ML11299A019

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Independent Spent Fuel Storage Installation, Response to NRC Request for Additional Information on Decommissioning Funding Status
ML11299A019
Person / Time
Site: Rancho Seco
Issue date: 10/19/2011
From: Ronningen E
Sacramento Municipal Utility District (SMUD)
To:
Document Control Desk, NRC/FSME
References
DPG 11-566
Download: ML11299A019 (32)
v • d • e


Text

SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT

~TL The Power To Do More.

P.O. Box 15830, Sacramento, CA 95852-1830; 1-888-742-SMUD (7683)

DPG 11-566 October 19, 2011 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555 Docket No.50-312 Rancho Seco Independent Spent Fuel Storage Installation License No. DPR-54 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON DECOMMISSIONING FUNDING STATUS Attention: John Hickman This letter is in response to the request for additional information (RAI) dated September 22, 2011. Attached for your information is the 2010 Decommissioning Cost Estimate.

It is understood that this information is required to be submitted per the regulations referenced in the RAI, and the 2011 Decommissioning Cost Estimate will be modified to include all required information to preclude the need for future RAI's.

RAI #1:

On March 29, 2011, SMUD provided the following radiological decommissioning costs associated with the license termination for Rancho Seco:

The total decommissioning costs are now estimated to be $504.3 million, with an estimated $22.2 million in remaining costs.

Per 10 CFR 50.75(f)(1),

The information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c);

RANCHO SECO NUCLEAR PLANT

  • 14440 Twin Cities Road, Herald, CA 95638-9799; (209) 333-2935

Provide the amount of decommissioning funds estimated to be required under 10 CFR 50.75 (b) and (c).

Response to RAI #1:

10 CFR 50.75(b) by reference to 50.33(k) requires submittal of information to demonstrate reasonable assurance that decommissioning funds will be available and 10 CFR 50.75(c) provides the basis for establishing a minimum amount of funding.

Per the calculation required by 10 CFR 50.75(c), the minimum estimated amount required for decommissioning Rancho Seco (2,770 MW thermal) is:

$445.7 Million As a comparison, San Onofre Units 1 and 2, which are each rated at 3,448 MW thermal, declare a minimum decommissioning estimate per 10 CFR 75(c) to be

$470.9 million as of December 31, 2010 (ADAMS Accession Number ML110900660).

The site-specific estimate for Rancho Seco is $504.3 million, but includes the following costs which may be considered non-Decommissioning costs:

  • Part 72 License Termination: $1.88 million This would result in an estimate of $502.4 million, which exceeds the minimum amount required by 10 CFR 50.75(c) for Rancho Seco as well as exceeding the minimum amount required for a facility with a higher power rating.

RAI #2:

On March 29, 2011, SMUD referenced a site-specific cost estimate for the amount of decommissioning funds estimated to be required.

Per 10 CFR 75(e)(1)(i) and (ii),

The licensee must specifically describe the safe storage period in order to take credit for projected future earnings when it uses a site-specific estimate as the basis for using the prepayment or external sinking fund methods of financial assurance.

Provide the most recent site-specific cost estimate for Rancho Seco, unless it was previously submitted to NRC. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site-specific cost estimate should include a summary schedule of annual expenses,

projected earnings, and end-of-year fund balances. Pursuant to 10 CFR 50.75(b), the cost estimate shall be in an amount that may be more, but not less, than the amount estimated to be required under 10 CFR 50.75(b) and (c).

Response to RAI #2:

The 2010 Decommissioning Cost Estimate for Rancho Seco is attached.

Additional information is provided as follows:

  • End-of-year Fund Balance: as reported in the Decommissioning Funding Status Report, the Trust Fund contained $30.2 million at the end of 2010. This exceeds the estimated Total Remaining Costs of

$22.2 million.

  • Identification of Non-Decommissioning Costs: the following costs are included in the Decommissioning Cost Estimate, but are not required to be included:

o Part 72 License Termination $1.88 million o This reduces the remaining decommissioning costs to $20.4 million, well below the existing Fund Balance.

  • Projected earnings: since the Decommissioning Trust Fund is fully funded (actually, currently estimated to be over-funded), projected earnings are not providing a basis for assuring sufficient decommissioning funding. Therefore, no information on projected earnings is provided.
  • The safe storage period as described in the Decommissioning Cost Estimate lasts until 2028 when the low-level radioactive waste in storage will be disposed. Since sufficient funds are available, SMUD may choose to accelerate the process which does not affect the Estimate nor Funding since future earnings are not required to provide funding assurance.

If you or members of your staff have questions requiring additional information or clarification, please contact me at (916) 732-4817.

Sincerely, Einar Ronningen Superintendent, Rancho Seco Assets Attachment

2010 DVCOMMI5510NING COST E_5TIMATE RANCHO SECO DECOMMISSIONING

Page ii of iv APPROVALS Approved by:

Superintendent, Rancho Seco Assets Einar T. Ronningen On the cover: IOSB - regulated by Part 50 license ISFIS - regulated by Part 72 license

Page iii of iv TABLE OF CONTENTS PAGE Approvals ............................................................................................................... ii Revision Log .................................................................................................... iv Summ ary ................................................................................................................. 1 Background .................................................................................................... 2 Introduction....................................................................................................... 4 History of Rancho Seco Decommissioning and Cost Estimates .................... 4 Phased Decom m issioning .............................................................................. 7 M ethodology and Approach .............................................................................. 8 Update M ethodology ..................................................................................... 8 Overview of Decommissioning Cost Estimate Components ......................... 8 Financial Com ponents of the Cost M odel ....................................................... 10 Assum ptions ........................................................................................................... 11 Used Fuel .......................................................................................................... 11 Reactor V essel and Internal Com ponents ................................................... 11 Transportation M ethods .............................................................................. 12 Low-Level Radioactive W aste D isposal ..................................................... 12 Estim ating Basis .......................................................................................... 12 Labor Costs .................................................................................................. 13 General ............................................................................ ................................... 13 Glossary of A cronym s and Abbreviations ........................................................ 14 References .............................................................................................................. 15 TABLES

1. Summary of Decommissioning Cost Contributors ..................................... 16
2. Decom m issioning Cost Estim ate - Phase II .............................................. 17
3. Decom m issioning Cost Estim ate - Phase I ................................................ 19

Page iv of iv REVISION LOG Revision 0: 12/15/10

Page I of 25 2010 DECOMMISSIONING COST ESTIMATE

SUMMARY

The remaining cost projected to complete the decommissioning of The Rancho Seco Nuclear Generating Station (Rancho Seco) is $22.2 million. This includes all projected costs to terminate both the Part 50 and Part 72 licenses. In 2009, Phase I license termination activities were completed and modification of the Part 50 license was approved by the Nuclear Regulatory Commission (NRC). Phase I costs (completed in 2009) totaled $482.0 million. As of 2010, Phase II expenditures totaled $0.1 million, with costs for remaining activities total $22.2 making the total 2010 Decommissioning Cost Estimate $504.3 million. Remaining activities include: the transfer of stored fuel and Greater Than Class "C" (GTCC) Radioactive Waste to the Department of Energy (DOE)' in 2027; disposal of Class B & C waste (resins and reactor vessel internal components) in2028 and oversight of that waste until disposal; and license termination activities following transfer of the stored materials. A summary of the major remaining decommissioning cost contributors is provided in Table 1. The cost estimate includes nuclear fuel storage costs only through 2008. Beginning in 2009, fuel costs are considered a normal operation and maintenance (O&M) expense and are not included in the-Decommissioning Cost--Estimate=.-... ..

