Text

ISFSI; Davis-Besse, Unit 1 & ISFSI and Perry, Unit 1 & ISFSI - Triennial ISFSI Decommissioning Funding Plans
	ML15343A350
Person / Time
Site:	Beaver Valley, Davis Besse, Perry, 07201043, 07200069
Issue date:	12/09/2015
From:	Halnon G; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Division of Spent Fuel Management
References
	L-15-327
	Download: ML15343A350 (32)
	v • d • e

FENOC Fir'. AsW rwry 4paugcdrpary-\\

341 White Pond Dr.

Akron. Ohio 44320 December 9,2015 L-15-327 ATTN: Document Control Desk

Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSI Docket No. 72-1043 Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI Docket No.72-14 Perry Nuclear Power Plant, Unit No. 1 ISFSI Docket No. 72-69 Triennial ISFSI Decommissionino Fundinq Plans 10 CFR 72.30(c\\

Pursuant to the requirements of 10 CFR 72.30(cl, FirstEnergy Nuclear Operating Company (FENOC) is submitting the triennial decommissioning funding plans for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Independent Spent Fuel Storage Installation (lSFSl); the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)

ISFSI; and the Perry Nuclear Power Plant, Unit No. 1 (PNPP) ISFSI (Attachments 1 through 3, respectively).

Enclosures A through C contain the ISFSI decommissioning cost estimates for BVPS, DBNPS, and PNPP, respectively.

The initial DBNPS and PNPP ISFSI funding plans were submitted to the Nuclear Regufatory Commission (NRC) on December 17,2012 (Accession No. ML123524194).

The initial BVPS ISFSI funding plan was submitted to the NRC on December 8,2014 (Accession No. ML14342A707).

FENOC is submitting the triennial BVPS ISFSI funding plan early in order to align its submittal date with the triennial ISFSI funding plan submittal date of the other two FENOC facilities.

On December 8, 2015, the DBNPS operating license was renewed for 20 years. In accordance with 10 CFR 72.30(cl, DBNPS is required to submit a revised ISFSI decommissioning funding plan upon the renewal of the operating license. The revised DBNPS ISFSI decommissioning funding plan will be submitted by the end of first quarter 2016.

Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI Perry Nuclear Power Plant, Unit No. 1 ISFSI L-15-327 Page 2 There are no regulatory commitments contained in this letter. lf there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager Fleet Licensing, at 330-315-6810.

Vice President, Regulatory Affairs and Lab Services Attachments:

1.

Decommissioning Funding Plan for Beaver Valley Power Station, Unit Nos. 1 and 2, Independent Spent Fuel Storage Installation Decommissioning Funding Plan for Davis-Besse Nuclear Power Station, Unit No. 1 Independent Spent Fuel Storage lnstallation Decommissioning Funding Plan for Perry Nuclear Power Plant, Unit No. 1 Independent Spent Fuel Storage Installation 2.

3.

Enclosures:

A.

Beaver Valley Power Station, Unit Nos. 1 and 2, Installation Decommissioning Cost Estimate B. Davis-Besse Nuclear Power Station, Unit No. 1, Installation Decommissioning Cost Estimate Independent Spent Fuel Storage Independent Spent Fuel Storage C. Perry Nuclear Power Plant, Unit No. 1, Independent Spent Fuel Storage Installation Decommissioning Cost Estimate cc: NRC Region lAdministrator NRC Region lll Administrator NRC Resident Inspector (Beaver Valley Power Station, Unit Nos. 1 and 2)

NRC Resident Inspector (Davis-Besse Nuclear Power Station, Unit No. 1)

NRC Resident Inspector (Perry Nuclear Power Plant, Unit No. 1)

NRC Project Manager (Beaver Valley Power Station, Unit Nos. 1 and 2)

NRC Project Manager (Davis-Besse Nuclear Power Station, Unit No. 1)

NRC Project Manager (Perry Nuclear Power Plant, Unit No. 1)

NRC Project Manager (FENOC Fleet)

Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board Sincerely,

1.

2.

L-15-327 Decommissioning Funding Plan for Beaver Valley Power Station, Unit Nos. 1 and2, Independent Spent Fuel Storage Installation Page 1 of3 Pursuant to 10 CFR 72.30(c),

each licensee of an independent spent fuel storage installation (lSFSl) is required to triennially submit a decommissioning funding plan for the lSFSl. FirstEnergy Nuclear Operating Company (FENOC),

hereby, provides the updated decommissioning funding plan for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS),

lSFSl.

The initial BVPS ISFSI funding plan was submitted to the Nuclear Regulatory Commission on December 8,2014 (Accession No. ML14342A707).

