ML20087J682

Trojan Independent Spent Fuel Storage Installation'S (ISFSI) Radiological Decommissioning Cost Estimate and Funding Plans

ML20087J682
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/23/2020
From:	Jenkins B Portland General Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
VPN-004-2020
Download: ML20087J682 (52)

Text

Portland General Electric Company Trojan ISFSI 71760 Columbia River Hwy Rainier, Oregon 97048 March 23, 2020 VPN-004-2020 Trojan ISFSI Docket No.72-017 License No. SNM-2509 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Trojan Independent Spent Fuel Storage Installation's (ISFSI)

Radiological Decommissioning Cost Estimate and Funding Plans Pursuant to 10 CFR 72.30(b), this letter submits for Nuclear Regulatory Commission (NRC) review and approval the proposed Trojan ISFSI Preliminary Radiological Decommissioning Plan (PGE-1082), Revision 2. This plan contains a site-specific Radiological Decommissioning Cost Estimate, associated Co-Owner Funding Plans, and other documents required or requested to meet the 10 CFR 72.30 sections of the Decommissioning Planning Rule and the guidance in NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness.

Portland General Electric's (PGE), Pacificorp's, and Eugene Water and Electric Board's (EWEB) Certifications of Financial Assurance are NOT included due to personnel unavailability associated with COVID-19/coronavirus workplace restrictions. These documents will be provided in a separate mailing for insertion as Appendix 7 in PGE-1082, Revision 2 once Certifications of Financial Assurance are completed and signed.

This Revision 2 contains changes to the document since its previous submittal in December 2015 and updated submittal that accompanied Trojan's license renewal package dated March 23, 2017. The Decommissioning Cost Estimate has been updated from 2015 dollars to use 2019 dollars. Text changes are identified by margin bars adjacent to the changes and revision numbers in the page footers.

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Document Control Desk March 23, 2020 VPN-004-2020 Page2 Portland General Electric Company's (PGE} proposed Trojan ISFSI Preliminary Radiological Decommissioning Plan (PGE-1082), Revision 2 is enclosed.

If there are any questions regarding this letter, please contact Mr. Mark E. Tursa ofmy staff at (503) 556-7030.

Sincerely, Bradley Y. Jenkins Vice. President, Utility Operations Enclosure c: Director, NRC Region IV, DNMS (without Enclosure)

Todd Cornett, ODOE Deborah Hart, EWEB Mike Johanson, PacifiCorp Dana Sandlin, BPA

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PGE-1082 Trojan ISFSI Preliminary Radiological Decommissioning Plan Revision 2 Portland General Electric

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN TABLE OF CONTENTS Section Title Page 1.0

