ML13247A055

Enclosures a & B: Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station and Financial Escalation Analysis for the Decommissioning of Davis-Besse Nuclear Power Station

ML13247A055
Person / Time
Site:	Davis Besse
Issue date:	05/13/2011
From:	TLG Services
To:	Office of Nuclear Reactor Regulation, FirstEnergy Corp
Shared Package
ML13247A048	List: L-13-270, Response to a Request for Additional Information Related to the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2: Davis-Besse Nuclear Power Station, Unit No. 1: and Perry Nuclear Power Plant, Unit No ML13247A055
References
TAC ME2162, TAC MF2163, TAC MF2186, TAC MF2229
Download: ML13247A055 (114)

Text

Document F07-1619-004, Rev. 1 DECOMMISSIONING COST ANALYSIS for the DAVIS-BESSE NUCLEAR POWER STATION prepared for FirstEnergy Corp.

prepared by TLG Services, Inc.

Bridgewater, Connecticut May 2011

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Page ii of xv APPROVALS Project Manager Project Engineer Technical Manager rancis W. Seygor Date Mark S. H~oughton Date William A. Cloutier, Jr.

Date TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Page iii of xv TABLE OF CONTENTS SECTION PAGE EXECU TIVE SU M M ARY.....................................................................................

vi-xv

1.

INTRODU CTION.....................................................................................................

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

1-1 1.2 Site Description.................................................................................................

1-1 1.3 Regulatory Guidance........................................................................................

1-2 1.3.1 N uclear W aste Policy Act......................................................................

1-4 1.3.2 Low -Level Radioactive W aste Acts......................................................

1-6 1.3.3 Radiological Criteria for License Term ination....................................

1-8

2.

DECON DECOMMISSIONING ALTERNATIVE.................................................

2-1 2.1 Period 1 - Preparations.....................................................................................

2-2 2.2 Period 2 - D ecom m issioning Operations.........................................................

2-4 2.3 Period 3 - Site Restoration...............................................................................

2-7 2.4 ISFSI Operations and Decom m issioning........................................................

2-8

3.

COST ESTIM A TE.....................................................................................................

3-1 3.1 Basis of Estim ate..............................................................................................

3-1 3.2 M ethodology......................................................................................................

3-1 3.3 Financial Com ponents of the Cost M odel.......................................................

3-3 3.3.1 Contingency...........................................................................................

3-3 3.3.2 Financial Risk........................................................................................

3-4 3.4 Site-Specific Considerations.............................................................................

3-6 3.4.1 Spent Fuel M anagem ent.......................................................................

3-6 3.4.2 Reactor Vessel and Internal Com ponents...........................................

3-8 3.4.3 Prim ary System Com ponents...............................................................

3-9 3.4.4 M ain Turbine and Condenser.............................................................

3-10 3.4.5 Transportation M ethods.....................................................................

3-10 3.4.6 Low -Level Radioactive W aste Disposal.............................................

3-11 3.4.7 Site Conditions Following Decom m issioning....................................

3-12 3.5 Assum ptions....................................................................................................

3-13 3.5.1 Estim ating Basis.................................................................................

3-13 3.5.2 Labor Costs..........................................................................................

3-13 3.5.3 D esign Conditions................................................................................

3-14 3.5.4 General.................................................................................................

3-14 3.6 Cost Estim ate Sum m ary...............................................................................

3-17 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Page iv of xv TABLE OF CONTENTS (continued)

SECTION PAGE

4.

SCHEDULE ESTIMATE........................................................................................

4-1 4.1 Schedule Estimate Assumptions.....................................................................

4-1 4.2 P roject Schedule................................................................................................

4-2

5.

RADIOACTIVE WASTES........................................................................................

5-1 6.

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

6-1

7.

R E F E R E N C E S..........................................................................................................

7-1 TABLES Cost Summary, Decommissioning Cost Elements........................................ xv 3.1 Schedule of Total Annual Expenditures.......................................................

3-19 3.2 Schedule of License Termination Expenditures...........................................

3-22 3.3 Schedule of Spent Fuel Management Expenditures....................................

3-23 3.4 Schedule of Site Restoration Expenditures..................................................

3-26 5.1 Decommissioning Waste Summary.................................................................

5-3 6.1 Decommissioning Cost Elements....................................................................

6-4 FIGURES 1.1 S ite P h oto.........................................................................................................

1-9 4.1 A ctivity Schedule..............................................................................................

4-3 4.2 Decommissioning Timeline..............................................................................

4-4 APPENDICES A.

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

A-1 B.

Unit Cost Factor Listing..................................................................................

B-1 C.

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

C-1 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. I Page v of xv REVISION LOG No.

Date Item Revised Reason for Revision 0

04-15-2011 Original Issue 1

05-13-2011 Executive Summary, Revised costs to include Tables 3.1 - 3.4, Table 5.1, contaminated soil disposition Chapter 6, Appendix C TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Page vi of xv EXECUTIVE

SUMMARY

This report presents an estimate of the cost to decommission the Davis-Besse Nuclear Power Station (Davis-Besse), for the selected decommissioning scenario, following the currently scheduled cessation of operation. The analysis relies upon site-specific, technical information from an evaluation prepared in 2005,[11 updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The current estimate is designed to provide FirstEnergy Corp. (FirstEnergy) with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station. The estimate does not reflect the actual plan to decommission Davis-Besse; the plan may differ from the assumptions made in this analysis based on facts that exist at the time of decommissioning.

The primary goal of the decommissioning is the removal and disposal of the contaminated systems and structures so that the operating licenses can be terminated. The analysis recognizes that spent fuel will be stored at the site in an independent spent fuel storage installation (JSFSI) until such time that it can be transferred to the U.S. Department of Energy (DOE). Consequently, the estimate also includes those costs to manage and subsequently decommission these interim storage facilities.

The currently projected cost to promptly decommission the station shortly after the cessation of operations (the DECON alternative), is estimated at $1,216.2 million, as reported in 2010 dollars. The estimate is based on numerous fundamental assumptions, including regulatory requirements, low-level radioactive waste disposal practices, high-level radioactive waste management options, project contingencies, and site restoration requirements. The estimate incorporates a minimum cooling period for the spent fuel that resides in the storage pool when operations cease. Once sufficiently cooled the spent fuel is transferred to the ISFSI for interim storage. The estimate also includes the dismantling of site structures and non-essential facilities and the limited restoration of the site.

Alternatives and Regulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material so that the license can be terminated. The Nuclear Regulatory Commission (NRC) provided initial decommissioning 1

"Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," Document F07-1525-003, Rev. 0, TLG Services, Inc., October 2005 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Page vii of xv requirements in its rule adopted on June 27, 1988.[21 In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities.

The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning.

The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and 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."15] As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of long-lived radioactive material. In 1997, the NRC directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option.

The resulting evaluation provided several recommendations; however, rulemaking has been deferred pending the 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 3

Ibid. Page FR24022, Column 3 4

Ibid.

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

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. I Decommissioning Cost Analysis Page viii of xv completion of additional research studies, for example, on engineered barriers.

In

1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[61 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 acceptable to the NRC staff for implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. The format and content of the estimate is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.[7]

Methodology The methodology used to develop the estimate described within this document follows the basic approach originally presented in the cost estimating guidelines[8] developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest available information on worker productivity in decommissioning.

The estimate also reflects lessons learned from TLG's involvement in the Shippingport Station decommissioning, completed in 1989, and 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 technical challenges of decommissioning commercial nuclear units.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which 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

"Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors,"

Regulatory Guide 1.202, U.S. Nuclear Regulatory Commission, February 2005 8

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

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Page ix of xv include program management, administration, field engineering, equipment rental, and support services, such as quality control and security.

Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur."1 91 The cost elements in the estimate are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

Contingency funds are expected to be frilly expended throughout the program. As such, inclusion of contingency is necessary to provide assurance that sufficient funding will be available to accomplish the intended tasks.

Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,1101 and its Amendments of 1985,111] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. However, with the exception of Texas (which has issued a license for a new facility), no new compact facilities have been successfully sited, licensed, and constructed.

Until recently, there were two facilities available to FirstEnergy for the disposal of low-level radioactive waste generated by Davis-Besse. As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of the states of Connecticut, New Jersey and South Carolina).

This leaves the facility in Clive, Utah, operated by EnergySolutions, as the only available destination for low-level radioactive waste requiring controlled disposal, until 9

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

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

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

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Page x of xv the construction of Waste Control Specialist's facility in Andrews County, Texas, is complete.

For the purpose of this analysis, the EnergySolutions' facility is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A [121).

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel. As a proxy, the disposal cost for this material is based upon the last published rate schedule for non-compact waste for the Barnwell facility.

The dismantling of the components residing closest to the reactor core generates radioactive waste that may be 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.

For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used for spent fuel. The GTCC is disposed of in a manner similar to high-level waste, at a cost equivalent to that envisioned for the spent fuel. Until a facility is available to accept the GTCC, it is stored with the spent fuel at the ISFSI.

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 for Davis-Besse reflects the savings from waste recovery/volume reduction.

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

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. I Decommissioning Cost Analysis Page xi of xv High-Level Radioactive Waste Management Congress passed the "Nuclear Waste Policy Act"['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. The 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 and the successful resolution of pending litigation. 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 and adequate funding, the DOE had expected that receipt of fuel could begin as early as 2020.[14] However, President Obama's first federal budget proposal, submitted to Congress in February 2009, recommended that the Yucca Mountain program "be scaled back to those costs necessary to answer inquiries from the Nuclear Regulatory Commission, while the Administration devises a new strategy toward nuclear waste disposal."[15]

If the Administration's actions result in the termination of the Yucca Mountain program, it may be some time before "a new strategy" provides tangible results (i.e.,

removal of spent fuel from the Davis-Besse site). As such, for purposes of this analysis, FirstEnergy has assumed that the spent fuel transfer process will not be completed (ISFSI emptied) until the year 2100. In the interim, the spent fuel is assumed to be stored at the site.

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 13 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982 14 "Project Decision Schedule," DOE/RW-0604, U.S. Department of Energy, Office of Civilian Radioactive Waste Management, January 2009 15 "A New Era of Responsibility, Renewing America's Promise," President Obama's Budget for FY 2010, Office of Management and Budget, page 65, February 2009 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Page xii of xv transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).1161 This funding requirement is ftilfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.

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

DOE's contracts with utilities order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. As such, the fuel from Davis-Besse would be picked up in a sequential or chronological process, depending upon its discharge date, which would extend over many years. For purposes of this analysis, a twenty year duration is assumed, with the first assemblies removed from the Davis-Besse site in 2081. The process would then be completed in the year 2100.

Consequently, costs are included within the estimate for the long-term caretaking of the spent fuel at the Davis-Besse site until the year 2100.

An ISFSI, which can be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K), has been constructed to support continued station operations.

The facility is also assumed to be available to support future decommissioning operations. This will allow decommissioning to be completed and the operating license amended to release the property, exclusive of the ISFSI, for unrestricted use.

FirstEnergy's position is that the DOE has a contractual obligation to accept Davis-Besse's fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this 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.

Site Restoration The efficient removal of the contaminated materials at the site may result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities will substantially damage power block structures, 6 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.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. I Decommissioning Cost Analysis Page xiii of xv potentially weakening the footings and structural supports. Prompt dismantling of site structures (once the facilities are decontaminated) is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process is deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force. Consequently, this study assumes that site structures are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then to be graded and stabilized.

Summary The costs to decommission Davis-Besse assumes the removal of all contaminated and activated plant components and structural materials such that the owner may then have unrestricted use of the site with no further requirements for an operating license.

Low-level radioactive waste, other than GTCC waste, is sent to a commercial processor for treatment/conditioning or to a controlled disposal facility.

Decommissioning is accomplished within the 60-year period required by current NRC regulations. Throughout, and beyond, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility is complete. Once emptied, the ISFSI is decommissioned.

The decommissioning scenario is described in Section 2. The assumptions are presented in Section 3, along with the schedule of annual expenditures. The major cost contributors are identified in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendix C. The major cost components are also identified in the cost summary provided at the end of this section.

The cost elements in the estimate 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 Part 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 "Spent Fuel Management" subcategory contains costs associated with the containerization and transfer of spent fuel from the wet storage pool to the ISFSI for interim storage, as well as the transfer of the fuel in storage at the ISFSI to the DOE.

Costs are included for the operation of the storage pool and the management of the ISFSI until such time that the transfer is complete.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Page xiv of xv "Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.

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

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

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

As noted within this document, the estimate was developed and costs are presented in 2010 dollars. As such, the estimate does not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the plant or during the decommissioning period.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Page xv of xv COST

SUMMARY

DECOMMISSIONING COST ELEMENTS (thousands of 2010 dollars)

Cost Element Total Decontamination 10,385 Removal 122,605 Packaging 16,307 Transportation 12,796 Waste Disposal 58,160 Off-site Waste Processing 20,822 Program Management [1]

502,258 Spent Fuel Pool Isolation 11,477 Spent Fuel (ISFSI Related) [21 195,423 Insurance and Regulatory Fees 49,541 Energy 16,243 Characterization and Licensing Surveys 17,543 Property Taxes 122,851 Miscellaneous Equipment 6,605 Site O&M

_21,493 Corporate A&G 30,489 Other [3]

1,203 Total [41 j 1,216,201 Cost Element NRC License Termination 530,343

,4Spent Fuel Management 610,813 Site Restoration 75,045 Total [4]

1i,216,201 Includes engineering costs Excludes program management costs (staffing) but includes costs for spent fuel loading/transfer/spent fuel pool O&M and EP fees Disposal of clean asbestos containing materials, e.g., from the cooling tower Columns may not add due to rounding

[1]

[2]

[3]

[4]

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page I of 9

1. INTRODUCTION This report presents an estimate of the costs to decommission the Davis-Besse Nuclear Power Station (Davis-Besse) following the currently scheduled cessation of station operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,[11* updated to reflect current assumptions pertaining to the disposition of the nuclear station and relevant industry experience in undertaking such projects. The current estimate is designed to provide FirstEnergy Corp.

(FirstEnergy) with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning.

1.1 OBJECTIVES OF STUDY The objectives of this study are to prepare a comprehensive estimate of the cost to decommission Davis-Besse, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.

The operating license for the nuclear unit was issued on April 22, 1977. An application for license renewal was filed on August 30, 2010 to permit operations up to 60 years. However, for purposes of this analysis, Davis-Besse is assumed to cease operations on April 22, 2017, after approximately 40 years.

1.2 SITE DESCRIPTION The Davis-Besse is site located on the southwestern shore of Lake Erie in Ottawa County, Ohio (Figure 1). The City of Toledo is located approximately 20 miles to the west of the power station. The Bechtel Corporation and its affiliate, the Bechtel Company, provided architectural engineering services for the station design and construction management services for the plant construction.

The Nuclear Steam Supply System (NSSS) consists of a pressurized water reactor and a two-loop Reactor Coolant System (RCS), supplied by the Babcock and Wilcox Company. Following a 1.63% power uprate in 2008, the generating unit has a reference core design of 2,817 MWt (megawatts-thermal). This corresponds to a net design electrical output of 908 MWe (megawatts-electric)

• References provided in Section 7 of the document TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 2 of 9 and maximum dependable net electrical capacity of 894 MWe, with the reactor at rated power.

The RCS is comprised of the reactor vessel and two heat transfer loops, each containing a vertical once-through steam generator, and two shaft sealed coolant-circulating pumps. In addition, the system includes an electrically heated pressurizer, a pressurizer relief tank, and interconnecting piping. The system is housed within a free-standing, steel-shell containment, which is located within a separate reinforced concrete shield building. The concrete shield building consists of an upright cylinder topped with a hemispherical dome, supported on a reinforced concrete foundation mat that is keyed into sound rock.

Heat produced in the reactor is converted to electrical energy by the steam and power conversion system. A turbine-generator system converts the thermal energy of steam produced in the steam generators into mechanical shaft power and then into electrical energy. The unit turbine-generator is a General Electric 1800-rpm, M-7 design tandem-compound unit. It consists of a double-flow, high-pressure section, and two double-flow low-pressure sections. The turbine provides the extraction steam for six stages of feedwater heating and two steam generator feed pump turbines. Steam leaving the high-pressure turbine is passed through two moisture separator units (in parallel) where the steam is dried and reheated. The steam then enters the two low-pressure turbines.

The condenser circulating water system is sized to handle the maximum condenser heat loads and consists of a closed system utilizing a hyperbolic natural draft cooling tower and the associated circulating water pumps, piping and valves. Fill and makeup water is taken from Lake Erie through the intake water system and intake structure. There are four circulating water pumps which take their suction from the cooling tower discharge channel, the water is pumped through the condenser and then back to the cooling tower.

1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.121 This rule set forth financial criteria for decommissioning licensed nuclear power facilities. The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements.

The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose. Subsequent to the rule, TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 3 of 9 the NRC issued Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"[31 which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.

The rule defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated or activated portion of the plant's systems, structures and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations.

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

The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with rulemaking permitting the controlled release of a site,J41 the NRC has re-evaluated this alternative. The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombments.[51 The NRC's staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, and the NRC's current priorities, at least until after the additional research studies are complete. The NRC Commissioners concurred with the staffs recommendation.

In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.[6]

When the decommissioning TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 4 of 9 regulations were adopted in 1988, it was assumed that the majority of licensees would operate for their full licensed life. However, shortly after the regulations were enacted, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements.

The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process from operations to decommissioning.

Under the revised regulations, licensees will submit written certification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel.

Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Within two years of submitting notice of permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequence and

schedule, and an estimate of expected costs.

Prior to completing decommissioning, the licensee is required to submit an application to the NRC to terminate the license, which will include a license termination plan (LTP).

