Text

Framatome Response to Request for Additional Information Regarding Triennial Update to Decommissioning Funding Plan (Enterprise Project Identifier L-2018-DFA-0001)
	ML18159A052
Person / Time
Site:	Framatome ANP Richland
Issue date:	05/31/2018
From:	Travis Tate; Framatome
To:	Kevin Ramsey; Fuel Manufacturing Branch
References
	TJT:18:022
	Download: ML18159A052 (79)
	v • d • e

framatome May 31, 2018 T JT:18:022 Kevin M. Ramsey, Senior Project Manager Fuel Manufacturing Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555-0001

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING TRIENNIAL UPDATE TO DECOMMISSIONING FUNDING PLAN (ENTERPRISE PROJECT IDENTIFIER L-2018-DF A-0001)

Dear Mr. Ramsey:

By letter dated May, 16, 2018, the NRC requested additional information regarding Framatome's Decommissioning Funding Plan (DFP) that was submitted on January 17, 2018.

The attachment to this letter provides responses to these requests.

If you have questions, please feel free to contact me at 509-375-8550 or Calvin Manning of my staff at 509-375-8237.

Very truly yours, T. J. Tate, Manager Environmental, Health, Safety and Licensing

/mah Framat ome Inc.

2101 Horn Rapids Road Richland, WA 99354 Tel: (509) 375-8100 www.framatome.com

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NRC May 31, 2018 Attachment DFP RAI Responses T JT:18:022 Page 3

1. Your 2016 DFP submittal included the following key assumption. You need to retain this information (either verbatim or by reference) or explain why it no longer applies:

Response: FRAMATOME will retain this information verbatim and has included it in the attached DFP.

2. Your 2016 DFP contains the following line item in Table 12. The inventory disposition cost does not appear in the 2018 DFP. What is the basis for removing that cost?

Table 12 Miscellaneous Costs - Production and Production Support Facilities No longer contains line item:

USEC UF6 Inventory Disposition

$756,000 Response: FRAMATOME will retain this information has included it in the attached DFP. We had 330 USEC Cylinders stored in Nov. 2015, and now have 179.

3. Comparing Table 26 in AREVA's 2016 DFP to Table 26 in AREVA's 2018 DFP, the low-level radiological disposal rate went from to $275.71 in 2016 to $268.53 in 2018. What is the basis for the reduction? Additionally, line item MW-No Disposal Option $300/ft3 totaling

$434,558 in the 2016 DFP is removed from the 2018 DFP. What is the basis for removing that cost?

Response: The low-level radiological disposal rate listed in Table 26 is largely the cost of operating our incinerator (SWUR) for volume reduction. The cost went from 275.71 to 268.53 because the cost associated with operating SWUR has decreased.

The line item MW-No Disposal Option was removed because Framatome developed a unique process to separate the uranium from this waste and completed processing this waste, removed sufficient amounts of uranium from this waste so that it could disposed of at Energy Solutions in Clive Utah. This waste has since been shipped offsite.

4. Regarding AREVA's e-mail coming in with the 2018 DFP which covered the 8 regulatory factors, the following factors need more basis than what has been provided:

a. "Spills-no spills that will impact decommissioning costs occurred since the last update." Additional information would help us make a finding. Have you reported any unplanned contamination events since the last update?

Response: We have had a couple of very minor unplanned contamination events since the last update, but each was cleaned up to release limits and any contaminated soil or asphalt was packaged into waste drums and is accounted for in the DFP. (See section 5.3.2 of the DFP)

b. Waste inventory increases-the e-mail does not address this factor. A statement is needed regarding changes in the waste inventory since the last update and the reason for the changes (if any).

NRC May31, 2018 T JT: 18:022 Page 4

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80,000 Response: The waste volume on is shown on the following graph. The current waste inventory as of March 31 is 13,225 ft3 CY 2018 Radioactive Solid Waste Inventory (CuFt) 70,000 l,I---Filr-----------------------1 a TMBL OVA a EVC 60,000 50,000 40,000 30,000 20,000 10,000 0

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"Increasing waste disposal costs-the estimated cost increases listed in this update of the DFP are primarily due to increased disposal and labor costs."

Additional information would help us make a finding. What factors have changed since the last update? Has the waste volume changed (if so, how much)? Have the disposal charges changed (if so, how much)? Have the labor rates changed (if so, how much)?

Response: The estimated disposal costs are primarily due to increased disposal and labor costs. The waste volume estimates for decommissioning is unchanged. Disposal costs estimates have changed as follows:

Waste Category Disposal Rates, Disposal Comments

$/ft3-2015 Rates, $/ft3-2017 LRW-lncinerate in 275.71 268.53 SWUR LLRW Direct disposal MW-Disposal at 325.00 370.11 contracted mixed waste disposal site

No incremental disposal costs above the money already allocated to US Ecology (see Table 9b).

Most key labor costs have changed. The rates used follow (note that in most cases where we found a lower labor rate in 2017, we retained the 2015 rates:

NRC May31, 2018 Project Manager Senior Engineer Engineer Health & Safety Tech (HST)

HST Supervisor Crafts (D&D)

Equipment Operator Laborer Clerical Health Physicist Technician-Plant Operations Support 2015 119.32 99.84 69.78 42.00 42.00 90.10 57.91 49.51 36.08 97.28 50.00

$/hr -2017 67.96 102.40 76.80 48.00 63.00 93.47 57.66 53.09 38.30 111.18 53.15 T JT:18:022 Page 5 Retained 2015 rate HST Supervisor was not included in 2015 estimate.

One HST is now assumed to be a supervisor.

Retained 2015 rate

d. "Facility Modifications-no facility modifications were made since the last update that will impact decommissioning costs." Additional information would help us make a finding. Has the footprint of contaminated buildings changed? Has the volume of contaminated piping, duct work, or other equipment changed significantly?

Response: The answer to both questions is no.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Item Paragraph

1.

Document Rewrite

2.

3.

4.

5.

6.

7.

8.

9.

10.

EHS&L Document Decommissioning Funding Plan Nature of Changes Description Editorial/technical revisions and updates E06-04-007 Version 8.0 Page i Justification Triennial update List Below any Documents, including Forms & Operator Aids which must be issued concurrently with this document revision:

Pages 55-66 are place holders until financial documents are signed and received. (THIS WILL BE REMOVED PRIOR TO PROMOTION.)

This Document contains a total of 73 pages excluding the signature page.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page ii DOCUMENT REVIEW/APPROVAUDELETION CHECKLIST All new and/or revised procedures shall be approved by the change author, cognizant manager(s) of areas affected by the changes, and by applicable manager(s) of any function that approved the previous revision of the document unless responsibility for such approval has been transferred to another organization. Also, the procedure shall be approved by manager(s) of functional organizations that provide technical reviews with the exception of the Training Department. Finally, Document Control shall verify that the required approvals have been properly obtained and that any documents that must be issued concurrently are ready to be issued.

Document Reviews Document Approvals Specify Reviewer(s)

(Check (Check Purpose/Function of Review (Optional except for all that Title of Approver all that change author) apply)

Apply)

Document Control (Automatic) 181 Document Control (Automatic) 181 Chanoe Author CD Manninq 181 Author 181 Independent Technical Review LKim 181 Operability Review(s)

Mqr, Richland Operations(1l D

Conversion D

Mgr, Uranium Conversion &

D Recoverv D

Recovery Operations<1l Ceramics D

Mor, Ceramic Operations<1l D

Rods D

Mgr, Rods & Bundles<1l D

Bundles D

Components D

Mgr, Component Fabrication111 D

Maintenance Review D

Mor, Maintenance<1>

181 Lab Review D

Mqr, Production Suooort<1l D

Transportation D

Mgr, Ops Strategy & Supply Chain D

EHS&L Review(s)

Mqr, EHS&L1L1 181 Criticalitv D

Mgr, Nuclear Safety(2)

D Radiation Protection YR Sakach 181 Safetv D

Mor, Safety1~1 D

Securitv/Emeroencv Prep.

D Mgr, Security & Emergency D

Fire Safety D

Preparedness(2l MC&A D

Transportation D

Mgr, Licensing & Compliance<2l D

Environmental JB Perryman 181 Mechanics Richland Review D

Mgr, Mechanics Richland D

Mechanics Lynchburg Review D

Thermal-Hydraulics Richland Review D

Mor, Thermal-Hydraulics Richland D

Thermal-Mechanics Richland Review D

Mor, Materials & Therm-Mechs D

Project & Reliabilitv Review D

Mor, Project & Reliability Enq.

D Qualitv Review D

Mor, Richland Site Quality D

Purchasino Review D

Mgr, PP&CPC D

Others:

D Mgr, Richland Site/Other 181 Document Control D

Richland Records Management D

Trainino & Employee Dev. : <3l D

Training & Employee Dev.

D

<1lNote:

<2lNote:

<3lNote:

If approvals include 2 or more product center managers, the Operations manager can be substituted for the applicable product center managers.

If approvals include 2 or more EHS&L functional managers, the EHS&L manager can be substituted for the applicable EHS&L functional managers.

Training department review is required for all procedures that require or affect a Learning Plan and if additional training materials or curriculum must be revised before issuing procedure.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan EHS&L CHANGE IMPACT EVALUATION FORM EOG-04-007 Version 8.0 Page iii 23371 (Rev. 001, 01 /09/2018)

The scope and content of this document have been determined by EHS&L to not impact the safety disciplines checked below. Future revisions do not require review by those EHS&L component(s) unless the scope changes such that a previously excluded safety discipline may be impacted.

D Criticality 0 Radiation Protection D Safety/Security D Emergency Preparedness 0MC&A D Transportation D Environmental DOCUMENT VERSION:

EHS&L REVIEW COMPONENT:

EVALUATION DATE:

CHANGE EVALUATOR*:

2" 0 PARTY APPROVAL*:

The scope and content of this document have been determined by EHS&L to not directly impact the safe D

handling of licensed materials (enriched uranium). Future revisions to this document do not require the 1 OCFR 70. 72 change evaluation unless the scope of the document changes such that it directly impacts the handlinQ of licensed materials.

DOCUMENT/ ECN No**:

I EVALUATION DATE:

I CHANGE EVALUATOR:

EOS-04-007 5/30/18 CD Manning Does the change potentially impact Criticality Alarm System (CAS) coverage?

DYES [8J No EVALUATION OF NRC PRE-APPROVAL:

IS NRC PRE-APPROVAL ( LICENSE AMENDMENT) NEEDED?

DYES [8J No

~ Based on "YES" answer to any of five questions below.

);a, Based on "NO" answer to all five questions below.

1.

Does the change create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 (create high or intermediate DYES [8J No consequence events) and that have not previously been described in Framatome's ISA Summary?

2.

Does the change use new processes, technologies, or control systems for which Framatome has DYES [8J No no orior exoerience?

3.

Does the change remove, without at least an equivalent replacement of the safety function an DYES [8J No item relied on for safety (IROFS) that is listed in the ISA Summarv?

4.

Does the change alter any item relied on for safety, listed in the ISA Summary, that is the sole DYES [8J No item oreventinq or mitigating an accident sequence of hiqh or intermediate consequences?

5.

Does the change qualify as a change specifically prohibited by NRC regulation, order or license D

Y ES [8J No condition?

Evaluation of Actions Required PRIOR TO OR CONCURRENT with Change Implementation:

6.

Modification I Addition to CAS system or system coverage documentation YES

)<

No

7.

Acquire NRC ore-approval (LICENSE AMENDMEND YES

~ No

8.

Conduct/modify ISA YES No

9.

