ML18081A579

Report on Decommissioning Funding Status

ML18081A579
Person / Time
Site:	Rancho Seco, 07200011
Issue date:	03/05/2018
From:	Tallman D Sacramento Municipal Utility District (SMUD)
To:	William Allen, Cruz Z Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DPG 18-048
Download: ML18081A579 (32)

Text

March 5, 2018 DPG 18-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 Docket No. 72-11 Rancho Seco Spent Fuel Storage Installation License No. SNM-2510 RANCHO SECO REPORT ON DECOMMISSIONING FUNDING STATUS Attention: Zahira Cruz Attention: William Allen As required by 10 CFR 50.75(f)(1) and 10 CFR 72.30(b)(6), this letter provides the information on the status of decommissioning funding for Rancho Seco.

Background

Rancho Seco began commercial power operation in April 1975 and shutdown permanently in June 1989. In 1991, the Sacramento Municipal Utility District (SMUD) submitted the proposed Decommissioning Plan for Rancho Seco, along with a Revised Financial Assurance Plan. The NRC approved the Decommissioning Plan in March 1995. Due to revisions to 10 CFR 50.82, SMUD submitted the Post Shutdown Decommissioning Activities Report for Rancho Seco in March 1997. Rancho Seco has been undergoing decommissioning since February 1997.

In April 2006, SMUD submitted the License Termination Plan for Rancho Seco outlining a phased approach to decommissioning. Phase I of the decommissioning was completed in 2009 when the majority of the facility land area, including the major plant systems and structures, was released from the license. The facility remaining under the Part 50 license now consists of a 1-acre land area that contains the Interim Onsite Storage Building (IOSB). Decommissioning of the IOSB was completed in 2017 with the acceptance of the Final Survey Status Report by NRC letter "REVIEW OF FINAL STATUS SURVEY REPORT FOR RANCHO SECO NUCLEAR GENERATING STATION INTERIM ONSITE STORAGE BUILDING" dated May 16, 2017. SMUD Rancho Seco Nuclear Generating Station I 14440 Twin Cities Road I Herald, CA 95638-9799 I 916.452.3211 I smud.org Printed on Recycled Paper

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DPG 18-048 Page 2 of 7 submitted its request to terminate the Part 50 license in letter "Termination of the Rancho Seco 10 CFR Part 50 License, Number DPR-54" dated September 21, 2017, which is currently under technical review by the NRC.

Decommissioning Financial Assurance Method and Trust Fund Status An "External Sinking Decommissioning Trust Fund" continues to be maintained by Wells Fargo Bank on behalf of SMUD. Per the Financial Assurance Plan, SMUD made contributions to the Trust Fund through 2008, at which time it was considered to be fully funded. At this time, no future contributions are planned but SMUD will continue to perform Decommissioning Cost Estimates and compare the results with the available funds in the Decommissioning Trust to ensure reasonable financial assurance.

Administration of the Decommissioning Fund The trust fund holdings were reviewed at the end of 2017, and the trust fund contained

$8.41 million. As discussed below, this provides the amount of funding estimated as required to complete decommissioning. If during the annual review the cost to complete decommissioning exceeded the available funds, a single contribution would be made the following calendar year to provide reasonable financial assurance.

Estimating Required Decommissioning Funding 10 CFR 50.75(c) provides the calculation basis for determining minimum amounts of funding required to demonstrate reasonable assurance of funds for decommissioning.

However, the calculation does not take into consideration work that has already been completed. For Rancho Seco, of the total estimated costs to complete decommissioning based on the site-specific cost estimate, 99% of the total costs have already been expended.

To demonstrate reasonable financial assurance in accordance with the regulation, two comparisons will be made:

• Minimum estimated amount per 50.75(c) vs. total site-specific cost estimate

• Site-specific cost estimate for remaining work vs. currently available funds For comparison purposes, this report will *determine "total site specific cost estimate" by adding the previously expended funds with the current estimate for remaining work to complete decommissioning. It should be noted that the "previously expended funds" represent the total of actual expenditures made as a sum of annual expenditures: these annual expenditures represent actual costs incurred in the year they were incurred and no attempt has been made to inflate the expenditures to current-year dollars. This provides an additional level of conservatism to the comparison.

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DPG 18-048 Page 3 of 7 These comparisons will demonstrate that the site-specific estimate is conservative compared to 50.75(c), and that sufficient funding is available to complete remaining estimated decommissioning work, thereby providing better assurance than a simple comparison against the minimum amount required.

Minimum Funding Required per 10 CFR 50.75(c)

The 2018 Decommissioning Cost Estimate contains the 50.75(c) evaluation. In summary, the Minimum Funding Required by 50.75(c) is $478.8 million. The total Rancho Seco Decommissioning Cost Estimate is $520.1 million, which exceeds the Minimum Funding required. Although this amount includes activities to terminate the Part 72 license, the total remaining License Termination costs that include both Part 50 and Part 72 activities is $10 million (this includes $4.8 million in funds expended but not withdrawn in addition to $5.2 million in future expected costs): completely subtracting this amount from the total leaves $510.2 million which still exceeds the Minimum Funding required.

Site-Specific Decommissioning Cost Estimate A copy of the 2017 Decommissioning Cost Estimate for Rancho Seco is included as Attachment 1. The costs are summarized as follows:

Total Actual Expenditures: $ 514.9 million Total Remaining Costs: $ 5.2 million Total Site Specific Estimate: $ 520.1 million Certification of Financial Assurance The Total Site Specific Cost Estimate exceeds the minimum estimated amount as calculated per 10 CFR 50.75(c). Therefore, funding that meets or exceeds the site-specific amount provides reasonable assurance that sufficient funding is available to complete decommissioning.