1.3.1 Nuclear Waste Policy Act Congress passed the "Nuclear Waste Policy Act"[7 1 (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. The 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.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 5 of 9 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 and the successful resolution of pending litigation. 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 and adequate funding, the DOE had expected that receipt of fuel could begin as early as 2020.[81 However, President Obama's first federal budget proposal, submitted to Congress in February 2009, recommended that the Yucca Mountain program "be scaled back to those costs necessary to answer inquiries from the Nuclear Regulatory Commission, while the Administration devises a new strategy toward nuclear waste disposal."[g9 If the Administration's actions result in the termination of the Yucca Mountain program, it may be some time before "a new strategy" provides tangible results (i.e., removal of spent fuel from the Davis-Besse site). As such, for purposes of this analysis, FirstEnergy has assumed that the spent fuel transfer process will not be completed (ISFSI emptied) until the year 2100. In the interim, the spent fuel is assumed to be stored at the site.

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).[ 101 This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.

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

DOE's contracts with utilities order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. As such, the fuel from Davis-Besse would be picked up in a sequential or chronological process, depending upon its discharge date that would extend over many years. For purposes of this analysis, a twenty year duration is assumed, with the first assemblies removed from the Davis-TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 6 of 9 Besse site in 2081. The process would then be completed in the year 2100. Consequently, costs are included within the estimate for the long-term caretaking of the spent fuel at the Davis-Besse site until the year 2100.

An ISFSI, which can be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K), has been constructed to support continued station operations. The facility is also assumed to be available to support future decommissioning operations.

This will allow decommissioning to be completed and the operating license amended to release the property, exclusive of the ISFSI, for unrestricted use.

FirstEnergy's position is that the DOE has a contractual obligation to accept Davis-Besse's fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this 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.

1.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,[111 and its Amendments of 1985,[121 the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. However, with the exception of Texas (which has issued a license for a new facility), no new compact facilities have been successfully sited, licensed, and constructed.

Until recently, there were two facilities available to FirstEnergy for the disposal of low-level radioactive waste generated by Davis-Besse. As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of the states of Connecticut, New Jersey and South Carolina). This leaves the facility in Clive, Utah, operated by EnergySolutions, as the only available destination for low-level radioactive waste requiring controlled disposal, until the construction of Waste Control Specialist's facility in Andrews County, Texas, is complete.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document P07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 7 of 9 For the purpose of this analysis, the EnergySolutions' facility is used as the basis for estimating the disposal cost for the lowest level and majority of the radioactive waste (Class A [131). EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel.

As a proxy, the disposal cost for this material is based upon the last published rate schedule for non-compact waste for the Barnwell facility.

The dismantling of the components residing closest to the reactor core generates radioactive waste that may be 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 (Greater-than Class C or 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.

For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used for spent fuel. The GTCC is disposed of in the same manner as high-level waste, at a cost equivalent to that envisioned for the spent fuel. Until a facility is available to accept the GTCC, it is stored with the spent fuel at the ISFSI.

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 andlor 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, decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Davis-Besse reflects the savings from waste recovery/volume reduction.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 1, Page 8 of 9 1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination,"[ 14] amending 10 CFR Part 20. This subpart provides radiological criteria for releasing a facility for unrestricted use.

The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).

The decommissioning estimate assumes that the Davis-Besse site will be remediated to a residual level consistent with the NRC-prescribed level.

It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).[' 5l An additional and separate limit of 4 millirem per year, as defined in 40 CFR § 141.16, is applied to drinking water.[161 On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU)[171 provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.

The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees. The present study does not include any costs for this occurrence.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document FO 7-1619-004, Rev. 1 Section 1, Page 9 of 9 FIGURE 1.1 DAVIS-BESSE NUCLEAR POWER STATION SITE PHOTO TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page I of 8

2. DECON DECOMMISSIONING ALTERNATIVE A detailed cost estimate was developed to decommission Davis-Besse utilizing the approved decommissioning alternative of DECON, with the ultimate objective of the release of the site for unrestricted use.

The operating license currently expires in April 2017. Spent fuel, generated over the operating life of the nuclear unit, is transferred to the ISFSI so as to facilitate decontamination and dismantling activities within the fuel handling area of the auxiliary building. Spent fuel storage operations continue at the site until the transfer of the fuel to the DOE is complete, assumed to be in the year 2100.

The following sections describe the basic activities associated with the DECON alternative. Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work, i.e.,

engineering and planning at the time of decommissioning.

The DECON alternative, as defined by the NRC, is "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." This study does not address the cost to dispose of the spent fuel residing at the site; such costs are funded through a surcharge on electrical generation. However, the study does estimate the costs incurred with the interim on-site storage of the fuel pending shipment by the DOE to an off-site disposal facility.

The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e., power production) to facility deactivation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee would then be prohibited from reactor operation.

The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimate developed for Davis-Besse is also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 2 of 8 2.1 PERIOD 1 - PREPARATIONS In anticipation of the cessation of plant operations, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Through implementation of a staffing transition plan, the organization required to manage the intended decommissioning activities is assembled from available plant staff and outside resources. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.

Engineering and Planning The PSDAR, required within two years of the notice to cease operations, provides a description of the licensee's planned decommissioning activities, a timetable, and the associated financial requirements of the intended decommissioning program. Upon receipt of the PSDAR, the NRC will make the document available to the public for comment in a local hearing to be held in the vicinity of the reactor site. Ninety days following submittal and NRC receipt of the

PSDAR, the licensee may begin to perform major decommissioning activities under a modified 10 CFR §50.59 procedure, i.e.,

without specific NRC approval. Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC, as defined by 10 CFR §61. Major components are further defined as comprising the reactor vessel and internals, large bore reactor coolant system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the §50.59 process in decommissioning. The proposed activity must not:

" foreclose release of the site for possible unrestricted use, significantly increase decommissioning costs, cause any significant environmental impact, or violate the terms of the licensee's existing license.

Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations. The environmental impact associated with the planned decommissioning activities is also considered. Typically, a licensee will not be allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 3 of 8 evaluated environmental assessments or impact statements. In this instance, the licensee would have to submit a license amendment for the specific activity and update the environmental report.

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

Site Preparations Following final plant

shutdown, and in preparation for actual decommissioning activities, the following activities are initiated:

" Initial characterization of the site and surrounding environs. This includes radiation surveys of work areas, major components (including the reactor vessel and its internals), internal piping, and sacrificial shield cores.

• Expansion of the existing ISFSI for the interim storage of spent fuel in the fuel storage pool.

• Isolation of the spent fuel storage pool and fuel handling systems, such that decommissioning operations can commence on the balance of the plant. Decommissioning operations are scheduled around the fuel handling area of the auxiliary building to optimize the overall project schedule. The fuel is transferred to the ISFSI as it decays to the point that it meets the heat load criteria of the containers. Consequently, it is assumed that the fuel pool remains operational for approximately five and one-half years following the cessation of plant operations.

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

• Development of procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste (including dry-active

waste, resins, filter media, metallic and non-metallic components generated in decommissioning), site security and emergency programs, and industrial safety.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 4 of 8 2.2 PERIOD 2 - DECOMMISSIONING OPERATIONS This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR §50 operating license. Significant decommissioning activities in this phase include:

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

Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on-and off-site) to facilitate hauling and transport.

Modifications may be required to the containment structure to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the building to support the segmentation of the reactor vessel internals and component extraction.

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

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

o Decontamination of components and piping systems as required to control (minimize) worker exposure.

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

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

Removal and segmentation of the upper internals assemblies.

Segmentation will maximize the loading of the shielded transport casks, i.e., by weight and activity. The operations are conducted under water using remotely operated tooling and contamination controls.

" Disassembly and segmentation of the remaining reactor internals, including the core former and lower core support assembly. Some material is expected to exceed Class C disposal requirements. As such, the segments will be packaged in modified fuel storage canisters for geologic disposal.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 5 of 8 Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air using remotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Segments are transferred in-air to containers that are stored under water, for example, in an isolated area of the refueling canal.

• Removal of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the associated steam generator D-rings necessary for access and component extraction are removed.

Removal of the steam generators and pressurizer for material recovery and controlled disposal. These components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized, e.g., with grout. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations.

Transfer of the spent fuel from the storage pool to the ISFSI pad for interim storage. Spent fuel storage operations continue throughout the active decommissioning period.

At least two years prior to the anticipated date of license termination, an LTP is required. Submitted as a supplement to the Final Safety Analysis Report (FSAR) or its equivalent, the plan must include:

a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. With the release criteria established via the approved LTP, the licensee may then commence with the final remediation of site facilities and services, including:

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

o Removal of the steel liners from the refueling canal, disposing of the activated and contaminated sections as radioactive waste. Removal of any activated/contaminated concrete.

• Surveys of the decontaminated areas of the containment structure.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 6 of 8

" Removal of the contaminated equipment and material from the auxiliary building, and any other contaminated facility. Use radiation and contamination control techniques until radiation surveys indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems and components (both clean and contaminated) located within the buildings. This activity will facilitate surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.

o Removal of the remaining components, equipment, and plant services in support of the area release survey(s).

" Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination is released for unrestricted disposition, e.g., as scrap, recycle, or general disposal. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.

Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)."[l81 This document incorporates the statistical approaches to survey design and data interpretation used by the EPA. It also identifies commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the survey is complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on the requested change to the operating license (that would release the property, exclusive of the ISFSI, for unrestricted use).

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

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 7 of 8 2.3 PERIOD 3 - SITE RESTORATION Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the structures. Although performed in a controlled, safe manner; blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures including the reactor and auxiliary buildings.

Under certain circumstances, verifying that subsurface radionuclide concentrations meet NRC site release requirements will require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity will be necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station.

Prompt dismantling of site structures is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers.

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

This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity. Foundations and exterior walls are removed to a nominal depth of three feet below grade.

The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can beestablished for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.

Non-contaminated concrete rubble produced by demolition activities is processed to remove rebar and miscellaneous embedments. The processed material is then used on site to backfill voids. Excess non-contaminated materials are trucked to an off-site area for disposal as construction debris.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 2, Page 8 of 8 2.4 ISFSI OPERATIONS AND DECOMMISSIONING The ISFSI will continue to operate under a general license (10 CFR §50) following the amendment of the operating license to release the adjacent (former power block) property. Assuming the DOE starts accepting fuel from Davis-Besse in 2081, transfer of spent fuel from the ISFSI is anticipated to continue through the year 2100.

At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The Commission will terminate the §50 license if it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI.

Spent fuel is stored on the ISFSI in multi-purpose canisters, within a horizontal storage module. For purposes of this cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required decontamination performed on the module (some minor activation is assumed), and the license for the facility terminated, the concrete modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad is then removed and the area regraded.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page I of 26

3. COST ESTIMATE The cost estimate prepared for decommissioning Davis-Besse considers the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimate, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.

3.1 BASIS OF ESTIMATE The estimate was developed using the site-specific, technical information from the 2005 analysis. This information was reviewed for the current analysis and updated as deemed appropriate.

The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.

3.2 METHODOLOGY The methodology used to develop the estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[191 and the DOE "Decommissioning Handbook."[20]

These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates. The activity-dependent costs are 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 rely upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.[211 The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 2 of 26 This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory

aspects, and the technical challenges of decommissioning commercial nuclear units.

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 inefficiencies associated with working in confined, hazardous environments.

The ranges used for the WDFs are as follows:

" Access Factor 10% to 20%

" Respiratory Protection Factor 10% to 50%

o Radiation/ALARA Factor 10% to 37%

" Protective Clothing Factor 10% to 30%

• Work Break Factor 8.33%

The factors and their associated range of values were developed in conjunction with the AIF/NESP-036 study. The application of the factors is discussed in more detail in that publication.

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

The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is based upon productivity information available from the "Building Construction Cost Data" publication.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 3 of 26 engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs.

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

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.

3.3.1 Contingency The activity-and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers "Project and Cost Engineers' Handbook"[221 as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, contingency is included. In the AIF/NESP-036 study, the types of unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 4 of 26 successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a

contingency. Individual activity contingencies ranged from 10% to 75%,

depending on the degree of difficulty judged to be appropriate from TLG's actual decommissioning experience. The contingency values used in this study are as follows:

• Decontamination 50%

Contaminated Component Removal 25%

Contaminated Component Packaging 10%

o Contaminated Component Transport 15%

Low-Level Radioactive Waste Disposal 25%

• Reactor Segmentation 75%

NSSS Component Removal 25%

• Reactor Waste Packaging 25%

• Reactor Waste Transport 25%

" Reactor Vessel Component Disposal 50%

GTCC Disposal 15%

o Non-Radioactive Component Removal 15%

• Heavy Equipment and Tooling 15%

• Supplies 25%

o Engineering 15%

• Energy 15%

" Characterization and Termination Surveys 30%

Construction 15%

" Taxes and Fees 10%

" Insurance 10%

o Staffing 15%

The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of the detailed estimate provided in Appendix C (i.e., 15.86%).

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

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 5 of 26 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, public participation in local community meetings, legal challenges, and national and local hearings.

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

• Regulatory changes, for example, 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, for example, the start and rate of acceptance of spent fuel by the DOE.

• Pricing changes for basic inputs such as labor, energy, materials, and disposal. Items subject to widespread price competition (such as materials) may not show significant variation; however, others such as waste disposal could exhibit large pricing uncertainties, particularly in markets where limited access to services is available.

This cost study does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimate.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 6 of 26 3.4 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study.

3.4.1 Spent Fuel Management The cost to dispose the spent fuel generated from plant operations is not reflected within the estimate to decommission Davis-Besse. Ultimate disposition of the spent fuel is within the province of the DOE's Waste Management System, as defined by the Nuclear Waste Policy Act. As such, the disposal cost is financed by a 1 mill/kWhr surcharge paid into the DOE's waste fund during operations. However, the NRC requires licensees to 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. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimate, as described below.

ISFSI FirstEnergy has constructed an ISFSI to permit continued plant operations (e.g., maintain full core off-load capability). Based upon the assumptions in this analysis regarding DOE performance, the ISFSI will need to be expanded once site operations cease to support decommissioning operations (e.g., off-load the wet storage pool so that the fuel handling area of the auxiliary building can be deactivated and/or decommissioned).

The ISFSI will continue to operate throughout decommissioning, and beyond, until such time that the transfer of spent fuel to the DOE can be completed. Assuming that the DOE does not start accepting fuel from Davis-Besse until 2081, the process is expected to be completed by the year 2100.

Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the estimate and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided for the final disposition of the facilities once the transfer is complete.

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Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 7 of 26 Canister Design The spent fuel management costs included within the decommissioning estimate are based upon a horizontal dry storage cask system for long-term storage (e.g., the NUHOMS@ system). Cask capacity is assumed to be 24 spent fuel assemblies. It is also assumed that there will be sufficient older (and cooler) fuel in the storage pool at the time of plant shutdown to mix with the warmer, last core load that the pool can be emptied within five and one half years after shutdown (i.e., that the heat load can be managed so as not to require short-loading of the casks or a longer active cooling period).

Canister Loading and Transfer The estimate includes the cost for the labor and equipment to load and transfer each spent fuel canister to the ISFSI from the wet storage pool.

For estimating purposes, 50% of this cost is used to estimate the future cost to transfer the fuel from the ISFSI into the DOE transport cask.

Operations and Maintenance The estimate also includes the cost of operating and maintaining the spent fuel pool and the ISFSI, respectively. Pool operations are expected to continue approximately five and one half years after the cessation of operations. ISFSI operating costs are based upon an 83 year period of operations following shutdown.

ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a horizontal, reinforced concrete storage module is used as a basis for the cost analyses. The modules 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. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the estimate.

GTCC The dismantling of the reactor internals may generate 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)).

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 8 of 26 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. Although the DOE is responsible for disposing of GTCC waste, any costs for that service have not been determined. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged and disposed of in a manner similar to high-level waste, at a cost equivalent to that envisioned for the spent fuel.

For purposes of this study, GTCC is packaged in the same canisters used to store spent fuel. Disposal costs are based upon a cost equivalent to that envisioned for the spent fuel. It is not anticipated that the DOE would accept this waste prior to completing the transfer of spent fuel.

Therefore, until such time the DOE is ready to accept GTCC waste, it is reasonable to assume that this material would remain in storage with the spent fuel in the ISFSI at the Davis-Besse site.

3.4.2 Reactor Vessel and Internal Components The reactor pressure vessel and internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed in the refueling canal, where a turntable and remote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor cavity. Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.

Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites that have been decommissioned.

Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel.

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 (including the internals). However, its location on the Columbia River simplified the transportation analysis since:

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 9 of 26

• the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport,

• there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and a transport speeds were very low, limited by the overland transport vehicle and the river barge.

As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State.

The characteristics of this arid site proved favorable in demonstrating compliance with land disposal regulations.

It is not known whether intact disposal (of the vessel shell or the complete vessel and internals) will be available when Davis-Besse ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition. With lower levels of activation, the vessel shell can be packaged more efficiently than the curie-limited internal components. This will allow the use of more conventional waste packages rather than shielded casks for transport (although some shielded casks are still required).

3.4.3 Primary System Components The NSSS (reactor vessel and reactor coolant system components) will be decontaminated using chemical agents prior to the start of cutting operations. A decontamination factor (average reduction) of 10 is assumed for the process. Disposal of the decontamination solution effluent is included within the estimate as a "process liquid waste" charge.

The following discussion deals with the removal and disposition of the steam generators, but the techniques involved are also applicable to other large components, such as heat exchangers, component coolers, and the pressurizer. The steam generators' size and weight, as well as their location within the reactor building, will ultimately determine the removal strategy.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 10 of 26 A trolley crane will be 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, will be removed to create sufficient laydown space for processing these large components.