Modify/

181 None D ISA Database 0

NCSA 0

NCSP 0

RHA D

update the ChHA followino:

D Other D Red-Line Drawings/P&ID 0 NCSS 0 PHA 0

FHA D Procedures Evaluation of Actions Required SUBSEQUENT TO Change Implementation:

10. Modify/

181 D ISA Database update the None D NCSA D NCSP D RHA D ChHA following:

D Other 0

AS-Built Drawings/P&ID D NCSS D PHA D FHA D Procedures Justification Section for "YES" preceding Questions 1 - 8 or other for 9, 1 O:

(*)

Only required if one or more of the boxes to exclude a particular safety discipline review is checked.

(**)

If this form exists as a part of a document, the document number is not required.

I I

I

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table of Contents E06-04-007 Version 8.0 Page iv 1.0 Introduction and Summary............................................................................................... 1 2.0 Decommissioning Criteria................................................................................................ 5 2.1 Uncontaminated Facilities.................................................................................... 5 2.2 Residual Radiation Levels.................................................................................... 5 2.3 Records............................................................................................................... 5 2.4 Financial Provisions............................................................................................. 5 3.0 Key Assumptions............................................................................................................. 5 4.0 Facility Description Summary.......................................................................................... 7 4.1 NRC License........................................................................................................ 7 4.2 Authorized Radioactive Materials......................................................................... 7 4.3 Usage of Licensed Materials................................................................................ 8 4.4 Description of Facilities Utilizing Special Nuclear Material.................................... 8 4.5 Pre-Shipment/Disposal Waste Accumulations..................................................... 9 5.0 Closure Procedures and Cost Estimates....................................................................... 10 5.1 Production and Production Support Facilities..................................................... 10 5.1.1 Dry Conversion Facility........................................................................ 10 5.1.2 U02 Building........................................................................................ 11 5.1.3 Specialty Fuels Building....................................................................... 12 5.1.4 Production Support (Ancillary) Facilities............................................... 12 5.2 Containerized Waste Storage Pads and Inventories.......................................... 28 5.2. 1 Container Storage Pad Structures........................................................ 28 5.2.2 Containerized LLRW Inventory............................................................ 37 5.2.3 Containerized Mixed Waste lnventory.................................................. 37 5.3 Environmental Remediation............................................................................... 39 5.3.1 Legacy Surface lmpoundment System................................................. 39 5.3.2 Historic Spills and Releases (Documented).........................................40 5.3.3 Potential Soil Contamination Areas......................................................40 6.0 Adjustment of Cost Estimates and Funding Level.......................................................... 53 7.0 Certification of Financial Assurance............................................................................... 54 8.0 Financial Assurance lnstruments................................................................................... 55

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan List of Tables E06-04-007 Version 8.0 Page v Table 1 Decommissioning Cost Estimate Summary...................................................................4 Table 2 Total Dimensions of Facility Components - Production and Production Support Facilities........................................................................................................... 15 Table 3 Planning and Preparation - Production and Production Support Facilities (Work Days).................................................................................................................. 16 Table 4 Decontamination or Dismantling of Radioactive Facility Components -

Production and Production Support Facilities (Work Days)............................................ 17 Table 5 Final Radiation Survey - Production and Production Support Facilities (Work Days).................................................................................................................. 20 Table 6 Total Work Days by Labor Category - Production and Production Support Facilities........................................................................................................... 21 Table 7 Worker Unit Cost Schedule......................................................................................... 22 Table 8 Total Labor Costs by Major Decommissioning Task - Production and Production Support Facilities......................................................................................... 23 Table 9 Shipping and Disposal of Radioactive Wastes - Production and Production Support Facilities (Excluding Labor Costs).................................................. 24 Table 10 Equipment/Supply Costs - Production and Production Support Facilities................... 25 Table 11 Laboratory Costs - Production and Production Support Facilities.............................. 25 Table 12 Miscellaneous Costs - Production and Production Support Facilities......................... 26 Table 13 Total Decommissioning Costs - Production and Production Support Facilities........................................................................................................................ 27 Table 14 Number and Dimensions of Facility Components - Storage Areas............................ 30 Table 15 Planning and Preparation - Storage Areas (Work Days)............................................ 31 Table 16 Decontamination or Dismantling of Radioactive Facility Components -

Storage Areas (Work Days)........................................................................................... 32 Table 17 Restoration of Contaminated Areas on Facility Grounds - Storage Areas (Work Days)........................................................................................................ 32 Table 18 Final Radiation Survey - Storage Areas (Work Days)................................................ 32 Table 19 Total Work Days by Labor Category-Storage Areas................................................ 33 Table 20 Total Labor Costs by Major Decommissioning Task-Storage Areas........................ 34 Table 21 Packaging, Shipping, and Disposal of Radioactive Wastes - Storage Areas (Excluding Labor Costs)...................................................................................... 34 Table 22 Equipment/Supply Costs - Storage Areas (Excluding Containers)............................. 35 Table 23 Laboratory Costs - Storage Areas............................................................................. 35 Table 24 Miscellaneous Costs - Storage Areas........................................................................ 35 Table 25 Total Decommissioning Costs - Storage Areas......................................................... 36 Table 26 Containerized Waste Inventory Costs........................................................................ 38

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 27 Residual Labor Requirements for Final Release of Former Surface E06-04-007 Version 8.0 Page vi lmpoundment Area (Work Days)...................................................................................42 Table 28 Total Labor Costs for Final Release of Former Surface lmpoundment Area.............................................................................................................................. 42 Table 29 Laboratory and Miscellaneous Costs - Final Release of Former Surface lmpoundment Area........................................................................................................ 43 Table 30 Total Decommissioning Costs - Final Release of Former Surface lmpoundment Area........................................................................................................ 43 Table 31 Labor Requirements - Historic Spills/Releases (Work Days).................................... 43 Table 32 Total Labor Costs for Historic Spills/Releases........................................................... 44 Table 33 Laboratory and Miscellaneous Costs - Historic Spills/Releases................................ 44 Table 34 Total Costs - Environmental Remediation for Historic Spiils/Releases.......................44 Table 35 DimensionalNolume Assumptions for Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping..................................................45 Table 36 Planning and Preparation - Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.............................................................................. 46 Table 37 Environmental Investigation/Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.............................................................................. 47 Table 38 Total Work Days by Labor Category-Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping....................................................................................................... 48 Table 39 Total Labor Costs by Major Decommissioning Task - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.............................................................................. 49 Table 40 Packaging, Shipping and Disposal of Radioactive Wastes - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping.................................................................... 50 Table 41 Laboratory and Miscellaneous Costs - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping....................................................................................................... 51 Table 42 Total Decommissioning Costs - Potential Soil Contamination Areas -

Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping....................................................................................................... 52

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan List of Exhibits E06-04-007 Version 8.0 Page vii Exhibit 1 - Irrevocable Standby Letter of Credit......................................................................... 52 Exhibit 2 - Standby Trust Agreement......................................................................................... 56

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 1.0 Introduction and Summary E06-04-007 Version 8.0 Page 1 This Decommissioning Funding Plan (DFP) is submitted by Framatome Inc. (Framatome) in compliance with 10 CFR 70.25(c) (2) and contains the information required by 1 O CFR 70.25(e).

Furthermore it provides the required [10 CFR 70.25(e)] triennial adjustment of the decommissioning cost estimate, last conveyed to the NRC via Version 6.0 of this plan (January 2015). The DFP was developed using the guidance provided in NUREG-1757, Volume 3, Rev.

1, "Consolidated Decommissioning Guidance".

The DFP establishes decommissioning criteria and key assumptions and outlines the major technical approaches in the decommissioning of all facilities on the Framatome Richland site with a potential for radioactive contamination. This includes the major production facilities, production support facilities, containerized waste storage areas, and contaminated environmental media (soil). Certain portions of the containerized waste storage areas manage wastes that are classified as mixed wastes, i.e., wastes that are radiologically contaminated and also contain chemical constituents that cause them to be designated as dangerous wastes under the State of Washington Dangerous Waste Regulations. The decommissioning/closure procedures and provision of financial assurance for these mixed waste areas are, therefore, intended to meet the pertinent requirements of both the NRC and the Washington State Department of Ecology (Ecology).

The DFP also provides associated decommissioning/closure cost estimates, a commitment for periodic (minimum triennial) cost estimate adjustments, and appropriate evidence of financial assurance via a Financial Assurance Instruments section. The total consolidated decommissioning/closure cost estimate addresses all required costs relative to NRC licensed materials for both the NRC and Ecology and is summarized in Table 1. The Table 1 costs are effective as of December 2017.

The major components of the cost estimate are described in Sections 5.1, Production and Production Support Facilities; 5.2, Containerized Waste Storage Pads, and 5.3, Environmental Remediation. Section 5.1 is further broken down into the major production facilities and production support (ancillary) facilities. Decommissioning the waste storage pads involves decommissioning the pad structures and disposing of the containerized mixed and low level radioactive wastes stored on the pads. Environmental remediation will entail any activities and associated costs to address any environmental contamination that will require remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402.

Each of the major cost estimate components is presented via a set of tables, as similar as practicable to those in NUREG-1757, which support the estimates. In some cases, e.g.,

dispositioning of the containerized waste inventories, the NUREG-1757 tables are not easily applied; in those cases alternate or modified tables better suited to communicate the pertinent cost data have been used.

Some key items to note since the 2015 DFP update are:

There have not been any changes in the authorized possession limit.

No spills that will impact decommissioning costs have occurred. The few very minor unplanned contamination events since the last update have been cleaned up to release limits and any contaminated soil or asphalt was packaged into waste drums and is accounted for in section 5.3.2.

The volume of contaminated piping, duct work and other equipment has not changed significantly since 2015. The foot print of contaminated buildings has not changed.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan No onsite disposal has occurred.

No use of settling ponds has occurred since the last update.

No actual remediation costs have occurred since the last update.

E06-04-007 Version 8.0 Page 2 The total estimated cost of decommissioning has increased by $3,845,604 to

$66,435,800.

The inventory of USEC cylinders stored on site has decreased from 330 in November of 2015 to 179 in March of 2018.

The cost of disposal of low-level radiological waste processed through the Framatome incinerator has been reduced from $276/ft3 to $269/ft3. This decrease is largely due to decreased costs in operating the incinerator.

The $434,558 line item in Table 26 was removed because Framatome developed a unique process to separate most of the uranium from this waste and has completed processing this waste and has disposed of it at a commercial disposal site.

There has been little change in the inventory of waste volume since 2015 as shown in the following figure.

CY 201 s Radloactlvo Solid w aste Inventory (CuFt) 80,000 70.000 U----,,,;----------------------i a TUBL DVR

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The estimated disposal costs are primarily due to increased disposal and labor costs.

The waste volume estimates for decommissioning is unchanged. Disposal costs estimates have changed as follows:

Waste Category LRW-lncinerate in SWUR LLRW Direct dis osal MW-Disposal at contracted mixed waste Disposal Rates,

$/ft -2015 275.71 325.00 Disposal Rates, $/ft3-2017 268.53 370.11 Comments

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 3 I disposal site I

I I

No incremental disposal costs above the money already allocated to US Ecology (see Table 9b).

Most key labor costs have changed. The rates used follow (note that in most cases where we found a lower labor rate in 2017, we retained the 2015 rates):

Labor Category Labor Rates, $/hr-Labor Rates, Comments 2015

$/hr -2017 Project Manager 119.32 67.96 Retained 2015 rate Senior Engineer 99.84 102.40 Engineer 69.78 76.80 Health & Safety Tech 42.00 48.00 (HST)

HST Supervisor 42.00 63.00 HST Supervisor was not included in 2015 estimate.

One HST is now assumed to be a supervisor.