Cost changes in this estimate are based on inflation of the previous estimate. The costs for the decommissioning line items by category and as a schedule of expenditures are provided in Tables 2 and 3: Table 2 contains the information for Phase II actual and future expenditures and Table 3 outlines the actual costs for Phase I of decommissioning.

With Phase I of radiological decommissioning complete, the single largest remaining cost is waste disposal. The GTCC disposal is now a significant portion of the remaining cost representing 15% of the total. The Class B & C waste produced during Phase I of the license termination process remains in storage until a suitable disposal facility becomes available, conservatively estimated to occur just after the DOE takes possession of the waste stored at the Independent Spent Fuel Storage Installation (ISFSI). The projected costs for disposal of all Class B & C Wastes represent 53% of the total. Oversight of the stored Class B & C waste accounts for 10%, while the License Termination costs for both licenses represent 22% of the remaining costs.

BACKGROUND Rancho Seco is located approximately 25 miles southeast of Sacramento, California. The industrial facility is 87 acres and sits within a 2,480-acre plot of land that is owned by the SMUD believes that the DOE has been paid for and is responsible for the GTCC disposal under the terms of the Standard Contract. However the DOE does not agree, thus, as a prudent business contingency, funds are set aside in the Cost Estimate and Trust Fund.

Page 2 of 25 Sacramento Municipal Utility District (SMUD). The station was comprised of a single B&W-designed generation unit with support facilities.

Rancho Seco commenced reactor operations September 16, 1974, and began commercial operation April 18, 1975. SMUD permanently terminated operations at Rancho Seco on June 7, 1989 following passage of a public referendum June 6, 1989. The reactor was completely defueled on December 8, 1989 and a Possession Only License,a long with Permanently Defueled Technical Specifications,be came effective April 28, 1992.

On May 20, 1991, SMUD submitted a proposed Decommissioning Plan to the NRC that outlined the decommissioning option of Hardened SAFSTOR. This alternative put the fuel in dry storage and placed the plant in a safe, dormant condition with a small site maintenance staff until 2008 when a Decommissioning Operations Contractor would be brought in to complete decommissioning. This allowed for the Decommissioning Trust Fund to be fully funded before dismantlement began. The NRC issued a decommissioning order and approved the Rancho Seco decommissioning funding plan on March 20, 1995.

Beginning in 1995, TLG Services, Inc. (TLG) provided SMUD with alternative cost estimates that included options for the decommissioning of the facility. Delays in the Fuel Dry Storage project caused increases in projected costs, and the alternatives were provided-to -take-advantage-of-the-available-opportunities,-including:--availability of-.

SMUD Staff on site to support dismantlement due to delays in the Fuel Dry Storage project, and; availability of Envirocare's Clive, Utah disposal facility (Envirocare is now EnergySolutions) as an appealing option for low level radioactive waste (LLW) disposal.

Transfer of fuel to dry storage in the Part 72 licensed ISFSI was completed August 22, 2002.

In January of 1997, SMUD Board of Directors (the Board) approved the Incremental Decommissioning Project, and dismantlement of the facility began in earnest. In 1999, the Board approved expansion of the Incremental project to include all activities necessary for license termination. In April of 2006, SMUD submitted the License Termination Plan (LTP) to the NRC, outlining the activities necessary for the NRC to allow license termination. The LTP was approved by the NRC in November 2007. In September 2009 the NRC approved the request for modification of the Part 50 license.

Only the Interim Onsight Storage Building (IOSB) and the land enclosed by the exterior fence (approximately 1 acre) remains licensed under Part 50.

With the closure of the Barnwell, S.C. waste disposal facility, there are no options for disposition of Class B and Class C LLW available to SMUD. EnergySolutions is currently pursuing licensing of a process that would allow disposal of the stored resin at their Clive, Utah facility. Waste Control Specialists (WCS) was awarded a license for disposal of all classifications of LLW in 2009 and has begun construction of their LLW facility in Andrews, Texas. The facility is currently scheduled to begin operations in late 2011 and will initially accept in-compact waste only. However, WCS is working with

Page 3 of 25 the newly formed Texas Low Level Waste Compact Commission to allow importation of waste from other compacts in the future.

This cost estimate assumes the following: DOE acceptance of the used fuel and GTCC waste in 2027; disposal of the Class B & C radioactive waste in 2028.

Page 4 of 25 INTRODUCTION This decommissioning cost estimate is prepared to satisfy the requirements of Title 10 of the Code of Federal Regulations, Part 50.75. The origin of this cost estimate is the area-based decommissioning cost estimate prepared in 1999 and later updated in the year 2000 by TLG. Subsequently, SMUD staff updated the estimate in the years 2001 through 2005. Each of these updates prepared by SMUD staff was reviewed by TLG. Since 2006, updates are performed by SM1UD staff without outside agency review. SMUD staff has determined that outside review is not necessary because all activities involving significant cost and/or schedule risk have been completed. This cost estimate updates the 2009 estimate. The current cost estimate for decommissioning Rancho Seco is $504.3 million.

The technical portion of the TLG cost estimate was based on system and component removal and facility decontamination which is complete and the remaining waste is stored in containers ready for shipment: there is little technical basis to the remaining costs. In addition, the decommissioning costs to date have all been well within the estimated costs, and the small scope of work remaining poses little risk of changing the historical trend. The largest risk factor is the cost of disposal of the waste currently stored at Rancho Seco. These costs will be readily quantified when a suitable facility becomes available;--and staff-has -used-available -industry knowledge-to-estimate-these-----

future costs. Therefore, staff has determined that outside review would not provide additional confidence in the cost basis.

This document is based upon the latest information available including actual costs to date, projections for the work remaining, and projections of SMUD overhead costs.

Updated information was used to make this cost estimate as accurate as possible, and revisions to costs were made in the following areas:

  • the actual withdrawals from the Trust Fund for work completed through June 2010

" projected costs for the Stored Waste Oversight

  • projected costs for license termination activities

" projected costs for future waste disposal History of Rancho Seco Decommissioning and Cost Estimates After the cessation of plant operations on June 7, 1989, the initial decommissioning alternative chosen was a modified SAFSTOR option identified as Hardened SAFSTOR.