The generators will be rigged for removal, disconnected from the surrounding piping and supports, and maneuvered into the open area where they will be lowered onto a dolly. Once each steam generator has been placed in the horizontal position, nozzles and other openings will be welded closed. The lower shell will have a carbon steel membrane welded to its outside surface for shielding, if required, during transport.

The interior volume will be filled with low-density cellular concrete for stabilization of the internal contamination and to satisfy burial ground packaging requirements. When this stage has been completed, each generator will be moved out of containment and lowered onto a multi-wheeled transporter to be staged at an on-site storage area and await transport to the disposal facility. The pressurizer will be removed using the same technique. Each component will then be loaded onto a railcar for transport to the disposal facility.

3.4.4 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 is 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.

3.4.5 Transportation Methods 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 49J[231 The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 11 of 26 containers. The reactor vessel and internal components are expected to be transported in accordance with Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could 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 quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.

Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be 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 shipment assumed permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits.

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

Transportation costs for material requiring controlled disposal are based upon the mileage to the EnergySolutions facility in Clive, Utah.

Transportation costs for off-site waste processing are based upon the mileage to Oak Ridge, Tennessee. Truck transport costs are estimated using published tariffs from Tri-State Motor Transit.[241 3.4.6 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptance criteria of the disposal site) and recovery of the waste stream is performed off site at a licensed processing center. Costs were based upon contracted rates for off-site processing.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 12 of 26 The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in the detailed Appendix C and summarized in Section 5. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete.

Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. The volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

Disposal fees are based upon estimated charges, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the lowest level and majority of the material generated from the decontamination and dismantling activities is based upon the current cost for disposal at EnergySolutions facility in Clive, Utah. Disposal costs for the higher activity waste (Class B and C) were based upon the last published rate schedule for non-compact waste for the Barnwell facility (as a proxy).

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

Non-essential structures or buildings severely damaged in decontamination process are removed to a nominal depth of three feet below grade.

Concrete rubble generated from demolition activities is TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 13 of 26 processed and made available as clean fill.

The excavations will be regraded such that the power block area will have a final contour consistent with adjacent surroundings.

The estimate assumes the remediation of approximately 60,000 cubic feet of contaminated soil, 30,000 pounds of contaminated lead, 5,500 gallons of contaminated hazardous liquid wastes, 143,000 cubic feet of contaminated asbestos, and 1,000 pounds of other contaminated hazardous materials. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria.

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

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

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

FirstEnergy will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. The owner will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases.

Contract personnel will provide engineering

services, e.g.,

for TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 14 of 26 preparing the activity specifications, work procedures, activation, and structural analyses, under the direction of FirstEnergy.

Security, while reduced from operating

levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel.

3.5.3 Design Conditions 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 quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major NSSS components to be shipped under current transportation regulations and disposal requirements.

The curie contents of the vessel and internals at final shutdown are derived from those listed in NUREG/CR-3474.[25] Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Davis-Besse components, projected operating life, and different periods of decay. Additional short-lived isotopes were derived from CR-0130[261 and CR-0672,[271 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.

Activation of the reactor building structures is confined to the surrounding biological shield. More extensive activation (at very low levels) of the interior structures within containment has been detected at several reactors and the owners have elected to dispose of the affected material at a controlled facility rather than reuse the material as fill on site or send it to a landfill. The ultimate disposition of the material removed from the reactor building will depend upon the site release criteria selected, as well as the designated end use for the site.

3.5.4 General Buried Piping Yard piping that is potentially contaminated will be excavated and the piping removed for survey and disposal. Clean yard piping that is less than one foot in diameter will be abandoned in place; all other yard TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 15 of 26 piping will be either excavated or backfilled to prevent future surface subsidence.

Transition Activities Existing warehouses will be cleared of non-essential material and remain for use by FirstEnergy and its subcontractors during the decommissioning program, after which the warehouses will be demolished.

The plant's operating staff will perform 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.

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

Process operating waste inventories, i.e., the estimate does not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioning expense.

Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only.

FirstEnergy 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 some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, 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 estimate do not include the additional cost for size reduction and preparation to meet "furnace TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 16 of 26 ready" conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project.

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

Eneray For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage.

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

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."[2 8]

NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.

Taxes Property taxes are included for all decommissioning periods through the demolition of the ISFSI.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 3, Page 17 of 26 Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.

Road and parking lot surfaces will be broken up and the asphalt material disposed of in a local construction debris landfill.

3.6 COST ESTIMATE

SUMMARY

Schedules of expenditures are provided in Tables 3.1 through 3.4. The tables delineate the cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).

In Appendix C, the cost elements are also assigned to one of three subcategories: "License Termination," "Spent Fuel Management," and "Site Restoration." The subcategory "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 plant's operating license, recognizing that there may be some additional cost impact from spent fuel management.

The "Spent Fuel Management" subcategory contains costs associated with the expansion of the ISFSI, containerization and transfer of spent fuel from the pool to the ISFSI for interim storage, and the transfer of casks from the ISFSI to the DOE. Costs are also included for the operations of the pool and 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.

"Site Restoration" is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.

As discussed in Section 3.4.1, it is not anticipated that the DOE will accept the GTCC waste prior to completing the transfer of spent fuel. Therefore, the cost of GTCC disposal is shown in the final year of ISFSI operation. While designated for disposal at the geologic repository along with the spent fuel, TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 3, Page 18 of 26 GTCC waste is still classified as low-level radioactive waste and, as such, included as a "License Termination" expense.

Decommissioning costs are reported in 2010 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedules are based upon the detailed activity costs reported in Appendix C, along with the timeline presented in Section 4.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. I Section 3, Page 19 of 26 TABLE 3.1 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2017 31,253 8,0671 1,908 919 10,428 52,574 2018 55,729 26,531 4,098 10,638 26,762 123,757 2019 54,158 40,509 2,605 23,838 16,127[

137,236 2020 51,118 26,099 2,206 13,327 13,864 106,615 2021 49,847 20,879 2,056 9,541 13,008 95,332 2022 45,852 17,761 1,872 8,356 12,416 86,257 2023 29,690 2,883 795 1,526 9,443 44,338 2024 21,414 7,021 330 6

8,593 37,362 2025 19,141 8,380 274 0

8,448 36,243 2026 9,049 3,031 99 0

4,727 16,906 2027 3,332 0

0 0

2,619 5,951 2028 3,341 0

0 0

2,626 5,967 2029 3,332 0

0 0

2,619 5,951 2030 3,332 0

0 0

2,6191 5,951 2031 3,332 0

0 0

2,619 5,951 2032 3,341 0

0 0

2,626 5,967 2033 3,332 0

0 0

2,619 5,951 2034 3,332 0

0 0

2,619 5,951 2035 3,332 --

01 0

0 2,619 5,951 2036 3,341 0

0 0

2,626 5,967 2037 3,332 0

0 0

2,619 5,951 2038 3,332 0

0 0

2,619 5,951 2039 3,332 0

0 0

2,619 5,951 2040 3,341 0

0 0

2,626 5,967 2041 3,332 0

0 0

2,619 5,951 2042 3,332 0

0 0

2,619 5,951 2043 3,332 0

0 0

2,6191 5,951 2044 3,341 0

0 0

2,6261 5,967 2045 3,332 0

0 0

0 2,619 5,951 2046 2047 2048 2049 3,332 3,332 0

0 0

2.619 5,951 4

4 0

2,6191 5,951 3,341 3,332 0

0 0

0 0

0 2,6261 5,967 2,6191 5.951 2050 3.332 0

01 0

2.6191 5.951 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document FO 7-1619-004, Rev. I Section 3, Page 20 of 26 TABLE 3.1 (continued)

DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 051

-3,33-22,32 0

2.619[

5.951

-- I-F F

F 2052 2053 2054 3,341 3,332 3,332 0

0 0

0 0

0 2,626 2,619 5,967 5,951 0

0 0

2,619 2055 2056 2057 2058 3,332 3,341 0

0 0

0 0

2,619 2,626 5,951 5,951 5,967 0

F F

F----------

F 3,332 3,332 0

0 0

0 0

2,619 2,619 5,951 5,951 2059 3,332 0

0 0

0 2,619 5,951 2060 2061 3,341 3.332 0

0 2,626 0

0 2,619 5,967 5,951 5,951 F

F

-F F

2062 2063

.2064 -..

2065 2066 2067 2068 2069 2070 2071 3,332 3,332 3,341 3,332 3,332 3,332 3,341 3,332 3,332 3,332 0

0 0

2,619 0

0 0

0 0

0 0

0 0

0 0

2,619 2,626 2,619 5,951 5,967 5,951 0

F 2,619 2,619 5,951 5,951 0

0 0

C 0

0 0

2,626 2,619 5,967 5,951 0

0 0

0 0

2,619 5,951 0

0]

0 2,619 5,951 F-4 0

0 2072 2073 2074 2075 3,341 3,332 3,332 3,332 0

0 0

C C

0 0

0 2,626 2,619 0

0 0

2,619 2,619 2,626 5,967 5,951 5,95.1 5,951 5,967

-4

'--4 2076 2077 2078 3,341 3,332 3,332 0

0 0

0 0

0 0

0 2,619 2,619 5,951 5,951 2079 2080 3,332 3,342 0

01 0

2,619 5,951 2

01

-4

+

+

4-C 0

2,626 2,687 5,97C 11,000 2081 3.735 01

-4

- 2082 3,551 657 01 0

2,687 6,895 2083 2084 3,551 657 0

0 2,687 6,895 3,561 6591 oi 0

2.6941 6.915 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 3, Page 21 of 26 TABLE 3.1 (continued)

DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 3, Page 22 of 26 TABLE 3.2 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2017 2018 2019 2020 29,843 50,504 46,889 42,444 4,924 14,097 1,908 9191 7,6681 45,262 22,9821 102,318 4,098 10,638 23,838 21,8781 2,605 13,127 108,337 9,890 2,206 13,327 10,835 4

2021 2022 40,707 38,464 5,591 5,405 2,056 1,872 9,541 8,356 9,980 9,887 78,703 67,876 63,984 2023 2024 2025 2026 2100 2101 Total 29,690 6,115 83 2,8831 795 1,526 293 110 6

01 0

0

_0 0

0 0

Years 2027 through 2099 9,015 1,725 0

43,909 8,249 83 30 A

A 30 0

0 0

65,788 0

0 0

0 10,766 0

11,591 0

A A

15,649 68,150 95,986 __

_ 530,3343 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 3, Page 23 of 26 TABLE 3.3 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2010 dollars)

Year Labor Equipment &

Materials Energy Burial Other Total 2017 1,048 3,143 0

0 2,759 6,950 2018 4,143 12,428 0

0 3,695!

20,265 2019 6,200 18,600 0

0 2,556 27,355 2020 5,326 15,978 0

0 2,563 23,867 2021 4,996 14,987 0

0 2,556 22,538 2022

_4,038 12,113 0

0 2,148 18,298 2023 0

0 0

0 429 429 2024 2,634 0

0 0

4,586 7,220 2025 3,281 0

0 0

5,606 8,888 2026 3,314 0

0 0

3,699 7,013 2027 3,332 0

0 0

2,619 5,951 2028 3,341 0

0 0

2,626 5,967 2029 3,332 0

0 0

2,619 5,951 2030 3,332.

.0_.

0 0

2,619 5,951 2031 3,332 0

0 0

2,619 5,951 2032 3,341 0

0 2,626 5,967 2033 3,332 0

0 01 2,619 5,951 2034 3,332

-0 01 2,619 5,951 2035 3,332 0

0 0

2,619 5,951 2036 3,341 0

0 0

2,626 5,967 2037 3,332 0

0 01 2,619 5,951 2038 3,332 0

0 0

2,619 5,951 2039 3,332 0

0 0

2,619 5,951 2040 3,341 0

0 0

2,626 5,967 2041 3,332

_0 0

0 2,619 5,951 2042 3,332 0

0 0

2,619 5,951 2043 3,332 0

0 0

2,619 5,951 2044 3,341 0

0 0

2,626 5,967 2045 3,332 0

0 2,619 5,951 2046 3,332 0

0 0

2,619 5,951 2047 3,332 0

0 0

2,619 5,951 2048 3,3411 0

0 0

2,6261 5,967 2049 3,3321 0

01flL_

0 2,6191 5,951 2050 3,3321 C

0 0

2,6191 5,951 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. I Section 3, Page 24 of 26 TABLE 3.3 (continued)

DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2051 3.332 0

0 C

2,619 5,951 2051 2052 2053 2054 2055 2056 2057 2058 2059 3.332 0

0 4

F C

2,619 5,951 3,341 3,332 0

0*

2,62C 5,967 5,951 0

0 C

0 2,619 C

C 3,332 3,341 3,332 3,332 3,332 0

C C

C C

2,619 2,619 2,626 5,951 5,951 5,967 0

0 0

C C

C C

2,619 2,619 5,951 5,951 C

C 2,619 5,951 0

C F

+

-+

+

2060 2061 3,341 3.332 0

C C

2,626 A-5,967 5.95 1 C

C 2.619 2062-3,3322,619 5,951 2062 3,332 0

0 0

2,619 5,951 2063 3,332 0

0 0

2,619 5,951 20 64.

3,341..

0 0

2,626 5,96-7 2065 3,332 0

0 0

2,619 5,951 2066 3,332 0

0 0

2,619 5,951 2067 3,332 4

0 0

2,619 5,951 2068 3,3410 0

0 2,626 5,967 2069 3,332 0

o 0

2,619 5,951 2070 3,332 0

0 0

2,619 5,951 2071 3,332 0

0 0

2,619 5,951 2072 03,341 0

0 2,6261 5,967 2073 3,332 0

10-0 2,619 5,951 2074 3,332 0,

0 0

2,619 5,951 2075 3,332 0

0 0

2,619 5,951 2076 3,341 0

0 0

2,626 5,967 2077 3,332 0

0 0

.. 2,619 5,951 2078 3,332 0

0 0

2,619 5,951 2079 3,332 0

0 0

2,619 5,951 2080 3,342 2

0 0

2,626 5,970 2081 4,577 3,735 0

0 2,687 11,000 2082 2083 3,551 3.551 657 0

0 2,687 6,895 657 0

0 2.687 6.895

+

4 2083 00 6.89 2084 3,5611 659 0

0 2,694 6,915 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 3, Page 25 of 26 TABLE 3.3 (continued)

DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 3, Page 26 of 26 TABLE 3.4 DAVIS-BESSE NUCLEAR POWER STATION SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2017 362 0

0 0

0 362 2018 1,082 6

0 0

85 1,173 2019 1,069 32 0

0 444 1,544 2020 3,347 231 0

0 466 4,044

...2021...

2022 2023 2024 2025 2026 4,145 3,350 0

12,664 15,777 5,706 301 243 0

0 0

0 472 382 2022 3,975 4-4-

4,918 3,975 0

21,893 0

6,727 8,380 0

220 274 0

0 0

2,281 0

2,842 27,273 3,031 599 0

1,028 9,863 Total 47,50T2o l, 4

18,951 593 0

i

-4 7,999 75,045 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 4, Page 1 of 4

4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follows the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan described in Section 3.4.1.

A schedule or sequence of activities for the DECON alternative from shutdown through site restoration is presented in Figure 4.1. The scheduling sequence is based on the fuel being removed from the spent fuel pool within five and one half years. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project Professional 2010" computer software.[291 4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique) Software Package. The work activity durations used in the precedence network reflect the actual man-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:

The ffuel handling area of the auxiliary building is isolated until such time that all spent fuel has been discharged from the spent fuel pool to the ISFSI. Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel to the ISFSI is complete.

• All work (except vessel and internals removal) is performed during an 8-hour workday, 5 days per week, with no overtime. There are eleven paid holidays per year.

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

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

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 4, Page 2 of 4 For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activity.

4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost table are based upon the durations developed in the schedule for decommissioning Davis-Besse. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is also shown for the spent fuel cooling period, which determines the release of the auxiliary building for final decontamination.

A project timeline is provided in Figure 4.2. Milestone dates are based on a shutdown date of April 22, 2017.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 4, Page 3 of 4 FIGURE 4.1 ACTIVITY SCHEDULE Task Name Davis-Besse Unit 1 schedule DECON Shutdown Unit I Period la Unit 1 S-hutdown through transition Certifcate of permanent cessation of operations submitted Fuel storage pool operations Dry fuel storage operations Reconfigure plant Prepare activity specifications Perform site characterization P SDAR submitteA Written certificate of permanent removal of fuel submitted Site specific decommissioning cost estimate submitted DOC staff mobilized Period lb Unit 1 - Decommissioning preparations Fuel storage pool operations Rsconflgcre plant fcontinued)

Dry fuel storage operations Prepare detailed work procedures Decon NSSS Isolate spent fuel pool Period 2a Unit 1 - Large component removal Fuel storage pool operations Dry fuel storage operations i..

m i

• r g * ~

• Preparatiio for reactor ver-Al renaioal Reactor veEsci & internal..

Renanusng large -S*S componentE di*pnoition Non-essential systems fain turbinelgenerator

,Main condenser Lice 11e termination plan zubmitted Period b Lnot I1 Decontamination (wet fuel) u...............

