 Coentrl Rod Hydraulic System 4b.1.2.3 Cooling Water 4b.1.2.4 Electrical - Contaminated 4bti1.2.5 Electdral - RCA 4b.1.2.6 Fire Protection 4". 1.2.7 Fire Protection - RCA 4b.1.2.8 FloorDroat Tank & Laundry Waste 4b..2.9 Fuel & Luhe Oil 4b.1.2.10 Fuel Oil Tanks 4b.1.2.1 1 Improvements Radiation Detecton Unit 4b.1.2.12 Liquid Waste Storage & Hold-Up Tanks 4b.1.2.13 Main Steam & Coedensate 4b.1.2.14 Misc Serice Piping 4h.1.2.1S Nuclear Steam Supply 4b..1.2.16 Plant Heating - RCA 4b.1.2.17 Plant Heating Contaminated 4b.1.2.1 8 REDT & Fuel Handling Water Treatnent 4b.1.2.19 Radwaste & Waste Dentin Tanks 4b.1,2.20 Service Water-RCA 4b1.1.2.21 Sludge Handling Resin Star & Waste Conc 4b.1.2.22 Waste Neutralizer & Waste Collectar Tank 4b.1.2.23 Waste Treament 4b.1.2 Totals 4b.1.3 Scaftolding in support of decommissioning Decontamination of Site Buldings 4b.1.4.1 Reactor Contalement 4b.1.4.2 Chemical Systems Building 4b.1.4.3 Fuel Handling Building 4b.1.4.4 Nuclear Senvice Building

41. 1.4.5 Service Buiding & H. T. Switchgear 4b. 1.4.6 Superheater Building 4b.1.4.7 Turbine Building 4b.1.4 Totss 4b.1 Subtotal Period 48 Activity Costs 1,313 1,439 5

75 562 109 294 235 288 7,561 5

75 9.050 802 994 7,735 10.277 37 2.752 8

198 29.070 2,603 313 36 96 43 338 182 224 285 58 934 52 21 94 191 412 107 1,492 5

198 382 131 230 487 188 154 110 1.289 7,144 2,035 1,336 3.434 771 2.146 109 1,850 270 656 169 482 888 260 1,329 3,229 10.471 3.542 19,867 3

2 8

1 20 0

2 6

87 8

8 2

5 7

7 3

2 37 210 25 11 137 8

94 29

.359 2

26 73 810 2

21 6

73 20 254 5

67 329 4,110 31 387 29 359 8

98 20 248 27 339 25 318 11 141 9

107 140 1,749 784 9,797 9

93 15 328 1.642 1,642 216 1.655 1,655 20 108 108 64*

646 646 11 120 120 40 338 338 35 271 271 43 331 331 1.134 8,695 8,695 1,926 13,853 13.a53 15,615 67,295 66.587 266 1.092 1,092 68 400 400 71 399 399 130 811 011 19 105 105 383 2,320 "

2,320 8

60 9

53 53 35 209 209 89 560 560 62 473 0

1 38 218 218 1,048 7,066 7,066 1

6 113 738 738 154 931 931 49 287 287 98 601 601 158 939 939 99 638 638 61 370 370 45 273 273 609 3,825 3,825 3,347 21.283 20,744 830 2,708 2,708 4.716 27.867 27.867 3.126 18.899 18,699 2,610 16.976 16,576 977 5,791 5.791 235 1.910 1.510 1,479 8.678 8,678 1,984 12,302 12,302 15,128 91,424 91,424 19,272 116.507 110,968 1,658 1.546 1,810 1.249 4.759 342 12.048 60 274 962 3,361 473 886 54,411 5,130 4.746 1,299 3,282 4,491 4,213 1,863 1.415 23.157 539 129,696 1,108 69 8,859 277,680 1.223 197,917 362 188.869 346 60,836 17,456 91,935 137.660 10.790 972,352 039 141,594 973,967 138,718 603 73,494 2.593 50,719 2,937 193,258 4,093 13,892 838 489,258 13.381 778 11.122 290 39,087 1,328 136,476 2.734 5,920 S -

9 35,976 1,483 2,209,667 21,743 78 200.325 2,912 192,742 5,375 52,747 1,715 133.264 3.312 182,398 5.806 171,087 2,691 75,143 2,206 57,471 1,598 940,414 18,680 5,267,039 102.498 56,049 32,904 28,116,760 68,101 19,839,890 41,698 18.901,140 28,298 6,097,243 13,247 1.745,550 2,436 9,193,00 19,903 13.765.950 23,032 97,660,020 196,715 103,121,800 332,720 126,060 1,658 33,169 13 126.060 707 10.150 11,919 1.740 115 47 1,588,763 227,723 127,388 33.169 13 5,873 4,576 669 7,263 4,178 3.234 92 5.152 3,985 3,082 27 4,912 1,284 994 26 1,583 368 285 454 1,940 1.499 2.390 2,904 2,245 3.579 20,532 15,916 815 25,334 20,862 16,752 10,794 25.687 TLG Services, In,.

Indian Point Energy Center, Unit 1 Decsommissioning Cost Analysis Document EI1-1593o004 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 Activity Doecon Removal Packaging Transport Processing Disposal Other Total Total LIc. Tosm.

Management Restoration Voiume Class A Class B Class C GTCC Processed Craft Contractor Index Activitt Description 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 Period 4b Additional Costs 4b.2.1 Final Site Survey Program Management 4b.2.2 AOC PCB Soil Remediaton 4b.2 Subtotal Period 4b Additional Costs Period 4b CollateIra Costs 4b.3.1 Provess liquid waste 4b.3.2 Small tooi aottoc.

4L.33 Decommissioning Equipment Oisposition 4b.3.4 Survey and Release of Scrap Metal 4b.3 Subtotal Peorod 4rb Collateral Costs Period 4b Peioo-Dependent Costs 4b.4.1 Deon suppiies 4b.4.2 Insurance 4b.4.3 Property taxes 4b.4.4 Health physics supplies 4b.4.5 Heavy equipment rental 4b.4.6 Disposal of DAW generated 4b.4.7 P

Plant energy budget 4b.4.8 NRC Fees 4b.4.9 Site O&M 4b.4.10 Radwaste Processing EquipmentoSerlces 4b.4.11 Environmental 4b.4.12 Utility Slaff Cost 4b.4 Subtotal Period 41b Perod-tepesdent Costs 4b.0 TOTAL PERIOD 4b COST PERIOD 4o - License Termination Period 4e Direct Decommissioning Activities 4e.1.1 ORISE confionatory survey 4e.1.2 Terminate Olense 4e.1 Subtotal Period 4e Activity Costs Perod 4d Additional Costs 4e.2.1 Final Site Survey 4e.2.2 Staff relocations expenses 4e.2 Subtotal Period 4e Additional Costs Period 4e Period-Dependent Costs 4e.4.1 Insurance 4e.4.2 Property taxes 4e.4.3 Health physics supplies 4e.4.4 Disposal of DAW generated 4e.4.5 Plant energy budget 4e.4.6 NRC Fees 4e.4.7 Site O&M 4e.4.0 Environmental 4e.4.9 Utility Staff Cost 4a.4 Subtotal Period 4e Pnri*-Dependent Costs 4e.0 TOTAL PERIOD 4e COST PERIOD 4 TOTALS 37 12 76 37 12 76 652 196 848 548 218 76 420 420 218 652 272 1.267 1,267 12,181 12,181 6,240 1.280,000 320 1,280,000 320 6,240 24 13 72 51 37 198 198 443 66 599 509 135 59 502 82 110 896 896 966 290 1,255 1,255 24 443 148 132 502 133 965 511 2,859 2.859 185 6,000 373 6,000 558 11,098 36 303,507 88 314,605 124 1.333 333 1,666 1,666 1,863 1,929 466 2,329 2,329 289 2,218 2,218 21 14 204 55 293 293 4,503 599 90 689 689 148 15 163 163 397 60 456 456 318 48 365 365 389 58 447 447 5,331 800 6.131 6.131 21 14 2G4 7,182 2,213 14.759 14,759 4,503 21,043 16.974 11.207 26,243 8,800 22,269 135,392 134.853 539 147,594 991.209 90,057 36 95,383 90.057 36 95.383 104.806.500 333.200 101.623 1,333 3,792 4,898 23,959 152 46 198 198 152 46 196 198 4,076 1,223 5,298 5.298 1.639 246 1.685 1,005 5,715 1.469 7,184 7.184 56,068 3,120 56,068 3,120 526 131 657 657 1

1 13 4

19 19 294 5,881 2

141 21 162 162 130 13 143 143 350 52 402 402 343 51 394 394 2,165 325 2.490 2,490 33,000 526 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 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 TLG Services, Ine.

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

Ott-Site LLRW NRC Spent Foei sine Processed Butial Volouees Burial I Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total LIc. Teem.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activit Description Cost Cost Costs Costs Coons Costs Costs Consneenct '

Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.

