ML18320A034

Post Shutdown Decommissioning Activities Report

ML18320A034
Person / Time
Site:	Pilgrim
Issue date:	11/16/2018
From:	Halter M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.18.070
Download: ML18320A034 (157)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel: (601)368-5000 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.82 November 16, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Post Shutdown Decommissioning Activities Report Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, Notification of Permanent Cessation of Power Operations, 2.15.080, dated November 10, 2015 (ML15328A053)

LETTER NUMBER: 2.18.070

Dear Sir or Madam:

Pursuant to 10 CFR 50.82(a)(4), Entergy Nuclear Operations, Inc. (ENO), on behalf of itself and Entergy Nuclear Generation Company (ENGC), is submitting a Post Shutdown Decommissioning Activities Report (PSDAR) for the Pilgrim Nuclear Power Station (PNPS).

By letter dated November 10, 2015, ENO notified the NRC of its intent to permanently cease power operations at PNPS no later than June 1, 2019 (Reference 1).

The enclosed PSDAR has been developed consistent with Regulatory Guide 1.185, Revision 1, Standard Format and Content for Post-Shutdown Decommissioning Activities Report. The PSDAR includes a description of the planned decommissioning activities, a schedule for their accomplishment, a site-specific decommissioning cost estimate, and a discussion that provides the basis for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate, previously issued, environmental impact statements. The PSDAR also includes a discussion of the schedule and projected costs associated with spent fuel management and site restoration activities. Funding for spent fuel management activities is being addressed in a separate submittal as an update to the PNPS Spent Fuel Management Plan, pursuant to 10 CFR 50.54(bb).

In accordance with 10 CFR 50.82(a)(4)(i), a copy of the PNPS PSDAR is being provided to the Commonwealth of Massachusetts by transmitting a copy of this letter and its Enclosure to the designated State Officials.

Letter No. 2.18.070 I Page 2 of 2 There are no new regulatory commitments contained in this letter.

Should you have any questions concerning this submittal or require additional information, please contact Mr. Peter J. Miner at (508) 830-7127.

Sincerely, MKH/shr

Enclosure:

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report cc:

Mr. David C. Lew Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. John Lamb, Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-9D12 Washington, DC 20555-0001 Mr. John Giarrusso, Jr.

Planning, Preparedness and Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 Mr. John Priest, Director Massachusetts Department of Public Health Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1M2A Charlestown, MA 02129-1121 NRC Resident Inspector Pilgrim Nuclear Power Station

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Prepared on Behalf of Entergy Nuclear Generation Company by TLG Services, Inc.

November 2018 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report TABLE OF CONTENTS Section Page 1.0 Introduction and Summary ..................................................................................................... 1 1.1 Introduction ........................................................................................................................1 1.2 Background ........................................................................................................................ 1 1.3 Summary of Decommissioning Alternatives ................................................................... 2 2.0 Description of Planned Decommissioning Activities.............................................................. 5 2.1 Discussion of Decommissioning Activities ..................................................................... 8 2.1.1 Preparations for Dormancy................................................................................ 8 2.1.2 Dormancy..........................................................................................................11 2.1.3 Preparations for Decommissioning .................................................................12 2.1.4 Decommissioning (Dismantling and Decontamination)................................12 2.1.5 Site Restoration ................................................................................................14 2.2 General Decommissioning Considerations ....................................................................14 2.2.1 Major Decommissioning Activities ..................................................................14 2.2.2 Other Decommissioning Activities...................................................................15 2.2.3 Decontamination and Dismantlement Activities..............................................15 2.2.4 Radioactive Waste Management ......................................................................15 2.2.5 Removal of Mixed Wastes................................................................................16 2.2.6 Site Characterization .........................................................................................16 2.2.7 Groundwater Protection and Radiological Decommissioning Records Program...............................................................................................16 2.2.8 Changes to Management and Staffing..............................................................17 3.0 Schedule of Planned Decommissioning Activities ................................................................18 4.0 Estimate of Expected Decommissioning and Spent Fuel Management Costs ..................19 4.1 Means of Adjusting Cost Estimates................................................................................20 4.2 Means of Adjusting Associated Funding Levels ...........................................................20 5.0 Environmental Impacts ..........................................................................................................21 5.1 Environmental Impact of PNPS Decommissioning.........................................................21 5.1.1 Onsite/Offsite Land Use................................................................................21 5.1.2 Water Use .........................................................................................................22 5.1.3 Water Quality ...................................................................................................22 5.1.4 Air Quality ........................................................................................................23 5.1.5 Aquatic Ecology............................................................................................23 5.1.6 Terrestrial Ecology........................................................................................24 5.1.7 Threatened and Endangered Species .............................................................24 5.1.8 Radiological ..................................................................................................28 ii Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 5.1.9 Radiological Accidents .................................................................................29 5.1.10 Occupational Issues ......................................................................................30 5.1.11 Cost ...............................................................................................................30 5.1.12 Socioeconomics ............................................................................................30 5.1.13 Environmental Justice...................................................................................31 5.1.14 Cultural, Historic, and Archeological Resources..........................................32 5.1.15 Aesthetic Issues.............................................................................................33 5.1.16 Noise .............................................................................................................33 5.1.17 Transportation ...............................................................................................34 5.1.18 Irreversible and Irretrievable Commitment of Resources.............................35 5.2 Environmental Impacts of License Termination - NUREG-1496 ...............................35 5.3 Discussion of Decommissioning in the Supplemental Environmental Impact Statement (SEIS)..........................................................................................................36 5.4 Additional Considerations ...........................................................................................36 5.5 Conclusions..................................................................................................................37 6.0 References ............................................................................................................................39 TABLES 2.1 Decommissioning Schedule Summary ..........................................................................7 2.2 Decommissioning Cost Summary..................................................................................8 5.1 Protected Terrestrial Species, Plymouth County .........................................................25 5.2 Protected Aquatic Species, Cape Cod Bay ..................................................................27 5.3 Plymouth and Barnstable Counties Updated Population Growth 2000-2015 .............31 ATTACHMENTS

1. PNPS Site-Specific Decommissioning Cost Estimate .............................................41 iii Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Acronyms AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable BMP Best Management Practices BWR Boiling Water Reactor CFR Code of Federal Regulations DCE Decommissioning Cost Estimate DOE Department of Energy DSEIS Draft Supplemental Environmental Impact Statement (NUREG-1437)

ENGC Entergy Nuclear Generation Company ENOI Entergy Nuclear Operations, Inc.

ENTERGY Entergy Corporation EPA Environmental Protection Agency FSAR Final Safety Analysis Report FSS Final Status Survey GEIS Generic Environmental Impact Statement (NUREG-0586)

GTCC Greater than Class C GW Groundwater ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MassDEP Massachusetts Department of Environmental Protection MWth Megawatt-thermal NEI Nuclear Energy Institute NESP National Environmental Studies Project NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission PNPS Pilgrim Nuclear Power Station PSDAR Post-Shutdown Decommissioning Activities Report SEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437), Supplement 29 Regarding Pilgrim Nuclear Power Station SFP Spent Fuel Pool SSCs Structures, Systems and Components UFSAR Updated Final Safety Analysis Report iv Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report

1.0 INTRODUCTION

AND

SUMMARY

1.1 Introduction In accordance with the requirements of Title 10 of the Code of Federal Regulations (CFR) 50.82, Termination of license, paragraph (a)(4)(i), this report constitutes the Post-Shutdown Decommissioning Activities Report (PSDAR) for the Pilgrim Nuclear Power Station (PNPS).

This PSDAR contains the following:

1. A description of the planned decommissioning activities along with a schedule for their accomplishment.

2. A discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements.

3. A site-specific decommissioning cost estimate (DCE), including the projected cost of managing irradiated fuel and the post-decommissioning site restoration cost.

The PSDAR has been developed consistent with Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, (Reference 1). This report is based on currently available information and the plans discussed herein may be modified as additional information becomes available or conditions change. As required by 10 CFR 50.82(a)(7), ENOI will notify the Nuclear Regulatory Commission (NRC) in writing, with copies sent to the affected State(s), before performing any decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the PSDAR, including changes that significantly increase the decommissioning cost.

1.2 Background

The PNPS site is located on the rocky western shore of Cape Cod Bay in the Town of Plymouth, Plymouth County, Massachusetts. The nearest large cities are Boston, Massachusetts, approximately 38 miles to the northwest and Providence, Rhode Island, approximately 44 miles to the west. The PNPS facility occupies approximately 140 acres. ENGC also owns approximately 1,500 acres of forestland adjacent to the plant site, which falls under Massachusetts General Law Chapter 61 and holds a documented forest management plan.

PNPS employs a General Electric boiling water reactor nuclear steam supply system licensed to generate 2,028 megawatts - thermal (MWth). PNPS was purchased by Entergy Nuclear Generation Company (ENGC) in July 1999, and is operated by Entergy Nuclear Operations, Inc. (ENOI) on behalf of ENGC. The current facility operating license for PNPS expires at midnight, June 8, 2032.

PNPS employs a General Electric boiling water reactor nuclear steam supply system licensed to generate 2,028 megawatts - thermal (MWth) The principal structures of PNPS are the reactor and turbine buildings, off-gas retention building, radwaste building, diesel generator building, intake structure, switchyard, main stack, trash compaction facility, and administration buildings.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report PNPS structures are primarily located within the fenced owner-controlled area (OCA), with the exception of the wastewater treatment facility and the main stack.

A brief overview of the major milestones related to PNPS construction and operational history is as follows:

x Construction Permit Issued: August 26, 1968 x Operating License Issued: June 8, 1972 x Commercial Operation: December 1, 1972 x Initial Operating License Expiration: June 8, 2012 x Renewed Operating License Expiration: June 8, 2032 By letter dated November 10, 2015 (Reference 2), ENOI notified the NRC that it intended to permanently cease power operations of PNPS no later than June 1, 2019. ENOI will submit a supplement to this letter certifying the date on which operations have ceased, or will cease, in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8). Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Pursuant to 10 CFR 50.51(b), Continuation of license, the license for a facility that has permanently ceased operations continues in effect beyond the expiration date to authorize ownership and possession of the utilization facility until the Commission notifies the licensee in writing that the license has been terminated.

During the period that the license remains in effect, 10 CFR 50.51(b) requires that ENGC:

1. Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility including storage, control, and maintenance of the spent fuel in a safe condition.

2. Conduct activities in accordance with all other restrictions applicable to the facility in accordance with NRC regulations and the 10 CFR 50 facility license.

10 CFR 50.82(a)(9) states that power reactor licensees must submit an application for termination of the license at least two years prior to the license termination date and that the application must be accompanied or preceded by a license termination plan to be submitted for NRC approval.

1.3 Summary of Decommissioning Alternatives The NRC has evaluated the environmental impacts of three general methods for decommissioning power reactor facilities in NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, (GEIS) (Reference 3). The three general methods evaluated are summarized as follows:

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report x DECON: The equipment, structures and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

x SAFSTOR: After the plant is shut down and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

x ENTOMB: Radioactive structures, systems and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

The decommissioning approach that has been selected by ENGC for PNPS is the SAFSTOR method. The primary objectives of the PNPS decommissioning project are to remove the facility from service, reduce residual radioactivity to levels permitting unrestricted release, restore the site, perform this work safely, and complete the work in a cost effective manner. The selection of a preferred decommissioning alternative is influenced by a number of factors at the time of plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of low-level waste disposal facilities, availability of a high-level waste (spent fuel) repository or a Department of Energy (DOE) interim storage facility, regulatory requirements, and public concerns. In addition, 10 CFR 50.82(a)(3) requires decommissioning to be completed within 60 years of permanent cessation of operations.

Under the SAFSTOR methodology, the facility is placed in a safe and stable condition and maintained in that state allowing levels of radioactivity to decrease through radioactive decay, followed by decontamination and dismantlement. After the safe storage period, the facility will be decontaminated and dismantled to levels that permit license termination. In accordance with 10 CFR 50.82(a)(9), a license termination plan will be developed and submitted for NRC approval at least two years prior to termination of the license.

The decommissioning approach for PNPS is described in the following sections.

x Section 2.0 describes the planned decommissioning activities and the general timing of their implementation.

x Section 3.0 describes the overall decommissioning schedule, including the spent fuel management activities.

x Section 4.0 provides an analysis of expected decommissioning costs, including the costs associated with spent fuel management and site restoration.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report x Section 5.0 describes the basis for concluding that the environmental impacts associated with decommissioning PNPS are bounded by the NRC generic environmental impact statement related to decommissioning.

x Section 6.0 is a list of references.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report

2.0 DESCRIPTION

OF PLANNED DECOMMISSIONING ACTIVITIES ENGC is currently planning to decommission PNPS using a SAFSTOR method. SAFSTOR is broadly defined in Section 1.3 of this report. Use of the SAFSTOR method will require the management of spent fuel because of the DOEs failure to perform its spent fuel removal obligations under its contract with ENGC. To explain the basis for projecting the cost of managing SNF, a discussion of spent fuel management activities for the site is included herein.

The initial decommissioning activities to be performed after plant shutdown will entail preparing the plant for a period of safe-storage (also referred to as dormancy). This will entail de-fueling the reactor and transferring the fuel into the spent fuel pool, draining of fluids and de-energizing non-essential systems, and reconfiguring the electrical distribution, ventilation, heating, and fire protection systems. Systems temporarily needed for continued operation of the spent fuel pool will be reconfigured for operational efficiency. Additional ISFSI storage capacity will be developed to allow for dry storage of all spent fuel assemblies and GTCC waste generated during the plant operations.

During dormancy the PNPS will be staffed with personnel who will monitor, maintain and provide security for the ISFSI and plant facilities. Staffing and configuration requirements are expected to change during the period of dormancy, principally dependent upon the status of the spent fuel being stored on-site. This can be characterized as one of three spent fuel conditions, as follows:

x Wet and dry storage of spent fuel x On-site dry storage of all spent fuel x All spent fuel removed from the site Spent fuel will remain in the spent fuel pool (SFP) until it meets the criteria for transfer to the ISFSI. After all fuel has been transferred to the ISFSI, the pool and supporting systems will be in a drained and de-energized condition for the remainder of the dormancy period. The spent fuel will be stored in the ISFSI until transfer to the Department of Energy (DOE).

After the final spent fuel transfer to the ISFSI, the plant will remain in dormancy until the start of dismantling and decontamination (D&D) activities. D&D activities will be scheduled to enable the license to be terminated within 60 years after permanent cessation of operations. Following completion of the D&D activities and termination of the NRC license, site restoration will be performed.

For the purposes of the current site-specific decommissioning cost estimate, it is assumed that remaining structures are to be demolished to three-feet below grade and the excavations backfilled.

Decommissioning activities will be performed in accordance with written, reviewed and approved site procedures. There are no identified or anticipated decommissioning activities that are unique to the PNPS site outside the bounds considered in the GEIS.

Radiological and environmental programs will be maintained throughout the decommissioning process to ensure occupational, public health and safety, and environmental compliance.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Radiological programs will be conducted in accordance with the facilitys revised Technical Specifications, Operating License, Updated Final Safety Analysis Report (UFSAR), Radiological Environmental Monitoring Program, and the Offsite Dose Calculation Manual. Non-radiological Environmental Programs will be conducted in accordance with applicable requirements and permits.

Tables 2.1 and 2.2 provide summaries of the schedule / plant status and costs for decommissioning PNPS. The major decommissioning activities and the general sequence of activities are discussed in more detail in the sections that follow.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report TABLE 2.1 Decommissioning Schedule and Plant Status Summary Approximate Duration Decommissioning Activities / Plant Status Start End (years)

Pre-Shutdown Planning May 2018 2019 1.0 Transition from Operations Plant Shutdown May 31, 2019 -------- --------

Preparations for SAFSTOR Dormancy May 31, 2019 March 2020 0.84 SAFSTOR Dormancy Dormancy w/Wet Fuel Storage March 2020 2022 2.8 Dormancy w/Dry Fuel Storage 2022 2062 40.0 Dormancy w/No Fuel Storage 2062 2073 10.4 Preparations for Dismantling &

Decontamination (D&D)

Preparations for D&D 2073 2074 1.5 Dismantling & Decontamination (D&D)3 Large Component Removal 2074 2076 1.4 Plant Systems Removal and Building 2076 2078 2.3 Decontamination License Termination 2078 2079 0.7 Site Restoration Site Restoration 2079 2080 1.5 Total from Shutdown to Completion of

---

-------- 60 License Termination 7

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report TABLE 2.2 Decommissioning Cost Summary (Thousands of 2018 dollars)

License Spent Fuel Site Decommissioning Periods Termination Management Restoration Totals Planning and Preparations 144,683 93,869 0 238,552 Dormancy w/Wet Fuel Storage 125,888 134,770 0 260,658 Dormancy w/Dry Fuel Storage 245,489 191,611 0 437,100 Dormancy w/No Fuel Storage 49,031 0 0 49,031 Site Reactivation 46,701 0 571 47,272 Decommissioning Preparation 35,482 0 451 35,933 Large Component Removal 225,394 0 369 225,763 Plant Systems Removal and Building Remediation 281,263 0 881 282,143 License Termination 33,840 0 0 33,840 Site Restoration 225 0 50,743 50,968 Total [a] 1,187,994 420,250 53,014 1,661,258

[a]

Columns may not add due to rounding 2.1 Discussion of Decommissioning Activities The following narrative describes the basic activities associated with decommissioning the PNPS.

The site specific DCE (detailed in Attachment 1) is divided into phases or periods based upon major milestones within the project or significant changes in the annual projected expenditures.

The following sub-sections correspond to the five major decommissioning periods within the estimate.

2.1.1 Preparations for Dormancy The NRC defines SAFSTOR as, A method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use. The facility is left intact (during the dormancy period), with structures maintained in a stable condition.

Systems that are not required to support the spent fuel, HVAC, Emergency Plan or site security 8

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report are drained, de-energized, and secured. Minimal cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination is performed. Access to contaminated areas is maintained secure to provide controlled access for inspection and maintenance.

The process of placing the plant in safe-storage will include, but is not limited to, the following activities:

o Creation of an organizational structure to support the decommissioning plan and evolving emergency planning and site security requirements.

o Revision of technical specifications, plans and operating procedures appropriate to the operating conditions and requirements.

o Characterization of the facility and major components as may be necessary to plan and prepare for the dormancy phase.

o Isolation of the spent fuel pool and reconfiguring fuel pool support systems so that draining and de-energizing may commence in other areas of the plant.

o Design and construction of additional ISFSI capacity.

o Deactivation (de-energizing and /or draining) of systems that are no longer required during the dormancy period.

o Processing and disposal of water and water filter and treatment media not required to support dormancy operation.

o Disposition of incidental waste that may be present prior to the start of the dormancy period, such as excess tools and equipment and waste produced while deactivating systems and preparing the facility for dormancy.

o Reconfiguration of power, lighting, heating, ventilation, fire protection, and any other services needed to support long-term storage and periodic plant surveillance and maintenance.

o Stabilization by fixing or removing loose incidental surface contamination to facilitate future building access and plant maintenance. Decontamination of high-dose areas is not anticipated.

o Performance of interim radiation surveys of the plant, posting caution signs and establishing access requirements, where appropriate.

o Maintenance of appropriate barriers for contaminated and radiation areas.

o Reconfiguration of security boundaries and surveillance systems, as required.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report The following is a general discussion of the planned reconfiguration expected after plant shutdown.

Electrical Systems The electrical system will undergo a series of reconfigurations between shutdown and the time all spent fuel has been transferred to dry storage. The reconfigurations will be performed to improve system flexibility and operational control, reduce operating and maintenance expenses, and to provide diverse means of aligning the power sources to the station loads particularly for Spent Fuel Pool-related systems and critical security equipment. The ISFSI facility will require installation of a new electrical distribution system independent of the existing station service and will also include a new diesel generator and uninterruptable power supply system.

Mechanical Systems Following shutdown, as applicable, fluid filled systems will be drained and abandoned, and resins removed based on an evaluation of system category, functionality, and plant configuration. System categories include: 1) Balance of Plant (BOP), 2) Emergency Core Cooling System (ECCS), 3)

Nuclear Steam Safety System (NSSS), 4) Spent Fuel Pool Cooling (SFPC), and 5) Dry Fuel Storage (DFS). Plant configurations include: 1) Post-shutdown (fuel in the reactor), 2) Post-defuel (no fuel in the reactor); 3) Post-gates in (no fuel in reactor, spent fuel pool is physically isolated from the reactor); 4) Reactor vessel drained; 5) Reduced risk of zirconium fire; and 6) Post-dry fuel storage (all spent fuel in dry fuel storage). The plant configuration and functionality of each system within the plant configuration as it evolves will determine when a system can be drained and abandoned.

Ventilation and Heating Systems Ventilation will be reconfigured for the Turbine Building (TB) and Reactor Building (RB) to support remaining systems and habitability. Fluid filled systems in the TB will either be drained or freeze protection installed, and the heating steam secured. The RB ventilation system will be reconfigured to maintain building temperature to support habitability and the functioning of Fuel Pool Cooling systems, Fire Protection systems, and systems required for Dry Fuel Storage loading.

Fire Protection Systems Active and passive features of the Fire Protection (FP) systems will be revised based on a fire hazards analysis. The fire hazards analysis provides a comprehensive evaluation of the facility's fire hazards, the fire protection capability relative to the identified hazards, and the ability to protect spent fuel and other radioactive materials from potential fire-induced releases. The fire hazards analysis will be reevaluated and revised as necessary to reflect the unique or different fire protection issues and strategies associated with decommissioning. It is expected that as the plants systems are drained and de-energized, the combustible loading footprint shrinks, and the hazards are removed, the FP systems, features and requirements will be reduced or eliminated.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Maintenance of Systems Critical to Decommissioning There are no currently identified mechanical systems that will be critical to the final decommissioning process. As such, mechanical systems will be abandoned after all spent fuel has been transferred to Dry Fuel Storage, with the exception of systems required to maintain habitability during dormancy. The site power distribution system will be abandoned with the possible exception of Motor Control Centers that are required to support ventilation and lighting.

The organization responsible for the final dismantlement will be expected to establish necessary temporary services, including electrical and cranes.

2.1.2 Dormancy Activities required during the early dormancy period while spent fuel is stored in the fuel pool will be substantially different than those activities required during dry fuel or no fuel storage.

Early activities include operating and maintaining the spent fuel pool and its associated systems, relocating the ISFSI, and transferring spent fuel from the pool to the ISFSI. Assuming the timely receipt of the required regulatory approvals, the construction of the consolidated ISFSI is estimated to be completed in 2020. Spent fuel transfer is expected to be complete by mid-year 2022. After the fuel transfer is completed, the pool and systems will be drained and de-energized for long-term storage.

Dormancy activities will include a 24-hour security force, an evolving risk-based emergency response program, preventive and corrective maintenance on security systems, area lighting, general building maintenance, freeze protection heating, ventilation of buildings for periodic habitability, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. A fire protection program will be maintained.

Security during the dormancy period will be conducted primarily to safeguard the spent fuel on site and prevent unauthorized entry. A security barrier, sensors, alarms, and other surveillance equipment will be maintained as required to provide security.

An environmental surveillance program will be carried out during the dormancy period to monitor for radioactive material in the environment. Appropriate procedures will be established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program will consist of a version of the program in effect during normal plant operations that will be modified to reflect the plants conditions and risks at the time.

Late in dormancy, activities will include transferring the spent fuel from the ISFSI to the DOE.

For planning purposes, ENGCs current spent fuel management plan for the PNPS spent fuel is based, in general, upon the following projections: 1) a 2030 start date for the DOE initiating transfer of commercial spent fuel to a federal facility, 2) a corresponding 2030 date for beginning to remove spent fuel from PNPS, and 3) a 2062 completion date for removal of all PNPS spent fuel. Transfer could occur earlier if the DOE is successful in implementing its current strategy for 11 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report the management and acceptance of spent fuel. 1 The ISFSI pad and facilities will be decommissioned at the time of plant decommissioning or after DOE has removed all spent fuel from the site.

2.1.3 Preparations for Decommissioning Prior to the commencement of decommissioning operations, preparations will be undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a site characterization, and the assembly of a decommissioning management organization. This will include the development of work plans, specifications and procedures.

2.1.4 Decommissioning (Dismantling and Decontamination)

Following the preparations for decommissioning, physical decommissioning activities will take place. This includes the removal and disposal of contaminated and activated components and structures, leading to the termination of the 10 CFR 50 operating license. Although much of the radioactivity will decrease during the dormancy period due to decay of 60Co and other short-lived radionuclides, the internal components of the reactor vessel will still exhibit radiation dose rates that will likely require remote sectioning under water due to the presence of long-lived radionuclides such as 94Nb, 59Ni, and 63Ni. Portions of the sacrificial shield and primary containment walls may also be radioactive due to the presence of activated trace elements with longer half-lives (such as 152Eu and 154Eu). It is assumed that radioactive contamination on structures, systems, and component surfaces will not have decayed to levels that will permit unrestricted release. These surfaces will be surveyed and items dispositioned in accordance with the existing radioactive release criteria.

Significant decommissioning activities in this phase include:

o Reconfiguration and modification of site structures and facilities, as needed, to support decommissioning operations. Modifications may also be required to the reactor or other buildings to facilitate movement of equipment and materials, support the segmentation of the reactor vessel and reactor vessel internals, and for large component removal.

o Design and fabrication of temporary and longer-term shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

o Procurement or leasing of shipping cask, cask liners, and industrial packages for the disposition of low-level radioactive waste (LLRW).

1 DOEs repository program assumes that spent fuel is accepted for disposal from the nations commercial nuclear plants in the order (queue) in which it was removed from service (oldest fuel first). The contracts that U.S.

generators have with the DOE provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst generators, and the option of providing priority acceptance from permanently shutdown nuclear reactors. Given DOEs failure to accept fuel under its contracts, it is unclear how these mechanisms will operate once DOE begins accepting spent fuel from commercial reactors. Accordingly, this PSDAR assumes that DOE will accept spent fuel in an oldest fuel first order.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report o Decontamination of components and piping systems, as required, to control (minimize) worker exposure.

o Disposition of the turbine, condenser, main steam piping, and associated equipment; with appropriate dispositioning based upon radiological surveys.

o Disposition of systems and components.

o Removal of the recirculation pumps and associated piping for controlled disposal.

o Contaminated material will be characterized and segregated for additional offsite processing (disassembly, chemical cleaning, volume reduction, and waste treatment),

and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.

o Disposition of control rod blades.

o Disassembly and segmentation of the reactor vessel internals. This will likely involve use of remotely operated equipment within the reactor cavity, covered with a contamination control envelope. The cavity water level will likely need to be maintained just below the cut to maintain the working area dose rates ALARA. Some of this material may exceed Class C (GTTC) disposal requirements. This GTTC material will be packaged for transfer to the DOE.

o Segmentation of the reactor vessel. Similar to the internals some of this work may involve the use of remotely operated equipment.

o Removal of the steel liners from the drywell, torus, refueling pool and spent fuel pool, disposing of the activated and/or contaminated sections as radioactive waste.

o Disposition of the activated and contaminated portions of the concrete sacrificial shield and primary containment walls and contaminated concrete surfaces that exceed the material release criteria.

o Material likely to be free of contamination may be surveyed and released for unrestricted disposition, e.g., as scrap, recycle, or general disposal, or sent to an off-site NRC /

Agreement State licensed processor for radiological evaluation and appropriate disposition.

o Remediation of contaminated surface soil or sub-surface media will be performed as necessary to meet the unrestricted use criteria in 10 CFR 20.1402.

o Underground piping (or similar items) and associated soil will be removed as necessary to meet license termination criteria.

At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) will be submitted to the NRC. That plan will include: a site characterization, description of the remaining dismantling / removal activities, plans for remediation of remaining radioactive materials, developed site-specific Derived Concentration Guideline Levels (DCGLs), plans for the final status (radiation) survey (FSS), designation of the end use of the site, an updated cost estimate to complete the decommissioning, and associated environmental concerns.

The FSS plan will identify the radiological surveys to be performed once the decontamination activities are completed and will be developed using the guidance provided in the Multi-Agency 13 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Radiation Survey and Site Investigation Manual (MARSSIM) (reference 14). This document incorporates statistical approaches to survey design and data evaluation. It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the FSS is complete, the results will be submitted to the NRC, along with a request for termination of the NRC license.

2.1.5 Site Restoration After the NRC terminates the license, site restoration activities will be performed. ENGC currently assumes that remaining clean structures will be removed to a nominal depth of three feet below the surrounding grade level. Affected area(s) would then be backfilled with suitable fill materials, graded, and appropriate erosion controls established. The unused portion of non-contaminated concrete rubble produced by the demolition activities will be transported to an offsite area for appropriate disposal as construction debris.

2.2 General Decommissioning Considerations 2.2.1 Major Decommissioning Activities As defined in 10 CFR 50.2, definitions, a major decommissioning activity is any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than class C waste in accordance with § 61.55. The following discussion provides a summary of the major decommissioning activities currently planned for PNPS. These activities are envisioned to occur in the Dismantling and Decontamination Period. The schedule may be modified as conditions dictate.

Prior to starting a major decommissioning activity, the affected components will be surveyed and decontaminated, as required, in order to minimize worker exposure, and a plan will be developed for the activity. Shipping casks and other equipment necessary to conduct major decommissioning activities will be procured.

The initial major decommissioning activity inside the reactor building will be the removal, packaging, and disposal of systems and components attached to the reactor.

Following reactor vessel and cavity re-flood, the reactor vessel internals will be removed from the reactor vessel and segmented, if necessary, for packaging, transport and disposal, or to separate greater than Class C (GTCC) waste. Internals classified as GTCC waste will be segmented and packaged into containers similar to spent fuel canisters for transfer to the DOE. Removal of the reactor vessel follows the removal of the reactor internals. While industry experience indicates that there may be several options available for the removal and disposal of the reactor vessel (i.e.,

segmentation or disposal as an intact package) intact removal may not be a viable option due to 14 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report transportation size and weight restrictions. If segmented it is likely that the work would be performed remotely in-air, using a contamination control envelope.