As of December 31, 2017 the available funds in the Decommissioning Trust Fund were

$8.41 million, which exceeds the estimated funding needed to complete decommissioning.

Certification in accordance with 10 CFR 50.75(b)(1) and 10 CFR 72.30(b)(6) is hereby made that financial assurance is being provided through an external sinking fund for

$8.41 million to complete decommissioning at Rancho Seco and terminate both the 10 CFR Part 50 and Part 72 licenses.

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DPG 18-048 Page 4 of 7 Adjustments to Cost Estimate and Trust Fund Phase I of the decommissioning project is complete as is the Phase II decommissioning of the IOSB. The remaining projected costs include the funds necessary to demonstrate compliance with NRC license termination criteria in Subpart E of both licensed facilities. Contingency funds are included.

The actual costs for the prior years (2015 thru 2017) as well as projections for 2018 are provided to determine the potential impact on the Cost Estimate. No funds were withdrawn from the Trust in 2015, 2016, or 2017.

Actual Cost of Decommissioning Activities for 2015: $1,340,000 Actual Cost of Decommissioning Activities for 2016: $2,523,459 Actual Cost of Decommissioning Activities for 2017: $633,403 Estimated Cost of License Termination Activities for 2017: $20,000 Overall cost of decommissioning activities in 2015-2017 exceeded the estimates contained within previously reported estimates. In large part this was due to the effort required to support confined space entries, overcome repeated failure of aging equipment (IOSB crane) required to gain access to survey units, and approximately twice the number of survey units requiring remediation (5 vs 2) as anticipated at the time the estimates were developed. Each of these contributed to the extension of the project schedule and associated staff retention and resulted in an increase to the overall cost of decommissioning. SMUD has funded these activities through the normal budgetary process, electing not to withdraw funds until the Part 50 license is terminated, while ensuring sufficient funds are retained within the trust to support the Part 72 ISFSI decommissioning cost estimate. With the completion of decommissioning activities, the only remaining costs associated with the Part 50 license termination are those associated with the NRC review of SMUD's license amendment request.

Assumptions Regarding Rates of Trust Fund Escalation and Earnings Since, the Trust Fund contains sufficient funding to complete all decommissioning work, no assumptions are necessary concerning the rate of return to demonstrate sufficient funding.

Contractual Obligations There are no contractual obligations associated with SMUD's Financial Assurance Plan or the operation of the decommissioning trust fund.

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DPG 18-048 Page 5 of 7 Modifications to Financial Assurance Method No modifications have been made since last year's report. The Trust has been fully funded since 2008 and remains in an external sinking fund as previously described.

Material Changes to the Trust Fund Agreement No material changes to the Trust Fund Agreement have been made since last year's report. The Trust remains with Wells Fargo Bank, N.A.

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DPG 18-048 Page 6 of 7 If you or members of your staff have questions or require additional information, please contact me by email at dan.tallman@smud.org or by phone at (916) 732-4893.

Sincerely,

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Dan A. Tall~-----

Manager, Rancho Seco Assets (OT)

Attachment 1: DPG 18-047, 2017 Rancho Seco Decommissioning Cost Estimate Cc: NRC, Region IV (w/Attachment)

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DPG 18-048 Page 7 of 7 ATTACHMENT 1 2018 DECOMMISSIONING COST ESTIMATE RANCHO SECO DECOMMISSIONING Rancho Seco Nuclear Generating Station I 14440 Twin Cities Road I Herald, CA 95638-9799 I 916.452.3211 I smud.org @

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201 7 DECOMMISSIONING COST ESTIMATE RANCHO SECO DECOMMISSIONING

Page ii of iii APPROVALS Prepared by:

Approved by:

Manager, Rancho Seco Assets On the cover: IOSB - regulated by Part 50 License ISFSI - regulated by Part 72 License

Page iii of iii TABLE OF CONTENTS PAGE Approvals ................................................................................................................ ii Summary .................................................................................................................. l Background .............................................................................................................. 2 Introduction .............................................................................................................. 4 History of Rancho Seco Decommissioning and Cost Estimates ......................... 5 Phased Decommissioning ................................................................................... 7 Financial Assurance for ISFSI Decommissioning .............................................. 8 Methodology and Approach .................................................................................. 10 Update Methodology ......................................................................................... 10 Overview of Decommissioning Cost Estimate Components ........................... .10 Financial Components of the Cost Model ............................................................ .11 Assumptions ........................................................................................................... 12 Used Fuel .......................................................................................................... 13 ISFSI Decommissioning ................................................................................... 13 Reactor Vessel and Internal Components ......................................................... 13 Transportation Methods .................................................................................... 13 Low-Level Radioactive Waste Disposal.. ......................................................... 13 Estimating Basis ................................................................................................ 13 Labor Costs ....................................................................................................... 14 General .............................................................................................................. 14 10 CFR 50.75(c) Determination ........................................... ,................................ 17 Glossary of Acronyms and Abbreviations ............................................................ .20 References .............................................................................................................. 21 TABLES

1. Decommissioning Cost Estimate ..................................................................... 22

DPG 18-047 Page 1 of 22 2017 DECOMMISSIONING COST ESTIMATE

SUMMARY

. The remaining cost projected to complete the decommissioning of the Rancho Seco Nuclear Station (Rancho Seco) is $5.2 million. This includes all projected costs to terminate both the Part 50 and Part 72 licenses.