Crafts (D&D) 90.10 93.41 Equipment Operator 57.91 57.66 Retained 2015 rate Laborer 49.51 53.09 Clerical 36.08 38.30 Health Physicist 97.28 111.18 Technician-Plant 50.00 53.15 Operations Support A certification that Framatome has obtained financial assurance in an amount sufficient to meet the decommissioning cost estimate is provided in Section 7.0. Evidence of that financial assurance utilizing the letter of credit/standby trust method is provided in Section 8.0.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page4 Table 1 Decommissioning Cost Estimate Summary CateQorv Cost Estimate, $

1. Production and Production Support Facilities (Table 13) 48,033,688

2. Containerized Waste Storage Pads and Inventories A.

Storage Area (Pad) Structures (Table 25) 69,757 B.

LLRW Inventory Disposal (Table 26) 2,924,292 C.

Mixed Waste Inventory Disposal (Table 26) 592,176

3. Environmental Remediation A.

Legacy Surface lmpoundment Area (Table 30) 265,885 B.

Historic Spills/Releases (Table 34) 14,110 C.

Potential Soil Contamination Areas (Table 42) 1,240,732 Subtotal 53,140,640 25% ContinQencv 13,285,160 TOTAL 66,425,800

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 2.0 Decommissioning Criteria E06-04-007 Version 8.0 Page 5 This DFP and associated decommissioning cost estimate for Framatome's Richland Facility, located at 2101 Horn Rapids Road, Richland, Washington (License SNM-1227, Docket 70-1257) have been prepared per the requirements of 10 CFR 70.25 and guidance provided in NUREG-1757, "Consolidated NMSS Decommissioning Guidance, Volume 3", Rev. 1, February 2012.

2.1 Uncontaminated Facilities The disposition of uncontaminated equipment and facilities is not within the scope of this plan, provided that such facilities are verified to be uncontaminated in accordance with approved radiation survey procedures.

2.2 Residual Radiation Levels In accordance with 10 CFR 20.1402, the residual radioactive contamination distinguishable from background radiation for the decontaminated Richland facility shall result in dose levels of less than 25 mrem/yr to the average member of the critical group. Any equipment or facility which cannot be decontaminated to acceptable levels will be demolished, packaged, and disposed of at a licensed low-level radioactive waste (LLRW) or mixed waste disposal site, or alternatively, could be transferred to another licensed facility. Residual environmental contamination will be remediated to levels consistent with the 25 mrem/yr unrestricted use criterion.

2.3 Records Records of the decommissioning procedures and results will be preserved for at least five years, or as required by then-current regulations.

2.4 Financial Provisions Decommissioning of the Framatome Richland facility will be conducted at no cost to the public.

Framatome's provisions for funding of the decommissioning activities are provided in Section 7.0 of this plan.

3.0 Key Assumptions The following key assumptions were used in the preparation of the DFP and cost estimate for the decommissioning of the licensed facilities at Framatome's Richland Facility.

1. This DFP assumes the availability of LLRW and mixed waste disposal facilities at reasonable cost and the application of packaging and transportation requirements consistent with existing regulations.

2. Prior to the start of final site decommissioning, a detailed decommissioning plan consistent with NRC guidance, including a proposed closeout survey plan, will be submitted to the NRC for approval. The results of the closeout survey shall be approved by the NRC prior to release of equipment or grounds to unrestricted use.

3. All work will be performed in compliance with procedures written specifically for the decommissioning activity in conjunction with the detailed decommissioning plan.

4. All work inside contaminated areas will be performed using approved radiation work procedures.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan EOG-04-007 Version 8.0 Page 6

5. The typical costs associated with decontamination of process equipment and ventilation ductwork for free release are expected to be greater than their salvage value, as well as in excess of the cost savings realized by disposal at a non-radioactive waste disposal site. In general, therefore, no attempt at decontamination for this purpose will be made except in special cases when it may be warranted. Contaminated process equipment and ductwork along with other decommissioning-related wastes will typically be disposed of by burial in LLRW disposal sites, and only the facility will be decontaminated.

6. The facilities themselves, i.e., the buildings housing activities utilizing licensed materials, will be decontaminated via a combination of physical processes (steamcleaning, sandblasting, scarification, etc.) such that their demolition will not be required to meet the 25 mrem unrestricted use criteria.

7. All LLRW generated in the decontamination and/or dismantling of site facilities will be containerized and staged to allow shipment to the U.S. Ecology-operated Northwest Compact LLRW Disposal Site over a two calendar year period. The site operator is limited to a maximum allowable total revenue collection from all facility users over a one year period; this limit is currently at $6.230M as set by the Washington Utilities and Transportation Commission. The disposal cost estimate [(see Table 9b)] conservatively assumes application of the entire disposal site fee for the two year period to Framatome.

8. The cost estimate does not take credit for any salvage value that may be realized from the sale of potential assets (e.g., recovered materials or decontaminated equipment) during or after decommissioning.

9. The cost estimate does not take credit for reduced taxes that might result from payment of decommissioning costs or site control and maintenance costs.

10. The site's stored inventory of uranium hexafluoride (UF6) in Model 30-8 cylinders falls into three categories, (1) a relatively small number of cylinders owned by Framatome as working stock, (2) cylinders of UFs owned by Framatome's utility customers and staged for utilization in manufacturing customer reactor reload fuel, and (3) UF6 cylinders stored on a temporary basis in behalf of the United States Enrichment Corporation (USEC). Richland's primary plan assumes that the entire UF6 inventory will be dispositioned prior to the initiation of the decommissioning process, i.e. either processed into and delivered as product to Framatome's customers or transferred offsite to locations consistent with the ownership of the UFs. As such, assuming routine facility conditions leading into the decommissioning stage, the site's UFs inventory will not constitute a decommissioning liability. UF6-related assumptions considering an unanticipated non-routine shutdown scenario are as follows:

o Framatome-owned working stock. This relatively small number of cylinders (typically

~15) will be dispositioned offsite to a European Framatome-affiliate fuel fabricator under an existing long-term NRC export license. If necessary, the costs of this inventory transfer will be borne by the Framatome recipient as an Framatome action to retain full usage of this Framatome-owned asset.

o Framatome customer-owned UFs. Under the unlikely scenario of Framatome inability to pay for transfer costs, the primary assumption is that customers will reclaim their UF6 at their expense as a practical action to retain control and usage of their valuable business asset. However Framatome's business interruption plan and associated property insurance will provide financial coverage for inventory removal/transfer activities if such activities are necessitated by covered events (fire, lightning, aircraft, explosions, earthquake, windstorm, theft, equipment failure, terrorism, etc.)

o Consistent with contract language, in the event of a unilateral Framatome decision to terminate storage of cylinders stored in behalf of USEC, the cylinders will be transferred

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 7 to an alternate location of USEC's choice at Framatome expense. Based on a conservative assumption that the entire transfer cannot be accomplished promptly in the case of a sudden shutdown scenario, these costs are assumed to be covered from decommissioning reserves. In recognition that the stored USEC-related inventory is an extraordinary one-time occurrence related to the shutdown of that facility, the cost estimate uses a cylinder inventory total equal to 50% of the peak inventory (currently being approached as of June 2016). Costs based on currently contracted carrier and labor rates are reflected in Table 12. Miscellaneous Costs, of this DFP.

11. Non-UFs inventory of licensed material, i.e. powder pellets, fuel rods, and fuel assemblies, are anticipated to be dispositioned to customers and/or Framatome affiliates prior to initiation of the decommissioning process. In the unlikely event of a sudden plant closure, it is assumed that the material can be rapidly dispositioned within a 30-60 day timeframe.

12. For the sake of this DFP and associated cost estimate, the limit for free release of materials, e.g., soil, in which the radioactive contamination is distributed throughout the material matrix, is assumed to be 30 pCi/gram.

13. The DFP assumes that the site and associated facilities will be decommissioned via decontamination activities and materials removal/disposal in a manner that will not necessitate stabilization and long-term surveillance programs.

14. Increases in plant processing throughput, associated and not associated with increases in site possession limits, are not assumed to increase plant decommissioning liability unless they result in increases in contaminated facilities, equipment, or environmental media.

Concurrent increases in generation of operational wastes also are not assumed to necessarily increase decommissioning liability in that estimate waste disposal costs are based on maximum expected waste accumulation (see Sections 5.2.2, 5.2.3, and Table 26).

Maximum expected waste accumulations are based on plant history and are updated as aQpropriate.

4.0 Facility Description Summary This section provides a facility description as called for in the Facility Description section of Volume 3, Rev. 1, of NUREG-1757. The information supplements the facility description on record (Docket 70-1257) as part of Framatome's NRC special nuclear materials license (SNM-1227) for the Richland site.

4.1 NRG License The Framatome Richland nuclear fuel fabrication facility is operated in accordance with an NRC special materials license issued under 10 CFR Part 70. The license, SNM-1227, is docketed under NRC Docket No. 70-1257 for the Richland site.

4.2 Authorized Radioactive Materials NRC License SNM-1227 authorizes Framatome to possess U-235 present in uranium enriched up to 5 wt. % U-235; and a small amount of U-235 may be possessed in uranium U-235 enrichments exceeding 5 wt. %. In addition to this NRC license, Framatome has a Radioactive Materials license with the State of Washington, WN-1062-1. The disposal costs associated with the material authorized in this license, other than the sealed sources, is included in this Decommissioning Funding Plan.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 4.3 Usage of Licensed Materials E06-04-007 Version 8.0 Page 8 The Framatome Richland nuclear fuel fabrication facility utilizes enriched uranium (:,:;5 wt. % U-235) for the production of enriched uranium nuclear fuel for use in commercial light water reactors, both domestically and internationally. Finished fuel assemblies (bundles) are supplied to nuclear utilities for direct usage as fuel in their nuclear power reactors; however intermediate products such as enriched uranium powder or pellets are also produced on behalf of other nuclear fuel cycle facilities.

The typical feed material to the plant is uranium hexafluoride (UF6) received in 30-inch diameter steel cylinders, each containing approximately 1500 kilograms of enriched uranium. Some feed material is Urania or UN solutions received in licensed shipping packages which are unloaded and eventually processed through the appropriate process stream(s). The UF6* UN, and Urania are chemically converted to ceramic grade uranium dioxide (U02) powder. The resultant powders pressed into fuel pellets, which are then sintered and subsequently loaded into fuel rods. These loaded fuel rods, in conjunction with other supporting hardware (tie plates and grid spacers), are assembled into a variety of fuel bundle designs, depending on customer-specific requirements. The fuel products - powder, pellets, or fuel bundles (assemblies) - are loaded for shipment into specially designed shipping containers licensed by the NRC and/or the U.S.

Department of Transportation.

4.4 Description of Facilities Utilizing Special Nuclear Material The Framatome Richland nuclear fuel fabrication plant is located at 2101 Horn Rapids Road just within the northern limits of the City of Richland in Benton County, Washington. More specifically, the facility is located in the approximate center of the more easterly of two adjacent quarter sections (160 acres each) of land owned by Framatome. All facilities storing or processing special nuclear material are located within an approximately 53 acre fenced, secured area; the remainder of the surrounding Framatome property is either devoted to vehicle parking areas, is undeveloped, or is leased for agricultural usage.

The primary production activities involving special nuclear material and state licensed material are conducted in three major facilities - the Dry Conversion Facility; the Uranium Dioxide (U02)

Building, which includes the Blended Low-Enriched Uranium (BLEU) addition; and the Specialty Fuels (SF) Building. The specific functions of these facilities, the general approach to their decommissioning, and the associated decommissioning cost tables are provided in Section 5.1, Production and Production Support Facilities, of this DFP.

The primary production facilities are supported by a number of ancillary support facilities that also entail the storage or handling of SNM or SNM-containing materials. These facilities are most typically involved with materials storage (feed materials, product intermediates, or finished product) or waste processing functions but also provide a number of other miscellaneous production support functions, e.g., purification of contaminated fuel scrap, laundering of contaminated clothing, and recertification of UF6 shipping cylinders. A listing of these facilities and their functions, the general assumptions/approach pertinent to their decommissioning, and the associated decommissioning cost tables are also provided in Section 5.1 of this DFP.