Other major decommissioning activities that would be conducted include the removal and disposal of the turbine, condenser, recirculation pumps, main steam piping, feed water piping, pumps and heaters, liners (from the spent fuel pool, drywell and reactor cavity), the torus, spent fuel storage racks and neutron activated / contaminated concrete materials. The disposition of the drywell structure would be undertaken as part of the reactor building demolition.

2.2.2 Other Decommissioning Activities In addition to the reactor and large components discussed above, all other plant components will be removed from the reactor, turbine and associated buildings, radiologically surveyed and dispositioned appropriately.

2.2.3 Decontamination and Dismantlement Activities The overall objective of D&D is to ensure that radioactively contaminated or activated materials will be removed from the site to allow the site to be released for unrestricted use. This is achieved by radioactive decay during the SAFSTOR period which will significantly reduce the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement. The disposition of remaining radioactive materials will be accomplished by the decontamination and/or dismantlement of contaminated structures. This may be accomplished by decontamination in place, off-site processing of the materials, or direct disposal of the materials as radioactive waste. A combination of these methods may be utilized. The methods chosen will be those deemed most appropriate for the particular circumstances.

Low-level radioactive waste (LLRW) will be managed in accordance with approved procedures and commercial disposal facility requirements. This includes characterizing contaminated materials, packaging, transporting and disposal at a licensed LLRW disposal facility.

2.2.4 Radioactive Waste Management A major component of the decommissioning work scope for PNPS is the packaging, transportation and disposing of primarily contaminated / activated equipment, piping, concrete, and soil. A waste management plan will be developed to incorporate the most cost effective disposal strategy, consistent with regulatory requirements and disposal / processing options for each waste type at the time of the D&D activities. Because it is located in Massachusetts, PNPS is not affiliated with a waste compact agreement. As such, PNPS wastes may be disposed of at any available licensed LLRW facilities that engage in an agreement with PNPS. LLRW from PNPS will be transported by licensed transporters. The waste management plan will be based on the evaluation of available methods and strategies for processing, packaging, and transporting radioactive waste in conjunction with the available disposal facility options and associated waste acceptance criteria.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 2.2.5 Removal of Mixed Wastes If mixed wastes are generated they will be managed in accordance with applicable Federal and State regulations.

Mixed wastes from PNPS will be transported by authorized and licensed transporters and shipped to authorized and licensed facilities. If technology, resources, and approved processes are available, the processes will be evaluated to render the mixed waste non-hazardous.

2.2.6 Site Characterization During the decommissioning process, site characterization will be performed in which radiological, regulated, and hazardous wastes will be identified, categorized, and quantified.

Surveys will be conducted to establish the contamination and radiation levels throughout the plant.

This information will be used in developing procedures to ensure that hazardous, regulated, and radiologically contaminated areas are remediated and to ensure that worker exposure is controlled.

As decontamination and dismantlement work proceeds, surveys will be conducted to maintain a current site characterization and to ensure that decommissioning activities are adjusted accordingly.

As part of the site characterization process, a neutron activation analysis calculation study of the reactor internals, the reactor vessel, and the biological shield wall was performed. Using the results of this analysis (along with benchmarking surveys), neutron irradiated components will be classified (projected for the future D&D time-frame) in accordance with 10 CFR 61, Licensing requirements for land disposal of radioactive waste. The results of the analysis will form the basis of the plans for removal, segmentation, packaging and disposal.

2.2.7 Groundwater Protection and Radiological Decommissioning Records Program A groundwater (GW) protection program currently exists at PNPS in accordance with the Nuclear Energy Institute (NEI) Technical Report 07-07, Industry Groundwater Protection Initiative - Final Guidance Document. A site hydrology study was completed as part of this initiative. Twenty-five (25) groundwater monitoring wells were installed around the plant to identify any leakage and transport of radiological contaminants. Twenty-three (23) of these wells are currently operational (one was abandoned due to location, and one was replaced due to poor functionality). This program is directed by procedures and will continue during decommissioning.

ENOI will also continue to maintain the existing radiological decommissioning records program required by 10 CFR 50.75(g). The program is directed by procedures.

Neither the monitoring results of the groundwater protection program nor events noted in 10 CFR 50.75(g) indicate the presence of long-lived radionuclides in sufficient concentrations following remediation as needed to preclude unrestricted release under 10 CFR 20.1402, "Radiological criteria for unrestricted use."

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 2.2.8 Changes to Management and Staffing Throughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization. Staffing levels and qualifications of personnel used to monitor and maintain the plant during the various periods after plant shutdown will be subject to appropriate Quality, Technical Specification, Security and Emergency Plan requirements. The future worker dynamic will be comprised of both in-house and contract employees. The duties of this combined workforce include fuel movements, plant modifications in preparation for SAFSTOR, and D&D / license termination / site restoration work. Contractors may also be used to provide general services, staff augmentation or replace permanent staff. The monitoring and maintenance staff will be comprised of radiation protection, REMP, plant engineering and craft workers as appropriate for the anticipated work activities.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 3.0 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES ENGC intends to pursue the decommissioning of PNPS utilizing a SAFSTOR methodology. The SAFSTOR method involves removal of radioactively contaminated or activated material from the site following an extended period of dormancy. Work activities associated with the planning and preparation period began before the plant was permanently shut down and will continue through mid-2019. The schedule of spent fuel management and major decommissioning activities is provided in Table 2-1. Additional detail is provided in Attachment 1, the DCE.

The schedule accounts for spent fuel being stored in the ISFSI until the assumed date of transfer to the DOE.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 4.0 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS 10 CFR 50.82(a)(4)(i) requires the submission of a PSDAR either before or not later than two years after permanent cessation of operations. TLG Services, Inc. has prepared a site-specific decommissioning cost analysis for PNPS, which also provides projected costs of managing spent fuel, as well as non-radiological decommissioning and site restoration costs, accounted for separately. The site-specific DCE is provided in Attachment 1 and fulfills the requirements of 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). A summary of the site-specific DCE, including the projected cost of managing spent fuel is provided in Table 2-2. The site-specific DCE, from which this table was derived, is provided as Attachment 1.

The methodology used by TLG Services, Inc. to develop the site-specific DCE follows the basic approach originally advanced by the Atomic Industrial Forum (AIF) in its program to develop a standardized model for decommissioning cost estimates. The results of this program were published as AIF/NESP-036, A Guideline for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, (Reference 4). The AIF document presents a unit cost factor method for estimating direct activity costs, simplifying the estimating process. The unit cost factors used in the study reflect the latest available data, at the time of the study, concerning worker productivity during decommissioning.

Under NRC regulations (10 CFR § 50.82(a)(8)), a licensee must provide reasonable assurance that funds will be available (or financial assurance) for decommissioning (i.e., license termination) costs. The regulations also describe the acceptable methods a licensee can use to demonstrate financial assurance. Most licensees do this by funding a nuclear decommissioning trust (NDT).

The NRC methodology limits the projected growth rate of the funds in the NDT to 2% per year (real, not nominal). ENGC uses an NDT for this purpose. The trust was transferred with the decommissioning liability as part of the sale transaction when Entergy acquired the plant. The trustee is The Bank of New York Mellon. The trust had a balance of $1,051,722,466 at of the end of October 2018.

10 CFR 50.82(a)(6)(iii) states that, Licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2 that, Result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. ENGC does not intend to perform any decommissioning activities that result in there no longer being reasonable assurance that adequate funds will be available for decommissioning.

10 CFR 50.82(a)(8)(iv) states that, For decommissioning activities that delay completion of decommissioning by including a period of storage or surveillance, the licensee shall provide a means of adjusting cost estimates and associated funding levels over the storage or surveillance period.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 4.1 Means of Adjusting Cost Estimates The PNPS SAFSTOR schedule and the associated site-specific cost estimate summarized in Tables 2.1 and 2.2 and detailed in the DCE (Attachment 1) is reported in 2018 dollars using up-to-date 2018 pricing. ENOI will update the PNPS DCE as required by procedure and regulation. In calculating projected earnings, ENGC will apply a compounded 2% real rate of return on the trust fund per 10 CFR 50.75 (e). In accordance with 10 CFR 50.82(a)(8)(v)-(vii), ENOI will provide annual reports projecting the cost to complete decommissioning and spent fuel management costs.

4.2 Means of Adjusting Associated Funding Levels During the SAFSTOR period, the site-specific DCE will be periodically updated in compliance with ENOI procedures and applicable regulatory requirements. In accordance with 10 CFR 50.82(a)(8)(v), decommissioning funding assurance will be reviewed and reported to the NRC annually during the SAFSTOR period. The latest site-specific DCE adjusted for inflation, in accordance with applicable regulatory requirements, will be used to demonstrate funding assurance. In addition, actual radiological and spent fuel management expenses will be included in the annual report in accordance with the applicable regulatory requirements.

If the funding assurance demonstration shows the DTF is not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in Regulatory Guide 1.159 (Reference 5) will be put in place.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report 5.0 ENVIRONMENTAL IMPACTS ENGC has concluded that the environmental impacts associated with planned PNPS site-specific decommissioning activities are less than and bounded by the impacts addressed by previously issued environmental impact statements. 10 CFR 50.82(a)(4)(i) requires that the PSDAR include,

"...a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements." The following discussion provides the reasons for reaching this conclusion and is based on two previously issued environmental impact statements:

1. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (Reference 3) (Referred to as the GEIS).

2. NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities (Reference 6).

In evaluating whether the impacts in these previously issued environmental impact statements are bounding, information from NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 29, Regarding Pilgrim Nuclear Power Station (Reference

7) was also considered.

5.1 Environmental Impact of PNPS Decommissioning The following is a summary of the reasons for reaching the conclusion that the environmental impacts of decommissioning Pilgrim Nuclear Power Station (PNPS) are bounded by the GEIS.

Each environmental impact standard in the GEIS is listed along with an explanation as to why ENGC concludes the GEIS analysis bounds the impacts of PNPS decommissioning on that standard. As a general matter, PNPS is smaller than the reference boiling water reactor used in the GEIS to evaluate the environmental impacts of decommissioning, and is therefore bounded by those assessments. Further, no unique site-specific features or unique aspects of the planned decommissioning have been identified.

5.1.1 Onsite/Offsite Land Use Section 4.3.1 of the GEIS concluded that the impacts on land use are not detectable or small for facilities having only onsite land use changes as a result of large component removal, structure dismantlement, and low-level waste packaging and storage. PNPS has sufficient area onsite that has been previously disturbed (due to construction or operations activities) upon which to conduct all of these decommissioning activities. Any construction activities that would disturb one acre or greater of soil would require a construction storm water permit per the current EPA regulations 21 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report (EPA-2017). The storm water permit would contain best management practices (BMPs) to control sediment and erosion effect on water courses and wetlands.

Based on the GEIS, the experience of plants that are being decommissioned has not included any needs for additional land offsite. Consistent with this determination, ENGC does not anticipate any changes in land use beyond the site boundary during decommissioning. Therefore, ENGC concludes that the impacts of PNPS decommissioning on onsite/offsite land use are bounded by the GEIS.

5.1.2 Water Use After plant shutdown, the operational demand for cooling water and makeup water will dramatically decrease. Additionally, after the plant is shut down and defueled, the amount of water used by the service water system will be much less than during normal operation of the plant. The need for cooling water will continue to decrease as the heat load of spent fuel in the spent fuel pool declines due to radioactive decay and as spent fuel is relocated from the spent fuel pool to the ISFSI. During plant shutdown, the use of potable water will decrease commensurate with the expected decrease in plant staffing levels. For these reasons, Section 4.3.2 of the GEIS concluded that water use at decommissioning nuclear reactor facilities is significantly smaller than water use during operation.

The GEIS also concluded that water use during the decontamination and dismantlement phase will be greater than that during the storage phase. However, there are no unique aspects associated with the decommissioning of PNPS and water use for such activities as flushing piping, high pressure water washing, dust abatement, etc. Consequently, PNPS water use impacts were addressed by the evaluation of the reference facility in the GEIS.

Therefore, ENGC concludes that the impacts of PNPS decommissioning on water use are bounded by the GEIS.

5.1.3 Water Quality This section considers water quality impacts of nonradioactive material for both surface and groundwater during the decommissioning process. Table E-3 of the GEIS identifies decommissioning activities that may affect water quality. These activities include system deactivation activities (draining, flushing, and liquid processing) as well as facility decontamination and dismantlement activities (water spraying for dust suppression). The GEIS also emphasizes the need to minimize water infiltration during the SAFSTOR period.

ENGC has chosen to decommission PNPS using the SAFSTOR method. During the SAFSTOR planning and actual storage periods, storm water runoff and drainage paths will be maintained in 22 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report their current configuration. Regulatory mandated programs and processes designed to minimize, detect, and contain spills will be maintained throughout the decommissioning process. Federal, state and local regulations and permits pertaining to water quality will remain in effect and no significant changes to water supply reliability are expected. The National Pollutant Discharge Elimination System (NPDES) permit, which regulates surface water discharges from the site (Reference 8) will remain in place as will the Groundwater Discharge Permit for the PNPS Wastewater Treatment Facility (Reference 9). ENOI concludes that the impacts of PNPS decommissioning on water quality are bounded by the GEIS.

5.1.4 Air Quality There are many types of decommissioning activities listed in Section 4.3.4 of the GEIS that have the potential to affect air quality. NRC considered the potential for adverse impacts from these activities, the greatest of which would be fugitive dust, for the range of decommissioning plants and generically determined air quality impacts to be small. For those activities applicable to the SAFSTOR option, ENGC does not anticipate any activities beyond those listed in the GEIS that could potentially affect air quality. Also, reasonable and appropriate control measures such as wetting down unpaved areas, wetting of soil piles, covering loads and staging areas, and seeding of bare areas would be implemented to minimize fugitive dust. In addition, federal, state and local regulations pertaining to air quality will remain in effect to regulate emissions associated with criteria air pollutants, hazardous air pollutants, ozone-depleting gases and fugitive dust. Therefore, ENGC concludes that the impacts of PNPS decommissioning on air quality are bounded by the GEIS.

5.1.5 Aquatic Ecology Aquatic ecology encompasses the plants and animals in the Atlantic Coastal Area near Cape Cod Bay and other wetlands near PNPS. Aquatic ecology also includes the interaction of those organisms with each other and the environment. Section 4.3.5 of the GEIS evaluates both the direct and indirect impacts from decommissioning on aquatic ecology.

Direct impacts can result from activities such as the removal of shoreline structures or the active dredging of canals. PNPS's shoreline structures are similar to the plants listed in Table E-2 of the GEIS, and there are no apparent discriminators based on the salient characteristics (size and location) listed in Table E-5 of the GEIS. Removal of the intake and discharge structures as well as other shoreline structures will be conducted in accordance with BMPs outlined in permits issued by the Massachusetts Department of Environmental Protection and if necessary, the U. S. Army Corps of Engineers. The intake canal dredging should no longer be required due to the diminished residual heat removal requirements, and the eventual relocation of the spent fuel to the ISFSI.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report As previously discussed in Section 5.1.2, the amount of cooling water withdrawn from the Atlantic Ocean will significantly decrease thus reducing the potential impacts from impingement and entrainment of aquatic species. Additionally, any significant potential for sediment runoff or erosion on disturbed areas will be controlled in accordance with BMPs outlined in the storm water permit. ENOI does not anticipate disturbance of lands beyond the current operational areas of the plant, so there should not be any new impacts to aquatic ecology from runoff associated with land disturbance activities.

Therefore, ENOI concludes that the impacts of PNPS decommissioning on aquatic ecology are bounded by the GEIS.

5.1.6 Terrestrial Ecology Terrestrial ecology considers the plants and animals in the vicinity of PNPS as well as the interaction of those organisms with each other and the environment. Evaluations of impacts to terrestrial ecology are usually directed at important habitats and species, including plant and animals that are important to industry, recreational activities, the area ecosystems, and those protected by endangered species regulations and legislation. Section 4.3.6 of the GEIS evaluates the potential impacts from both direct and indirect disturbance of terrestrial ecology.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland.

ENGC does not anticipate that any decommissioning activities, including ISFSI construction, will disturb habitat beyond the industrial area of the plant. All dismantlement, demolition, and waste staging activities are expected to be conducted within this industrial area of the site. Also the EPA controls significant impacts to the environment through regulation of construction activities.

Indirect impacts may result from effects such as erosional runoff, dust or noise. Any construction activities that would disturb one acre or greater of soil would require a permit from the EPA prior to proceeding with the activity. The storm water permit would contain BMPs to control sediment and the effects of erosion associated with the construction activity. Fugitive dust emissions would be controlled through the judicious use of water spraying. The basis for concluding that the environmental impacts of noise are bounded by the GEIS is discussed in Section 5.1.16 below.

5.1.7 Threatened and Endangered Species As previously discussed in Section 5.0, the PNPS facility occupies approximately 140 acres.

ENGC also owns an additional 1,500 acres adjacent to the plant site that is in a forest management plan. However, these 1,500 acres are not considered part of the PNPS industrial area. Therefore, evaluation of decommissioning impacts is limited to the 140 acres occupied by the PNPS facility.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Protected Terrestrial Species There are five federally and/or state-listed terrestrial species within Plymouth County, including three birds, one reptile and one mammal as shown in Table 5.1-1 below.

TABLE 5.1 Protected Terrestrial Species, Plymouth County Species Scientific Name Federal Status State Status Birds Piping Plover Charadrius melodus Threatened Threatened Red Knot Calidris canutus Threatened Not listed Roseate Tern Sterna dougallii Endangered Endangered Reptile Northern Red-bellied Pseudemys rubriventris Endangered Endangered Cooter Mammal Northern Long-eared Myotis septentrionalis Threatened Endangered Bat (USFWS 2017a; MESA 2017)

Of the species listed above, two birds (piping plover and roseate tern), and one reptile (northern red-bellied cotter) were identified in Supplement 29 to the GEIS regarding PNPS (PNPS SEIS) as occurring within the vicinity of the facility (Reference 7, Section 2.2.6.3). Although the piping plover and roseate tern occur in the vicinity of the facility, they are not dependent on habitats within the facility (Reference 7, Section 4.6.2), and are unlikely to be affected by decommissioning activities. The northern red-bellied cooter inhabits freshwater ponds that have abundant aquatic vegetation. Sandy soil with an open canopy on land surrounding the ponds is required for successful nesting. (Reference 7, Section 2.2.6.3) No such habitat exists on the PNPS property; therefore, this species will not be affected by decommissioning activities.

The red knot prefers coastal beaches and rocky shores, sand and mud flats. However, this bird species is migratory only, scattered along the coast in small numbers. (USWS 2016) The northern long-eared bat prefers mines and caves during the winter, and forested habitats during the summer.

Since suitable habitat for the red knot and northern long-eared bat does not exist on the PNPS operational area, they are unlikely to be affected by decommissioning activities.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Based on the PNPS SEIS, there were approximately 73 additional species within the Town of Plymouth that are State-listed as endangered, threatened, or of special concern in Massachusetts.

Approximately 22 of the State-listed species potentially could utilize habitats available on the PNPS site or the transmission line ROW based on their preferred habitat characteristics; however, their presence has not been confirmed. (Reference 7, Section 2.2.6.3 and Table 2.5)

Decommissioning activities with the greatest potential for affecting terrestrial plant and animal communities are those scheduled for late phases, when major reactor structures are to be removed, and the cooling water intake and discharge structures are to be demolished. The discharge canal itself and the breakwater wall will remain in place. As discussed in Section 5.1.1, land within the operational area is sufficient to provide space for laydown yards, equipment or materials storage, temporary offices, and other decommissioning support areas or structures. Current parking facilities have been adequate to support refueling and maintenance outages over the years, and are assumed to be adequate to support decommissioning.

Because there is ample open space to support PNPS decommissioning operations, there would be no reason to clear any land outside of the site operational area. Therefore, there would be no impacts to wildlife, such as destruction or degradation of existing habitat.

All decommissioning activities at PNPS will take place within the site operational area; therefore, impacts to terrestrial ecological resources, including threatened and endangered species, are expected to be small. State and federal resource agency staff would be consulted at the appropriate time to rule out the presence of previously undiscovered/unreported threatened or endangered species, and, if present, to ascertain if any mitigation measures are warranted.

Section 5.1.6 contains a more detailed discussion of potential impacts of decommissioning activities on (non-protected) terrestrial resources, and also concludes impacts would be bounded by the Decommissioning GEIS's finding of small impacts.

Protected Aquatic Species Eleven federally and/or state-listed anadromous and marine species could occur in Cape Cod Bay in the vicinity of PNPS, including four sea turtles, five whales, and two fishes as shown in Table 5.2 below.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report TABLE 5.2 Protected Aquatic Species Species Scientific Name Federal Status State Status Turtles Loggerhead Turtle Caretta caretta Threatened Threatened Green Turtle Chelonia mydas Threatened Threatened Leatherback Turtle Dermochelys coriacea Endangered Endangered Kemp's Ridley Turtle Lepidochelys kempii Endangered Endangered Whales Sei Whale Balaenoptera borealis Endangered Endangered Fin Whale Balaenoptera physalus Endangered Endangered Blue Whale Balaenoptera musculus Endangered Endangered North Atlantic Right Whale Eubalaena glacialis Endangered Endangered Sperm Whale(a) Physeter catadon Endangered Endangered Fish Shortnose Sturgeon Acipenser brevirostrum Endangered Endangered Acipenser oxyrinchus Atlantic Sturgeon Threatened Endangered oxyrinchus (Reference 7, Table 2-4; MESA 2017; USFWS 2017b; USFWS 2017c; USFWS 2017d)

(a) The sperm whale has two accepted scientific names: Physeter catadon and P. microcephalus.

The endangered North Atlantic Right Whale and Sei Whale have recently been sighted in the shallow waters of Cape Cod Bay. PNPS has adopted procedures for reporting whale sightings in response to this development in cooperation with the U.S. Army Corps of Engineers. A live loggerhead turtle sighting was also reported in the bay approximately 4 miles offshore from the Pilgrim Plant in August 2018. Considering these new developments and in keeping with our commitment to environment and endangered species, PNPS acknowledges that it is possible for any of the listed species to occasionally appear in the vicinity of the Pilgrim Station. PNPS does not intend to disturb the canal and breakwater structures. The Massachusetts Department of Environmental Protection and/or the U. S. Army Corps of Engineers will evaluate and issue the permit(s) outlining BMP(s) for the removal of the intake and discharge systems in the later phases of decommissioning.

Conclusion Section 4.3.7 of the GEIS also suggests that care be exercised in conducting decommissioning activities after an extended SAFSTOR period because there is a greater potential for rare species 27 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report to colonize the disturbed portion of the site. However as previously discussed, procedural administrative controls and federal and state regulations that will remain in effect would ensure that mitigation measures are implemented as appropriate to protect wildlife.

NRC has determined that potential impacts of decommissioning on threatened and endangered species must be evaluated on a site-specific basis. ENGC has determined that none of the planned decommissioning activities at PNPS would encroach on the habitat of any state or federally listed species. Any indirect (disturbance-related) impacts from construction noise and human activity would be localized, of short duration, and ecologically insignificant. Birds and mammals that are intolerant of noise and human activity are expected to simply avoid (or move away from) noisy construction sites. ENGC therefore concludes that adverse impacts to threatened and endangered species from PNPS decommissioning activities would be small. However, as decommissioning plans mature, ENOI will update the PSDAR in accordance with applicable NRC regulations if relevant threatened and endangered species listings and critical habitat designations are revised.

Based on the above, the planned decommissioning of PNPS will not result in a direct mortality or otherwise jeopardize the local population of any threatened or endangered species.

5.1.8 Radiological The GEIS considered radiological doses to workers and members of the public when evaluating the potential consequences of decommissioning activities.

Occupational Dose The occupational radiation exposure to PNPS plant personnel will be maintained As Low As Reasonably Achievable (ALARA) and below the occupational dose limits in 10 CFR Part 20 during decommissioning. The need for plant personnel to routinely enter radiological areas to conduct maintenance, calibration, inspection, and other activities associated with an operating plant will be reduced, thus it is expected that the occupational dose to plant personnel will significantly decrease after the plant is shut down and defueled. The station ALARA program will be maintained during dormancy and the D&D periods to ensure that occupational dose is maintained ALARA and well within 10 CFR Part 20 limits.

ENGC has elected to decommission PNPS using the SAFSTOR alternative. It is expected that the occupational dose required to complete the decommissioning activities at PNPS would be reduced significantly by radioactive decay during the SAFSTOR period. ENGC estimates that the occupation radiation exposure would be 823, 111, and 80 person-rem, after SAFSTOR dormancy periods of 10, 30 and 50 years respectively. This estimate is based on an analysis of area by area decommissioning worker occupancy, current radiation levels and projected radionuclide decay.

28 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report The estimates for dormancy periods greater than 10 years are within the range of SAFSTOR dose estimates (326-834 person-rem) provided in Table 4-1 of the Decommissioning GEIS.

Public Dose Section 4.3.8 of the GEIS considered doses from liquid and gaseous effluents when evaluating the potential impacts of decommissioning activities on the public. Table G-15 of the GEIS compared effluent releases between operating facilities and decommissioning facilities and concluded that decommissioning releases are lower. The GEIS also concluded that the collective dose and the dose to the maximally exposed individual from decommissioning activities are expected to be well within the regulatory standards in 10 CFR Part 20 and Part 50.

The expected radiation dose to the public from PNPS decommissioning activities will be maintained within regulatory limits and below comparable levels when the plant was operating through the continued application of radiation protection and contamination controls combined with the reduced source term available in the facility. Also Section 7.1 of the SEIS (Reference 7) concluded that there were no site-specific radiological dose aspects associated with decommissioning of PNPS. Therefore, ENGC concludes that the impacts of PNPS decommissioning on public dose are small and are bounded by the GEIS.

5.1.9 Radiological Accidents The likelihood of a large offsite radiological release that impacts public health and safety after PNPS is shut down and defueled is considerably lower than the already very low likelihood of a release from the plant during power operation. This is because the majority of the potential releases associated with power operation are not relevant after the fuel has been removed from the reactor.

Furthermore, handling of spent fuel assemblies will continue to be controlled under work procedures designed to minimize the likelihood and consequences of a fuel handling accident. In addition, emergency plans and procedures will remain in place to protect the health and safety of the public while the possibility of significant radiological releases exists.

Section 4.3.9 of the GEIS assessed the range of possible radiological accidents during decommissioning and separated them into two general categories; fuel related accidents and non-fuel related accidents. Fuel related accidents have the potential to be more severe and zirconium fire accidents, in particular, could produce offsite doses that exceed EPA's protective action guides (Reference 14). As part of its effort to develop generic, risk-informed requirements for decommissioning, the NRC staff performed analysis of the offsite radiological consequences of beyond-design-basis spent fuel pool accidents using fission product inventories at 30 and 90 days and 2, 5, and 10 years. The results of the study indicate that the risk at spent fuel pools is low and 29 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report well within the NRCs Quantitative Health Objectives. The generic risk is low primarily due to the very low likelihood of a zirconium fire. (Reference 3)

The potential for decommissioning activities to result in radiological releases not involving spent fuel (i.e., releases related to decontamination, dismantlement, and waste handling activities) will be minimized by use of procedures designed to minimize the likelihood and consequences of such releases.

Therefore, ENGC concludes that the impacts of PNPS decommissioning on radiological accidents are small and are bounded by the previously issued GEIS.

5.1.10 Occupational Issues Occupational issues are related to human health and safety. Section 4.3.10 of the GEIS evaluates physical, chemical, ergonomic, and biological hazards. ENGC has reviewed these occupational hazards in the GEIS and concluded that the decommissioning approach chosen for PNPS poses no unique hazards from what was evaluated in the GEIS. ENGC will continue to maintain appropriate administrative controls and requirements to ensure occupational hazards are minimized and that applicable federal, state and local occupational safety standards and requirements continue to be met. Therefore, ENGC concludes that the impacts of PNPS decommissioning on occupational issues are bounded by the GEIS.

5.1.11 Cost Decommissioning costs for PNPS are discussed in Section 4.0 and in Attachment 1 to this report.

Section 4.3.11 of the GEIS recognizes that an evaluation of decommissioning cost is not a National Environmental Policy Act requirement. Therefore, a bounding analysis is not applicable.

5.1.12 Socioeconomics Decommissioning of PNPS is expected to result in negative socioeconomic impacts. As PNPS transitions from an operating plant to a shutdown plant and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff will result in decreases in revenues available to support the local economy and local tax authorities.

Some laid-off workers may relocate, thus potentially impacting the local cost of housing and availability of public services.

Section 4.3.12 of the GEIS evaluated changes in workforce and population, changes in local tax revenues, and changes in public services. The evaluation also examined plants that permanently shut down early and selected the SAFSTOR option. The GEIS determined that this situation is likely to have negative impacts. The GEIS concluded that socioeconomic impacts are neither 30 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report detectable nor destabilizing and that mitigation measures are not warranted. Therefore, ENGC concludes that the impacts of PNPS decommissioning on socioeconomic impacts are bounded by the GEIS.

5.1.13 Environmental Justice Executive Order 12898 dated February 16, 1994, directs Federal executive agencies to consider environmental justice under the National Environmental Policy Act. It is designed to ensure that low-income and minority populations do not experience disproportionately high and adverse human health or environmental effects because of Federal actions.

Section 4.4.6 of the SEIS (Reference 7) analyzed 2000 census data within 50 miles of PNPS to identify minority and low income populations. The SEIS analysis concluded that there were no census block groups within the 6-mile PNPS region that exceeded the NRC thresholds defining minority populations. The closest census block groups that exceeded the NRC minority population thresholds was located 25 miles northwest of PNPS in Massachusetts. The closest census block group exceeding the threshold defining a low-income population was in the same location 25 miles northwest of the PNPS Site. The analysis was based on 2000 census data and remains valid for this decommissioning analysis because the population in the PNPS region has not changed appreciably since 2000.