FENOC is submitting the triennial BVPS ISFSI funding plan early in order to align its submittal date with the triennial ISFSI funding plan submittal date of the other two FENOC facilities, Davis-Besse Nuclear Power Station, Unit No. 1 and Perry Nuclear Power Plant, Unit No. 1, respectively.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI:

The response to ltem 4 below provides the method of financial assurance pursuant to 10 CFR 72.30(e).

A detailed cost estimate for decommissioning:

By letter dated December 8,2014 (Accession No. ML14342A707),

FENOC submitted the initial BVPS ISFSI decommissioning funding plan. The plan is based on a BVPS ISFSI decommissioning cost estimate that was enclosed in the letter. For ease of review, the BVPS ISFSI decommissioning cost estimate is provided in Enclosure A. The cost estimate assumes that an independent contractor will perform the decommissioning activities, assumes a contingency factor of 25 percent (%), and includes the cost of meeting 10 CFR 20.1402 for license termination for unrestricted use. The total decommissioning cost with contingency is $8,018,000 (2014 dollars).

Changes in the responses to the four criterion listed in 10 CFR 72.30(c) for the period between the initial plan submittal and this submittal are as follows:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: None Facili$ modifications:

None Changes in authorized possession limits: None Actual remediation costs that exceed the previous cost estimate: None 1.

2.

3.

4.

L-15-327 Page 2 of 3 3.

ldentification of and justification for using the key assumptions contained in the decommissioning cost estimate:

The ISFSI decommissioning cost estimate key assumptions and justifications are provided in Enclosure A.

A description of the method of assuring funds for decommissioning from 10 CFR 72.30(el, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility:

Financial assurance in the amount of $9,250,000 for the decommissioning of the BVPS ISFSI is provided through two parent guarantees totaling $24.5 million (Accession Nos. ML141838295 and ML151814323) that support the lSFSls located at BVPS, Davis-Besse Nuclear Power Station, and Perry Nuclear Power Plant. These guarantees will be payable to the existing nuclear decommissioning trust funds established for BVPS pursuant to the nuclear decommissioning master trust agreements.

The guarantees will provide for the ISFSI decommissioning amounts to be deposited into a separate subaccount to be maintained by the Trustee.

10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and Parent Company Guarantees for Providing Reasonable Assurance of Funds for Decommissioning,"

provides guidance for establishing parent guarantees to provide assurance for decommissioning funding. The test includes the current cost estimate for decommissioning and the amount to be guaranteed.

The regulation requires the test to be performed annually. The performance of the test, with the current decommissioning cost estimate, provides information such that the values of the parent guarantees can be adjusted to ensure that adequate funding will be available to decommission the lSFSl.

The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination:

BVPS uses the Transnuclear NUHOMS system for spent fuel storage. The NUHOMS system has been designed, fabricated, and tested to be leak tight. As a result, FENOC assumes the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination to be zerc.

4.

5.

L-15-327 Page 3 of 3

6.

A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning:

The submission of this report in conjunction with the two parent guarantees totaling

$24.5 million (Accession Nos. M1141838295 and ML15181A323) serves as certification that financial assurance has been provided in the amount of the cost estimate for ISFSI decommissioning.

1.

2.

L-15-327 Decommissioning Funding Plan for Davis-Besse Nuclear Power Station, Unit No. 1 Independent Spent Fuel Storage Installation Page 1 of3 Pursuant to 10 CFR 72.30(c),

each licensee of an independent spent fuel storage installation (lSFSl) is required to triennially submit a decommissioning funding plan for the lSFSl. FirstEnergy Nuclear Operating Company (FENOC) hereby provides the updated decommissioning funding plan for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) lSFSl.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI:

The response to number 4 below discusses the appropriate method of financial assurance contemplated under 10 CFR 72.30(e).

A detailed cost estimate for decommissioning:

In a report dated March 2,2015, TLG Services, Inc. prepared a DBNPS ISFSI decommissioning cost estimate for FENOC. This report is included as Enclosure B. This revises the decommissioning cost estimate described in the initial ISFSI decommissioning funding plan submitted to the NRC by FENOC fetter dated December 17,2012 (Accession No. ML12352A194).

The revised cost estimate, like the original cost estimate, assumes that an independent contractor will perform the decommissioning activities and includes the cost of meeting 10 CFR 20.1402 for license termination for unrestricted use. The revised estimate assumes a contingency factor of 25o/o. The total decommissioning cost with contingency is $5,493,000 (2014 dollars).

Below is the effect of the following on the detailed cost estimate since the previous report:

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: None Facility modifications:

None Changes in authorized possession limits: None Actual remediation costs that exceed the previous cost estimate: None 1.

2.

3.

4.

L-15-327 Page 2 of 3 3.

ldentification of and justification for using the key assumptions contained in the decommissioning cost estimate:

The ISFSI decommissioning cost estimate key assumptions and justifications are provided in Enclosure B.