The facility was to be placed into a safe, stable condition including transferring of the used nuclear fuel from wet to dry storage. Because of the premature shutdown, the Decommissioning Trust Fund had not collected adequate funds for decommissioning.

SMUD proposed a plan, which the NRC approved, to continue annual contributions to the Decommissioning Trust Fund over the time period of the original operating license, extending through 2008, at which time the Trust would be fully funded. This allowed

Page 5 of 25 collection of funds while minimizing the overall financial impact to SMUD operations.

Dismantlement activities were to commence once the funding was complete.

This original plan was the basis for the 1991 cost estimate, and was the baseline used for comparison when TLG prepared the 1995 cost estimate that included several decommissioning options. The two critical bases for these cost estimates were the use of a Decommissioning Operations Contractor to perform decommissioning, and the use of the then-proposed Ward Valley Low Level Waste Disposal Site (Ward Valley) as the cost basis for radioactive waste disposal.

Difficulties in the Fuel Dry Storage project caused delays over several years. The delays resulted in increases in overall decommissioning costs. The increases were reflected in the cost estimate updates and required increasing annual contributions to the Trust Fund, impacting SMUD's annual operating budget. Because of the financial impact, options were sought to mitigate the consequences of the increased costs. TLG was tasked with estimating the cost of several decommissioning options when preparing the 1995 update, and several options were evaluated.

Shortly after the 1995 decommissioning cost estimate update was prepared, EnergySolutions (then Envirocare) began accepting LLW from nuclear utilities.

EnergySolutions did not (and currently does not) accept the full spectrum of waste that is categorized--as- LLW,-but-the-waste-they do-accept-represents-the-vast-majority- of waste--

generated during a power reactor decommissioning project. The Ward Valley cost basis was over $400 per ft3 of LLW, while the EnergySolutions cost was under $100 per ft3.

With over 200,000 ft3 of material estimated to be generated during Rancho Seco decommissioning that would be acceptable for disposal at EnergySolutions, the opportunity to favorably impact the overall cost of decommissioning became possible.

In the original basis for the cost estimate, after Hardened SAFSTOR was achieved a staffing reduction was planned to correspond with the reduced need to maintain plant systems and facilities. Delays in the fuel project resulted in maintaining site staff at a higher level longer than originally planned. While this caused increases to the annual contributions to the Trust Fund, it also maintained a large talent pool on site with considerable process knowledge of operating history and radiological conditions within the facility. --

The availability of EnergySolutions combined with the presence of a large talent pool within the available staff presented an opportunity to begin the dismantlement process early. In 1996, a plan was developed to take advantage of both circumstances and perform dismantlement of the majority of the secondary systems in the Turbine Building.

This was proposed to the Board as the Incremental Decommissioning Project, which they subsequently approved as a 3-year project in January 1997.

The Incremental Decommissioning Project was successful in helping to mitigate the impacts of the delay in the fuel project, and the work was completed ahead of schedule

Page 6 of 25 and below projected costs. The Incremental project was so successful that the scope was expanded to include systems in the Tank Farm and other outside areas.

During the time period of Incremental Decommissioning, additional circumstances outside of SMUD's control resulted in further delays in the fuel project and additional impacts to the cost estimate and the annual Trust Fund contribution. Based upon the success of the Incremental project and the need to mitigate additional increases to the annual Trust Fund contribution, the decommissioning staff proposed a plan for continuing decommissioning through license termination, with an end-date to complete decommissioning in 2008. The Board approved this plan in July 1999, and SMUD shifted from Incremental Decommissioning to Decommissioning.

Early cost estimates throughout the industry were based upon plant inventories by system. Based upon the experiences gained at Rancho Seco and at other decommissioning nuclear utilities, TLG shifted the performance of cost estimating from a system-based approach to an area-based approach. To facilitate shifting the Rancho Seco cost estimate to the area-based approach, staff performed an area-by-area inventory of the systems in the Auxiliary and Reactor Buildings. The cost estimate prepared by TLG in 1999 represented both the shift to the area-based approach and the schedule change of completing decommissioning in 2008. (An additional cost estimate representing an update to the 1995 system-based estimate was also performed by TLG in 1999 for comparison-purposes. 1-999-was-the-last-year- the system-based-estimate-was updated.) -

With the commencement of active Decommissioning came the requirement to perform annual updates to the cost estimate. In 2000, TLG prepared an update to the 1999 area-based cost estimate. By this time, relatively long-term contracts were in place to provide labor, technical staff, transportation, radwaste packaging materials, radwaste processing, and radwaste disposal to support the decommissioning process. TLG used this actual information when preparing the 2000 cost estimate.

The date of January 1, 2000 is defined as the dividing line between Incremental Decommissioning and Decommissioning. The demarcation between the two projects may be defined as that point where the planned Turbine Building work was completed, and work in the Auxiliary Building was begun. In actuality, there was some overlap between the projects, with work occurring simultaneously on both projects for 1-2 months before and after 1/1/2000. Defining 1/1/2000 as both the end of Incremental Decommissioning (completion of work defined as within Incremental Decommissioning scope) and the beginning of Decommissioning (no work yet begun defined as within Decommissioning scope) has negligible impact on cost. However, it would be difficult to carry forward a demarcation point other than the beginning of the calendar year because Trust Fund calculations, the budget process, and the scheduling of costs over the duration of the project are all based upon calendar year.

Page 7 of 25 Phased Decommissioning By 2001, after Decommissioning had begun, SMUD decided not to send any LLW to the Barnwell, SC disposal facility, having never sent any material there for disposal. This decision precluded the ability to complete Decommissioning and termination of the Part 50 license. At that time, the plan to decommission in phases was implemented. During Phase I, the majority of the identified activities would be completed, including large component removal and decontamination of the facility to meet NRC release criteria.

Class B & C LLW resulting from these activities would be stored in the IOSB. With Phase I complete, the Part 50 license would be modified to include only the IOSB and 1-acre surrounding it. Phase II would include the stored waste oversight, shipping of the stored waste for disposal, and completion of all license termination activities at the IOSB resulting in termination of the Part 50 license. Decommissioning of the ISFSI, resulting in termination of the Part 72 license, is included in this cost estimate, but is a separate project not considered in the phased decommissioning of the former reactor facility.

All physical system removal and building decontamination was complete by the end of 2008, with Final Status Surveys completed in June 2009. In September 2009, the NRC approved SMUD's request to modify the Part 50 license, releasing all of the facility from the license except for the 1-acre area encompassing the IOSB. This completed Phase I of Decommissioning. In 2010, and for the foreseeable future, the facility remains in a SAFSTOR-mode..- -. . . . ."

Page 8 of 25 METHODOLOGY AND APPROACH This cost estimate reflects the actual costs of Phase I (defined as all costs of the dismantlement effort including some license termination activities that resulted in the modification of the part 50 license), and provides actual and estimated costs for Phase II (defined as costs beginning in 2009 with the oversight of stored waste through termination of both Part 50 and Part 72 licenses). The technical basis for previous estimates included detailed calculations for: system and component removal; extensive building and outside area decontamination, and; determination of radioactive waste volumes and packaging requirements. While some radioactive waste is expected to result from future license termination activities, these costs are very small in comparison to previous expenditures.