SUMMARY

OF DECOMMISSIONING PLAN.............................................................. 1-1 1.1 OVERVIEW ................................................................................................................................ 1-1 1.2 TROJAN OWNERSIIIP............................................................................................................. 1-1 1.3 TROJAN ISFSI DEC01\1MISSIONING OVERVIEW ........................................................... 1-2 2.0 TROJAN SITE LOCATION AND ISFSI FACILITY DESCRIPTION ....................... 2-1 2.1 SITE LOCATION .......................................................................................................................2-1 2.2 ISFSI FACILITY DESCRIPTION............................................................................................2-1 2.3 FACILITY COMPONENTS AND DIMENSIONS THAT MAY REQUIRE DECONTAMINATION..............................................................................................................2-2 2.4 QUANTITIES OF MATERIALS OR WASTE ACCUMULATED DURING STORAGE OPERATIONS AND SPENT FUEL TRANSFER ...................................................................2-3 2.5 NO VOLUME OF SUBSURFACE MATERIAL THAT REQUIRES REMEDIATION ....2-3 2.6 LEVELS OF ACTIVATION ......................................................................................................2-4 3.0 PROJECTED RADIOLOGICAL DECOMMISSIONING SCHEDULE ..................... 3-1 3.1 PGE'S ASSUMPTIONS AND BASIS FOR THE TROJAN ISFSI PROJECTED RADIOLOGICAL DECOMMISSIONING SCHEDULE .......................................................3-l 4.0 ISFSI RADIOLOGICAL DECOMMISSIONING COST ESTIMATE ........................ 4-1 4.1 DECOMMISSIONING COST ESTIMATE UPDATES ......................................................... 4-1 4.2 DECOMMISSIONING COST ESTIMATE ............................................................................. 4-2 4.3 RADIOLOGICAL DECOMMISSIONING COST ESTIMATE RESULTS ...................... 4-13 5.0 ISFSI RADIOLOGICAL DECOMMISSIONING FUNDING PLAN .......................... 5-1 5.1 RADIOLOGICAL DECOMMISSIONING FUNDING PLAN .............................................. 5-l 5.2 TROJAN CO-OWNERS' DECOMMISSIONING FUNDING PLANS ................................ 5-1 5.3 STATEMENT OF PGE'S AND PACIFICORP'S TRUST BALANCES ..............................5-6 5.4 MONITORING OF PGE'S AND PACIFICORP'S TRUST BALANCES ............................ 5-8 6.0 TROJAN CO-OWNER FINANCIAL ASSURANCE INSTRUMENTS ....................... 6-1 6.1 CO-OWNER FINANCIAL ASSURANCE INSTRUMENTS ................................................. 6-1 6.2 PGE'S FINANCIAL ASSURANCE INSTRUMENT *~*************** .............................................6-1 6.3 EWEB'S FINANCIAL ASSURANCE INSTRUMENT .......................................................... 6-1 6.4 PACIFICORP'S FINANCIAL ASSURANCE INSTRUMENT .............................................6-1 6.5 SUBMIT FINANCIAL ASSURANCE DOCUMENT TO NRC IF 10 CFR 72.30(e)

INFORMATION CHANGES .................................................................................................... 6-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN TABLE OF CONTENTS Section Title Page 7.0 TROJAN ISFSI CO-OWNERS' CERTIFICATIONS THAT FINANCIAL ASSURANCE HAS BEEN PROVIDED FOR THEIR SHARE OF RADIOLOGICAL DECOMMISSIONING COSTS .................................................. 7-1 8.0 RECORD KEEPING FOR DECOMMISSIONING ....................................................... 8-1