TABLE 5.3 Plymouth and Barnstable Counties Updated Population Growth, 2000-2015 Plymouth County Barnstable County Percent Annual Percent Annual Year Population Population Growth Growth 2000 472,822(a) ----- 222,230(a) -----

2010 494,919(b) 0.5 215,888(c) -0.3 2015 Estimate 510,393(b) 0.6 214,333(c) -0.1 (a) Reference 7, Table 2-13 (b)USCB 2017a (c)USCB 2017b Section 4.13.3 of the GEIS reviewed environmental justice decommissioning impacts related to land use, environmental and human health, and socioeconomics. ENGC does not anticipate any 31 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report offsite land disturbances during decommissioning, thus the land use impacts are not applicable for PNPS. In addition as previously discussed in Section 5.1.12, it was determined that socioeconomic impacts from decommissioning are bounded by the GEIS. Potential impacts to minority and low-income populations would mostly consist of radiological effects. Based on the radiological environmental monitoring program data from PNPS, the SEIS determined that the radiation and radioactivity in the environmental media monitored around the plant have been well within applicable regulatory limits. As a result, the SEIS found that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations (i.e.,

minority and/or low income populations) in the region as a result of subsistence consumption of water, local food, fish, and wildlife.

Therefore, ENGC concludes that the impacts of PNPS decommissioning on environmental justice are small and are bounded by the GEIS.

5.1.14 Cultural, Historic, and Archeological Resources In 1972, in advance of construction of the station, an archaeological survey was conducted of the 517 acre parcel of land on which the PNPS facility and the Jordan Road transmission line were proposed. This survey was conducted by the Archaeological Research Department of Plymouth Plantation and the Brown University Department of Anthropology. This survey identified a total of 25 archaeological sites: 24 historic sites and one prehistoric site. The 24 historic sites were determined to not be significant and no further work was recommended. The one prehistoric site was the subject of a more intensive investigation, which concluded that the site was not eligible for listing. This more intensive archaeological survey, conducted by the two previously mentioned groups in collaboration with the Massachusetts Archaeological Society, further concluded that the land around the proposed power station site showed no evidence of prehistoric occupation.

(Reference 7, Section 2.2.9.2.1)

During the renewal of the PNPS operating license, NRC determined that there were no National Register eligible or listed archaeological or historic above ground resources identified on the PNPS site based on a review of the Massachusetts Historical Commission files. The 1972 archaeological survey identified 25 archaeological sites (24 historic and one prehistoric), all of which were eventually determined to be ineligible for listing on the National Register. This testing also concluded that there is no evidence of prehistoric occupation in the area around the station (Reference 7, Section 4.4.5.1).

The NRC's conclusion was based on: 1) no prehistoric archaeological sites have been identified on the PNPS property, and 2) environmental review procedures have been put in place at PNPS regarding undertakings that involve land disturbing activities in undisturbed surface and subsurface areas as well as modifications to historic structures.

32 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report The cultural, historic, and archeological impact evaluation conducted in the GEIS (Reference 6) focused on similar attributes as the SEIS (Reference 7). The GEIS evaluated direct effects such as land clearing and indirect effects such as erosion and siltation. The conclusion for the license renewal evaluation is also applicable to the decommissioning period because: 1) decommissioning activities will be primarily contained to disturbed areas located away from areas of existing or high potential for archaeological sites 2) construction activities that disturb one acre or greater of soil are permitted by EPA and BMPs are required to control sediment and the effects of erosion, and

3) environmental protection procedures pertaining to archaeological and cultural resources will remain in effect during decommissioning.

Therefore, ENGC concludes that the impacts of PNPS decommissioning on cultural, historic, and archeological resources are small and are bounded by the GEIS.

5.1.15 Aesthetic Issues During decommissioning, the impact of activities on aesthetic resources will be temporary and remain consistent with the aesthetics of an industrial plant. In most cases, Section 4.3.15 of the GEIS concludes that impacts such as dust, construction disarray, and noise would not easily be detectable offsite.

The GEIS concluded that the retention of structures during a SAFSTOR period or the retention of structures onsite at the time the license is terminated is likewise not an increased visual impact, but instead a continuation of the visual impact analyzed in the facility construction or operations final environmental statement.

After the decommissioning process is complete, site restoration activities will result in structures being removed from the site and the site being backfilled, graded and landscaped as needed. The GEIS concludes that the removal of structures is generally considered beneficial to the aesthetic impacts of the site.

Therefore, ENGC concludes that the impacts of PNPS decommissioning on aesthetic issues are bounded by the GEIS.

5.1.16 Noise General noise levels during the decommissioning process are not expected to be any more severe than during refueling outages and are not expected to present an audible intrusion on the surrounding community. Some decommissioning activities may result in higher than normal onsite noise levels (i.e., some types of demolition activities). However, these noise levels would be temporary and are not expected to experience an audible intrusion on the surrounding community.

33 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report Section 4.3.16 of the GEIS indicates that noise impacts are not detectable or destabilizing and makes a generic conclusion that potential noise impacts are small. Based on the standard decommissioning approach proposed for PNPS, ENGC concludes that the impacts of PNPS decommissioning on noise are bounded by the GEIS.

5.1.17 Transportation The transportation impacts of decommissioning are dependent on the number of shipments to and from the plant, the types of shipments, the distance the material is shipped, and the radiological waste quantities and disposal plans. The shipments to and from the plant would primarily result from construction activities associated with the ISFSI relocation and shipments of radioactive wastes and non-radioactive wastes associated with dismantlement and disposal of structures, systems and components.

The estimated cubic feet of radioactive waste associated with PNPS decommissioning that will either be processed, destined for land disposal (Class A, B and C), or placed in a geologic repository (Greater than Class C) is summarized as follows:

x Recycle/Potentially contaminated waste: 596,942 cubic feet x Class A: 262,602 cubic feet x Class B: 1,753 cubic feet x Class C: 742 cubic feet x Greater than Class C (GTCC): 817 cubic feet Table 4-7 of the GEIS estimated that the volume of land needed for LLRW (Class A, B and C) disposal from the referenced BWR was 636,000 cubic feet under the SAFSTOR alternative. ENGC presently estimates the LLRW volume of Class A, B, and C (other than recycle waste) for PNPS that is destined for shallow land disposal is approximately 265,097 cubic feet using the SAFSTOR alternative which is far below the GEIS bounding volume.

The quantity of recycle/potentially contaminated waste reflects the volume of bulk material such as ductwork before it is processed. This recycle / potentially contaminated waste volume (596,942 cubic feet) is shipped off-site to a licensed waste processing vendor for volume reduction, survey and release, decontamination, segregation, or other appropriate methods of waste minimization.

Recycle waste before processing is expected to comprise 69 percent of the overall PNPS waste volume and would have negligible radiological impacts. The current Decommissioning GEIS does not consider recycle waste.

ENGC must comply with applicable regulations when shipping radioactive waste from decommissioning. The NRC has concluded in Section 4.3.17 of the GEIS that these regulations 34 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report are adequate to protect the public against unreasonable risk from the transportation of radioactive materials.

The number of GTCC waste shipments during decommissioning is expected to be below the number referenced in Table 4-6 of the GEIS. These shipments will occur over an extended period of time and will not result in significant changes to local traffic density or patterns, the need for construction of new methods of transportation, or significant dose to workers or the public.

In addition, shipments of non-radioactive wastes from the site are not expected to result in measurable deterioration of affected roads or a destabilizing increase in traffic density.

Therefore, ENGC concludes that the impacts of PNPS decommissioning on transportation are bounded by the GEIS.

5.1.18 Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot be recovered, and irretrievable commitments of resources are those that are lost for only a period of time.

Uranium is a natural resource that is irretrievably consumed during power operation. After the plant is shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short-term investment. Since the PNPS site will be decommissioned to meet the unrestricted release criteria found in 10 CFR 20.1402, the land is not considered an irreversible resource. The only irretrievable resources that would occur during decommissioning would be materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools), and the fuel used for decommissioning activities and transportation of materials to and from the site. However, the use of these resources is minor.

While the GEIS does not specify quantitative bounds for commitment of irreversible and irretrievable resources, ENGC concludes that the impacts of PNPS decommissioning on these resources are negligible and consistent with the conclusions of the GEIS.

5.2 Environmental Impacts of License Termination - NUREG-1496 According to the schedule provided in Section 3 of this report, a license termination plan for PNPS will not be developed until approximately two years prior to the final site decontamination which is currently assumed to be approximately the year 2078. At that time, a supplemental environmental report will be submitted as required by 10 CFR 50.82(a)(9).

While detailed planning for license termination activities will not be performed until after the SAFSTOR dormancy period, the absence of any unique site-specific factors, significant 35 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report groundwater contamination, unusual demographics, or impediments to achieving unrestricted release support an expectation that impacts resulting from license termination will be similar to those evaluated in NUREG-1496 (Reference 6).

5.3 Discussion of Decommissioning in the Supplemental Environmental Impact Statement (SEIS)

As part of the PNPS license renewal process, decommissioning was discussed in Section 7.0 of the SEIS (Reference 7). Identified were six issues related to decommissioning as follows:

x Radiation Doses x Waste Management x Air Quality x Water Quality x Ecological Resources x Socioeconomic Impacts The NRC staff did not identify any new and significant information during their independent review of the PNPS license renewal environmental report (Reference 11), the site audit, or the scoping process for license renewal. The NRC concluded that there are no impacts related to these issues beyond those discussed in the GEIS for license renewal (Reference 12) or the GEIS for decommissioning (Reference 3). For the issues identified above, the license renewal and decommissioning GEISs both concluded the impacts are small. The NRC found no site-specific issues related to decommissioning. There are no contemplated decommissioning activities that would alter that conclusion.

5.4 Additional Considerations The following considerations are relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed:

x The release of effluents will continue to be controlled by plant license requirements and plant procedures.

x ENGC will continue to comply with the Offsite Dose Calculation Manual, Radiological Environmental Monitoring Program, and the Groundwater Protection Initiative Program during decommissioning.

x Releases of non-radiological effluents will continue to be controlled per the requirements of the NPDES permit and applicable Commonwealth of Massachusetts permits.

36 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report x Systems used to treat or control effluents during power operation will either be maintained or replaced by temporary or mobile systems for the decommissioning activities.

x Radiation protection principles used during plant operations will remain in effect during decommissioning.

x Sufficient decontamination and source term reduction prior to dismantlement will be performed to ensure that occupational dose and public exposure will be maintained below applicable limits.

x Transport of radioactive waste will be in accordance with plant procedures, applicable Federal regulations, and the requirements of the receiving facility.

x Site access control during decommissioning will minimize or eliminate radiation release pathways to the public.

Additionally, NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, found that the generic environmental impacts of ongoing spent fuel storage are small (Reference 13).

5.5 Conclusions Based on the above discussions, ENGC concludes that the environmental impacts associated with planned PNPS site-specific decommissioning activities are less than and bounded by the impacts addressed by previously issued environmental impact statements. Specifically, the environmental impacts are bounded by the GEIS (Reference 3) and SEIS (Reference 7).

1. The postulated impacts associated with the decommissioning method chosen, SAFSTOR, have already been considered in the SEIS and GEIS.

2. There are no unique aspects of PNPS or of the decommissioning techniques to be utilized that would invalidate the conclusions reached in the SEIS and GEIS.

3. The methods assumed to be employed to dismantle and decontaminate PNPS are standard construction-based techniques fully considered in the SEIS and GEIS.

Therefore, it can be concluded that the environmental impacts associated with the site-specific decommissioning activities for PNPS will be bounded by appropriate previously issued environmental impact statements.

10 CFR 50.82(a)(6)(ii) states that licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2 that result in significant environmental impacts not previously reviewed.

37 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report No such impacts have been currently identified. ENGC will conduct ongoing reviews during the decommissioning process to assure identification of any such impacts.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report

6.0 REFERENCES

1. Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Revision 1. June 2013.

2. Letter, Entergy Nuclear Operations, Inc., to USNRC, Notification of Permanent Cessation of Power Operations, Pilgrim Station, November 10, 2015 (ADAMS Accession No. ML15328A053).

3. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, Final Report. November 2002.

4. AIF/NESP-036, A Guideline for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates. May 1986.

5. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Revision 2. October 2011.

6. NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities. July 1997.

7. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 29, Regarding Pilgrim Nuclear Power Station. July 2007.

8. Entergy Nuclear Pilgrim, LLC NPDES Draft Permit No. MA0003557 October 2014.

9. Entergy Nuclear Pilgrim, LLC Groundwater Discharge Permit #SE 389-4. November 4, 2016.

10. PAG Manual, Protective Action Guides and Planning Guidance for Radiological Incidents, EPA-400/R-17/001. January 2017.

11. Pilgrim Nuclear Power Station, License Renewal Application. Appendix E, Applicants Environmental Report. January 2006.

12. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants. June 2013.

13. NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, Final Report. September 2014.

14. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual. August 2000.

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Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report

15. USCB (U.S. Census Bureau). 2017a. American Fact Finder - Community Facts, 2010 and 2015 Population Estimates, Plymouth County, Massachusetts.

Retrieved from https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml (accessed September 7, 2018).

16. USCB. 2017b. American Fact Finder - Community Facts, 2010 and 2015 Population Estimates, Barnstable County, Massachusetts. Retrieved from https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml (accessed September 7, 2018).

17. USCB. 2017c. American Fact Finder, Profile of General Population and Housing Characteristics: 2010 Demographic Profile Data, Plymouth County, Massachusetts.

Retrieved from https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=CF (accessed September 7, 2018).

18. USCB. 2017d. American Fact Finder, Profile of General Population and Housing Characteristics: 2010 Demographic Profile Data, Barnstable County, Massachusetts.

Retrieved from https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=CF (accessed September 7, 2018).

40 Rev. 0

Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report ATTACHMENT 1 PNPS Site-Specific Decommissioning Cost Estimate

Document E11-1724-001, Rev. 0 SITE-SPECIFIC DECOMMISSIONING COST ESTIMATE for the PILGRIM NUCLEAR POWER STATION prepared for Entergy Nuclear Generation Company prepared by TLG Services, Inc.

Bridgewater, Connecticut November 2018

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page ii of xxiii APPROVALS Project Manager William A. Cloutier, Jr. Date Project Engineer Leasa Goetchius Date Technical Manager Francis W. Seymore Date TLG Services, Inc. 

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page iii of xxiii TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

..........................................................................................vii-xxiii

1. INTRODUCTION ..................................................................................................... 1-1 1.1 Objectives of Study ........................................................................................... 1-1 1.2 Site Description................................................................................................. 1-2 1.3 Regulatory Guidance ........................................................................................ 1-3 1.3.1 High-Level Radioactive Waste Management ...................................... 1-5 1.3.2 Low-Level Radioactive Waste Management ....................................... 1-9 1.3.3 Radiological Criteria for License Termination .................................. 1-10

2. DECOMMISSIONING ALTERNATIVE................................................................. 2-1 2.1 Period 1 - Preparations..................................................................................... 2-1 2.1.1 Engineering and Planning .................................................................... 2-1 2.1.2 Site Preparations ................................................................................... 2-2 2.2 Period 2 - Dormancy ........................................................................................ 2-4 2.3 Period 3 - Preparations for Decommissioning ................................................ 2-5 2.4 Period 4 - Decommissioning (Dismantling and Decontamination)............... 2-6 2.5 Period 3 - Site Restoration ............................................................................... 2-8

3. COST ESTIMATES................................................................................................... 3-1 3.1 Basis of Estimates ............................................................................................ 3-1 3.2 Methodology ...................................................................................................... 3-1 3.3 Financial Components of the Cost Model ....................................................... 3-3 3.3.1 Contingency ........................................................................................... 3-3 3.3.2 Financial Risk ........................................................................................ 3-5 3.4 Site-Specific Considerations............................................................................. 3-6 3.4.1 Spent Fuel Management....................................................................... 3-6 3.4.2 Reactor Vessel and Internal Components ........................................... 3-9 3.4.3 Primary System Components ............................................................. 3-10 3.4.4 Main Turbine and Condenser............................................................. 3-11 3.4.5 Transportation Methods ..................................................................... 3-11 3.4.6 Low-Level Radioactive Waste Disposal ............................................. 3-12 3.4.7 Site Conditions Following Decommissioning .................................... 3-13 3.5 Assumptions .................................................................................................... 3-14 3.5.1 Estimating Basis ................................................................................. 3-14 3.5.2 Labor Costs .......................................................................................... 3-14 3.5.3 Design Conditions................................................................................ 3-16 3.5.4 General ................................................................................................. 3-16 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page iv of xxiii TABLE OF CONTENTS (continued)

SECTION PAGE 3.6 Cost Estimate Summary ............................................................................... 3-18

4. SCHEDULE ESTIMATE ........................................................................................ 4-1 4.1 Schedule Estimate Assumptions ..................................................................... 4-1 4.2 Project Schedule ................................................................................................ 4-2

5. RADIOACTIVE WASTES ........................................................................................ 5-1

6. RESULTS ................................................................................................................. 6-1

7. REFERENCES .......................................................................................................... 7-1 TABLES

1. Decommissioning Schedule and Plant Status Summary ................................ xx

2. Decommissioning Cost Summary .................................................................... xxi

3. License Termination Expenditures ................................................................ xxii 3.1 Spent Fuel Management Schedule................................................................ 3-20 3.2 Total Annual Expenditures ........................................................................... 3-22 3.2a License Termination Expenditures ............................................................... 3-24 3.2b Spent Fuel Management Expenditures ........................................................ 3-26 3.2c Site Restoration Expenditures ...................................................................... 3-28 5.1 Decommissioning Waste Summary ................................................................. 5-5 6.1 Decommissioning Cost Elements .................................................................... 6-4 FIGURES 3.1 Decommissioning Personnel Levels .............................................................. 3-29 4.1 Activity Schedule .............................................................................................. 4-3 4.2 Decommissioning Timeline .............................................................................. 4-4 5.1 Radioactive Waste Disposition ........................................................................ 5-3 5.2 Decommissioning Waste Destinations, Radiological ...................................... 5-4 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page v of xxiii TABLE OF CONTENTS (continued)

SECTION PAGE APPENDICES A. Unit Cost Factor Development ............................................................................. A-1 B. Unit Cost Factor Listing ...................................................................................... B-1 C. Detailed Cost Analysis .......................................................................................... C-1 D. Detailed Cost Analysis, ISFSI.............................................................................. D-1 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page vi of xxiii REVISION LOG No. Date Item Revised Reason for Revision 0 11-14-2018 Original Issue TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page vii of xxiii EXECUTIVE

SUMMARY

This report presents a site-specific estimate of the cost to decommission the Pilgrim Nuclear Power Station (PNPS) following the scheduled cessation of plant operations.

By letter dated November 10, 2015[1], Entergy Nuclear Operations (ENO) notified the NRC that it intended to permanently cease power operations of PNPS no later than June 1, 2019. ENO will submit a supplement to this letter certifying the date on which operations have ceased, or will cease, in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8). Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii), pursuant to 10 CFR 50.82(a)(2),

the 10 CFR Part 50 license for PNPS will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel.

This estimate has been prepared for PNPS to comply with the requirements of 10 CFR 50.82(a)(8)(iii).[2] It relies upon the detailed planning that has been performed in anticipation of the pending cessation of operations and the site-specific, technical information from an earlier evaluation prepared in 2008,[3] updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects.

The current estimate is designed to provide Entergy Nuclear Generation Company (ENGC) with sufficient information to assess its financial obligations, as they pertain to the decommissioning of the nuclear unit. It is not a detailed budget and engineering document, but a financial analysis prepared in advance of the detailed budgeting and engineering work that will be required to carry out the decommissioning.

The estimate does include the cost for the detailed planning (and budgeting) for placing the unit in safe-storage and moving the spent fuel from the pool located within the reactor building to an on-site, interim storage facility. It may not reflect the actual plan to decommission PNPS; the plan may differ from the assumptions made in this analysis based on facts that exist at the time the plant is dismantled.

PNPS intends to decommission the plant using the NRC-approved SAFSTOR alternative. The projected total cost to decommission the nuclear unit, after an extended period of safe storage, is estimated at $1.661 billion, as reported in 2018 1 Letter, Entergy Nuclear Operations, Inc., to USNRC, Notification of Permanent Cessation of Power Operations, Pilgrim Station, November 10, 2015 (ADAMS Accession No. ML15328A053) 2 Within 2 years following permanent cessation of operations, if not already submitted, the licensee shall submit a site-specific decommissioning cost estimate.

3 Preliminary Decommissioning Cost Analysis for the Pilgrim Nuclear Power Station, Document E11-5690-003, Rev. 0, TLG Services, Inc., July 2008 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page viii of xxiii dollars. The cost includes monies anticipated to be spent for operating license termination (radiological remediation), interim spent fuel management and site restoration activities. The cost is based on several key assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, performance uncertainties (contingency) and site remediation and restoration requirements. A discussion of the assumptions relied upon in this analysis is provided in Section 3, along with schedules of annual expenditures. A sequence of significant project activities is provided in Section 4 along with a timeline for the scenario. A detailed cost report, used to generate the summary tables presented within this document, is provided in Appendix C.

The estimate includes the continued operation of the reactor building as an interim wet fuel storage facility for approximately three and one half years after operations cease. During this time period, the spent fuel residing in the storage pool will be transferred to an independent spent fuel storage installation (ISFSI) at the site, the spent fuel storage racks removed, and the pool cleaned out and drained. The ISFSI will remain operational until the Department of Energy (DOE) is able to complete the transfer of the spent fuel to a federal facility (e.g., a monitored retrievable storage facility).[4]

DOE has breached its obligations to remove fuel from reactor sites, and has also failed to provide the plant owner with information about how it will ultimately perform. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to DOEs contracts with plant licensees to remove the fuel (the Standard Contract), but DOE has not explained what any such amendment would involve. Consequently, the plant owner has no information or expectations on how DOE will remove fuel from the site in the future. In the absence of information about how DOE will perform, and for purposes of this analysis only, it is assumed that DOE will accept already-canistered fuel. (It is recognized that the canisters may not be licensed or licensable for transportation when DOE performs.) If this assumption is incorrect, it is assumed that DOE will have liability for costs incurred to transfer the fuel to DOE-supplied containers.

4 Projected expenditures for spent fuel management identified in the cost analyses do not consider the outcome of the litigation (including compensation for damages) with the DOE with regard to the delays incurred by PNPS in the timely removal of spent fuel from the site. As such, this analysis takes no credit for collection of damages, even though utilities are now routinely being awarded such damages in the courts. Collection of spent fuel damages from the DOE is expected to provide the majority of funds needed for spent fuel management following shutdown.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page ix of xxiii Alternatives and Regulations The Nuclear Regulatory Commission (NRC) provided general decommissioning requirements in a rule adopted on June 27, 1988.[5] In this rule, the NRC set forth technical and financial criteria for decommissioning licensed nuclear facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB.

DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations."[6]

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[7]

Decommissioning is required to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety.

ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."[8] As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years, although longer time periods will also be considered when necessary to protect public health and safety.

The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of 5 U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988 6 Ibid. Page FR24022, Column 3 7 Ibid. Page FR24022, Column 3 8 Ibid. Page FR24023, Column 2 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page x of xxiii long-lived radioactive material. In 1997, the Commission directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations, however, rulemaking has been deferred pending the completion of additional research studies (e.g., on engineered barriers).

In a draft regulatory basis document published in March 2017 in support of rulemaking that would amend NRC regulations concerning nuclear plant decommissioning, the NRC staff proposed removing any discussion of the ENTOMB option from existing guidance documents since the method is not deemed practically feasible.

In 1996, the NRC published revisions to its general requirements for decommissioning nuclear power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[9] The amendments allow for greater public participation and better define the transition process from operations to decommissioning. Regulatory Guide 1.184, issued in July 2000, (as revised in October 2013), further described the methods and procedures that are acceptable to the NRC staff for implementing the requirements of the 1996 revised rule that relate to the initial activities and the major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and sequence in the amended regulations. The format and content of the estimates is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.[10]

In 2011, the NRC issued regulations to improve decommissioning planning and thereby reduce the likelihood that any current operating facility will become a legacy site.[11] The regulations require licensees to report additional details in their decommissioning cost estimate, including a decommissioning estimate for the ISFSI.

This estimate is provided in Appendix D.

9 U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61, (p 39278 et seq.), July 29, 1996 10 Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Regulatory Guide 1.202, Nuclear Regulatory Commission, February 2005 11 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70, and 72, "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, (p 35512 et seq.), June 17, 2011 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xi of xxiii Basis of the Cost Estimate For planning purposes, the SAFSTOR decommissioning alternative has been selected by ENGC for PNPS. In SAFSTOR, the facility is placed in a safe and stable condition and maintained in that state, allowing levels of radioactivity to decrease through radioactive decay. After the safe storage period, the facility is decontaminated and dismantled, removing residual radioactivity so as to permit termination of the operating license and unrestricted use of the site.

Additional dry storage capacity will be added to accommodate all the spent fuel assemblies generated during operations. The spent fuel will remain in storage until it can be transferred to a DOE facility. Based upon the performance assumptions discussed herein, ENGC anticipates that the removal of spent fuel from the site could be completed by the end of year 2062.

For purposes of this analysis, the plant is assumed to remain in safe-storage until 2073, at which time decommissioning will commence. The start date allows sufficient time to accomplish the activities described in this document and to terminate the operating license within the required 60-year time period.

Methodology Entergys Nuclear Decommissioning Organization, the plant staff, and numerous other corporate entities and subject matter experts have been engaged in the planning and engineering needed to transition the nuclear unit and its operating organization from power generation to safe-storage. This information was used to create working budgets and the forecast for the first three and one half years following the cessation of operations, or until the spent fuel is relocated to the ISFSI (years 2019 through 2022),

and the plant secured for long-term storage.

These same organizations provided substantial input into estimating the annual costs associated with maintaining the station in a dormancy state (years 2023 through 2072).

The methodology used to develop the estimate for the deferred decontamination and dismantling activities, and restoration of the site, described within this document (years 2073 through 2080) follows the basic approach originally presented in the cost estimating guidelines[12] developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis 12 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xii of xxiii incorporate site-specific costs and the latest available information on worker productivity in decommissioning.

An activity duration critical path is used to determine the total decommissioning program schedule. This is required for calculating the carrying costs, which include program management, administration, field engineering, equipment rental, quality assurance, and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs.

The estimates also reflect lessons learned from TLGs involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells and associated facilities, completed in 1997. In addition, the planning and engineering for the Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, Crystal River, Vermont Yankee and Fort Calhoun nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur.[13] The cost elements in the estimates are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, does not account for the escalation of costs (due to inflationary and market forces) over the safe-storage and decommissioning period.

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

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

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xiii of xxiii Low-Level Radioactive Waste Management The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is generally classified as low-level radioactive waste, although not all of the material is suitable for shallow-land disposal.

With the passage of the Low-Level Radioactive Waste Disposal Act in 1980 and its Amendments of 1985,[14] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

With the exception of Texas, no new compact facilities have been successfully sited, licensed, and constructed. The Texas Compact disposal facility is now operational and waste is being accepted from generators within the Compact by the operator, Waste Control Specialists (WCS). The facility is also able to accept limited volumes of non-Compact waste.

Disposition of the various waste streams produced by the decommissioning process considered all options and services currently available to PNPS. The majority of the low-level radioactive waste designated for direct disposal (Class A[15]) can be sent to EnergySolutions facility in Clive, Utah. Therefore, disposal costs for Class A waste were based upon Entergys most recent General Services Agreement with EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream.

The WCS facility is able to receive the Class B and C waste. As such, for this analysis, Class B and C waste was assumed to be shipped to the WCS facility and disposal costs for the waste were based upon Entergys current services agreement with WCS.

The dismantling of the components residing closest to the reactor core generates radioactive waste that may be considered unsuitable for shallow-land disposal (i.e.,

low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost, if any, for GTCC disposal or a schedule for acceptance.

14 Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, January 15, 1986 15 Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xiv of xxiii For purposes of this analysis only, the GTCC radioactive waste is assumed to be packaged and disposed of in a manner similar to high-level waste and at a cost equivalent to that envisioned for the spent fuel. The GTCC is packaged in the same canisters used for spent fuel and shipped directly to a federal facility as it is generated (since the spent fuel, in this scenario, has already been removed from the site prior to the start of decommissioning).

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates reflect the savings from waste recovery/volume reduction.

High-Level Radioactive Waste Management Congress passed the Nuclear Waste Policy Act (NWPA) in 1982, assigning the federal governments long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The DOE was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made.

Today, the country is at an impasse on high-level waste disposal, despite DOEs submittal of its License Application for a geologic repository to the NRC in 2008.

The Obama administration eliminated the budget for the repository program while promising to conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle and make recommendations for a new plan.[16] Towards this goal, the Obama administration appointed a Blue Ribbon Commission on Americas Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commissions charter included a requirement that it consider [o]ptions for safe storage of used nuclear fuel while final disposition pathways are selected and deployed.[17]

On January 26, 2012, the Blue Ribbon Commission issued its Report to the Secretary of Energy containing a number of recommendations on nuclear waste 16 Advisory Committee Charter, Blue Ribbon Commission on Americas Nuclear Future, Appendix A, January 2012 17 Ibid.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xv of xxiii disposal. Two of the recommendations that may impact decommissioning planning are:

x [T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage facilities[18]

x [T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear waste.[19]

In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the Blue Ribbon Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[20]

With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

x Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2021 with an initial focus on accepting used nuclear fuel from shut-down reactor sites; x Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and x Makes demonstrable progress on the siting and characterization of repository sites to facilitate the availability of a geologic repository by 2048.[21]

The NRCs review of DOEs license application to construct a geologic repository at Yucca Mountain was suspended in 2011 when the Obama administration significantly reduced the budget for completing that work. However, the US Court of Appeals for the District of Columbia Circuit issued a writ of mandamus (in 18 Blue Ribbon Commission on Americas Nuclear Future, Report to the Secretary of Energy, January 2012 19 Ibid., p.27 20 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S. DOE, January 11, 2013 21 Ibid., p.2 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xvi of xxiii August 2013)[22] ordering NRC to comply with federal law and resume its review of DOE's Yucca Mountain repository license application to the extent allowed by previously appropriated funding for the review. That review is now complete with the publication of the five-volume safety evaluation report. A supplement to DOEs environmental impact statement and adjudicatory hearing on the contentions filed by interested parties must be completed before a licensing decision can be made.

Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report. Because of this continued delay, this estimate revises the assumed start date for DOE fuel acceptance from 2025 to 2030.

Holtec International submitted a license application to the NRC on March 30, 2017 for a consolidated interim spent fuel storage facility in southeast New Mexico called HI-STORE CIS (Consolidated Interim Storage) under the provisions of 10 CFR Part

72. The application is currently under NRC review.

Waste Control Specialists submitted an application to the NRC on April 28, 2016, to construct and operate a Consolidated Interim Storage Facility (CISF) at its West Texas facility. On April 18, 2017, WCS requested that the NRC temporarily suspend all safety and environmental review activities, as well as public participation activities associated with WCSs license application. In March 2018, WCS and Orano USA, announced their intent to form a joint venture to license the facility. In June 2018, the joint venture, Interim Storage Partners, submitted a renewed application and requested that the NRC resume its review of the revised CISF license application.

On May 10, 2018, the U.S. House of Representatives passed H.R. 3053, the Nuclear Waste Policy Amendments Act of 2018. Proposed to amend the Nuclear Waste Policy Act of 1982, the legislation, if approved by the Senate and signed by the President, would provide the DOE the authority to site, construct, and operate one or more Monitored Retrieval Storage (MRS) facilities while a permanent repository is licensed and constructed and/or to enter into an MRS agreement with a non-Federal entity for temporary storage.

Completion of the decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site in a timely manner. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor.[23] ENGCs current spent fuel management plan for 22 U.S. Court of Appeals for the District Of Columbia Circuit, In Re: Aiken County, et al, Aug. 2013 23 In 2008, the DOE issued a report to Congress in which it concluded that it did not have authority, TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xvii of xxiii the PNPS spent fuel is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel from the industry to a federal facility (not necessarily a final repository), and 2) an assumed schedule for spent fuel receipt by the DOE for the Pilgrim fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium (MTU)/year, [24] the removal of spent fuel from the site could be completed in 2062. Different DOE acceptance schedules may result in different completion dates.

The NRC requires that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE.[25] Interim storage of the fuel, until the DOE has completed the transfer, will be in the reactor buildings spent fuel storage pool, as well as at an on-site ISFSI.

An ISFSI, operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[26]), has been constructed to support continued plant operations. Additional storage capacity will be added to accommodate all the spent fuel generated during operations. Once the spent fuel storage pool is emptied the reactor building can be prepared for long term storage.

ENGCs position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient under present law, to accept spent nuclear fuel for interim storage from decommissioned commercial nuclear power reactor sites. However, the Blue Ribbon Commission, in its final report, noted that:

[A]ccepting spent fuel according to the OFF [Oldest Fuel First] priority ranking instead of giving priority to shutdown reactor sites could greatly reduce the cost savings that could be achieved through consolidated storage if priority could be given to accepting spent fuel from shutdown reactor sites before accepting fuel from still-operating plants. . The magnitude of the cost savings that could be achieved by giving priority to shutdown sites appears to be large enough (i.e., in the billions of dollars) to warrant DOE exercising its right under the Standard Contract to move this fuel first. For planning purposes only, this estimate does not assume that PNPS, as a permanently shutdown unit, will receive priority; the fuel removal schedule assumed in this estimate is based upon DOE acceptance of fuel according to the Oldest Fuel First priority ranking. The plant owner will seek the most expeditious means of removing fuel from the site when DOE commences performance.

24 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004 25 U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses 26 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xviii of xxiii decommissioning funds at the end of the stations life if, contrary to its contractual obligation, the DOE has not performed earlier.

Site Restoration The efficient removal of the contaminated materials at the site may result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities can substantially damage power block structures, potentially weakening the footings and structural supports. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized is more efficient and less costly than if the process is deferred.

Consequently, this study assumes that non-essential site structures addressed by this analysis are removed, once remediation is complete, to a nominal depth of three feet below the local grade level wherever possible. The site is then graded and stabilized.

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

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

Decommissioning is accomplished within the 60-year period required by current NRC regulations. In the interim, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility is complete.

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

The cost elements are assigned to one of three subcategories: NRC License Termination (radiological remediation), Spent Fuel Management, and Site Restoration. The subcategory NRC License Termination is used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR §50.75). In situations where the long-TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xix of xxiii term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate a reactors operating license.

The Spent Fuel Management subcategory contains costs associated with adding dry storage capacity, containerization and transfer of spent fuel to the ISFSI, and the operation of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location is complete. It does not include any costs related to the final disposal of the spent fuel.

Site Restoration is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination.

This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are assumed to be removed to a nominal depth of three feet and backfilled to conform to local grade.

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

Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., ARO determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

As noted within this document, the estimate was developed and costs are presented in 2018 dollars. The estimate does not reflect the escalation of costs (due to inflationary and market forces) over the safe-storage and decommissioning period.

The decommissioning subperiods and milestone dates for the analyzed SAFSTOR decommissioning alternative are identified in Table 1. The cost projected for license termination (in accordance with 10 CFR 50.75) is shown in Table 2, along with the costs for spent fuel management and site restoration. The schedule of expenditures for license termination activities is provided in Table 3.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xx of xxiii TABLE 1 DECOMMISSIONING SCHEDULE AND PLANT STATUS

SUMMARY

Approximate Decommissioning Activities / Duration Plant Status Start End (years)

Pre-Shutdown Planning 2018 May 2019 1.0 Period 1: Transition from Operations Plant Shutdown May 31, 2019 -------- --------

Preparations for SAFSTOR Dormancy May 31, 2019 March 2020 0.84 Period 2: SAFSTOR Dormancy Dormancy w/Wet Fuel Storage March 2020 2022 2.8 Dormancy w/Dry Fuel Storage 2022 2062 40.0 Dormancy w/No Fuel Storage 2062 2073 10.4 Period 3: Preparations for Dismantling & Decontamination (D&D)

Preparations for D&D 2073 2074 1.5 Period 4: Dismantling & Decontamination (D&D)

Large Component Removal 2074 2076 1.4 Plant Systems Removal and Building Decontamination 2076 2078 2.3 License Termination 2078 2079 0.7 Period 5: Site Restoration Site Restoration 2079 2080 1.5 Total from Shutdown to Completion of License Termination --------- -------- 60 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xxi of xxiii TABLE 2 DECOMMISSIONING COST

SUMMARY

(thousands, of 2018 dollars)

Decommissioning License Spent Fuel Site Total Periods Termination Management Restoration Pre-Shutdown Planning and Period 1: Transition from Operations $144,683 $93,869 $0 $238,552 Period 2: SAFSTOR Dormancy Wet Fuel Storage $125,888 $134,770 $0 $260,658 Dry Fuel Storage $245,489 $191,611 $0 $437,100 No Fuel Storage $49,031 $0 $0 $49,031 Period 3: Preparations for Dismantling &

Decontamination (D&D)

Site Reactivation $46,701 $0 $571 $47,271 Decommissioning Preparation $35,482 $0 $451 $35,933 Period 4: Dismantling &

Decontamination D&D):

Large Component Removal $225,394 $0 $369 $225,763 Plant Systems Removal and Building Remediation $281,263 $0 $881 $282,143 License Termination $33,840 $0 $0 $33,840 Period 5: Site Restoration $225 $0 $50,743 $50,967 Total [a] $1,187,994 $420,250 $53,014 $1,661,258

[a]

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

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xxii of xxiii TABLE 3 LICENSE TERMINATION EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2018 0 0 0 0 19,142 19,142 2019 45,256 1,040 1,409 276 52,043 100,024 2020 22,178 1,040 1,572 539 36,245 61,574 2021 13,526 454 1,157 323 30,572 46,032 2022 13,526 454 1,157 323 28,339 43,799 2023 2,276 130 524 7 11,579 14,516 2024 2,282 130 525 7 3,953 6,897 2025 2,276 130 524 7 3,322 6,259 2026 2,276 130 524 7 2,947 5,884 2027 2,276 130 524 7 2,947 5,884 2028 2,282 130 525 7 2,953 5,897 2029 2,276 130 524 7 2,947 5,884 2030 2,276 130 524 7 2,947 5,884 2031 2,276 130 524 7 2,947 5,884 2032 2,282 130 525 7 2,953 5,897 2033 2,276 130 524 7 2,947 5,884 2034 2,276 130 524 7 2,947 5,884 2035 2,276 130 524 7 2,947 5,884 2036 2,282 130 525 7 2,953 5,897 2037 2,276 130 524 7 2,947 5,884 2038 2,276 130 524 7 2,947 5,884 2039 2,276 130 524 7 2,947 5,884 2040 2,282 130 525 7 2,953 5,897 2041 2,276 130 524 7 2,947 5,884 2042 2,276 130 524 7 2,947 5,884 2043 2,276 130 524 7 2,947 5,884 2044 2,282 130 525 7 2,953 5,897 2045 2,276 130 524 7 2,947 5,884 2046 2,276 130 524 7 2,947 5,884 2047 2,276 130 524 7 2,947 5,884 2048 2,282 130 525 7 2,953 5,897 2049 2,276 130 524 7 2,947 5,884 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Page xxiii of xxiii TABLE 3 (continued)

LICENSE TERMINATION EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2050 2,276 130 524 7 2,947 5,884 2051 2,276 130 524 7 2,947 5,884 2052 2,282 130 525 7 2,953 5,897 2053 2,276 130 524 7 2,947 5,884 2054 2,276 130 524 7 2,947 5,884 2055 2,276 130 524 7 2,947 5,884 2056 2,282 130 525 7 2,953 5,897 2057 2,276 130 524 7 2,947 5,884 2058 2,276 130 524 7 2,947 5,884 2059 2,276 130 524 7 2,947 5,884 2060 2,282 130 525 7 2,953 5,897 2061 2,276 130 524 7 2,947 5,884 2062 2,276 130 524 7 2,947 5,884 2063 1,663 298 216 6 2,514 4,697 2064 1,668 298 217 6 2,521 4,710 2065 1,663 298 216 6 2,514 4,697 2066 1,663 298 216 6 2,514 4,697 2067 1,663 298 216 6 2,514 4,697 2068 1,668 298 217 6 2,521 4,710 2069 1,663 298 216 6 2,514 4,697 2070 1,663 298 216 6 2,514 4,697 2071 1,663 298 216 6 2,514 4,697 2072 1,668 298 217 6 2,521 4,710 2073 22,411 1,183 1,324 21 3,694 28,634 2074 38,252 8,293 2,154 5,384 7,668 61,751 2075 47,682 24,256 2,053 68,469 17,586 160,046 2076 63,341 15,092 1,775 41,144 16,992 138,344 2077 66,082 10,159 1,621 26,451 16,606 120,920 2078 56,725 7,373 1,230 17,765 13,112 96,205 2079 15,548 693 178 12 2,457 18,888 2080 137 0 0 0 0 137 Total 512,400 78,223 38,769 161,050 397,552 1,187,994 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 1 of 11

1. INTRODUCTION This report presents a site-specific estimate of the cost to decommission the Pilgrim Nuclear Power Station (PNPS) following the scheduled cessation of plant operations.

The estimate is designed to provide Entergy Nuclear Generation Company (ENGC) with sufficient information to assess its financial obligations, as they pertain to the decommissioning of the nuclear unit.

The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2008,[1]* updated to reflect current assumptions pertaining to the disposition of the nuclear plant and relevant industry experience in undertaking such projects. The costs are based on several key assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, performance uncertainties (contingency) and site restoration requirements.

The analysis is not a detailed engineering evaluation, but rather an estimate prepared in advance of the detailed engineering required to carry out the decommissioning of the nuclear unit. It may not reflect the actual plan to decommission PNPS; the plan may differ from the assumptions made in this analysis based on facts that exist at the time the plant is dismantled.

The 2008 plant inventory, the basis for the decontamination and dismantling requirements and cost, and the decommissioning waste streams, were reviewed for this analysis. There were no substantive changes made to the plant that would impact decommissioning except for the additions of the K1, LLRW, Trash Compaction and Maintenance Warehouse structures.

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

The original operating license for Pilgrim (DPR-35) was issued in 1972 for 40 years of operation, with expiration at midnight on June 8, 2012. Pursuant to an application that was submitted to the Nuclear Regulatory Commission (NRC) in January 2006, on May 29, 2012, the NRC renewed Pilgrims operating license for an additional 20 years, i.e., to June 8, 2032.

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

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 2 of 11 By letter dated November 10, 2015[2], ENO has since notified the NRC that it intended to permanently cease power operations of PNPS no later than June 1, 2019. ENO will submit a supplement to this letter certifying the date on which operations have ceased, or will cease, in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8). Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel.

1.2 SITE DESCRIPTION Pilgrim is located on the western shore of Cape Cod Bay in the town of Plymouth, Plymouth County, Massachusetts. It is 38 miles southeast of Boston, Massachusetts and 44 miles east of Providence, Rhode Island. The station comprises a single boiling water reactor, designed and fabricated by General Electric Company, producing steam for direct use in the steam turbine. Supporting facilities were engineered and constructed by Bechtel Corporation.

The reactor vessel and the recirculation system are contained within the drywell of a pressure suppression system housed within the reactor building.

The system consists of a drywell, a pressure suppression chamber that stores a large volume of water (torus), and a connecting submerged vent system between the drywell and water pool, isolation valves, containment cooling systems, and other service equipment. The reactor building encloses the pressure suppression primary containment thereby providing a secondary containment.

In July 2002, Entergy Nuclear Operations, Inc. requested an amendment to its facility operating license to increase the maximum authorized power level from 1998 megawatts-thermal (MWt) to 2,028 MWt. This increase corresponds to an output of approximately 690 megawatts-electric (MWe). The request was subsequently approved, the uprate was implemented, and the unit is operating at the higher level.

Heat produced in the reactor is converted to electrical energy by the power conversion system. A turbine-generator system converts the thermal energy of steam produced by the reactor into mechanical shaft power and then into electrical energy. The turbine consists of a double-flow, high pressure cylinder and two double-flow, low pressure cylinders all aligned in tandem. The generator is a direct-driven 1800 rpm conductor-cooled, synchronous generator.

The turbine is operated in a closed feedwater cycle which condenses the steam; TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 3 of 11 the heated feedwater is returned to the reactor. Heat rejected in the main condensers is removed by the circulating water system.

The circulating water system provides the heat sink required for removal of waste heat in the power plants thermal cycle. This system has the principal function of removing heat by absorbing this energy in the main condenser.

Circulating water is drawn from the Cape Cod Bay (Atlantic Ocean) with heated cooling water returned to the bay.

1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[3] This rule set forth financial criteria for decommissioning licensed nuclear power facilities. The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose.

Subsequent to the rule, the NRC issued Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors,[4] which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.

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

The rule also placed limits on the time allowed to complete the decommissioning process. For all alternatives, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. At the conclusion of a 60-year dormancy period (or longer if the NRC approves such a case), the site would still require significant remediation to meet the unrestricted release limits for license termination.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 4 of 11 The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with rulemaking permitting the controlled release of a site,[6] the NRC did re-evaluate the alternative. The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. The staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative.

The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombments.[5] However, the NRCs staff has subsequently recommended that rulemaking be deferred, based upon several factors (e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRCs current priorities), at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.

In a draft regulatory basis document published in March 2017 in support of rulemaking that would amend NRC regulations concerning nuclear plant decommissioning, the NRC staff proposes removing any discussion of the ENTOMB option from existing guidance documents since the method is not deemed practically feasible.

In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.[7] When the decommissioning regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facilitys operating licensed life.

Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process from operations to decommissioning.

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

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 5 of 11 Submittal of these notices, along with related changes to Technical Specifications, entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. The regulation at 10 CFR 50.82(a)(4)(i) requires the licensee to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC either before or not later than 2 years after permanent cessation of operations.

The PSDAR describes the planned decommissioning activities, the associated sequence and schedule, and an estimate of expected costs. Prior to completing decommissioning, the licensee is required to submit an application to the NRC to terminate the license, which includes a license termination plan (LTP).

In 2011, the NRC issued regulations to improve decommissioning planning and thereby reduce the likelihood that any current operating facility will become a legacy site.[8] The regulations require licensees to report additional details in their decommissioning cost estimate including a decommissioning estimate for the ISFSI. This estimate is provided in Appendix D.

1.3.1 High-Level Radioactive Waste Management Congress passed the Nuclear Waste Policy Act[9] (NWPA) in 1982, assigning the federal governments long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. It was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made.

Today, the country is at an impasse on high-level waste disposal, even with the License Application for a geologic repository submitted by the DOE to the NRC in 2008. The Obama administration cut the budget for the repository program while promising to conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle and make recommendations for a new plan. Towards this goal, the Obama administration appointed a Blue Ribbon Commission on Americas Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commissions charter includes a requirement that it consider

[o]ptions for safe storage of used nuclear fuel while final disposition pathways are selected and deployed.[10]

On January 26, 2012, the Blue Ribbon Commission issued its Report to the Secretary of Energy containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are:

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 6 of 11 x [T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage facilities x [T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear waste.[11]

In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the Blue Ribbon Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[12]

With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

x Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2021 with an initial focus on accepting used nuclear fuel from shut-down reactor sites; x Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and x Makes demonstrable progress on the siting and characterization of repository sites to facilitate the availability of a geologic repository by 2048.

The NRCs review of DOEs license application to construct a geologic repository at Yucca Mountain was suspended in 2011 when the Obama administration significantly reduced the budget for completing that work. However, the US Court of Appeals for the District of Columbia Circuit issued a writ of mandamus (in August 2013)[13] ordering NRC to comply with federal law and resume its review of DOE's Yucca Mountain repository license application to the extent allowed by previously appropriated funding for the review. That review is now complete with the publication of the five-volume safety evaluation report. A supplement to DOEs environmental impact statement and adjudicatory hearing on the contentions filed by interested parties must TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 7 of 11 be completed before a licensing decision can be made. Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report. Because of this continued delay, this estimate revises the assumed start date for DOE fuel acceptance from 2025 to 2030.

Holtec International submitted a license application to the NRC on March 30, 2017 for a consolidated interim spent fuel storage facility in southeast New Mexico called HI-STORE CIS (Consolidated Interim Storage) under the provisions of 10 CFR Part 72. The application is currently under NRC review.

Waste Control Specialists submitted an application to the NRC on April 28, 2016, to construct and operate a Consolidated Interim Storage Facility (CISF) at its West Texas facility. On April 18, 2017, WCS requested that the NRC temporarily suspend all safety and environmental review activities, as well as public participation activities associated with WCSs license application. In March 2018, WCS and Orano USA, announced their intent to form a joint venture to license the facility. In June 2018, the joint venture, Interim Storage Partners, submitted a renewed application and requested that the NRC resume its review of the revised CISF license application.

On May 10, 2018, the U.S. House of Representatives passed H.R. 3053, the Nuclear Waste Policy Amendments Act of 2018. Proposed to amend the Nuclear Waste Policy Act of 1982, the legislation, if approved by the Senate and signed by the President, would provide the DOE the authority to site, construct, and operate one or more Monitored Retrieval Storage (MRS) facilities while a permanent repository is licensed and constructed and/or to enter into an MRS agreement with a non-Federal entity for temporary storage.

Completion of the decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site in a timely manner.

DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. ENGCs current spent fuel management plan for the PNPS spent fuel is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel from the industry to a federal facility (not necessarily a final repository), and 2) an assumed schedule for spent fuel receipt by the DOE for the PNPS fuel. The DOEs TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 8 of 11 generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium (MTU)/year, as reflected in DOEs latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567),[14] the removal of spent fuel from the site could be completed in 2062. Different DOE acceptance schedules may result in different completion dates.

The NRC requires that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE.[15] Interim storage of the fuel, until the DOE has completed the transfer, will be in the reactor buildings spent fuel storage pool, as well as at an on-site ISFSI.

An ISFSI, operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K,[16] has been constructed to support continued plant operations. Additional storage capacity will be added to accommodate all the spent fuel generated during operations. Once the spent fuel storage pool is emptied the reactor building can be prepared for long term storage.

ENGCs position is that the DOE has a contractual obligation to accept PNPSs fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds at the end of the stations life if, contrary to its contractual obligation, the DOE has not performed earlier.

DOE has breached its obligations to remove fuel from reactor sites, and has also failed to provide the plant owner with information about how it will ultimately perform. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to DOEs contracts with plant licensees to remove the fuel (the Standard Contract), but DOE has not explained what any such amendment would involve. Consequently, the plant owner has no information or expectations on how DOE will remove fuel from the site in the future. In the absence of information about how DOE will perform, and for purposes of this analysis only, it is assumed that DOE will accept already-canistered fuel. (It is recognized that the canisters may not be licensed or licensable for transportation when DOE performs.) If this assumption is incorrect, it is assumed that DOE will TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 9 of 11 have liability for costs incurred to transfer the fuel to DOE-supplied containers.

1.3.2 Low-Level Radioactive Waste Management The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for shallow-land disposal. With the passage of the Low-Level Radioactive Waste Policy Act in 1980,[17] and its Amendments of 1985,[18] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

With the exception of Texas, no new compact facilities have been successfully sited, licensed, and constructed. The Texas Compact disposal facility is now operational and waste is being accepted from generators within the Compact by the operator, Waste Control Specialists (WCS). The facility is also able to accept limited volumes of non-Compact waste.

Disposition of the various waste streams produced by the decommissioning process considered all options and services currently available to Entergy. The majority of the low-level radioactive waste designated for direct disposal (Class A[19]) can be sent to EnergySolutions facility in Clive, Utah. Therefore, disposal costs for Class A waste were based upon Entergys most recent General Services Agreement with EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream.

The WCS facility is able to receive the Class B and C waste. As such, for this analysis, Class B and C waste was assumed to be shipped to the WCS facility and disposal costs for the waste were based upon Entergys current services agreement with WCS.

The dismantling of the components residing closest to the reactor core generates radioactive waste that may be considered unsuitable for shallow-land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 10 of 11 that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste.

However, to date, the federal government has not identified a cost, if any, for GTCC disposal or a schedule for acceptance.

For purposes of this analysis only, the GTCC radioactive waste is assumed to be packaged and disposed of in a manner similar to high-level waste and at a cost equivalent to that envisioned for the spent fuel. The GTCC is packaged in the same canisters used for spent fuel and shipped directly to a federal facility as it is generated (since the spent fuel, in this scenario, has already been removed from the site prior to the start of decommissioning).

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates reflect the savings from waste recovery/volume reduction.

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, Radiological Criteria for License Termination,[20] amending 10 CFR Part 20. This subpart provides radiological criteria for releasing a facility for unrestricted use.

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

The decommissioning estimates assume that the PNPS site will be remediated to a residual level consistent with the NRC-prescribed level.

It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 1, Page 11 of 11 Response, Compensation, and Liability Act (CERCLA or Superfund).[21]

An additional and separate limit of 4 millirem per year, as defined in 40 CFR §141.66, is applied to drinking water.[22]

On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU)[23] provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.

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

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 1 of 8

2. DECOMMISSIONING ALTERNATIVE Costs were determined for decommissioning PNPS for the NRC-approved SAFSTOR decommissioning alternative. The following sections describe the basic activities associated with the SAFSTOR alternative. Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work (i.e., engineering and planning at the time of decommissioning).

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

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

2.1 PERIOD 1 - PREPARATIONS The NRC defines SAFSTOR as, A method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use. The facility is left intact (during the dormancy period), with structures maintained in a stable condition. Systems that are not required to support the spent fuel, heating ventilation and air conditioning, the site emergency plan or site security are drained, de-energized, and secured. Access to contaminated areas is maintained for inspection and maintenance.

2.1.1 Engineering and Planning In anticipation of the cessation of plant operations, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Through implementation of a TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 2 of 8 staffing transition plan, the organization required to manage the intended decommissioning activities is assembled from available plant staff and outside resources. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, addition of security barriers, a limited characterization of the facility and major components, and the development of the PSDAR.

2.1.2 Site Preparations The process of placing the plant in safe-storage will include, but is not limited to, the following activities:

x Creation of an organizational structure to support the decommissioning plan and evolving emergency planning and site security requirements.

x Revision of technical specifications, plans and operating procedures appropriate to the operating conditions and requirements.

x Characterization of the facility and major components as may be necessary to plan and prepare for the dormancy phase.

x Isolation of the spent fuel pool and reconfiguring fuel pool support systems so that draining and de-energizing may commence in other areas of the plant.

x Adding additional dry storage capacity for all the spent fuel assemblies generated during operations.

x Deactivation (de-energizing and /or draining) of systems that are no longer required during the dormancy period.

x Processing and disposal of water and water filter and treatment media not required to support dormancy operation.

x Disposition of incidental waste that may be present prior to the start of the dormancy period, such as excess tools and equipment and waste produced while deactivating systems and preparing the facility for dormancy.

x Reconfiguration of power, lighting, heating, ventilation, fire protection, and any other services needed to support long-term storage and periodic plant surveillance and maintenance.

x Stabilization by fixing or removing loose incidental surface contamination to facilitate future building access and plant maintenance. Decontamination of high-dose areas is not anticipated.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 3 of 8 x Performance of interim radiation surveys of the plant, posting caution signs and establishing access requirements, where appropriate.

x Maintenance of appropriate barriers for contaminated and radiation areas.

x Reconfiguration of security boundaries and surveillance systems, as required.

The following is a general discussion of the planned reconfiguration expected after plant shutdown.

Electrical Systems The electrical system will undergo a series of reconfigurations between shutdown and the time all spent fuel has been transferred to dry storage. The reconfigurations will be performed to improve system flexibility and operational control, reduce operating and maintenance expenses, and to provide diverse means of aligning the power sources to the station loads particularly for Spent Fuel Pool-related systems and critical security equipment. The ISFSI facility will require installation of a new electrical distribution system independent of the existing station service and will also include a new diesel generator and uninterruptable power supply system.

Mechanical Systems Following shutdown, as applicable, fluid filled systems will be drained and abandoned, and resins removed based on an evaluation of system category, functionality, and plant configuration. System categories include: 1) Balance of Plant (BOP), 2) Emergency Core Cooling System (ECCS), 3) Nuclear Steam Safety System (NSSS), 4) Spent Fuel Pool Cooling (SFPC), and 5) Dry Fuel Storage (DFS). Plant configurations include: 1) Post-shutdown (fuel in the reactor), 2) Post-defuel (no fuel in the reactor); 3) Post-gates in (no fuel in reactor, spent fuel pool is physically isolated from the reactor); 4) Reactor vessel drained; 5)

Reduced risk of zirconium fire (spent fuel is in the spent fuel pool); and

6) Post-dry fuel storage (all spent fuel in dry fuel storage). The plant configuration and functionality of each system within the plant configuration as it evolves will determine when a system can be drained and abandoned.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 4 of 8 Ventilation and Heating Systems Ventilation will be reconfigured for the Turbine Building (TB) and Reactor Building (RB) to support remaining systems and habitability.

Fluid filled systems in the TB will either be drained or freeze protection installed, and the heating steam secured. The RB ventilation system will be reconfigured to maintain building temperature to support habitability and the functioning of Fuel Pool Cooling systems, Fire Protection systems, and Dry Fuel Storage systems.

Fire Protection Systems Active and passive features of the Fire Protection (FP) systems will be revised based on a fire hazards analysis. The fire hazards analysis provides a comprehensive evaluation of the facility's fire hazards, the fire protection capability relative to the identified hazards, and the ability to protect spent fuel and other radioactive materials from potential fire-induced releases. The fire hazards analysis will be reevaluated and revised as necessary to reflect the unique or different fire protection issues and strategies associated with decommissioning. It is expected that as the plants systems are drained, the combustible loading footprint shrinks, and the hazards are removed, the FP systems, features and requirements will be reduced or eliminated.

Maintenance of Systems Critical to Decommissioning There are no currently identified mechanical systems that will be critical to the final decommissioning process. As such, mechanical systems will be abandoned after all spent fuel has been transferred to Dry Fuel Storage, with the exception of systems required to maintain habitability during dormancy. The site power distribution system will be abandoned with the possible exception of Motor Control Centers that are required to support ventilation and lighting. The organization responsible for the final dismantlement will be expected to establish necessary temporary services, including electrical and cranes.

2.2 PERIOD 2 - DORMANCY Activities required during the early dormancy period while spent fuel is stored in the fuel pool will be substantially different than those activities required during dry fuel or no fuel storage.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 5 of 8 Early activities include operating and maintaining the spent fuel pool and its associated systems, and transferring spent fuel from the pool to the ISFSI.

Assuming the timely receipt of the required regulatory approvals, the ISFSI modification is estimated to be completed in 2020. Spent fuel transfer is expected to be complete by mid-year 2022. After the fuel transfer is completed, the pool and systems will be drained and de-energized for long-term storage.

Dormancy activities will include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, freeze protection heating, ventilation of buildings for periodic habitability, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. A fire protection program will be maintained.

Security during the dormancy period will be conducted primarily to safeguard the spent fuel on site and prevent unauthorized entry. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security.

An environmental surveillance program will be carried out during the dormancy period to monitor for radioactive material in the environment.

Appropriate procedures will be established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program will consist of a version of the program in effect during normal plant operations that will be modified to reflect the plants conditions and risks at the time.