Manhours Manhours PERIOD 5b - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 51,1.1.1 Reactor Costaironont 50.1.1.2 Chemical Systems Building 5b01.1.3 Fuel Handling Building 5b. 1.1.4 Fuel Oil Tank Farn 5b.11.5 Gas Bottle Storage 5b.1.1.6 Gas Turbine 5.1.1.7 Sornenwell H-ouse 5b. 1.1.8 Service Building & H. T. Siltchgear 5b.1.1.9 Superheater Building 5b.1.1.10 Transformer Area Sb.1.1.11 Turbine Building 5b.1.1.12 Turbine Pedestal 5b.1.1 Totals Site Closeout Activities 5b.1.2 BackFill Site 5b.1.3 Grade & landscape site 50.1.4 Final report to NRC 5b.1 Subtotal Pesod 5b Activity Costs Pesod 5b Additional Costs 5b.2.1 Concrete Crushing 5b.2.2 Unit 1 Legacy Soil Remediaono 5b.2 Subtotal Pesod 5b Additional Costs Petiod 5b Collateral Costs 5b.3.1 Small tOOl allowance 5b.3 Subtotal Period 51 Collateral Costs Period 5b Pediod-Depeodnnl Costs 504.1 insurance 5b.4.2 Property taxes 50.4.3 Heavy equipment rental 5b.4.4 Plant energy budget 50.4.5 Site O&M 5b.4.6 Environmental 5b.4.7 Utility Staff Cost 5b.4 Subtotal Period 5b Pedod-Dependent Costs 50.0 TOTAL PERIOD 5b COST PERIOD 5 TOTALS TOTAL COST TO DECOMMISSION a

24 16 259 17 21 98 252 1.030 35 1,267 401 3.429 3,469 77 6.976 104 2.898 3.002 1

4 3

39 3

3 15 38 154 5

190 60 514 10 27 21 297 20 24 112 289 1,184 40 1,457 462 3,944 10 27 21 297 20 24 112 289 1,194 40 1,457 462 3,944 3,990 89 8,022 116 375 289 2,721 209 168 1,127 2.865 12,177 435 13.445 3,289 37,215 520 12 111 17 111 1,063 3,990 89 127 8.150 8.904 168 1.114 46,288 1,114 127 127 64,645 64,645 33B 16,719 339 16,719 1

16 120 33,139 11,551 64,645 33,139 1

11.567 64,765 120 1,262,434 120 1,262,434 434 96.444.000 25,372 96,444,000 25,806 106 106 16 122 16 122 122 122 9,291 375 1.861 1.824 55349 9,291 9.409 19,375 338 16.719 33,139 9.520 19.375 338 16.719 33,139 9.520 6.085 81,216 24,073 34,678 12,201 69.920 287,479 1.394 56 279 274 802 2.805 15,450 15,457 75,278 10,684 431 2,140 2,098 6,151 21,504 94,542 94,542 590,930 10,684 431 2,140 2,098 4,238 69,010 69,010 547,458 6.151 17.266 25.531 25.531 15.929 27.543 79,420 79,420 1.262,434 96.444,000 72,094 80,534 1,262,434 96,444,000 72,094 80,534 157,744 2,296,075 1,740 115 47 203,371,900 710.102 979,487 TLG Services, Ine.

Indian Pointt Ener-gy Center, Unit I Dercommissiaoning Cast A..tyoio Documoent E1I14583-004 Appensdix A, Page 9 of 9 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 Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total LIc. Teno.

Managenent Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor index Activit Description Cost Cost Costo Costs Costs Costs Costs Continh0nc Costs Costs Costs Costs Cu. Feet Cu. Foot Cu. Feet Cu. Feet Cu. Foot Wt., Lbs.

Manhours Manhours TOTAL COST TO DECOMMISSION WITH 14.6% CONTINGENCY:

$590,930 thousands of 2007 dollars TOTAL NRC LICENSE TERMINATION COST IS 92.64% OR:

$547,458 thousands of 2007 dollars SPENT FUEL MANAGEMENT COST IS 2.7% OR:

$15,929 thousands of 2007 dollars NON-NUCLEAR DEMOLITION COST is4.66% OR:

$27,543 thousands of 2007 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

2,297,929 cubic feet OTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED 47 cubic feet TOTAL SCRAP METAL REMOVED:

26,675 tons TOTAL CRAFT LABOR REQUIREMENTS:

710,102 man-hours End Notes:

ria - indicates that this activity not charged as decormmissioning expense.

a -Indicates that this activity performed 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.

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 prepared for Entergy Nuclear prepared by TLG Services, Inc.

Bridgewater, Connecticut October 2008

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis APPROVALS Document Eli-1583-003 Page ii of v Project Manager Project Engineer Technical Manager Quality Assurance Manager William A. Cloutier, 6 r.

Thomas e Garrett Geoff e".

Griffit hs Jeh J. Adled

/0/?a tle.

Date Date Date Dateý TLG Services, Inc.

Indian Point Energy Center, Unit 2 Document Eli-1583-003 Preliminary Decommissioning 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 R isk.......................................................................................

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 ssum ptions..................................................................................................

18 1.8.1 E stim ating B asis................................................................................

18 1.8.2 R elease Criteria..................................................................................

19 1.8.3 L abor C osts.........................................................................................

19 1.8.4 Design Conditions..............................................................................

20 1.8.5 G en eral................................................................................................

20 2.

R E S U L T S...................................................................................................................

24 2.1 Decommissioning Trust Fund........................................................................

25 2.2 Financial A ssurance.......................................................................................

25 FIGURE 1

SAFSTOR Decommissioning Timeline...........................................................

26 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis Document Eli-1583-003 Page iv of v TABLE OF CONTENTS SECTION PAGE TABLES 1

2 3

4 5

6 7

Low-Level Radioactive W aste Disposition.......................................................

27 Summary of M ajor Cost Contributors............................................................ 28 Schedule of Annual Expenditures, Total Decommissioning Cost................. 29 Schedule of Annual Expenditures, License Termination Allocation............. 31 Schedule of Annual Expenditures, Spent Fuel Management Allocation.....

33 Schedule of Annual Expenditures, Site Restoration Allocation.................... 35 Funding Requirements for License Termination........................................... 36 APPENDIX A.

2007 Detailed Cost Analysis............................................................................

A-1 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis REVISION LOG Document Eli-1583-003 Page v of v 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 Preliminary Decommissioning 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 2 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 of operations."[3]

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 4 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 5 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 Point Energy Center, Unit 2 Document El1-1583-003 Preliminary Decommissioning 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.

Indian Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost 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.

Indian Point Energy Center, Unit 2 Document Eli-1583-003 Preliminary Decommissioning Cost 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 Point Energy Center, Unit 2 Document Eli-1583-003 Preliminary Decommissioning Cost Analysis Page 9 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 Point Energy Center, Unit 2 Document Eli-1583-003 Preliminary Decommissioning Cost Analysis Page 10 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 11 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 Point Energy Center, Unit 2 Document Eli-1583-003 Preliminary Decommissioning 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 Preliminary Decommissioning Cost Analysis Page 13 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 Preliminary Decommissioning 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., 137Cs, 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 Point Energy Center, Unit 2 Document El1-1583-003 Preliminary Decommissioning Cost 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning 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.

Indian Point Energy Center, Unit 2 Document El1-1583-003 Preliminary Decommissioning Cost 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 and commitments for the site.[221 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 Point Energy Center, Unit 2 Document El1-1583-003 Preliminary Decommissioning Cost Analysis Page 18 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 Point Energy Center, Unit 2 Document Ell-1583-003 Preliminary Decommissioning 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 year."[25]

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 Point Energy Center, Unit 2 Document El1-1583-003 Preliminary Decommissioning Cost Analysis Page 20 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, Unit 2 Document El1-1583-003 Preliminary Decommissioning Cost Analysis Page 21 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.

Indian Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 22 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.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis Document El1-1583-003 Page 23 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.

Indian Point Energy Center, Unit 2 Document Eli-1583-003 Preliminary Decommissioning Cost Analysis Page 24 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 25 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 Point Energy Center, Unit 2 Document E1l-1583-003 Preliminary Decommissioning Cost Analysis Page 26 of 38 FIGURE 1 SAFSTOR DECOMMISSIONING TIMELINE (not to scale)

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

.Period 1 Transition and Preparations Period 2 Safe-Storage Period 3 SPreparations Period 4 Decommissioning Operations Period 5 Site Remediation 1

12/2045 2

06/2064 I22 12/2065 2

09/2069 09/2013 03/2015 ISFSI Expansion Canister and overpack fabrication 09/2073 License Terminated Fuel to ISFSI 06/2021 Storage Pool Empty ISFSI Operations All Spent Fuel Off Site TLG Services, Inc.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis Document E1l-1583-003 Page 27 of 38 TABLE 1 Indian Point Energy Center, Unit 2 Low-Level Radioactive Waste Disposition Waste Low-Level Radioactive Waste near-surface disposal)

Greater than Class C Processed/Conditioned off-site recyeh'ng center Total [21 Cost Basis Class [1I EnrgSolutions A

Barnwell B

Barnwell C

Spent Fuel Equivalent GTCC Recycling Vendors A

Waste Volume (cubic feet) 620,166 3,330 501 496 381,062 Mass (pounds) 53,686,179 352,433 45,688 104,146 15,069,040 69,257,486 1,005,554 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 Point Energy Center, Unit 2 Document El1-1583-003 Preliminary Decommissioning Cost Analysis Page 28 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)

S pent Fuel Pool Isolation Insurance and Regulatory Fec Energy 95.895 10,503 47,813 95,895 10,503 48,555 742 31,888 1,966 1,260 35,114 Radiological Characterization Pro Taxes Miscellaneous Equpment Environmental 17,072 17,072 4

4

+

15,098 3,521 4

15,102 3,521 Total 659,351 4

I 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 Preliminary Decommissioning Cost Analysis TABLE 3

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

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

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

Document E1l-1583-003 Page 30 of 38 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 1,205 3,668 4

t 2052 2053 2054 2055 2056 1,854 1.849 279 278 315 21 1,209 3,678

-. 4 4.