In 2009, Phase I license termination activities were completed and modification of the Part 50 license was approved by the Nuclear Regulatory Commission (NRC). Phase I costs (completed in 2009) totaled $487.1 million. As of December 2017, Phase II expenditures already withdrawn from the Decommissioning Trust Fund totaled $23.0 million and expenditures not yet withdrawn total$ 4.8 million, making the total 2017 Decommissioning Cost Estimate $520.1 million. Remaining decommissioning activities include: the transfer of the used nuclear fuel and Greater Than Class "C" (GTCC) radioactive waste to the Department of Energy (DOE) in 2021 1; license termination activities for the area licensed under Part 50, scheduled for completion in 2018; and, decommissioning and license termination activities for the Part 72 licensed facility following removal of the material from the ISFSI. Previously expended costs included nuclear fuel storage costs only through 2008. Beginning in 2009, used fuel management costs are considered a normal operation and maintenance (O&M) expense, recoverable from the DOE, and are not included in the Decommissioning Cost Estimate.

Cost changes in this estimate reflect the completion of decommissioning activities for the Part 50 licensed facility and estimated costs for license termination activities as well activities associated with decommissioning of the ISFSI. The costs for the decommissioning line items for Phase II and a schedule of future expenditures are provided in Table 1. Act~al costs for funds expended in Phase I and II are reported in detail in previous Cost Estimates.

With Phase I completed in 2009, and now Phase II of the Part 50 radiological decommissioning complete including the disposal of the previously-stored Class B and Class C LLRW, the remaining cost is comprised of the license termination activities necessary to demonstrate compliance with the facility release standards in 10 CFR 20.

1 Based on the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste", January 2013.

DPG 18-047 Page 2of 22 BACKGROUND Rancho Seco is located approximately 25 miles southeast of Sacramento, California. The industrial facility is 87 acres and sits within a 2,480-acre plot of land that is owned by the Sacramento Municipal Utility District (SMUD). The station was comprised of a single B&W-designed generation :unit with support facilities.

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

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

Beginning in 1995, TLG Services, Inc. (TLG) provided SMUD with alternative cost estimates that included options for the decommissioning of the facility. Delays in the Dry Fuel Storage project caused increases in projected costs, and the alternatives were provided to take advantage of the available opportunities, including: availability of SMUD Staff on site to support dismantlement due to delays in the Dry Fuel Storage project, and; availability of Envirocare's Clive, Utah disposal facility (Envirocare is now EnergySolutions) as an appealing option for low level radioactive waste (LLRW)

• disposal.

In January of 1997, the SMUD Board of Directors (the Board) approved the Incremental Decommissioning Project, and physical dismantlement of the facility began later that year. In 1999, the Board approved expansion of the Incremental project to include all activities necessary for license termination. In April of 2006, SMUD submitted the License Termination Plan (LTP) to the NRC, outlining the activities necessary for the NRC to allow license termination. The LTP was approved by the NRC in November 2007. In September 2009 the NRC approved SMUD's request for modification of the Part 50 license. Currently, only the Interim Onsite Storage Building (IOSB) and the land enclosed by the exterior fence (approximately 1 acre) remains licensed under Part 50.

In the interim, the NRC issued SMUD a specific license for fuel storage in the Independent Spent Fuel Storage Installation (ISFSI) under Part 72 in June of 2000.

Transfer of all nuclear fuel to dry storage in the ISFSI was completed August 22, 2002.

DPG 18-047 Page 3of 22 With the closure of the Barnwell, S.C. waste disposal facility, there were no options for disposition of Class Band Class C LLRW available to SMUD beginning in 2008. The Class Band Class C LLRW was stored in the IOSB until the Waste Control Specialists, Inc. (WCS) facility in Andrews, Texas was deemed by SMUD as a suitable facility for disposal of the material. Shipping of the stored waste was completed in November 2014.

The estimated date for DOE acceptance of the used nuclear fuel and GTCC waste is 2021 based on the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste". That report, and the 2012 report by the Blue Ribbon Commission on America's Nuclear Future still provides the best available published information on the potential for DOE to take possession of the material stored at the ISFSI. SMUD recognizes that the schedule provided within the DOE report has been severely compromised by the failure of Congress to pass the necessary enabling legislation, however, considering that the Decommissioning Trust Fund is fully funded, and SMUD is not relying on increases in trust fund value through investment growth to ensure available funds for decommissioning, the uncertainty in the schedule for used fuel removal does not impact SMUD's ability to fund all decommissioning activities.

DPG 18-047 Page 4 of 22 INTRODUCTION This decommissioning cost estimate is prepared to satisfy the requirements of Title 10 of the Code of Federal Regulations, Part 50.75 and Part 72.30. As the base assumptions used in the development and subsequent updates of the cost basis for decommissioning the ISFSI remain unchanged, this required 2017 update consists of only an inflationary adjustment.

The origin of this current cost estimate is the area-based decommissioning cost estimate prepared in 1999 and later updated in the year 2000 by TLG (previous estimates were system-based). Subsequently, SMUD staff updated the estimate in the years 2001 through 2005. Each of these updates prepared by SMUD staff was reviewed by TLG.

Since 2006, updates are performed by SMUD staff without outside agency review.

SMUD staff has determined that outside review is not necessary because all activities involving significant cost and/or schedule risk have been completed. This Estimate also includes ISFSI decommissioning costs. These costs are not significant in comparison to the cost of decommissioning the reactor facility as no evidence exists that any remediation of ISFSI facilities or land areas would be required following removal of the used nuclear fuel and GTCC material. This cost estimate updates the 2016 estimate. The current cost estimate for decommissioning Rancho Seco is $520.1 million.