F el eage pool opera**ti Dr. fuci

,race ope-ratIno Remove systems not supporting wet fuel storage De con buildings not supporting wet fuel storage License termination plan approved Fuel storage pool available for decommissioning Period 2c Unit 1 - Decontamination following wet fuel storage Dry fuel storaoe oPerations Remove remaining systems

• ~

Deemn wet fu4l torige arýa Period 0d Unit 1 -Delay before licen.e termination Period 2e Unit I. Plant license termination Dry fuel storage operations Final Sine Sur, NE i

revewc & appr.,va Part 50hcense terminated Period 3 Unit 1-Site restoration Dry sue 1l strage ope-rationi Building e meihzoions, backfill and laind.caping 17 i'1S 1 '11 1'20 1'2 1'22 123 1'24 1'25 1'26 F-

• Z EJ ---

LC1 EJ TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 4, Page 4 of 4 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale)

DECON ALTERNATIVE (Shutdown April 22, 2017)

Period 1 Period 3 Transition and Period 2 Site Preparations Decommissioning 0

ISFSI perations ISFSI 04/2017 10/2018 03/2024 05/2026 12/2100 07/2101 Spent Fuel Pool Operations/

Fuel Transfer to ISFSI 09/2022 DOE Transfer ISFSI Operations 01/2081 Y

12/2100 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 5, Page I of 3

5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[301 the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.

Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR Parts 173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in 10 CFR

§173.411). For this study, commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.

The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in Appendix C, and summarized in Tables 5.1. The quantified waste volume summaries shown in these tables are consistent with Part 61 classifications. The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.

The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners.

In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste),

where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone (i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides).

While the dose rates decrease with time, radionuclides such as 137Cs will still control the disposition requirements.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 5, Page 2 of 3 The waste material produced in the decontamination and dismantling of the nuclear plants is primarily generated during Period 2. Material that is considered potentially contaminated when removed from the radiological controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.

For purposes of constructing the estimate, the cost for disposal at the EnergySolutions and Barnwell facilities were used as a proxy for future disposal facilities. Separate rates were used for containerized waste and large components, including the steam generators, reactor coolant pumps and motors. Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste.

Since EnergySolutions is not currently able to receive the more highly radioactive components generated in the decontamination and dismantling of the reactor, disposal costs for the Class B and C material were based upon the last published rate schedule for non-compact waste for the Barnwell facility (as a proxy).

Additional surcharges were included for activity, dose rate, and/or handling added as appropriate for the particular package.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 5, Page 3 of 3 TABLE 5.1 DECON ALTERNATIVE DECOMMISSIONING WASTE

SUMMARY

Waste Volume Mass Waste Cost Basis Class [1]

(cubic feet)

(pounds)

Low-Level Radioactive EnergySolutions A

305,825 15,524,887 Waste (near-surface disposal)

Barnwell B

1,712 192,069 Barnwell C

517 61,605 Greater than Class C Spent Fuel

_(geolo gicrKep2ositoiy)_.

Equivalent GTCC 453 89,800 Processed/Conditioned Recycling (off-site recycling center)

Vendors A

210,629 9,452,583 Total [21 519,136 25,320,944

[1 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.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 6, Page I of 4

6. RESULTS The analysis to estimate the costs to decommission Davis-Besse relies upon the site-specific, technical information developed for a previous analysis prepared in 2005.

While not an engineering study, the estimate provides FirstEnergy with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The estimate described in this report is based on numerous fundamental assumptions, including regulatory requirements, low-level radioactive waste disposal practices, high-level radioactive waste management options, project contingencies, and site restoration requirements.

The decommissioning scenario assumes continued operation of the station's spent fuel pool for a minimum of five and one half years following the cessation of operations for continued cooling of the assemblies.

The cost projected to promptly decommission (DECON) Davis-Besse is estimated to be $1,216.2 million. The cost associated with the physical decontamination and dismantling of the nuclear plant, so that the operating license can be terminated, represents approximately 43.6% of the total cost. Another 50.2% is related to the management, interim storage, and eventual transfer of the spent fuel. The remaining 6.2% is for the demolition of the designated structures and limited restoration of the site.

The primary cost contributors, identified in Table 6.1, are either labor-related or associated with the management and disposition of the radioactive waste. Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the decommissioning and ISFSI operations, as well as the duration of the program. It is assumed, for purposes of this analysis, that FirstEnergy will hire a contractor to manage the decommissioning. The size and composition of the management organizations (owner and contractor) varies with the decommissioning phase and associated site activities. However, once the operating license is amended, and the site exclusive of the ISFSI released for unrestricted use, the staff is substantially reduced for the conventional demolition and restoration of the site, and the long-term care of the spent fuel.

As described in this report, the spent fuel pool will remain operational for a minimum of five and one half years following the cessation of operations. The pool will be isolated and an independent spent fuel island created. This will allow decommissioning operations to proceed in and around the pool area. Over the five TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 6, Page 2 of 4 and one half-year period, the spent fuel will be packaged into transportable canisters for relocation to the ISFSI.

The cost for waste disposal includes only those costs associated with the controlled disposition of the low-level radioactive waste generated from decontamination and dismantling activities, including plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, disposition of the majority of the low-level radioactive material requiring controlled disposal is at the EnergySolutions' facility. Highly activated components, requiring additional isolation from the environment (GTCC), are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.

A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processes as survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at the EnergySolutions facility. The cost identified in the summary tables for processing is all-inclusive, incorporating the ultimate disposition of the material.

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

Decontamination and packaging costs also have a large labor component that is based upon prevailing wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can be more cost effective than deferral, due to the deterioration of the facilities (and therefore the working conditions) with time.

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

Decontamination is used to reduce the plant's radiation fields and minimize worker exposure. Slightly contaminated material or material located within a contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. I Decommissioning Cost Analysis Section 6, Page 3 of 4 uncontrolled release in-situ. Centralized processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear plant.

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

The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance.

While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Section 6, Page 4 of 4 TABLE 6.1 DECOMMISSIONING COST ELEMENTS (thousands of 2010 dollars)

Cost Element Total Percentage, Decontamination 10,385 0.9 Removal 122,605 10.1 Packaging 16,307 1.3 Transportation 12,796 1.1 Waste Disposal 58,160 4.8 Off-site Waste Processing 20,822 1.7 Program Management [1]

502,258 41.3 Spent Fuel Pool Isolation 11,477 0.9 Spent Fuel (ISFSI Related) [21 195,423 16.1 Insurance and Regulatory Fees 49,541 4.1 Energy 16,243 1.3 Characterization and Licensing Surveys 17,543 1.4 Property Taxes 122,851 10.1 Miscellaneous Equipment 6,605 0.5 Site O&M 21,493 1.8 Corporate A&G 30,489 2.5 Other [3]

1,203 0.1 Total [4]

1,216,201 100.0 Cost Element Total Percentage License Termination 530,343 43.6 Spent Fuel Mana ement 610,813 50.2 Site Restoration 75,045 6.2 Total [4]

1,216,201 100.00

[1W Includes engineering costs

[21 Excludes program management costs (staffing) but includes costs for spent fuel loading/transfer costs/spent fuel pool O&M and EP fees

[3] Disposal of clean asbestos containing materials, e.g., from the cooling tower

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

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Section 7, Page 1 of 3

7. REFERENCES

1.

"Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station,"

Document F07-1525-003, Rev. 0, TLG Services, Inc., October 2005

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

3.

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

4.

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

5.

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

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.

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

8.

"Project Decision Schedule," DOE/RW-0604, U.S. Department of Energy, Office of Civilian Radioactive Waste Management, January 2009

9.

"A New Era of Responsibility, Renewing America's Promise," President Obama's Budget for FY 2010, Office of Management and Budget, page 65, February 2009

10.

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

11.

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

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 7, Page 2 of 3

7. REFERENCES (continued)

12.

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

13.

Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55

14.

U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "Radiological Criteria for License Termination," Federal Register, Volume 62, Number 139 (p 39058 et seq.), July 21, 1997

15.

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

16.

U.S.

Code of Federal Regulations, Title 40, Part 141.16, "Maximum contaminant levels for beta particle and photon radioactivity from man-made radionuclides in community water systems"

17.

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

18.

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

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

19.

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

20.

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

Department of Energy, DOE/EV/10128-1, November 1980

21.

"Building Construction Cost Data 2010," Robert Snow Means Company, Inc.,

Kingston, Massachusetts

22.

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

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Section 7, Page 3 of 3

7. REFERENCES (continued)

23.

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

24.

Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March

2004, Radioactive Materials Tariff, March 2010

25.

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

26.

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

27.

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

28.

"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

29.

"Microsoft Project Professional 2010," Microsoft Corporation, Redmond, WA.

30.

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

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Appendix A, Page I of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Set-vices, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Appendix A, Page 2 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example:

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

1.

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

2.

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

(minutes)*

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

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

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

Unbolt from mounts 30 30 h

Remove contamination controls 15 15 i

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

+ Respiratory protection adjustment (50% of critical duration) 128

+ Radiation/ALARA adjustment (37% of critical duration) 95 Adjusted work duration 478

+ Protective clothing adjustment (30% of adjusted duration) 143 Productive work duration 621

+ Work break adjustment (8.33 % of productive duration) 52 Total work duration (minutes) 673

• • • Total duration = 11.217 hr ***

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

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. I Appendix A, Page 3 of 4 APPENDIX A (continued)

3.

LABOR REQUIRED Duration (hours)

Crew Number Laborers Craftsmen Foreman General Foreman Fire Watch Health Physics Technician 3.00 2.00 1.00 0.25 0.05 1.00 11.217 11.217 11.217 11.217 11.217 11.217 Rate

($/hr)

$39.51

$56.89

$60.02

$62.81

$39.51

$41.28

$1,329.55

$1,276.27

$673.24

$176.13

$22.16

$463.04

$3,940.39 Cost Total Labor Cost

4.

EQUIPMENT & CONSUMABLES COSTS Equipment Costs Consumables/Materials Costs

-Blotting paper 50 @ $0.49 sq ft (1)

-Tarp, oil/fire retardant, 7.5 mils, 50 @ $0.36/sq ftj2)

-Gas torch consumables 1 @ $8.91/hr x 1 h* 131 Subtotal cost of equipment and materials Overhead & profit on equipment and materials @ 17.00 %

none

$24.50

$18.00

$8.91

$51.41

$8.74

$60.15 Total costs, equipment & material TOTAL COST:

Removal of contaminated heat exchanger <3000 pounds:

Total labor cost:

Total equipment/material costs:

Total craft labor man-hours required per unit:

$4,000.54

$3,940.39

$60.15 81.88 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Appendix A, Page 4 of 4

5.

NOTES AND REFERENCES

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

" References for equipment & consumables costs:

1. www.mcmaster.com online catalog, McMaster Carr Spill Control (7428T13)

2. R.S. Means (2010) Division 01 56, Section 13.60-0600, page 20

3. R.S. Means (2010) Division 01 54 33, Section 40-6360, page 658 Material and consumable costs were adjusted using the regional indices for Toledo, Ohio.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Appendix B, Page I of 7 APPENDIX B UNIT COST FACTOR LISTING (DECON: Power Block Structures Only)

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.45 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.70 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 6.79 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 13.55 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 25.92 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 33.63 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 49.49 Removal of clean pipe >36 inches diameter, $/linear foot 58.83 Removal of clean valve >2 to 4 inches 89.38 Removal of clean valve >4 to 8 inches 135.50 Removal of clean valve >8 to 14 inches 259.18 Removal of clean valve >14 to 20 inches 336.26 Removal of clean valve >20 to 36 inches 494.89 Removal of clean valve >36 inches 588.33 Removal of clean pipe hanger for small bore piping 28.78 Removal of clean pipe hanger for large bore piping 103.44 Removal of clean pump, <300 pound 227.02 Removal of clean pump, 300-1000 pound 639.03 Removal of clean pump, 1000-10,000 pound 2,523.23 Removal of clean pump, >10,000 pound 4,874.43 Removal of clean pump motor, 300-1000 pound 269.18 Removal of clean pump motor, 1000-10,000 pound 1,051.52 Removal of clean pump motor, >10,000 pound 2,365.93 Removal of clean heat exchanger <3000 pound 1,353.69 Removal of clean heat exchanger >3000 pound 3,400.03 Removal of clean feedwater heater/deaerator 9,593.36 Removal of clean moisture separator/reheater 19,734.61 Removal of clean tank, <300 gallons 292.21 Removal of clean tank, 300-3000 gallon 924.30 Removal of clean tank, >3000 gallons, $/square foot surface area 7.82 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean electrical equipment, <300 pound 124.60 Removal of clean electrical equipment, 300-1000 pound 438.26 Removal of clean electrical equipment, 1000-10,000 pound 876.51 Removal of clean electrical equipment, >10,000 pound 2,094.48 Removal of clean electrical transformer < 30 tons 1,454.59 Removal of clean electrical transformer > 30 tons 4,188.95 Removal of clean standby diesel generator, <100 kW 1,485.73 Removal of clean standby diesel generator, 100 kW to 1 MW 3,316.26 Removal of clean standby diesel generator, >1 MW 6,865.31 Removal of clean electrical cable tray, $/linear foot 11.60 Removal of clean electrical conduit, $/linear foot 5.06 Removal of clean mechanical equipment, <300 pound 124.60 Removal of clean mechanical equipment, 300-1000 pound 438.26 Removal of clean mechanical equipment, 1000-10,000 pound 876.51 Removal of clean mechanical equipment, >10,000 pound 2,094.48 Removal of clean HVAC equipment, <300 pound 150.66 Removal of clean HVAC equipment, 300-1000 pound 526.59 Removal of clean HVAC equipment, 1000-10,000 pound 1,049.51 Removal of clean HVAC equipment, >10,000 pound 2,094.48 Removal of clean HVAC ductwork, $/pound 0.47 Removal of contaminated instrument and sampling tubing, $/linear foot 1.36 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 19.47 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 33.39 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 53.47 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 104.10 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 124.80 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 172.35 Removal of contaminated pipe >36 inches diameter, $/linear foot 203.54 Removal of contaminated valve >2 to 4 inches 401.58 Removal of contaminated valve >4 to 8 inches 485.01 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-004, Rev. 1 Decommissioning Cost Analysis Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated valve >8 to 14 inches 991.31 Removal of contaminated valve >14 to 20 inches 1,258.05 Removal of contaminated valve >20 to 36 inches 1,673.74 Removal of contaminated valve >36 inches 1,985.69 Removal of contaminated pipe hanger for small bore piping 128.26 Removal of contaminated pipe hanger for large bore piping 427.12 Removal of contaminated pump, <300 pound 864.24 Removal of contaminated pump, 300-1000 pound 2,028.46 Removal of contaminated pump, 1000-10,000 pound 6,631.35 Removal of contaminated pump, >10,000 pound 16,147.96 Removal of contaminated pump motor, 300-1000 pound 869.86 Removal of contaminated pump motor, 1000-10,000 pound 2,706.87 Removal of contaminated pump motor, >10,000 pound 6,077.30 Removal of contaminated heat exchanger <3000 pound 4,000.54 Removal of contaminated heat exchanger >3000 pound 11,604.80 Removal of contaminated tank, <300 gallons 1,439.37 Removal of contaminated tank, >300 gallons, $/square foot 28.34 Removal of contaminated electrical equipment, <300 pound 670.09 Removal of contaminated electrical equipment, 300-1000 pound 1,655.55 Removal of contaminated electrical equipment, 1000-10,000 pound 3,188.99 Removal of contaminated electrical equipment, >10,000 pound 6,303.48 Removal of contaminated electrical cable tray, $/linear foot 32.28 Removal of contaminated electrical conduit, $/linear foot 15.93 Removal of contaminated mechanical equipment, <300 pound 745.35 Removal of contaminated mechanical equipment, 300-1000 pound 1,827.96 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,515.33 Removal of contaminated mechanical equipment, >10,000 pound 6,303.48 Removal of contaminated HVAC equipment, <300 pound 745.35 Removal of contaminated HVAC equipment, 300-1000 pound 1,827.96 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,515.33 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document FO 7-1619-004, Rev. 1 Decommissioning Cost Analysis Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated HVAC equipment, >10,000 pound 6,303.48 Removal of contaminated HVAC ductwork, $/pound 1.90 Removal/plasma arc cut of contaminated thin metal components, $/linear in.