1,849 278 314 314 314 315 21 4

4-1,205 1,849 1,854 278 279 21 21 21 1,205 1,205 1,209 3,668 3,668 3,668 3,678 2057 1,849 278 314 21 1,205 3,668 2058 2059 2060 2061 2062 2063 2064 2065 2066 2067 2068 2069 2070 2071 2072 1,849 1,849 1,854 1,849 1,849 1,849 18,046 33,595 59,374 36,100 12,254 13,376 278 278 279 278 278 278 1,528 314 21 314 315 314 21 21 21 1,205 1,205 1,209 1,205 3,668 3,668 3,678 3,668 1

314 314 1,904 21 1,205 3,668 21 26 5,569 30,267 8,503 2,813 6,018 3,135 2,986 2,366 965 2,703 48,793 16,144 5,036 1,205 3,390 11,377 29,516 12,189 5,579 3,732 3,732 3,732 4,059 17.162

+

4 13,376 13,376 13,368 6,018 6,018 5,960 314 314 314 320 2,089 2,089 2,089 2,061 3,668 24,894 56,378 170,936 75,302 26,647 25,529 25,529 25,529 25,767 26,485 920,477 2073 7,802 1,03*9 463 18

-4 4

4 Total......

448,403 137,873 35,114 83,259 215,828 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis TABLE 4 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures License Termination Allocation

.(thousands, 2007 dollars)

Document Eli-i1583-003 Page 31 of 38 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 Preliminary Decommissioning Cost Analysis TABLE 4 (continued)

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

Document Eli-i1583-003 Page 32 of 38 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 Preliminary Decommissioning Cost Analysis TABLE 5 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2007 dollars)

Document Ell-1583-003 Page.33 of 38 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 Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis TABLE 5 (continued)

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

Document Ell-1583-003 Page 34 of 38 Equip &

Yearly Year Labor Materials Energ Burial Other Totals 2045 1,503 192 0

0 889 2,585 2046 0

0 0

0 2047 0

0 0

0 2048 0

0 0

0 2049 0

0 0

0 2050 0

0 0

0 2051 0

0 0

0 2052 2053 2054 2055 0

0 0

0~

0 0

0 2056 0

i 4

-t

+

0 0

2057 0

0 0

2058 2059 2060 2061 0

0 0

0

+

2062 2063 2064 2065 2066 2067 2068 2069 2070 2071 2072 0

0 0

423 137 32 32 32 0

0 0

0 191 68 280 280 280 276 45,689 0

0 0

0 81 26 0

0 0

666 215 6

6 0

0 0

1,361 446 318 318 318 314 0

0 31 0

0 0

1,966 0

02 107 0

6 6

4 4-Total 89,115 41,379 178,256 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis TABLE 6 Indian Point Energy Center, Unit 2 Schedule of Annual Expenditures Site Restoration Allocation (thousands, 2007 dollars)

Document Ell-1583-003 Page 35 of 38 Equip &

Yearly Year Labor Materials Enry Burial Other Totals 2013-2063 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 Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis Document Eli-1583-003 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 2030 2031 2032 2033 2034 3.676 3.676 3.676 3.686 3.676 3.676 3.676 362.798 3.676 3.676 3.686 3.676 3.676 366.378 370.030 i

373.744 377.543 381.418 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis Document Eli-1583-003 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 Point Energy Center, Unit 2 Preliminary Decommissioning Cost Analysis Document El1-1583-003 Page 38 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 =

Column C =

(A)*(1+.00)A(current year - 2007) or for 0%, B = A (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 Preliminary Decommissioning Cost Analysis Appendix A, Page 1 of 14 APPENDIX A 2007 DETAILED COST ANALYSIS TLG Services, Inc.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Doeuntent E1-1583-003 Appendix A, Page 2 of 14 Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommnissioning Cost Estimate (thousands of 2007 dollars)

I A'tiorty Off-Site LLRW NRC Spent Fuel Site Processed Bural Volumes Burial I Utility and Dncon Removal Packaging Transport Processing Disposal Other Total Toti Us. Term.

Management Restotion Volue Class A Class B Ctass C GTCC Processed

' Craft Cantrator Cost Coat Casts Costs Costs Costa Casts Continoeonv Coats Costs Costs Coats C,,- Feat C,,- Feet Cs. Feet Cu.- Foot C,,- Feet Wit, tn.

Mootnh,,rMsnho,,rI d ex I ý....

Cost osts Costs Cost.

Costs Costs Conting-ey Costs

ýora's Costs Costs Cu Feet Cu Feet Cu Feet Cu Feet Cu Feet Wt Lh-Ma-h-um PERIOD Ia -Shutdown through Transition Period Ia Direct Decommissioning Activities la.1o1 SAFSTOR site characterization survey l ai1.2 Prepare preliminary decommissioning cost la.1.3 Noblication of Cessation of Operations it 1.4 Remove fuel & source material 1.1.5 Nolification of Permanent Defueling as.1,6 Deactivate plant systems & process waste la.t.7 Prepare and submit PSDAR 1a.1.8 Review plant dwgs & specs.

la.1.9 Perform dettsled rad survey la.t.t0 Estimate by-product inventtory lath.

1,1 End product description la.1.12 Detaited by-product inventory la.1.13 Define majororc sequence ild.4 Portorn SER and EA la.1.15 Perform Sito-Specibc Cost Study Activity Specifications la.1.16.1 Prepare plant and facilities for SAFSTOR la1.16.2 Plant systems la.1.16.3 Plant structures and buildings lai.116.4 Waste management la.1.16.5 Facility and site dormancy la.1.6 Total Datailed Work Procedures la.t.17.1 Plant systems 1a.1.17.2 Facility closeout & dormancy la.1.17 Total la.1.18 Procure vacoum drying system lai11 Drain/de-eonrgize con-cant, systems la.1.20 Drain & dry NSSS la.1.21 Drainlde-energize contaminated systems la.1.22 DOcon/secora contaminated systems lo.

Subtotal Period ia Activity Costs Period ta Additional Costs 1 a.2.1 Asbestos Abatement 1 a.2 Subtotal Period 1 a Additional Costs Period 1i Callateral Costs la.3.1 Small tool allowance t.. 3 Subtotal Period 1 a Collateral Costs Period la Pedod-Dependent Costs la.4.I Insurance 1a.4.2 Property taxes 1 a.4.3 Health physics supplies la.4.4 Heavy equipment rental la.4.5 Disposal of DAW generated 1 a.4.6 Plant energy budget lad.7 NRC Fees la.4.8 Emergency Planning Fees 493 148 641 641 61 9

70 70 We 93 14 107 107 61 9

70 70 928 1.428 928 714 714 1,071 714 2.213 3,570 47 47 70 47 144 233 229 194 145 93 93 755 a

7 54 54 7

54 5

10 80 80 7

54 54 22 166 166 35 268 268 34 263 263 29 223 223 22 167 167 14 107 107 14 107 107 113 868 868 3.513 2,975 2,228 1,428 1,428 11,572 55 8

63 63 56 8

64 64 111 17 128 128 5

1 5

5 a

a 2,164 398 2,562 2,562 845 857 1,702 71 25,625 1,144 0

87 1,144 6

87 202 202 350 1,783 1,783 350 1,783 1,783 6,880 89,440 11,698 6,880 89,440 11,698 19 19 553 466 3

22 22 3

22 22 1,051

-25 2,733 258 981 105 1,156 1,156 138 691 691 70 536 536 7

40 40 410 3,143 3.143 26 264 284 98 1,079 1,079 610 12,190 S5 TLG Services, Into.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Document El1-153l-003 Appendix A, Page 3 of 14 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&

lsa4.1O Spent Fuel Pool O&M la.411 ISFSI Operating Costs la.4.12 Groundwater Monitoring ta.4. 3 Corporate A&G 1a.4.14 Security Staff Cost l.a4.15 Utiity Staff Cost la.4 Subtotal Period 1 a Period-Dependent Costs 1,018 la.0 TOTAL PERIOD to COST 2,181 PERIOD lb - SAFSTOR Limited DECON Activities 2,848 738 41 51 1,862 1,648 22,005 28 34,217 230 38,380 427 3,275 3,275 111 849 6

47 8

59 59 279 2,141 2,141 247 1,895 1,898 3,301 25,306 25.306 5,233 40,500 38,526 5,984 44,867 42.893 549 47 1,974 1,974 610 7.490 46,678 423,400 12,190 5

470,078 101.630 11,703 495.704 3

2 3

88 Period lb Direct Decommissioning Activities Decontamination of Site Buildings lb.1.1.1 Reactor Containment Sb.

1.1.2 Fuel Storage Building

, b.1.1 3 Maintainance & Outage Buiding 1 b.1.1A4 Primary Auxiliary Building 1 b.1.1.5 Waste Holdup Tank Pit 1b.1.1 Totals 1,594 506 31 219 42 2,391 1b.1 Subtotal Peniod 1 b Activity Costs 2,391 Period lb Collateral Costs lb.3.1 Decon equipment 959 1 b.3.2 Process liquid maste 165 80 440 1b.3.3 Smal tool allowance 50 I b.3 Subtotal PeFod l b Collateral Costs 1,124 50 80 440 Period lb Period-Dependent Costs lb.4.1 Deoun supplies 713 1b.4.2 Insurance 1 b.4.3 Property taxes 1 b.4.4 Health physics supplies 284 1 0o4.