Details on the methods used by TLG in preparing the historical cost estimates are contained in the respective cost estimate documents. The methods used unique to this latest update are included in the discussion below.

Update Methodology Previous updates to the cost estimate utilized actual cost bases to update ongoing activities;---In-2009, the -future -costs-were-reevaluated and-a-new-baseline-was-established based on the limited scope of the remaining work and reflecting the need to re-establish a decommissioning organization when physical work resumes. This update includes actual costs of waste oversight and inflates future costs. The major cost categories are:

"Oversight, Shipping and Burial for Waste Disposal and Contract Staff'.

Overview of Decommissioning Cost Estimate Components The cost estimate provides an overall cost for the duration of the project including all costs incurred after transitioning from O&M-financed expenses after plant shutdown through 10 CFR 50 & 72 license terminations, plus an amount to cover SMUD costs anticipated for disposal of the GTCC material.

The previously expended funds include all expenditures for Phase I and actual costs for Phase II through 2009. This data is based upon the certified amounts withdrawn from the Trust Fund each year. The annual amounts withdrawn from the Trust Fund are meant to be the same as the actual expenditures in any given year, but for logistical reasons, the withdrawal is based upon actual expenditures through the 3 rd quarter and a Budget Forecast for the 4 th quarter in any given year. Because the withdrawal is based upon a forecast, there is invariably a difference between the amount withdrawn and the actual costs incurred. The amount withdrawn is over or under the actual expenditure for the calendar year, and the difference is corrected the following year. This results in a history of actual costs by year, represented by Trust Fund withdrawal amounts. Actual costs prior to 2000 are provided in a lump sum, demarcating the shift from Incremental

Page 9 of 25 Decommissioning to Decommissioning. Actual costs from 2000 and forward are carried in the cost estimate by year.

Oversight represents the costs necessary to ensure safe storage of the Class B & C waste until disposal. These are annually recurring costs for monitoring and maintaining the IOSB.

Waste disposal costs for the Class B and C LLW are based on industry standard projections with some contingency due to the uncertainty of future costs with no disposal option currently available. The cost for the GTCC waste disposal is carried forward from previous estimates. The disposal of the GTCC material is tied to the fuel storage because it is assumed the GTCC material would be placed into the same repository as the fuel when the DOE develops the repository.

Staff costs include the cost for contract staff to support LLW shipping activities and ultimately perform the remaining license termination activities including limited decontamination of the IOSB and performance of Final Status Surveys at the ISOB and ISFSI. Also included are staff costs required to oversee the radioactive waste stored in the IOSB until shipped for disposal.

Page 10 of 25 FINANCIAL COMPONENTS OF THE COST MODEL The decommissioning cost estimate in total is defined as the funding required to complete decommissioning through license termination. Historically, the estimate consisted of a large number of calculated costs based on cost factors, and the cost assigned to a given line item within the estimate was not as rigorously defended as the total. A basic assumption of the estimating process has been that when specific line items have been over-estimated, the unspent funds will be required to cover the costs associated with other line items that have been under-estimated. The historical costs captured in this estimate for Phase I of decommissioning reflect that the cost of the work completed was, in general, over-estimated.

The remaining future costs within this estimate were rigorously reviewed and/or refined.

The format was changed in the 2009 update for ease of performing future updates. The estimate is divided into costs by license for the Part 50 stored LLW, and for the Part 72 stored used fuel and GTCC waste. The Stored Waste Oversight costs are carried forward from the last update. The cost for LLW disposal has been split between the resins and the reactor vessel internals components, with the possibility of near-term resin disposal. The cost model has been updated to reflect the actual activity and dose rates for the waste in storage. Since the Barnwell, SC disposal facility that was the cost model for the LLW disposal-costs-was-closed- in-2008 -additional-contingency-has-been-added-due to the-uncertainty of future disposal costs. The GTCC disposal costs are carried forward from the last update. The Part 72 License termination costs were added to reflect the anticipated costs for ISFSI license termination. This information is taken from an estimate previously performed by TLG and is based on ISFSI materials activation calculations performed by staff in the mid-1990's.

The 1999 decommissioning cost estimate prepared by TLG was comprised of a detailed list of activities to which the unit cost factor methodology was applied. This provided a sound basis for determining overall costs, but contingencies were also added. The contingency provides additional funds to cover unforeseeable costs that are within the defined scope of the decommissioning project. It is important to note that contingency funds are an important part of the decommissioning cost estimate, and represent funds that are expected to be completely expended through the decommissioning process.

All of the activities which presented significant cost risk were completed in Phase I of Decommissioning, including dispositioning of the reactor vessel, reactor vessel internals, and all interior structures in the containment building. The reactor vessel and its internal components became radioactive as a result of activation during plant operation. Portions of the internals are highly radioactive and do not qualify as LLW, but are classified as GTCC waste and are currently in storage at the ISFSI. The radioactive waste Class B and Class C internals are in storage at the IOSB.

Page 11 of 25 Examples of remaining contingencies include changes in the regulatory environment and projected radioactive waste disposal costs (e.g., Class B & C waste disposition options and costs or regulatory changes that would impact remaining license termination activities). The cost impacts of these uncertainties have been defined by TLG in previous estimates under the term "financial risk". To date, financial risk has not been specifically addressed within any Rancho Seco decommissioning cost estimate. Outside of the scope of the cost estimate itself, staff deals with these uncertainties on a project-by-project basis. An overall risk assessment taking into account any anticipated risk factor would typically be addressed through a probability analysis, perhaps utilizing a Monte Carlo-type probability simulation. Such a detailed risk analysis is considered to be outside of the scope of the decommissioning cost estimate. However, contingency is included as a component of the estimate where prudent.

ASSUMPTIONS The following are the assumptions used in developing the Rancho Seco cost estimate.

Some assumptions are generic in nature, and some are specific to the Rancho Seco site.

U sed-Fuel.-. .-.. . . . . . . . . . . .

I. The cost to remove and dispose of the used fuel from the site is not reflected within the estimate to decommission Rancho Seco. The Nuclear Waste Policy Act assigns responsibility to the DOE's Waste Management System.

2. The ISFSI will remain operational under the 10 CFR 72 license until the DOE takes possession of, or accepts responsibility for, the fuel. The cost for maintenance of the fuel is considered O&M and is not included in this cost estimate.
3. DOE acceptance of fuel in 2027 is carried forward from previous estimates. This will be reviewed for each subsequent estimate as there is currently great uncertainty with the acceptance date.