A description of the method of assuring funds for decommissioning from 10 CFR 72.30(e),

including means for adjusting cost estimates and associated funding levels periodically over the life of the facility:

Financial assurance in the amount of $6,000,000 for the decommissioning of the DBNPS ISFSI is provided through two parent guarantees totaling $24.5 million (Accession Nos. ML141838295 and M115181A323) that support the lSFSls located at Beaver Valley Power Station, DBNPS, and Perry Nuclear Power Plant.

These guarantees will be payable to the existing nuclear decommissioning trust funds established for DBNPS pursuant to the nuclear decommissioning master trust agreements.

The guarantees will provide for the ISFSI decommissioning amounts to be deposited into a separate subaccount to be maintained by the Trustee.

10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and Parent Company Guarantees for Providing Reasonable Assurance of Funds for Decommissioning,"

provides guidance for establishing parent guarantees to provide assurance for decommissioning funding. The test includes the current cost estimate for decommissioning and the amount to be guaranteed.

The regulation requires the test to be performed annually. The performance of the test, with the current decommissioning cost estimate, provides information such that the values of the parent guarantees can be adjusted to ensure that adequate funding will be available to decommission the lSFSl.

The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination:

DBNPS uses the Transnuclear NUHOMS system for spent fuel storage. The NUHOMS system has been designed to be a no effluent system. As a result, FENOC assumes the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination to be zero.

4.

5.

L-15-327 Page 3 of 3 A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning:

The submission of this report in conjunction with the two parent guarantees totaling

$24.5 million (Accession Nos. M1141838295 and ML15181A323) serves as certification that financial assurance has been provided in the amount of the cost estimate for ISFSI decommissioning.

L-15-327 Decommissioning Funding Plan for Perry Nuclear Power Plant, Unit No. 1 Independent Spent Fuel Storage Installation Page 1 of3 Pursuant to 10 CFR 72.30(c),

each licensee of an independent spent fuel storage installation (lSFSl) is required to triennially submit a decommissioning funding plan for the lSFSl. FirstEnergy Nuclear Operating Company (FENOC) hereby provides the updated decommissioning funding plan for the Perry Nuclear Power Plant, Unit No. 1 (PNPP) tSFSt.

1.

Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI:

The response to number 4 below discusses the appropriate method of financial assurance contemplated under 10 CFR 72.30(e).

2.

A detailed cost estimate for decommissioning:

In a report dated March 3,2015, TLG Services, Inc. prepared a PNPP ISFSI decommissioning cost estimate for FENOC. This report is included as Enclosure C. This revises the decommissioning cost estimate described in the initial ISFSI decommissioning funding plan submitted to the NRC by FENOC letter dated December 17,2012 (Accession No. ML12352A194).

The revised cost estimate, like the original cost estimate, assumes that an independent contractor will perform the decommissioning activities and includes the cost of meeting 10 CFR 20.1402 for license termination for unrestricted use. The revised estimate assumes a contingency factor of 25o/o. The total decommissioning cost with contingency is $7,891,300 (2014 dollars).

Below is the effect of the following on the detailed cost estimate since the previous report:

1.

Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: None

2.

Facility modifications:

None

3.

Changes in authorized possession limits: None

4.

Actual remediation costs that exceed the previous cost estimate: None L-15-327 Page 2 of 3 3.

4.

ldentification of and justification for using the key assumptions contained in the decommissioning cost estimate:

The ISFSI decommissioning cost estimate key assumptions and justifications are provided in Enclosure C.

A description of the method of assuring funds for decommissioning from 10 CFR 72.30(e),

including means for adjusting cost estimates and associated funding levels periodically over the life of the facility:

Financial assurance in the amount of $9,250,000 for the decommissioning of the PNPP ISFSI is provided through two parent guarantees totaling $24.5 million (Accession Nos. ML141838295 and ML151814323) that support the lSFSls located at Beaver Valley Power Station, Davis-Besse Nuclear Power Station, and PNPP. These guarantees will be payable to the existing nuclear decommissioning trust funds established for PNPP pursuant to the nuclear decommissioning master trust agreements.

The guarantees will provide for the ISFSI decommissioning amounts to be deposited into a separate subaccount to be maintained by the Trustee.

10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and Parent Company Guarantees for Providing Reasonable Assurance of Funds for Decommissioning,"

provides guidance for establishing parent guarantees to provide assurance for decommissioning funding. The test includes the current cost estimate for decommissioning and the amount to be guaranteed.

The regulation requires the test to be performed annually. The performance of the test, with the current decommissioning cost estimate, provides information such that the values of the parent guarantees can be adjusted to ensure that adequate funding will be available to decommission the lSFSl.

The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination:

PNPP uses the Holtec International HI-STORM system for spent fuel storage.

The HI-STORM cask has been designed to assure that there is no release of radioactive materials to the environment.

As a result, FENOC assumes the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination to be zero.

