ULNRC-06349, Callaway, Unit 1 - Document A22-1690-001, Rev. 0, Decommissioning Cost Analysis for the Callaway Energy Center, Section 3, Page 14 of 30 - Section 5, Page 2 of 6

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Callaway, Unit 1 - Document A22-1690-001, Rev. 0, Decommissioning Cost Analysis for the Callaway Energy Center, Section 3, Page 14 of 30 - Section 5, Page 2 of 6
ML17097A561
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Site: Callaway Ameren icon.png
Issue date: 03/16/2015
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TLG Services
To:
Ameren Missouri, Office of Nuclear Reactor Regulation
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ULNRC-06349 A22-1690-001, Rev. 0
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ULNRC-06349 Page 51 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 14 of 30 Operations Contractor (DOC)will provide the supervisory staff needed to oversee the labor subcontractors, consultants, and specialty contractors needed to perform the work required for the decontamination and dismantling effort.The DOC will also provide the engineering services needed to develop activity specifications, detailed procedures, detailed activation analyses, and support field activities such as structural modifications.

Personnel costs are based upon average salary information provided by Ameren Missouri.Overhead costs are included for site and corporate support, reduced commensurate with the staffing of the project.Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel.The craft labor required to decontaminate and dismantle the nuclear unit is acquired through standard site contracting practices.

The current cost of labor at the site is used as an estimating basis.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.,'37Cs, 905r, or transuranics) has been prevented from reaching levels exceeding those that permit the major N$$S 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/CR3474.[23]

Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Callaway components, projected operating life, and different periods of decay.Additional short-lived isotopes were derived from CR-0130[24]

and CR-0672,[251 and benchmarked to the long-lived values from CR-3474.The control elements are thsposed of along with the spent fuel, i.e., there is no additional cost provided for their disposal.Activation of the containment building structure is confined to the biological shield.TLG Services, Inc.

ULNRC-06349 Page 52 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.U Decommissioning Cost Analysis Section 3, Page 15 of 30 3.5.4 General Transition Activities Existing warehouses are cleared of non-essential material and remain for use by Ameren Missouri and its subcontractors.

The plant's operating staff performs the following activities at no additional cost or credit to the project during the transition period: 0 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 estimates do 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.Ameren Missouri 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 estimates do not include the additional cost for size reduction and preparation to meet"furnace ready"conditions.

For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, TLG Services, Inc.

ULNRC-06349 Page 53 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 16 of 30 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 is removed at no cost or credit to the decommissioning project.Disposition may include relocation to other facilities.

Spare parts are also made available for alternative use.Energy 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 to calculate the cost of energy consumed during decommissioning for tooling, lighting, ventilation, and essential services.Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums.Reductions in premiums, throughout the decommissioning process, are based upon the guidance provided in SECY-OO-0145,"Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning"[26l The NRC's financial protection requirements are based on various reactor (and spent fuel)configurations.

Taxes Property tax payments are included for the land only and will continue through the decommissioning project.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.TLG Services, Inc.

ULNRC-06349 Page 54 of 173.Callaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 1 7 of 30 3.6 COST ESTIMATE

SUMMARY

Schedules of expenditures for the base case are provided in Tables 3.1 and 3.2.The tables delineate the cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).

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 unit's operating license, recognizing that there may be some additional cost impact from spent fuel management.

These costs are identified in Tables 3.la and 3.2a.The"Spent Fuel Management" subcategory contains costs associated with the five and one-half years of post-shutdown pooi operations and the transfer of the fuel from the pool to the I$FSI.These costs are identified in Tables 3.lb and 3.2b."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.These costs are identified in Tables 3.ic and 3.2c.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., Asset Retirement Obligation determinations).

In reality, there can be considerable interaction between the activities in the three subcategories.

For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components.

In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity.However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

TLG Services, Inc.

ULNRC-06349 Page 55 of 173 Caflaway Energy Center Document M2-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 18 of 30 As discussed in Section 3.4.1, while designated for disposal at the geologic repository along with the spent fuel, GTCC waste is still classified as low-level radioactive waste and, as such, included as a"License Termination" expense.The estimates were developed and costs are presented in 2014 dollars.As such, the estimates do not reflect the escalation of costs (due to inflationary and market forces)over the remaining operating life of the reactor or during the decommissioning period.The schedules are based upon the detailed activity costs reported in Appendices C and D, along with the timeline presented in Section 4.For the purposes of this analysis, the costs presented in the following tables reflect plant decommissioning at the expiration of its current license (2024)and the use of off-site low-level radioactive waste processing to minimize the volume designated for controlled disposal.Costs for the other identified scenarios (including those for a 60-year operating life)are presented in the appendices (E through H).TLG Services, Inc.