Late in dormancy, activities will include transferring the spent fuel from the ISFSI to the DOE. For planning purposes, ENGCs current spent fuel management plan for the PNPS spent fuel is based, in general, upon the following projections: 1) a 2030 start date for the DOE initiating transfer of commercial spent fuel to a federal facility, 2) allocations and acceptance priority for PNPS spent fuel, and 3) a 2062 completion date for removal of all PNPS spent fuel. Transfer could occur earlier if the DOE is successful in implementing its current strategy for the management and acceptance of spent fuel. The ISFSI pad and facilities will be decommissioned at the time of plant decommissioning or after DOE has removed all spent fuel from the site.

2.3 PERIOD 3 - PREPARATIONS FOR DECOMMISSIONING Prior to the commencement of decommissioning operations, preparations will be undertaken to reactivate site services and prepare for decommissioning.

Preparations include engineering and planning, a site characterization, and TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 6 of 8 the assembly of a decommissioning management organization. This would likely include the development of work plans, specifications and procedures.

2.4 PERIOD 4 - DECOMMISSIONING (DISMANTLING AND DECONTAMINATION)

Following the preparations for decommissioning, physical decommissioning activities will take place. This includes the removal and disposal of contaminated and activated components and structures, leading to the termination of the 10 CFR 50 operating license. Although much of the radioactivity will decrease during the dormancy period due to decay of 60Co and other short-lived radionuclides, the internal components of the reactor vessel will still exhibit radiation dose rates that will likely require remote sectioning under water due to the presence of long-lived radionuclides such as 94Nb, 59Ni, and 63Ni. Portions of the sacrificial shield and primary containment walls may also be radioactive due to the presence of activated trace elements with longer half-lives (such as 152Eu and 154Eu). It is assumed that radioactive contamination on structures, systems, and component surfaces will not have decayed to levels that will permit unrestricted release. These surfaces will be surveyed and items dispositioned in accordance with the existing radioactive release criteria.

Significant decommissioning activities in this phase include:

x Reconfiguration and modification of site structures and facilities, as needed, to support decommissioning operations. Modifications may also be required to the reactor or other buildings to facilitate movement of equipment and materials, support the segmentation of the reactor vessel and reactor vessel internals, and for large component removal.

x Design and fabrication of temporary and longer-term shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

x Procurement or leasing of shipping cask, cask liners, and industrial packages for the disposition of low-level radioactive waste (LLRW).

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

x Disposition of the turbine, condenser, main steam piping, and associated equipment; with appropriate dispositioning based upon radiological surveys.

x Disposition of systems and components.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 7 of 8 x Removal of the recirculation pumps and associated piping for controlled disposal.

x Contaminated material will be characterized and segregated for additional offsite processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.

x Disposition of control rod blades.

x Disassembly and segmentation of the reactor vessel internals. This will likely involve use of remotely operated equipment within the reactor cavity, covered with a contamination control envelope. The cavity water level will likely need to be maintained just below the cut to maintain the working area dose rates ALARA. Some of this material may exceed Class C disposal requirements. This will be packaged for transfer to the DOE.

x Segmentation of the reactor vessel. Similar to the internals some of this work may involve the use of remotely operated equipment.

x Removal of the steel liners from the drywell, torus, refueling pool and spent fuel pool, disposing of the activated and/or contaminated sections as radioactive waste.

x Disposition of the activated and contaminated portions of the concrete sacrificial shield and primary containment walls and contaminated concrete surfaces that exceed the material release criteria.

x Material likely to be free of contamination may be surveyed and released for unrestricted disposition, e.g., as scrap, recycle, or general disposal, or sent to an off-site NRC / Agreement State licensed processor for radiological evaluation and appropriate disposition.

x Remediation of contaminated surface soil or sub-surface media will be performed as necessary to meet the unrestricted use criteria in 10 CFR 20.1402.

x Underground piping (or similar items) and associated soil will be removed as necessary to meet license termination criteria.

At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) will be submitted to the NRC. That plan will include: a site characterization, description of the remaining dismantling /

removal activities, plans for remediation of remaining radioactive materials, developed site-specific Derived Concentration Guideline Levels (DCGLs), plans for the final status (radiation) survey (FSS), designation of the end use of the site, an updated cost estimate to complete the decommissioning, and associated environmental concerns.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 2, Page 8 of 8 The FSS plan will identify the radiological surveys to be performed once the decontamination activities are completed and will be developed using the guidance provided in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).[24] This document incorporates statistical approaches to survey design and data evaluation. It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the FSS is complete, the results will be submitted to the NRC, along with a request for termination of the NRC license.

2.5 PERIOD 5 - SITE RESTORATION After the NRC terminates the license, site restoration activities will be performed. ENO currently assumes that remaining clean structures will be removed to a nominal depth of three feet below the surrounding grade level.

Affected area(s) would then be backfilled with suitable fill materials, graded, and appropriate erosion controls established. The unused portion of non-contaminated concrete rubble produced by the demolition activities will be transported to an offsite area for appropriate disposal as construction debris.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 1 of 29

3. COST ESTIMATE The cost estimate prepared for decommissioning PNPS consider the unique features of the site, including the nuclear steam supply system, electric power generating systems, structures and supporting facilities. The basis of the estimate, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.

3.1 BASIS OF ESTIMATES The current estimate was developed using the site-specific, technical information relied upon in the decommissioning analysis prepared in 2008.

This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.

3.2 METHODOLOGY The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[25] and the DOE "Decommissioning Handbook."[26] These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) are developed using local labor rates. The activity-dependent costs are estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures rely upon information available in the industry publication, "Building Construction Cost Data," published by RSMeans.[27]

The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 2 of 29 Regulatory Guide 1.184 [28] Revision 1, issued in October 2013, describes the methods and procedures that are acceptable to the NRC staff for implementing the requirements that relate to the initial activities and the major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and sequence in the regulations. The format and content of the estimates is also consistent with the recommendations of Regulatory Guide 1.202,[29] issued February 2005.

This analysis reflects lessons learned from TLGs involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, Crystal River, Vermont Yankee and Fort Calhoun nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

Work Difficulty Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment. WDFs are assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined, hazardous environments.

The ranges used for the WDFs are as follows:

x Access Factor 10% to 20%

x Respiratory Protection Factor 10% to 50%

x Radiation/ALARA Factor 10% to 15%

x Protective Clothing Factor 10% to 30%

x Work Break Factor 8.33%

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

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

The resulting labor-hours, or crew-hours, are used in the development of the TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 3 of 29 decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is based upon productivity information available from the "Building Construction Cost Data" publication.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs.

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

3.3.1 Contingency Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages.

In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.

The activity- and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers Project and Cost Engineers' Handbook[30] as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, contingency is included. In the AIF/NESP-036 study, the types of TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 4 of 29 unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for a contingency percentage in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 10% to 75%,

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

x Decontamination 50%

x Contaminated Component Removal 25%

x Contaminated Component Packaging 10%

x Contaminated Component Transport 15%

x Low-Level Radioactive Waste Disposal 25%

x Low-Level Radioactive Waste Processing 15%

x Reactor Segmentation 75%

x NSSS Component Removal 25%

x Reactor Waste Packaging 25%

x Reactor Waste Transport 25%

x Reactor Vessel Component Disposal 50%

x GTCC Disposal 15%

x Non-Radioactive Component Removal 15%

x Heavy Equipment and Tooling 15%

x Supplies 25%

x Engineering 15%

x Energy 15%

x Insurance, Taxes and Fees 10%

x Characterization and Termination Surveys 30%

x Operations and Maintenance Expense 15%

x ISFSI Decommissioning 25%

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 5 of 29 The contingency values are applied to the appropriate components of the estimates on a line item basis. A composite value is then reported at the end of the detailed estimate (as provided in Appendix C). A contingency of 25% is applied to the subtotal of the ISFSI decommissioning costs.

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

Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur.

Consideration is sometimes necessary to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term financial risk. Included within the category of financial risk are:

x Transition activities and costs: ancillary expenses associated with reducing the size of the labor force 50% to 80% shortly after the cessation of plant operations, national or company-mandated retraining, and retention incentives for key personnel.

x Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, legal challenges, and national and local hearings.

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

x Regulatory changes, for example, affecting worker health and safety, site release criteria, waste transportation, and disposal.

x Policy decisions altering national commitments (e.g., in the ability to accommodate certain waste forms for disposition, or in the timetable for such, or the start and rate of acceptance of spent fuel by the DOE).

x Pricing changes for basic inputs such as labor, energy, materials, and waste disposal.

This cost study does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 6 of 29 project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.

3.4 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study.

3.4.1 Spent Fuel Management The cost to dispose the spent fuel generated from plant operations is not reflected within the estimates to decommission PNPS. Ultimate disposition of the spent fuel is within the province of the DOEs Waste Management System, as defined by the Nuclear Waste Policy Act. As such, the disposal cost is financed by a surcharge paid into the DOEs waste fund during operations. On November 19, 2013, the U.S. Court of Appeals for the D.C. Circuit ordered the Secretary of the Department of Energy to suspend collecting annual fees for nuclear waste disposal from nuclear power plant operators until the DOE has conducted a legally adequate fee assessment.

The NRC does, however, require licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy. This requirement is prepared for through inclusion of certain high-level waste cost elements within the estimates, as described below.

Completion of the decommissioning process is highly dependent upon the DOEs ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel is accepted for disposal from the nation's commercial nuclear plants in the order (the "queue") in which it was removed from service ("oldest fuel first"). The DOE contracts provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst utilities and the option of providing priority acceptance from permanently shutdown nuclear reactors. Because it is unclear how these mechanisms may operate once DOE begins accepting spent fuel from commercial reactors, this study assumes that DOE will accept spent fuel in an oldest fuel first order. The timing for removal of spent fuel from the site is based upon the DOEs most recently published TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 7 of 29 annual acceptance rates of 400 MTU/year for year 1, 3,800 MTU total for years 2 through 4 and 3,000 MTU/year for year 5 and beyond.[31]

ISFSI Due to DOEs inability to remove fuel from the site, an ISFSI has been constructed at the site and fuel casks have been emplaced thereon to support continued plant operations. Additional storage capacity will be added to accommodate all the spent fuel generated during operations.

Assuming that DOE begins accepting commercial spent fuel from the industry in 2030, DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority, and a maximum rate of transfer of 3,000 metric tons of uranium (MTU)/year, as reflected in DOEs latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567), the removal of spent fuel from the site could be completed in 2062. Different DOE acceptance schedules may result in different completion dates. It is acknowledged that the plant owner will seek the most expeditious means of removing fuel from the site when DOE commences performance.

Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the estimates and address the cost for staffing the facility, as well as security, insurance, and licensing fees. The estimates include the costs to purchase, load, and transfer the multi-purpose spent fuel storage canisters (MPCs) from the pool to the ISFSI. Costs are also provided for transfer of the MPCs to the DOE from the ISFSI (although it is acknowledged that this may not occur and that the fuel in the MPCs may have to be repackaged at DOE expense).

Canister Loading and Transfer The estimates include the cost for the labor and equipment to load and transfer the spent fuel canisters to the ISFSI from the wet storage pool -

based upon HOLTECs HI-STORM dry storage system (68-assembly capacity MPCs). For estimating purposes, an allowance is used for the cost to transfer the fuel from the ISFSI into the DOE transport cask.

Operations and Maintenance The estimates also include the cost of operating and maintaining the spent fuel pool and the ISFSI, respectively. Pool operations are expected to continue approximately three and one half years after the cessation of operations. It is assumed that the time period provides the necessary TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 8 of 29 cooling period for the final core to meet the dry cask storage vendors system specifications. ISFSI operating costs are based upon the previously stated assumptions on fuel transfer and DOE performance (in removing the fuel from the site).

ISFSI Decommissioning In accordance with 10 CFR §72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan needs to contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor-related GTCC waste have been removed.

The dry storage vendor does not expect the concrete casks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is also expected to be extremely small. However, the decommissioning estimate is based on the premise that some of the concrete casks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 9 casks are assumed to be affected, i.e., contain residual radioactivity. The allowance is based upon the number of casks required for the final core off-load (i.e., 580 offloaded assemblies, 68 assemblies per cask) which results in 9 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of any neutron activation products.

No contamination or activation of the ISFSI pad is assumed. It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. As such, only verification surveys are included for the pad in the decommissioning estimate. The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use.

In accordance with the specific requirements of 10 CFR §72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities; 2) an adequate contingency factor; and 3) the cost of meeting the criteria for unrestricted use. The cost summary for decommissioning the ISFSI is presented in Appendix D.

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 9 of 29 GTCC The dismantling of the reactor internals is expected to generate radioactive waste considered unsuitable for shallow land disposal (i.e.,

low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. Although the DOE is responsible for disposing of GTCC waste, any costs for that service have not been determined. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used to store spent fuel and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel. The number of canisters required (two) and the packaged volume for GTCC was based upon experience at Maine Yankee (e.g., the constraints on loading as identified in the canisters certificate of compliance).

It is assumed only for purposes of these estimates that the DOE would not accept this waste prior to completing the transfer of spent fuel.

Therefore, until such time as the DOE is ready to accept GTCC waste, it is assumed that this material would remain in storage at the PNPS site.

It is acknowledged, however, that the plant owner will seek the most expeditious means of removing GTCC from the site when DOE commences performance.

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

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

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

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Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 10 of 29 Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (including the internals). However, its location on the Columbia River simplified the transportation analysis since:

x the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport, x there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and x transport speeds were very low, limited by the overland transport vehicle and the river barge.

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

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

It is not known whether this option will be available when PNPS is ultimately dismantled. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensees ability to accept highly radioactive packages and effectively isolate them from the environment. Additionally, with BWRs, the diameter of the reactor vessel may severely limit overland transport.

Consequently, the study assumes that the reactor vessel will require segmentation, as a bounding condition.

3.4.3 Primary System Components In the SAFSTOR scenario, the reactor recirculation system components are not assumed to be decontaminated (by chemical agents). The 50 year dormancy is expected to provide the necessary reduction in work area dose rates for dismantling operations.

Reactor recirculation piping is cut from the reactor vessel once the water level in the vessel (used for personnel shielding during dismantling and cutting operations in and around the vessel) is dropped below the nozzle zone. The piping is boxed and transported by shielded van. The reactor TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 11 of 29 recirculation pumps and motors are lifted out intact, packaged, and transported for processing and/or disposal.

3.4.4 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled demolition. The main condensers are also disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it is surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.

3.4.5 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.[32] The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart 10 CFR

§173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with 10 CFR Part 71, in Type B containers. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.

Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.

Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per shipment assumed TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 12 of 29 permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits.

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

Transportation costs for Class A radioactive material requiring controlled disposal are based upon the route and mileage to the EnergySolutions facility in Clive, Utah. Transportation costs for the higher activity Class B and C radioactive material are based upon the route and mileage to the WCS facility in Andrews County, Texas.

Transportation cost for the GTCC material is assumed to be included within the disposal charge. Transportation costs for off-site waste processing are based upon the route and mileage to Oak Ridge, Tennessee. Truck transport costs were developed from published tariffs from Tri-State Motor Transit.[33]

3.4.6 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptance criteria of the disposal site) and recovery of the waste stream is performed off site at a licensed processing center. Any material leaving the site is subject to a survey and release charge, at a minimum.

The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in the detailed Appendix C, and summarized in Section 5. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete.

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

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 13 of 29 The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Class A waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

The cost to dispose of the lowest level waste and the majority of the material generated from the decontamination and dismantling activities is based upon Entergys most recent services agreement with EnergySolutions. Disposal costs for the higher activity waste (Class B and C) is based upon Entergys current agreement with WCS.

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

A significant amount of the below grade piping is located around the perimeter of the power block. The estimate includes a cost to excavate this area to an average depth of twelve feet so as to expose the piping, duct bank, conduit, and any near-surface grounding grid. The overburden is surveyed and stockpiled on site for future use in backfilling the below grade voids.

The electrical switchyard remains after PNPS is decommissioned in support of the regional transmission and distribution system. The discharge canal and breakwater are also abandoned in place. Structures are removed to a nominal depth of three feet below grade. The voids are backfilled with clean debris and capped with soil. The site is then re-graded to conform to the adjacent landscape. Vegetation is established to inhibit erosion. These non-radiological costs are included in the total cost of decommissioning.

Concrete rubble generated from demolition activities is processed and made available as clean fill for the power block foundations. Additional TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 14 of 29 fill is brought in to cap the power block excavations and to permit seeding for erosion control.

The estimate includes the disposal of approximately 14,000 cubic feet of contaminated soil.

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

3.5.1 Estimating Basis Decommissioning costs are reported in the year of projected expenditure; however, the values are provided in 2018 dollars.

The 2008 plant inventory, the basis for the decontamination and dismantling requirements and cost, and the decommissioning waste streams, were reviewed for this analysis. There were no substantive changes made to the plant that would impact decommissioning except for the additions of the K1, LLRW, Trash Compaction and Maintenance Warehouse structures.

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

3.5.2 Labor Costs For purposes of this estimate, it is assumed that ENO (or a comparable organization) will manage the decontamination and dismantling of the nuclear unit, in addition to maintaining site security, radiological health and safety, quality assurance and overall site administration during the decommissioning. A Decommissioning Operations Contractor (DOC) will provide the supervisory staff needed to oversee the labor subcontractors, consultants, and specialty contractors engaged to perform the field work associated with the decontamination and dismantling efforts. An TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 15 of 29 independent contractor is assumed in the decommissioning of the ISFSI, as described in Section 3.4.1).

Reduction in the operating organization is assumed to be handled through normal company human resource practices (e.g., reassignment and outplacement). An allowance is included for severance, however, the severance is intended for the decommissioning organization only (i.e.,

not for reduction in the plant operating staff that is not retained for decommissioning. Severance for the non-essential (to decommissioning) operations personnel is typically considered to be an operating expense).

Personnel costs are based upon average salary information provided by ENO. Overhead costs are included for site and corporate support, reduced commensurate with the staffing of the project.

The craft labor required to decontaminate and dismantle the nuclear plant is acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis.

This estimate includes additional plant staffing resources to support the decommissioning engineering, planning, and licensing efforts for the plant, prior to the cessation of operations (one year duration). Costs for an external Decommissioning Project Organization (DPO) for project oversight are also included, as well as costs for external support contractors and consultants.

A profile of the staffing levels for decommissioning, including contractors and craft, is provided in Figure 3.1. Staffing levels and management support will vary based upon the amount and type of decommissioning work. Craft manpower levels decrease after systems removal and structures decontamination and drop substantially during the license termination survey period. However, craft levels increase again during the site restoration period due to the work associated with structures demolition.

Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel (in accordance with the requirements of 10 CFR Part 37, Part 72, and Part 73). Security costs include provisions for institutional overtime and recurring expenses while the pool is still operational. Once the fuel has been transferred to the DOE in 2062, the security organization will be reduced to Part 37 requirements.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 16 of 29 3.5.3 Design Conditions Activation levels in the vessel and internal components are based upon an activation analysis prepared by WMG, Inc.[34] The activation source terms were adjusted for the SAFSTOR decay period.

The disposal cost for the control blades removed from the vessel with the final core load is included within the estimate. Disposition of any blades stored in the pools from operations is considered an operating expense and therefore not accounted for in the decommissioning estimate.

Activation of the reactor building structures is assumed to be confined to the sacrificial shield and pedestal.

3.5.4 General Transition Activities Existing warehouses are cleared of non-essential material and remain for use by Entergy and its subcontractors. The warehouses are removed once they are no longer needed. The plants operating staff performs the following activities at no additional cost or credit to the project during the transition period:

x Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale.

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

x Process operating waste inventories. Disposal of operating wastes (e.g., filtration media, resins) during this initial period is not considered a decommissioning expense.

Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Entergy will make economically reasonable efforts to salvage equipment following final plant shutdown.

However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 17 of 29 equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts.

It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimates do not include the additional cost for size reduction and preparation to meet furnace ready conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project.

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

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

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

Emergency Planning The estimate includes FEMA, state and local fees associated with emergency planning.

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 18 of 29 guidance provided in SECY-00-0145, Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning.[35] The NRCs financial protection requirements are based on various reactor (and spent fuel) configurations.

Taxes Property taxes are included within the estimate for the years 2019 and 2020.

Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.

3.6 COST ESTIMATE

SUMMARY

Summaries of the decommissioning costs and annual expenditures are provided in Table 3.2. The schedules are based upon the costs reported in Appendix C.

The cost elements in Table C are assigned to one of three subcategories:

License Termination, Spent Fuel Management, and Site Restoration. The subcategory License Termination is used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR §50.75). The cost reported for this subcategory is generally sufficient to terminate the plants operating license, recognizing that there may be some additional cost impact from spent fuel management. The License Termination cost subcategory also includes costs to decommission the ISFSI (as required by 10 CFR §72.30). The basis for the ISFSI decommissioning cost is provided in Appendix D.

The Spent Fuel Management subcategory contains costs associated with the containerization and transfer of spent fuel from the pool to the ISFSI, and the transfer of the multipurpose canisters from the ISFSI to the DOE. Costs are also included for the operations of the pool and management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g., interim storage facility) is complete.

Site Restoration is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 19 of 29 materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are assumed to be removed to a nominal depth of three feet and backfilled to conform to local grade.

The disposal of the GTCC is assumed to be concurrent with the disposal of the other reactor internals. While designated for disposal at the geologic repository along with the spent fuel, GTCC waste is still classified as low-level radioactive waste and, as such, included as a License Termination expense.

Decommissioning costs are reported in 2018 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedules are based upon the detailed activity costs reported in Appendix C, along with the timeline presented in Section 4.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 20 of 29 TABLE 3.1 SPENT FUEL MANAGEMENT SCHEDULE (Fuel Assembly Totals by Location)

Pool ISFSI DOE Year Inventory Inventory Acceptance[1]

2018 2,378 1,156 2019 2,958 1,156 2020 2,958 1,156 2021 2,958 1,156 2022 - 4,114 2023 4,114 2024 4,114 2025 4,114 2026 4,114 2027 4,114 2028 4,114 2029 4,114 2030 4,094 20 2031 3,962 132 2032 3,534 428 2033 3,534 -

2034 3,442 92 2035 3,210 232 2036 2,986 224 2037 2,986 -

2038 2,794 192 2039 2,794 -

2040 2,794 -

2041 2,626 168 2042 2,486 140 2043 2,350 136 2044 2,350 -

2045 2,144 206 2046 2,128 16 2047 1,984 144 2048 1,840 144 2049 1,676 164 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 21 of 29 TABLE 3.1 (continued)

SPENT FUEL MANAGEMENT SCHEDULE (Fuel Assembly Totals by Location)

Pool ISFSI DOE Year Inventory Inventory Acceptance[1]

2050 1,676 -

2051 1,516 160 2052 1,356 160 2053 1,356 -

2054 1,200 156 2055 1,048 152 2056 1,048 -

2057 896 152 2058 896 -

2059 752 144 2060 580 172 2061 580 -

2062 - 580 Total 4,114

[1] DOE acceptance schedule provided by Energy Resources International, Inc., assuming industry acceptance begins in year 2030. The schedule is provided for illustrative purposes only. It is expected that ENGC will seek to accelerate acceptance based on shutdown reactor priority, exchanges of acceptance allocations and other contractual provisions.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 22 of 29 TABLE 3.2 TOTAL ANNUAL EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2018 4,033 12,100 0 0 19,142 35,275 2019 57,094 36,553 1,409 276 64,708 160,040 2020 34,789 29,355 1,572 539 50,013 116,268 2021 25,798 24,684 1,157 323 42,968 94,930 2022 25,798 24,684 1,157 323 40,735 92,697 2023 6,464 130 524 7 20,273 27,398 2024 6,481 130 525 7 4,075 11,219 2025 6,464 130 524 7 3,444 10,569 2026 6,464 130 524 7 3,069 10,194 2027 6,464 130 524 7 3,069 10,194 2028 6,481 130 525 7 3,075 10,219 2029 6,464 130 524 7 3,069 10,194 2030 6,464 130 524 7 3,069 10,194 2031 6,550 389 524 7 3,069 10,539 2032 6,783 1,036 525 7 3,075 11,427 2033 6,464 130 524 7 3,069 10,194 2034 6,507 259 524 7 3,069 10,366 2035 6,636 648 524 7 3,069 10,884 2036 6,611 519 525 7 3,075 10,737 2037 6,464 130 524 7 3,069 10,194 2038 6,593 518 524 7 3,069 10,711 2039 6,464 130 524 7 3,069 10,194 2040 6,481 130 525 7 3,075 10,219 2041 6,593 518 524 7 3,069 10,711 2042 6,550 389 524 7 3,069 10,539 2043 6,550 389 524 7 3,069 10,539 2044 6,481 130 525 7 3,075 10,219 2045 6,593 518 524 7 3,069 10,711 2046 6,464 130 524 7 3,069 10,194 2047 6,550 389 524 7 3,069 10,539 2048 6,568 389 525 7 3,075 10,564 2049 6,593 518 524 7 3,069 10,711 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 23 of 29 TABLE 3.2 (continued)

TOTAL ANNUAL EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2050 6,464 130 524 7 3,069 10,194 2051 6,550 389 524 7 3,069 10,539 2052 6,568 389 525 7 3,075 10,564 2053 6,464 130 524 7 3,069 10,194 2054 6,550 389 524 7 3,069 10,539 2055 6,550 389 524 7 3,069 10,539 2056 6,481 130 525 7 3,075 10,219 2057 6,550 389 524 7 3,069 10,539 2058 6,464 130 524 7 3,069 10,194 2059 6,550 389 524 7 3,069 10,539 2060 6,611 519 525 7 3,075 10,737 2061 6,464 130 524 7 3,069 10,194 2062 6,852 1,294 524 7 3,069 11,746 2063 1,663 298 216 6 2,514 4,697 2064 1,668 298 217 6 2,521 4,710 2065 1,663 298 216 6 2,514 4,697 2066 1,663 298 216 6 2,514 4,697 2067 1,663 298 216 6 2,514 4,697 2068 1,668 298 217 6 2,521 4,710 2069 1,663 298 216 6 2,514 4,697 2070 1,663 298 216 6 2,514 4,697 2071 1,663 298 216 6 2,514 4,697 2072 1,668 298 217 6 2,521 4,710 2073 22,736 1,183 1,324 21 3,694 28,959 2074 38,964 8,295 2,154 5,384 7,668 62,464 2075 47,918 24,281 2,053 68,469 17,586 160,307 2076 63,669 15,103 1,775 41,144 16,992 138,683 2077 66,458 10,162 1,621 26,451 16,606 121,298 2078 56,977 7,375 1,230 17,765 13,112 96,460 2079 28,238 4,772 305 12 5,397 38,724 2080 19,909 6,356 198 0 4,580 31,044 Total 770,385 220,980 39,095 161,050 469,748 1,661,258 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 24 of 29 TABLE 3.2a LICENSE TERMINATION EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2018 0 0 0 0 19,142 19,142 2019 45,256 1,040 1,409 276 52,043 100,024 2020 22,178 1,040 1,572 539 36,245 61,574 2021 13,526 454 1,157 323 30,572 46,032 2022 13,526 454 1,157 323 28,339 43,799 2023 2,276 130 524 7 11,579 14,516 2024 2,282 130 525 7 3,953 6,897 2025 2,276 130 524 7 3,322 6,259 2026 2,276 130 524 7 2,947 5,884 2027 2,276 130 524 7 2,947 5,884 2028 2,282 130 525 7 2,953 5,897 2029 2,276 130 524 7 2,947 5,884 2030 2,276 130 524 7 2,947 5,884 2031 2,276 130 524 7 2,947 5,884 2032 2,282 130 525 7 2,953 5,897 2033 2,276 130 524 7 2,947 5,884 2034 2,276 130 524 7 2,947 5,884 2035 2,276 130 524 7 2,947 5,884 2036 2,282 130 525 7 2,953 5,897 2037 2,276 130 524 7 2,947 5,884 2038 2,276 130 524 7 2,947 5,884 2039 2,276 130 524 7 2,947 5,884 2040 2,282 130 525 7 2,953 5,897 2041 2,276 130 524 7 2,947 5,884 2042 2,276 130 524 7 2,947 5,884 2043 2,276 130 524 7 2,947 5,884 2044 2,282 130 525 7 2,953 5,897 2045 2,276 130 524 7 2,947 5,884 2046 2,276 130 524 7 2,947 5,884 2047 2,276 130 524 7 2,947 5,884 2048 2,282 130 525 7 2,953 5,897 2049 2,276 130 524 7 2,947 5,884 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 25 of 29 TABLE 3.2a (continued)

LICENSE TERMINATION EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2050 2,276 130 524 7 2,947 5,884 2051 2,276 130 524 7 2,947 5,884 2052 2,282 130 525 7 2,953 5,897 2053 2,276 130 524 7 2,947 5,884 2054 2,276 130 524 7 2,947 5,884 2055 2,276 130 524 7 2,947 5,884 2056 2,282 130 525 7 2,953 5,897 2057 2,276 130 524 7 2,947 5,884 2058 2,276 130 524 7 2,947 5,884 2059 2,276 130 524 7 2,947 5,884 2060 2,282 130 525 7 2,953 5,897 2061 2,276 130 524 7 2,947 5,884 2062 2,276 130 524 7 2,947 5,884 2063 1,663 298 216 6 2,514 4,697 2064 1,668 298 217 6 2,521 4,710 2065 1,663 298 216 6 2,514 4,697 2066 1,663 298 216 6 2,514 4,697 2067 1,663 298 216 6 2,514 4,697 2068 1,668 298 217 6 2,521 4,710 2069 1,663 298 216 6 2,514 4,697 2070 1,663 298 216 6 2,514 4,697 2071 1,663 298 216 6 2,514 4,697 2072 1,668 298 217 6 2,521 4,710 2073 22,411 1,183 1,324 21 3,694 28,634 2074 38,252 8,293 2,154 5,384 7,668 61,751 2075 47,682 24,256 2,053 68,469 17,586 160,046 2076 63,341 15,092 1,775 41,144 16,992 138,344 2077 66,082 10,159 1,621 26,451 16,606 120,920 2078 56,725 7,373 1,230 17,765 13,112 96,205 2079 15,548 693 178 12 2,457 18,888 2080 137 0 0 0 0 137 Total 512,400 78,223 38,769 161,050 397,552 1,187,994 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 26 of 29 TABLE 3.2b SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2018 4,033 12,100 0 0 0 16,133 2019 11,838 35,513 0 0 12,665 60,016 2020 12,611 28,315 0 0 13,768 54,694 2021 12,272 24,230 0 0 12,396 48,898 2022 12,272 24,230 0 0 12,396 48,898 2023 4,188 0 0 0 8,694 12,882 2024 4,200 0 0 0 122 4,322 2025 4,188 0 0 0 122 4,310 2026 4,188 0 0 0 122 4,310 2027 4,188 0 0 0 122 4,310 2028 4,200 0 0 0 122 4,322 2029 4,188 0 0 0 122 4,310 2030 4,188 0 0 0 122 4,310 2031 4,274 259 0 0 122 4,655 2032 4,501 906 0 0 122 5,529 2033 4,188 0 0 0 122 4,310 2034 4,231 129 0 0 122 4,482 2035 4,361 518 0 0 122 5,000 2036 4,329 388 0 0 122 4,839 2037 4,188 0 0 0 122 4,310 2038 4,317 388 0 0 122 4,827 2039 4,188 0 0 0 122 4,310 2040 4,200 0 0 0 122 4,322 2041 4,317 388 0 0 122 4,827 2042 4,274 259 0 0 122 4,655 2043 4,274 259 0 0 122 4,655 2044 4,200 0 0 0 122 4,322 2045 4,317 388 0 0 122 4,827 2046 4,188 0 0 0 122 4,310 2047 4,274 259 0 0 122 4,655 2048 4,286 259 0 0 122 4,667 2049 4,317 388 0 0 122 4,827 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 27 of 29 TABLE 3.2b (continued)

SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2050 4,188 0 0 0 122 4,310 2051 4,274 259 0 0 122 4,655 2052 4,286 259 0 0 122 4,667 2053 4,188 0 0 0 122 4,310 2054 4,274 259 0 0 122 4,655 2055 4,274 259 0 0 122 4,655 2056 4,200 0 0 0 122 4,322 2057 4,274 259 0 0 122 4,655 2058 4,188 0 0 0 122 4,310 2059 4,274 259 0 0 122 4,655 2060 4,329 388 0 0 122 4,839 2061 4,188 0 0 0 122 4,310 2062 4,576 1,164 0 0 122 5,862 Total 223,294 132,279 0 0 64,677 420,250 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 3, Page 28 of 29 TABLE 3.2c SITE RESTORATION EXPENDITURES (thousands, 2018 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2018-72 0 0 0 0 0 0 2073 325 0 0 0 0 325 2074 712 2 0 0 0 713 2075 236 25 0 0 0 261 2076 328 11 0 0 0 339 2077 376 3 0 0 0 379 2078 252 2 0 0 0 254 2079 12,690 4,079 127 0 2,939 19,836 2080 19,772 6,356 198 0 4,580 30,907 Total 34,691 10,478 326 0 7,519 53,014 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Section 3, Page 29 of 29 FIGURE 3.1 SITE STAFFING LEVELS (Full Time Equivalent Positions) 0 0

(D 0

0 L()

0 0

0 0

S3J..:I (")

N 0 0

I 0

0 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 4, Page 1 of 4

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

A schedule or sequence of activities for the decommissioning scenario is presented in Figure 4.1. The scheduling sequence is based on the fuel being removed from the spent fuel pool in three years. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost table, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project Professional" computer software.[36]

4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique) Software Package. The work activity durations used in the precedence network reflect the actual man-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:

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

x All work (except reactor vessel and reactor vessel internals removal and the spent fuel loading campaigns) is performed during an 8-hour workday, 5 days per week, with no overtime.