3.63 Additional decontamination of surface by washing, $/square foot 7.36 Additional decontamination of surfaces by hydrolasing, $/square foot 33.58 Decontamination rig hook up and flush, $/ 250 foot length 6,275.83 Chemical flush of components/systems, $/gallon 14.77 Removal of clean standard reinforced concrete, $/cubic yard 132.29 Removal of grade slab concrete, $/cubic yard 175.02 Removal of clean concrete floors, $/cubic yard 342.66 Removal of sections of clean concrete floors, $/cubic yard 1,016.84 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 226.96 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,996.51 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 287.03 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,640.40 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 432.49 Removal of below-grade suspended floors, $/cubic yard 342.66 Removal of clean monolithic concrete structures, $/cubic yard 854.07 Removal of contaminated monolithic concrete structures, $/cubic yard 1,986.80 Removal of clean foundation concrete, $/cubic yard 670.17 Removal of contaminated foundation concrete, $/cubic yard 1,850.94 Explosive demolition of bulk concrete, $/cubic yard 29.42 Removal of clean hollow masonry block wall, $/cubic yard 92.07 Removal of contaminated hollow masonry block wall, $/cubic yard 296.04 Removal of clean solid masonry block wall, $/cubic yard 92.07 Removal of contaminated solid masonry block wall, $/cubic yard 296.04 Backfill of below-grade voids, $/cubic yard 21.57 Removal of subterranean tunnels/voids, $/linear foot 107.84 Placement of concrete for below-grade voids, $/cubic yard 114.68 Excavation of clean material, $/cubic yard 2.91 TLG Se-vices, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document F07-1619-004, Rev. 1 Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Excavation of contaminated material, $/cubic yard Removal of clean concrete rubble (tipping fee included), $/cubic yard Removal of contaminated concrete rubble, $/cubic yard Removal of building by volume, $/cubic foot Removal of clean building metal siding, $/square foot Removal of contaminated building metal siding, $/square foot Removal of standard asphalt roofing, $/square foot Removal of transite panels, $/square foot Scarifying contaminated concrete surfaces (drill & spall), $/square foot Scabbling contaminated concrete floors, $/square foot Scabbling contaminated concrete walls, $/square foot Scabbling contaminated ceilings, $/square foot Scabbling structural steel, $/square foot Removal of clean overhead crane/monorail < 10 ton capacity Removal of contaminated overhead crane/monorail < 10 ton capacity Removal of clean overhead crane/monorail >10-50 ton capacity Removal of contaminated overhead crane/monorail >10-50 ton capacity Removal of polar crane > 50 ton capacity Removal of gantry crane > 50 ton capacity Removal of structural steel, $/pound Removal of clean steel floor grating, $/square foot Removal of contaminated steel floor grating, $/square foot Removal of clean free standing steel liner, $/square foot Removal of contaminated free standing steel liner, $/square foot Removal of clean concrete-anchored steel liner, $/square foot Removal of contaminated concrete-anchored steel liner, $/square foot Placement of scaffolding in clean areas, $/square foot Placement of scaffolding in contaminated areas, $/square foot Landscaping with topsoil, $/acre Cost of CPC B-88 LSA box & preparation for use 40.11 22.19 25.13 0.30 1.04 3.53 2.10 2.03 11.67 7.14 18.90 64.88 5.78 621.24 1,696.73 1,490.98 4,071.50 6,252.04 26,180.94 0.19 4.47 12.60 11.72 33.16 5.86 38.62 15.41 24.39 23,754.59 1,896.43 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document FO 7-1619-004, Rev. 1 Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

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

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

Decontamination of surfaces with vacuuming, $/square foot 1,736.37 1,412.05 8,293.40 179.45 6,690.92 7,326.78 0.71 TLG Services, Inc.

Davis-Besse Nuclear Power Station Decommissioning Cost Analysis Document FO 7-1619-004, Rev. 1 Appendix C, Page 1 of 13 APPENDIX C DETAILED COST ANALYSIS TLG Services, Inc.

Dacs-BSesse Nuclear Power Station Decommissioning Cost Analsris Document F07-1619-004. Rer. I Appendix C, Page 2 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Ott-.tn LLRW NRC Spent Fuel site Proes.ssd Bur.alVolumes Bur.alI Utility and IoAotty Decnon Removal Packaging Transport Processing Ditposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor index Act vity/Desciprion Cost Cost Costh Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WL, Lbs.

Manhours Manhours PERIOD la - Shutdown through Transition Period la Direct Decommissioning Activities la.1.1 Prepare preliminary decommissioning cost

.1 1.2 Notification of Cessation of Operations 1 a,1.3 Remove fuel & source material la.1.4 Notification of Permanent Defueling la.1.5 Deactivate plant systems & process waste la.1.6 Prepare and submit PSDAR la.1.7 Review plant dwgs & specs.

1a.1.8 Perform detailed rad survey la.1.9 Estimate by-product inventory la,1l10 End product description lall11 Detailed by-product inventory la.1.12 Define major work sequence lail13 Perform SER and EA l1.1i4 Perform Site-Specific Cost Study ala.1.5 Preparelsubmit License Termination Plan la1.16 Receive NRC approval of termination plan Activity Specifications la.1.17.1 Plant & temporary facilities la.1.17.2 Plant systems la.1.17.3 NSSS Decontamination Flush la.1.17.4 Reactor intemals la.1.17.5 Reactor vessel la.1.17.6 Biological shield la.1.17.7 Steam generators la.1.17.8 Reinforced concrete la.1.17.9 Main Turbine la.1,17.10 Mats Condensers la.1,17.11 Plant structures & buildings la.1.17.12 Waste management la.1.17.13 Facility & she closeout 1a,1.17 Total Planning & Site Preparations la.118 Prepare dismantling sequence la.1.19 Plant prep. & temp. svces la.1.20 Design water clean-up system la.1.21 Rigging/Cont. Cntd Envlps/looling/etc.

la.l.22 Procure casksitiners & containers la.1 Subtotal Period la Activity Costs Period la Additional Costs la.2.1 Asbestos Remediation la.2 Subtotal Period la Additional Costs Period la Collateral Costs la.3.1 Small tool allowance la.3.2 Spent Fuel Capital and Transfer 130 20 150 150 a

200 30 230 230 460 89 529 026 a

100 15 115 115 100 15 115 115 130 20 150 150 750 113 863 863 310 47 357 357 500 75 575 575 410 61 471 471 a

1,300 2.000 4.600 492 74 566 509 417 63 479 431 so 8

58 58 710 107 817 817 650 98 748 748 50 8

58 58 312 47 359 359 160 24 184 92 40 6

46 40 6

46 312 47 359 179 460 69 529 529 90 14 104 52 3,783 568 4,351 3.831 240 36 276 276 2,800 420 3,220 3,220 140 21 161 161 2.200 330 2.530 2,530 123 18 141 141 12.377 1,857 14.233 13.714 57 48 92 46 46 179 52 520 520

- 148,859 1,000 1,000 1,300 7,500 3,100 5.000 4,096 4.920 4,167 500 7,100 6,500 500 3.120 1,600 4O0 400 3,120 4.600 900 37,827 2.400 1.400 1,230 73,753 4,414 10 1,278 1,027 15 1,555 8,301 8.301 4,414 10 1.278 1,027 15 1,555 8.301 8.301 4

1 4

4 5,237 786 6,022 146,859 146.859 6.022 2.027,722 54,935 2.027.722 54.935 TLG Services, Inc.

Davi,-Besse Nuclear Power Station De.o..nnimioning Cost Anaswits Document F07-1619-004, Rer. 1 Appendit C, Page 3of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burala Utility and Actvlty Decon Reooval Packaging Transport Processing Disposal Other Total Total LIc. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Acetvity Descripeon Cost Cost Costa C Co Csta Co Cost Csts Cooenno Cost Costs Costa Costs Cu. Feel Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt.. Lbs.

Manhours Manhours la.3 Subtotal Period la Collateral Costs Period la Period-Dependent Costs la.4.1 Insurance 1 a.4.2 Property taxes la.4.3 Health physics supplies la.4.4 Heavy equipment rental 1 a.4.5 Disposal of DAW generated 1 a.4.6 Plant energy budget la.4.7 NRC Fees la.4.8 Emergency Planning Fees la.4.9 Corporate A&G la.4.10 Spent Fuel Pool O&M la.4.11 ISFSI Operating Costs 1a.4.12 Site O&M 1a.4.13 Security Staff Cost la.4.14 DOC Staff Cost la.4.15 Utility Staff Cost la.4 Subtotal Period 1a Period-Dependent Costs la.0 TOTAL PERIOD la COST PERIOD lb - Decommissioning Preparations Period lb Direct Decommissioning Activities Detailed Work Procedures lb.1.1.1 Plant systems 1b.1.1.2 NSSS Decontamination Flush lb.1.1.3 Reactor internals lb.1.1.4 Remaining buildings lb.1.1.5 CRD cooling assembly tb.t.t.6 CRD housings & ICI tubes lb.1.1.7 Incore instrumentation 1b.1.1.8 Reactor vessel lb.1.1.9 Facility closeout lb.l.1.10 Missile shields lb.1.1.11 Biological shield 11b.1.1.12 Steam generators lb.1.1.13 Reinforced concrete lb.1.1.14 Main Turbine lb.1.1.15 Main Condensers lb.1.1.16 Auxiliary building lb.1.1.17 Reactor building 1b.1.1 Total lb.1.2 Decon primary loop lb.1 Subtotal Period lb Activity Costs Period lb Additional Costs lb.2.1 Spent fuel pool isolation lb.2.2 Site Characterization 4

5,237 786 6.027 4

6,022 590 447 1.038 12 12 2

2 1,282 4,033 29 2,384 769 2,714 1.599 764 89 868 5.565 657 S

19.386 29 40.109 128 1.410 1.410 403 4,436 4,436 148 738 738 67 514 514 9

51 51 358 2.742 2.742 77 846 846 271 2,985 2,985 240 1,839 1,839 115 878 878 13 102 102 130 999 999 835 6,400 6,400 98 755 755 2,908 22,294 22,294 5.800 46.989 43,024 3,965 610 610 520 147,469 12,190 20 157,471 27.114 396,286 12,190 20 580,871 2,039,912 54,955 654,624 5,456 22 1,280 1,056 57,738 9,998 75,550 65,042 9,988 473 100 250 135 100 100 100 363 120 45 120 460 100 156 156 273 273 3,325 71 544 490 15 115 115 38 288 288 20 155 39 15 115 115 15 it5 115 15 115 115 54 418 4108 18 138 69 7

52 52 10 138 138 69 529 529 15 115 58 23 179 23 179 41 314 283 41 314 283 499 3.824 3,105 54 116 69 58 179 179 31 31 719 4.733 1,000 2,500 1,350 1,000 1,000 1.000 3,630 1,200 450 1,200 4,600 1.000 1,560 1,560 2,730 2.730 33,243 1,067 1,067 33,243 28,890 10.432 528 264 792 792 528 3,325 763 4,615 3,896 9.980 1,497 11,477 11.477 4,523 1,357 5,879 5,879 719 TL3G Sercices, Ine.

Davia-Besse Nuclear Power Station Decommissioning Cost Analt-is Document F07-1619-O04, Rev. 1 Appendio C, Page 4 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I utility and Acutvity Decon Removal packaging Transport Processing Disposal Other Total Total Lis.Term.

Management Restoratuon Volume Class A Class B Class C GTCC Processed Craft Contractor Index Actol Descnpaou Cust Cost Costs

Cust,

-cost Csts Cuetneeco CostC Custs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WL, Lbs.

Manhours Mauhours Period lb Additional Costs (continuecd lb.2.3 Mixed/Hazardous Waste lb.2 Subtotal Period lb Additional Costs Period lb Collateral Costs 1b.3.1 Decon equipment 1b.3.2 DOC staff relocation expenses 1 b.3.3 Process decommissioning water waste lb.3.4 Process decommissioning chemicat flush waste 11.3.5 Small tool allowance lb.3.6 Pipe cutting equipment lb.3.7 Decon rig 1b.3.8 Spent Fuel Capital and Transfer lb.3 Subtotal Period lb Cotlateral Costs Period lb Period-Dependent Costs lb.4.1 Decon supplies 1b.4.2 Insurance 1 b.4.3 Property taxes 1b.4.4 Health physics supplies lb.4.5 Heavy equipment rental 1b.4.6 Disposal of DAW generated lb.4.7 Plant energy budget lb.4.8 NRC Fees 1b.4.9 Emergency Planning Fees lb.4.10 Corporate A&G lb.4.11 Spent Fuel Pool O&M lb.4.12 ISFSI Operating Costs lb.4.13 Site O&M lb.4.14 Security Staff Cost lb.4.15 DOC Staff Cost lb.4.16 Utility Staff Cost tb.4 Subtotal Period lb Period-Dependent Costs lb.0 TOTAL PERIOD lb COST PERIOD 1 TOTALS PERIOD 2a - Large Component Removal Period 2a Direct Decommissioning Activities Nuclear Steam Supply System Removal 2a.1.1.1 Reactor Coolant Piping 2a.1.1.2 Pressurizer Relief Tank 2a.1.1.3 Reactor Coolant Pumps & Motors 2a.1.1.4 Pressurizer 2a.1.1.5 Steam Generators 2a.1.1.6 CRDMs/ICIs/Service Structure Removal 2a.1.1.7 Reactor Vessel intemals 2a.1.1.8 Reactor Vessel 2a.1.1 Totals 530 326 1.467 322 2,645 2.645 530 326 1,467 14,503 3,176 20,002 20,002 41,195 41,195 2.467.581 7.081 2.467.581 35,971 10,432 745 50 2

1 1.100 1,400 2,197 1,101 23 247 225 23 472 19 116 44 280 63 396 1,105 124 3,041 8,681 3,165 9,786 646 2,033 17 2,404 388 1,368 806 385 45 438 2,805 4.849 9,828 17 25.995 112 857 857 166 1,271 1,271 75 383 383 808 4,174 4,174 6

2 2

165 1,265 1,265 210 1.610 1,610 1.302 96983 9,983 2,837 19,545 98562 9.983 6

29 29 65 711 711 203 2,236 2,236 62 309 309 34 259 259 5

30 30 361 2,764 2,764 39 426 426 137 1,605 1,505 121 927 927 58 443 443 7

51 51 66 503 503 421 3.226 3.226 727 5,577 5,577 1,474 11,302 11.302 3,784 30,300 28.301 1.999 341 820 341 820 360 360 20,453 66 87,364 153 107,818 220 7.197 12 79,.383 77,806 200.823 7,197 12 358,011 2,582,595 37,270 401,686 4,622.508 92,225 1,056.311 7

1 2,748 1,574 600 723 1,467 3,182 53,609 10,560 74,463 61,762 11,982 719 41,195 701 820 2.748 7,030 622 2,004 1.467 4.238 111,347 20,558 150,012 126.804 21,969 1.239 41,195 148.169 820 242 284 17 15 172 94 50 57 199 5,744 155 77 113 2,599 79 5,431 1,027 14,270 23 4

79 465 2.653 188 5,800 1.454 10,665 35 6

173 149 2,901 62 1,435 893 5,653 462 68 1,911 897 6,233 183 9,243 233 2,204 233 21,202 467 307 1,323 1,323 31 141 141 621 3.049 3,049 333 1,982 1,952 3,794 21.524 21,524 171 836 836 8,470 27,892 27,892 5,837 16,131 16,131 19,563 72.847 72,647 1.256 192 6,974 3,275 22,742 3,335 1,127 892 517 8,705 47,606 8692 517 143,596 9,348 21,269 624 745,200 5.662 100 360.226 2,577 1.875 2,904,296 11,617 5,750 71,688 4,310 281.360 26,317 1.185 955-533 26,317 1,185 5.483,167 86,771 10,094 TLG Serviee. Inc.

Davis-Besse Nuclear Poster Station Decomuaissioning Cost Anatisis Document FOT-1615-004, Ret. I Appendix C, Page 5 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Oft-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial/

utility and Actvity Itan Removal Packaging Transport Processing Disposal Other Toal Total Llc, Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Aesol Descriton Cost Cost Costs Costh Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feat Cu, Feet Cu. Feet Cu. Feet WL. Lbs.

Manhours Manhours Removal of Major Equipment 2a.1.2 Main Turbine/Generator 2a.1.3 Main Condensers Cascading Costs from Clean Building Demolition 2a.1.4.1 Reactor Building 2a.1.4.2 Auxiliary Building 2a.1.4.3 Fuel Handling Area (Aux Bldg) 2a.1.4 Totals Disposal of Plant Systems 2a.1.5.1 Auxiliary Feedwater 2a.1.5.2 Condensate Demineralizer 2a.1.5.3 Containment Hydrogen Dilution 2a.1.5.4 Containment Leak Rate Test 2a.1.5.5 Discharge On-Shore 2a.1.5.6 Electro Hydraulic Control 2a.1.5.7 Exhaust Steam 2a.1.5.8 Extraction Steam 2a.1.5.9 Feedwater-Clean 2a.1.5.10 Feedwater-RCA 2a.1.5.11 Generator Seal Oil 2a.1.5.12 Gland Steam 2a.1.5.13 Heater Drains 2a.1.5.14 Hydrogen & Carbon Dioxide Supply 2a.1.5.15 Lube Oil 2a.1.5.16 MSR Drains 2a.1.5.17 Main Condenser 2a.1.5.18 Main Generator Seal Oil 2a.1.5.19 Main Steam & Reheat - Clean 2a.1.5.20 Main Steam & Reheat - RCA 2a.1.5.21 Main Turbine 2a.1.5.22 Makeup & Purification 2a.1.5.23 Nitrogen Supply - Clean 2a.1.5.24 Nitrogen Supply-RCA 2a.1.5.25 Plant Sampling - Clean 2a.1.5.26 Plant Sampling-RCA 2a.1.5.27 Vacuum Piping 2a.1.5 Totals 2a.1.6 Scaffolding in support of decommissioning 2a.1 Subtotal Period 2a Activity Costs Period 2a Collateral Costs 2a.3.1 Process decommissioning water waste 2a.3.3 Small tool allowance 2a.3.4 Spent Fuel Capital and Transfer 2a.3 Subtotal Period 2a Collateral Costs 327 124 1,768 143 49 517 328 56 596 378 755 272 186 1.212 214 67 40 53 242 10 11 237 200 113 25 102 38 16 103 84 46 9

98 388 3

1,078 39 58 14 24 36 3.339 261 1.606 1.606 649 3,590 3,590 113 868 868 41 313 313 28 213 213 182 1.394 1,394 4.828 1.512 5,567 1,744 345.835 6.448 358.726 34,820 9,888 3.664 2,159 15,711 3

8 244 0

1 30 0

1 31 3

8 247 12 28 893 44 46 336 359 0

1 25 0

1 22 65 93 1,829 359 92 561 561 10 77 15 85 85 18 103 103 36 279 1

11 2

13 36 273 30 230 67 438 438 3

24 15 117 6

44 2

18 15 118 13 96 7

53 1

10 15 113 236 1,558 1,558 0

3 421 2.283 2,283 6

44 18 102 102 2

16 9

57 57 5

41 1,082 6,768 5.188 233 1,194 1,194 467 21,970 87,399 85,819 2,529 77 309 324 279 11 13 273 230 2,557 24 117 44 18 118 96 53 10 113 9-,239 3

3.478 1,664 44 259 16 S -

232 41 1,580 18.926 1.664 537 36 1.580 29,859 52,562 634 21 36,078 36,078 21 634 892 517 102,713 4.093 1,355 12,540 748 13.175 1,108 5,267 198 251 4,991 4.223 103.823 2,209 S -

443 2,218 776 339 2.111 1,770 996 174 2.078 375.197 7,634 S -

55 281,976 21.206 S -

851 10,501 1,103 S -

291 9,411 443 S -

769 909.336 67.699 27,193 20,600 7,164,260 232,050 10.094 883 11 3

58 1,027 21,800 11.1 91 182 91 182 5,853 3,000 22.274 35 215 35 215 231 31,373 231 31,373 139 711 711 27 209 188 4,706 36,078 4,872 36,999 899 38.052 124 38,052 124 TLG Ser-ices, Inc.