ULNRC-06349 Page 56 of 173.Catlaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 19 of 30 TABLE 3.1 DECON ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING TOTAL ANNUAL EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other['1 Total[2]2024}i3: 1,612 l487 2025 68,781 7,053 2,325 2,O16 12,890 93,064 2026 77,965 25,246 2,437 33,861 24,285 163,793*76 ,8fi 27,425 1,809 42,108 20,099 168,303 2028 67,852 10,602 1,450 10,079 8,664 98,647 2029 67,666 10,573 1,446 10,051 8,641 98,377 2030 49,267 7,323 956 8,271 6,289 72,106 2031 34,224 9,547 331 21 2,424 46,547 2032 32,080 29,448 193 0 3,320 65,042 2033 7,012 6,437 42 0 726 14,2l7 Total 495,290 134,543 11,386 106,415 88,948 836,582J[11 Includes property taxes, insurance, fees, surveys, and GTCC disposal[2]Columns may not add due to rounding TLG Services, Inc.

ULNRC-06349 Page 57 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 20 of 30 TABLE 3.la DECON ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING LICENSE TERMINATION EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total J 13,276-1,O66 15,12&2025 67,064 4,573 2,325 2,016 10,232 86,209 2026 75,013 22,852 2,437 33,861 22,036 156,197 2027 73,677 25,015 1,809 42,108 18,007 160,616 2028 63,256 7,458 1,450 10,079 6,315 88,559 2029 63,084 7,438 1,446 10,051 6,298 88,317 2030 47,9111 6,396 956 8,271 5,595 69,129 2031 25,239 1,259 277 21 1,489 28,286..9[.....2033 33 01 0 0 0 33.j_t I-b.P!..JbP..692,622 TLG Services, Inc.

ULNRC-06349 Page 58 of 173 Caflaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 8, Page 21 of 30 TABLE 3.lb DECON ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total 2024 170 510 0 O___546 1,227 ,p----2026 776 2,328 0 0 2,228 5,332 2027 759 2,276 0 0 2,045 5,080*2 028 792 2,376 0 01 2,050 5,218 2029 790 2,369 0 0 2,045 5,204 2030 234 701 0 0 605 1,540 2031 0 0 0 0 0&2032 0 0 0 0 0 0 2033 0 0 0 0 0 0 Total 4,347 13,041 0 0 12,176 29,564 TLG Services, Inc.

ULNRC-06349 Page 59 of 173 CaUaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 22 of 30 TABLE 3.lc DECON ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING SITE RESTORATION EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total 20241135 000]0 135 2025 890 0 0 0 0 890 2026 2,176 66 0 0 22 2,264 2027 2,425 134 0 0 47 2,607 2028 3,803 768 0 0 299 4,870 2029 3,793 766 0 0 298 4,857 2030 1,122 227 0 0 88 1,437 2031 8,986 8,287 54 0 934 18,262 2032 31,929 29,448 193 0 3,320 64,891 20;3 62%9 6,437 42 0 726 14,184 Total 62,239 46,133 290 0 5,734 114,396 TLG Services, Inc.

ULNRC-06349 Page 60 of 173.Caflaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 23 of 80 TABLE 3.2 SAF$TOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING TOTAL ANNUAL EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other[']Total[2]2024-ioL:::: 75 396-14,208___1L 2026 29,144 4,632 8461 796 17,502 52,920 J"2,776-2028 18,544 2,784 387 15 3,707 25,436-2p?18,493 2,776 3,697 25,367 2030 7,679 1,039 250 9 2,103 11,079 2031 3,134 309 193 6 1,432 5,075 2032 3,143 310 193 6 i,436T 5,089 2033 3,134 309 193 6 1,432 5,075 J Gjl,432 5075 c?I4 Q75]2036 3,143 310 193 6 1,436 5,089 2037 3,134 309 193 6 1,432 5,075 2038 3,134 309 193 6 1,432 5,075 2040 3,143 310 193 6 1,436 5,089 2041 3,134 309 193 6 1,432 5,075-,--"---2042 3,134 309 193 6 1,432 5,075 2043 3,134 309 193 6 1,432 5,075_Q44_---436 2045 3,134 309 193 6 1,432 5,075 2046 3,134 309 193 6 1,432 5,075 2047 3,134 309 193 6 1,432 5,075 2048 3,143 310 193 6 1,436 5,089 2049 3,134 309 193 6 1,432 5,075 2050 3,134 309 193 6 1,432 5,075 2051 3,134 309 193 6 1,432 5,075 2052 3,143 310 193 6 1,436 5,089=_[_,__i TLG Services, Inc.