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

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

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 4, Page 2 of 4 4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based upon the durations developed in the schedules for decommissioning. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs.

A project timeline is provided in Figure 4.2, with milestone dates based on the 2019 shutdown date. The fuel pool is emptied approximately three years after shutdown, while ISFSI operations continue until the DOE can complete the removal of spent fuel from the site.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 4, Page 3 of 4 FIGURE 4.1 ACTIVITY SCHEDULE LEGEND

1. Red scheduling bars indicate critical path activities

2. Blue scheduling bars associated with major decommissioning periods, e.g., Period 1a, indicate overall duration of that period

3. Diamond symbols indicate major milestones TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 4, Page 4 of 4 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale)

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 5, Page 1 of 5

5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[37] the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.

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

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

The destinations for the various waste streams from decommissioning are identified in Figures 5.1 and 5.2. The volumes are shown on a line-item basis in Appendix C and summarized in Table 5.1. The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.

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

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

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

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

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

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 5, Page 2 of 5 The waste material produced in the decontamination and dismantling of the nuclear plant is primarily generated during Period 2. Material that is considered potentially contaminated when removed from the radiological controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.

For purposes of constructing the estimate, the current cost for disposal at EnergySolutions facility in Clive, Utah was used for a majority of the radioactive waste produced from the decommissioning activities. Separate rates were used for containerized waste and large components. Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste.

Since the EnergySolutions facility is not currently able to receive the more highly radioactive components generated in the decontamination and dismantling of the reactor, disposal costs for the Class B and C material were based upon Entergys current agreement with WCS for the Andrews County disposal facility.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 5, Page 3 of 5 FIGURE 5.1 RADIOACTIVE WASTE DISPOSITION DAW Resin / Filters (Class A)

Direct Burial EnergySolutions Containerized Clive, Utah Waste Decommissioning Bulk Waste Low-Level Radioactive Waste (Contaminated Soil Streams and Concrete)

Reactor Waste (Class A)

EnergySolutions Metal Bear Creek Processing Oak Ridge, TN Reactor Waste (Classes B/C)

Waste Control Specialists Andrews County, Resin Texas NSSS Decontamination (Class B/C)

Reactor Waste Geologic Disposal (Class GTCC) Federal Facility TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 5, Page 4 of 5 FIGURE 5.2 DECOMMISSIONING WASTE DESTINATIONS RADIOLOGICAL EnergySolutions Clive, UT Bear Creek Oak Ridge, TN Waste Control Specialists Andrews County, TX The figure indicates the destinations for the low-level radioactive waste designated for direct disposal (Clive, Utah and Andrews County, Texas) and processing/

recovery (Oak Ridge, Tennessee).

Disposal options (and destinations) for GTCC are still being evaluated.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 5, Page 5 of 5 TABLE 5.1 DECOMMISSIONING WASTE

SUMMARY

Waste Volume Mass Waste Cost Basis Class [1] (cubic feet) (pounds)

Low-Level Radioactive EnergySolutions Waste (near-surface Containerized A 88,453 5,624,824 disposal) EnergySolutions Bulk A 174,149 7,487,311 WCS B 1,753 165,640 WCS C 742 81,096 Greater than Class C Spent Fuel (geologic repository) Equivalent GTCC 817 169,336 Total (Direct Disposal)[2] 265,913 13,528,206 Processed/Conditioned (off-site recycling/recovery Recycling center) Vendors A 596,942 24,470,490

[1] Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55

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

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 6, Page 1 of 4

6. RESULTS The analysis to estimate the costs to decommission PNPS relied upon the site-specific, technical information developed for a previous analysis prepared in 2008.

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

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

The cost projected for radiological remediation, dismantling the structures, and managing the spent fuel is estimated to be $1.661.2 billion. The majority of this cost (approximately 71.5%) is associated with the physical decontamination and dismantling of the nuclear plant so that the operating license can be terminated.

Another 25.3% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 3.2% is for the demolition of the designated structures and limited restoration of the site.

The primary cost contributors, identified in Table 6.1, are either labor-related or associated with the management and disposition of the radioactive waste. Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the decommissioning, as well as the duration of the program.

As described in this report, the spent fuel pool will remain operational for approximately three and one half years following the cessation of operations. The pool will be isolated which will allow decommissioning operations to proceed in and around the pool area. Over the time period, the spent fuel will be packaged into canisters and transferred to the ISFSI.

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

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 6, Page 2 of 4 A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processes as survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at one of the currently operating facilities. The cost identified in the summary tables for processing is all-inclusive, incorporating the ultimate disposition of the material.

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

Decontamination and packaging costs also have a large labor component that is based upon prevailing wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license.

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

Decontamination is used to reduce the plants radiation fields and minimize worker exposure. Slightly contaminated material or material located within a contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for uncontrolled release in-situ. Centralized processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear plant.

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

The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 6, Page 3 of 4 final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 6, Page 4 of 4 TABLE 6.1 DECOMMISSIONING COST ELEMENTS (thousands of 2018 dollars)

Cost Element Total Percentage Preparations for Safe-Storage 32,497 2.0 PNPS Projects 30,130 1.8 Decontamination 16,770 1.0 Removal 172,716 10.4 Packaging 16,255 1.0 Transportation 18,828 1.1 Waste Disposal 95,053 5.7 Off-site Waste Processing 71,574 4.3 Program Management [1] 424,299 25.5 Security 176,042 10.6 ISFSI and Spent Fuel Pool Operating Costs 12,580 0.8 DFS [2] 176,373 10.6 Insurance 52,899 3.2 Energy 39,321 2.4 Characterization and Licensing Surveys 27,248 1.6 Property Taxes 16,467 1.0 Site O&M 70,626 4.3 Corporate A&G 98,899 6.0 Regulatory / NRC 18,427 1.1 NDO Contingency 80,741 4.9 Legal 7,015 0.4 ETR Oversight 4,140 0.2 Finance & Interest 6,740 0.4 Defueling Credit -12,492 -0.8 Emergency Planning 8,111 0.5 Total [3] 1,661,258 100.0 Cost Category Total Percentage License Termination 1,187,994 71.5 Spent Fuel Management 420,250 25.3 Site Restoration 53,014 3.2 Total [3] 1,661,258 100.0

[1] Includes engineering costs

[2] Excludes program management costs (staffing) but includes costs for spent fuel loading/transfer costs

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

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 7, Page 1 of 3

7. REFERENCES

1. Preliminary Decommissioning Cost Analysis for the Pilgrim Nuclear Power Station, Document E11-5690-003, Rev. 0, TLG Services, Inc., July 2008

2. Letter, Entergy Nuclear Operations, Inc., to USNRC, Notification of Permanent Cessation of Power Operations, Pilgrim Station, November 10, 2015 (ADAMS Accession No. ML15328A053)

3. U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, 53 Fed. Reg. 24018, June 27, 1988 [Open]

4. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Rev. 2, October 2011 [Open]

5. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination [Open]

6. U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, Entombment Options for Power Reactors, Advance Notice of Proposed Rulemaking, 66 Fed.

Reg. 52551, October 16, 2001 [Open]

7. U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, 61 Fed. Reg. 39278, July 29, 1996 [Open]

8. U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70, and 72, "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, (p 35512 et seq.), June 17, 2011 [Open]

9. Nuclear Waste Policy Act of 1982, 42 U.S. Code 10101, et seq. [Open]

10. Charter of the Blue Ribbon Commission on Americas Nuclear Future, Objectives and Scope of Activities [Open]

11. Blue Ribbon Commission on Americas Nuclear Future, Report to the Secretary of Energy, p. 27, 32, January 2012 [Open]

12. Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S. DOE, January 11, 2013 [Open]

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 7, Page 2 of 3

7. REFERENCES (continued)

13. United States Court of Appeals for the District of Columbia Circuit, In Re:

Aiken County, Et Al., August 2013 [Open]

14. Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004

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

[Open]

16. U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites [Open]

17. Low-Level Radioactive Waste Policy Act, Public Law 96-573, 1980 [Open]

18. Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, January 15, 1986 [Open]

19. U.S. Code of Federal Regulations, Title 10, Part 61, Licensing Requirements for Land Disposal of Radioactive Waste [Open]

20. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Final Rule, Radiological Criteria for License Termination, 62 Fed. Reg. 39058, July 21, 1997 [Open]

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

[Open]

22. U.S. Code of Federal Regulations, Title 40, Part 141.66, Maximum contaminant levels for radionuclides [Open]

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

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

NUREG-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000 [Open]

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Section 7, Page 3 of 3

7. REFERENCES (continued)

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

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

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

27. "Building Construction Cost Data 2018," RSMeans (From the Gordian Group),

Rockland, Massachusetts

28. Decommissioning of Nuclear Power Reactors, Regulatory Guide 1.184, Nuclear Regulatory Commission, October 2013 [Open]

29. Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Regulatory Guide 1.202, Nuclear Regulatory Commission, February 2005 [Open]

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

31. DOE/RW-0351, Civilian Radioactive Waste Management System Waste Acceptance System Requirements Document, Revision 5, May 31, 2007 [Open]

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

33. Tri-State Motor Transit Company, Radioactive Materials Tariffs, TSMT 4007-E, January 2018

34. Pilgrim Nuclear Power Station Reactor Vessel and Internals Activation Evaluation, Report 17-318-RE-226, Revision 0, WMG Inc., February 2018

35. SECY-00-0145, Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning, June 2000

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

37. Atomic Energy Act of 1954, (68 Stat. 919) [Open]

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix A, Page 1 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix A, Page 2 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example: Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

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

2. CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes) (minutes)*

a Remove insulation 60 (b) b Mount pipe cutters 60 60 c Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e Cap openings 20 (d) f Rig for removal 30 30 g Unbolt from mounts 30 30 h Remove contamination controls 15 15 i Remove, wrap, send to waste processing area 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):

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

+ Radiation/ALARA adjustment (15% of critical duration) 38 Adjusted work duration 421

+ Protective clothing adjustment (30% of adjusted duration) 126 Productive work duration 547

+ Work break adjustment (8.33 % of productive duration) 46 Total work duration (minutes) 593

• • • Total duration = 9.883 hr ***

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

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix A, Page 3 of 4 APPENDIX A (continued)

3. LABOR REQUIRED Duration Rate Crew Number (hours) ($/hr) Cost Laborers 3.00 9.883 $69.13 $2,049.64 Craftsmen 2.00 9.883 $85.29 $1,685.84 Foreman 1.00 9.883 $91.07 $900.04 General Foreman 0.25 9.883 $96.60 $238.67 Fire Watch 0.05 9.883 $69.13 $34.16 Health Physics Technician 1.00 9.883 $67.29 $665.03 Total Labor Cost $5,573.38

4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs

-Universal Sorbent 50 @ $0.59 sq ft {1} $29.50

-Tarpaulins (oil resistant/fire retardant) 50 @ $0.46/sq ft {2} $23.00

-Gas torch consumables 1 @ $19.74/hr x 1 hr {3} $19.74 Subtotal cost of equipment and materials $72.24 Overhead & profit on equipment and materials @ 16.25 % $11.74 Total costs, equipment & material $83.98 TOTAL COST:

Removal of contaminated heat exchanger <3000 pounds: $5,657.36 Total labor cost: $5,573.38 Total equipment/material costs: $83.98 Total craft labor man-hours required per unit: 72.15 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix A, Page 4 of 4

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

x References for equipment & consumables costs:

1. www.mcmaster.com online catalog, McMaster Carr Spill Control (7193T88)

2. R.S. Means (2018) Division 01 56, Section 13.60-0600, page 23

3. R.S. Means (2018) Division 01 54 33, Section 40-6360, page 734 x Material and consumable costs were adjusted using the regional indices for Brockton, Massachusetts TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 1 of 7 APPENDIX B UNIT COST FACTOR LISTING (DECON: Power Block Structures Only)

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.75 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 8.04 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 11.42 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 21.98 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 42.64 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 55.40 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 81.52 Removal of clean pipe >36 inches diameter, $/linear foot 96.88 Removal of clean valve >2 to 4 inches 146.83 Removal of clean valve >4 to 8 inches 219.84 Removal of clean valve >8 to 14 inches 426.41 Removal of clean valve >14 to 20 inches 554.04 Removal of clean valve >20 to 36 inches 815.25 Removal of clean valve >36 inches 968.77 Removal of clean pipe hanger for small bore piping 49.63 Removal of clean pipe hanger for large bore piping 179.09 Removal of clean pump, <300 pound 370.18 Removal of clean pump, 300-1000 pound 1,020.35 Removal of clean pump, 1000-10,000 pound 4,048.49 Removal of clean pump, >10,000 pound 7,827.60 Removal of clean pump motor, 300-1000 pound 427.65 Removal of clean pump motor, 1000-10,000 pound 1,683.78 Removal of clean pump motor, >10,000 pound 3,788.52 Removal of clean heat exchanger <3000 pound 2,174.92 Removal of clean heat exchanger >3000 pound 5,471.96 Removal of clean feedwater heater/deaerator 15,418.54 Removal of clean moisture separator/reheater 31,689.34 Removal of clean tank, <300 gallons 476.25 Removal of clean tank, 300-3000 gallon 1,502.95 Removal of clean tank, >3000 gallons, $/square foot surface area 12.51 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean electrical equipment, <300 pound 201.59 Removal of clean electrical equipment, 300-1000 pound 696.25 Removal of clean electrical equipment, 1000-10,000 pound 1,392.50 Removal of clean electrical equipment, >10,000 pound 3,307.67 Removal of clean electrical transformer < 30 tons 2,297.13 Removal of clean electrical transformer > 30 tons 6,615.34 Removal of clean standby diesel generator, <100 kW 2,346.32 Removal of clean standby diesel generator, 100 kW to 1 MW 5,237.13 Removal of clean standby diesel generator, >1 MW 10,841.94 Removal of clean electrical cable tray, $/linear foot 18.88 Removal of clean electrical conduit, $/linear foot 8.25 Removal of clean mechanical equipment, <300 pound 201.59 Removal of clean mechanical equipment, 300-1000 pound 696.25 Removal of clean mechanical equipment, 1000-10,000 pound 1,392.50 Removal of clean mechanical equipment, >10,000 pound 3,307.67 Removal of clean HVAC equipment, <300 pound 243.77 Removal of clean HVAC equipment, 300-1000 pound 836.61 Removal of clean HVAC equipment, 1000-10,000 pound 1,667.34 Removal of clean HVAC equipment, >10,000 pound 3,307.67 Removal of clean HVAC ductwork, $/pound 0.79 Removal of contaminated instrument and sampling tubing, $/linear foot 2.02 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 28.29 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 48.15 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 76.22 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 149.95 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 180.48 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 250.86 Removal of contaminated pipe >36 inches diameter, $/linear foot 296.45 Removal of contaminated valve >2 to 4 inches 588.37 Removal of contaminated valve >4 to 8 inches 694.69 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated valve >8 to 14 inches 1,438.46 Removal of contaminated valve >14 to 20 inches 1,835.12 Removal of contaminated valve >20 to 36 inches 2,447.52 Removal of contaminated valve >36 inches 2,903.51 Removal of contaminated pipe hanger for small bore piping 192.12 Removal of contaminated pipe hanger for large bore piping 640.10 Removal of contaminated pump, <300 pound 1,225.91 Removal of contaminated pump, 300-1000 pound 2,847.99 Removal of contaminated pump, 1000-10,000 pound 9,507.36 Removal of contaminated pump, >10,000 pound 23,115.38 Removal of contaminated pump motor, 300-1000 pound 1,213.78 Removal of contaminated pump motor, 1000-10,000 pound 3,851.68 Removal of contaminated pump motor, >10,000 pound 8,662.55 Removal of contaminated heat exchanger <3000 pound 5,657.36 Removal of contaminated heat exchanger >3000 pound 16,417.38 Removal of contaminated feedwater heater/deaerator 40,789.65 Removal of contaminated moisture separator/reheater 89,294.45 Removal of contaminated tank, <300 gallons 2,039.81 Removal of contaminated tank, >300 gallons, $/square foot 40.73 Removal of contaminated electrical equipment, <300 pound 965.68 Removal of contaminated electrical equipment, 300-1000 pound 2,323.23 Removal of contaminated electrical equipment, 1000-10,000 pound 4,480.36 Removal of contaminated electrical equipment, >10,000 pound 8,906.78 Removal of contaminated electrical cable tray, $/linear foot 46.78 Removal of contaminated electrical conduit, $/linear foot 22.82 Removal of contaminated mechanical equipment, <300 pound 1,076.13 Removal of contaminated mechanical equipment, 300-1000 pound 2,598.21 Removal of contaminated mechanical equipment, 1000-10,000 pound 5,000.83 Removal of contaminated mechanical equipment, >10,000 pound 8,906.78 Removal of contaminated HVAC equipment, <300 pound 1,076.13 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated HVAC equipment, 300-1000 pound 2,598.21 Removal of contaminated HVAC equipment, 1000-10,000 pound 5,000.83 Removal of contaminated HVAC equipment, >10,000 pound 8,906.78 Removal of contaminated HVAC ductwork, $/pound 2.70 Removal/plasma arc cut of contaminated thin metal components, $/linear in. 5.22 Additional decontamination of surface by washing, $/square foot 10.70 Additional decontamination of surfaces by hydrolasing, $/square foot 45.75 Decontamination rig hook up and flush, $/ 250 foot length 9,077.11 Chemical flush of components/systems, $/gallon 19.99 Removal of clean standard reinforced concrete, $/cubic yard 80.31 Removal of grade slab concrete, $/cubic yard 91.38 Removal of clean concrete floors, $/cubic yard 487.97 Removal of sections of clean concrete floors, $/cubic yard 1,494.56 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 116.13 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 2,640.28 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 157.42 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 3,490.79 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 604.94 Removal of below-grade suspended floors, $/cubic yard 220.85 Removal of clean monolithic concrete structures, $/cubic yard 1,248.22 Removal of contaminated monolithic concrete structures, $/cubic yard 2,628.61 Removal of clean foundation concrete, $/cubic yard 978.54 Removal of contaminated foundation concrete, $/cubic yard 2,446.16 Explosive demolition of bulk concrete, $/cubic yard 65.17 Removal of clean hollow masonry block wall, $/cubic yard 27.91 Removal of contaminated hollow masonry block wall, $/cubic yard 65.08 Removal of clean solid masonry block wall, $/cubic yard 27.91 Removal of contaminated solid masonry block wall, $/cubic yard 65.08 Backfill of below-grade voids, $/cubic yard 31.35 Removal of subterranean tunnels/voids, $/linear foot 154.52 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Placement of concrete for below-grade voids, $/cubic yard 154.35 Excavation of clean material, $/cubic yard 3.46 Excavation of contaminated material, $/cubic yard 45.77 Removal of clean concrete rubble (tipping fee included), $/cubic yard 28.37 Removal of contaminated concrete rubble, $/cubic yard 27.70 Removal of building by volume, $/cubic foot 0.38 Removal of clean building metal siding, $/square foot 1.91 Removal of contaminated building metal siding, $/square foot 5.54 Removal of standard asphalt roofing, $/square foot 3.52 Removal of transite panels, $/square foot 2.93 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 14.80 Scabbling contaminated concrete floors, $/square foot 9.47 Scabbling contaminated concrete walls, $/square foot 25.85 Scabbling contaminated ceilings, $/square foot 89.13 Scabbling structural steel, $/square foot 7.83 Removal of clean overhead crane/monorail < 10 ton capacity 966.29 Removal of contaminated overhead crane/monorail < 10 ton capacity 2,376.16 Removal of clean overhead crane/monorail >10-50 ton capacity 2,319.09 Removal of contaminated overhead crane/monorail >10-50 ton capacity 5,699.95 Removal of polar crane > 50 ton capacity 9,689.58 Removal of gantry crane > 50 ton capacity 41,345.84 Removal of structural steel, $/pound 0.27 Removal of clean steel floor grating, $/square foot 6.85 Removal of contaminated steel floor grating, $/square foot 17.22 Removal of clean free standing steel liner, $/square foot 18.76 Removal of contaminated free standing steel liner, $/square foot 47.41 Removal of clean concrete-anchored steel liner, $/square foot 9.38 Removal of contaminated concrete-anchored steel liner, $/square foot 55.05 Placement of scaffolding in clean areas, $/square foot 19.25 Placement of scaffolding in contaminated areas, $/square foot 31.74 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Landscaping with topsoil, $/acre 24,472.73 Cost of CPC B-88 LSA box & preparation for use 2,071.96 Cost of CPC B-25 LSA box & preparation for use 1,946.29 Cost of CPC B-12V 12 gauge LSA box & preparation for use 1,672.59 Cost of CPC B-144 LSA box & preparation for use 10,319.90 Cost of LSA drum & preparation for use 248.32 Cost of cask liner for CNSI 8 120A cask (resins) 12,389.69 Cost of cask liner for CNSI 8 120A cask (filters) 9,101.60 Decontamination of surfaces with vacuuming, $/square foot 1.12 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix C, Page 1 of 10 APPENDIX C DETAILED COST ANALYSIS TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 2 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours PERIOD 0a - Pre-Shutdown Early Planning 0a.2.8 PNPS Pre Planning - - - - - - 18,497 - 18,497 18,497 - - - - - - - - - -

0a.2.9 PNPS Transaction Cost - - - - - - 14,000 - 14,000 14,000 - - - - - - - - - -

0a.2 Subtotal Period 0a Additional Costs - - - - - - 32,497 - 32,497 32,497 - - - - - - - - - -

Period 0a Collateral Costs 0a.3.1 Dry Fuel Storage (DFS) Project - - - - - - 23,816 3,572 27,388 - 27,388 - - - - - - - - -

0a.3 Subtotal Period 0a Collateral Costs - - - - - - 23,816 3,572 27,388 - 27,388 - - - - - - - - -

0a.0 TOTAL PERIOD 0a COST - - - - - - 56,313 3,572 59,885 32,497 27,388 - - - - - - - - -

PERIOD 0 TOTALS - - - - - - 56,313 3,572 59,885 32,497 27,388 - - - - - - - - -

PERIOD 1a - Shutdown through Transition Period 1a Additional Costs 1a.2.2 PNPS Spent Fuel Island Modificaitons - - - - - - 419 63 481 481 - - - - - - - - - -

1a.2.3 PNPS System Abandonment Modifications - - - - - - 42 6 48 48 - - - - - - - - - -

1a.2.4 PNPS Instrument Air Modifications - - - - - - 42 6 48 48 - - - - - - - - - -

1a.2.5 PNPS Control Room HVAC Modifications - - - - - - 35 5 40 40 - - - - - - - - - -

1a.2.6 PNPS Security Modifications - - - - - - 349 52 401 401 - - - - - - - - - -

1a.2.7 PNPS IT Modifications - - - - - - 70 10 80 80 - - - - - - - - - -

1a.2.10 PNPS Radwaste System Modifications - - - - - - 70 10 80 80 - - - - - - - - - -

1a.2.12 Corporate A&G - - - - - - 1,995 299 2,294 1,037 1,257 - - - - - - - - -

1a.2.20 Defueling Credit - - - - - - (10,863) (1,629) (12,492) (11,992) (501) - - - - - - - - -

1a.2 Subtotal Period 1a Additional Costs - - - - - - (8,349) (1,328) (9,678) (10,435) 757 - - - - - - - - -

Period 1a Collateral Costs 1a.3.1 Dry Fuel Storage (DFS) Project - - - - - - 4,424 664 5,088 - 5,088 - - - - - - - - -

1a.3.2 Legal - - - - - - 167 25 193 193 - - - - - - - - - -

1a.3.4 Site O&M - - - - - - 1,279 192 1,471 1,471 - - - - - - - - - -

1a.3 Subtotal Period 1a Collateral Costs - - - - - - 5,871 881 6,751 1,664 5,088 - - - - - - - - -

Period 1a Period-Dependent Costs 1a.4.1 Insurance - - - - - - 170 17 187 187 - - - - - - - - - -

1a.4.2 Property taxes - - - - - - 1,115 111 1,226 1,226 - - - - - - - - - -

1a.4.3 Health physics supplies - 61 - - - - - 15 76 76 - - - - - - - - - -

1a.4.4 Heavy equipment rental - 45 - - - - - 7 52 52 - - - - - - - - - -

1a.4.5 Disposal of DAW generated - - 2 1 - 4 - 1 7 7 - - - 76 - - - 1,527 2 -

1a.4.6 Plant energy budget - - - - - - 197 30 227 227 - - - - - - - - - -

1a.4.7 NRC Fees - - - - - - 94 9 103 103 - - - - - - - - - -

1a.4.8 Emergency Planning Fees - - - - - - 444 44 488 - 488 - - - - - - - - -

1a.4.9 Finance & Interest - - - - - - 11 2 12 12 - - - - - - - - - -

1a.4.10 Spent Fuel Pool O&M - - - - - - 67 10 77 - 77 - - - - - - - - -

1a.4.11 ISFSI Operating Costs - - - - - - 9 1 10 - 10 - - - - - - - - -

1a.4.12 Security Staff Cost - - - - - - 1,173 176 1,349 1,349 - - - - - - - - - 23,079 1a.4.13 Utility Staff Cost - - - - - - 6,268 940 7,208 7,208 - - - - - - - - - 80,009 1a.4 Subtotal Period 1a Period-Dependent Costs - 106 2 1 - 4 9,546 1,364 11,022 10,447 575 - - 76 - - - 1,527 2 103,088 1a.0 TOTAL PERIOD 1a COST - 106 2 1 - 4 7,575 1,068 8,755 2,336 6,419 - - 76 - - - 1,527 2 103,088 PERIOD 1b - SAFSTOR Limited DECON Activities Period 1b Additional Costs 1b.2.1 Advanced Site Work (DOC) - - - - - - 17,391 2,609 20,000 20,000 - - - - - - - - - -

1b.2.2 PNPS Spent Fuel Island Modificaitons - - - - - - 2,344 352 2,696 2,696 - - - - - - - - - -

1b.2.3 PNPS System Abandonment Modifications - - - - - - 234 35 270 270 - - - - - - - - - -