The technical portion of the TLG cost estimate was based on system and component removal and facility decontamination. With all system and component removal complete and no remaining facility decontamination anticipated, there is little technical basis to the remaining costs. In addition, the decommissioning costs to date have all been well within the estimated costs, and the small scope of work remaining poses little risk of changing the historical trend. With a firm basis for estimating the remaining costs, staff has determined that outside review would not provide additional confidence in the cost basis.

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

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

• Completion ofIOSB decommissioning activities.

• Completion of the Final Site Status Survey in support of license termination.

• Completion of NRC' s review of the Final Site Survey Report. (May 16, 2017)

• NRC acceptance of SMUD's License Amendment Request, Terminating the Part 50 license.

DPG 18-047 Page 5 of 22 History of Rancho Seco Decommissioning and Cost Estimates After the cessation of plant operations on June 7, 1989, the initial decommissioning alternative chosen was a modified SAFSTOR option identified as Hardened SAFSTOR.

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

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

Dismantlement activities were to commence once the funding was complete.

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

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

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

EnergySolutions did not (and currently does not) accept the full spectrum of waste that is categorized as LLRW, but the waste they do accept represents the vast majority of waste generated during a power reactor decommissioning project. The Ward Valley cost basis was over $400 per ft3 ofLLRW, while the EnergySolutions cost was under $100 per ft3 .

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

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

DPG 18-047 Page 6of 22 The availability of EnergySolutions combined with the presence of a large talent pool within the available staff presented an opportunity to begin the dismantlement process early. In 1996, a plan was developed to take advantage of both circumstances and perform dismantlement of the majority of the secondary systems in the Turbine Building.

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

The Incremental Decommissioning Project was successful in helping to mitigate the impacts of the delay in the fuel project, and the work was completed ahead of schedule and below projected costs. The Incremental project was so successful that the scope was expanded to include systems in the Tank Farm and other outside areas.

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

Early cost estimates throughout the industry were based upon inventories of plant components and commodities by system. Based upon the experiences gained at Rancho Seco and at other decommissioning nuclear utilities, TLG shifted the performance of cost estimating from a system-based approach to an area-based approach. To facilitate shifting the Rancho Seco cost estimate to the area-based approach, staff performed an area-by-area inventory of the plant systems and components in the Auxiliary and Reactor Buildings. The cost estimate prepared by TLG in 1999 represented both the shift to the area-based approach and the schedule change of completing decommissioning in 2008.

(An additional cost estimate representing an update to the 1995 system-based estimate was also performed by TLG in 1999 for comparison purposes. 1999 was the last year the system-based estimate was updated.)

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

The date of January 1, 2000 is defined as the dividing line between Incremental Decommissioning and Decommissioning. The demarcation between the two projects may be defined as that point where the planned Turbine Building work was completed, and work in the Auxiliary Building was begun. In actuality, there was some overlap

DPG 18-047 Page 7of 22 between the projects, with work occurring simultaneously on both projects for 1-2 months before and after 1/1/2000. Defining 1/1/2000 as both the end of Incremental Decommissioning (completion of work defined as within Incremental Decommissioning scope) and the beginning of Decommissioning (no work yet begun defined as within Decommissioning scope) has negligible impact on cost. However, it would be difficult to carry forward a demarcation point other than the beginning of the calendar year because Trust Fund calculations, the budget process, and the scheduling of costs over the duration of the project are all based upon calendar year.

Beginning in December, 2013, financial assurance for ISFSI decommissioning is required. This cost estimate carries forward the information necessary to allow compliance with the regulations in 10 CFR 72.30 which is being updated in this report in accordance with those regulations.

Phased Decommissioning By 2001, after Decommissioning had begun, SMUD decided not to send any LLRW to the Barnwell, SC disposal facility, having never sent any material there for disposal. This decision precluded the ability to complete Decommissioning and termination of the Part 50 license. At that time, the plan to decommission in phases was implemented. During Phase I, the majority of the identified license termination activities would be completed, including large component removal and decontamination of the facility to meet NRC release criteria. Class B & C LLRW resulting from these activities would be stored in the IOSB. With Phase I complete, the Part 50 license would be modified to include only the IOSB and land surrounding it (approximately I-acre). Phase II included oversight of the stored waste, shipping of the waste for disposal, followed by completion of all license termination activities at the IOSB resulting in termination of the Part 50 license.

Decommissioning of the ISFSI will occur following removal of the material stored at the ISFSI by the DOE.

All physical system removal and building decontamination was complete by the end of 2008, with Final Status Surveys completed in June 2009. In September 2009, the NRC approved SMUD's request to modify the Part 50 license, releasing all of the facility from the license except for the I-acre area encompassing the IOSB. This completed Phase I of Decommissioning. In 2014, the stored LLRW was shipped for disposal. Phase II decommissioning activities for the IOSB commenced in 2015 and were completed in 2016. In January 2017, SMUD submitted the Final Status Survey Report for the Phase II decommissioning and in May 2017, the NRC informed SMUD that" ... on the basis of clean-up activities carried out by the licensee, the NRC's review of SMUD's final status survey report, and the results of NRC confirmatory surveys, the NRC concludes that the licensee has met the criteria of 10 CFR 20.1402 and therefore, the Phase II area is suitable to be released for unrestricted use." SMUD formally requested that its 10 CFR Part 50 license be terminated in September 2017.