ULNRC-06349 Page 61 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 24 of 30 TABLE 3.2 (continued)

$AFSTOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING TOTAL ANNUAL EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other['1 Total[2]2054 3,134 309[193 6 1,432 5,075 2055 3,134 309 193 6 1,432 5,075 2056 3,143 310 193 6 1,436 5,089 2057 3,134 309 193 6 1,432 5,075 2058 3,134 309 193 6 1,432 5,075 2059 3,134 309 193 6 1,432 5,075 2060 3,143 310 193 6 1,436 5,089 2061 3,134 309 193 6 1,432 5,075 2062 3,134 309 193 6 1,432 5,075 2063 3,134 309 193 6 1,432 5,075 2064 3,143 310 193 6 1,436 5,089 2Q6.5 3,134 309 193 6 1,432k 2066 3,134 309 193 61 1,432 5,075 2067 3,134 309 193 6 1,432 5,075?IP--2069 3,134 309 193 6 1,432 5,075 2070 3,134 309 193 6 1,432 5,075 2071 3,134 309 193 6 1,432 5,075 2072 3,143 310 193 6 1,436 5,089 2073 3,134 309 193 6 1,432 5,075 2074 3,134 309 193 6 1,432 5,075 2075 3,134 309 193 6 1,432 5,075 2076 3,143 310 193 6 1,436 5,089 2077 3,134 309 193 6 1,432 5,075 2078 12,946 687 511 11 1,658 15,813: 2079 49,150 4,498 1,928 35 2,782 58,394 2080 56,932 21,216 1,868 30,307 14,982 125,305 2081 59,485 22,303 1,715 34,062 16,324 133,88Q, 2082 53,7081 8,092 1,446 10,385 6,479 80,1111 14__Q1 479 80,111;TLG Services, Inc.

ULNRC-06349 Page 62 of 173 CaUaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 25 of 30 TABLE 3.2 (continued)

$AFSTOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING TOTAL ANNUAL EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other['1 Total[21[2084 33247,694 391J449 2516 46,373=___?I 2086 9,554 8,770 58 0 989 19,370 Toi i:3i9 146,747 23,204 87,354 163,128[1,091752

[1]Includes property taxes, insurance, fees, surveys, and GTCC disposal[2]Columns may not add due to rounding TLG Services, Inc.

ULNRC-06349 Page 63 of 173 Caflaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 26 of 30 TABLE 3.2a$AFSTOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING LICENSE TERMINATION EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total C 2024 li27 12Q 12981 5E528 1 2026 18,126 2,263 711 796 15,148 37,044 2027 3,134 447 193 15 1,472 5,261 2028 3,143 449 193 15 1,476 5,276 2029 3,134 447 193 15 1,472 5,261 2030 3,134 350 193 9 1,444 5,130 2031 3,134 309 193 6 1,432 5,075 2032 3,143 310 193 6 1,436 5,089 2P?3 ,309 124 2034 3,134 309 193 6 1,432 5,075 2035 3,134 309 193 6 1,432 5,075 2036 3,143 310 193 6 1,436 5,089 2037 3,134 309 193 6 1,432 5,075 2038 3,134 309 193 6 1,432 5,075 2039 3,134 309 193 6 1,432 5,075 2040 3,143 310 193 6 1,436 5,089 2041 3,134 309 193 6 1,432 5,075 2042 3,134 309 193 6 1,432 5,075 2043 3,134 309 193 6 1,432 5,075 2044 3,143 310 193 6 1,436'5,089.3Q:?6 1L4 2046 3,134 309 193 6 1,432 5,075 2047 3,134 309 193 6 1,432 5,075 2048..P...---...._:i4_2050 3,134 309 193 6 1,432 5,075 2051 3,134 309 193 6 1,432 5,075 2052 3,143 310 193 6 1,436 5,089 P_[_?TLG Services, Inc.