9. 0 RE FEREN CES .................................................................................................................... 9-1 APPENDICES Appendix Title 7-1 Certification of Financial Assurance from Portland General Electric Company for 67.5% Ownership 7-2 Certification of Financial Assurance from Eugene Water and Electric Board (EWEB) for 30% Ownership 7-3 Certification of Financial Assurance from PacifiCorp for 2.5% Ownership 11 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN LIST OF TABLES Table Title Page 2-1 Concrete Cask Activation .......................................................................................... 2-4 2-2 Comparison of the Trojan TranStor and HI-STORM 100 Concrete Casks ............... 2-5 2-3 Comparison of Residual Activation Activity v. Concentration Equivalent to 25 mrem/yr ................................................................................................................. 2-5 4.2-1 Labor Cost- Characterization of Activated Cask ..................................................... 4-3 4.2-2 Non-Labor Cost- Characterization of Concrete Casks ............................................. 4-3 4.2-3 Labor Cost - Disposal of Activated Cask .................................................................. 4-4 4.2-4 Non-Labor Cost-Disposal of Activated Cask. ......................................................... 4-5 4.2-5 Labor Cost - Final Status Survey .............................................................................. 4-7 4.2-6 Summary of Non-Labor Cost - Final Status Survey ................................................. 4-8 4.2-6a Contractor Non-Labor Cost (Travel)- Final Status Survey ...................................... 4-8 4.2-6b NRC/ORISE Non-Labor Cost (Travel/Miscellaneous) - Final Status Survey .......... 4-8 4.2-6c Contractor Non- Labor Cost (Equipment/Consumables)-Final Status Survey ....... 4-9 4.2-6d Contractor Non- Labor Cost (Laboratory Services)-Final Status Survey ........... '. ... 4-9 4.2-6e NRC/ORISE Non- Labor Cost (Laboratory Services)-Final Status Survey ......... 4-10 4.2-7 PGE Labor Cost - Final Radiological Decommissioning Plan ............................... 4-11 4.2-8 Non-Labor Cost-Final Radiological Decommissioning Plan................................ 4-12 4.3-1 Radiological Decommissioning Costs ..................................................................... 4-14 4.3-2 ISFSI Radiological Decommissioning Annual Costs .............................................. 4-14 5.1-1 ISFSI Radiological Decommissioning Total Annual Costs in Nominal Dollars ...... 5-1 5.2-1 Portland General Electric Decommissioning Funding Cash Flow ............................ 5-2 5.2-2 EWEB / BPA Decommissioning Funding Annual Cash Obligations ....................... 5-3 5.2-3 PacifiCorp Decommissioning Funding Cash Flow.................................................... 5-4 5.3-1 PGE's Decommissioning Trust Funds' Balances ...................................................... 5-6 5.3-2 PacifiCorp's Decommissioning Trust Funds' Balances ............................................ 5-7 111 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN LIST OF FIGURES Figures Title 2-1 ISFSI Pad Layout 2-2 Transfer Station 2-3 Concrete Cask 2-4 Transfer Cask 3-1 Trojan ISFSI Project Timeline IV Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN LIST OF EFFECTIVE PAGES Section/Page Revision Title Page 2 Table of Contents i through iv 2 List of Effective Pages v 2 Section 1 Pages 1-1 through 1-3 2 Section 2 Pages 2-1 through 2-5 2 Figures 2-1 through 2-4 2 Section 3 Page 3-1 2 Figure 3-1 2 Section 4 Page 4-1 through 4-14 2 Section 5 Pages 5-1 through 5-8 2 Section 6 Pages 6-1 through 6-2 2 Section 7 Page 7-1 2 Section 8 Page 8-1 2 Section 9 Page 9-1 2 All Appendices 2 V Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 1.0

SUMMARY

OF DECOMMISSIONING PLAN 1.1 OVERVIEW This Trojan ISFSI Preliminary Radiological Decommissioning Plan was prepared to satisfy the requirements of 10 CFR 72.30, Financial Assurance and Record.keeping for Decommissioning (Reference 4). The plan includes a description of the facility; a projected decommissioning schedule; a detailed site-specific cost estimate for radiological decommissioning; co-owners' funding plans; co-owners' financial assurance instrument information; co-owners' certifications of financial assurance; and record.keeping for radiological decommissioning.

As required by 10 CFR 72.30(a), this plan contains sufficient information on proposed practices and procedures for the decontamination of the site and facilities and for disposal of residual radioactive materials after all of the spent fuel has been removed from the Trojan site, in order to provide reasonable assurance that the decontamination and decommissioning of the ISFSI at the end of its useful life will provide adequate protection to the health and safety of the public. This plan also identifies and discusses those design features of the ISFSI that facilitate its decontamination and decommissioning at the end of its useful life.

In accordance with 10 CFR 72.30(b), this plan provides details on how reasonable assurance will be provided that funds will be available to decommission the ISFSI. This information includes a site-specific cost estimate for radiological decommissioning of the Trojan ISFSI and a description of the methods from 10 CFR 72.30(e) that the Trojan ISFSI co-owners use to assure adequate funds for radiological decommissioning, including means of adjusting the cost estimate and associated co-owner funding levels periodically over the life of the ISFSI.