Reactor Vessel Internal Components I. The reactor vessel internal components are removed and packaged. Resulting Class B and Class C radioactive waste is stored in the IOSB until a suitable option for the material becomes available. The resulting GTCC material is stored in the ISFSI until the DOE takes possession of the material. However, the DOE has not yet established an acceptance criteria or a disposition schedule for this material.

Therefore, this cost estimate is based upon industry-accepted assumptions regarding DOE schedules. Industry assumptions for the acceptance criteria are modeled on

Page 12 of 25 the packaging for the used nuclear fuel: the GTCC is stored in a canister with the same outer geometry as the used fuel canisters.

2. The cost to dispose of the GTCC material stored in the ISFSI is reflected in this cost estimate. The cost for maintenance and transfer of the GTCC material is not included in this cost estimate.

Transportation Methods

1. Contaminated materials resulting from remaining decommissioning activities will qualify under Title 49 of the Code of Federal Regulations Part 173 as LSA -I, -II, or -III, or SCO-I or -II.
2. Transportation of Class A LLW is by truck or rail to EnergySolutions. Class B & C LLW transportation costs are modeled on the cost of transportation of that material by truck to the Barnwell facility, which, due to the distance from the Rancho Seco facility, is considered bounding. Transportation assumes a normal maximum road weight limit of 80,000 lbs. Cask shipments may exceed 95,000 pounds.

Low-Level Radioactive Waste Disposal

1. The majority of the LLW generated during decommissioning has been disposed at EnergySolutions. Future disposal rates used in the estimate are based upon current contractual rates and potential future rate impacts based on over 10-years of historical trends. EnergySolutions considers contract disposal rates proprietary.
2. Waste not suitable for disposal at EnergySolutions (class B & C) is being stored in the IOSB until a suitable disposal facility becomes available. No facility currently exists that is available to SMUD for the disposal of this material.
3. Barnwell disposal rates are used as the model for waste not suitable for disposal at EnergySolutions. The basis for this cost model is the rate schedule published in NUREG-1307. Because the Barnwell facility is no longer available, a contingency of 15% of the disposal costs is included due to the uncertainty of future rates.

Estimating Basis

1. Future decommissioning costs are in general reported in the current year's currency regardless of the scheduled year of the expenditure; therefore, changes in schedule do not impact the cost estimate.
2. Remaining costs are based upon an estimate of the remaining activities including contract staff to perform the activities and other costs such as waste disposal.

Page 13 of 25 Labor Costs

1. The craft labor required to complete decommissioning is obtained through standard SMUD contracting practices.
2. Future activities such as waste shipments and license termination activities will be performed by contracted staff.
3. Costs for stored waste oversight are based upon current salary information obtained through the current budget process, and estimates of future changes in SMUD overhead costs.
4. Engineering services for such items as writing activity specifications, detailed procedures, and work procedures are assumed to be performed by contracted staff.

General I. Only the 1-acre facility encompassing the IOSB remains under the Part 50 license.

The Class B & Class C waste will be stored in the IOSB through 2028.

2. The approximately- 0-acre-ISFSt-remains underthe-Part72--license:- The used-fuel will be completely transferred to the DOE by the end of 2027.
3. Phase I of the LTP is complete. Phase II of the LTP will be completed after the Class B & C waste is shipped for disposal and the used fuel and GTCC has been shipped to a DOE facility. Completion of Phase II of the LTP will result in complete termination of both the Part 50 and Part 72 licenses.
4. Equipment such as administrative equipment (desks, chairs, etc.), forklifts, trucks, other mobile equipment and items of personal property owned by SMUD will be easily removed without the use of special equipment at no cost or credit to the project.
5. The decommissioning activities are performed in accordance with applicable regulations.
6. The principles of ALARA used in determining work duration adjustment factors are minimal for the remaining work scope, but remain an element in the cost estimate.
7. SMUD provides the electrical power required for the decommissioning project at no cost to the project.

Page 14 of 25 GLOSSARY INCLUDING ACRONYMS AND ABBREVIATIONS

1. ALARA: As Low As Reasonably Achievable
2. Barnwell: The Barnwell, SC LLW Disposal Facility
3. DOE: Department of Energy
4. Energy Solutions: Formerly Envirocare of Utah, Inc. - headquartered in Salt Lake City that operates the LLW disposal facility in Clive, UT and is developing a resin processing technique in TN
5. GTCC: Greater Than Class "C" Waste - disposal of this waste is the responsibility of the DOE
6. IOSB: Interim Onsight Storage Building
7. ISFSI: Independent Spent Fuel Storage Installation
8. LLW: Low Level Radioactive Waste
9. LTP: License Termination Plan
10. NRC: Nuclear Regulatory Commission
11. 0 & M: Operation and Maintenance
12. Part 50: Title 10 of the Code of Federal Regulations, Part 50- regulations governing the former operating plant license now applicable to the IOSB
13. Part 72: Title 10 of the Code of Federal Regulations, Part 72 -regulations governing the license for the ISFSI
14. Rancho Seco: Used in reference to both facilities licensed by the NRC, Rancho Seco Nuclear Generating Station (Part 50) and Rancho Seco ISFSI (Part 72)
15. SMUD: Sacramento Municipal Utility District
16. TLG: TLG Services, Inc
17. Ward Valley: The proposed Ward Valley Low Level Waste Disposal Site in Needles, CA
18. WCS: Waste Control Specialist, Inc. - operates the LLW disposal facility being constructed in Andrews, TX

Page 15 of 25 REFERENCES

1. "2009 Decommissioning Cost Estimate for the Rancho Seco Nuclear Generating Station", November 30, 2008, Document No DPG 09-329, Rev 0
2. Rancho Seco Stored Waste Oversight cost basis, Post 2008 ARO Costs, 2003; ARO Response to Data Request and Assumptions, Attachment S 11-1481-0302
3. Rancho Seco Part 72 License Termination cost basis, TLG Services, Inc "Independent Spent Fuel Storage Installation Decommissioning" Cost Summary, 2003; ARO Response to Data Request and Assumptions, Attachment SI 1-1481-0302
4. Rancho Seco Resin Disposal cost basis,
5. Rancho Seco Reactor Vessel Internals Disposal cost basis,

Rancho Seco Nuclear Generating Station Area-based Decommissioning Cost Estimate Page 16 of 25 TABLE I

SUMMARY

OF DECOMMISSIONING COST CONTRIBUTORS Cost in 2010$ Percent of Work Category (2010 & beyond) Remaining Costs Stored Waste Oversight 2,201 10%

Future LLW Disposal 11,831 53%

GTCC Disposal 3,278 15%

Final License Termination Activities 4,882 22%

Total 22,192 100%

53%

~z Z

10-, ,** *  : 15 %

22%

[Stored Waste Oversight El Future LLW Disposal E9 GTCC Disposal El Final License Termination Activities

Rancho Seco NuclearGenerathg Station Area Based Decommissioning Cost Estimate Page 17 of 25 Tabl 2 Decomrnissioning Cost Estimate - Phase II (Thousands ofs010 Dollars)