ULNRC-06349 Page 64 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 27 of 80 TABLE 3.2a (continued)

$AF$TOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING LICENSE TERMINATION EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total"193 6 1,432 5,075.3,134----1,432 2056 3,143 310 193 6 1,436 5,089 3q9 6 1,4321---2059 3,134 309 193 6 1,432 5,075 2060 3,143 310 193 6 1,436 5,089 2061 3,134 309 193 6 1,432 5,075'2062 3,134 309 193 6 1,432 5,075 2063 3,134 309 193 6 1,432 5,075 2064 3,143 310 193 6 1,436 5,089 A'?4 ,,,----2066 3, 134 309 193 6 1,432 5,075 2067 3,134 309 193 6 1,432 5,075 2068 3,143 310 193 6 1,436 5,089 2069 3,134 309 193 6 1,432 5,075 2070 3,134 309 193 6 1,432 5,075 2071 3,134 309 193 6 1,432 5,075 2072 3,143 310 193 6 1,436 5,089 2073 3,134 309 193 6 1,432 5,075 2074 3,134 309 193 6 1,432 5,075 2075 3,134 309 193 6 1,432 5,075 2076 3,143 310 193 6 1,436 5,089 2077 3,134 309 193 6 1,432 5,075 2078 12,695 687 511 11 1,658 15,561 2079 48,095 4,498 1,928 35 2,782 57,339 2080 54,743 21,143 1,868 30,307 14,961 123,021 2081 56,387 21,994 1,715 34,062 16,212 130,369 2082 49,893 7,322 1,446 10,385 6,179 75,225 2083 49,893 7,322 1,446 10,385 6,179 75,225 TLG Services, Inc.

ULNRC-06349 Page 65 of 173 Caflaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 3, Page 28 of 30 TABLE 3.2a (continued)

$AFSTOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING LICENSE TERMINATION EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total[2084 1,628 351 4491,823 3875 2085 150 0 0 0 0 15Q 2086 45 0 0 0 0 45 JL_28P 22,143 87,354[i45O5 887,947, TLG Services, Inc.

ULNRC-06349 Page 66 of 173 Caflaway Energy Center*Document A22-1690-OOi, Rev.0 Decommissioning Cost Analysis Section 3, Page 29 of 30 TABLE 3.2b$AF$TOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2014 dollars)Equipment&Year Labor Materials Energy Burial Other Total ic)-X L-oj 546 1,227 2025 827 2,480 0&2,658 5,964 2026 J 11,018 369 135 Oj 2,354 1876 L 2028 l5,4O1 2,335 193 0 2,231 2O,16l 2029 15,359 2,329 193 0 2,225 20,106..,____1...Total 62,678 13,041 771 0 12,898 89,38&!.,_;÷..,."?;;.%F TLG Services, Inc.

ULNRC-06349 Page 67 of 173 Callaway Energy Center Decommissioning Cost Analysis Document A22-1690-OO1, Rev.0 Section 3, Page 30 of 30 TABLE 3.2c SAFSTOR ALTERNATIVE 40-YEAR PLANT OPERATING LIFE LOW-LEVEL RADIOACTIVE WASTE OFF-SITE PROCESSING SITE RESTORATION EXPENDITURES (thousands, 2014 dollars)Equipment&Labor Materials 8,770 Energy Burial Year Other Total 2cI;7Er1 0 o ol 2078 252 0 0 0 0 252 2079 1,055 0 0 0 0 1,055 2080 2,190 73 0 0 21 2,284 2081 3,097 309 0 0 113 3,519 2082 3,815 770 0 0 300 4,885 2083 3,815 770 0 0 300 4,885 2084 6,700 6,066 40 0 693 13,498 2085 31,842 29,368 193 0 3,311 64,714 2086 9,509 58 0 Total 62,2751 46,127 290 0 5,726 114,417 989 19,325 TLG Services, Inc.

ULNRC-06349 Page 68 of 173 Caflaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 4, Page 1 of 5 4.SCHEDULE ESTIMATE The schedules for the decommissioning scenarios considered in this study follow the sequences presented in the MFJNE$P-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 is presented in Figure 4.1.The scheduling sequence assumes that fuel is 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.[271

  • 1 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 fuel building is isolated until such time that all spent fuel has been transferred from the spent fuel pool to the DOE.Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel is complete (DECON option)..AU 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.

ULNRC-06349 Page 69 of 173 Callaway Energy Center Document A22-1690-OO1, Rev.U Decommissioning Cost Analysis Section 4, Page 2 of 5.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 tables are based upon the durations developed in the schedules for decommissioning.

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 shown for the spent fuel storage period, which determines the release of the fuel building for final decontamination.

Project timelines are provided in Figures 4.2 and 4.3 with milestone dates based on a 2024 shutdown date.The fuel pool is emptied approximately five and one-half years after shutdown.Deferred decommissioning in the SAFSTOR scenarios is assumed to commence so that the operating license is terminated within a 60-year period from the cessation ofplant operations.

TLG Services, Inc.