1.2 TROJAN OWNERSHIP The Trojan site and Trojan ISFSI facilities are jointly owned by Portland General Electric Company (PGE), 67 .5 percent; the City of Eugene, Oregon, 30 percent through the Eugene Water and Electric Board (EWEB); and PacifiCorp, 2.5 percent. PGE is the majority owner and has responsibility for operating and maintaining the Trojan ISFSI. The Bonneville Power Administration (BP A), a power marketing agency under the United States Department of Energy, is obligated through Net Billing Agreements to pay costs associated with EWEB ' s share of Trojan, including decommissioning and spent fuel management costs.

1-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 1.3 TROJAN ISFSI DECOMMISSIONING OVERVIEW Pursuant to the requirements of 10 CFR 72.130 (Reference 6), the ISFSI was designed to minimize the decontamination efforts required for decommissioning. The design of the Holtec Multi-Purpose Canister (MPC) and the operational process for handling the MPC during Storage and Transfer Station operations ensure that the radioactive materials are contained within the sealed MPC, which minimize the potential for contamination of the ISFSI components and structures. Thus, after the spent fuel is transferred to the DOE and removed from the Trojan site, radiological decommissioning of the ISFSI facility will primarily consist of contamination and radiation surveys and disposal of radioactive waste.

As indicated in the Trojan ISFSI Safety Analysis Report (SAR), Section 3.5 and Table 4.2-3, no contamination is expected on the Concrete Cask and because of low neutron flux levels, no significant activation of the concrete and steel is anticipated.

The Trojan ISFSI radiological decommissioning is contingent on the U.S. Department of Energy (DOE) taking title to the spent fuel and removing it from the Trojan site. Based on PGE's assumptions and projection described in Section 3.0, the spent fuel shipments would occur over a period of approximately 10 years, and the last shipment of spent fuel would be removed from the Trojan site in year 2057. ISFSI facility radiological decommissioning will begin subsequent to this last spent fuel shipment.

Pursuant to 10 CFR 72.54 (Reference 5) and Oregon Administrative Rule (OAR) 345-026-0370 (Reference 7), approximately three to four years prior to the last spent fuel shipment, PGE plans to have characterization activities performed to determine the level of neutron activation in a sample of Concrete Casks. This characterization information will be used to prepare and submit a proposed Trojan ISFSI Final Radiological Decommissioning Plan to the NRC for their review and approval. Subsequent to its approval, expected to be by 2058, this Trojan ISFSI Final Radiological Decommissioning Plan will be used to promptly perform ISFSI facility radiological decommissioning activities.

NRC regulation 10 CFR 72.54(d)(l) contains requirements for providing written notification to the NRC when a licensee has decided to permanently cease principal activities and prepare a Final Radiological Decommissioning Plan and begin the radiological decommissioning process.

This written notification serves to initiate the radiological decommissioning process. This written notification and the beginning of Trojan ISFSI radiological decommissioning activities are projected to occur in year 2055 .

The estimates and assumptions in this report are for projection purposes only, and do not represent any conclusion by Trojan ISFSI licensees about how the USDOE will actually perform in the future. This report should not be taken as any indication that the licensees know how the USDOE will eventually perform its obligations, or have any specific expectation concerning that performance. If USDOE's failure to perform results in specific additional costs beyond those reflected in this supplemental report, it is expected that the USDOE will compensate the licensees for those costs.

1-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN PGE's position is that the USDOE 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 report should be interpreted to be inconsistent with this claim. ISFSI operations at Trojan are in response to the USDOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the USDOE is responsible, according to the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the Trojan ISFSI would be a USDOE-reimbursable expense.

1-3 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 2.0 TROJAN SITE LOCATION AND ISFSI FACILITY DESCRIPTION 2.1 SITE LOCATION The Trojan site consists of approximately 634 acres located in Columbia County in western Oregon on the Columbia River at River Mile 72.5 from the mouth and approximately 42 miles north of Portland, Oregon. The Trojan ISFSI is located in the northeast comer of the Trojan site industrial area.