5.

L-15-327 Page 3 of 3 A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning:

The submission of this report in conjunction with the two parent guarantees totaling $24.5 million (Accession Nos. ML14183B295 and ML15181A323) serves as certification that financial assurance has been provided in the amount of the cost estimate for ISFSI decommissioning.

Enclosure A

L-15-327 Beaver Valley Power Station, Unit Nos. 1 and 2, Independent Spent Fuel Storage Installation Decommissioning Cost Estimate (Six Pages Follow)

Fir stE ner gy C orp oratio n Beaver Vallev Power Station ISFSI F07-1 69 1 -1 4002 ; Attiichment I Page l of 6 1.

10 CFR 72.30ISFSI Decommissioning Cost Estimate Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17,20ll,t'l with the rule becoming effective on December 17,2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning,'o requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Beaver Valley Power Station (Beaver Valley) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, that will require remediation to meet the criteria for license termination.

Spent Fuel Management Strategy Beaver Valley's operating licenses were renewed effective November 9, 2009. The scheduled license termination dates for Beaver Valley Units I and2 are January 29, 2036, andMay 27,2047, respectively.

Currently, 5,010 spent fuel assemblies are projected to be discharged over the operating life of the two units. If DOE is able to initiate acceptance of commercial spent fuel in 2025,2,346 assemblies are projected to be shipped during plant operations or within seven years following the cessation of operations (during which time the spent fuel pools are operational). For the purpose of this analysis, the remaining2,664 assemblies would be placed in dry storage at an on-site ISFSI. The ISFSI would operate (under a Part 50 General License) until the transfer of spent fuel to the DOE is completed. At that time, the ISFSI could be decommissioned.

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June 17, 20 I I.

2.

TLG Semices,Inc.

3.

Fir stE nergt Co rp o r atia n Beaver VaUey Power Station ISFSI F 0 7-1 69 1 - 1 4 0 0 2 ; Attachment 1 Page 2 of 6 Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.l'l FirstEnergy Corporation's current spent fuel management plan for the Beaver Valley spent fuel is based in general upon completion of spent fuel receipt by no later than the year 2075.

ISFSI Decom missioning Strategy At the conclusion of the spent fuel transfer process the ISFSI can be decommissioned by removing and disposing of residual radioactivity and veriffing that remaining materials satisff NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

ISFSI Description The Beaver Valley ISFSI currently uses a Transnuclear NUHOMS system (with a 37-fuel assembly capacity) for spent fuel storage. The system consists of a multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSIO. The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

In addition to the spent fuel casks located on the ISFSI pad after shutdown there may be additional casks used for Greater-than-Class-C (GTCC) storage. The HSMs used to store the GTCC canisters (estimated quantity of 8) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final stafus survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

U.S. Code of Federal Regulations, Title 10, Part 961.1l, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) "... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as..."

TLG Services,Inc.

4.

5.

F irstE n eryyt C orp o r ati.o n Beaver Valley Power Station ISFSI Email Matt Minniti to Francis Seymore, November 18,2014.

TLG Sewices,Inc.

F07-1 69 1-1 4002; Attachment I Page 3 of 6 Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI at the cessation of plant operations (Beaver Valley IJnit? operating until2047, and the assumptions associated with DOE's spent fuel acceptance, as previously described).

The nominal size of the ISFSI pad to store the projected amount of spent fuel is expected to be approximately 90 feet in width, and 400 feet in length.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a t00Yo survey of the concrete HSM surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad, and the other ISFSI structures.

It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for further characterization of 10% of the HSMs; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate conservatively assumes that l0 HSMs (equivalent to the number of casks to store the final full core offloads for both units) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. For purposes of this estimate, these HSMs are designated for controlled disposal as lowlevel radioactive waste.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad once the HSMs are removed, the cask transporter, or other facilities at the Beaver Valley ISFSL IT is expected that these assumptions would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. As such, only verification surveys are included for the other facilities in the decommissioning estimate.

The ISFSI was constructed upon part of the property that was released as a result of the decommissioning of the Shippingport Atomic Power Station by the U.S. Department of Energy in 1989. The pad area was excavated down approximately 15 feet, and backfilled with clean engineered fill. The surrounding ISFSI areas were not disturbed, and remain as left by the DOE, other than a topcoat of gravel. As such, the decommissioning estimate assumes that no soil remediation is required [3], to meet the unrestricted use criteria of 10 cFR 20.1402.

Fir stE ner gt C orp o r ation Beaver Valley Power Station ISFSI F07-1 69 1-1 4 002 ; Attachment I Page 4 of 6 6.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions are expected to be provided locally. FirstEnergy Corporation, as licensee, will oversee the site activities; the estimate includes FirstEnergy Corporation's labor and overhead costs.

Low-level radioactive waste packaging and transport costs are based on industry data.