Waste Disposal Contract  %

DESC OVERSIGHT SHIP BURY STAFF CNTGCY CNTGCY TOTAL 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020-2026 2027 2028 TOTAL 1059 (part 50 license)

Stored Waste Oversight 2,250 2,250 165 116 116 116 116 116 116 116 116 116 811 116 116 2,250 Resin Disposal 118 3,094 147 3,359 3,359 32359 RVIDisposal 346 6,714 406 1,007 13% 8,472 8,472 8,472 Part 50 License termination 4 27 2,829 141 5% 3,001 3,001 3,001 Totals 2,250 468 9,834 3,382 1,148 17,082 165 116 116 116 116 116 116 116 116 116 811 11614, 948 17,082 ISFS1(part 72 license) 2,447 829 34% 3,278 3,278 3,278 GTCC Disposal Part 72 License tarminaflon 15 294 1,573 1,681 941 941 1,681 TOTAL COST (CE 2010) 2,250 468 12,261 3,382 1,977 10% 20,360 165 116 116 116 116 116 116 116 116 116 811 3,393 14,948 22,241 Phase ICosts 482,002 482,002 Phase IIActual Pre-2010 63 63 63 Total Decom Cost Pre-201 0 482,064 482,064 Total Decommissioning Cost 5

Rancho Seco Nuclear Generating Station Table 3 18 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Surcharges  %

DESC DECON REMOVE PACKSHIP BURY OTHER MATERIAL CONTRACT WASTE CNTGCY CNTGCY TOTAL Decomm Funds expended through 1999 156,310 156,310 Reactor Building Rx - RX00 Building System Removal 486 24 71 139 656 Rx - RX01 Building System Removal 1,064 167 50 975 2,256 Rx - RX02 Building System Removal 2,728 248 74! 1,445 15 4,509 Rx - RX03 Building System Removal 3,192 316 94. 1,844 279 5,725 Rx - RX04 Building System Removal 27 524 45 15 271 494 1,375 Rx - RX05 Building System Removal 241 4 0, 155 0 130 530 RPSB- Pack Ship Bury Activities 9 28 113 895 3 105 1,153 X411 - Liner Preparation 28 28 ERM Efficiency Removal Method (25% of Removal Costs) -1,754 -1,754 LEM Correction (inflation of prior work performed) -3 -1,154 -112 -40 -705 0 -96 -2,110 Totals 24 5,336 720 312: 5,019 3 955 12,369 Auxiliary Building Aux -AXOO Building System Removal 2,804 217 87; 2,432 28 5,568 Aux -AX01 Building System Removal 3,469 277 104 2,718 83 6,650 Aux -AX02 Building System Removal 37 1,501 142 67, 1,801 65 3,612 Aux -AX03 Building System Removal 14 723 73 35. 1,000 93 1,938 Aux -AX04 Building System Removal 10 542 66 25 553 16 1,212 Aux -AX05 Building System Removal 244 38 12 237 42 574 Aux -AX06 Building System Removal 51 3 4 28 2 85 Aux -AX07 Building System Removal 87 86 12 41 73 205 17 11 496 Aux 211 Ventilation Equipment Room APSB & BPSB - Pack Ship Bury Activities 194 96 88i 429 101 8 1 12 282 1,210 TSM1 - Remove Temporary Stack ERM Efficiency Removal Method (25% of Removal Costs) -2,122 -2,122 LEM Correction (inflation of prior work performed) -44 -2,130 -259 -1151 -2,996 -3 0 -2 -37 -5,586 Totals 104 5,363 665 307: 6,276 303 8 1 26 584 13,637 Auxiliary Building - Non Controlled Area 350 AB Non Controlled 8 8 350A +40' Elevation 210 210 350B +20' Elevation 440 440 350C Grade & Below Elevation 222 7 229 LEM Correction (inflation of prior work performed) -82 -1 -83 Totals 797 6 803 Tank Farms Tank Farm - Above Ground 45 1,699 103 38 599 10 2 83 2,580 Tank Farm - Below Ground 882 26; 69 6 984 LEM Correction (inflation of prior work performed) -3 -240 -11 -7. -76 0 -9 -347 Totals 41 2,341 92 581 592 10 2 80 3,216

Rancho Seco Nuclear GeneratingStation Table 3 19 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Surcharges DESC DECON REMOVE PACKSHIP BURY OTHER MATERIAL CONTRACT WASTE CNTGCY CNTGCY TOTAL Additional Costs Asbestos Removal 514 117 4 28 5 12 3 77 759 Lead Remediation 623 2 40 666 LEM Correction (inflation of prior work performed) -60 -6 0 -1 0 -1 0 -7 -75 Totals 1,076 111 4 27 5 14 2 111 1,350 Embedded Piping Preparation Steps 68 40 59 170 Reactor Building 161 65 226 Auxiliary Building 284 305 107 5 701 Turbine Building 192 1 10 46 249 Spent Fuel Building 105 20 73 0 199 Embedded Pipe Final Status Surveys (F00-F134) 436 436 LEM Correction (inflation of prior work performed) -16 -46 0 -21 0 0 -5 -89 Totals 374 701 1 709 4 3 100 1,892 Spent Fuel Building Spent Fuel Bldg Roof 138 22 159 Mechanical & Electrical Equip 23 536 106 68 1,311 5 11 26 223 2,308 Drain & Process Wate 9 9 Removal of Fuel Rack 58 246 122 426 Complete SFP C/U & R 581 108 32- 277 203 1,200 LEM Correction (inflation of prior work performed) -8 -200 -42 -13ý -202 -1 -1 -3 -61 -531 Totals 74 1,300 293 87: 1,385 5 10 23 395 3,572 Nuclear Steam Supply System Removal RCP Motors 34 155 38 389 617 Incore Instrumentation 66 33 11 6 55 80 252 RC Pumps 87 92 198 49, 495 252 1,172 Control Rod Drive 66 33 11 6 55 80 252 Service Structure 66 47 12 6: 59 80 270 Pressurizer 139 295 254 331 254 166 1,142 Steam Generators 2,339 289 624! 3,591 86 6,928 Reactor Vessel Internals 83 14,276 1,251 207, 1,272 542 87 261 36 298 18,313 Reactor Vessel 3,099 429 142 1,255 44 72 5,041 Reactor Coolant Piping 143 214 6 31 21 386 LEM Correction (inflation of prior work performed) -62 -1,532 -225 -89ý -586 -81 -7 -19 -2 -77 -2,681 Totals 589 18,929 2,390 1,024. 6,862 746 80 242 34 796 31,691 Turbine Building Turbine Building 1,025 8 2 32 1 1 8 1 110 1,189 Area Between DG Room & SFB 150 4 5 159 LEM Correction (inflation of prior work performed) -67 -1 0. -3 0 0 0 0 -6 -78 Totals 1,109 7 6& 34 1 0 7 1 104 1,269