1b.2.4 PNPS Instrument Air Modifications - - - - - - 234 35 270 270 - - - - - - - - - -

1b.2.5 PNPS Control Room HVAC Modifications - - - - - - 195 29 225 225 - - - - - - - - - -

1b.2.6 PNPS Security Modifications - - - - - - 1,953 293 2,247 2,247 - - - - - - - - - -

1b.2.7 PNPS IT Modifications - - - - - - 391 59 449 449 - - - - - - - - - -

1b.2.10 PNPS Radwaste System Modifications - - - - - - 391 59 449 449 - - - - - - - - - -

1b.2.12 Corporate A&G - - - - - - 11,558 1,734 13,291 6,008 7,284 - - - - - - - - -

1b.2.15 ETR Oversight - - - - - - 3,600 540 4,140 4,140 - - - - - - - - - -

1b.2 Subtotal Period 1b Additional Costs - - - - - - 38,292 5,744 44,036 36,752 7,284 - - - - - - - - -

Period 1b Collateral Costs 1b.3.2 Process decommissioning liquid waste 76 - 48 147 - 159 - 105 535 535 - - - 466 - - - 27,963 91 -

1b.3.4 Dry Fuel Storage (DFS) Project - - - - - - 24,775 3,716 28,491 - 28,491 - - - - - - - - -

1b.3.5 Legal - - - - - - 938 141 1,078 1,078 - - - - - - - - - -

1b.3.7 Site O&M - - - - - - 5,603 840 6,444 6,444 - - - - - - - - - -

1b.3 Subtotal Period 1b Collateral Costs 76 - 48 147 - 159 31,316 4,802 36,548 8,057 28,491 - - 466 - - - 27,963 91 -

Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 33 - - - - - - 8 41 41 - - - - - - - - - -

1b.4.2 Insurance - - - - - - 950 95 1,045 1,045 - - - - - - - - - -

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 3 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 1b Period-Dependent Costs (continued) 1b.4.3 Property taxes - - - - - - 6,243 624 6,868 6,868 - - - - - - - - - -

1b.4.4 Health physics supplies - 227 - - - - - 57 284 284 - - - - - - - - - -

1b.4.5 Heavy equipment rental - 251 - - - - - 38 289 289 - - - - - - - - - -

1b.4.6 Disposal of DAW generated - - 6 2 - 13 - 4 25 25 - - - 262 - - - 5,234 9 -

1b.4.7 Plant energy budget - - - - - - 1,111 167 1,278 1,278 - - - - - - - - - -

1b.4.8 NRC Fees - - - - - - 303 30 333 333 - - - - - - - - - -

1b.4.9 Emergency Planning Fees - - - - - - 2,486 249 2,735 - 2,735 - - - - - - - - -

1b.4.10 Finance & Interest - - - - - - 1,059 159 1,218 1,218 - - - - - - - - - -

1b.4.11 Spent Fuel Pool O&M - - - - - - 373 56 429 - 429 - - - - - - - - -

1b.4.12 ISFSI Operating Costs - - - - - - 49 7 56 - 56 - - - - - - - - -

1b.4.13 Security Staff Cost - - - - - - 6,570 985 7,555 7,555 - - - - - - - - - 129,245 1b.4.14 Utility Staff Cost - - - - - - 13,417 2,013 15,430 15,430 - - - - - - - - - 161,796 1b.4 Subtotal Period 1b Period-Dependent Costs 33 478 6 2 - 13 32,561 4,492 37,585 34,365 3,220 - - 262 - - - 5,234 9 291,040 1b.0 TOTAL PERIOD 1b COST 109 478 54 149 - 172 102,169 15,038 118,169 79,175 38,994 - - 728 - - - 33,197 99 291,040 PERIOD 1c - Preparations for SAFSTOR Dormancy Period 1c Direct Decommissioning Activities 1c.1.1 Prepare support equipment for storage - 256 - - - - - 38 294 294 - - - - - - - - 3,000 -

1c.1.2 Install containment pressure equal. lines - 60 - - - - - 9 69 69 - - - - - - - - 700 -

1c.1.3 Interim survey prior to dormancy - - - - - - 733 220 953 953 - - - - - - - - 10,252 -

1c.1 Subtotal Period 1c Activity Costs - 316 - - - - 733 267 1,316 1,316 - - - - - - - - 13,952 -

Period 1c Additional Costs 1c.2.2 PNPS Spent Fuel Island Modificaitons - - - - - - 975 146 1,121 1,121 - - - - - - - - - -

1c.2.3 PNPS System Abandonment Modifications - - - - - - 97 15 112 112 - - - - - - - - - -

1c.2.4 PNPS Instrument Air Modifications - - - - - - 97 15 112 112 - - - - - - - - - -

1c.2.5 PNPS Control Room HVAC Modifications - - - - - - 81 12 93 93 - - - - - - - - - -

1c.2.6 PNPS Security Modifications - - - - - - 812 122 934 934 - - - - - - - - - -

1c.2.7 PNPS IT Modifications - - - - - - 162 24 187 187 - - - - - - - - - -

1c.2.10 PNPS Radwaste System Modifications - - - - - - 162 24 187 187 - - - - - - - - - -

1c.2.12 Corporate A&G - - - - - - 6,002 900 6,902 3,120 3,782 - - - - - - - - -

1c.2.16 NDO Contingency - - - - - - 428 64 492 492 - - - - - - - - - -

1c.2.23 Water Processing - - - - - - 615 92 707 707 - - - - - - - - - -

1c.2 Subtotal Period 1c Additional Costs - - - - - - 9,433 1,415 10,848 7,065 3,782 - - - - - - - - -

Period 1c Collateral Costs 1c.3.1 Process decommissioning liquid waste 130 - 82 252 - 272 - 179 915 915 - - - 797 - - - 47,837 155 -

1c.3.3 Small tool allowance - 6 - - - - - 1 6 6 - - - - - - - - - -

1c.3.4 Dry Fuel Storage (DFS) Project - - - - - - 13,776 2,066 15,842 - 15,842 - - - - - - - - -

1c.3.5 Legal - - - - - - 685 103 788 788 - - - - - - - - - -

1c.3.7 Site O&M - - - - - - 2,436 365 2,801 2,801 - - - - - - - - - -

1c.3 Subtotal Period 1c Collateral Costs 130 6 82 252 - 272 16,896 2,714 20,353 4,510 15,842 - - 797 - - - 47,837 155 -

Period 1c Period-Dependent Costs 1c.4.1 Insurance - - - - - - 605 61 666 666 - - - - - - - - - -

1c.4.2 Property taxes - - - - - - 2,348 235 2,583 2,583 - - - - - - - - - -

1c.4.3 Health physics supplies - 212 - - - - - 53 266 266 - - - - - - - - - -

1c.4.4 Heavy equipment rental - 160 - - - - - 24 184 184 - - - - - - - - - -

1c.4.5 Disposal of DAW generated - - 4 1 - 8 - 3 16 16 - - - 167 - - - 3,333 5 -

1c.4.6 Plant energy budget - - - - - - 720 108 828 828 - - - - - - - - - -

1c.4.7 NRC Fees - - - - - - 193 19 212 212 - - - - - - - - - -

1c.4.8 Emergency Planning Fees - - - - - - 1,031 103 1,134 - 1,134 - - - - - - - - -

1c.4.9 Finance & Interest - - - - - - 48 7 55 55 - - - - - - - - - -

1c.4.10 Spent Fuel Pool O&M - - - - - - 237 36 273 - 273 - - - - - - - - -

1c.4.11 ISFSI Operating Costs - - - - - - 31 5 36 - 36 - - - - - - - - -

1c.4.13 Security Staff Cost - - - - - - 2,736 410 3,147 3,147 - - - - - - - - - 54,878 1c.4.14 Utility Staff Cost - - - - - - 8,546 1,282 9,827 9,827 - - - - - - - - - 103,048 1c.4 Subtotal Period 1c Period-Dependent Costs - 372 4 1 - 8 16,495 2,345 19,226 17,784 1,442 - - 167 - - - 3,333 5 157,926 1c.0 TOTAL PERIOD 1c COST 130 694 86 253 - 281 43,557 6,742 51,742 30,676 21,067 - - 964 - - - 51,170 14,113 157,926 PERIOD 1 TOTALS 239 1,278 141 403 - 457 153,301 22,848 178,667 112,186 66,480 - - 1,768 - - - 85,894 14,214 552,055 PERIOD 2a - SAFSTOR Dormancy with Wet Spent Fuel Storage Period 2a Additional Costs 2a.2.2 PNPS Spent Fuel Island Modificaitons - - - - - - 2,262 339 2,602 2,602 - - - - - - - - - -

2a.2.3 PNPS System Abandonment Modifications - - - - - - 226 34 260 260 - - - - - - - - - -

2a.2.4 PNPS Instrument Air Modifications - - - - - - 226 34 260 260 - - - - - - - - - -

2a.2.5 PNPS Control Room HVAC Modifications - - - - - - 189 28 217 217 - - - - - - - - - -

2a.2.6 PNPS Security Modifications - - - - - - 1,885 283 2,168 2,168 - - - - - - - - - -

2a.2.7 PNPS IT Modifications - - - - - - 377 57 434 434 - - - - - - - - - -

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 4 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 2a Additional Costs (continued) 2a.2.10 PNPS Radwaste System Modifications - - - - - - 377 57 434 434 - - - - - - - - - -

2a.2.11 Fuel Pool Clean up - - - - - - 5,000 750 5,750 5,750 - - - - - - - - - -

2a.2.12 Corporate A&G - - - - - - 43,654 6,548 50,203 22,692 27,511 - - - - - - - - -

2a.2.16 NDO Contingency - - - - - - 13,680 1,607 15,287 15,287 - - - - - - - - - -

2a.2.23 Water Processing - - - - - - 4,385 658 5,043 5,043 - - - - - - - - - -

2a.2.24 UST Fuel Oil Tank Remediations - 35 - - - - 29 10 74 74 - - - - - - - - 81 400 2a.2.25 Asbestos Remedation - 1,596 2 261 - 680 - 608 3,147 3,147 - - - 13,623 - - - 177,093 14,317 -

2a.2 Subtotal Period 2a Additional Costs - 1,631 2 261 - 680 72,291 11,013 85,878 58,367 27,511 - - 13,623 - - - 177,093 14,398 400 Period 2a Collateral Costs 2a.3.1 Small tool allowance - 23 - - - - - 3 26 26 - - - - - - - - - -

2a.3.2 Dry Fuel Storage (DFS) Project - - - - - - 77,427 11,614 89,041 - 89,041 - - - - - - - - -

2a.3.3 Legal - - - - - - 4,310 646 4,956 4,956 - - - - - - - - - -

2a.3.5 Site O&M - - - - - - 11,608 1,741 13,349 13,349 - - - - - - - - - -

2a.3 Subtotal Period 2a Collateral Costs - 23 - - - - 93,345 14,005 107,372 18,331 89,041 - - - - - - - - -

Period 2a Period-Dependent Costs 2a.4.1 Insurance - - - - - - 2,164 216 2,380 2,380 - - - - - - - - - -

2a.4.2 Property taxes - - - - - - 5,264 526 5,790 5,790 - - - - - - - - - -

2a.4.3 Health physics supplies - 646 - - - - - 162 808 808 - - - - - - - - - -

2a.4.4 Disposal of DAW generated - - 14 6 - 32 - 10 61 61 - - - 636 - - - 12,716 21 -

2a.4.5 Plant energy budget - - - - - - 2,774 416 3,190 3,190 - - - - - - - - - -

2a.4.6 NRC Fees - - - - - - 723 72 796 796 - - - - - - - - - -

2a.4.7 Emergency Planning Fees - - - - - - 3,413 341 3,754 - 3,754 - - - - - - - - -

2a.4.8 Finance & Interest - - - - - - 479 72 551 551 - - - - - - - - - -

2a.4.9 Spent Fuel Pool O&M - - - - - - 2,231 335 2,566 - 2,566 - - - - - - - - -

2a.4.10 ISFSI Operating Costs - - - - - - 292 44 336 - 336 - - - - - - - - -

2a.4.12 Security Staff Cost - - - - - - 25,728 3,859 29,587 21,243 8,344 - - - - - - - - 515,954 2a.4.13 Utility Staff Cost - - - - - - 15,295 2,294 17,590 14,371 3,219 - - - - - - - - 229,313 2a.4 Subtotal Period 2a Period-Dependent Costs - 646 14 6 - 32 58,362 8,348 67,408 49,190 18,218 - - 636 - - - 12,716 21 745,267 2a.0 TOTAL PERIOD 2a COST - 2,300 16 266 - 712 223,998 33,366 260,658 125,888 134,770 - - 14,258 - - - 189,808 14,419 745,667 PERIOD 2b - SAFSTOR Dormancy with Dry Spent Fuel Storage Period 2b Additional Costs 2b.2.1 NDO Contingency - - - - - - 32,670 3,267 35,937 35,937 - - - - - - - - - -

2b.2 Subtotal Period 2b Additional Costs - - - - - - 32,670 3,267 35,937 35,937 - - - - - - - - - -

Period 2b Collateral Costs 2b.3.1 Spent Fuel Transfer (ISFSI to DOE) - - - - - - 9,150 1,373 10,523 - 10,523 - - - - - - - - -

2b.3.3 Site O&M - - - - - - 25,917 3,888 29,805 29,805 - - - - - - - - - -

2b.3 Subtotal Period 2b Collateral Costs - - - - - - 35,067 5,260 40,327 29,805 10,523 - - - - - - - - -

Period 2b Period-Dependent Costs 2b.4.1 Insurance - - - - - - 31,423 3,142 34,565 34,565 - - - - - - - - - -

2b.4.3 Health physics supplies - 4,090 - - - - - 1,022 5,112 5,112 - - - - - - - - - -

2b.4.4 Disposal of DAW generated - - 97 39 - 225 - 72 432 432 - - - 4,472 - - - 89,442 146 -

2b.4.5 Plant energy budget - - - - - - 18,241 2,736 20,977 20,977 - - - - - - - - - -

2b.4.6 NRC Fees - - - - - - 9,977 998 10,975 10,975 - - - - - - - - - -

2b.4.7 Finance & Interest - - - - - - 1,780 267 2,047 2,047 - - - - - - - - - -

2b.4.8 ISFSI Operating Costs - - - - - - 4,242 636 4,878 - 4,878 - - - - - - - - -

2b.4.9 Corporate A&G - - - - - - 20,117 3,018 23,135 14,562 8,572 - - - - - - - - -

2b.4.10 Security Staff Cost - - - - - - 107,015 16,052 123,067 2,092 120,975 - - - - - - - - 2,580,967 2b.4.11 Utility Staff Cost - - - - - - 117,955 17,693 135,649 88,986 46,663 - - - - - - - - 1,415,369 2b.4 Subtotal Period 2b Period-Dependent Costs - 4,090 97 39 - 225 310,749 45,636 360,835 179,747 181,088 - - 4,472 - - - 89,442 146 3,996,336 2b.0 TOTAL PERIOD 2b COST - 4,090 97 39 - 225 378,486 54,163 437,100 245,489 191,611 - - 4,472 - - - 89,442 146 3,996,336 PERIOD 2c - SAFSTOR Dormancy without Spent Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.4 Bituminous roof replacement - - - - - - 477 72 549 549 - - - - - - - - - -

2c.1.5 Maintenance supplies - - - - - - 1,392 348 1,740 1,740 - - - - - - - - - -

2c.1 Subtotal Period 2c Activity Costs - - - - - - 1,870 420 2,289 2,289 - - - - - - - - - -

Period 2c Collateral Costs 2c.3.1 NDO Contingency - - - - - - 7,823 782 8,605 8,605 - - - - - - - - - -

2c.3.2 Site O&M - - - - - - 3,202 480 3,682 3,682 - - - - - - - - - -

2c.3 Subtotal Period 2c Collateral Costs - - - - - - 11,024 1,263 12,287 12,287 - - - - - - - - - -

Period 2c Period-Dependent Costs 2c.4.1 Insurance - - - - - - 8,091 809 8,900 8,900 - - - - - - - - - -

2c.4.3 Health physics supplies - 980 - - - - - 245 1,225 1,225 - - - - - - - - - -

2c.4.4 Disposal of DAW generated - - 22 9 - 52 - 17 100 100 - - - 1,041 - - - 20,810 34 -

2c.4.5 Plant energy budget - - - - - - 1,961 294 2,256 2,256 - - - - - - - - - -

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 5 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 2c Period-Dependent Costs (continued) 2c.4.6 NRC Fees - - - - - - 2,372 237 2,610 2,610 - - - - - - - - - -

2c.4.7 Finance & Interest - - - - - 313 47 360 360 - - - - - - - - - -

2c.4.8 Corporate A&G - - - - - - 1,742 261 2,004 2,004 - - - - - - - - - -

2c.4.9 Security Staff Cost - - - - - - 2,117 318 2,435 2,435 - - - - - - - - - 108,559 2c.4.10 Utility Staff Cost - - - - - - 12,666 1,900 14,566 14,566 - - - - - - - - - 151,983 2c.4 Subtotal Period 2c Period-Dependent Costs - 980 22 9 - 52 29,263 4,128 34,455 34,455 - - - 1,041 - - - 20,810 34 260,541 2c.0 TOTAL PERIOD 2c COST - 980 22 9 - 52 42,157 5,810 49,031 49,031 - - - 1,041 - - - 20,810 34 260,541 PERIOD 2 TOTALS - 7,369 135 314 - 988 644,642 93,339 746,789 420,408 326,381 - - 19,771 - - - 300,061 14,599 5,002,544 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 3a.1.1 Prepare preliminary decommissioning cost - - - - - - 163 24 187 187 - - - - - - - - - 1,300 3a.1.2 Review plant dwgs & specs. - - - - - - 576 86 662 662 - - - - - - - - - 4,600 3a.1.3 Perform detailed rad survey - - - - - - - - a - - - - - - - - - - -

3a.1.4 End product description - - - - - - 125 19 144 144 - - - - - - - - - 1,000 3a.1.5 Detailed by-product inventory - - - - - - 163 24 187 187 - - - - - - - - - 1,300 3a.1.6 Define major work sequence - - - - - - 939 141 1,080 1,080 - - - - - - - - - 7,500 3a.1.7 Perform SER and EA - - - - - - 388 58 446 446 - - - - - - - - - 3,100 3a.1.8 Perform Site-Specific Cost Study - - - - - - 626 94 720 720 - - - - - - - - - 5,000 Activity Specifications 3a.1.9.1 Re-activate plant & temporary facilities - - - - - - 922 138 1,061 955 - 106 - - - - - - - 7,370 3a.1.9.2 Plant systems - - - - - - 522 78 600 540 - 60 - - - - - - - 4,167 3a.1.9.3 Reactor internals - - - - - - 889 133 1,022 1,022 - - - - - - - - - 7,100 3a.1.9.4 Reactor vessel - - - - - - 814 122 936 936 - - - - - - - - - 6,500 3a.1.9.5 Sacrificial shield - - - - - - 63 9 72 72 - - - - - - - - - 500 3a.1.9.6 Moisture separators/reheaters - - - - - - 125 19 144 144 - - - - - - - - - 1,000 3a.1.9.7 Reinforced concrete - - - - - - 200 30 230 115 - 115 - - - - - - - 1,600 3a.1.9.8 Main Turbine - - - - - - 261 39 301 301 - - - - - - - - - 2,088 3a.1.9.9 Main Condensers - - - - - - 261 39 301 301 - - - - - - - - - 2,088 3a.1.9.10 Pressure suppression structure - - - - - - 250 38 288 288 - - - - - - - - - 2,000 3a.1.9.11 Drywell - - - - - - 200 30 230 230 - - - - - - - - - 1,600 3a.1.9.12 Plant structures & buildings - - - - - - 390 59 449 225 - 225 - - - - - - - 3,120 3a.1.9.13 Waste management - - - - - - 576 86 662 662 - - - - - - - - - 4,600 3a.1.9.14 Facility & site closeout - - - - - - 113 17 130 65 - 65 - - - - - - - 900 3a.1.9 Total - - - - - - 5,586 838 6,424 5,854 - 571 - - - - - - - 44,633 Planning & Site Preparations 3a.1.10 Prepare dismantling sequence - - - - - - 300 45 345 345 - - - - - - - - - 2,400 3a.1.11 Plant prep. & temp. svces - - - - - - 3,300 495 3,795 3,795 - - - - - - - - - -

3a.1.12 Design water clean-up system - - - - - - 175 26 202 202 - - - - - - - - - 1,400 3a.1.13 Rigging/Cont. Cntrl Envlps/tooling/etc. - - - - - - 2,300 345 2,645 2,645 - - - - - - - - - -

3a.1.14 Procure casks/liners & containers - - - - - - 154 23 177 177 - - - - - - - - - 1,230 3a.1 Subtotal Period 3a Activity Costs - - - - - - 14,795 2,219 17,014 16,443 - 571 - - - - - - - 73,463 Period 3a Collateral Costs 3a.3.1 NDO Contingency - - - - - - 750 75 825 825 - - - - - - - - - -

3a.3.2 Site O&M - - - - - - 1,861 279 2,140 2,140 - - - - - - - - - -

3a.3 Subtotal Period 3a Collateral Costs - - - - - - 2,611 354 2,965 2,965 - - - - - - - - - -

Period 3a Period-Dependent Costs 3a.4.1 Insurance - - - - - - 775 78 853 853 - - - - - - - - - -

3a.4.3 Health physics supplies - 455 - - - - - 114 569 569 - - - - - - - - - -

3a.4.4 Heavy equipment rental - 546 - - - - - 82 628 628 - - - - - - - - - -

3a.4.5 Disposal of DAW generated - - 11 4 - 26 - 8 50 50 - - - 514 - - - 10,287 17 -

3a.4.6 Plant energy budget - - - - - - 1,879 282 2,161 2,161 - - - - - - - - - -

3a.4.7 NRC Fees - - - - - - 350 35 385 385 - - - - - - - - - -

3a.4.8 Finance & Interest - - - - - - 161 24 185 185 - - - - - - - - - -

3a.4.9 Corporate A&G - - - - - - 167 25 192 192 - - - - - - - - - -

3a.4.10 Security Staff Cost - - - - - - 1,268 190 1,458 1,458 - - - - - - - - - 65,000 3a.4.11 Utility Staff Cost - - - - - - 18,098 2,715 20,813 20,813 - - - - - - - - - 257,920 3a.4 Subtotal Period 3a Period-Dependent Costs - 1,001 11 4 - 26 22,698 3,552 27,293 27,293 - - - 514 - - - 10,287 17 322,920 3a.0 TOTAL PERIOD 3a COST - 1,001 11 4 - 26 40,103 6,126 47,271 46,701 - 571 - 514 - - - 10,287 17 396,383 PERIOD 3b - Decommissioning Preparations Period 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems - - - - - - 592 89 681 613 - 68 - - - - - - - 4,733 3b.1.1.2 Reactor internals - - - - - - 501 75 576 576 - - - - - - - - - 4,000 3b.1.1.3 Remaining buildings - - - - - - 169 25 194 49 - 146 - - - - - - - 1,350 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 6 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Detailed Work Procedures (continued) 3b.1.1.4 CRD housings & NIs - - - - - - 125 19 144 144 - - - - - - - - - 1,000 3b.1.1.5 Incore instrumentation - - - - - - 125 19 144 144 - - - - - - - - - 1,000 3b.1.1.6 Removal primary containment - - - - - - 250 38 288 288 - - - - - - - - - 2,000 3b.1.1.7 Reactor vessel - - - - - - 454 68 522 522 - - - - - - - - - 3,630 3b.1.1.8 Facility closeout - - - - - - 150 23 173 86 - 86 - - - - - - - 1,200 3b.1.1.9 Sacrificial shield - - - - - - 150 23 173 173 - - - - - - - - - 1,200 3b.1.1.10 Reinforced concrete - - - - - - 125 19 144 72 - 72 - - - - - - - 1,000 3b.1.1.11 Main Turbine - - - - - - 260 39 299 299 - - - - - - - - - 2,080 3b.1.1.12 Main Condensers - - - - - - 261 39 301 301 - - - - - - - - - 2,088 3b.1.1.13 Moisture separators & reheaters - - - - - - 250 38 288 288 - - - - - - - - - 2,000 3b.1.1.14 Radwaste building - - - - - - 342 51 393 354 - 39 - - - - - - - 2,730 3b.1.1.15 Reactor building - - - - - - 342 51 393 354 - 39 - - - - - - - 2,730 3b.1.1 Total - - - - - - 4,098 615 4,713 4,262 - 451 - - - - - - - 32,741 3b.1 Subtotal Period 3b Activity Costs - - - - - - 4,098 615 4,713 4,262 - 451 - - - - - - - 32,741 Period 3b Additional Costs 3b.2.1 Site Characterization - - - - - - 3,640 1,092 4,732 4,732 - - - - - - - - 20,060 8,092 3b.2.2 Asbestos Remedation - 1,596 2 261 - 680 - 608 3,147 3,147 - - - 13,623 - - - 177,093 14,317 -

3b.2.3 NDO Contingency - - - - - - 2,274 38 2,311 2,311 - - - - - - - - - -

3b.2 Subtotal Period 3b Additional Costs - 1,596 2 261 - 680 5,914 1,738 10,191 10,191 - - - 13,623 - - - 177,093 34,377 8,092 Period 3b Collateral Costs 3b.3.1 Decon equipment 999 - - - - - - 150 1,148 1,148 - - - - - - - - - -

3b.3.2 DOC staff relocation expenses - - - - - - 1,456 218 1,675 1,675 - - - - - - - - - -

3b.3.3 Small tool allowance - 23 - - - - - 3 26 26 - - - - - - - - - -

3b.3.4 Pipe cutting equipment - 1,200 - - - - - 180 1,380 1,380 - - - - - - - - - -

3b.3.6 Site O&M - - - - - - 938 141 1,079 1,079 - - - - - - - - - -

3b.3 Subtotal Period 3b Collateral Costs 999 1,223 - - - - 2,395 692 5,308 5,308 - - - - - - - - - -

Period 3b Period-Dependent Costs 3b.4.1 Decon supplies 36 - - - - - - 9 45 45 - - - - - - - - - -

3b.4.2 Insurance - - - - - - 396 40 435 435 - - - - - - - - - -

3b.4.4 Health physics supplies - 322 - - - - - 80 402 402 - - - - - - - - - -

3b.4.5 Heavy equipment rental - 275 - - - - - 41 316 316 - - - - - - - - - -

3b.4.6 Disposal of DAW generated - - 6 3 - 15 - 5 28 28 - - - 293 - - - 5,866 10 -

3b.4.7 Plant energy budget - - - - - - 947 142 1,089 1,089 - - - - - - - - - -

3b.4.8 NRC Fees - - - - - - 176 18 194 194 - - - - - - - - - -

3b.4.9 Finance & Interest - - - - - - 104 16 120 120 - - - - - - - - - -

3b.4.10 Corporate A&G - - - - - - 84 13 97 97 - - - - - - - - - -

3b.4.11 Security Staff Cost - - - - - - 639 96 735 735 - - - - - - - - - 32,767 3b.4.12 DOC Staff Cost - - - - - - 1,537 230 1,767 1,767 - - - - - - - - - 58,719 3b.4.13 Utility Staff Cost - - - - - - 9,123 1,369 10,492 10,492 - - - - - - - - - 130,020 3b.4 Subtotal Period 3b Period-Dependent Costs 36 597 6 3 - 15 13,007 2,058 15,721 15,721 - - - 293 - - - 5,866 10 221,506 3b.0 TOTAL PERIOD 3b COST 1,034 3,416 9 263 - 694 25,413 5,103 35,933 35,482 - 451 - 13,916 - - - 182,958 34,386 262,339 PERIOD 3 TOTALS 1,034 4,417 20 268 - 720 65,516 11,229 83,204 82,183 - 1,021 - 14,430 - - - 193,246 34,403 658,722 PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.1.1 Recirculation System Piping & Valves 27 99 29 43 114 155 - 103 571 571 - - 682 722 - - - 95,829 1,637 -

4a.1.1.2 Recirculation Pumps & Motors 14 64 17 52 167 170 - 100 584 584 - - 1,075 894 - - - 122,005 1,104 -

4a.1.1.3 CRDMs & NIs Removal 54 1,083 471 200 - 783 - 571 3,161 3,161 - - - 4,306 - - - 254,900 15,023 -

4a.1.1.4 Reactor Vessel Internals 143 5,969 5,605 1,735 - 38,599 289 25,726 78,066 78,066 - - - 2,002 1,753 742 - 366,551 23,365 1,093 4a.1.1.5 Vessel & Internals GTCC Disposal - - - - - 4,033 - 605 4,638 4,638 - - - - - - 817 169,336 - -

4a.1.1.6 Reactor Vessel - 8,247 2,042 1,736 - 5,434 289 9,890 27,639 27,639 - - - 22,970 - - - 1,442,217 23,365 1,093 4a.1.1 Totals 238 15,461 8,165 3,765 281 49,174 579 36,995 114,658 114,658 - - 1,757 30,894 1,753 742 817 2,450,838 64,494 2,186 Removal of Major Equipment - - - - - - - - - - - - - - - - - - - -

4a.1.2 Main Turbine/Generator - 403 1,732 706 9,057 - - 1,738 13,636 13,636 - - 80,183 - - - - 3,608,249 5,035 -

4a.1.3 Main Condensers - 1,171 672 274 3,514 - - 928 6,560 6,560 - - 31,111 - - - - 1,400,000 14,554 -

Cascading Costs from Clean Building Demolition 4a.1.4.1 Reactor - 308 - - - - - 46 354 354 - - - - - - - - 2,015 -