Daeio-messie Nongear Power Station Devommissioning Coot Anoca(ito Document F07-1619-004. Rev. I Appendix C, Page 6 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommnissioniog Cost Estimate (Thousands of 2010 Dollars) m IActotty Off-Site LLRW NRC Spent Fuel Sti Processed Bral Volumes Burial I Utlity and Dec-0 Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. 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. Feet Cu. Feet Cu. Fe-t CU. Feet Cu. Feet Wt., Lbs,.

Manhours Manhours l Index

• vt/w

[po Period 2a Period-Dependent Costs 2a.4.1 Decon supplies 2a.4.2 Insurance 2a.4.3 Property taxes 2a.4.4 Health physics supplies 2a.4.5 Heavy equipment rental 2a.4.6 Disposal of DAW generated 2a.4.7 Plant energy budget 2a.4.8 NRC Fees 2a.4.9 Emergency Planning Fees 2a.4.10 Corporate A&G 2a.4.11 Spent Fuel Pool O&M 2a.4.12 ISFSI Operating Costs 2a.4.13 Site O&M 2a.4.14 Security Staff Cost 2a.4.15 DOC Staff Cost 2a.4.16 Utility Staff Cost 2a.4 Subtotal Period 2a Period-Dependent Costs 2a.0 TOTAL PERIOD 2a COST PERIOD 2b - Site Decontamination Period 2b Direct Decommissioning Activities Disposal of Plant Systems 2b.1.1.1 Auxiliary Steam-Clean 2b.1.1.2 Auxiliary Steam-RCA 2b.1.1.3 Borated Water 2b.1.1.4 Chemical Addition-Clean 2b.1.1.5 Chemical Addition - RCA 2b.1.1.6 Chilled Water - Clean 2b.1.1.7 Chilled Water-RCA 2b.1.1.8 Chlorination 2b.1.1.9 Circulating Water 2b.1.1.10 Component Cooling 2h.t.1.11 Condensate 2b.1.1.12 Containment Purge 2b.1.1.13 Containment Rad Monitoring 2b.1.1.14 Containment Spray 2b.1.1.15 Containment Vacuum 2b.1.1.16 Cooling Tower Acid/Screen Wash 2b.1.1.17 Cooling Water 2b.1.1.18 Core Flooding 2b.1.1.19 Decay Heat Removal 2b.1.1.20 Demineralized Water - Clean 2b.1.1.21 Demineralized Water - RCA 2b.1.1.22 Domestic Water 2b.1.1.23 Electrical -Clean 2b.1.1.24 Electrical - Clean - RCA 2b.1.1.25 Electrical - Contaminated 2b.1.1.26 Electrical-Decon - RCA 67 1.424 2,682 S

77 67 4,105 77 1,185 26,087 11,120 13 13 715 5.867 189 3,295 1,044 2,084 2.326 1.111 129 1.263 6,846 16,626 19.959 189 61,265 17 84 84 72 787 787 587 6.454 5,808 356 1,780 1,780 402 3,084 3,084 57 336 336 494 3,789 3,789 104 1,148 1,148 208 2,292 349 2,675 2,675 167 1,278 19 148 190 1,453 1.453 1,027 7,873 7,873 2,494 19,120 19,120 2,994 22,953 22,953 9,536 75,253 70,889 36,378 199.650 157,608 2,292 1.278 148 3.718 645 3.993 645 3,993 79,857 130 191.919 257,914 402.043 79,857 130 851,876 7,282,170 232,304 861.970 6,082 3,000 22,694 93,105 39,797 2,246 29,859 57,189 892 517 212 147 2

221 18 12 85 1

78 148 1

38 223 751 24 691 45 30 48 2

141 2

13 4

23 284 150 9

362 17 95 16 0

28 863 1.886 29 449 25 1,324 15 5

156 22 282 131 2

56 3

100 56 1,753 23 63 214 4

120 5

173 3

5 30 11 91 84 21 258 132 0

13 67 2,113 32 154 277 34 1.074 32 244 61 371 371 136 810 810 2

14 30 174 174 12 90 53 305 305 6

43 34 257 461 3,044 3,044 104 794 81 455 455 31 204 204 62 385 385 12 67 67 3

26 43 326 75 421 421 167 957 957 14 110 6

36 36 4

32 129 992 801 4,897 4,897 212 1,149 1,149 499 2,945 2,945 244 1.618 2,917 747 14 580 90 1,031 43 257 18,134 794 654 988 1,239 1,791 51 142 26 326 938 417 2,666 610 110 131 32 992 21,860 1,090 1,276 11,110 4,571 65,724 2,765 169.872 4.539 265 23.569 1.529 1,722 41.877 2,685 804 4.773 736.421 14,397 14,788 110,442 1,015 50,317 962 72,742 2,717 13.778 265 456 5.985 71.173 3,050 160,121 7,301 1,983 5,318 308

-94 17,662 887,752 34.370 172,994 8,782 451,189 23,591 TLG Sernices, Inc.

Da-is-Besse Nuclear Power Station Decommnissioning Cost Analsis Document F07-1619-004. Rer, 1 Appendix C, Page 7 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Oft-Site LLRW NRC Spont Fuel Site Processed Burial Volumes Burial I Utility and Activty Decomn Removal packaging Transport Processing Disposal Otther Total Total Lic. Term.

Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Acul Oetdpion Cost Cost Costs

Cost, Costs Costs Costs Contngencs Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WL., Lbs.

Manhours Manhours Disposal of Plant Systems (continued) 2b.1.1.27 Emergency Diesel Generator - Clean 2b.1.1.28 Emergency Diesel Generator - RCA 2b.1.1.29 Fire Protection - Clean 2b.1.1.30 Fire Protection - RCA 2b.1.1.31 Fuel Oil-Clean 2b.1.1.32 Fuel Oil-RCA 2b.1.1.33 Gaseous Radwaste 2b.1.1.34 HVAC-Aux Building (Clean) 2b.1.1.35 HVAC-Aux Building (Cont) 2b.1.1.36 HVAC-Containment 2b.1.1.37 HVAC-Control Room 2b.1.1.38 HVAC-Miscetlaneous 2b.1.1.39 HVAC-Offlce Building 2b.1.1.40 HVAC-Turbine/Serice Building 2b.1.1.41 HVAC-Water Treatment Bldg 2b.1.1.42 High Pressure Injection 2b.1.1.43 Instrument Air-Clean 2b.1.1.44 Instrument Air-RCA 2b.1.1.45 Intake & Screen Wash 2b.1.1.46 Liquid Radwaste 2b.1.1.47 Liquified Propane Gas 2b.1.1.48 Low Pressure Injection 2b.1.1.49 Makeup Water Treatment-Clean 2b.1.t.50 Makeup Water Treatment -RCA 2b.1.1.51 Miscellaneous Radwaste 2b.1.1.52 NSSS I&C Piping 2b.1.1.53 Primary Water Transfer & Storage 2b.1.1.54 Reactor Coolant 2b.1.1.55 Sanitary Sewage 2b.1.1.56 Service Water - Clean 2b.1.1.57 Service Water-RCA 2b.1.1.58 Shop Facility 2b.1.1.59 Station Air - Clean 2b.1.1.60 Station Air - RCA 2b.1.1.61 Station Drainage 2b.1.1.62 Station Heating - Clean 2b.1.1.63 Station Heating - RCA 2b.1.1.64 Steam Generator 2b.1.1.65 Vent Exhaust/Stack Piping 2b.1.1 Totals 2b.1.2 Scaffolding in support of decommissioning Decontamination of Site Buildings 2b.1.3.1 Reactor Building 2b.1.3.2 Auxiliary Building 2b.1.3.3 Low Level Radwaste Storage Facility 2b.1.3 Totals 2b.1 Subtotal Period 2b Activity Costs 81 61 402 422 62 6

366 178 296 252 40 20 14 5o 6

167 96 105 77 1,475 3

73 230 59 76 2,595 254 142 6

256 234 2

50 64 222 958 326 65 154 18.231 3

6 190 7

17 528 0

0 4

23 21 133 171 4

9 289 18 24 239 173 18 24 205 175 2

4 129 9

11 44 98 1

2 69 57 74 1,199 363 0

0 9

43 46 223 396 1

3 84 3

4 46 23 123 98 424 866 13 16 175 103 2

3 74 5

7 17 539 1

1 30 4

8 266 3

4 12 36 21 25 69 228 543 705 11,398 3.505 12 93 45 305 305 60 462 188 1,161 1.161 9

71 2

13 13 160 873 873 90 570 570 159 909 909 143 816 816 30 256 206 3

24 2

16 7

57 1

7 76 406 406 14 110 37 214 214 12 89 656 3,824 3,824 2

14 14 162 942 942 35 265 28 175 175 32 154 154 956 5,562 5.062 107 617 617 48 274 274 1

7 38 295 143 940 940 0

3 8

58 22 127 127 33 256 144 1,102 123 727 727 28 149 149 112 608 608 6,796 41,178 35,335 291 1,493 1,493 1,262 5.319 5,319 215 913 913 69 261 261 1,547 6,493 6,493 8,634 49,164 43.321 93 1,967 462 5,460 71 44 1.375 837 2.992 2,468 797 2,123 807 1.338 24 16 57 7

459 453 110 717 89 12,409 1,760 90 2.308 1,027 265 870 479 105 4,383 4,000 1,814 564 764 28 7

295 5,577 3

58 3398 256 1,102 2,749 127 168 710 1,054 5,843 117,930 16,580 671 44 4.068 8.071 1,400 1,230 34 492 5,503 9,793 5.843 124,104 26.417 1,616 79,803 1,201 0,608 221,725 8,063 1,290 1,798 109 122,944 7,202 121,522 3,197 168,021 5,819 154,787 4,913 54,345 823 423 290 1,068 S -

132 57,144 3,361 2,095 29,103 1,972 1,678 646,246 29,446 3,646 64 248,950 1,549 4,653 35,342 1,100 28,280 1,530 517,671 50,094 113,923 4,145 33,058 2,982 143 5,465 226,475 4,592 48 1,108 16,161 1.149 4,738 21.176 111,649 5,931 19,447 1,303 118,435 3,170 6,163,845 360,044 33,992 25,750 909,162 42,603 176,544 8,224 50,526 2,665 1,136,232 53,492 7,334,069 439,286 1,103 14 3

72 10 1,326 886 248 180 98 40 1,672 1,106 157 25 10 192 207 393 1,089 36 135 73 14 3

27 257 532 1,189 1,672 20,440 748 965 12,002 4,704 T7G Serrices, Inc.

Davci-Besse Nuclear Power Station Decom oissioig Cost Analhi.

Document F07-1619-004, Rev,. I Appendix C, Page 8 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Ott-Site, LLRW NRC Spent Fuel site Processed RurloiVotomes Bonieti fliOtitynd AcOtvity 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 Actvity Descdipon Cost Cost Costs Costs Costs Costs Costs Contngency Costs Costs Cests Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WL, Lbs.

Manhours Manhours Period 2b Additional Costs 2b.2.1 Cooling lower fill removal 2b.2.2 Soil Remediation 2b-2 Subtotal Perod 2b Additional Costs Period 2b Collateral Costs 2b.3.1 Process decommissioning water waste 2b.3.3 Small tool allowance 2b.3.4 Decommissioning Equipment Disposition 2b.3.5 Spent Fuel Capital and Transfer 2b.3 Subtotal Period 2b Collateral Costs 4,770 147 4,917 1.046 872 6,688 8

1.308 2,508 22 864 4,858 4.858 a

1,308 2,508 1.08 1,737 11,546 4,858 6-688 60.000 6.688 600.00 85 34 381 124 85 381 158 208 33 643 241 643 223 133 682 682 612 5

7 438 438 86 135 1,021 1,021 6.000 397 44,273 6,641 50,914 50,914 309 44,273 6,966 53.055 2.141 50,914 6,000 1,009 Period 2b Period-Dependent Costs 2b.4.1 Decon supplies 694 2b.4.2 Insurance 2b.4.3 Property taxes 2b.4.4 Health physics supplies 2,866 2b.4.5 Heavy equipment rental 4.662 2b.4.6 Disposal of DAW generated 120 2b.4.7 Plant energy budget 2b.4.8 NRC Fees 2b.4.9 Emergency Planning Fees 2b.4.10 Corporate A&G 2b.4.11 Spent Fuel Pool O&M 2b.4.12 Liquid Radwaste Processing Equipment/Services 2b.4.13 ISFSI Operating Costs 2b.4.14 Site O&M 2b.4.15 Security Staff Cost 2b.4.16 DOC Staff Cost 2b,4.17 Utility Staff Cost 2b.4 Subtotal Period 2b Period-Dependent Costs 694 7,528 120 21 21 173 887 867 1,253 125 1.378 1,378 10,276 1.028 11,323 11,303 717 3,583 3.583 699 5,361 5,361 295 89 524 524 4,556 683 5.239 5,239 1,828 183 2,010 2.010 3-649 365 4,014 4.014 4,074 611 4.685 4,685 1,946 292 2,238 2,238 494 74 569 569 226 34 260 260 2.213 332 2,545 2,54 11,990 1,799 13,789 13,789 28.114 4,217 32.331 32,331 33.425 5,014 38,439 38,439 295 104,044 16,434 129,135 122,623 6,512 6.237 6.237 72,739 4.560.000 1,156 4.560,000 73.895 36,717 119 303,726 88 340,443 207 124.736 203 336,129 435.771 672,257 124,736 203 1,444,157 12,359,250 513.592 1.444,157 2b.0 TOTAL PERIOD 2b COST PERIOD 2d - Decontamination Following Wet Fuel Storage Period 2d Direct Decommissioning Activities 2d.1.1 Remove spent fuel racks Disposal of Plant Systems 2d.1.2.1 Fuel Handling 2d.1.2.2 Spent Fuel Cooling 2d.1.2 Totals Decontamination of Site Buildings 2d.1.3.1 Fuel Handling Area (Aux Bldg) 2d.1.3 Totals 2d.1.4 Scaffolding in support of decommissioning 2d.1 Subtotal Period 2d Activity Costs 2,450 33,266 1.035 227 23 77 4

0 216 16 220 16 733 685 35 733 685 35 221 3

960 1,149 131 2,535 12,W45 7,815 149,385 33,771 242,901 172,943 57,426 12,531 130,104 93.662 31 316 211 885 885 0

5 1

2 13 13 17 87 144 107 586 586 17 92 145 109 599 599 51 231 101 609 2,444 2.444 51 231 101 609 2,444 2,444 1,458 123.943 535 53 3

898 668 952 871 2.385 1,647 2,385 1,647 134 9

3,471 3,785 2.437 86 93,029 4,356 95,467 4,442 258,668 27,452 258,668 27,452 6,798 5,150 484.876 37.579 14 2

58 299 299 99 337 564 987 4.227 4.227 TLG Sercices, Isc.

Daris-Besse Nuclear Poower Station DOc.aramisianimig Cost A-tUmis Document F07-1619-004, Ret,. I Appendix C, Page 9of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Offt-Sit fLRW NRC Spent Fouel site Ptooessud Banial Volaunes Burial IOftoan Activity Des Remomal Packaging Transport Processing Disposal Other Tot Total Lie. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Coetaotor Index Activity Desciton Cost Cost Cost "

costs costs cost osta Cootingencs Costa Costs Costs Costs Cu. Feet Cu. Feet Cu. Feel Ca. Feet Cu. Feet WL, Lbs.