Disposal costs are based on FirstEnergy Corporation's existing contracted disposal rates.

Costs are reported in20l4 dollars.

Contingency has been added at an overall rate of 25o/o. This is consistent with the contingincy evaluation criteria referenced by the NRC in NUREG-1757.I41 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the $20.1402 criteriafor unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2.The cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized and the specifications and work procedures for the decontamination (liner removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of as lowlevel waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), FirstEnergy Corporation's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2076,the year following the last of the spent fuel removal.

4 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision l,February 2012.

TLG Services,Inc.

FirstEn ergt Corporation Bewer Vallev Power Station TLG Semices, Inc.

F07-1 69 1 -l 4002 : Afrachmmt 1 Page 5 of 6 Table I Significant Quantities and Physical Dimensions ISFSI Pad Item Lensth (ft) widrh (ft)

Residual Radioactivitv ISFSI Pad (dimensions are for current pad) 300 90 No ISFSI Pad Exoansion (dimensions are for exoansion) 100 90 No ISFSI Horizontal Storage Modules ltem Value Notes (all dimensions are nominal)

Overall Length (inches) 244 HSM dimensions based upon Overall Width (inches) 116 Transnuclear HSM-H desien Overall Heieht (inches) 222 6uantitv (f.nfsl) 72 Quantity (with residual radioactivity) t0 Equivalent to the number of HSMs needed to store the last core ofrloads from both units at Beaver Vallev Total Surface Area of HSM interior with Residual Radioactivitv (so uare feet) 7,500 Low-Level Radioactive Waste (cubic feet) 21.853 low-Level Radioactive Waste (packaged density) 151 Most weight shipped as concrete slabs Other Potentially Impacted Items Item Value Notes Cask Transoorter I

No residual radioactivity ISFSI Equipment Storaee Buildine I

No residual radioactivity Number of HSMs used for GTCC storaee 8

No residual radioactivitv

Firx,t E n e rg) C o rp o r ali on Beaver Valley Power Staion Table 2 ISFSI Decomrnissioning Costsr and Waste Volumes Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2076 TLG Semiceg Inc.

F0 7 - 1 69 1 - 1 4002 ; Attachment I Page 6 of 6 (Thousande, 2014 dollars)

Person-Hours Decon Removal Transnort Disnosal Other Total Waste Volume 1fr3\\

Craft Oversight and Decommissioning Cnntmr.fnr Planning (characterization, cnacc qnrl n:nnartrrroc\\

218 2r8 t,096 Remediation

/oar'irrorod lfSMo\\

250 4

853 2.106 528 3.741 2r,853 2.O92 186 1.186 9.234 Srrhlolal 260 4

863 2-106 1.932 6.146 21.863 1.fl27 r.096 Sunoortino Costs NRC and NRC Crntractor Fees and Costs 384 384 lnsurance 65 OD ProDertv taxes ffir 331 Cornorate A&G a2 82 Securitv (industrial) 48 148 5.020 FirstEnergy Corporation Owcrsicht Staff 259 259 3.803 Subtotal 7-270 1.270 9.699 Total (w/o continEenev) 260 4

868 2.106 3.202 6.416 2r.868 r1.327 r0.696 T otal (w 1260/" ontinpeno) 8.0r8

Enclosure B

L-15-327 Davis-Besse Nuclear Power Station, Unit No. 1 Independent Spent Fuel Storage Installation Decommissioning Cost Estimate (Six Pages Follow)

FirstEnergt Corp.

Davis-Besse Nuclear Power Station.LSf',SI F07-1 698-1 5003 ; Attachment 1 Page I of6 1.

10 CFR 72.30ISFSI Decommissioning Cost Estimate Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17,20ll,t'l with the rule becoming effective on December 17,2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Davis-Besse Nuclear Power Station (Davis-Besse) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy Davis-Besse's scheduled license termination date is April 22, 2017. Currently, l,452 spent fuel assemblies are projected to be discharged over the operating life of the unit. If DOE is able to initiate acceptance of commercial spent fuel in 202l,the first spent fuel assemblies from Davis-Besse are projected to be shipped by 2026. For the purpose of this analysis, all of the 1,452 assemblies would be placed in dry storage at an on-site ISFSI.

The ISFSI would operate (under a Part 50 General License in accordance with 10 CFR 72 Subpart K) until the transfer of spent fuel to the DOE is completed. At that time, the ISFSI could be decommissioned.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel t

U.S. Code of Federal Regulations, Title 10, Parts 20,30,40, 50, 70 andT2 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June I 7, 201 I.

TLG Semices,Inc.

3.

FirstEnergt Corp.

Davis-Besse Nuclear Power Station.LsffSl F 07-1 69 8-1 5 00 3 ; Attac hment I Page 2 of 6 allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.[2]

FirstEnergy Corp. current spent fuel management plan for the Davis-Besse spent fuel is based in general upon completion of spent fuel receipt by no later than the year 2056.