Heavy equipment rental 117 10b4.6 Disposal of DAW generated 2

1 1 4.7 Plant energy budget 10 4.8 NRC Fees 1 b.4.9 Emergency Planning Fees 1 b04.10 Site O&M 10.4.11 Speot Fuel Pool O&M 1b4.12 ISFSI Opealing Costs lb.4.13 Groundwater Monitoring 10.4.14 Corporate A&G 1 b,4.15 Security Staff Cost lb.4.16 Utiity Staff Cost 1 b.4 Subtotal Period 1 b Period-Dependent Costs 713 401 2

1 1 b.0 TOTAL PERIOD 1b COST 4,229 451 82 442 797 2.391 2,391 203 759 759 1 5 46 46 109 328 328 21 63 63 1,196 3,587 3,587 1,196 3,587 3,587 144 1,103 1,103 235 1,232 1,232 8

58 58 386 2,393 2,393 22,977 6,818 3,200 612 34.0866 313 313 1,123 1,123 67,402 219 67.402 219 178 892 892 265 26 291 291 71 355 355 18 135 130 21 6

30 30 689 103 792 792 65 7

72 72 247 25 272 718 108 826 826 185 28 214 10 2

12 13 2

15 15 469 70 540 540 415 62 478 478 5,547 832 6,379 6,379 21 8,624 1,538 11,302 10,804 334 8,624 3,119 17,261 16.784 272 214 12 498 498 467 9,349 4

11,765 106,720 467 9,349 4

118,4B6 1.591 76,751 34,288 118,486 TLG Sercices, Ine.

Indian Point Energy Center, Unit 2 Deeoemmisoioniog Cost Anialysi Document E11-1583-003 Appendix A, Page 4 of 14 Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars) m Activity Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial t 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

wt he.

Marnhooue Manhtnlre.

Rm InQ*

A*IVI* U*CrlD[LOn Inde Cost osts Costs Cost Cost Cu eet C

Fas Fee"t F t PERIOD tc -Preparations for SAFSTOR Dormancy Period 1c Direct Decommissioning Activities 1 c.1.1 Prepare support equipment for storage 1 c.1.2 Install containment pressure equal, lines c.1.3 Interim survey prior to dormancy 1 c.1.4 Secure building accesses 1 c.1.5 Prepare & submit interim report tc.1 Subtotal Period 1 c Activity Costs Period lc Additional Costs lc.2.1 Spent Fuel Pool Isolation l c.2 Subtotal Period 1 c Additional Costs Period Ic Collateral Costs lv.3.1 Process liquid waste rc.3.2 Small tool allowance 1 v.3 Subtotal Period lc Collateral Costs Period le Period-Dependent Costs lc,4.1 Insurance 1c.4.2 Property taxes 1c.4.3 Health physics supplies I c4.4 Heavy equipment rental 1 c.4.5 Disposal of DAW generated lv.4.6 Plant energy budgel lc.4.7 NRC Fees lc.4.8 Emergency Planning Fees lcA.9 Site O&M l c4.10 Spent Fuel Pool O&M I c,4.11 ISFS1 Operating Costs lc.4.12 Groundwater Monitoring lc.4.13 Corporate A&G lC.4.14 Secutly Staff Cost lvc4.15 Utility Staff Cost I c4 Subtotal Period 1 c Period-Dependent Costs lc.0 TOTAL PERIOD lc COST PERIOD I TOTALS 480 53 533 733 27 760 73 552 552 8

y1 61 220 953 953 4

31 31 304 1.596 1,596 3,000 700 10.582 2-416 l,282 416 9,133 1,370 10,503 10,503 9,133 1,370 10,503 10,503 185 89 494 6

15 6

89 494 351 351 265 193 310 185 849 4,414 3,481 1

7 689 65 247 718 185 10 13 469 415 5.547 1

0 7

8.624 90 494 358 10,518 175 1,025 921 630523 263 1,382 1,382 1

7 7

264 1.389 1,389 26 291 291 48 241 241 1l 135 135 z

10 10 103 792 792 7

72 72 2S 272 108 826 826 29 214 12 15 15 T0 540 540 62 478 478 833 6,379 6,379 1,332 10,275 9,778 3,270 23,764 23,267 12,374 85,913 82.943 272 214 12 498 498 2,970 1.260 1,260 75,615 246 75,615 246 154 154 1,414 10,494 3,073 1

11,765 106,720 3,073 1

118,486 78,687 14,529 118,902 257,068 60,520 733,091 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 Bituminous roof replacement 2'.1.5 Maintenance supplies 2a.1 Subtotal Period 2a Activity Costs Period 2. Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 2u.3 Subtotal Period 2a Collateral Costs 134 20 154 154 786 197 983 983 920 21?

1,137 1,137 45,666 6,850 52,516 45,666 6,850 52,516 52,516 52,516 TLG Sereices, Ioe.

Indian Point Energy Center, Unit 2 Document E11-1583-003 Decommissioning Cost Analysis Appendix A, Page 5 of 14 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 Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Tenm.

Managemeot Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor index Activi Descrition Cost 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 Period 2a Period-oependenl Costs 2a:4.1 Insurance 3,783 378 4,161 3,771 390 2.4.2 Property Waxs 2a.4.3 Health physics supplies 724 181 905 905 2a.4.4 Disposal of o

AW generated 12 8

117 32 168 168 2,581 51,612 20 2a.4.5 Plant energy budget 3.419 513 3,932 1,966 1,966 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 ISFSI Operating 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 2a.4.13 Security Staff Cost 14,276 2,141 16.418 4,897 11,521 381,587 2a.4.14 Utility Staff Cost 27,611 4,142 31.752 6,566 25,186 515,306 2a.4 Subtotal Period 2a Pehod-Dependent Costs 724 12 9

117 65,082 9,411 75.353 22,012 53,341 2,581

-1.612 20 896,893 2a.0 TOTAL PERIOD 2. COST 724 12 8

117 111,668 16,478 129,006 23,149 105.857 2,581 51,612 20 896,893 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 Activity Costs 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 2b.4.4 Disposal of DAW generated 43 29 425 115 612 612 9,406 188,114 74 2b.4.5 Plant energy budget 6,691 1,004 7,694 7,694 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 ISFSI Operating 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 2b.4.12 Securty Staff Cost 27,478 4,122 31,600 19,163 12,437 689,194 2b64.13 Itility Staff Cost 43,660 6,549 50,210 25,696 24,514 816,823 2b.4 Subtotal Period 2b Period-Dependent Costs 2,375 43 29 425 124,841 17,596 145,309 85,522 59,787 9,406 198,114 74 1,506,017 2b.0 TOTAL PERIOD 2b COST 2,375 43 29 425 134,155 19,300 156,327 89,971 66,356 9,406 188,114 74 1,506,017 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.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Document El-1583-003 Appendix A, Page 6 of 14 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 Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lie. Term.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt.. Lbs.

Manhouos Manhours 2c.1.4 Biturmjous roof replacement 2c3.5 Maintenance supplies 2c.

Subtotal Period 2c Activiy Costs Period 2c Period-Dependenl Costs 2c4.1 inscrance 2c 4.2 Property taxes 2c4.3 Health physics supplies 2c.4.4 Disposal of DAW generated 2c.4.5 Plant energy budget 2c,4.6 NRC Fees 2c.4.7 Site O&M 2c.4.8 Grundwaler Monitoring 2c4.9 Corporate A&G 2c4.10 Secupty Staff Cost 2c4.11 Utility Staff Cost 2c4 Subtotal Period 2c Perod-Oepeodent Costs 2c.0 TOTAL PERIOD 2. COST PERIOD 2 TOTALS 396 59 455 455 2,325 581 2,907 2,907 2,721 641 3,382 3,362 1,686 32 21 1,688 32 21 1,688 32 21 4,786 87 59 10,139 314 5,057 3,989 1,412 943 3,445 12,594 16,887 314 54,465 1,014 11,153 11,153 422 2,110 2,110 65 452 452 758 5,815 5,815 399 4,388 4,388 212 1.623 1,623 142 1.085 1,085 517 3,961 3,961 1,889 14,483 14,483 2,533 19,420 19,420 7,970 64,491 64,491 6,947 6,947 138,939 556 314

.57,187 8.611 67,653 67,853 856 303,009 44,389 353,186 180,972 172,213 6,947 18,933 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 3o.1.1 Prepare preliminary deoommissioning cost 3a.1.2 Review plant dwgs &specs.