2.2 ISFSI FACILITY DESCRIPTION The Trojan ISFSI is used to store spent fuel assemblies resulting from the operation of Trojan Nuclear Plant. The facility is located within a secure boundary and consists principally of concrete storage and service pads, a steel fuel Transfer Station, Concrete Casks that hold Multi-Purpose Canisters (MPCs), and a Transfer Cask expected to be used to transfer the MPCs to the DOE Shipping Cask (a.k.a. Transport Cask). The following sections provide facility information and expected characteristics at the time of ISFSI facility radiological decommissioning.

2.2.1 LICENSE NUMBER AND TYPE License Number - SNM-2509, Amendment 6, Renewed on August 9, 2019 for 40 years (new expiration date of March 31 , 2059)

Type - ISFSI 10 CFR 72 specific license 2.2.2 SPECIFIC QUANTITIES AND TYPES OF MATERIALS AUTHORIZED BY THE LICENSE The facility holds 791 spent fuel assemblies and ten containers of fuel debris and/or fuel assembly-related hardware, all contained in 34 MPCs that will be transferred to the DOE and removed from the Trojan site.

2.

2.3 DESCRIPTION

OF FACILITY STRUCTURES AND DIMENSIONS OF AREAS THAT REQUIRE DECONTAMINATION After the removal of the spent fuel from the Trojan site, the ISFSI structures and grounds will consist of an ISFSI pad, a Transfer Station, a Utility building, security barriers, and a short roadway between the ISFSI pad to a rail spur (not yet constructed). A description of the ISFSI facility follows:

• ISFSI Pad - Consists of concrete Storage, Service, and Transfer Pads approximately 170 feet long by 105 feet wide. The concrete pads are approximately 18 inches thick and are constructed on approximately 24 inches of fill. The layout of the ISFSI Pad is shown in Figure 2-1.

2-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN

• Transfer Station - The Transfer Station is a structural steel assembly that allows a Concrete Cask or Transport Cask to be positioned under the Transfer Cask for MPC transfers. A sketch of the Transfer Station is shown in Figure 2-2.

• Utility Building - This is a metal building approximately 20 feet by 40 feet.

For purposes of this radiological decommissioning plan, the structures and grounds are expected to meet release criteria without decontamination, with only a final status survey required.

2.3 FACILITY COMPONENTS AND DIMENSIONS THAT MAY REQUIRE DECONTAMINATION After the removal of the spent fuel from the Trojan site, the Transfer Cask and 34 empty Concrete Casks will remain. A description of these components follows:

2.3.1 CONCRETE CASK The TranStor' Concrete Cask (manufactured by BNFL Fuel Solutions) is a reinforced concrete cylinder with an internal coated steel liner and bottom plate. There is an air flow path between the air inlet ducts at the bottom of the cask and two openings in the bottom plate. There is an air flow path between the four air outlet ducts at the top of the cask and the four openings in the internal steel liner plate. The Concrete Cask lid is steel plate. The empty nominal weight of the Concrete Cask is 214,000 lbs. The height of the cask is 211.5 inches; the outer diameter is 136.5 inches. An elevation view of the Concrete Cask is shown in Figure 2-3.

2.3.2 TRANSFER CASK The Transfer Cask (manufactured by Holtec) is a multi-layered steel cylinder designed to facilitate the transfer of a loaded MPC to and from the Concrete Cask or into the Transport Cask. The wall of the cask consists of various materials. The inner and outer layers are made of steel. Sandwiched between the steel shells is a thickness of lead. A water jacket welded to the outer shell wall of the Transfer Cask provides neutron shielding. There are moveable shield doors at the lower end. The empty nominal weight of the Transfer Cask is 111,500 lbs.

The height of the cask is 195.75 inches; the outer diameter is 92 inches. A sketch of the Transfer Cask configuration is shown in Figure 2-4.