Rancho Seco Nuclear Generating Station Table 3 20 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Surcharges DESC DECON REMOVE PACKSHIP BURY OTHER MATERIAL CONTRACT WASTE CNTGCY CNTGCY TOTAL IOSB Project IOSB Project 15 0 528 543 LEM Correction (inflation of prior work performed) -1 -8 -9 Totals 14 0 520 534 Waste Water Disposal System RHUTArea 568 40 17 150 58 2 6 25 867 Discharge Lines 172 3 175 Retention Basin Area 476 1,075 1,026 39 145 94 41 2,897 LEM Correction (inflation of prior work performed) -75 -4 -2 -43 -29 -1 -4 -2 -3 -164 Totals 1,141 36 15 1,182 1,056 40 147 91 65 3,775 Remediation of Site Buildings Reactor Building 349 561 4 80 994 Auxiliary Building 1,417 1,609 153 231 1,249 1,217 31 176 1,109 6,984 Turbine Building 9 44 524 10 588 Out-Building Demolition 57 53 70 180 Spent Fuel Building 303 854 264 359 1 2 3 266 2,052 Retention Basin Area 8 8 Tank Farm 22 22 Pack, Ship, Bury 65 651 381 75 107 105 346 1,143 LEM Correction (inflation of prior work performed) -57 -76 -4 -58 -41 -43 0 -1 -4 -22 -254 Totals 2,021 2,509 214 83ý 1,853 2,753 107 142 175 1,860 11,718 Rx Bldg Concrete/Steel Removal Rx Bldg Concrete/Steel Removal 10,950 0 0' 19,044 708 765 31,467 LEM Correction (inflation of prior work performed) -146 0 o0 -501 -9 -17 -673 Totals 10,804 0 0: 18,543 699 748 30,794 Final Status Survey & License Termination Reactor Building 20 216 9 246 Auxiliary Building 1,765 7 1,772 Auxiliary Building - Non Controlled 143 143 Turbine Building 244 244 Spent Fuel Building 240 240 Tank Farm 166 166 Waste Water Disposal 78 19 97 OutBuiildings 23 128 799 657 1,607 Other Outside Areas 6 788 278 1,072 Other Licenses Term Activities 819 31 850 LEM Correction (inflation of prior work performed) -2 -3 -179 0 -128 -313 Totals 48 124 5,078 18 854 6,123

Rancho Seco Nuclear Generating Station Table 3 21 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Surcharges DESC DECON REMOVE PACKSHIP BURY OTHER MATERIAL CONTRACT WASTE CNTGCY CNTGCY TOTAL Undistributed Costs Decon Equipment 542 546 22 81 1,192 Decon Supplies 613 430 13 49 1,105 LLRW Processing Equipment 627 868 37 457 1,989 Process Liquid Waste 136 20 90 665 1,125 6 11 8 249 2,309 Insurance 3,362 182 3,543 Health Physics Supplies 1,400 642 57 350 2,448 Heavy Equipment Rent 4,685 2,254 192 703 7,835 Small Tools Allowance 383 221 16 57 677 Pipe Cutting Equipment 407 640 17 61 1,125 Disposal of DAW Geneerated 66 8; 385 456 3 6 28 104 1,056 Purchased Material 4,588 136 332 5,056 Dues & Publication 1,757 124 1,882 Rent & Leases 11 1 11 Licenses 4,625 363 4,989 Other 1,543 6 1,549 Training Expenses 328 25 353 Air - Travel 398 18 416 Consultants 516 32 547 Outside Services 6,576 62 413 7,050 LEM Correction (inflation of prior work performed) -123 -465 -5 -6; -67 -2,638 -27 -4 -2 -241 -3,578 Totals 1,795 6,410 80 91' 983 28,248 473 75 34 3,366 41,555 Planned Staff Costs SMUD Staff Support 92,595 92,595 Other SMUD Staff 6,038 6,038 Contractor Staff Support 22,727 22,727 Other Cost 6,735 6,735 Totals 128,095 128,095 Spent Fuel Removal/GTCC Disposal Spent Fuel Project 33,294 33,294 Totals 33,294 33,294 Sewer Plant Construct Sewer System 4 4 LEM Correction (inflation of prior work performed)

Totals 4 4 TOTAL PHASE I COSTS (THRU 2009) 5,021 57,879 4,609 1,988; 42,882 357,825 718 1,409 396 9,276 482,002

Rancho Seco Nuclear Generating Station Table 3 22 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

DESC 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 TOTAL Decomm Funds expended through 1999 156,310 156,310 Reactor Building Rx - RXOO Building System Removal 656 656 Rx - RX01 Building System Removal 2,256 2,256 Rx - RX02 Building System Removal 4,509 4,509 Rx - RX03 Building System Removal 5,725 5,725 Rx - RX04 Building System Removal 1,375 1,375 Rx - RX05 Building System Removal 530 530 RPSB - Pack Ship Bury Activities 256 897 1,153 X411 - Liner Preparation 28 28 ERM Efficiency Removal Method (25% of Removal -95 -326 -450 -647 -235 -1,754 LEM Correction (inflation of prior work performed) -74 -252 -599 -858 -219 -61 -46 -1 -2,110 Totals 487 1,678 3,459 4,219 922 725 851 28 12,369 Auxiliary Building Aux -AXO0 Building System Removal 5,568 5,568 Aux -AX01 Building System Removal 6,650 6,650 Aux -AX02 Building System Removal 3,612 3,612 Aux -AX03 Building System Removal 1,938 1,938 Aux -AX04 Building System Removal 1,212 1,212 Aux -AX05 Building System Removal 574 574 Aux -AX06 Building System Removal 85 85 Aux -AX07 Building System Removal 14 142 340 0 496 Aux 211 Ventilation Equipment Room APSB & BPSB - Pack Ship Bury Activities 513 258 438 0 1,210 TSM1 - Remove Temporary Stack ERM Efficiency Removal Method (25% of Removal -612 -888 -401 -204 -14 -2,122 LEM Correction (inflation of prior work performed) -563 -3,870 -483 -306 -298 -39 -19 -8 -5,586 Totals 4,394 1,892 2,725 1,429 900 535 593 392 778 13,637 Auxiliary Building - Non Controlled Area 350 AB Non Controlled 8 6

350A +40' Elevation 68 23 18 60 3 94 6 210 350B +20' Elevation 76 166 68 43 11 8 440 350C Grade & Below Elevation 2 22 62 74 52 10 5 229 LEM Correction (inflation of prior work performed) -11 -17 -31 -16 -5 -3 -83 73 214 187 93 113 18 803 Totals 104 Tank Farms Tank Farm - Above Ground 1,485 185 691 126 83 10 2,580 Tank Farm - Below Ground 435 376 172 984 LEM Correction (inflation of prior work performed) -178 -71 -82 -15 -2 -347 Totals 1,307 549 986 283 81 10 3,216