The major containerized solid waste storage pads consist of two asphalted areas managing currently generated and legacy containerized (barreled or boxed) wastes. These facilities are distinguished by their large spatial size and the fact that they may manage mixed wastes, i.e.,

wastes that are both radiologically contaminated and chemically hazardous. These facilities are therefore simultaneously subject to the decommissioning requirements of the NRC and, for those portions managing chemically hazardous wastes, the closure requirements of the

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 9 Washington State Department of Ecology. The inventory disposition and closure approach pertinent to the containerized waste pads are addressed in Section 5.2 of this DFP.

In addition to the facilities themselves as discussed above, operation of the site offers the potential for contamination of the land (soil) below and/or around those facilities. That contamination may have resulted from releases from the facilities or from releases/spills associated with the transfer of licensed materials between facilities, e.g., piping leaks, container spills, etc.

The most significant area of known soil contamination on the Framatome Richland site was the area associated with operation of the legacy surface impoundment system. Known liquid releases from at least three of the six impoundments in the 1970s - early 1980s resulted in contamination of the soils underlying these units with uranium as well as certain chemicals (fluorides, nitrates, ammonia). The surface impoundment system has been removed and associated radiological and non-radiological soil contamination remediated to meet Washington Department of Ecology (Ecology) soil cleanup levels for uranium and regulated chemical constituents. Additional soil remediation to meet NRG radiological decommissioning criteria is not anticipated to be necessary.

Less significant instances of soil contamination with licensed materials have occurred from documented spills/releases over the course of the plant's operating history. These contamination incidents have typically been small and remediated at the time of occurrence but in some cases the potential for residual contamination (detected or undetected) remains. These areas are documented in decommissioning records maintained by Framatome in accordance with 10 CFR 70.25(g).

Also addressed are two potential soil contamination areas that have not been characterized but that may, based on operating history, impose soil contamination levels requiring remediation.

The two areas are the soil underlying current and historic wet chemical processing areas within the U02 Building and soil underlying current and historic underground piping carrying uranium-bearing solutions.

Decommissioning obligations and associated costs relative to environmental remediation are discussed in Section 5.3. These include residual decommissioning-related final survey costs associated with the remediated surface impoundment area, potential characterization/

remediation costs associated with certain spills/releases documented in required decommissioning records, and estimated characterization/remediation costs postulated for the two uncharacterized potential soil contamination areas discussed above.

4.5 Pre-Shipment/Disposal Waste Accumulations With the elimination of the site's historic surface impoundment system, current liquid waste processing is very closely coupled to production, using relatively small volume tanks.

Temporary accumulation of liquid SNM-containing wastes from production activities is very limited with respect to time and volume and an insignificant contributor to the overall plant decommissioning liability.

Current inventories of containerized solid wastes (low-level radioactive and mixed) and their associated disposition costs are provided in Table 26. Based on the site's continued progress in working down its legacy backlog of stored wastes, current inventories are no longer necessarily higher than possible maximum foreseeable inventories in the future. Therefore in addition to current inventories, Table 26 provides estimates of maximum anticipated volumes in each solid waste category. These higher inventory volumes have been conservatively utilized to estimate disposal cost liabilities.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 10 Accumulated volumes of low-level radioactive waste (LLRW) generated by the actual decommissioning activities will be dispositioned to LLRW disposal and/or recycle facilities.

These waste volumes are presented in Table 9. Disposal volumes related to postulated environmental remediation activities are included in Table 40. As noted in Section 3.0, Key Assumptions, No. 7, the waste volumes set forth in Tables 9 and 40 will be containerized and staged over the course of the decommissioning/remediation activities and then all shipped to the LLRW disposal site over a two year period.

5.0 Closure Procedures and Cost Estimates This section outlines the major technical approaches involved in the decontamination and decommissioning of each major facility with a significant potential for radiological contamination.

In the case of the containerized waste storage areas, the DFP also extends to the onsite waste inventory associated with these units. Minor ancillary facilities such as external docks, grounds, and warehouses, where contamination is not anticipated but may be found, will be decontaminated in a similar fashion as the known-contaminated facilities described herein.

Certain portions of the containerized waste storage areas may manage mixed wastes, i.e.,

wastes that are radiologically contaminated and also contain chemical constituents that cause them to be designated as dangerous wastes under the State of Washington Dangerous Waste Regulations. These wastes are dually regulated by the NRC and Ecology and the units are subject to the decommissioning requirements of the NRC (10 CFR 70.25) and the closure requirements of Ecology (WAC 173-303-610 and 650). Detailed decommissioning procedures written pursuant to this DFP and closure plans/procedures developed pursuant to Ecology's regulations will jointly address the requirements of both regulatory agencies with respect to the mixed waste areas.

Environmental remediation costs apart from costs associated with the decommissioning of site structures are not anticipated to be significant by comparison. Environmental remediation-related approaches and costs are discussed in Section 5.3.

5.1 Production and Production Support Facilities The production activities at the Framatome Richland facility encompass the full scale of nuclear fuel fabrication, i.e., chemical conversion of UF6 to U02 powder, U02 pellet production, rod loading, and fuel bundle assembly. These activities occur in three major production facilities, namely the Dry Conversion Facility; the U02 Building, including the Blended Low Enriched Uranium (BLEU) addition; and the Specialty Fuels Building. The major production activities are supported by a number of production support, or ancillary, facilities. The general approach to decommissioning these facilities, along with the associated costs, is described below. The associated cost estimates are shown in Tables 2 through 13.

5.1.1 Dry Conversion Facility The Dry Conversion Facility (DCF) houses the head-end processes for the Richland plant's nuclear fuel fabrication activities, namely the vaporization of UF6 out of Model 30-B cylinders using electrically-heated autoclaves, the conversion of the UF6 vapor to dry U02 powder in fluidized bed reactors, final defluoridation of the powder in calciners, and the physical preparation (milling, compacting, etc.) of the powder for subsequent pellet pressing. Major aspects of the decommissioning of the DCF are as follows:

1. All process equipment in the various contaminated areas of the building will be surveyed to determine the degree of contamination. Equipment with contamination which is below acceptable release levels can be disposed of on a commercial basis at non-radiological

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 11 disposal facilities. Equipment which is contaminated to levels above such release levels will be decontaminated if warranted, and packaged for shipment. Such equipment contaminated above free release levels will be shipped to an appropriate low-level radioactive waste disposal site or alternatively, could be transferred to another licensed facility.

Liquid effluent systems exiting radiation zones will be treated in the same manner as process equipment in the contaminated areas.

Sufficient radiation surveys of process equipment outside the contaminated areas will be made to assure that unacceptable levels of contamination have not spread outside the contaminated operating areas. Non-contaminated process equipment outside the contaminated areas can be disposed of on a commercial basis at non-radiological disposal facilities or can be left in place to support the mission of associated decontaminated facilities.

2. All contaminated exhaust ductwork will be treated in a manner similar to the contaminated process equipment as described in item 1 above. The final filter bank of the ventilation system will also be disposed of by burial.

3. After removal of all process equipment, ancillary equipment, and exhaust ducting, the facility ceiling and walls will be cleaned as necessary. The cost estimate for this work is based on sandblasting. The typical wall materials (painted concrete and painted cement block) and ceiling materials (metal panels) are amenable to coating removal and decontamination via sandblasting. Porous, non-durable wall coverings such as gypsum wallboard are uncommon and are present in noteworthy quantities only within two production facilities (U02 and Specialty Fuels Buildings) and a single production support facility (ELO Building).

The total packed disposal volume for the potentially radioactively contaminated portion of this material is relatively small (~2.500 ft3) and is included in the packed disposal volumes provided in Table 2.

4. The floors of the controlled areas will be stripped of all protective coatings and appropriately cleaned. Solvents, if used, will be selected such that they will not cause materials to be designated as dangerous wastes under the State of Washington Dangerous Waste Regulations. The cost estimates for floor decontamination assume the utilization of mechanical scarification. Due to the fact that the floors are in most cases coated with some type of sealant, less aggressive surface decontamination techniques may suffice for large areas of the facility, making scarification a conservative assumption.

5. A radiation survey described in the decommissioning plan will be completed to verify that areas are successfully decontaminated.

6. After NRC approval of the radiation survey results, the entire affected area may be resurfaced as appropriate.

5.1.2 U02 Building The U02 Building houses the majority of Framatome's nuclear fuel fabrication process downstream of the Dry Conversion Facility, i.e., pellet pressing to final fuel bundle assembly.

The building also houses the Richland plant's one remaining "wet" chemical conversion (ammonium diuranate) production line, now utilized strictly for uranium scrap recovery. The activities (excluding the ADU conversion-related activities) are broadly grouped into two categories as follows:

Ceramics, including additive blending, pellet pressing, pellet sintering, pellet grinding and pellet inspection; and

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 12 Rod Fabrication/Bundle Assembly, including rod loading; rod welding, leak checking, assaying, and x-raying; rod inspection; bundle assembly; and bundle inspection, cleaning, and packaging.

These ceramics and rod fabrication/bundle assembly activities include those performed in the traditional portions of the U02 Building as well as those more recently added (2004) to accommodate processing of BLEU material.

Other miscellaneous support facilities located within the U02 Building include the U30a Facility, Powder Storage Facility, Powder Dissolution Facility, Pellet Dissolution Facility, Miscellaneous Uranium Recovery (MURS) Facility, Powder Characterization Facility, UFs cylinder wash facility,

, Quality Control Analytical/Testing Laboratories, Waste Volume Reduction Facility (VRF), and "hot" maintenance facilities.

Decontamination and decommissioning of the U02 Building will be accomplished via an approach consistent with that described for the Dry Conversion Facility with one exception. The cost estimate includes enhanced approaches to address potential floor contamination in historic and current wet chemical processing areas, including deeper floor scarification or concrete removal.

5.1.3 Specialty Fuels Building The Specialty Fuels (SF) Building houses fuel fabrication activities related to the production of fuel containing gadolinia (Gd203) as a neutron poison. The activities include the blending of U02 powder, produced in the Dry Conversion Facility or U02 Building, with purchased Gd203; powder preparation and additive blending; pellet pressing; pellet sintering; and pellet grinding. Loading of gadolinia-containing pellets into rods occurs in the U02 Building. Also located in the SF Building is the Solid Waste Uranium Recovery (SWUR) Incinerator Facility.

Decontamination and decommissioning of the SF Building will be accomplished via an approach consistent with that described for the Dry Conversion Facility and U02 Building.

5.1.4 Production Support (Ancillary) Facilities In addition to the Dry Conversion Facility and the U02 and SF Buildings, a number of other facilities are involved with enriched uranium handling and processing in varying degrees, and will, therefore, require decontamination/decommissioning efforts commensurate with those activities. The facilities, along with a brief summary of their associated enriched uranium/

radionuclide-handling activities, are as follows:

1. Engineering Laboratory Operations (ELO) Building - process development laboratories, Gadolinia Scrap Uranium Recovery (GSUR) Facility (fuel scrap dissolution and solvent extraction activities), decontamination area, and hot maintenance area.

2. Contaminated Clothing Laundry - laundering of contaminated protective clothing.

3. Fuels Storage Warehouse (Warehouse 4) - storage of packaged special nuclear material in various compounds and forms.

4. UNH Drum Storage Warehouse - storage of closed drums of uranyl nitrate liquid awaiting processing.

5. Uranium Storage Warehouse (Warehouse 6) - past storage of packaged special nuclear material in various compounds and forms; currently devoted to non-SNM processing/storage activities.

6. Operations Scrap Warehouse (Warehouse 7) - storage of closed containers of uranium-containing feed materials, product, or scrap awaiting processing.