DPG 18-047 Page 8of 22 Financial Assurance for ISFSI Decommissioning As discussed previously, SMUD fully funded the Part 50 Decommissioning Trust Fund by making the last contribution in 2008. However, because of the level of uncertainty inherent in power reactor decommissioning, the amount of funding provided was conservative. When Phase I of decommissioning was completed in 2009, an estimated

$18 - $20 Million in excess funds were available in the Decommissioning Trust Fund.

Much of the former excess was utilized for LLRW disposal in 2014 and sufficient funds remain to assure available funding for ISFSI decommissioning. Therefore, no additional contributions to the Trust Fund are currently planned.

10 CFR 72.30 contains specific requirements for documenting the financial assurance for ISFSI decommissioning. These specifics are addressed here.

72.30(b)(l) requires documentation of how funds will be provided: The Trust Fund initially established for Part 50 Decommissioning was over-funded. The activities to decommission Rancho Seco include the activities necessary for terminating both NRC licenses. This cost estimate demonstrates that sufficient funds are available in the Trust Fund to provide financial assurance for ISFSI decommissioning.

72.30(b)(2) requires a detailed cost estimate for decommissioning the ISFSI: This document provides the information required.

72.3 O(b)(2)(i) requires that the cost estimate include the cost of an independent contractor to perform decommissioning activities. This cost estimate assumes all activities are conducted by an independent contractor in compliance with this requirement, in addition to including the cost of a SMUD Project Manager.

72.30(b)(2)(ii) requires an adequate contingency factor: A factor of 15% is used. This is sufficient to account for project uncertainties and demonstrates compliance with this requirement. Contingency is provided to account for uncertainties in the decommissioning process. Given that detailed information exists documenting the radiological conditions of the facility, and the robust nature of the sealed fuel storage systems, there is little radiological uncertainty regarding the condition of the facility and 15% provides a sufficient margin.

72.30(b)(2)(iii) requires inclusion of the cost of meeting the radiological criteria for license termination contained in 10 CFR 20: Those activities are specifically included in this cost estimate demonstrating compliance with this requirement.

72.30(b)(3) requires identification and justification of the key assumptions used in the cost estimate: That information is specifically included later in this document, demonstrating compliance with this requirement.

DPG 18-047 Page 9of 22 72.30(b)(4) requires a description of assuring funds for decommissioning and a means for adjusting the cost estimate periodically over the life of the facility: The funds for decommissioning are already contained in a Decommissioning Trust Fund set aside for Part 50 license termination. 72.30(c) requires that the decommissioning funding plan be resubmitted at intervals not to exceed 3 years. In 2014, 2015, and 2016 updated plans were submitted reflecting the updated schedule for Part 50 decommissioning. As none of the baseline assumptions for decommissioning and license termination cost of the Rancho Seco ISFSI have changed, this update consists of only an inflationary adjustment of the 2016 update. License termination of the Part 50 license will occur in 2018. Therefore it is expected that when the next Part 72 decommissioning funding plan is updated, only Part 72 decommissioning costs will remain and the financial instrument used to demonstrate assurance with 72.30(e) will reflect that information. Until then, the existing Trust Fund is justified for providing financial assurance. The Rancho Seco ISFSI License expires in 2020, so per 72.30(c), the decommissioning funding plan will be resubmitted with the renewal application. The license renewal process will incorporate a mechanism for future funding plan updates.

72.30(b)(5) requires information regarding the subsurface residual radioactivity that will require remediation to meet the radiological criteria for license termination: No removal of subsurface materials will be required to meet the radiological release criteria. The radiological condition of the land area of the ISFISI was evaluated prior to construction and no residual radioactivity was evident. Given that the material in storage at the facility resides in robust, sealed containers and there is no reasonable accident that can occur to cause failure of the containers, there is no reasonable likelihood that the stored radioactive materials will enter the environment. Detailed radiological surveys conducted during the process of moving the fuel from wet to dry storage document that no contamination of the area occurred during operations. With no reasonable method of introducing radioactive materials into the land within the ISFSI facility, there is no reasonable expectation that subsurface materials will require remediation. This documents compliance with this requirement.

72.30(b)(6) requires certification that financial assurance for decommissioning be provided: Compliance with this requirement was satisfied by a separate letter dated March 1, 2018 As discussed previously, SMUD fully funded the Part 50 Decommissioning Trust Fund by making the last contribution in 2008. However, because of the level of uncertainty inherent in power reactor decommissioning, the amount of funding provided was conservative. When Phase I of decommissioning was completed in 2009, excess funds were available in the Decommissioning Trust Fund. With Phase II decommissioning now complete, funded primarily through the annual budgeting process, an excess of available fund still exists. This excess provided more than sufficient funds to assure available funding for future ISFSI decommissioning. Therefore, no additional contributions to the Trust Fund are currently planned.

DPG 18-047 Page JO of 22 METHODOLOGY AND APPROACH This cost estimate reflects the actual costs of Phase I (defined as all costs of the dismantlement effort including some license termination activities that resulted in the modification of the part 50 license), and provides actual and estimated costs for Phase II (defined as costs beginning in 2009 with the oversight of stored waste through termination of the Part 50 license). Part 72 license termination activities are included separately. The technical basis for previous estimates included detailed calculations for:

system and component removal; extensive building and outside area decontamination, and; determination of radioactive waste volumes and packaging requirements. With the completion of Phase I and Phase II of decommissioning, all nuclear systems and components have been removed and all remaining decommissioning costs are associated with the Part 50 License Termination review and the ISFSI decommissioning.