Manhours Masrots Period 2d Additional Costs 24.2.1 License Termination Survey Planning 2d.2 Subtotal Period 2d Additional Costs Period 2d Collateral Costs 2d.3.1 Process decommissioning water waste 2d.3.3 Small tool allowance 2d.3.4 Decommissioning Equipment Disposition 2d.3 Subtotal Period 2d Collateral Costs 1.316 395 1,711 1.711 1.316 395 1,711 1,711 12.480 12,480 44 18 31 124 44 31 142 Period 2d Period-Dependent Costs 2d.4.1 Decon supplies 200 2d.4.2 Insurance 2d.4.3 Property taxes 2d.4.4 Heath physics supplies 365 2d.4.5 Heavy equipment rental 1,173 2d.4.6 Disposal of DAW generated 23 2d.4.7 Plant energy budget 2d.4.8 NRC Fees 2d.4.9 Emergency Planning Fees 2d.4.10 Corporate A&G 2d.4.11 Liquid Radwaste Processing Equipment/Services 2d.4.12 ISFSI Operating Costs 2d.4.13 Site O&M 2d.4.14 Security Staff Cost 2d.4.15 DOC Staff Cost 2d.4.16 Utility Staff Cost 2d.4 Subtotal Period 2d Period-Dependent Costs 200 1,538 23 109 33 643 142 643 4

4 117 86 203 315 2,586 67 611 460 190 1,025 249 57 557 1,668 4.891 6,042 67 18.650 70 358 358 5

36 36 135 1,021 1,021 210 1,415 1.415 50 250 250 32 347 347 259 2,844 2.844 91 456 456 176 1,349 1.349 17 102 102 92 703 703 46 506 506 19 209 154 1,179 1.179 37 286 286 9

65 84 640 640 250 1,918 1.918 734 5,624 5,624 906 6,948 6,948 2,954 23,426 23,151 209 65 275 321 6,000 397 6,000 718 1.211 1.211 19,287 63 303,726 88 323.013 151 24,221 24,221 39 44,460 76,217 118.337 39 239,014 2d.0 TOTAL PERIOD 2d COST PERIOD 2f - License Termination Period 2f Direct Decommissioning Activities 2f.1.1 ORISE confirmatory survey 2f.1.2 Terminate license 21.1 Subtotal Period 2f Activity Costs Period 2f Additional Costs 21.2.1 License Termination Survey 2f.2 Subtotal Period 2f Additional Costs Period 2f Collateral Costs 2f,3.1 DOC staff relocation expenses 2f.3 Subtotal Period 21 Collateral Costs Period 2f Period-Dependent Costs 21.4.1 Insurance 2f.4.2 Property taxes 2f.4.3 Health physics supplies 2f.4.4 Disposal of DAW generated 2f.4.5 Plant energy budget 1,205 2,718 296 246 980 824 19,966 4,546 30,779 30,504 275 9,471 5,714 832.110 37,770 251.494 151 45 197 197 a

151 45 197 197 7.505 2,251 9,756 9.756 7,505 2,251 9.756 9.756 1,105 186 1,271 1.271 1,105 166 1,271 1,271 149,117 6,240 148,117 8,240 567 344 3,027 17 358 34 379 379 303 3,330 3,330 142 709 709 5

30 30 54 412 412 354 7,071 12 TLG Serices, Inc.

Darie-Besse Nuclear Power Station Decommisnioeing Cost Ana(lis Dcutent F07-1619-004. Re,, I Appendix C. Page 10 of 13 Table C Davis-Bense Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2818 Dollars)

I Table C

Davis-Besse Nuc ea owe Stat o DECON eco ss o g Cost st ate (Thousands o

0 0 o a s)

SActuivit Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Bural I utlity and Deson Removal Packaging Transport Processing Disposal Other Total Total Lc. Term, Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Cost Cost Costs Costs Costs Costs Costs Contingenc Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WL, Lbs.

Manhoutr Manhours I

,extu, Period 2f Period-Dependent Costs (continued) 2f.4.6 NRC Fees 2f.4.7 Emergency Planning Fees 21.4.8 Corporate A&G 2f.4.9 ISFSI Operating Costs 2f.4.10 Site O&M 2f.4.11 Security Staff Cost 2f.4.12 DOC Staff Cost 21.4.13 Utility Staff Cost 2f.4 Subtotal Period 2f Period-Dependent Costs 2f.0 TOTAL PERIOD 2f COST PERIOD 2 TOTALS PERIOD 3b - Site Restoration Period 38 Direct Decommissioning Activities Demolition of Remaining Site Buildings 3b.1.1.1 Reactor Building 3b.1.1.2 Administration Office Building 3b.1.1.3 Auxiliary Building 3b.1.1.4 Circulating Water Pump House 3b.1.1.5 Diesel Generator Building 3b.1.1.6 Fire Water Storage Tank Building 3b.1.1.7 Gatehouse (Near Storage Tank Area) 3b.1.1.8 Intake Structure 3b.1.1.9 Low Level Radwaste Storage Facility 3b.1.1.10 Miscellaneous Yard Structures 3b.1.1.11 Nitrogen Storage Building 3b.1.1.12 Nuclear Projects Center 3b.1.1.13 Office Building 3b.1.1.14 Personnel Processing Facility 3b.1.1.15 Recharge System Water Treatment Building 3b.1.1.16 Service Building # 2 3b.1.1.17 Service Building 8 4 3b.1.1.18 Service Building # 6 3b.1.1.19 Sewage Treatment Plant 3b.1.1.20 Training Simulator 3b.1.1.21 Turbine Building 3b.1.1.22 Turbine Pedestal 3b.1.1.23 Warehouse # 2 3b.1.1.24 Water Treatment Building 3b.1.1.25 Fuel Handling Area (Aux Bldg) 3b.1.1 Totals Site Closeout Activities 3b.1.2 Remove Rubble 3b.1.3 Grade & landscape site 3b.1.4 Final report to NRC 3b.1 Subtotal Period 3b Activity Costs 577 58 635 635 223 22 245 1.200 180 1.380 1,380 67 10 77 652 98 750 750 1,913 287 2.200 2.200 4,198 630 4,827 4.827 4,206 631 4,837 4.837 567 7

1 17 16.766 2,453 19,811 19,489 567 7

1 17 256527 4,916 31.035 30,713 4,840 62,639 12,458 8,863 168624 31,348 287,983 79,610 504,365 391,768 245 77 50,886 62.629

-75.154 322 354 7,071 12 188.669 322 354 7.071 148,128 194.909 97,820 14,777 169.434 156,919 892 517 20,480.600 931,793 2,752,530 4.303 1.008 1,544 124 97 12 18 415 513 2,803 23 55 506 116 12 35 20 61 38 254 2,002 795 253 147 1,697 16,851 19 1,371 18,241 646 4,949 151 1,159 232 1,775 19 143 14 111 2

14 3

21 62 477 77 590 420 3,223 3

26 8

63 76 582 17 134 2

14 5

41 3

23 9

70 6

44 38 292 300 2,303 119 914 38 291 22 169 255 1,951 2,528 19,379 4,949 1,159 1,775 143 111 14 21 477 590 3,223 26 63

- 82 134 14 41 23 70 44 292 2.303 914 291 169 1.951 19.379 22 1,576 20,978 56,217 15,558 20,832 2.042 1,582 217 265 5,568 6,319 31.329 324 964 7,598 2,061 220 623 356 1,077 455 4,171 32,139 8,373 4,449 2,140 19.946 224,826 119 3,035 1,560 227,980 1,560 3

22 206 1.576 156 23 179 179 156 2,760 21,157 179 TLG Sericea, Inc.

Dovrs-Bease Nuclear Poner Station Deconaisaioning Cost Analcois Document F07-1619-004, Rer,. I Appendix C, Page I1 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

Off-Sit LLRW NRC Spent Fuel Sift Processed BurialVolumes BurialI Utility and Activiy Decon Removal Packaging Transport processing Disposal Other Total Total Llc. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index ActivityDescrl ptton Cost Cast Costs Costs Costs Costs Costs Contngency Costs costs costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WL, Lbs.

Manhours Manhours Period 3b Additional Costs 3b.2.1 Concrete Crushing 3b.2.2 Cooling tower demolition 3b.2 Subtotal Period 3b Additional Costs Period 3b Collateral Costs 3b.3.1 Small tool allowance 3b.3.2 Corporate A&G 3b.3 Subtotal Period 3b Collateral Costs Period 3b Period-Dependent Costs 3b.4.1 Insurance 3b.4.2 Property taxes 3b.4.3 Heavy equipment rental 3b.4.4 Plant energy budget 3b.4.5 NRC ISFSI Fees 3b.4.6 Emergency Planning Fees 3b.4.7 ISFSI Operating Costs 3b.4.8 Site O&M 3b.4.9 Security Staff Cost 3b.4.10 DOC Staff Cost 3b.4.11 Utility Staff Cost 3b.4 Subtotal Period 3b Period-Dependent Costs 3b.0 TOTAL PERIOD 3b COST PERIOD 3c - Fuel Storage Operations Period 3c Period-Dependent Costs 3c.4.1 Insurance 3c.4.2 Property taxes 3c.4.3 Plant energy budget 3c.4.4 NRC ISFSI Fees 3c.4.5 Emergency Planning Fees 3c.4.6 Corporate A&G 3c.4.7 ISFSI Operating Costs 3c.4.8 Site O&M 3c.4.9 Security Staff Cost 3c.4.10 Utility Staff Cost 3c.4 Subtotal Period 3c Period-Dependent Costs 3c.0 TOTAL PERIOD 3c COST PERIOD 3d - Fuel Storage OperationslShipping Period 3d Direct Decommissioning Activities Nuclear Steam Supply System Removal 3d.1.1.1 Vessel& Internals GTCC Disposal 3d.1.1 Totals 3d.1 Subtotal Period 3d Activity Costs 606 3,649 4,255 199 199 5,681 5.681 28,376 8

92 706 547 4,197 8

640 4,903 30 229 3,461 519 3,980 3.461 549 4.209 706 4,197 4,903 229 3.980 4,209 3.038 19,612 22.650 993 99 1.092 1.092 8,729 873 9.602 9,602 052 6,533 6,533 516 77 593 593 466 47 512 512 643 64 707 707 192 29 221 221 1,880 282 2.161 2.161 5,516 827 6.343 (0) 5,392 952 11.283 1,692 12,975 12.975 6,465 970 7.435 0

1,710 5,725 36,682 50813 48,176 0

19,236 28,939 40,307 9,761 78,445 179 19,236 59,029 25,088 2,509 27,597 27.597 54.637 5,464 60,100 60,100 11.765 1,177 12,942 12,942 16,237 1,624 17.860 17.860 8.742 1,311 10.053 10,053 4,852 728 5.579 5.579 7,868 1,180 9,048 9,048 118,241 17,736 135.978 135.978 40.171 6,026 46.197 46,197 287,601 37,754 325.355 325.355 146,714 158,000 118.500 423,214 250,630 424.774 3,078.926 769,731 3,848.657 3.848,657 287.601 37,754 325,355 325,355 750 9,362 1.479 11.591 11,591 453 89,800 750 9.362 1,479 11,591 11,591 453 89.800 750 9.362 1,479 11,591 11,591 453 89,800 TLG Services lax.

DOais-B ese Nuclear Power Station Decommissianing Cost Asalssi.

Document F07-1619-004, Re,. I Appendix C, Page 12 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

I sb Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumesodale UtlitY and I

Deson Remooal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Clans B Class C GTCC Processed Craft Contractor Cost Cost Costs Costs Costs Costs Costs Confngency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WI.. Lbs.

Manhours Manhours I

Index A-ty eescnpoton Period 3d Collateral Costs 3d.3.1 Spent Fuel Capital and Transfer 3d.3 Subtotal Pedod 3d Collateral Costs Period 3d Period-Dependent Costs 3d.4.1 Insurance 3d.4.2 Property taxes 3d.4.3 Plant energy budget 3d.4.4 NRC ISFSI Fees 3d.4.5 Emergency Planning Fees 3d.4.6 Corporate A&G 3d.4.7 ISFSI Operating Costs 3d.4.8 Site O&M 3d.4.9 Security Staff Cost 3d.4.10 Utility Staff Cost 3d.4 Subtotal Period 3d Period-Dependent Costs 3d.0 TOTAL PERIOD 3d COST PERIOD 3e - ISFSI Decontamination Period 3e Direct Decommissioning Activities Period 3e Additional Costs 3e.2.1 ISFSI License Termination 3e.2 Subtotal Period 3e Additional Costs Period 3e Collateral Costs 3e.3.1 Small tool allomance 3e.3 Subtotal Period 3e Collateral Costs Period 3e Period-Dependent Costs 3e.4.1 Insurance 3e.4.2 Property taxes 3e.4.3 Plant energy budget 3e.4.4 Corporate A&G 3e.4.5 Site O&M 3e.4.6 Security Staff Cost 3e.4.7 Utility Staff Cost 3e.4 Subtotal Period 3e Period-Dependent Costs 3e.0 TOTAL PERIOD 3e COST PERIOD 3f - ISFSI Site Restoration Period 3f Direct Decommissioning Activities Period 3f Additional Costs 3f.2.1 ISFSI Demolition and Site Restoration 31.2 Subtotal Period 3f Additional Costs 18.819 2.823 21.642 21,842 18,819 2,823 21,642 21,642 9,183 918 10.101 10.101 19,997 2,000 21,997 21,997 5.549 555 6.104 6,104 5.943 594 6,537 6.537 3,200 480 3,680 3.680 1.776 266 2,042 2,042 2.880 432 3,312 3,312 43,277 6,492 49,768 49,768 14,703 2.205 16.908 16,908 106.507 13,942 120,449 120,449 1.126.903 281.726 1,408,629 1,408.629 750 9,362 125.326 18.245 153.682 11.591 142,091 453 89,800 213 5

28 39 1,247 255 1,787 213 5

28 39 1.247 255 1,787 2

-0 3

2

-0 3

1,787 737 128.037 5.883 2,560 1,787 737 128.037 5,883 2,560 3

3 152 10 167 331 33 364 53 8

61 48 7

55 191 29 220 210 32 242 985 124 1,109 39 2.233 379 2,899 167 364 81 55 220 242 1,109 5,013 3.803 8.816 128,037 5,883 11,376 215 28 2,899 737 809 809 48 128 983 46 128 983 983 083 5,938 5,938 TLG Sert-ice, fnc.

Doci-Beose Nuclear Poter Station Decomissionsing Cost Ana.sis Document F07-1613-004. Ret. 1 Appendix C. Page 13 of 13 Table C Davis-Besse Nuclear Power Station DECON Decommissioning Cost Estimate (Thousands of 2010 Dollars)

IActivity Off-Site LLRW NRC Spent Fuol Site Processed Burial Volumes Burial I Ufityand D

-non Removal PacSkagng Transport Processing Disposal Other Total Total Lc. Tern.

Management Restoraton Volume Class A Class B Class C GTCC Processed Craft Contrator Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt. Lbs.

Manhours Manhours I I

ndex AoVoty Descripton Period 3f Collateral Costs 3f.3.1 Small tool allowance 31.3 Subtotal Period 3f Collateral Costs Period 31 Period-Dependent Costs 3f.4.1 Insurance 3f.4.2 Property taxes 3f.4.3 Plant energy budget 3f.4.4 Corporate A&G 3t.4.5 Site O&M 3f.4.6 Security Staff Cost 3f.4.7 Utility Staff Cost 31.4 Subtotal Perod 3f Period-Dependent Costs 3f.0 TOTAL PERIOD 3f COST PERIOD 3 TOTALS TOTAL COST TO DECOMMISSION S

S 1

5 1

5 5

167 17 184 184 27 4

31 31 24 4

28 28 96 14 111 l

2,527 89 13 102 102 1.569 403 52 455 455 4.096 814 449 181 1,443 1,443 5,938 4.096 29,405 755 28 9,401 455,915 66.319 561.824 11.771 491,024 59.029 737 453 217.837 262,451 5,697.531 7,588 99,073 13,835 10,895 18,091 44,988 855,244 166,486 1,216,201 530,343 610,813 75,045 210,629 305,825 1,712 517 453 25,320,940 1,286,469 9,506,371 rOTAL COST TO DECOMMISSION WITH 15.86% CONTINGENCY:

$1,216,201 thousands of 2010 dollars rOTAL NRC LICENSE TERMINATION COST IS 43.61% OR:

$530,343 thousands of 2010 dollars SPENT FUEL MANAGEMENT COST IS 50.22% OR:

$610,813 thousands of 2010 dollars 9ON-NUCLEAR DEMOLITION COST IS 6.17% OR:

$75,045 thousands of 2010 dollars rOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

308,054 cubic feet rOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:

453 cubic feet rOTAL SCRAP METAL REMOVED:

37,158 tons rOTAL CRAFT LABOR REQUIREMENTS:

1,286,469 man-hours End Notes:

n/a - indicates that this activity not charged as decommissioning expense.

a - indicates that this activity performed by decommissioning staff.

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

a cell containing "- " indicates a zero value TLG Serticee, Inc.

Enclosure B L-1 3-270 Financial Escalation Analysis for the Decommissioning of Davis-Besse Nuclear Power Station, May 2011 (Seventeen pages follow)

Document F07-1619-010, Rev. 1 FINANCIAL ESCALATION ANALYSIS for the DECOMMISSIONING OF DAVIS-BESSE NUCLEAR POWER STATION C

I

/

prepared for FirstEnergy Corp.

prepared by TLG Services, Inc.

Bridgewater, Connecticut May 2011

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 2 of 17 APPROVALS Project Manager Project Engineer Date a;F/C Date Technical Manager William A. Cloutier,,r.

05/a o/a Date TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 3 of 17 REVISION LOG No.

Date Item Revised

]

Reason for Revision 0

4-29-2011 Original Issue 1

5-16-2011 Tables 1, 2 and 4 Revised costs to include contaminated soil disposition TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-010, Rev. 1 Financial Escalation Analysis Page 4 of 17 TABLE OF CONTENTS SECTION PAGE IN TR O D U CTIO N...................................................................................................

5 TABLES

1.

E scalation Sum m ary......................................................................................

10

2.

Schedule of Annual Expenditures (2010 dollars)......................................... 11

3.

E scalation B ases............................................................................................

14

4.

Schedule of Annual Expenditures (escalated dollars)................................. 15 TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-010, Rev. 1 Financial Escalation Analysis Page 5 of 17 INTRODUCTION This report presents the results of an escalation of the costs to decommission the Davis-Besse Nuclear Power Station (Davis-Besse) to the projected year of expenditure. Financial schedules are provided for the decommissioning scenario evaluated for Davis-Besse.

Decommissioning Scenario The DECON decommissioning scenario was evaluated for the Davis-Besse nuclear unit. This scenario assumes decommissioning upon expiration of the existing operating license for Davis-Besse, in April 2017. Decommissioning operations would then commence with the cessation of operations. Spent fuel is transferred from the wet storage pool to the ISFSI for interim, storage. Spent fuel storage operations continue at the site until the transfer of the fuel to the DOE is complete, assumed to be in the year 2100.