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7. Product Development Test Facility (PDTF) - LOCA heat transfer, seismic, and coolant flow testing of nuclear fuel assemblies.

8. UF6 Receiving and Storage Facility - receipt and storage of UF6 cylinders.

9. Lagoon Uranium Recovery (LUR) Facility - past recovery of uranium from liquid process wastes; no current SNM-related activities.

10. Solids Processing Facility (SPF) - an addition to LUR containing equipment for recovery of uranium from contaminated sludges.

11. Silicon Removal Process (SRP) - equipment housed at LUR/SPF to remove silicon from low-U liquid effluents before treatment in the Ammonia Recovery Facility.

12. Modular Extraction Recovery Facility (MERF) - recovery of uranium from certain solid phase low-level radioactive and mixed wastes.

13. Wastewater Treatment Facility - includes the traditional Ammonia Recovery Facility (ARF) for the recovery of ammonium hydroxide from high-ammonia-content liquid process wastes; the filtration and ion exchange (IX) systems for removal of trace levels of uranium from the plant's final sewered effluent, including equipment to flush and regenerate these systems; and wastewater tanks for interim management of the site's contaminated liquid effluents.

14. Fuel Services Facility (Building 9) - disassembly of contaminated fuel bundles; waste handling/packaging activities; miscellaneous production-support activities.

15. Cylinder Recertification Facility (CRF) - testing and recertification of UF6 cylinders.

16. Warehouse 2 - storage/loading of packaged special nuclear material in various compounds and forms.

17. Uranyl Nitrate Building (UNB) - receipt of uranyl nitrate (UN) solution from offsite sources (download from shipping containers) and onsite sources (pipeline transfer) with subsequent storage of the UN in tanks while awaiting transfer to the U02 Building for conversion to U02.

The same basic plan as outlined above for the major production facilities will be implemented, as necessary, in the decontamination and decommissioning of these ancillary facilities.

Assumptions specific to ancillary facilities are as follows:

1. The following facilities contain contaminated equipment to be disposed of and, based on the nature of their operations, will likely require decontamination of the facility and supporting structures prior to release.

ELO (process areas)

LUR/SPF/SRP MERF Fuel Services Building (Building 9) process area WWTF (ARF process sump areas only)

Laundry

2. The following facilities contain contaminated equipment to be disposed of, but no significant contamination of the facilities themselves is anticipated because the radioactive material was well contained in equipment or in closed containers:

WWTF (exclusive of ARF process sump areas)

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Cylinder Recertification Facility Uranyl Nitrate Building E06-04-007 Version 8.0 Page 14

3. The following facilities contain neither contaminated equipment requiring disposal nor significant levels of structural contamination because they contain, or previously contained, radioactive material exclusively in closed containers.

Operations Scrap Warehouse (Warehouse 7)

UNH Drum Storage Warehouse Boron Pellet Production Facility (a.k.a. Warehouse 6, this building was formerly used for Uranium Oxide Storage in inner shipping packages, 5-gallon buckets and 45-gallon powder storage drums.)

PDTF Fuels Storage Warehouse (Warehouse 4)

UF6 Receiving and Storage Facility Warehouse 2

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 15 Table 2 Total Dimensions of Facility Components - Production and Production Support Facilities Level of Contamination: <2000 dpm/100 cm2 Production Facilities Components Total Dimensions Dry Conversion Floors 17,818ft2 Facility Walls 46,179 ft2 Ceilings 20,611 ft2 EquipmenUComponents/Wallboard 4,301 ft3 (packaqed for disposal)

U02 Building, Floors 116,269 ft2 including BLEU Walls 268,606 ft2 Ceilings 135,355 ft2 EquipmenUComponents/Wallboard 20,786 ft3 (packaqed for disposal)

Specialty Fuels Floors 13,540 ft.!

Building Walls 52,804 ft2 Ceilings 15,825 ft2 EquipmenUComponents/Wallboard 6,929 ft3 (packaqed for disposal)

Production Support Components Total Dimensions Facilities WWTF (ARF Sumps Floors 527 ft2 Only)

LUR/SPF/SRP Floors 6,165 ft2 Building

Walls 25,823 ft2 Ceilings 6,673 ft2 ELO Building Floors 8,772 ft2 (process areas)

Walls 19,743 ft2 Ceilings 8,770 ft2 MERF Floors 2,045 ft2 Walls 5,091 ft2 Ceilings 2,045 ft2 Fuel Services Floors 5,305 W Building (Building 9)

Walls 10,361 ft2 (process area)

Ceilings 5,455 ft2 Laundry Floors 299 ft£ Walls 690 ft2 Ceilings 299 ft2 All Production EquipmenUcomponents/wallboard 10,323 ft3 Support Facilities from all production support facilities (packaged for disposal)

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 16 Table 3 Planning and Preparation - Production and Production Support Facilities (Work Days)

Estimate of the number of work days, by specific labor category, that will be required to It I d

r rT comp e e p anninq an prepara 10n ac 1v1 1es.

Safety Health and Engineer Safety NRC Crafts Laborer -

Activity Engineer Work Technician Work Work Work Work Days Work Days Days Days Days Days Preparation of Documentation for 181 Regulatory Agencies Submittal of Decommissioning Plan to NRC when required 27 25 by 10 CFR 30.36(g)(1 ),

40.42(g)(1), or 70.38(Q)(1)

Development of Work 44 Plans Procurement of Special 44 EquipmenUServices Staff Training 10 20 40 40 Characterization of Radiological Condition of the Facility (including sampling, soil and 482 tailings analysis, or groundwater analysis if applicable)

TOTALS 218 88 502 25 40 40

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 17 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days)

Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.

Name of room, laboratory, or area: Dry Conversion Facility Level of Contamination: <2000 dpm/100 cm2 Health and Component Decon.

Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/

56 Mobilization EquipmenU Component 478 478 Removal Floors Scarification

$47,330 (See Table 12)

Walls/

Sandblast Estimated@ $4.16/ft2 (See Table 12) = $277,847 Ceilings Remedial Radiation 208 Surveys QNQC 25 TOTALS 25 478 534 208

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 18 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days) (cont.)

Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.

Name of room, laboratory, or area: U02 Building, including BLEU Level of Contamination: <2000 dpm/100 cm2 Health and Component Decon.

Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/

276 Mobilization Equipment/

Component 1,766 1,766 Removal Floors Scarification*

$485,090 (See Table 12)

Walls/

Sandblast**

Estimated@ $4.16/ft2 (See Table 12) = $1,680,479 CeilinQs Remedial Radiation Surveys QA/QC 129 TOTALS 129 1,766 2,042

Based on commercial rates for a scarification vendor.

- Based on commercially-available environmental meditation cost estimation manual (R.S. Means) 1,098 1,098

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 19 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days) (cont.)

Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.

Name of room, laboratory, or area: Specialty Fuels Building Level of Contamination: <2000 dpm/100 cm2 Health and Component Decon.

Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Davs Preparation/

103 Mobilization Equipment/

Component 873 873 Removal Floors Scarification*

$35,966 (See Table 12)

Walls/

Sandblast**

Estimated@ $4.16/ft2 (See Table 12) = $285,497 Ceilinqs Remedial Radiation Surveys QNQC 30 TOTALS 30 873 976

Based on commercial rates for a scarification vendor.

- Based on commercially-available environmental meditation cost estimation manual (R.S. Means) 510 510

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 20 Table 4 Decontamination or Dismantling of Radioactive Facility Components - Production and Production Support Facilities (Work Days) (cont.)

Estimate of the number of workdays, by specified labor category that will be required to complete the specified decontamination and/or dismantling activities.

Name of room, laboratory, or area: Production Support (Ancillary) Facilities Level of Contamination: <2000 dpm/100 cm2 Health and Component Decon.

Engineer Crafts Laborer Safety Method Work Days Work Days Work Days Technician Work Days Preparation/

157 Mobilization Equipment/

Component 927 927 Removal Floors Scarification*

$105,422 (See Table 12)

Walls/

Sandblast**

Estimated@ $4.16/ft2 (See Table 12) = $353,394 Ceilings Remedial Radiation Surveys QA/QC 43 TOTALS 43 927 1,084

Based on commercial rates for a scarification vendor.

- Based on commercially-available environmental meditation cost estimation manual (R.S. Means) 276 276 Table 5 Final Radiation Survey - Production and Production Support Facilities (Work Days)

Estimate of the number of work days, by specific labor category that will be required to conduct a final radiation survey.

Activity Health and Safety Technician Work Days Final Survey 628 TOTAL 628

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 6 Total Work Days by Labor Category - Production and Production Support Facilities E06-04-007 Version 8.0 Page 21 Total work days estimated for each specific labor category from the applicable tables above (i.e., from Tables 3 through 5) plus total work days associated with overall project support functions (non-task-specific).

Safety Senior Engineer Health and Clerical Crafts Laborer NRC Support Health Project Engineer Engineer Safety Physicist Activity Manager Work Work Work Technician Work Work Work Work Technician Work Days Days Days Work Days Days Days Days Days Work Days Days Planning and Preparation (TOTALS 218 88 502 40 40 25 from Table 3)

Decontamination and/or Dismantling of Radioactive Facility 227 2,092 4,044 4,636 Components (Sum of TOTALS from Table 4)

Operation of Waste Volume Reduction 4,680 Facility Final Radiation Survey 628 (TOTAL from Table 5)

Project Administration 1,040 1,040 1,040 1,040 1,040 1,040 (6 FTE)

Craft Support - Plant 2,340 Operations (3 FTE)

Technician Support -

Plant Operations (4 3,120 FTE)

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 7 Worker Unit Cost Schedule E06-04-007 Version 8.0 Page 22 Fully burdened billing rates (wages, benefits, overheads, and profits) from State of Washington-based third party contractors (with exception of NRC).

Labor Category Labor Rate, $/hr.

Labor Rate, $/day*

Project Manager 119.32 955 Senior Engineer 102.40 819 Engineer 76.80 614 Health and Safety Technician (HST) 48.00 384 Health Physicist 111.18 889 Safety Engineer 72.40 580 Crafts (D&D) 93.47 748 Crafts - Plant Operations Support 88.92 711 Equipment Operator 57.91 463 Laborer 53.09 425 Technician - Plant Operations Suooort 53.15 425 Clerical 38.30 306 NRC 279.00 2,232

Eight hour day; rounded to the nearest dollar.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 23 Table 8 Total Labor Costs by Major Decommissioning Task - Production and Production Support Facilities Estimated work days for each specific labor category (from Table 6) multiplied by the total cost per work day for the corresponding labor category (from Table 7). Costs for Craft Support - Plant Operations and Technician Support - Plant Operations based on full time equivalent staffing (FTE) as indicated and composite labor rates reflecting staffing mix.

Health Technician Project Safety Senior Engineer and Health Clerical Crafts Laborer Plant NRC Task Manager Engineer Engineer Cost,$

Safety Physicist Cost, $

(Avg.)

Cost,$

Support, Cost, Cost, $

Cost,$

Cost, $

Tech.

Cost, $

Cost$

Cost,$

Planning and 126,222 54,067 192,768 29,910 16,989 55,860 Preparation Decontaminati on or Dismantling of 139,468 803,328 3,023,941 1,970,300 Radioactive Facility Components Operation of Waste Volume 1,989,000 Reduction Facility Final Radiation 241,152 Survev Project Administration 993,200 602,160 851,760 638,560 925,018 318,656 (6 FTE)

Craft Support -

Plant 1,664,582 Operations (3 FTE)

Technician Support - Plant 1,451,424 Operations (4 FTE)

Total Labor Cost, $

475,816 5,937,037 1,989,000 241,152 4,329,3564 1,664,582 1,451,424

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 24 Table 9 Shipping and Disposal of Radioactive Wastes - Production and Production Support Facilities (Excluding Labor Costs)

Note: Labor costs for waste packaging included in Table 8 under Operation of Waste Volume Reduction Facility. Labor costs for shipping activities are included in Table 12 under Logistics/

Shipping Support.