ISFSI Decom missioning Strategy At the conclusion of the spent fuel transfer process the ISFSI can be decommissioned by removing and disposing oiresidual radioactivity and verifying that remaining materials satis$ NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning altemative identified for the nuclear power plant.

ISFSI Description The dry fuel storage system consists of a TransnuclearNUHOMS multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSM). The Davis-Besse ISFSI expects to use three different versions of the system.

There are three modules currently on the ISFSI pad with 24-assembly capacity DSCs. A scheduled 2017 campaign will load four 32-assembly capacity DSCs. All subsequent spent fuel DSC loadings are planned using a 37-fuel assembly capacity DSC. The DSCs aie assumed to be transfened directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and veriff that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

In addition to the spent fuel modules located on the ISFSI pad after shutdown there may be additional HSMs used for Greater-than-Class-C (GTCC) storage. The HSMs used to store the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

Table I provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

t U.S. Code of Federal Regulations, Title 10, Part 961.1l, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) "... DOg shall issue an annual acceptance prioriry ranking for recerpt 9f SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated fiom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as...'o TLG Services,Inc.

4.

FirstEnergy Corp.

Davis-Besse Nuclear Power Statinn ISF,SI F0 7-1 69 8-1 5 0 03 ; Attachment I Page 3 of 6

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI at the cessation of plant operations (operating until 2017), and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad to store the projected amount of spent fuel is expected to be approximately 88 feet in width, and344 feet in length.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a l00o/o survey of the concrete HSM surfaces, and a significant fraction of the ISFSI pad and the immediate area surrounding the pad, and the other ISFSI structures.

It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely stnail. To validate this assumption, the estimate accounts for further characteization of 10% of the HSMs; it is likely that some of this charucterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate conservatively assumes that 5 HSMs (equivalent to the number of HSMs to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. For purposes of this estimate, these HSMs are designated for controlled disposal as low-level radioactive waste.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad once the HSMs are removed, the transfer cask and transporter, or other facilities at the Davis-Besse ISFSI. It is expected that these assumptions would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. As such, only verification surveys are included for the other facilities in the decommissioning estimate.

A review of drawing and pictures taken during the pad construction identified no piping running under the pad. A duct bank going East-West under the pad can be identified.

The area of the pad plus five feet on each side was excavated down to undisturbed soil and then refilled with an engineered backfill prior to pouring the pad. At this time there is no reason to believe the soil under the pad has been contaminated. As such, the decommissioning estimate assumes that no soil remediation is required t3l, to meet the unrestricted use criteria of 10 CFR 20.1402.

3 Email Matt Minniti to Francis Seymore, February 25,2015.

TLG Services,Inc.

FirstEnergt Corp.

Davis-Besse Nuclear Power Station.LSESl F 0 7-1 69 8-1 5 003 ; Attachment 1 Page 4 of 6 6.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions are expected to be provided locally. FirstEnergy Corp.,

as licensee, will oversee the site activities; the estimate includes FirstEnergy Corp. labor and overhead costs.

Low-level radioactive waste packaging and transport costs are based on industry data.

Disposal costs are based on FirstEnergy Corp. existing contracted disposal rates.

Costs are reported in20l4 dollars.

Contingency has been added at an overall rate of 25o/o. This is consistent with the continfency evaluation criteria referenced by the NRC in NUREG-I757.t41 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the $20.1402 critefiafor unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2.T\\e cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized andthe specifications and work procedures for the decontamination (heat shields and rails) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of as low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), FirstEnergy Corp's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2057,the year following the last of the spent fuel removal.

4 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision l, February 2012.

TLG Services,Inc.

FintEnergt Corp.

Davis-Besse Nuclear Power Station TLG Semices, Inc.

F07-1 698-1 5003 : Afrachment 1 Page 5 of 6 Table I Significant Quantities and Physical Dimensions ISFSI Pad Item Leneth (ft) width (ft)

Residual Radioactivifw ISFSI Pad (dimensions are for current pad) 229 88 No ISFSI Pad Flxnansion (dimensions are for exnansion) 115 88 No ISFSI Horizontal Storage Modules Item Value Notes (all dimensions are nominal)

Overall Lencth (inches) 248 HSM dimensions based upon Overall Width (inches) 116 Transnuclear HSM-H desisn Overall HeiEht (inches) 222 Ouantitv (total) 45 Quantity (with residual radioactivity) o Equivalent to the number of HSMs needed to store the last core offload from Davis-Besse Total Surface Area of HSM interior with Residual Radioactivitv (souare feet) 3.750 Low-Level Radioactive Waste (cubic feet) r 1,356 low-l,evel Radioactive Waste (packaeed densitv) lDo Most weieht shipped as concrete slabs Other Potentially Impacted ltems Item Value Notes Cask Tlansoorter No residual radioactivitv ISFSI Eouioment Storase Buildins I

No residual radioactivitv Number of HSMs used for GTCC storage 4

No residual radioactivity

FirstEnergt Corp.