Background

The Nuclear Regulatory Commission (NRC) provided initial decommissioning requirements in its rule adopted on June 27, 1988. In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. As part of the process to demonstrate financial assurance, licensees must adjust the estimate of the cost of decommissioning their plants, in dollars of the current year (10 CFR

§50.75). To facilitate the process, and provide uniformity in reporting, the NRC periodically reissues NUREG-1307, "Report on Waste Burial Charges." This document develops the basis for the escalation of waste disposal costs (since 1986),

and identifies the appropriate indices for the labor and energy cost components.

While the NRC's burial index is not used (a site-specific index is available for Davis-Besse), the escalation analysis does rely upon the NRC's labor index (the Employment Cost Index published by the U.S. Department of Labor, Bureau of Labor Statistics (BLS)) and the NRC's energy index (the Producer Price Index).

For purposes of escalation, the NRC divides its reference costs for decommissioning into categories of labor, energy, and burial. TLG also allocates its costs for decommissioning into categories, with the NRC's labor category further subdivided into "labor" and "equipment and materials," and an "other" category added for miscellaneous fees, taxes, GTCC disposal charges and other unique or one-time expenditures.

The Financial Accounting Standards Board (FASB) issued a Statement of Financial Accounting Standards, No. 143 (FAS 143) in 2001. The Statement addressed financial accounting and reporting for obligations associated with the retirement of tangible long-lived assets and the associated asset retirement costs.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-010, Rev. 1 Financial Escalation Analysis Page 6 of 17 TLG has prepared ARO liability assessments (partial or total) for several major nuclear plant owners. The assessments follow the process outlined in FAS 143 and have been reviewed and deemed acceptable by the owner's financial auditors.

FAS 143 allows for estimating the fair value of an ARO liability by using an expected present value technique. FAS 143 states in paragraph 8: "If a present value technique is used to estimate fair value, estimates of future cash flows used in that technique shall be consistent with the objective of measuring fair value."

TLG develops future cash flows by escalating the cost categories (labor, equipment and materials, energy, low-level radioactive waste disposal, and other) with indices provided by IHS Global Insight (IHS Global Insight is a privately held company which acquired Global Insight in 2008. The combined company includes well-known businesses such as Cambridge Energy Research Associates (CERA), Jane's Information Group, and IHS Herold; it also includes the former companies known as DRI (Data Resources, Inc.) and WEFA (Wharton Econometric Forecasting Associates)). For this analysis, the escalation rate for Burial had been established through an agreement between FirstEnergy and EnergySolutions, the disposal service provider; specifically the Bureau of Labor Statistics Consumer Price Index (CPI).

Since the timeframe of decommissioning exceeds that of the published indices, in these years the inflation factor is determined using a "moving-average" method, averaging the most recent 25 years of indices to determine the future year index.

Assumptions and Methodology The baseline estimate (in 2010 dollars) was extracted from the TLG cost estimate[']

and is presented in Tables 1 and 2. A single-value effective escalation rate (composite value) is identified for Davis-Besse. This is also provided in Table 1.

Decommissioning costs were divided into the five escalation categories, for which future rate of inflation factors were established. The five categories are:

Labor Wages, fringes and benefits for craft, salaries and benefits for professional workers, clerical, administrative, service, contract workers, as well as for certain trades 1

"Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station," Document No.

F07-1619-004, TLG Services, Inc., Rev. 1 May 2011.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-010, Rev. 1 Financial Escalation Analysis Page 7 of 17 Equipment & Material Heavy equipment, specialty tooling, packaging, small

tools, construction materials, consumables, rental equipment and temporary construction facilities (trailers)

Energy Electrical power purchases (as a large industrial customer) to support site operations Burial Costs for the processing of low-level radioactive waste as well as for the controlled disposal of material that cannot be recovered (released for unrestricted use)

Other Site operating costs (not already accounted for), for example, taxes, fees, and costs for specialized services and project support activities (may include unspecified contributions from labor, equipment and materials, and transportation), and payments for one-time disposal services (e.g., Greater-than-Class C, or GTCC waste)

Escalation As previously noted, escalation factors for the cost categories were obtained from IHS Global Insight. Forecast data for labor, equipment/materials, energy, and general inflation were available through 2035. In order to extrapolate beyond the available Global Insight data, TLG calculated a 25-year moving average inflation factor to extend the Global Insight indices through 2100, the end point of the spent fuel storage component of the decommissioning scenario.

Index Selection Table 3 identifies the Global Insight forecast data sets used for the five cost categories. Consistent with NRC's guidance, TLG escalates the labor component of its decommissioning cost estimates using an Employment Cost Index (ECI) and the energy cost component with a Producer Price Index (PPI).

Use of the Consumer Price Index for Services (CPI, Services) for general services, site operating costs and one-time expenditures is consistent with the intent of the index (the measure of the average change in prices over time of goods and services).

The decommissioning process is labor intensive, with labor representing more than half of the total cost. The estimates for Davis-Besse include the cost of the craft labor performing field activities, the field supervision and support services, project management, administration, security, and costs for specialty contractors. The Employment Cost Index (ECI) is a quarterly measure of changes in labor costs. It is one of the principal economic indicators used by the Federal Reserve Bank. The TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-010, Rev. 1 Financial Escalation Analysis Page 8 of 17 index shows changes in wages and salaries and benefit costs, as well as changes in total compensation. The ECIPCTNS index, provided by Global Insight, is a yearly estimate of change in the cost of labor, defined as compensation per employee hour worked. The self-employed, owners-managers, and unpaid family workers are excluded from coverage. The ECI is designed as a fixed-weight index at the occupational level, thus eliminating the effects of employment shifts among occupations. Both components of compensation, wages/salaries, and benefits, are covered.

Equipment and material costs in the decommissioning estimates include small tools and consumables as well as the heavy construction equipment involved in the dismantling, demolition and movement of materials around the site. The Producer Price Indexes (PPI) measures monthly average changes in selling prices received by domestic producers for their output. Most of the information used in the PPI is obtained by sampling of industries in the mining and manufacturing sectors of the economy. The indexes reflect price trends for a constant set of goods and services representing the total output of an industry.

TLG's analysis uses a Consumer Price Index to project future expenditures. "Other" costs in the decommissioning estimates include such items as licensing fees, taxes, special services (for example, a fee for the geologic disposal of GTCC waste), as well as labor-intensive activities such as radiological surveys that include costs for off-site analytical services. The CUSASNS measures changes in the prices of goods and services. It is therefore more representative of the non-labor cost elements included in the decommissioning estimates.

The EnergySolutions' Life-of-Plant Disposal Agreement with FirstEnergy Corp.

specifies that CPI will be used for the escalation of disposal charges.

There will be some wastes generated in the decommissioning of Davis-Besse that are not suitable for shallow land burial and therefore cannot be shipped for disposal to EnergySolutions. This material, primarily from reactor vessel internals near the core during operations, requires greater isolation from the environment. For estimating purposes, a geologic waste repository, or some interim storage facility, is assumed to be available for the disposal of this material. The estimates for Davis-Besse assume the removal of waste designated for geologic disposal following the shipment of the spent fuel from the site, at the end of the dry fuel storage period.

Order of Operations The process to escalate the decommissioning estimates was conducted in the following sequence:

TLG Services, Inc.

Davis-Besse Nuclear Power Station Document F07-1619-010, Rev. 1 Financial Escalation Analysis Page 9 of 17

" Source information was extracted from the latest decommissioning cost analyses (reproduced in Table 2).

• The schedules of expenditures are presented in the following five categories:

Labor, Equipment & Materials, Energy, Low-Level Radioactive Waste Burial and Recycling, and Other. The appropriate escalation index for each of the five escalation categories was identified, as summarized in Table 3.

• The index values were applied against each of the decommissioning costs schedules of expenditures to calculate a schedule of future value (Table 4).

• An effective single value annual escalation rate was determined (Table 1).

Results The total estimated escalated expenditure of dollars through the completion of decommissioning for Davis-Besse, as well as the composite annual escalation rate, is presented in Table 1.

TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. I Page 10 of 17 TABLE 1 ESCALATION

SUMMARY

(millions of dollars)

Decommissioning Scenario Cash Flow Start Year Cash Flow Final Year Baseline Cost, 2010 Dollars Sum of Escalated Dollars Effective Annual Escalation Rate DECON 2017 2101 1,216.20 3,410.14 2.657%

TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 11 of 17 TABLE 2 DAVIS-BESSE NUCLEAR POWER STATION DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2017 31,253 8,067 1,908!

919 10,428 52,574 2018 55,729 26,531 4,098.

10,638 26,762 123,757 2019 54,158 40,509 2,605 23,838 16,127 137,236 2020 51,118 26,099 2,206 13,327 13,864 106,615 2021 49,847 20,879 2,056 9,541 13,008 95,332 2022 45,852 17,761 1,872 8,356 12,416 86,257 2023 29,690 2,883 795 1,526 9,443 44,338 2024 21,414 7,021 330 6

8,593 37,362 2025 19,141 8,380 274 0

8,448 36,243 2026 9,049 3,031 99 0

4,727 16,906 2027 3,332 0

0 0

2,619 5,951 2028 3,341 0

0 0

2,626 5,967

...2029...

....3,332..

... 0....

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

.. 0...

.... 2,619 5,951 2030 3,332 0

0 0

2,619 5,951 2031 3,332 0!

0 0

2,619 5,951 2032 3,341 0

0 0

2,626j 5,967 2033 3,332 0

0 0

2,619 5,951 2034 3,332 0

0 0

2,619 5,951 2035 3,332 0

0 0

2,619 5,951 2036 3,341 0

0 0

2,626 5,967 2037 2038 2039

_3,33 2 3,332 a

0

+

4 4--

0 0

0 0

0 0

2,619 2,619 2,619 5,951 5,951 5,951 3,332 0

2040 2041 2042 3,341 3,332 3,332 0

0 0

0 0

2,626 5,967 0

0 2,619 5,951 2042 00 0

0 2,619 5,951 2043 2044 2045 2046 2047 3,332 3,341 3,332 3,332 3,332 0

0 2,619 5,951 0

0 0

0 0

0 0

0 0

0 0

0 0

2,626 2,619 2,619 2,619 2,626 5,967 5,951 5,951 5,951 5,967 2048 2049 3,341 3,332 0

0 0

0 0

0 0

2,619 5,951 2050 3,332 0

2,619 5,951 TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 12 of 17 TABLE 2 (continued)

DAVIS-BESSE NUCLEAR POWER PLANT DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2051 3,332 2052 2053 2054 2055 2056 2057 2058 2059 2060 3,341 3,332 3,332 3,332 3,341 3,332 3,332 3,332 3,341 0

0 0

0 0

0 0

0 2,6191 5,951 0

0 0

2,6261 2,6191 2,6191 5,967 5,951 5,951 0

0 0

0 0

0 2,619 2,626 2,619 5,951 5,967 5,951 0

0 0

0 0

0 0

0 0

2,619 2.619 5,951 5.95 1 4--.

4-0 0

0 2,626 5,967 2061 2062 2063 2064 2065 2066 2067 2068 2069 2070 3,332 3,332 0

0 0

2,619 5,951 0

0 f0 2,619f 5,951 3,332 3,341 3,332 3,332 3,332 3,341 3,332 3,332 0

0 0

0 0

0 2,619 2,626 5,951 5,967 0

0 0

2,619 5,951 0

0 0

0 0

0 2,619 2,619 5,951 5,951 4-I-

4-0 0

4" 4---

0 0

0 0

0 0

0 2,626 2,619 2,619 5,967 5,951 5,951 2071 2072 2073 3,332 0

0 0

2,619 5,951 3,341 3.332 0

0 0

0 0

+

4-4-

4-2074 2075 2076 2077 2078 2079 2080 2081 3,332 3,332 3,341 3,332 3,332 0

0 0

0 0

0 0

2,6261 5,967 2,6191 5,951 2,619' 5,951 2,19 5,951 0

0 0

2.6261 5.967 4-4-

4-4-

0 0

0 0

2,619 5,951 0

0 3,332 3,342 4,577 0

2 3,735 0

0 0

0 0

0 0

2,619 2,626 2,687 2.687 5,951 5,951 5,970 11,000 6.895 2082 2083 2084 3,551 3,551 3,561 657 0

4-4-

657 659 01 0

2,687 6,895 0

0 2,694 6,915 TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 13 of 17 TABLE 2 (continued)

DAVIS-BESSE NUCLEAR POWER PLANT DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2010 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2085 2086 2087 2088 2089 2090 2091 2092 2093 2094 2095 2096 2097 2098 2099 2100 2101 3,551 3,551 3,551 3,561 3,551 3,551 3,551 3,561 3,551 3,551 3,551 3,561 3,551 3,551 3,551 3,547 1,189 657 0

ol 2,687 6,895 6...............

.......5.

7.

657 0

0 0

0 0

0 2,6871 2,687 2,694 659 657 657 657

-_ 659 657 657 6,895 6,895 6,915 6,895 0

0 0

0 0

0 2,687 0

0 0

0 2,687 2.687 6,895 6,895 I.

I-2,694 2,687 2,687 6,915 6,895 6,895 6,895 0

0 657 659 657 657 657 1,481 689 0

0 0

0 0

2,687 0

2.694 0

0 2,687 2,687 6,915 6,895 6,895 0

0 2,687 6,895 0

0 0

13,464 18,491 49 2.391 4.318 I Total 1 620,5801 178,9071 16,2431 68,1991 332,2721 1,216,2011 TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 14 of 17 TABLE 3 ESCALATION BASES Cost Category Escalation Source Labor Equipment and Materials Energy Global Insight Forecast Database, Employment cost index, total private compensation (ECIPCTNS)

Global Insight Forecast Database, Producer Price Index, Machinery & Equipment (WPIP 11)

Global Insight Forecast Database, Producer Price Index, Fuels and Related Products and Power (WPIP05)

Global Insight Forecast Database, Consumer price index, services (CUSASNS)

EnergySolutions Life-of-Plant agreement specifies the use of CPI; therefore Global Insight Forecast Database, Consumer price index, All Urban All Items (CPI)

Other Low-Level Radioactive Waste Processing/Disposal TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 15 of 17 TABLE 4 DAVIS-BESSE NUCLEAR POWER STATION DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands of escalated dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2017 37,556

_____8,151 2,242 1,051 12,457 61,457 2018 69,020 26,781 4,874 12,422 32,872 145,969 2019 69,079 40,930 3,105 28,438 20,357 161,909 2020 67,143, 26,394 2,628 16,214 17,981.

130,360 2021 67,478 21,126 2,458-.-

11,831 17,314 120,207 2022

__64,018 17,977 -----

2,268 10,5441 16,950 111,757 2023 42,707 2,919 975 1,958 13,222 61,781 2024 31,727 7,112 411 7

12,337 51,594 2025 29,190 8,493 348 12,440 50,471 2026 14,207 3,074 128 7,140 24,549 2027 5,383 __

4,057 9,440 2028 1 5,554 4,175 9,729 2029

_5664,273

_9,969 2030 5,858

-4,3851 10,243 2031

-~6,0261_______

4,5001 10,526 2032 6,215 4,6311 10,846 2033 6,374 1

4,739, 11,113 2034 6,555 ______4,864 11,419 2035 6,742

__4,992 11,734 2036 6,954 5,136 12,090 2037 7,136 5,258 12,394 2038 7,344

_____5,397 12,741 2039 7,559

______5,540 13,099 2040 7,803

______5,703 13,506 2041 8,011

________5,839 13,850 2042 8,246

_____5,993 14,239 2043 8,488 6,151 14,639 2044 8,760

______6,330 15,090 2045 8,991

_________6,478 15,469 2046 9,254

___6,648 15,902 2047 9,5 2 4 1 6,822 16,346 2048 9,8281 7,019 16,847 2049 10,086{

7,184 17,270 2050 10,3781_____

7,3721 17,750 TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 16 of 17 TABLE 4 (continued)

DAVIS-BESSE NUCLEAR POWER STATION DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands of escalated dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2051 10,679 7,566 18,245 2052 11,019 7,786 18,805 2053 11,307 7,969 19,276 2054 11,635 8,179 19,814 2055 11,973 8,394 20,367 2056 12,354 8,638 20,992 2057 12,677 8,841 21,518 2058 13,045 9,073 22,118 2059 13,424 9,312 22,736 2060 13,852 9,5831 23,435 2061 14,216 9,808 24,024 2062 14,630 10,066 24,696 2063 15,056 1.0.....

,331 25,387 2064 15,537 10,632 26,169 2065 15,945 10,882 26,827 2066 16,409 11,168 27,577 2067 16,887 11,462 28,349 2068 17,426 11,795 29,221 2069 17,884 12,072 29,956 2070 18,404 12,390 30,794 2071 18,940 12,716 31,656 2072 19,5441 13,086 32,630 2073 20,058 13,393 33,451 2074 20,642 13,746 34,388 2075 21,243 14,107 35,350 2076 21,921 14,518 36,439 2077 22,497 14,859 37,356 2078 23,152 15,250 38,402 2079 23,825 15,650 39,475 2080 24,591 2

16,107 40,700 2081 34,661 3,951 16,915 55,527 2082 2083 27,674 28,479 696 17,36C 45,730 696 17,816' 18,3351 46,991 48,423 2084 1

29,389 699 TLG Services, Inc.

Davis-Besse Nuclear Power Station Financial Escalation Analysis Document F07-1619-010, Rev. 1 Page 17 of 17 TABLE 4 (continued)

DAVIS-BESSE NUCLEAR POWER STATION DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands of escalated dollars)

Equipment &

Materials Year Labor Energy Burial Other Total

[--Total---[ 1,915,7621 18-1,857 19,437[

82,733ý 1,210,3461 3,410,1351 TLG Services, Inc.