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

Update Methodology Previous updates to the cost estimate utilized actual cost bases to update ongoing activities. In 2009, the future costs were reevaluated and a new baseline was established based on the limited scope of the remaining work and reflecting the need to re-establish a decommissioning organization when physical work resumes. This update reflects actual costs for LLRW disposal and costs for future license termination activities. The major cost categories are: "Shipping and Burial for Waste Disposal, Contract Staff and Miscellaneous".

Because the scope of Part 50 decommissioning exceeded previous estimates, due to the effort required to support confined space entries, overcome repeated failure of aging equipment (IOSB crane) required to gain access to survey units, and approximated twice the number of survey units requiring remediation (5 vs. 2), this update reflects not only a shift in schedule but a change in total cost ($520.1 vs. $518.3 million).

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

Phase I costs are identified as a single line item of costs previously expended and withdrawn from the Decommissioning Trust Fund. Some Phase II costs have also been withdrawn from the Trust.

DPG 18-047 Page 11 of 22 As the purpose of the DCE is to provide a basis for assuring sufficient funds for decommissioning, appropriate costs are identified as "withdrawn" meaning that these actual expenses have been removed from the Decommissioning Trust Fund. Historically, SMUD would make annual withdrawals from the Trust based on expenditures. In the interim, the actual expenses were small enough that withdrawals were not taken which was reflected in the cost estimate. Following the disposal of the LLRW, another withdrawal was taken, but the withdrawal also considered ensuring sufficient funding for remaining decommissioning activities.

Staff costs include the cost for contract staff to perform the remaining license termination activities of the IOSB and performance of subsequent Final Status Surveys at the ISFSI.

Miscellaneous costs have been included to document the support costs that are specifically identified for the duration of the decommissioning project. These costs also include materials costs for decommissioning.

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

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

The format was changed in the 2009 update for ease of performing future updates.

Previous estimates did include information for terminating the Part 72 license as a means to capture that data. With a regulatory requirement now in place to demonstrate financial assurance for Part 72 license termination, that information has been updated.

The 1999 area-based decommissioning cost estimate prepared by TLG was comprised of a detailed list of activities to which the unit cost factor methodology was applied. This provided a sound basis for determining overall costs, but contingencies were also added.

The contingency provides additional funds to cover unforeseeable costs that are within the defined scope of the decommissioning project. It is important to note that contingency funds are an important part of the decommissioning cost estimate, and represent funds that are expected to be completely expended through the decommissioning process.

DPG 18-047 Page 12 of 22 All of the activities which presented significant cost risk were completed in Phase I of Decommissioning, including disposition of the reactor vessel, reactor vessel internals, and all interior structures in the containment building. The reactor vessel and its internal components became radioactive as a result of activation during plant operation. Portions of the internals are highly radioactive and do not qualify as LLRW, but are classified as GTCC waste and are currently in storage at the ISFSI. With the 2016 completion of all decommissioning activities, including Final Site Status Surveys, of the IOSB virtually all Part 50 decommissioning costs have been incurred with the exception of the licensing action request review charges needed to allow NRC termination of the Part 50 license.

Examples of remaining contingencies include changes in the regulatory environment and cost or regulatory changes that would impact remaining license termination activities.

The cost impacts of these uncertainties have been defined by TLG in previous estimates under the term "financial risk". To date, financial risk has not been specifically addressed within any Rancho Seco decommissioning cost estimate. Outside of the scope of the cost estimate itself, staff deals with these uncertainties on a project-by-project basis. An overall risk assessment taking into account any anticipated risk factor would typically be addressed through a probability analysis, perhaps utilizing a Monte Carlo-type probability simulation. Such a detailed risk analysis is considered to be outside of the scope of the decommissioning cost estimate. However, contingency is included as a component of the estimate.

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

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

Used Fuel

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

2. The ISFSI will remain operational under the 10 CFR 72 license until the DOE takes possession of, or accepts responsibility for, the fuel. The cost for maintenance of the fuel is considered O&M and is not included in this cost estimate.

3. DOE acceptance of fuel in 2021. This will be reviewed for each subsequent estimate as there is currently great uncertainty with the acceptance date. Note that the actual date of fuel acceptance is currently not a factor in demonstrating financial assurance because the decommissioning costs are fully funded and do not rely on a return on investments over time.

DPG 18-047 Page 13of 22 ISFSI Decommissioning

1. No remediation will be required for any structures or land areas at the ISFSI.

Evaluation of Reference 4 indicates that activation of materials at the ISFSI will not result in contamination that requires remediation. No loose contamination at the ISFSI was measured during the fuel movement activities in 2000 through 2002, and no indication of fuel canister leakage is evident.

Reactor Vessel Internal Components

1. The reactor vessel internal components classified as GTCC material is stored in the ISFSI until the DOE takes possession of the material. However, the DOE has not yet established an acceptance criteria or a disposition schedule for this material.

Therefore, this cost estimate is based upon industry-accepted assumptions regarding DOE schedules. Industry assumptions for the acceptance criteria are modeled on the packaging for the used nuclear fuel: the GTCC is stored in a canister with the same outer geometry as the used fuel canisters.

2. The cost for maintenance, transfer and disposal of the GTCC material is not included in this cost estimate. Legal opinions and court decisions indicate that the GTCC disposal is the responsibility of the DOE.

Transportation Methods

1. Contaminated materials resulting from any remaining decommissioning activities will qualify under Title 49 of the Code of Federal Regulations Part 173 as LSA-I, -

II, or -III, or SCO-I or -II.

2. Transportation of Class A LLRW is by truck or rail to EnergySolutions in Clive, UT or Radioactive Waste Processing Facilities appropriately licensed and approved bySMUD.