3a.1.3 Perform detailod rod s"'oep 3a.1.4 En6 product description 3a.1.5 Oetauied by-produd inventory 3a.1.6 Define major work sequence 3..1.7 Perform SER and EA 3a.1.8 Perform Site-Specific Cost Study 3a.1.9 Prepare/submit License Termination Plan 3..1.10 Receive NRC approval of termination plan Activity Specifications 3a.1.11.1 Ro-activate plant & temporary facilities 3a.1.11.2 Plant systems 3a.ll11.3 Reactor internals 3a. 1.11.4 Reactor vessel 3a 1.11.5 Biological shield 3a.1.11.6 Steam genorators 3a.l.l1.7 Reinforced concrete 3a.1.11.8 Main Turbine 3a.1.11.9 Main Condensers 3a.1.11.10 Plant structures & buildings 3a.1.11.11 Waste management 3a.1.11.12 Facility & site doseut 3a.1.11 Total Planning & Site Preparations 3a.1.12 Prepare dismanding sequence 3a.1.13 Plan' prep. & temp. svces 3a.1.14 Design water dlean-up system 3a.1.15 Rigging/Cont. Cntd Envtps/toolingleto.

289,371 337,600 138,939 55 626,971 138,939 55 626,971 378,665 150 3,029,881 928 3,2124 714 928 5,355 2,213 3,570 2,925 61 214 47 61 349 144 233 191 9

70 70 -

32 246 246 7

7 54 54 9

70 70 52 402 402 22 166 166 35 268 268 29 219 219 a

343 194 331 303 23 145 74 19 19 145 214 42 1,852 51 395 355 29 223 201 50 380 365 45 348 348 3

27 27 22 167 167 11 86 43 3

21 3

21 22 167 54 32 246 246 6

48 24 278 2,130 1,875 39 22 43 21 21 84 24 255 5,262 2,975 5,069 4,641 357 2,228 1,142 286 2a6 2,228 3,284 643 28,401 1,714 1,000 112 17 129 129 2,419 363 2,782 2,782 65 10 75 75 2,048 307 2,355 2,355 TLG Services, Ine.

Indian Point Energy Center, Unit 2 Decommnivs t

ioning Coast Analysis Document E11-1583-003 Appendix A, Page 7 of 14 Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars)

I Activi iff-ýtie LLRW NRC Spent tuel Site Processed Bunal volumes Burial i Utirity anrt Decon Removal Packaging Transport Processing. Disposal Other Total Total Lic. Term.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor I

In*n*

A*t IVi* I ]eI*MNrlnR In a

Cast.

Cost cost....

.......ngency Cost cos"ts Cu..

Ft 3a.1.16 Procure casks/liners & containers 3a.1 Subtotal Period 3a Activity Costs Peorid 3a Additional Costs 3a.2.1 Site Characterization 3a.2 Subtotal Period 3a Additional Costs Period is Pedod-Oependenl Costs 3a.4.1 Insurance 3a.4 2 Properly taxes 3a.4.3 Health physics supplies 3a.44 Heavy equipment rental 3a4.5 Disposal of DAW generated 3a.4.6 Plant energy budget 3a,4.7 NRC Fees 3a 4.8 Sit O&M 3a.4.9 GroUndwater Monitoring 3aA4.10 Corporate A&G 3a 4.1 1 Security Staff Cost 3a.4.12 Utility Staff Cost 3a4 Subtotal Period 3a Period-Dependent Costs 3a.0 TOTAL PERIOD 3S COST PERIOD 31, - Decommissioning Preparations Period 3b Direct Decommissiooing Activities Detailed Work Procedures 3b.1 1.1 Plant systems 3b.l.1 2 Reactor inlemals 3ib.1.13 Remaining buildings 3b. 1.1 A CRD cooling assembly 3b.1l1.5 CRD housings & ICl tubes 3b.1.1.6 Incore instrumentation 3b.1.1.7 Reactor vessel 3b.1.1 8 Facility closeout 3b..t.f9 Missile shields 3b.1.1.10 Biological shield 3b.1.1.11 Steam generators 3b.1.1.12 Reinforced concrete 3b,1.1.13 Main Turbine 3b.1 1.14 Main Condensers 3b.1.1.15 Auxiliary building 3b.I.1.f16 Reactor building 3b.1.1 Total 3b.1 Subtotal Period 3b Activity Costs Period 3b Additional Costs 3b.2.1 Staff relocations expenses 3b.2 Subtotal Period 3b Additional Costs Period 3b Collateral Costs 3b.3,1 Decon equipment 3b.3.2 Pros cutting equipment 3b.3 Subtotal Period 3b Collutoral Costs 57 9

86 66 7,852 1.178 9,030 8,775 2,218 665 2,183 2,883 2,216 665 2,683 2,883 255 878 51,910 436 466 901 546t 2

23 2,733 258 1,740 51 1,862 2,558 14,994 2

23 24.745 55 603 603 109 54w 545 70 536 536 6

33 33 410 3,143 3,143 26 284 284 261 2,0f1 2.001 8

59 59 279 2,141 2,141 384 2,942 2,942 2,249 17,243 17,243 3,856 29,530 29,530 514 514 10,287 10,287 4

65,179 258.629 4

323,807 2

901 2

23 34,815 5,700 41,443 41,188 255 514 10,287 4

375,717 336 178 96 71 71 71 258 85 32 85 327 71 111 194 194 2,291 50 387 348 27 264 204 14 110 28 11 82 f2 11 82 82 11 82 82 39 297 297 13 98 49 5

37 37 13 98 98 49 376 376 11 82 41 17 127 17 127 29 223 201 29 223 201 344 2,635 2,124 39 83 49 41 127 127 22 22 511 511 3.379 t1,785 964 714 714 714 2,592 857 321 857 3,284 714 1,114 1,114 1,949 1,949 23,022 23,022 2,291 344 2,635 2,124 3,935 590 4,525 4,525 3,935 590 4,525 4,525 144 1,103 1,103 143 1,100 1,100 287 2,203 2,203 959 957 959

.957 TLG Serrices, Inc.

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

Acvity Decon Removal I ndex Activity Description Cost Cost Period 3b Period-Dependent Costs 3b4.1 Decon supplies 30 3b 42 Insurance 3043 Property taxes 3b.4.4 Health physics supplies 240 3b4.5 Heavy equipment rental 236 304.6 Disposal of DAW generated 3b.4.7 Plant energy budget 3b48 NRC Fees 3b.4.9 Site OM 3b.4.1t Groundwater Monitoring 3h.4.11 Corporate A&G 3b.4.12 Security Staff Cost 3b.4.13 Utility Staff Cost 3o.4 Subtotal Period 3b Period-Dependent Costs 30 476 3b.0 TOTAL PERIOD 3b COST 989 1,433 PERIOD 3 TOTALS 989 2.334 PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.t11 Reactor Coolant Piping 74 314 4a.t.1.2 Pressurizer Relief Tank 2

8 4a. 1.1.3 Reactor Coolant Pumps & Motors 28 123 4a.1.1.4 Pressurizer 11 76 4a.1.1.5 Steam Generators 95 4,780 4a.1.1.6 Retired Steam Generator Units 4a.1.1t.7 CRDMstlCtslSeroice Stmcture Removal 40 f1l 4a.1.1.8 Reactor Vessel Internals 61 2,444 4a.1.1.9 Vessel & Intermals GTCC Disposal 4a.1.1.10 Reactor Vessel-6,008 4a.1.1 Totols 312 13.864 Off-Site LLRW NRC Spent Foot Site Processed Burial Volumes Burial I Utility and Packaging Transport Processing Disposal Other Total Total Lic. Tem.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor 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 7

37 37 307 31 337 337 60 300 300 35 271 271 13 4

19 19 1,385 208 1.593 1,593 131 13 144 144 1,223 183 11407 1,407 26 4

30 30 944 142 1,085 1,085 1,297 194 1,491 1,491 11,102 1,685 12,768 12,768 13 18.415 2,547 19.483 19,483 13 22,640 3,768 28,845 28,334 36 57,455 9,468 70,288 89,522 290 5,800 290 5,800 511 290 5,800 766 804 16,087 2

33,036 181,829 2

214,864 2

237,886 6

613,603 4

2 32 31 158 226 204 1,040 1,040 2

2 9

12 8

42 42 53 214 170 1,135 391 2,115 2,115 354 556 617

,297 1,911 1,911 1,955 3,067 2,175 4.279 3,294 19,645 19,645 1.955 3,067 2,175 4,279 2,051 13,527 13,527 179 53 52 131 114 681 681 3,674 513 3,178 146 4,521 14,536 140536 11,347 1,702 13,049 13.049 902 439 6.382 148 8,054 21.931 21,931 9,106 7,943 4,738 31,585 292 20.637 88,476 88.476 766 766 177,710 5,523 43 43 9,557 153 336 4,324 1.274,302 3,631 2,349 258.971 1,805 37.344 16,301 3,111.893 20:108 2,850 337,344 18,381

" 3,111.93 10,800 2,850 753 2,947 81,668 2,120 2,312 376 501 324.059 16,767 803 496 104,146 6,481 2,955 954,563,

16,767 803 76,586 51,823 3,330 501 496 9.408,359 78,073 7,305 Removal of Major Equipment 4a.1.2 Main Turbine/Gonerator 4a.1.3 Main Condensers Cascading Costs from Clean Building Demolition 4.,1.4.1 Reactor Containment 4a.1.4.2 Fuel Storage Building 4a.1.4.3 Primary Auxiliary Building 4a.1.4.4 Turbine Buiding 4a.1.4.5 Waste Holdup Tank Pit 4a.1.4 Totals Disposal of Plant Systems 4a.1.5.1 Aoo Steam & Air Remova.