Dwis-Besse Nuclear Power Stalion Table 2 ISFSI Decomrnissioning Costsl and Waste Volumes Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2057 TLG Semices, Inc.

F0 7 - 1 69 8-I 500 3 ; Attachment I Page 6 ot6 (Ihoueands. 2014 dollars)

Person-Hours Decon Removal Packasins Transoort Disnosal Other Total Waste Volume l/frc\\

Craft Oversight and Decomissioning Contrac-tor Planning (characterization, snec-s and nrocedures) r86 186 L,024 Rerrecliation lsctiwaf.pd HSMs\\

5 1 6 t.t42 563 2.442 l.doo 1.880 License Terrnination (radiologica l srrrocls) 805 805 6.434 Subtotal 217 3

516 1.112 1.664 3.452 r1.356 8.313 1.024 Supportins Costs NRC and NRC Contractor Fees and Costs 384 384 a a o Insumnce bD oo ProDertv tiles 62 62 Comorate A&G 44 44 Secuitv (industrial) t48 148 5.013 FirstEnergy Corp.

Oversieht Staff qRo 259 3.803 Subtotal 962 s62 9.592 217 3

616 r.142 2-616 4.395 r1366 8.313 10.616 T otal (w I 260/o contin gencv) 5-493

Enclosure C

L-15-327 Perry Nuclear Power Plant, Unit No. 1 Independent Spent Fuel Storage Installation Decommissioning Cost Estimate (Six Pages Follow)

FirstEnergt Corp.

Perry Nuclear Power Plant ISFSI F07-1 699-1 5003 ; Attachment I Page 1 of 6 1.

10 CFR 72.30ISFSI Decommissioning Cost Estimate Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June l7,207l,tll with the rule becoming effective on December 17,2012.

Subpart 72.30,"Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Perry Nuclear Power Plant (Perry) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, that will require remediation to meet the criteria for license termination.

2, Spent Fuel Management Strategy Perry's scheduled license termination date is March 18,2026. Currently, 6,233 spent fuel assemblies are projected to be discharged over the operating life of the unit. If DOE is able to initiate acceptance of commercial spent fuel in 2025,the first spent fuel assemblies from Perry are projected to be shipped by 2034. For the pulpose of this analysis, all of the 6,233 assemblies would be placed in dry storage at an on-site ISFSI.

The ISFSI would operate (under a Part 50 General License in accordance with 10 CFR 72 Subpart K) until the transfer of spent fuel to the DOE is completed. At that time, the ISFSI could be decommissioned.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, t

U.S. Code of Federal Regulations, Title 10, Paxts 20,30,40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June 17, 201 I.

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3.

FirstEnergt Corp.

Perry Naclear Power Plant ISFSI F07-1 699-1 5003 ; Attachment I Page 2 of 6 with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.[2]

FirstEnirgy Corp. current spent fuel management plan for the Perry spent fuel is based in general upon completion of spent fuel receipt by no later than the year 2064.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI can be decommissioned by removing and disposing of residual radioactivity and verifuing that remaining materials satisfu NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

ISFSI Description The dry fuel storage system consists of a Holtec Intemational HI-STORM 100S System (with a 68-fuel assembly capacity). The system consists of a multi-purpose (storage and transport) canister (MPC) and a concrete shield (overpack). The MPCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining concrete overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verif that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted useo form the basis of the ISFSI decommissioning estimate.

In addition to the spent fuel casks located on the ISFSI pad after shutdown there may be additional casks used for Greater-than-Class-C (GTCC) storage. The overpacks used to store the GTCC canisters (estimated quantity of 5) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

2 U.S. Code of Federal Regulations, Title 10, Part 96l.ll, Article IV - Responsibilities of the Parties, B' DOE Responsibilities, 5.(a) '... IOB shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as..."

TLG Services,Inc.

4.

FirstEnergy Corp.

Perry Nuclear Power Plant ISFSI F07-1 699-1 5 003 ; Attachment 1 Page 3 of 6

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI at the cessation of plant operations (operating until2026), and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad to store the projected amount of spent fuel is expected to be approximately 75 feet in width, and 453 feet in length.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a l00Yo survey of the concrete overpack surfaces, and a significant fraction of the ISFSI pad and the immediate atea surrounding the pad, and the other ISFSI structures.

It is not expected that the overpacks will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for further chatactetization of 10% of the overpacks; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more defrnitive decommissioning scope.