Low-Level Radioactive Waste Disposal

1. The majority of the LLRW generated during decommissioning has been disposed at EnergySolutions. Future disposal rates for Class A waste used in the estimate are based upon historical rates and potential future rate impacts based on over 10-years of historical trends. EnergySolutions considers contract disposal rates proprietary.

Estimating Basis

1. Future decommissioning costs are in general reported in the current year's currency regardless of the scheduled year of the expenditure; therefore, changes in schedule do not impact the cost estimate.

DPG 18-047 Page 14of 22

2. Remaining costs are based upon an estimate of the remaining activities including contract staff to perform the activities and other costs such as waste disposal.

Labor Costs

1. The craft labor required to complete decommissioning is obtained through standard SMUD contracting practices.

2. Future activities such as waste shipments and license termination activities will be performed by contracted staff.

3. Engineering services for such items as writing activity specifications, detailed procedures, and work procedures are assumed to be performed by contracted staff.

General

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

All physical decommissioning activities have been completed and only NRC review of the license termination request remains.

2. The approximately 14-acre ISFSI remains under the Part 72 license. The used fuel will be transferred to the DOE starting 2021. Following transfer of the used fuel and GTCC material, a new decommissioning project will be undertaken to terminate this license.

3. Phase I of the LTP is complete. The disposal of previously-stored Class B & C LLRW has been completed as have Phase II decommissioning activities and only license termination activities remain.

4. Completion of license termination activities for the Part 72 license will be completed after the DOE removes the stored material from the ISFSI.

5. NRC oversight of the decommissioning process is estimated based on previous license termination activities. The amount of oversight effort is proportioned based on the number of Survey Units for license termination as a reasonable basis for the estimate.

6. Equipment costs for use during decommissioning are included as Miscellaneous Costs.

7. Demonstration of compliance with the radiological criteria for license termination of the Part 72 facilities will require documentation of no more than 25 Survey Units as follows;

DPG 18-047 Page 15 of 22

1. Units Description Location Classification 22 HS Ms ISFSI Class 1 1 Concrete Pad ISFSI Class 2 1 Concrete Apron ISFSI Class 3 1 Land Area ISFSI Class 3 The IOSB decommissioning required the documentation of 35 Survey Units. The surveys for these survey units and associated documentation, as submitted to the NRC under separate docket, demonstrate that these areas of the facility and site are suitable for release in accordance with the criteria for decommissioning in 10CFR20, subpart Eby meeting a site release criteria of 25 millirem TEDE per year over background for all dose pathways in accordance with the approved License Termination Plan. ,

DPG 18-047 Page 16of 22

1. Units Description Location Classification 15 Storage Cells IOSB Class 3 1 Storage Cell Deck IOSB Class 3 1 Hot Cell IOSB Class 1 1 Hot Cell Buffer IOSB Class 2 1 Cask Wash Down Area IOSB Class 3 1 Staging Bay (localized floor) IOSB Class 1 1 Staging Bay (Class 1 Buffer) IOSB Class 2 1 Staging Bay IOSB Class 3 1 DAW Bay IOSB Class 3 1 Truck Loading Dock IOSB Class 1 1 Loading Dock Buffer IOSB Class 2 1 Truck Bay IOSB Class 3 1 Sumps IOSB Class 3 1 Hot Cell Embedded Piping IOSB Class 1 1 Embedded Piping IOSB Class 3 1 Office Areas IOSB Class 3 1 Exterior Pavement (localized) IOSB Class 1 1 Pavement (Class 1 Buffer) IOSB Class 2 1 Land/Paved Areas IOSB Class 3 1 IOSB Exterior Surfaces IOSB Class 3 1 IOSB Roof IOSB Class 3

DPG 18-047 Page 17of 22

8. Equipment such as administrative equipment (desks, chairs, etc.), forklifts, trucks, other mobile equipment and items of personal property owned by SMUD will be easily removed without the use of special equipment at no cost or credit to the project.

9. The decommissioning activities are performed in accordance with applicable regulations .

. 10. The principles of ALARA used in determining work duration adjustment factors are minimal for the remaining work scope, but remain an element in the cost estimate.

11. SMUD provides the electrical power required for the decommissioning project at no cost to the project.

10 CFR 50.75(c) DETERMINATION In order to comply with 10 CFR 50.75(c), a determination must be made comparing this site-specific DCE with the NRC's generic DCE calculated in accordance with 50.75(c).

1986 Baseline Decommissioning Cost Per 10 CFR 50.75( c)(l)(i), the 1986 Baseline Decommissioning Cost for a Pressurized Water Reactor (PWR) rated below 3,440 MWt is calculated as follows (millions of dollars):

$(75 + 0.0088P)

Where: P = power level in mega-watts thermal (MWt)

For Rancho Seco, rated at 2,773 MWt, the 1986 baseline cost is:

$(75 + 0.0088 x 2773) = $ 99.402 Million Current 10 CFR 50.75(c) Decommissioning Cost Determination To determine the current value of the Baseline Decommissioning Cost Estimate, the 1986 value is adjusted by the factor specified in 10 CFR 50.75(c)(2), which is:

0.65 L + 0.13 E + 0.22 B Where: L = escalation factor for Labor, from US Department of Labor E = escalation factor for Energy, from US Department of Labor B = escalation factor for LLRW burial, from-NUREG-1307

DPG 18-047 Page 18of 22 Determination of Labor Escalation The US Department of Labor last adjusted labor in 2005 establishing a new baseline value for L:

L20os = 2.06 Utilizing the most recent Employment Cost Index information available from the Bureau of Labor Statistics (Q4 2017), the value of Lis calculated as follows:

L = 2.06 x 132.9 + 100 = 2.74 Determination of Energy Escalation The energy escalation is calculated based on two factors: industrial electric power (P) and light fuel oil (F) based on the following equation for a PWR (from NUREG-1307, Rev.