4a.1.5.2 Auo Steam & Air Removal (RCA) 4a.1.5.3 Aux Steam-Primary Plant 4a.1.5.4 Aux Steam-Primary Plant (RCA) 4a.1.5.5 Bearing Cooling Water 4a.1.5.6 Chemical Cleaning 4a.1.5.7 Chemical Feed 500 236 55 692 1,914 141 45 560 261 1,743 1,743 583 3,243 3,243 4,374 6,687 1,557 47 76 892 14 2.387 234 1,791 1,791 7

54 54 11 88 88 104 796 796 2

16 16 358 2,745 2.745 130 744 744 26 151 151 15 88 88 22 123' 123 43 330 91 699 1

11 371,814 7,141 300,932 27,443 14,977 422 758 7,864 142 24,163 377 73 44 65 287 607 10 5

17 216 1

4 47 1

2 26 1

3 33 2,856 624 347 431 330 699 11 115,977 5,429 25,326 1,040 14,081 628 17,506 909 4,420 9,466 155 TLG Services, Im.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Doenment El1.1583-003 Appendix A, Page 9 of 14 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 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 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 Disposal of Plan( Systems (continued) 4a.1.5.8 Chemical Food (RCA) 4a.t.5.9 Chemistry Monitoring 4a.1.5.10 Circulabng & Service Water 4a.1 5.11 Circuloaing & Service Water (RCA) 4a.1.5.12 Compressed Air 4a.1.5.13 Condensate 4a.1.5.14 Oeminereiizsr Regeneratlon 4a.1.5.15 Electro Hydraulic Fluid 4a.1.5.16 extraclion Stlam 4a.1.5.17 Feeodater 4a.1.5.18 Feedwater Emergency Make-Up 4a,15.19 Flosh Evaprator 4a.1.5.20 HVAC - Clean 4a.1.5.21 Heating Soam & Condensate 4:.1.5.22 Heating Stlam & Condensate (RCA) 4a.1.5.23 Hoating Steam & Condensate - FHB 4a.1.5.24 Helium & Vacuum Drying 4a.1.5.25 Hypechiorita Feed 4a.1.5.26 IP2 Petroleum Storage Tanks 4a.1.5.27 LP Heater Drains & Vents 4a.1.5.28 Low Lovon Intake Fish Screen Wash 4a.1.5.29 Low Level Vacuum Priming House 4a.1.5.30 Lube Oil 4a.1.5.31 Lube Oil Lines 4a.1.5.32 Main Gen Hydrogen Gas 4a.1.5.33 Main Stean 4a.1.5.34 Main Steam (RCA) 4a.l.5.35 Misr. Drains-Secondary Plant 4a.1.5.36 Moisture Separator & HP HTR DR & V 4a.1.5.37 Polymer Food 4a.1.5.38 Rod Monilor Circ & Ser WIr 4a.1.5.39 Red Moniltor Cont Particulate 4a.1.5.40 River Water Filtration 4a.1.5 41 Serice Water Fuel Oil 4a.1.5 42 St Gen Fd Pmp Lube Oil & Seal Water 4a.1.5.43 Sloan GOn Nitrogen Conn 4a.1.5 44 Steam Generator Siowdown 4aiS545 Stlam Generator Blowdown (RCA) 4a.1.5.46 SteaGenerator Blowdown Recrc & Xfer 4a.1.5.47 Turbine Generator Seal Oil 4a.1.5A8 Turbine Gland Steam 4a.1.5.49 Vacuum Priming 4a.1.5,50 Waste Holdup Tank Pit 4a.1.5.51 Water Tank 4..1.5 Totals 4a.1.6 Scaffolding in support of decommissioning 4a.1 Subtotal Period 4a Activity Costs Period 4a Collateral Costs 4:.3.1 Process liquid waste 4a.3.2 Small tool allowance 4a.3.3 Survey and Release of Scrap Metal 4a.3 Subtotal Period 4a Collateral Costs 52 3

1,548 66 115 2,158 51 7089 1.104 76 250 974 233 29 105 4

1 168 729 15 3

S 10 20 3

1,154 286 2

1,577 I

2 1

96 21 23 9

42 2

403 6

45 1694 314 197 14,273 511 6

2 22 O

0 1

5 65 244 3.051 2

9 ill 62 235 2,934 0

2 22 0

0 5

21 80 999 45 91 625 321 21 67 751 58 2

9 117 O

1 16 1

3 39 10 37 458 28 105 1,309 7

26 322 0

0 1

58 219 2,739 0

0 0

0 2

23 0

0 1

3 12 148 28 44 291 166 363 1,214 14.307 546 8

3 32 5

17 93 93 1

5 5

888 6

,796 5,796 35 222 222 17 133 1,021 6,410 6,410 16 92 92 3

18 18 341 2,150 2,150

. 468 2,654 2,654 11 87 37 287 383 2,254 2,254 78 440 440 10 "57 57 32 179 179 1

4 0

1 25 193 257 1,491 1.491 2

18 0

4 2

12 3

23 8

3 503 3,099 3,099 124 765 765 1

4 4

844 5,437 5,437 0

1 1

3 3

0 2

2 14 110 3

24 4

27 1

10 14 82 82 1

4 4

125 691 691 1

7 7

52 29 223 173 1,017 1,017 30 227 5,853 36,556 34,071 135 695 695 292 27,827 133,458 130,973 292 7

1 40,386 S -

1,464 133 38,847 289 71 13,226 8-,272 1,485 87 287 9,948 265 1,555 209 S -

510 4

193 6,067 18 4

12 233 17,328 4,2619 36,260 I

6 3

110 24 27 10 310 13 S -

1,957 7

52 223 3,855 994 227 2,485 189,404 2,744 S -

377 23 2,485 277,429 54,590 3.330 280 54 54 280 11,867 671 384 45 1,640,086 22,748 59,459 967 1,791 1,577,580 31,510 11,751 706 2,899 127 537,096 10,471 467,630 16,058 1,129 3,663 427,750 13,262 63,162 3,337 8,489 411 20,715 1,391 57 15 2,430 246,398 10,548 230 47 165 305 38 703,710 16,938 173,056 4,205 352 31 1,472,533 23,061 16 249 30 125 15 1,467 307 344 140 12,591 575 525 29 79,489 5,622 688 715 2,990 224,597 4,578 2,834

-7,915,381 208,356 19,059 8,247 501 496 18,015,550 353,423 7,305 16,780 55 16,780 55 312 33,449 9,854 9,260 20,328 32,135 36 20 110 472 36 472 20 110 78 78 111 111 56 299 299 71 543 488 33 144 144 160 985 931 TLG Services, Inn.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Document Eil-1583-003 Appendix A, Page 10 of 14 Table A Indian Point Energy Center, Unit 2 SAFSTOR Decommissioning Cost Estimate (thousands of 2007 dollars) i Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. 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 4a4.2 Insurance 4a.4.3 Property taxes 4..4A Health physics supplies 2,148 4..4.5 Heavy equipment rental 2,430 4a.4.6 Disposal of DAW generated 4a.4.7 Plant energy budg-t 4a.4.8 NRC Fees 4a.4.9 Site O&M 4.A10 Radwaste Processing EquipmentvServices 4,4.11 Groundwater Monitoring 4s.4.12 Corporate A&-