The decommissioning estimate conservatively assumes that 11 overpacks (equivalent to the number of casks to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. For purposes of this estimate, these overpacks are designated for conholled disposal as low-level radioactive waste.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad once the overpacks are removed, the cask transporter, or other facilities at the Perry ISFSI. It is expected that these assumptions would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. As such, only verification surveys are included for the other facilities in the decommissionine estimate.

FENOC Ct"-irlw reviewed the I0CFR 50.7SgfiIes that it maintains and found no mention of any contaminated soil found as a result of building the ISFSI pad. As such, the decommissioning estimate assumes that no soil remediation is requi..d t'1, to meet the unrestricted use criteria of 10 CFR 20.1402.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data Email Matt Minniti to Francis Seymore, March 3, 2015.

TLG Services,Inc.

FirstEnerglt Corp.

Perry Nuclear Power Plant ISFSI F07-I 699-1 5 003 ; Attachment I Page 4 ot6 (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions are expected to be provided locally. FirstEnergy Cotp.,

as licensee, will oversee the site activities; the estimate includes FirstEnergy Corp. labor and overhead costs.

Low-level radioactive waste packaging and transport costs are based on industry data.

Disposal costs are based on FirstEnergy Corp. existing contracted disposal rates.

Costs are reported in2014 dollars.

Contingency has been added at an overall rate of 25%o. This is consistent with the contingincy evaluation criteria referenced by the NRC in NUREG-I757.t41 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the $20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6.

Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2.T\\e cost has been organized into three phases, including:

o An initial planning phase - empty overpacks are characterized and the specifications and work procedures for the decontamination (steel liner removal) developed.

o The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of as low-level waste.

o The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning serviceso the estimate also contains costs for the NRC (and NRC contractor), FirstEnergy Corp's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2065,the year following the last of the spent fuel removal.

a "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S' Nuclear Regulatory Commission's Offrce of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision l,February 2012.

TLG Services,Inc.

FirctEnergt Corp.

Perry Nuclear Planl Station TLG Semices, Inc.

F0 7-1 69 9-1 5 00 3 ; Attachment 1 Page 5 of 6 Table I Significant Quantities and Physical Dimensions ISFSI Pad Item Leneth (ft) width (ft)

Residual Radioactivitv ISFSI Pad (dimensions are for current pad) 347 t o No ISFSI Pad Expansion (dimensions are for expansion) 105.5 t o No ISFSI Storage Overpack Item Value Notes (all dimensions are nominal)

Overall Heieht (inches) 2t8.5 Outside Diameter (inches) r32.5 Inside Diameter (inches) 73.5 Inner Liner Thickness (inches) 1.0 Chrqntifv (fnfsl) 97 92 spent fuel + 5 GTCC Quantity (with residual radioactivity) 11 Equivalent to the number of Overpacks needed to store the last core offload from Perrv Total Surface Area of Overpack Liner with Residual Radioactiwitv (souare feet) 3.750 Iow-Level Radioactive Waste (cubic feet) 11.356 Low-Level Radioactive Waste (packased densitv) roo Averase weisht densitv Other Potentially Impacted ltems Item Value Notes Cask Thansoorter I

No residual radioactivitv ISFSI Eouioment Storaee Buildine I

No residual radioactivitv Number of Overpacks used for GTCC storase a

No residual radioactivitv

FirstEnergt Corp.

Perry Nuclear Plant Station Table 2 ISFSI Decomrnissioning Costst and Waste Volumes Note 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2065 TLG Semices. Inc.

F07-1699-1 5003; Attachment I Page 6 of 6 fThousands. 2014 dollars)

Pe.rson-Hourg Decon Removal Packaeine Transnort Disnosal Of.her Total Waste Volume

/+t\\

Cra-ft Oversight and Conf.raelnr Decommissioning Contractor Planning (characterization, cnono and nrmodrrros\\

322.2 1.144.0 Remediahon

/a.fivot6.l

^tral 521 2 3 1 9 5 450 6 1 7 4 7. 4 3.033.1 15.766.0 1.204.1 Liense Termination hdialnoiool orrnrorro\\

r.670_3 1.670.3 Suhtntal 621-2 319_6

,t50^6 r.741-a 1.992.6 6.026.6 16.766.0 1.204.r

,144.0 NRC and NRC Contractor trroao oni f'lnefo 408.7 408.7 150.3 150.3 Prooertv taxes 276.4 27A.8 Cnmovatn A&G 43.8 43.8 Sperrritw ainductrial) 407 A 407.8 5,013 FirstEnergy Corp.

C)vprsishf.

Staff 1.247.5 r.287.5 3,803 Subtotal 3.280.0 6-313.1 9.592 Total (do mntinEencv) 621.2 319.6 460.6 1.741.8 3.280.0 6-313-l 15.766-O t-204-l 6.932.9 T otal ( w D6o/" contincend) 7.891.3