16):

E = 0.58 x P + 0.42 x F Both of the factors P and F are determined by a ratio of current Producer Price Index information (September 2017) to the January 1986 value. The current values are calculated as follows:

P = 249.0-;- 114.2 = 2.18 F = 192.5-;- 82.0 = 2.35 The resulting energy escalation factor is:

E = (0.58) x (2.18) + (0.42) x (2.35) = 2.25 Determination of Burial Escalation This value is taken directly from NUREG-1307, Rev. 16 Table 2.1 for "Values for Generators Located in the Unaffiliated States and those Located in Compact-Affiliated States having no Disposal Facility" (per footnote (c)) with B = 12.471.

Current 10 CFR 50.75(c) Decommissioning Cost Calculation The resulting 10 CFR 50.75(c) Decommission Cost is as follows (millions of dollars):

$99.402 X [(0.65) X (2.74) + (0.13) X (2.25) + (0.22) X (12.471)] = $478.831

DPG 18-047 Page 19 of 22 Comparison to Rancho Seco Decommissioning Cost Estimate The current total cost estimate for Rancho Seco decommissioning is $520.1 million, which exceeds the 10 CFR 50.75(c) required minimum of $478.8 million.

DPG 18-047 Page 20of 22 GLOSSARY INCLUDING ACRONYMS AND ABBREVIATIONS

1. ALARA: As Low As Reasonably Achievable

2. Barnwell: The Barnwell, SC LLRW Disposal Facility

3. DOE: Department of Energy

4. Energy Solutions: EnergySolutions, Inc., formerly Envirocare of Utah, Inc. -

headquartered in Salt Lake City that operates the LLRW disposal facility in Clive, UT and is a partner in "Sempra-Safe, LLC", a licensed resin processing technique in TN

5. GTCC: Greater Than Class "C" Waste - disposal ofthis waste is the responsibility of the DOE

6. IOSB: Interim Onsite Storage Building

7. ISFSI: Independent Spent Fuel Storage Installation

8. LLRW: Low Level Radioactive Waste

9. LTP: License Termination Plan

10. NRC: Nuclear Regulatory Commission

11. 0 & M: Operation and Maintenance

12. PWR: Pressurized Water Reactor

13. Part 50: Title 10 of the Code of Federal Regulations, Part SO-regulations governing the former operating plant license now applicable to the IOSB

14. Rancho Seco: Used in reference to both facilities licensed by the NRC, Rancho Seco Nuclear Generating Station (Part 50) and Rancho Seco ISFSI (Part 72)

15. SMUD: Sacramento Municipal Utility District

16. TLG: TLG Services, Inc

17. Ward Valley: The proposed Ward Valley Low Level Waste Disposal Site in Needles, CA

18. WCS: Waste Control Specialist, Inc. - operates the LLRW disposal facility being constructed in Andrews, TX

DPG 18-047 Page 21 of 22 REFERENCES

1. "2016 Decommissioning Cost Estimate for the Rancho Seco Nuclear Generating Station", March 23, 2017

2. Letter to NRC, "Rancho Seco Report on Decommissioning Funding Status",

March 22, 2017

3. Rancho Seco Part 72 License Termination cost basis, TLG Services, Inc "Independent Spent Fuel Storage Installation Decommissioning" Cost Summary, 2003; ARO Response to Data Request and Assumptions, Attachment Sl 1-1481-0302

4. SMUD Engineering Calculation #Z-XXX-N0057, Revision 1, October 4, 1993, "Neutron Activation of a Pacific Nuclear NUHOMS"

5. "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste", Department of Energy, January 2013

6. "Report to the Secretary of Energy", Blue Ribbon Commission on America's Nuclear Future, January 2012

Rancho Seco Nuclear Generating Station DPG18-047 Area Basd Decommissioning Cost Estimate Page22of22 Table1 Decommissioning Cost Estimate (Thousands of2017 Dollars)

COSTS BY ACTMTY COSTS BY YEAR Waste Diseosal  %

DESC SHIP BURY STAFF Misc CNTGCY CNTGCY TOTAL 2018 2027 2028 TOTAL License Termination ACMties Part 50 license termination 2D 25% 25 25 25 Part 72 license termination 2 32 3.117 1,36(] 655 15% 5,167 5,167 5.167 Total License Termination 2 32 3.117 1,380 660 15% 5,192 TOTAL COST (CE 2017) 2 32 3,117 1,380 660 15% 5,192 5.167 5,192 Phase I Costs 487,139 Phase II. Actual through 2D14 22,990 Total Actual Expenditures withdrawn from Trust Fund 510,129 Total Actual Expendttures (2015) not yet wilhdrawn from Trust Fund 1.618 Total Actual Expendttures (2016) not yet wilhdra!\vn from Trust Fund 2,523 Total Actual Expendttures (2017) not yet wilhdrawn from Trust Fund 633 Total Actual Expenditures 514,91>4 5,192 Remaining cost to complete Total Decommissioning Cost 52010961 Notes "TOTAL COST (CE 2D 17Y' represents total expected future Decommissioning Trust Fund wilhdrawals "Total Decommissic,ning Cosf' represents all previi,usly expended funds and estimated future costs "TD!al Decommissioning Cosf' represents all previously expended funds and estimated future costs