4.4..13 Security Staff Cost 4,4.14 Utlity Staff Cost 4a.4 Subtotal Period 4a Period-Dependenl Costs 63 4,578 4..6 TOTAL PERIOD 4a COST 410 38,499 23 23 16 16 646 228 2,776 368 3,073 397 54 1,990 2,733 24,803 228 36,839 9,897 9,385 20,328 32,441 37,241 PERIOD 4b -Site Decontamination Period 46 Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks Disposal of Plant Systems 4b.1.2.1 Borov Recovery 40.1.22 Cheorical & Volume Control 46.1.2.3 Component Cooling Water 4b.1.2.4 Component Cooting Water (RCA) 40.1.2.5 Component CooingWaeter-FHB 4b.1.2.6 Compressed Air (RCA) 4b.1.2.7 Containment Hydrogen Analyzer (RCA) 4b,1.28 Containment Instrument Air 4b.1.2.9 Containment Instrument Air (RCA) 4b.1.2.10 Corlairmerl Sprny 4b.1.2.11 Containrmor Spray (RCA) 46.1.2.12 Containmoen Vacuum & Leakage Monior 4b.1.2.13 Decontamination 4b.1,2.14 Electrical - Clean Nov RCA 4b.1.2,15 Electrical -Clean RCA 4b.1.2.16 Electrical - Corlaminated 4b.1.2.17 Elecltcal - FHB 4b.1.2.18 Fire Protecton & Domestic Wtoar 4b.1.2.19 Fire Protecton & Domeisc Water (RCA) 4b.1.2.20 Fuel Pit (RCA) 4b.1.2.21 Fuel Pit-FH3 4b.1.2,22 Gaseous W.ste Disposal 4b.1.2.23 Gaseous Wasle Disposal (RCA) 4b.1.2.24 Gaseos Waste Disposal - FHB 4b.1.2.25 HVAC - RCA (FH8) 4b.1.2.26 HVAC-RCA (Other) 46.1.2 27 Hydraulic Fluid -Personnel Hatch 4b.1.2.28 Oxy9en (RCA) 4b.1.2 29 Rsdislion Monitoring 4b.1.2.30 Rediation Monitoring (RCA) 4b.1.2.31 Reactor Cavity Purification 4b.1.2.32 Reactor Coonant 519 60 158 71 992 508 468 1,380 109 126 14 15 23 187 170 62 29

-1.749 2,991 432 29 174 32 189 27 53 60 2

8 260 1

2 85 60 226 36 20 35 645 1

0 0

2 2

S S

46 6

0 1

14 2

2 2

0 0

6 0

0 0

30 22 80 31 72 119 7

3 0

1 9

1 165 20 1

3 31 25 4

0 20 0

0 4

35 562 693 192 148 153 563 212 714 489 39 32 38 5

10 107 33 19 2,058 218 17 11 1

33 247 89 3

10 40 14 20 18 1

0 7

256 0

1 2

2 8

24 121 201 16 78 78 65 711 711 537 2,686 2,686 364 2,794 2,794 62 329 329 416 3.191 3,191 37 404 404 461 3,534 3.534 60 457 457 8

63 63 298 2,288 2,288 410 3,143 3,143 3,720 28,524 28,524 6,454 48,201 48,201 34.441 182,644 180,105 442 1,812 1,812 416 2,410 2,410 194 1,055 1,055 269 1,619 1,619 599 3,365 3,365 43 235 235 38 205 205 4

23 23 2

17 7

42 42 28 215 60 348 348 21 118 118 10 60 60 262 2,011 1,066 6,345 6,345 149 842 842 9

52 52 26 201 13 81 81 113 683 683 I0 54 54 24 138 138 23 128 128 1

4 4

3 19 19 107 649 649 0

1 1

1 5

5 2

13 13 2

9 9

23 121 121 132 737 737 5,048 5,048 2,539 277.429 59,918 3,330 2,565 9,177 959 1,961 710 7,455 971 9,452 2,236 519 147 501 65 17 130 215 1,412 431 246 2,011 27,243 2,891 77 149 4

201 431 3,273 408 38 47 525 67 265 82 18 1

87 3,3863 19 28 26 106 108 1,607 920 100,961 69,643 407,829 100,961 40 477,471 991 496 18,133,290 353,517 484,777 40 230,191 1,001 451,542 14.292 142,481 7,226 389,526 6,872 584.390 19,968 34,230 1,972 20,360 1,774 2.637 180 233 5,274 298 2,790 57,345 2,357 17,512 850 10,000 384 25,964 1,106,350 42,545 124,323 6.225 6,410 420 2,619 17,501 448 169,518 2,720 5,790 363 27,151 778 18,116 870 812 25 3,526 110 137,500 3,176 125 11 767 36 1,152 116 1,061 73 13,973 814 147,766 3,319 TLG Servicea, Inc.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Document El1-1583-003 Appendix A, Page 11 of 14 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 Activity 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]

endox Activity Description Cost Cast Costs Costs Costs Ctstsiens Costs Cssts Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.

Manhours Manhours Disposal of Plant Systems (continued) 4b.1 2.33 Recirculating Spray 4b.1.2 34 Residual Heat Removal 4b.1.2.35 Safety Injetone 4b.1.2.36 Sampling 4b.1.2.37 Sampling (RCA) 41b1.2.38 Service Air -Station Btack Out 4b.1.2.39 Vent & Drain 4b.1.2.40 Vevt & Drain (RCA) 4b.1,2.41 Waste Disposal 40.1.2.42 Waste Disposet (RCA) 4b.1.2.43 Waste Neutralization 4b.1.2 Totals 4b.1.3 Scaffolding in support of decommissioning Decontamination of Site Buildings 4b.1.4.1 Reactor Containment 4b.1,.4.2 Discharge Canal 4b.1.4.3 Fuel Storage Building 4bt.4.4 Maintainance & Outage Building 4b.1 4.5 Petroleum Tank Excavation 4b.1.4.6 Primary Auxiliary Building 4b.1,4,7 Turbine Building 4b.1.4.8 Waste Holdup Tank Pit 4b1.4 Totals 4b.1 Subtotal Period 4b Activity Costs Period 41b Additional Costs 4b1,21 Final Site Survey Program Management 4b.2.2 ISFS5 License Termination 4b.2.3 AOC PCB Soil Remediation 4b.2.4 AOC Soil Remediation 4b.2 Subtotal Period 41b Additional Costs Period 4b Collateral Costs 4b.3.1 Process liquid waste 4b.3.2 Small tool atowance 4b.3.3 Decommissioning Equipment Disposition 45.3.4 Survey and Release of Scrap Metal 4b.3 Subtotal Period 4rb Collateral Costs Period 4b Period-Dependent Costs 4b.4.1 Dacwn supplies 4b.4.2 Insurance 4b.4.3 Property taxes 4b.4.4 Health physics supplies 4b.4.5 Heavy equipment rental 40.4.6 Disposal sf DAW generated 4b.4.7 Plant energy budget 4b.4.8 NRC Fees 4b.4.9 Sits O&M 4b.4.10 Radwaste Processing EqaipmenoSeices 4b.4.11 Grousdwatcr Monitoring 4b.4.12 Curporate A&G 4b.4.13 Security Staff Cost

340 414 260 30 86 3

74 27 160 205 63 12.053 767 1,415 938 151 445 490 31 3

12 226 75 402 909 43 12 2,581 2,589 3,081 15,468 647 285 72 1,004 68 390 66 390 775 1,806 2,943-41 88 736 227 13 50 628 1

1 3

4 2

2 2

14 5

1 8

1 3

33 1

2 4

13 12 17 58 96 16 18 15 132 1

3 34 356 799 6.917 1,939 13 5

47 6

43 138 233 543 72 275 406 8

14 145 27 1

0 3

36 137 203 11 10 33 57 431 1,655 2.448 2

2 4

11 602 2,231 415 3,699 1,130 3,106 7,379 6,207 269 1,701 1,701 207 1,312 1,312 39 299 9

46 46 26 131 131 2

14 14 24 135 135 11 57 57 76 418 418 91 477 477 21 122 122 4,453 26,516 23,775 203 1,042 1,042 1,138 4,448 4,448 188 1,091 1,091 376 1,504 1,504 17 55 55 78 466 466 153 564 564 1,332 7,177 7,177 28 102 102 3,310 15,407 15,407 8,407 44,779 42,036 196 848 a48 298 1,800 619 3.399 3.399 228 1,272 1,272 1,341 7.318 5,518 106 569 569 59 449 449 118 896 896 268 1,162 1.162 551 3,077 3,077 194 969 969 79 868 868 452 2,258 2,258 441 3,3a4 3,384 47 248 248 401 3,075 3,075 45 493 493 381 2,922 2,922 73 557 557 10 76 76 364 2,793 2.793 155 1,187 1,187 9,746 1,038 8,313 299 40 19" 23 63 103 442 49 58 762 458 200 605 448 2.743 91.572 8,978 565 35 3,084 10,190 15.633 1,924 647 S -

119 7,803 434 2,122 94,163 54 404 5,496 131,080 2.743 97,633 142,659 3,189 99.394 24,481 127.064 488,849 4,882 337,582

. 6,055 4,011 3,369 449 6,598 1,301 4,184 48 17,945 1,031 7,169 367 70,158 2,271 62,389 2,713 18,194 854 4,513,573 173,408 26,588 12,370 921,883 32,755 1,563,309 1,796 141,972 13,098 11,909 483 780,300 173 229,089 4,203 9,416,250 16,710 42,501 770 13,107,200 69,989 17,879,560 256,768 382,518 8.165 10.436,000 2,331 1,860,556 604 12,679,070 11,100 31,991 104 303,507 88 335,498 192 76,334 30 2

103 93 622 7

323 101 1,048 38 209 135 59 173 268 652 86 663 1,781 643 2,509 1,315 148 502 82 894 502 230 894 789 173 2,674 449 2,541 485 67 2,428 1,032 1,800 6,240 1,280 7,520 533 6,000 373 6,000 907 3,817 17 12 29,240 TLG Services, Inc.