ULNRC-06349 Page 70 of 173 Callaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 4, Page 3 of 5 FIGURE 4.1 ACTIVITY SCHEDULE TazkName 4I5 Callawy Plant Decon Project Schedule Shutdowii plant*:*Period 1..Shutdown through transition Certificate ofpermanent cessation of operations submitted*-Fuel storage pool operations Recnf1guTe plant.Z2-Prepare activity specthcations Perform site characterizahon PSDARsubnutted Written certthcate of permanent remaraJ of fue'submitted S;t specthc decommissioning cost estimate submitted+DCC staff rnobibzd*Period lb-Decommissioning preparations J Fuel storage pool operations Reconfigure plant (continued)

Prepare detailed work procedures Decon NSSS: I5olate spent fuel pool EJ Period 2a-Large component removal Fu1 5torage pool operations Preparation for reactor vessel removal E1?.actor vessel&internals Remanin large NSSS comporents dposition t Nonessential systems[1 Main turbine/generator I I Main condenser F I License termination plan submitted Period 2b Oecontmination (wet fuel)Fuel s orage pool operations LE Th Remoje systems not supporting wet fuel storage E I Decon buildings not supporting wet fuel storage I Ltcense termination plan approved Fuel otorage pool availeble for decommissioning Period 2c Decontemine+/-ion following wet fuel storage ImDve remeinin systems 0 Decon wet fuel storage area Period 2e.Plant license termination Final Site Survey NRC reiew&approval Part 50 license terminated

  • i Period 3b-Site restoration I Buildang demohtions, backfill and landscaping Legend: 1.Red text andlor shaded scheduling bars indicate critical path activities 2.Shaded scheduling bars associated with major decommissioning periods, e.g., Period la, indicate overall duration of that period 3.Blue text and/or diamond symbols indicate major milestones TLG Services, Inc.

ULNRC-06349 Page 71 of 173 Callaway Energy Center.Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis Section 4, Page 4 of 5 FIGURE 4.2 DECOMMISSIONING TIMELINE 40-YEAR PLANT OPERATING LIFE DECON (not to scale)Shutdown October 18, 2024 END.Period 2 Period 3 Periodi Decommissioning Site Preparations Operations Restoration i Oct-2024 Mar-2033 Apr-2025 Sept-2031 Fuel Pool Operations Apr-2030 TLG Services, Inc.

.r*..ULNRC-06349 Page 72 of 173 Caflaway Energy Center Decommissioning Cost Analysis Shutdown October 18, 2024 FIGURE 4.3 DECOMMISSIONING TIMELINE 40-YEAR PLANT OPERATING LIFE$AF$TOR (not to scale)Document A22-1690-OO1, Rev.0 Section 4, Page 5 of 5 Period;SAFSIOR Preparations Period 2 Dormancy END Period 3 Period 4 Period 5 Decommissioning Decommissioning Site Preparations Operations Restoration Oct-2024 Apr-2O26 Fuel Pool 4.Operations Apr-2030 Oct-2078 Apr-2080 A Apr-2086 Oct-2084 TLG Services, Inc.

ULNRC-06349 Page 73 of 173 Caflaway Energy Center Document A22-1690-OO1, Rev.0 Decommissioning Cost Analysis.Section 5, Page 1 of C 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,[281 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§173.41 1).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 destinations for the various waste streams from decommissioning are identified in Figures 5.1 and 5.2.The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in appendices, and summarized in Tables 5.1 and 5.2 (base case).The quantified waste volume summaries shown in these tables are consistent with Part 6 1 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 rathonuclides 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).

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ULNRC-06349 Page 74 of 173 Callaway Energy Center Document A224690-OO1, Rev.U Decommissioning Cost Analysis Section 5, Page 2 of 6 While the dose rates decrease with time, radionuclides such as lS7Cs will still control the disposition requirements.

The waste material produced in the decontamination and dismantling of the nuclear units is primarily generated during Period 2 of DECON and Period 4 of$AFSTOR.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 estimates, the cost for disposal at the Energy$olutions facility was used as a proxy for future disposal facilities.

Separate rates were used for containerized waste and large components, including the steam generators and reactor coolant pump 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 rathoactive components generated in the decontamination and thsmantling of the reactor, disposal costs for the Class B and C material were based upon Ameren Missouri's current agreement with WC$for the Andrews County thsposal facility.A small quantity of material generated during the decommissioning will not be considered suitable for near-surface thsposal, and is assumed to be disposed of in a geologic repository, in a manner similar to that envisioned for spent fuel disposal.Such material, known as Greater-Than-Class-C or GTCC material, is estimated to require five spent fuel storage canisters (or the equivalent) to dispose of the most radioactive portions of the reactor vessel internals.

The volume and weight reported in Tables 5.1 and 5.2 represent the packaged weight and volume of the spent fuel storage canisters.

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