4a.1.4.2 AOG Rentention - 14 - - - - - 2 16 16 - - - - - - - - 70 -

4a.1.4.3 Main Stack & Filter - 3 - - - - - 0 3 3 - - - - - - - - 13 -

4a.1.4.4 Turbine - 147 - - - - - 22 169 169 - - - - - - - - 1,278 -

4a.1.4 Totals - 472 - - - - - 71 542 542 - - - - - - - - 3,376 -

Disposal of Plant Systems - - - - - - - - - - - - - - - - - - - -

4a.1.5.1 Circulating Water - 125 - - - - - 19 144 - - 144 - - - - - - 1,585 -

4a.1.5.2 Circulating Water (RCA) - 102 7 32 411 - - 93 645 645 - - 4,035 - - - - 163,883 1,277 -

4a.1.5.3 Circulating Water - Intake - 87 - - - - - 13 100 - - 100 - - - - - - 1,143 -

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 7 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Disposal of Plant Systems (continued) 4a.1.5.4 Condensate - 425 11 48 619 - - 207 1,311 1,311 - - 6,077 - - - - 246,780 5,315 -

4a.1.5.5 Condensate (RCA) - 745 34 153 1,969 - - 508 3,410 3,410 - - 19,320 - - - - 784,590 9,150 -

4a.1.5.6 Condensate Demineralizer - 426 7 32 408 - - 173 1,046 1,046 - - 4,004 - - - - 162,594 5,256 -

4a.1.5.7 Demineralized Water and Storage - 33 - - - - - 5 38 - - 38 - - - - - - 409 -

4a.1.5.8 Demineralized Water and Storage (RCA) - 278 4 19 239 - - 109 648 648 - - 2,348 - - - - 95,351 3,418 -

4a.1.5.9 Extraction Steam - 279 8 35 453 - - 144 919 919 - - 4,447 - - - - 180,590 3,531 -

4a.1.5.10 Feedwater - 506 22 101 1,292 - - 337 2,257 2,257 - - 12,677 - - - - 514,817 6,377 -

4a.1.5.11 Feedwater Heaters - 408 27 127 1,632 - - 368 2,562 2,562 - - 16,006 - - - - 650,000 5,175 -

4a.1.5.12 Generator Gas Control - 29 0 1 12 - - 9 51 51 - - 122 - - - - 4,969 334 -

4a.1.5.13 Heater Drain - 348 6 28 363 - - 146 892 892 - - 3,564 - - - - 144,718 4,336 -

4a.1.5.14 Lube Oil Purification & Transfer - 286 5 25 325 - - 125 767 767 - - 3,193 - - - - 129,653 3,567 -

4a.1.5.15 Main Steam - 695 14 67 855 - - 313 1,944 1,944 - - 8,387 - - - - 340,604 8,682 -

4a.1.5.16 Main Steam Moisture Separators - 357 13 58 749 - - 212 1,389 1,389 - - 7,348 - - - - 298,400 4,555 -

4a.1.5.17 Mechanical Vacuum - 86 3 12 155 - - 47 303 303 - - 1,521 - - - - 61,779 1,072 -

4a.1.5.18 Neutron Monitoring - 19 0 1 6 3 - 7 36 36 - - 58 15 - - - 3,299 252 -

4a.1.5.19 Offgas & Augmanted Offgas (RCA) - 807 21 93 1,194 - - 397 2,511 2,511 - - 11,713 - - - - 475,661 9,835 -

4a.1.5.20 Offgas & Augmented Offgas - 570 19 91 1,168 - - 333 2,183 2,183 - - 11,460 - - - - 465,379 7,234 -

4a.1.5.21 Post Accident Sampling - 12 0 0 3 - - 3 19 19 - - 34 - - - - 1,366 147 -

4a.1.5.22 Reactor Core Isolation Cooling - 119 6 12 76 34 - 52 300 300 - - 748 174 - - - 41,550 1,505 -

4a.1.5.23 Salt Service Water - 47 - - - - - 7 54 - - 54 - - - - - - 619 -

4a.1.5.24 Seal Oil - 39 0 2 29 - - 14 84 84 - - 280 - - - - 11,370 467 -

4a.1.5.25 Stator Cooling - 71 1 3 35 - - 24 134 134 - - 348 - - - - 14,124 882 -

4a.1.5.26 Turbine Building Closed Cooling Water - 424 4 18 228 - - 143 817 817 - - 2,236 - - - - 90,795 5,245 -

4a.1.5 Totals - 7,323 212 959 12,224 37 - 3,809 24,564 24,228 - 337 119,924 188 - - - 4,882,270 91,369 -

4a.1.6 Scaffolding in support of decommissioning - 2,640 26 13 125 19 - 688 3,511 3,511 - - 1,106 98 - - - 55,974 22,666 -

4a.1 Subtotal Period 4a Activity Costs 238 27,470 10,808 5,717 25,201 49,230 579 44,230 163,472 163,136 - 337 234,082 31,179 1,753 742 817 12,397,331 201,495 2,186 Period 4a Additional Costs 4a.2.1 Remedial Action Surveys - - - - - - 1,495 448 1,943 1,943 - - - - - - - - 22,210 -

4a.2.2 NDO Contingency - - - - - - 4,193 106 4,299 4,299 - - - - - - - - - -

4a.2 Subtotal Period 4a Additional Costs - - - - - - 5,688 554 6,242 6,242 - - - - - - - - 22,210 -

Period 4a Collateral Costs 4a.3.1 Process decommissioning liquid waste 3 - 4 14 - 15 - 8 43 43 - - - 43 - - - 2,605 8 -

4a.3.3 Small tool allowance - 282 - - - - - 42 324 292 - 32 - - - - - - - -

4a.3.5 Site O&M - - - - - - 2,647 397 3,044 3,044 - - - - - - - - - -

4a.3.6 On-site survey and release of 437.7 tons clean metallic - - - - - - 455 46 501 501 - - - - - - - - - -

4a.3 Subtotal Period 4a Collateral Costs 3 282 4 14 - 15 3,102 492 3,912 3,880 - 32 - 43 - - - 2,605 8 -

Period 4a Period-Dependent Costs 4a.4.1 Decon supplies 100 - - - - - - 25 126 126 - - - - - - - - - -

4a.4.2 Insurance - - - - - - 1,110 111 1,221 1,221 - - - - - - - - - -

4a.4.4 Health physics supplies - 1,805 - - - - - 451 2,256 2,256 - - - - - - - - - -

4a.4.5 Heavy equipment rental - 3,010 - - - - - 452 3,462 3,462 - - - - - - - - - -

4a.4.6 Disposal of DAW generated - - 100 40 - 232 - 74 446 446 - - - 4,622 - - - 92,442 151 -

4a.4.7 Plant energy budget - - - - - - 2,524 379 2,902 2,902 - - - - - - - - - -

4a.4.8 NRC Fees - - - - - - 809 81 890 890 - - - - - - - - - -

4a.4.9 Finance & Interest - - - - - - 672 101 773 773 - - - - - - - - - -

4a.4.10 Liquid Radwaste Processing Equipment/Services - - - - - - 576 86 663 663 - - - - - - - - - -

4a.4.11 Corporate A&G - - - - - - 236 35 271 271 - - - - - - - - - -

4a.4.12 Security Staff Cost - - - - - - 1,792 269 2,061 2,061 - - - - - - - - - 91,890 4a.4.13 DOC Staff Cost - - - - - - 6,414 962 7,376 7,376 - - - - - - - - - 202,894 4a.4.14 Utility Staff Cost - - - - - - 25,817 3,873 29,689 29,689 - - - - - - - - - 367,562 4a.4 Subtotal Period 4a Period-Dependent Costs 100 4,815 100 40 - 232 39,950 6,898 52,136 52,136 - - - 4,622 - - - 92,442 151 662,346 4a.0 TOTAL PERIOD 4a COST 341 32,568 10,912 5,771 25,201 49,477 49,318 52,175 225,763 225,394 - 369 234,082 35,845 1,753 742 817 12,492,378 223,864 664,532 PERIOD 4b - Site Decontamination Period 4b Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks 1,156 114 194 437 - 2,575 - 1,335 5,812 5,812 - - - 13,202 - - - 838,681 1,563 -

Disposal of Plant Systems 4b.1.2.1 Containment Atmospheric Control - 222 7 31 400 - - 121 781 781 - - 3,928 - - - - 159,520 2,795 -

4b.1.2.2 Control Rod Drive Hydraulic - 957 62 83 284 356 - 390 2,132 2,132 - - 2,788 1,778 - - - 229,188 11,231 -

4b.1.2.3 Core Spray - 204 3 14 174 - - 79 473 473 - - 1,707 - - - - 69,328 2,555 -

4b.1.2.4 Diesel Fuel Oil Storage & Transfer - 49 - - - - - 7 56 - - 56 - - - - - - 608 -

4b.1.2.5 Diesel Fuel Oil Storage & Transfer RCA - 21 0 2 21 - - 9 53 53 - - 208 - - - - 8,428 259 -

4b.1.2.6 Diesel Generator & Auxiliaries - 10 - - - - - 1 11 - - 11 - - - - - - 121 -

4b.1.2.7 Electrical (RCA) - 5,201 44 207 2,658 - - 1,734 9,845 9,845 - - 26,081 - - - - 1,059,160 64,855 -

4b.1.2.8 Electrical Clean - 587 - - - - - 88 675 - - 675 - - - - - - 7,450 -

4b.1.2.9 Electrical Contaminated - 144 1 5 55 4 - 46 255 255 - - 536 20 - - - 23,050 1,755 -

4b.1.2.10 Fire Protection - 27 - - - - - 4 31 - - 31 - - - - - - 351 -

4b.1.2.11 Fire Protection (RCA) - 159 2 10 123 - - 60 354 354 - - 1,211 - - - - 49,177 1,897 -

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 8 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Disposal of Plant Systems (continued) 4b.1.2.12 Fuel Pool Cooling & Demineralizer - 1,065 20 38 192 138 - 337 1,791 1,791 - - 1,884 702 - - - 121,489 13,684 -

4b.1.2.13 HVAC Diesel Generator - 5 - - - - - 1 6 - - 6 - - - - - - 67 -

4b.1.2.14 HVAC Off Gas Retention - 1,069 60 116 604 406 - 483 2,738 2,738 - - 5,930 2,062 - - - 372,957 13,187 -

4b.1.2.15 HVAC Other - 2,029 76 353 4,532 - - 1,248 8,238 8,238 - - 44,461 - - - - 1,805,597 25,590 -

4b.1.2.16 HVAC Radwaste - 917 58 86 156 435 - 380 2,031 2,031 - - 1,528 2,207 - - - 203,737 11,321 -

4b.1.2.17 HVAC Reactor - 6,442 434 887 5,294 2,795 - 3,280 19,133 19,133 - - 51,939 14,202 - - - 3,019,678 79,813 -

4b.1.2.18 HVAC Turbine - 5,706 128 599 7,689 - - 2,682 16,805 16,805 - - 75,429 - - - - 3,063,197 70,705 -

4b.1.2.19 High Pressure Coolant Injection - 294 9 40 510 - - 157 1,008 1,008 - - 4,999 - - - - 203,010 3,708 -

4b.1.2.20 Instrument Air - 250 2 11 138 - - 85 486 486 - - 1,356 - - - - 55,057 2,869 -

4b.1.2.21 Nuclear Boiler - 220 31 78 620 174 - 206 1,331 1,331 - - 6,087 888 - - - 304,021 2,843 -

4b.1.2.22 Potable Water - 186 2 12 148 - - 71 419 419 - - 1,457 - - - - 59,155 2,258 -

4b.1.2.23 RX Recirc Motor Generator Auxiliaries - 166 4 18 233 - - 79 500 500 - - 2,284 - - - - 92,751 2,098 -

4b.1.2.24 Radwaste Collection - 6,454 178 321 983 1,441 - 2,187 11,564 11,564 - - 9,641 7,361 - - - 860,803 82,731 -

4b.1.2.25 Reactor Building Closed Cooling Water - 506 9 40 509 - - 210 1,273 1,273 - - 4,996 - - - - 202,908 6,250 -

4b.1.2.26 Reactor Water Cleanup - 232 19 35 140 142 - 122 689 689 - - 1,372 727 - - - 102,107 2,883 -

4b.1.2.27 Residual Heat Removal - 751 49 112 728 328 - 401 2,369 2,369 - - 7,142 1,677 - - - 396,889 9,579 -

4b.1.2.28 Roof Drains - 15 - - - - - 2 17 - - 17 - - - - - - 190 -

4b.1.2.29 Service Air - 412 4 19 242 - - 142 819 819 - - 2,371 - - - - 96,288 5,003 -

4b.1.2.30 Service Water - 73 - - - - - 11 84 - - 84 - - - - - - 938 -

4b.1.2.31 Service Water (RCA) - 897 22 97 1,242 - - 427 2,686 2,686 - - 12,187 - - - - 494,923 10,748 -

4b.1.2.32 Standby Gas Treatment - 164 3 15 189 - - 72 443 443 - - 1,854 - - - - 75,303 2,019 -

4b.1.2.33 Standby Liquid Control - 87 2 7 93 - - 37 225 225 - - 909 - - - - 36,919 1,087 -

4b.1.2.34 Underground Yard Piping - 1,201 80 184 1,103 574 - 645 3,787 3,787 - - 10,826 2,940 - - - 626,670 14,977 -

4b.1.2 Totals - 36,720 1,308 3,419 29,062 6,794 - 15,805 93,107 92,226 - 881 285,109 34,564 - - - 13,791,309 458,426 -

4b.1.3 Scaffolding in support of decommissioning - 3,960 39 19 187 29 - 1,032 5,267 5,267 - - 1,659 146 - - - 83,961 34,000 -

Decontamination of Site Buildings 4b.1.4.1 Reactor 6,074 3,786 165 534 5,227 499 - 4,989 21,276 21,276 - - 51,283 5,787 - - - 2,391,751 121,194 -

4b.1.4.2 AOG Rentention 69 45 1 8 25 7 - 53 209 209 - - 247 222 - - - 20,526 1,408 -

4b.1.4.3 Main Stack & Filter 20 16 0 4 6 3 - 16 66 66 - - 60 107 - - - 7,444 442 -

4b.1.4.4 Radwaste 290 335 30 206 32 268 - 334 1,495 1,495 - - 309 6,755 - - - 337,147 7,297 -

4b.1.4.5 Trash Compactor 5 31 2 20 - 18 - 18 93 93 - - - 655 - - - 30,930 392 -

4b.1.4.6 Turbine 679 280 12 89 214 80 - 476 1,830 1,830 - - 2,102 2,467 - - - 203,175 11,710 -

4b.1.4.7 Spent Fuel Pool Area 336 2,029 152 1,619 86 1,442 - 1,307 6,970 6,970 - - 840 53,351 - - - 2,554,876 26,271 -

4b.1.4 Totals 7,474 6,521 363 2,480 5,590 2,317 - 7,193 31,939 31,939 - - 54,841 69,345 - - - 5,545,849 168,711 -

4b.1.5 Prepare/submit License Termination Plan - - - - - - 513 77 590 590 - - - - - - - - - 4,096 4b.1.6 Receive NRC approval of termination plan - - - - - - - - a - - - - - - - - - - -

4b.1 Subtotal Period 4b Activity Costs 8,630 47,315 1,904 6,355 34,839 11,714 513 25,442 136,714 135,833 - 881 341,609 117,257 - - - 20,259,799 662,700 4,096 Period 4b Additional Costs 4b.2.1 License Termination Survey Planning - - - - - - 1,430 429 1,859 1,859 - - - - - - - - - 12,480 4b.2.2 Remedial Action Surveys - - - - - - 3,733 1,120 4,852 4,852 - - - - - - - - 55,468 -

4b.2.3 Operational Equipment - - - 243 703 - - 142 1,087 1,087 - - 15,250 - - - - 280,000 - -

4b.2.4 Soil Remediation - 63 6 751 - 700 - 304 1,823 1,823 - - - 14,031 - - - 1,234,690 359 -

4b.2.5 License Termination ISFSI - 263 186 1,568 - 2,664 2,855 1,884 9,421 9,421 - - - 45,639 - - - 2,431,946 11,719 -

4b.2.6 Underground Services Excavation - - 1 6 - 104 - 27 138 138 - - - 2,025 - - - 182,250 - -

4b.2.7 Water Processing - - - - - - 1,500 225 1,725 1,725 - - - - - - - - - -

4b.2.8 NDO Contingency - - - - - - 6,724 174 6,898 6,898 - - - - - - - - - -

4b.2 Subtotal Period 4b Additional Costs - 325 193 2,568 703 3,468 16,241 4,305 27,803 27,803 - - 15,250 61,694 - - - 4,128,886 67,547 12,480 Period 4b Collateral Costs 4b.3.1 Process decommissioning liquid waste 13 - 22 69 - 74 - 38 216 216 - - - 217 - - - 13,013 42 -

4b.3.3 Small tool allowance - 894 - - - - - 134 1,028 1,028 - - - - - - - - - -

4b.3.4 Decommissioning Equipment Disposition - - 142 79 678 103 - 153 1,155 1,155 - - 6,000 529 - - - 303,608 147 -

4b.3.6 Site O&M - - - - - - 4,170 626 4,796 4,796 - - - - - - - - - -

4b.3.7 On-site survey and release of 384.0 tons clean metallic - - - - - - 399 40 439 439 - - - - - - - - - -

4b.3 Subtotal Period 4b Collateral Costs 13 894 164 147 678 177 4,570 991 7,634 7,634 - - 6,000 746 - - - 316,621 189 -

Period 4b Period-Dependent Costs 4b.4.1 Decon supplies 1,420 - - - - - - 355 1,775 1,775 - - - - - - - - - -

4b.4.2 Insurance - - - - - - 1,826 183 2,009 2,009 - - - - - - - - - -

4b.4.4 Health physics supplies - 4,701 - - - - - 1,175 5,876 5,876 - - - - - - - - - -

4b.4.5 Heavy equipment rental - 5,105 - - - - - 766 5,871 5,871 - - - - - - - - - -

4b.4.6 Disposal of DAW generated - - 232 93 - 539 - 172 1,037 1,037 - - - 10,746 - - - 214,915 350 -

4b.4.7 Plant energy budget - - - - - - 3,278 492 3,770 3,770 - - - - - - - - - -

4b.4.8 NRC Fees - - - - - - 1,331 133 1,464 1,464 - - - - - - - - - -

4b.4.9 Finance & Interest - - - - - - 836 125 962 962 - - - - - - - - - -

4b.4.10 Liquid Radwaste Processing Equipment/Services - - - - - - 948 142 1,091 1,091 - - - - - - - - - -

4b.4.11 Corporate A&G - - - - - - 388 58 446 446 - - - - - - - - - -

4b.4.12 Security Staff Cost - - - - - - 2,948 442 3,391 3,391 - - - - - - - - - 151,192 4b.4.13 DOC Staff Cost - - - - - - 31,288 4,693 35,982 35,982 - - - - - - - - - 324,155 4b.4.14 Utility Staff Cost - - - - - - 40,278 6,042 46,320 46,320 - - - - - - - - - 570,900 4b.4 Subtotal Period 4b Period-Dependent Costs 1,420 9,806 232 93 - 539 83,122 14,779 109,992 109,992 - - - 10,746 - - - 214,915 350 1,046,247 TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 9 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours 4b.0 TOTAL PERIOD 4b COST 10,063 58,341 2,494 9,163 36,220 15,899 104,446 45,517 282,143 281,263 - 881 362,859 190,443 - - - 24,920,220 730,786 1,062,823 PERIOD 4f - License Termination Period 4f Direct Decommissioning Activities 4f.1.1 ORISE confirmatory survey - - - - - - 172 51 223 223 - - - - - - - - - -

4f.1.2 Terminate license - - - - - - - - a - - - - - - - - - - -

4f.1 Subtotal Period 4f Activity Costs - - - - - - 172 51 223 223 - - - - - - - - - -

Period 4f Additional Costs 4f.2.1 License Termination Survey - - - - - - 9,756 2,927 12,683 12,683 - - - - - - - - 119,880 6,240 4f.2.2 NDO Contingency - - - - - - 2,140 55 2,195 2,195 - - - - - - - - - -

4f.2 Subtotal Period 4f Additional Costs - - - - - - 11,896 2,982 14,879 14,879 - - - - - - - - 119,880 6,240 Period 4f Collateral Costs 4f.3.1 DOC staff relocation expenses - - - - - - 1,456 218 1,675 1,675 - - - - - - - - - -

4f.3.3 Site O&M - - - - - - 735 110 845 845 - - - - - - - - - -

4f.3 Subtotal Period 4f Collateral Costs - - - - - - 2,191 329 2,520 2,520 - - - - - - - - - -

Period 4f Period-Dependent Costs 4f.4.1 Insurance - - - - - - 581 58 639 639 - - - - - - - - - -

4f.4.3 Health physics supplies - 665 - - - - - 166 831 831 - - - - - - - - - -

4f.4.4 Disposal of DAW generated - - 7 3 - 17 - 6 33 33 - - - 345 - - - 6,897 11 -

4f.4.5 Plant energy budget - - - - - - 278 42 320 320 - - - - - - - - - -

4f.4.6 NRC Fees - - - - - - 424 42 466 466 - - - - - - - - - -

4f.4.7 Finance & Interest - - - - - - 183 28 211 211 - - - - - - - - - -

4f.4.8 Corporate A&G - - - - - - 55 8 63 63 - - - - - - - - - -

4f.4.9 Security Staff Cost - - - - - - 360 54 414 414 - - - - - - - - - 18,464 4f.4.10 DOC Staff Cost - - - - - - 5,836 875 6,712 6,712 - - - - - - - - - 56,160 4f.4.11 Utility Staff Cost - - - - - - 5,677 852 6,529 6,529 - - - - - - - - - 73,085 4f.4 Subtotal Period 4f Period-Dependent Costs - 665 7 3 - 17 13,395 2,131 16,218 16,218 - - - 345 - - - 6,897 11 147,709 4f.0 TOTAL PERIOD 4f COST - 665 7 3 - 17 27,654 5,493 33,840 33,840 - - - 345 - - - 6,897 119,891 153,949 PERIOD 4 TOTALS 10,404 91,574 13,413 14,937 61,421 65,393 181,418 103,185 541,746 540,496 - 1,250 596,942 226,633 1,753 742 817 37,419,495 1,074,541 1,881,304 PERIOD 5b - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b.1.1.1 Reactor - 1,883 - - - - - 282 2,165 - - 2,165 - - - - - - 13,235 -

5b.1.1.2 AOG Rentention - 132 - - - - - 20 152 - - 152 - - - - - - 733 -

5b.1.1.3 Contractor Office - Warehouse - 118 - - - - - 18 135 - - 135 - - - - - - 827 -

5b.1.1.4 Diesel Generator - 110 - - - - - 16 126 - - 126 - - - - - - 620 -

5b.1.1.5 Engineering & Plant Support - 295 - - - - - 44 339 - - 339 - - - - - - 2,077 -

5b.1.1.6 Fencing & Pavement - 1,438 - - - - - 216 1,654 - - 1,654 - - - - - - 13,386 -

5b.1.1.7 Intake Structure - 160 - - - - - 24 184 - - 184 - - - - - - 1,055 -

5b.1.1.8 Main Stack & Filter - 24 - - - - - 4 27 - - 27 - - - - - - 119 -

5b.1.1.9 Miscellaneous Site Structures - 6,540 - - - - - 981 7,521 - - 7,521 - - - - - - 67,378 -

5b.1.1.10 Protected Area ISFSI - 127 - - - - - 19 146 - - 146 - - - - - - 642 -

5b.1.1.11 Radwaste - 325 - - - - - 49 374 - - 374 - - - - - - 1,962 -

5b.1.1.12 SSW Pipe Vault - 4 - - - - - 1 4 - - 4 - - - - - - 18 -

5b.1.1.13 Transformer Pads - 22 - - - - - 3 25 - - 25 - - - - - - 110 -

5b.1.1.14 Trash Compactor - 140 - - - - - 21 161 - - 161 - - - - - - 936 -

5b.1.1.15 Turbine - 1,483 - - - - - 223 1,706 - - 1,706 - - - - - - 13,501 -

5b.1.1.16 Turbine Pedestal - 299 - - - - - 45 343 - - 343 - - - - - - 1,507 -

5b.1.1 Totals - 13,099 - - - - - 1,965 15,063 - - 15,063 - - - - - - 118,106 -

Site Closeout Activities 5b.1.2 Remove Rubble - 90 - - - - - 14 104 - - 104 - - - - - - 435 -

5b.1.3 Grade & landscape site - 67 - - - - - 10 77 - - 77 - - - - - - 185 -

5b.1.4 Final report to NRC - - - - - - 195 29 225 225 - - - - - - - - - 1,560 5b.1 Subtotal Period 5b Activity Costs - 13,256 - - - - 195 2,018 15,469 225 - 15,244 - - - - - - 118,726 1,560 Period 5b Additional Costs 5b.2.1 Concrete Crushing - 476 - - - - 11 73 560 - - 560 - - - - - - 2,128 -

5b.2.2 Site Restoration ISFSI - 2,123 - - - - 306 364 2,794 - - 2,794 - - - - - - 23,794 160 5b.2.3 Construction Debris - - - - - - 1,606 241 1,846 - - 1,846 - - - - - - - -

5b.2.4 Intake cofferdam - 177 - - - - - 26 203 - - 203 - - - - - - 1,227 -

5b.2.5 NDO Contingency - - - - - - 3,847 44 3,891 - - 3,891 - - - - - - - -

5b.2 Subtotal Period 5b Additional Costs - 2,775 - - - - 5,770 749 9,294 - - 9,294 - - - - - - 27,148 160 Period 5b Collateral Costs 5b.3.1 Small tool allowance - 203 - - - - - 31 234 - - 234 - - - - - - - -

5b.3.3 Site O&M - - - - - - 1,018 153 1,171 - - 1,171 - - - - - - - -

5b.3 Subtotal Period 5b Collateral Costs - 203 - - - - 1,018 183 1,405 - - 1,405 - - - - - - - -

TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site Specific Decommissioning Cost Estimate Appendix C, Page 10 of 10 Table C Pilgrim Nuclear Power Station SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. ManagementRestoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 5b Period-Dependent Costs 5b.4.1 Insurance - - - - - - - - - - - - - - - - - - - -

5b.4.3 Heavy equipment rental - 4,505 - - - - - 676 5,181 - - 5,181 - - - - - - - -

5b.4.4 Plant energy budget - - - - - - 283 42 326 - - 326 - - - - - - - -

5b.4.5 Finance & Interest - - - - - - 214 32 246 - - 246 - - - - - - - -

5b.4.6 Security Staff Cost - - - - - - 733 110 843 - - 843 - - - - - - - 37,611 5b.4.7 DOC Staff Cost - - - - - - 11,150 1,672 12,822 - - 12,822 - - - - - - - 106,564 5b.4.8 Utility Staff Cost - - - - - - 4,679 702 5,381 - - 5,381 - - - - - - - 61,118 5b.4 Subtotal Period 5b Period-Dependent Costs - 4,505 - - - - 17,059 3,235 24,799 - - 24,799 - - - - - - - 205,293 5b.0 TOTAL PERIOD 5b COST - 20,740 - - - - 24,042 6,185 50,967 225 - 50,743 - - - - - - 145,875 207,013 PERIOD 5 TOTALS - 20,740 - - - - 24,042 6,185 50,967 225 - 50,743 - - - - - - 145,875 207,013 TOTAL COST TO DECOMMISSION 11,678 125,378 13,709 15,923 61,421 67,558 1,125,233 240,358 1,661,258 1,187,994 420,250 53,014 596,942 262,602 1,753 742 817 37,998,696 1,283,632 8,301,638 TOTAL COST TO DECOMMISSION WITH 16.92 % CONTINGENCY: 1,661,258 thousands of 2018 dollars TOTAL NRC LICENSE TERMINATION COST IS 71.51 % OR: 1,187,994 thousands of 2018 dollars SPENT FUEL MANAGEMENT COST IS 25.3 % OR: 420,250 thousands of 2018 dollars NON-NUCLEAR DEMOLITION COST IS 3.19 % OR: 53,014 thousands of 2018 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC): 265,097 cubic feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED: 817 cubic feet TOTAL SCRAP METAL REMOVED: 23,958 tons TOTAL CRAFT LABOR REQUIREMENTS: 1,283,632 man-hours End Notes:

n/a - indicates that this activity not charged as decommissioning expense a - indicates that this activity performed by decommissioning staff 0 - indicates that this value is less than 0.5 but is non-zero TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix D, Page 1 of 2 APPENDIX D ISFSI DECOMMISSIONING TLG Services, Inc.

Pilgrim Nuclear Power Station Document E11-1724-001, Rev. 0 Site-Specific Decommissioning Cost Estimate Appendix D, Page 2 of 2 Table D Pilgrim Nuclear Power Station ISFSI Decommissioning Cost Estimate SAFSTOR Decommissioning Alternative (thousands of 2018 dollars)

Burial Oversight LLRW Removal Packaging Transport Other Total Volume and Disposal Craft Hours Costs Costs Costs Costs Costs Class A Contractor Costs (cubic feet) Hours Activity Description Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 262 262 - - 1,048 Decontamination (overpack disposition) 263 186 1,568 2,664 25 4,707 45,639 2,669 -

License Termination (radiological surveys) - - - - 1,186 1,186 - 9,050 -

Subtotal 263 186 1,568 2,664 1,473 6,155 45,639 11,719 1,048 Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 481 481 - - 1,153 Site O&M - - - - 222 222 - - -

Insurance - - - - 80 80 - - -

Property Taxes - - - - 96 96 - - -

Security Staff Cost - - - - 231 231 - - 4,958 Oversight Staff - - - - 271 271 - - 3,761 Subtotal - - - - 1,382 1,382 - - 9,872 Total (w/o contingency) 263 186 1,568 2,664 2,855 7,537 45,639 11,719 10,920 Total (w/25% contingency) 329 233 1,960 3,331 3,569 9,421 The application of contingency (25%) is consistent with the evaluation criteria referenced by the NRC in NUREG-1757 ("Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. NRC's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Vol. 3, Rev. 1, February 2012)

TLG Services, Inc.