Indian Point Energy Center, Unit 2 Decommissioning Cost Anotlyis Docurment E11-1583-003 Appendix A, Page 12 of 14 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) 44b..14 Utility Staff Cost 19,535 4b.4 Subtotal Period 4b Period-Dependent Costs 775 4,749 17 12 173 29.9999 4b.0 TOTAL PERIOD 41 COST 3,924 21,612 1,421 4.435 7,882 9,119 32,208 PERIOD 4d -Delay before License Termination Period 4d Period-Dependent Costs 4d.4.1 Insuranco 4d.4.2 Property taxes 4d.4.3 Health physics supplies 60 4d.4.4 Disposal of DAW generated 3

4d.4.5 Plant energy budget 181 4d4.6 NRC Fees 143 4d.47 Site O&M 73 4d.4.8 Groundwater Moniolorsg 34 4d.4.9 Corposato A&G 1,235 4d.4,10 Security Staff Cost 8

4d.4.11 Utility Staff Cost 506 4d.4 Subtotal Period 4d Period-Dependent Costs 60 8

3 2,179 4d.0 TOTAL PERIOD 4d COST 50 0

0 3

2,179 PERIOD 4e-License Termination Period 4e Direct Decommissianing Actiilties 4e.1.1 ORISE confltrntory survey 152 4e.1.2 Terminate license 4e.1 Subtotal Period 4e Activity Costs 152 Period 4e Additional Costs 4a,2.1 Final Sitl Survey 7.880 4e.2.2 Staff relocations expenses 3,935 4e.2 Subtotal Period 4a Additional Costs 11,814 Period 4e Perod-Dependent Costs 4o.4.1 Insuranco 4..4.2 Property taxes 4e.4.3 Health physics supplies 817 4a.4.4 Disposal of DAW generated 2

1 15 4e.4.5 Plant energy budget 412 4e.4.6 NRC Fees 259 4.4.7 Site O&M 719 4e.4.

A Grondwater Monitoring 38 4e4.9 Corporat. A&

1,403 4e.4.10 Security Staff Cost 476 4o.4.11 Utility Staff Cost 6,319 4e.4 Subtotal Period 4e Perod-Dependenl Costs 817 2

1 15 9,827 4e.0 TOTAL PERIOD 4. COST 817 2

1 15 21.594 2,930 22,485 22,485 5,571 41,297 41,297 15,870 96,470 91,928 15 74 74 1

4 4

27 208 208 14 157 157 11 84 84 5

39 39 185 1,420 1,420 1

9 9

76 582 582 335 2,578 2,578 335 2,578 2,578 46 198 198 46 198 198 2,364 10,243 10,243 590 4,525 4,525 2,954 14,768 14,768 204 1.021 1,021 4

21 21 62 474 474 26 285 285 1098 827 827 6

44 44 210 1,613 1,613 71 548 548 948 7,267 7,267 1,639 12,100 12,100 4,639 27,067 27,067 55,286 308.759 301,677 3,817 1,800 2,743 103,633 274,446 337,280 76,334 30 366,520 30,970,460 268,090 374,040 66 1.322 66 1,322 66 1,322 1

4,149 9,680 1

13,829 1

13,829 113,935 3,120 113,935 3,120 330 6.603 3

11.786 95,494 330 6,603 3

107,250 330 6,603 113,938 110,370 1,800 5.282 381.062 334,761 3,330 501 496 49,111,670 735,546 983,015 PERIOD 4 TOTALS 4,334 60,988 11,320 13,821 28,209 41,578 93,223 TLG Services, Inr.

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

E IActivity Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Decor Remooat Psclaging Transport Processing Disposal Other Total Total Lic. Term.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Cost Cot Coots tosto toots Costs CostF Contineono tosto toots tests Costo tu Feat Cu. Feat Cuo Fot C, Feet to. Fit Wt. Lbs.

Uaohoum MunhoomU I

IN*X A*t IVI* u*scno[lon Ind..

-norv u...

11 oun Costs Costs Costs Costs Costs Contingency Costs Costs Cast.

Costs Cu Fast Cu Fast Cu Fast Cu isat Lbs.

Uarthours; Uanhoum PERIOD Sb - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b.1.1.1 Reactor Containment 51b1.1 2 Buried Fuel Oil Tanks 5b1.1.3 Control Building 5b1.1.4 Diesel Generator Building 5b.1.1.5 Electrical Penetrations Building 5bt1.1.6 Electrical Tunnel & Retaining Walls 51b.11.7 Equipment Hatch Enclosure 5b.1.1.8 Fan House 5b,1.1.9 Fuel Storage Building 5b.1.1.10 Maintainance & Outage Building b.t..l 11 Misc Structures 51b.1 1 2 Petroleum Tank Excavation 5b.1.1.13 Primary AuxtiaLry Buslding 5b.1.1.14 Screenwelt Structure 5b 1.1.l5 Steam Generator Storage Facility 51b.11.16 Tank Pads & Foundations 51..1.1.7 Transformer Pad S

lS.1.16 Turbine Building 5b.1.1.19 Turbine Pedestal 5b.1.1.20 Waste Holdup Tank Pit 5b.1.1.21 Water Tank and Meter House 5b.I.1 Totals Site Closeout Activities 51.1.2 BackFill Site 5S.1.3 Grade & landscape site 5b.1.4 Final repeI to NRC 5b.1 Subtotal Period 5b Activity Costs Period 5b Additional Costs 5b2.1 Concrete Crushing 5b.2.2 ISF15 Demolition and Restoration 5b.2.3 Unit 1 Legacy Soil Remediation 5b.2 Subtotal Period 5b Additional Costs Penod 5b Collateral Costs Sc3.1 Small tool allomance 5b.3 Subtotal Period 5b Collateral Costs Period 5b Period-Dependent Costs 5b.4.1 insurance 51b.4 2 Property taxes 5b.4.3 Heavy equipment rental 5b.4.4 Plant energy budget Sb.4.6 Site O&M 5b.4.6 Groindwater Monitorng 51b.4.

Corporate A&G 5b.4.8 Security Staff Cost 5b4.9 Utility Staff Cost 5b4.

Subtotal Period 5b Period-Dependent Costs 5o.0 TOTAL PERIOD 5b COST 8,833 4

26 139 160 50 36 1682 316 279 5,302 15 713 1,228 709 156 119 814 1.091 81 26 20,278 4,226 7

24.511 486 1,086 586 2,158 338 336 9,291 9,291 36,296 111 3

22 6,698 6,698 25 1,325 10,158 1

5 4

30 21 160 24 184 8

58 5

41 27 209 47 363 42 320 795 6,097 2

17 107 820 184 1,412 106 816 23 179 18 137 122 936 164 1,254 12 93

4.

30 3.042 23,320 634 4,860 1

0 17 127 127 3,693 28,315 127 73 563 166 1.274 2.335 13,066 13,066 2,574 14,903 13,066 50 387 50 387 1,394 10,604 164 1,260 290 2,225 2,225 31 235 235 1,120 8,583 6,583 341 2,617 4,320 33,122 7.660 58,727 11,044 13,979 102,332 24,237 10,158 5

30 160 184 58 41 209 363 320 6,097 17 820 1,412 816 179 137 936 1,254 93 30 23,320 4,8608 28,188 563 1,274 1,274 563 114,987 50 335 1,688 1.487 507 325 1,656 3,147 3,353 57,848 154 7,190 9,322 7,951 1,814 1,382 9,792 8,915 806 281 202,992 10,846 27 21 6

1,114 213,864 1,114 68 3,379 68 3,379 255,173 255,173 2,031 1,590 80 19,494.000 5,12 19,464,000 8,749 80 387 387 6B 3,379 1,096 1,935 204 7,464 2,276 28,802 41,777 6,698 41,913 10,6a4 1.260 2,617 33,122 47,684 1,274 76,821 255,173 55,427 426,360 481,787 19,494,000 222,613 482,981 TLG Services, IJe.

Indian Point Energy Center, Unit 2 Decommissioning Cost Analysis Dosesment E1l-1583-003 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 TOTAL COST TO DECOMMISSION 36,296 68 3,379 6,698 41,913 13,978 102,332 24,237 9,737 107,885 11,653 18,286 28,209 50,090 559,122 135,494 920,477 659,351 1,274 76,821 255,173 19,494,000 222,613 482,981 178,257 82,869 381,062 620,166 3,330 501 496 69,257,500 1,018,835 5,842.571 TOTAL COST TO DECOMMISSION WITH 17.26% CONTINGENCY:

$920,477 thousands of 2007 dollars TOTAL NRC LICENSE TERMINATION COST IS 71.63% OR:

$659,351 thousands of 2007 dollars SPENT FUEL MANAGEMENT COST IS 19.37% OR:

$178,256 thousands of 2007 dollars NON-NUCLEAR DEMOLITION COST IS9% OR:

$82,869 thousands of 2007 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

623,997 cubic fast TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:

496 cubic feet TOTAL SCRAP METAL REMOVED:

37,492 tnns TOTAL CRAFT 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 -ero value TLG Sercices, Inc.

v t e Letter Sequence Request
TAC:ME0020, (Open)
Initiation Request, Request Acceptance... Supplement Administration Questions 13 May 2009 Answers 15 July 2009 Results Approval Other:
MONTHYEAR2009-05-28 [Table View]

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)

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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)

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