Rancho Seco Nuclear GeneratingStation Table 3 23 of 25 Area Based DecommissioningCost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

DESC 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 TOTAL Additional Costs Asbestos Removal 234 221 232 72 759 Lead Remediation 381 132 112 41 666 LEM Correction (inflation of prior work performed) -49 -18 -8 -75 Totals 566 336 335 114 1.350 Embedded Piping Preparation Steps 87 72 0 . 10 170 Reactor Building 2 225 226 Auxiliary Building 203 438 60 701 Turbine Building 147 5 98 249 Spent Fuel Building 9 0 138 51 199 Embedded Pipe Final Status Surveys (F00-F134) 22 256 158 436 LEM Correction (inflation of prior work performed) -35 -40 -14 -89 Totals 414 722 537 219 1,892 Spent Fuel Building Spent Fuel Bldg Roof 145 1 14 159 Mechanical & Electrical Equip 92.6 1,045 82 209 13 33 2,308 Drain & Process Wate .9 9 Removal of Fuel Rack 168 258 426 Complete SFP C/U & R ,2 534 530 134 1,200 LEM Correction (inflation of prior work performed) -12i6 -276 -91 -36 0 -1 -531 Totals 979 1,561 522 452 13 46 3,572 Nuclear Steam Supply System Removal RCP Motors 617 617 Incore Instrumentation 16 236 252 RC Pumps 1,17,22 1,172 Control Rod Drive 125 237 252 Service Structure ;2 268 270 Pressurizer 18 1,123 1,142 Steam Generators 32 4,157 2,738 6,928 Reactor Vessel Internals 80 2,356 9,252 6,625 18,313 Reactor Vessel 124 299 356 2,586 1,676 5,041 Reactor Coolant Piping 38!3 4 386 LEM Correction (inflation of prior work performed) -79 -22.7 -96 -808 -953 -474 -44 -2,681 Totals 554 1,58'0 667 7,127 11,394 8,737 1,633 31,691 Turbine Building Turbine Building 9 52 74 202 355 390 108 1,189 Area Between DG Room & SFB 159 159 LEM Correction (inflation of prior work performed) -1 -5 -14 -30 -19 -9 -78 Totals 7 46 60 332 336 381 108 1,269

Rancho Seco Nuclear Generating Station Table 3 24 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

DESC 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 TOTAL IOSB Project IOSB Project 43 44 78 378 0 543 LEM Correction (inflation of prior work performed) -5 -2 -2 -9 Totals 38 42 76 378 0 534 Waste Water Disposal System RHUT Area 298 304 162 46 57 867 Discharge Lines 44 131 175 Retention Basin Area 2,897 2,897 LEM Correction (inflation of prior work performed) -30 -31 -16 -9 -78 -164 Totals 268 273 190 167 2,876 3,775 Remediation of Site Buildings Reactor Building 17 977 994 Auxiliary Building 101 1,333 3,534 2,016 6,984 Turbine Building 260 328 588 Out-Building Demolition 63 84 34 180 Spent Fuel Building 273 17 475 742 546 2,052 Retention Basin Area 8 8 Tank Farm 22 22 Pack, Ship, Bury 49 143 386 565 1,143 LEM Correction (inflation of prior work performed) -14 -11 -108 -120 -254 Totals 259 155 1,914 4,903 4,489 11,718 Rx Bldg Concrete/Steel Removal Rx Bldg Concrete/Steel Removal 0 25,621 5,846 31,467 LEM Correction (inflation of prior work performed) -673 -673 Totals 0 24,947 5,846 30,794 Final Status Survey & License Termination Reactor Building 81 60 47 58 246 Auxiliary Building 335 749 164 274 248 1,772 Auxiliary Building - Non Controlled 133 10 143 Turbine Building 244 244 Spent Fuel Building 28 84 128 240 Tank Farm 21 83 63 166 Waste Water Disposal 27 28 34 8 97 OutBuiildings 11 160 248 98 272 768 50 1,607 Other Outside Areas 34 56 516 229 166 70 1,072 Other Licenses Term Activities 136 231 222 261 850 LEM Correction (inflation of prior work performed) -1 -23 -62 -127 -54 -45 -313 Totals 10 172 577 1,501 1,040 1,684 1,139 6,123

Rancho Seco Nuclear GeneratingStation Table1 3 25 of 25 Area Based Decommissioning Cost Estimate Decommissioning Cost Estimate (Thousands of 2010 Dollars)

DESC 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 TOTAL Undistributed Costs Decon Equipment 266 280 131 131 131 131 120 1,192 Decon Supplies 166 .131 133 137 137 137 137 126 1,105 LLRW Processing Equipment 325 271 272 286 286 286 262 1,989 Process Liquid Waste 656 235 234 241 241 241 241 221 2,309 Insurance 563 616 366 407 407 407 407 372 3,543 Health Physics .Supplies 185 457 368 368 368 368 337 2,448 Heavy Equipment Rent 873 1,381 1,135 1,135 1,135 1,135 1,040 7,835 Small Tools Allowance 47 93 80 93 93 93 93 85 677 Pipe Cutting Equipment 595 46 82 82 82 82 82 75 1,125 Disposal of DAW Geneerated 102 205 149 153 153 153 140 1,056 Purchased Material 140 603 529 639 639 639 639 639 586 5,056 Dues & Publication 266 2416 278 278 278 278 255 1,882 Rent & Leases 2 2 2 2 2 2 11 Licenses 87 903 813 813 813 813 745 4,989 Other 900 579 12 12 12 12 12 11 1,549 Training Expenses 38 44 46 46 46 46 46 42 353 Air - Travel 103 76 40 40 40 40 40 37 416 Consultants 43 84 71 71 71 71 71 65 547 Outside Services 480 987 983 936 936 936 936 857 7,050 LEM Correction (inflation of prior work performed) -596 -974 -446 -116 -535 -451 -305 -154 -3,578 Totals 4,340 6,829 2,746 800 4,759 5,420 5,566 5,716 5,378 41,555 Planned Staff Costs SMUD Staff Support 15,272 16,060 13,346 10,804 8,578 5,659 10,030 6,653 6,193 92,595 Other SMUD Staff 3,824 2,214 0 0 6,038 Contractor Staff Support 2,129 2,028 2,539 2,337 2,597 2,408 3,038 2,848 2,803 22,727 Other Cost 2,212 2,516 2,007 6,735 Totals 17,401 18,088 15,885 15,353 14,998 12,798 13,069 9,501 8,996 2,007 128,095 Spent Fuel Removal/GTCC Disposal Spent Fuel Project 13,013 9,015 11,266 33,294 Totals 13,013 9,015 11,266 33,294 Sewer Plant Construct Sewer System 4 4 LEM Correction (inflation of prior work performed)

Totals 4 4 TOTAL PHASE I COSTS (THRU 2009) 156,310 39,636 38,055 38,731 25,928 31,159 35,689 33,761 53,249 27,476 2,007 482,002

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