(a) Packing Material Costs Estimate of the types and volumes of waste expected to be generated, along with the number and types of containers required for packing the waste.

Number of Type of Unit Cost of Total Waste Type Volume (ft3)

Packaging Containers Container Container, $

Costs,$

Bldg. Waste 42,338 455 93 ft3 Box 1,810*

823,550 Boron spider 1,418 16 28,960 drums (compacted)

Contaminated shipping 400 5

9,050 container (compacted) components TOTAL 44,156 476 861,560

Catalog price from commercial container supplier including shipping costs to the HRR site.

(b) Shipping and Disposition Costs Estimate of the volume of waste to be disposed and the shipping and disposal costs.

Waste Type Disposition Volume or Disposition Costs, $

Shipping Cost,$

Weight (as indicated)

Containerized Waste 44,156 ft3 12,460,000*

568,000**

for Burial 30-B Cylinders (melt, 478,800 lbs.

1,661,436 186,000**

reuse)

TOTAL 14,121,436 754,000

Assumes all wastes accumulated/staged for disposal over two calendar year period at maximum allowed waste site revenue collection of $6,230,000/yr. (see Section 3.0, Key Assumptions)

- This is for total cost, actual transport plus TN labor of about $6,500 per truck to support the shipments.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 25 Table 1 O Equipment/Supply Costs - Production and Production Support Facilities (Excluding Containers)

Estimate of the quantity of equipment and supplies required for decommissioning.

Equipment/Supplies Total Equipment/Supply Cost, $

Miscellaneous Decommissioning-Related 420,200 Tools/Eauipment/Consumable Supplies TOTAL 420,200 Table 11 Laboratory Costs - Production and Production Support Facilities Estimate of costs for analyses to be performed by an independent third-party laboratory.

Activity Total Cost, $

Lab analysis costs 180,960 TOTAL 180,960

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 26 Table 12 Miscellaneous Costs - Production and Production Support Facilities Estimate of any other applicable costs.

Cost Item Total Cost, $

State/Local Regulatory Fees 77,000/yr X 3 yr. = 231,000 Insurance 1, 144,000/yr x 3 yr. = 3,432,000 Taxes 1,994,000 NRC Inspections 90,000/yr X 3 yr. = 270,000 Sandblasting Walls/Ceilings 2,597,216*

Scarifying Floors 673,808*

Certification Survey 115,000 Logistics/Shipping Support 298,200 USEC UF6 Inventory Disposition**

778,680 Security 965, 120/yr. x 3 yr.= 2,895,360 Utilities (electricity, water, sewer) 975,000 X 3 yr. = 2,925,000 IT Support 175,581 TOTAL 16,385845 Totals from Table 4.

- See Section 3.0, Key Assumptions No. 10, $778.68K cost based ori 42 transports at

$18,540/transport. Transport costs made up of $12,360 commercial carrier charges and

$6,180 logistics/shipping documentation charges.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 27 Table 13 Total Decommissioning Costs - Production and Production Support Facilities Total of the reported costs in Tables 8, 9, 10, 11 and 12.

Task/Component Cost, $

Planning and Preparation 475,816 (TOTAL from Table 8)

Decontamination and/or Dismantling of Radioactive Facility Components 5,937,037 (TOTAL from Table 8)

Operation of Waste Volume Reduction Facility 1,989,000 (TOTAL from Table 8)

Final Radiation Survey 241,152 (TOTAL from Table 8)

Project Administration Costs 4,329,356 (TOTAL from Table 8)

Craft Support - Plant Operations Costs 1,664,582 (TOTAL from Table 8)

Technician Support - Plant Operations Costs 1,451,424 (TOTAL from Table 8)

Packing Material Costs 861,560 (TOTAL from Table 9a)

Shipping 754,000and Disposition Costs (14,121,436) 14,875,436 (TOTAL from Table 9b)

Equipment/Supply Costs 420,200 (TOT AL from Table 10)

Laboratory Costs 180,960 (TOT AL from Table 11)

Miscellaneous Costs 16,385845 (TOTAL from Table 12)

TOTAL - Production and Production Support Facilities 48,812,368

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 5.2 Containerized Waste Storage Pads and Inventories E06-04-007 Version 8.0 Page 28 Containerized (barreled or boxed) operational wastes are managed on an ongoing basis at two significant container storage areas at the Richland facility - an uncovered asphalt pad located in the central portion of the site, often referred to as the "old" or "historic" dangerous waste storage pad; and a newer, partially covered asphalt pad, located in the southeast corner of the site, and referred to as the Dangerous Waste Storage Facility (DWSF). Both pads manage containerized low-level radioactive waste (LLRW) and also manage, or have managed, LLRW that also designates as chemically dangerous per Ecology's Dangerous Waste Regulations (WAC 173-303), i.e., mixed wastes. As such, these waste management units, all or in part, are subject to both the NRC's decommissioning requirements and Ecology's closure requirements, as well as the financial assurance requirements of both agencies.

The decommissioning/closure of the containerized waste storage pads will involve disposition of the containerized inventories followed by decommissioning/closure of the physical structures.

Current plans call for utilization of both pads for the management of LLRW until time of plant closure, meaning that NRC decommissioning will not occur before then. With respect to mixed waste management, nearly all of the historic dangerous waste pad has been closed per Ecology regulations now that Framatome has completed its disposition of the large volume of legacy containerized mixed wastes once stored on the historic pad. Management of LLRW and mixed wastes on the newer DWSF will continue until time of plant closure, at which time Framatome will pursue Ecology closure of the DWSF plus the small unclosed portion of the historic pad. At that time, decommissioning of both pads will also be pursued per NRC requirements.

5.2.1 Container Storage Pad Structures Physical structures associated with the container storage pads (historic pad and DWSF) consist of the blacktop pads at both locations, a limited number of double containment storage pallets, and the roofed three-sided storage building at the DWSF. Contamination levels (radiological or chemical) are expected to be minimal at both locations based on the fact that the pads manage for the most part solid phase wastes in securely closed strong-tight containers. Outside surfaces of the containers have undergone appropriate radiological release surveys.

Furthermore, the containers are subject to routine operational inspections. The need for remediation of surrounding or underlying soil to any significant extent is also not anticipated but soil status will be verified via appropriate screening/sampling protocols. Prior (September 2004) closure of a significant portion of the historic waste pad under Ecology regulations confirmed the lack of surface and soil contamination associated with this longstanding operation.

Major aspects of the decommissioning/closure of the container storage pads and associated equipment/facilities are as follows:

radiological surface screening measurements at a detection sensitivity sufficient to detect past releases from containers to the blacktop or surrounding peripheral soils; removal of any asphalt with evidence of radiological contamination to allow similar screening of underlying soil; chemical constituent sampling of any underlying or peripheral soils found to be radiologically contaminated; removal/disposal of contaminated blacktop and/or soils in accordance with NRC/Ecology cleanup criteria; surveying/decontamination/release of double containment pallets, and; replacement of removed asphalt with non-contaminated material.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 29 Final release of the pad structures will be subject to the final release survey requirements of both the NRC and Ecology. Costs associated with closure/decommissioning of the waste storage pad structures are summarized in Tables 14-25.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan EOG-04-007 Version 8.0 Page 30 Table 14 Number and Dimensions of Facility Components - Storage Areas N

f I b t

ame o room, a ora ory, or area: 0 td u oor C t.

d W t St on a,nenze as e ora qe A reas Component Number of Dimensions of Total Dimensions, ft2 Components Components Asphalt Pad - Old 1

72' x 133' + 45' x 169' 17,181 Asphalt Pad - DWSF 1

120' X 170' 20,400 Double Containment 20 4' x4' 320 Pallets

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 15 Planning and Preparation - Storage Areas (Work Days)

E06-04-007 Version 8.0 Page 31 Estimate of the number of work days, by specific labor category, that will be required to It I d

f fT comp e e panning an prepara,on ac 1v1 res.

Safety Health and Activity Engineer Engineer Safety Laborer Work Days Work Days Technician Work Days Work Days Preparation and Submittal of Documentation for Regulatory Agencies Submittal of Decommissioning Plan to NRC when required by 10 CFR 30.36(g)(1),

40.42(g)(1), or 70.38(g)(1)

Development of Work 2

Plans/Safety Plans Procurement of Special 2

Equipment Staff Training 1

1 1

Characterization of Radiological Condition of the Facility (including sampling, 4

10 4

soil and tailings analysis, or groundwater analysis if applicable)

Other (specify)

TOTALS 3

6 11 5

Labor costs relative to NRC licensed materials included in Decommissioning Plan for Production and Production Support Facilities (Table 3). Closure plan for Ecology-regulated areas already on file with Ecology.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 32 Table 16 Decontamination or Dismantling of Radioactive Facility Components - Storage Areas (Work Days)

Estimate of the number of workdays, by specified labor category that will be required to complete decontamination and/or dismantling activities for each facility component.

N ameo f I b t

room, a ora orv, or area: w aste St oraqe A reas Component Health and Safety Technician Laborer Work Days Work Days Asphalt Pads 1

2 Double Containment Pallets 5

TOTALS 6

2 Table 17 Restoration of Contaminated Areas on Facility Grounds - Storage Areas (Work Days)

Estimate of the number of work days, by specific labor category that will be required to restore f

1 contaminated areas on ac1 itv grounds.

Activity Laborer Work Days Waste Storage Areas 3

TOTAL 3

Table 18 Final Radiation Survey - Storage Areas (Work Days)

Estimate of the number of work days, by specific labor category that will be required to conduct fi I

d' f a 1na ra 1a 10n survey.

Engineer Health and Safety Laborer Activity Work Days Technician Work Days Work Days Survey 30 Sampling Labor 2

2 TOTALS 2

30 2

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 19 Total Work Days by Labor Category - Storage Areas E06-04-007 Version 8.0 Page 33 Total work days estimated for each specific labor category from the applicable tables above (i.e., from Tables 15 through 18).

Safety Health and Engineer Safety Laborer Activity Engineer Work Days Technician Work Days Work Days Work Days Planning and Preparation 3

6 11 5

(TOTALS from Table 15)

Decontamination and/or Dismantling of Radioactive Facility 6

2 Components (Sum of TOTALS from Table 16)

Restoration of Contaminated Areas on 3

Facility Grounds (TOTAL from Table 17)

Final Radiation Survey 2

30 2

(TOTALS from Table 18)

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 34 Table 20 Total Labor Costs by Major Decommissioning Task - Storage Areas Estimated work days for each specific labor category (from Table 19) multiplied by the total cost per work day for the corresponding labor category (from Table 7).

Safety Health and Engineer Safety Laborer Total Labor Task Engineer Cost, $

Technician Cost, $

Cost, $

Cost,$

Planning and 1,737 3,684 4,224 2,125 11,770 Preparation Decontamination or Dismantling of 2,304 850 3,154 Radioactive Facility Components Restoration of Contaminated Areas on 1,275 1,275 Facilitv Grounds Final Radiation Survey 1,228 11,520 850 13,598 Table 21 Packaging, Shipping, and Disposal of Radioactive Wastes - Storage Areas (Excluding Labor Costs)

(a) Packing Material Costs Estimate of the types and volumes of waste expected to be generated, along with the number and types of containers required for packing the waste.

Number of Type of Unit Cost of Total Waste Type Volume (ft3)

Packaging Containers Container Container, $

Costs, $

AsphalUSoil 40 93 ft3 box (b) Processing, Packing, Shipping, Disposal Cost Estimate of the volume of waste to be disposed and the packing, shipping, and disposal costs.

Waste Type Disposal Volume (ft3)

Unit Cost ($/ft3)

Total Disposal Costs, $

AsphalUSoil 40

No incremental costs for containers or disposal for this small waste volume. Can be accommodated in void spaces of equipment disposal boxes (see Table 9).

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 35 Table 22 Equipment/Supply Costs - Storage Areas (Excluding Containers)

Estimate of the quantity of equipment and supplies required for decommissioning.

Equipment/Supplies Total Equipment/Supply Cost, $

Radiation Screening Instruments 13,400 TOTAL 13,400 Table 23 Laboratory Costs - Storage Areas Estimate of costs for analyses to be performed by an independent third-party laboratory.

Activity Total Cost, $

Testing and analysis - 48 samples@ $120 ea.

5,760 TOTAL 5,760 Table 24 Miscellaneous Costs - Storage Areas Estimate of any other applicable costs.

Cost Item Total Cost, $

Certification Survey (ORISE) 20,800 TOTAL 20,800

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 25 Total Decommissioning Costs - Storage Areas Total of the reported costs in Tables 20, 21, 22, 23 and 24.

Task/Component Planning and Preparation (From Table 20)

Decontamination and/or Dismantling of Radioactive Facility Components (From Table 20)

Restoration of Contaminated Areas on Facility Grounds (From Table 20)

Final Radiation Survey (From Table 20)

Packing Material Costs (TOTAL from Table 21)

Processing, Packing, Shipping, Disposal Costs (TOTAL from Table 21)

Equipment/Supply Costs (TOTAL from Table 22)

Laboratory Costs (TOTAL from Table 23)

Miscellaneous Costs (TOTAL from Table 24)

TOT AL - Storage Areas E06-04-007 Version 8.0 Page 36 Cost, $

11,770 3,154 1,275 13,598 13,400 5,760 20,800 69,757

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 5.2.2 Containerized LLRW Inventory E06-04-007 Version 8.0 Page 37 The LLRW inventory consists of drummed or boxed waste materials that are radioactively contaminated but that do not designate as chemically dangerous per Ecology regulations. They are essentially all solid-phase materials; all of the relatively few drums containing liquids, e.g.,

radioactively contaminated oils, are stored on double containment pallets or in drums within drums. Treatment and/or disposal options are available for each of the major containerized LLRW categories; disposition pathways vary primarily based on combustible versus non-combustible classification of the waste. Primary disposition pathways include:

for combustible wastes, incineration in Framatome's SWUR facility, followed by uranium recovery processing of the resultant ash; and for non-combustible LLRW, disposal at the U.S. Ecology-operated Hanford LLRW disposal site.

Table 26 summarizes the volumes and associated disposition costs for the containerized LLRW inventory. As noted in the table, current inventories are now somewhat lower than reasonably assumed maximum inventories, due in large part to the site's ongoing efforts to minimize its backlog of stored wastes. The maximum expected volumes have been conservatively utilized to estimate disposal cost liabilities.

5.2.3 Containerized Mixed Waste Inventory The containerized mixed waste inventory consists of wastes that are both radioactively contaminated and chemically dangerous (per Ecology criteria). Like the LLRW inventory, they are essentially all solid-phase; the few remaining liquid-containing drums are stored on containment pallets. Treatment and/or disposal options are available and being utilized for all of the major currently generated containerized mixed waste categories. Viable options for the final disposition of a relatively small volume of legacy mixed wastes and very small volume of currently generated mixed wastes have not been identified but continue to be pursued in the commercial sector.

Disposition pathways for the containerized mixed wastes depend primarily on the specific acceptance criteria of the available commercial mixed waste disposal vendors. Primary disposition pathways, depending on the specific waste stream, include:

direct shipment to the contracted mixed waste disposal site for treatment and/or disposal with or without pre-compaction; and offsite treatment via a permitted commercial mixed waste treatment facility followed by disposal of the treated residues at the contracted mixed waste disposal facility.

Table 26 also summarizes the volumes and associated disposition costs for the containerized mixed waste inventory. As in the case of the non-mixed LLRW, the current inventory of containerized mixed wastes is smaller than currently assumed maximum inventories. As such, the maximum expected inventories have been utilized to estimate disposal cost liabilities.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan Table 26 Containerized Waste Inventory Costs E06-04-007 Version 8.0 Page 38 Disposal Rate Current 4

Max Max Total Cost, $

1

$/ft3 Volume ft3 Expected Volume ft3 LLRW2 - Incinerate in

$268.53 4,479 10,890

$2,924,292 SWUR LLRW - Direct disposal at 3,720 5,000 LLRW burial site LLRW - On hold for 3,928 5,000 further processinq LLRW-Total 12,127 20,390

$2,924,292 MW3 - Disposal at

$370.11 1,510 1,600

$592,176 contracted mixed waste disposal site MW-Total 1,510 1,600

$592,176 Logistics/Shipping Suooort N/A**

Shiooing Costs N/A***

No incremental disposal costs above $12.460M already allocated to US Ecology (see Table 9 b.)

Logistics/shipping support included in Table 12.

- - Disposal rates include shipping costs, as applicable.

1 Because this waste is already containerized, the cost of containers is not included.

2 Low-level radioactive waste 3 Mixed waste 4 As of October 1st 2017

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 5.3 Environmental Remediation E06-04-007 Version 8.0 Page 39 Decommissioning financial liability can be associated with environmental contamination with licensed materials to the extent that the contamination requires remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402. At the Richland facility the most significant area of known soil contamination was the area associated with the legacy surface impoundment system. This historically contaminated area and its residual decommissioning liability are discussed below in Section 5.3.1. Similar discussion relative to other historic site spills/releases of licensed materials to the environment is provided in Section 5.3.2. Lastly, Section 5.3.3 addresses potential investigation/remediation costs associated with two potential soil contamination areas, namely soil underlying certain areas of the U02 Building and soil potentially impacted by underground piping.

5.3.1 Legacy Surface lmpoundment System The Richland site maintained and operated a surface impoundment system over the time period of 1971-2004 for the management of the plant's radioactively-contaminated (low-level uranium) liquid effluents. Certain of those impoundments initially installed with single liner systems developed leaks, resulting in contamination of the underlying soil. The leaks also resulted in uranium contamination within the shallow unconfined groundwater aquifer underlying the site.

From 1983 until their last usage in 2004, all of the impoundments were operated with multi-linered containment systems with inter-liner leak detection/leachate collection; no additional leaks were documented over that period.

The surface impoundment system has been removed from service in accordance with a consent decree and formal closure plan under Washington State Department of Ecology (Ecology)

Dangerous Waste Regulations. The work involved processing of the stored waste inventory, removal/disposal of lagoon structural components, characterization of contamination levels in underlying soil, and remediation (removal and offsite disposal) of contaminated soil to meet Ecology cleanup levels for uranium and regulated non-radiological chemicals. Certification of completion of the work in accordance with the approved closure plan and associated soil cleanup levels was submitted to Ecology in September 2006; Ecology concurrence was received on November 14, 2006.

Framatome believes that the surface impoundment area now conservatively meets NRC requirements for unrestricted release and that no additional remediation will be required at the time of final plant decommissioning. The Ecology-imposed uranium cleanup level of 12.1 mg/kg translates to an activity level of 29 pCi/g for uranium at a U-235 enrichment of 3.5%. In reality the residual soil uranium concentrations present upon completion of the Ecology-mandated closure work were generally well below the 29 pCi/g limit in that cleanup to a very conservative fluoride soil cleanup limit typically drove soil removal/disposal to an extent well beyond that required to meet the uranium cleanup limit. Framatome has calculated Derived Concentration Guideline Levels (DCGLs) of 63 pCi/g for U-234 and 66 pCi/g for U-235, U-236, and U-238 based on RESRAD 6.3 and ICRP 30 (using more up-to-date ICRP models would yield even higher DCGLs). While realizing the final NRC release of the former surface impoundment area will be based on NRG-approved DCGLs and final status and confirmatory surveys, it is not anticipated that such DCGLs will necessitate cleanup beyond that already conducted.

In accordance with its NRC license (SNM-1227) and Ecology Groundwater Compliance Monitoring Plan, Framatome continues its semi-annual monitoring of downgradient wells for gross alpha and uranium. Groundwater levels of gross alpha and uranium have continued their decline over the last three years and are expected to continue to decline via natural attenuation

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 40 in that the Ecology uranium soil cleanup level was calculated to be protective of groundwater at the 30 ppb Ecology groundwater cleanup limit, which also corresponds to the current federal (EPA) drinking water limit for uranium. In the first-half 2017 groundwater sampling event, none of the site's six groundwater monitoring wells downgradient of the legacy surface impoundment area still exceeded 30 ppb uranium. The highest measurement during this most recent sampling event was 28.4 ppb uranium. It should be noted that there is no domestic or agricultural usage of groundwater on the Framatome site or on the hydrologically-downgradient US Department of Energy Hanford Site.

Residual decommissioning cost liabilities related to the legacy surface impoundment area are limited to the costs associated with the planning for, and the conduct of, a technically compliant final survey, including anticipated NRC regulatory oversight and the conduct of an NRG-required third party certification survey. These residual costs are addressed in Tables 27-30. The costs will be incurred at the time of final plant decommissioning in that the NRC has granted Framatome an alternate schedule for official decommissioning of the remediated surface impoundment area in accordance with 10 CFR 70.38(f) (November 15, 2006; TAC L31973).

5.3.2 Historic Spills and Releases (Documented)

As required by 10 CFR 70.25(g)(3), Framatome maintains records of information important to the decommissioning of the Richland site, which includes areas of known or suspect environmental contamination that will require additional characterization and, if needs be, remediation at the time of plant decommissioning. These potential environmental remediation areas are a subset of the areas listed per 10 CFR 70.25(g)(3)(ii), i.e., records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site. Information in this regard has been derived from two major sources, namely (1) a major site-wide remedial investigation/feasibility study (RI/FS) conducted in the early 1990s which included a formal hazardous substance source review (the RI/FS was in response to surface impoundment-related issues and included both radiological and non-radiological constituents), and (2) the site's ongoing hazardous spill/release reporting procedure and associated spill reports/log.

Records of these past spills/releases typically reveal residual contamination levels below 30 pCi/g uranium-based activity; furthermore most of the areas are highly localized and typically were remediated at the time of occurrence. Extensive environmental remediation efforts are not anticipated for these areas to meet decommissioning radiological release criteria. Costs will primarily be related to characterization (investigation, sampling, analysis) with the potential for limited soil removal costs. Any limited soil removal required will not result in incremental disposal costs in that the soil can be easily accommodated within the void spaces in the approximately 450 93 ft3 burial boxes that will be utilized to contain removed facility equipment (see Table 9). A review of site spill logs for 2012 through October 2017 indicated no additional radiological environmental releases requiring evaluation at time of decommissioning beyond those previously accounted for. Estimated decommissioning costs related to environmental remediation of documented historic spills/releases (unrelated to the surface impoundments) are provided in Tables 31-34.

5.3.3 Potential Soil Contamination Areas Beyond the legacy surface impoundment area and the pertinent historic spill/release sites discussed in Sections 5.3.1 and 5.3.2, respectively, two other environmental areas of potential soil contamination will need to be accessed and evaluated at the time of plant decommissioning.

The first area is the soil underlying the historic and current wet chemical processing areas

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 41

[primarily ammonium diuranate (ADU) chemical conversion] within the Uranium Dioxide (U02)

Building. The long-term processing of uranium-bearing solutions in conjunction with concrete flooring challenged by the harsh chemical environment have created the possibility for the release of uranium to the soil column below those areas. Access to this soil for characterization and possible removal will necessitate concrete removal, soil characterization, soil excavation, and possible offsite soil disposal.

The second area of potential soil contamination is the soil underlying underground piping, historically or currently conveying uranium-bearing solutions. It is estimated that approximately 3,000 feet of trenching will be required to gain access for removal of the approximately 6,000 lineal feet of underground piping that has conveyed uranium-bearing solutions, past or present.

Estimated decommissioning costs for these two areas of potential soil contamination are provided in Tables 35-42. Conservatisms relative to the U02 wet chemical processing area estimate include removal of 1400 ft2 of concrete to allow backhoe access versus an implicated floor area of 500 ft2, and removal of all soil to a depth of ten feet over a total surface area of 1000 ft2 (twice the implicated floor area). Relative to the underground piping removal/

remediation, the estimate conservatively assumes soil removal/disposal to a depth of ten feet below ten percent of the 3000 feet of trenching.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 42 Table 27 Residual Labor Requirements for Final Release of Former Surface lmpoundment Area (Work Days)

Estimated number of work days by specific labor category that will be required to complete the planning and preparation for, and the conduct of, a final release survey for the former surface impoundment area.

Senior Engineer NRC Health and Activity Engineer Safety Work Days Work Days Work Days Technicians Planning and Preparation Preparation of Documentation 10 for Regulatory Agencies Submittal of Decommissioning Plan to 5

15 NRC when Required by 70.38(g)(1)

Development of Work Plans 5

Procurement of Special 4

Equipment Staff Training 4

2 Conduct of Survey Final Radiation Survey (gridding, sampling, sample 12 12 preparation)

TOTALS 15 25 15 14 Table 28 Total Labor Costs for Final Release of Former Surface lmpoundment Area Estimated work days for each specific labor category (from Table 27) multiplied by the total cost per work day for the corresponding labor categor11 (from Table 7).

Senior Health and Task Engineer Engineer Safety NRC Total Labor Cost, $

Cost, $

Technician Cost, $

Cost, $

Planning and 12,285 7,982 768 33,480 54,515 Preparation Conduct of Final Radiation 7,368 4,608 11,976 Survey

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 43 Table 29 Laboratory and Miscellaneous Costs - Final Release of Former Surface lmpoundment Area Estimate of costs for analyses to be performed by an independent third-party laboratory as well as other third party support costs.

Activity /Item Total Cost,$

Testing and analysis: 480 samples@ $120 57,600 ea.

40 sampling excavations (backhoe) 18,980 NRC Inspections 36,000 Certification Survey 86,814 TOTAL 199,394 Table 30 Total Decommissioning Costs - Final Release of Former Surface lmpoundment Area Total of the reported costs in Tables 28 and 29.

Task/Component Cost, $

Planning and Preparation 54,515 (From Table 28)

Conduct of Final Radiation Survey 11,976 (From Table 28)

Laboratory and Miscellaneous Costs 199,394 (TOTAL from Table 29)

TOTAL - Former Surface lmpoundment Area 265,885 Table 31 Labor Requirements - Historic Spills/Releases (Work Days)

Estimated number of work days by specific labor category that will be required to investigate, characterize and remediate pertinent environmental releases/spills recorded in accordance with 10 CFR 70.25(g)(3)

Activity Engineer Equipment Laborer Work days Operator Work Days Work Days Work plans/procedures 3

Pre-characterization dismantlement and/or 2

2 excavation Soil sample collection (characterization and 2

confirmation)

Soil removal/packaging (if required) 3 3

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 44 Table 32 Total Labor Costs for Historic Spills/Releases Estimated number of work days for each specific labor category (from Table 31) multiplied by the total cost per work day for the corresponding labor category (from Table 7)

Activity Engineer Equipment Laborer Total Cost, $

Operator Cost, $

Labor Cost, $

Cost, $

Work plans/procedures 1,842 1,842 Pre-characterization dismantlement 926 850 1,776 and/or excavation Soil sample collection 1,228 1,228 (characterization and confirmation)

Soil removal/packaging (if required) 1,389 1,275 Table 33 Laboratory and Miscellaneous Costs - Historic Spills/Releases Estimate of costs for analyses to be performed by an independent third-party laboratory.

Activity/Item*

Total Cost, $

Testing and analysis: 55 samples@ $120 ea.

6,600 2,664 NRC Inspections, certification survey Covered in Table 12 and 29 costs

No incremental soil disposal costs. Anticipated soil volumes accommodated in void spaces of equipment disposal boxes (see discussion in Section 5.3.2).

Table 34 Total Costs - Environmental Remediation for Historic Spills/Releases Total of reported costs in Tables 32 and 33.

Task/Component Cost, $

Work plans/procedures (from Table 32) 1,842 Pre-characterization dismantlement and/or 1,776 excavation (from Table 32)

Soil sample collection (from Table 32) 1,228 Soil removal/packaging (from Table 32) 2,664 Laboratory testing and analysis (from Table 6,600

33)

TOTAL - Environmental Remediation 14,110

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 45 Table 35 DimensionalNolume Assumptions for Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping a) Soil Below U02 Building Parameter Impacted Area, ft2 Area Removed, ft2 Disposal Vol., ft3 Concrete (floor) 500 1,400 700 Soil 1,000 10,000 b) Soil Below Underground Piping Parameter Length, ft.

Disposal Vol., ft3 Trenching 3,000 Piping 6,000 1,116 Soil 8,400

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 46 Table 36 Planning and Preparation - Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Estimate the number of work days, by specific labor category, that will be required to complete planning and preparation activities.

Activity Safety

Engineer, Health and

Laborer, Operator,

Engineer, Work Safety Work Work Work Days Days Technician, Days Days Work Days Preparation and Submittal of Documentation for Regulatory Agencies Submittal of Decommissioning Plan to NRC Development of Work 10 10 Plans/Safety Plans Staff Training 4

2 4

2

Included in labor costs for this activity in Table 3 for Production and Production Support Facilities.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 47 Table 37 Environmental Investigation/Remediation of Specific Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Estimate the number of work days, by specific labor category, for environmental investigation/

remediation activities.

Location

Operator, Laborer, Work Health and

Engineer, Work Days Days Safety Work Days Technician, Work Days*

Below U02 Building 18 23 13 2

Below Underground Piping 79 533 17 2

Health and Safety Technician labor includes radiation protection oversight of work plus collection of soil samples for pre-characterization and final confirmation.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 48 Table 38 Total Work Days by Labor Category - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Total work days estimated for each specific labor category from Tables 36 and 37.

Activity

Engineer, Safety

Operator, Laborer, Health and Work Days

Engineer, Work Work Safety Work Days Days Technician, Days Work Days Development of Work 10 10 Plans/Safety Plans Staff Training 4

2 4

2 Environmental Investigation/

4 97 556 30 Remediation

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 49 Table 39 Total Labor Costs by Major Decommissioning Task-Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Estimated work days for each specific labor category (from Table 38) multiplied by the total cost per work day for the corresponding labor category (from Table 7)

Activity

Engineer, Safety

Operator, Laborer, Health and Total Work

Engineer, Work Work Safety Labor Days Work Days Days Technician, Cost,$

Days Work Days Development of Work 6,140 5,790 11,930 Plans/Safety Plans Staff Training 2,316 926 1,700 768 5,710 Environmental 2 456 44,911 236,300 11,520 295,187 Investigation/

Remediation

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan EOS-04-007 Version 8.0 Page 50 Table 40 Packaging, Shipping and Disposal of Radioactive Wastes - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping a) Packing Material Costs Waste Type Volume, ft3 Number of Type of Container Total Containers Container Unit Cost,$

Packaging Costs Soil/Concrete 19,100 Piping 1,000 Total 20,100 223 93 ft3 box 1,800 401,400 b) Shipping and Disposal Costs Waste Type Disposal Volume, ft3 Disposal Cost, $

Shipping Cost, $

Containerized Waste 20,100 262,700**

for Burial

Catalog price from commercial container supplier.

- No incremental disposal costs above $12.460M already allocated to US Ecology (see Table 9b).

- - Assumes 37 shipments at $7, 100/shipment based on current TN rates.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 51 Table 41 Laboratory and Miscellaneous Costs - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Activity/Item*

Equipment (Backhoe) Charges Materials Analytical TOTAL Uranium in soil (364@ $120 ea.)

Nitrate/fluoride in soil (57 @ $30 ea.)

Cost, $

215,641 2,784 43,680 1,710 263,815

Does not include miscellaneous expenses that apply for the site-wide decommissioning effort, e.g., insurance, NRC inspections, logistics support, etc. (see Table 12).

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 52 Table 42 Total Decommissioning Costs - Potential Soil Contamination Areas - Soil Below U02 Building Wet Processing Area; Soil Underlying Underground Piping Total of reported costs in Tables 39, 40 and 41.

Task/Component Development of Work Plans/Safety Plans (from Table 39)

Staff Training (from Table 39)

Environmental Investigation/Remediation (from Table 39)

Packing Material Costs (TOTAL from Table 40a)

Shipping and Disposal Costs (from Table 40b)

Laboratory and Miscellaneous Costs (TOTAL from Table 41)

TOTAL - Potential Soil Contamination Areas Cost, $

11,920 5,710 295,187 401,400 262,700**

263,815 1,240,732

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 6.0 Adjustment of Cost Estimates and Funding Level E06-04-007 Version 8.0 Page 53 As required in 1 O CFR 70.25(e), Framatome will adjust these cost estimates at intervals not to exceed three years. Associated funding levels will be adjusted as needed. Consistent with guidance in NUREG-1757, the review will consider changes in costs of goods and services, including inflation; changes in facility conditions or operations; and changes in expected decommissioning procedures.

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 7.0 Certification of Financial Assurance Principal: Framato.me Inc., 2101 Horn Rapids Road, Richland, WA 99354 NRC License Number SNM-1227 for Framatome Inc. (same address)

Issued to: U.S. Nuclear Regulatory Commission E06-04-007 Version 8.0 Page 54 I certify that Framatome Inc. is licensed to possess the following types of unsealed special nuclear material licensed under 1 O CFR Part 70 in the following amounts:

Tvpe of Material Amount of Material Uranium compounds in any chemical/physical 120,000 kg U-235 form enriched up to 5.00 wt. % U-235 (uranium compounds)

Uranium enriched in U-235 (any enrichment or 350 g U-235 chemical/physical form)

I also certify that financial assurance in the amount of $66,425,800 has been obtained for the purpose of decommissioning as prescribed by 10 CFR Part 70.

Katherine Williams, Chief Financial Officer Date

EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan 8.0 Financial Assurance Instruments E06-04-007 Version 8.0 Page 55 This section provides copies of financial assurance instruments (Exhibits 1 and 2) to demonstrate financial assurance for all of the estimated decommissioning costs. The mechanism utilized by Framatome is the letter of credit/standby trust agreement provided for in 10 CFR 70.25 (f)(2).

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EHS&L Document Environmental Protection - Miscellaneous Reports Decommissioning Funding Plan E06-04-007 Version 8.0 Page 66

E06 Environmental Protection E06-04 Miscellaneous Reports Decommissioning Funding Plan Date(GMT)

Signed by 2018/05/30 22:24:07 Tate, Timothy Richland EHS&L Manager Authorizationffitle 2018/05/30 22:49:56 Land, Ron Richland Site Manager Authorizationffitle 2018/06/01 14:17:08 Powers, Steve Maintenance Manager Authorization/Title E06-04-007 Version 8.0

v t e Letter Sequence Response to RAI
EPID:L-2018-DFA-0001, (Approved, Closed)
Initiation Request Acceptance Administration Questions 16 May 2018 Answers 31 May 2018 Results Approval, Approval Other: ML18186A237
MONTHYEAR2018-05-31 [Table View]

ML18159A052

Text

SUBJECT:

Dear Mr. Ramsey:

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