As discussed in Section 1.3, the levels of surface contamination located on the Concrete Cask steel liners and interior of the Transfer Cask are expected to be minimal. Contamination is expected to be readily removable based on past experience associated with, the Transfer Cask during ISFSI fuel loading in 2003 and surface contamination is assumed to be removed after each spent fuel transfer.

2-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Contamination and radiation surveys will be performed to determine if there is any residual contamination and ifISFSI components have been neutron activated above release levels. For purposes of the radiological decommissioning cost estimate in Section 4.0, it is assumed that the following components will require decontamination or disposal:

• Removable surface contamination on the interior surface of the Concrete Cask steel liners

• Removable surface contamination on the Transfer Cask

• Activation of the steel liner in one Concrete Cask 2.4 QUANTITIES OF MATERIALS OR WASTE ACCUMULATED DURING STORAGE OPERATIONS AND SPENT FUEL TRANSFER Surface decontamination of the Concrete Cask steel liners and any impacted areas will be performed as an element of each spent fuel transfer campaign. Radioactive waste generated as part of surface decontamination will be placed in a container and stored on site. This waste will be disposed of at the completion of the spent fuel transfer campaigns (time oflast fuel shipment).

As a result, quantities of decontamination materials or waste accumulated during storage operations and spent fuel transfer to DOE are expected to be minimal.

2.5 NO VOLUME OF SUBSURFACE MATERIAL THAT REQUIRES REMEDIATION Pursuant to 10 CFR 72.3 O(b)( 5), this section provides information on Trojan's evaluation of past and current ISFSI radiological conditions related to subsurface material contamination that could contain residual radioactivity that would require remediation to meet the 10 CFR 20.1402 (Reference 1) radiological criteria for unrestricted use and ISFSI license termination.

Prior to the construction of the ISFSI storage pad and its other facilities, the ISFSI Site area was cleared and a final status survey of the surface and soils was performed. PGE letter VPN-067-96, titled, Trojan Nuclear Plant - Final Survey Report for the Trojan ISFSI Site (TAC No. L22102),

was submitted to the NRC on October 30, 1996 (Reference ML050810358). This PGE Report documented that "all surface activity measurements were less than 25% of the release limit values for unrestricted use, and soil concentrations were equivalent to environmental background concentrations." NRC letter, dated November 26, 1996, documents NRC approval of this Trojan ISFSI Site Final Survey Report (Reference ML0508800534).

The Trojan ISFSI Safety Analysis Report (SAR), Section 7.5.3.2.3, Facility Contamination Control, states in part: "Radioactive contamination of the ISFSI is not anticipated because accessible portions of the external surface of the MPC were checked for loose surface contamination during cask loading operations before the loaded Concrete Cask was moved tp the Storage Pad. In addition, the spent fuel is inside the seal-welded MPC and there are no credible accidents that would cause a gaseous, liquid, or solid release of radioactivity .... " The Trojan ISFSI SAR, Section 7.5.3.2.4, Personnel Contamination Control, states in part: "surveys for contamination at the Concrete Cask air inlets and outlets are routinely performed to confirm that 2-3 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN contamination is not present." As required by SAR Section 7.5.3.2.5, titled Area Surveys, "Quarterly surveys are performed in the accessible areas of the ISFSI. These surveys consist of contamination surveys and external radiation measurements in appropriate areas. Additionally, specific surveys are performed as needed for operational and maintenance functions involving potential exposure of personnel to radiation or radioactive materials." These surveys have consistently determined that no removable contamination is present.

Based on the above, PGE has determined that currently there is no volume of ISFSI onsite subsurface material containing residual radioactivity that will require remediation to meet the 10 CFR 20.1402 radiological criteria for unrestricted use and ISFSI license termination.

2.6 LEVELS OF ACTIVATION Estimated levels of activation in the Trojan TranStor' Concrete Casks are based on information extracted from the .Holtec Final Safety Analysis Report (FSAR) for the similarly configured HI-STORM 100 Concrete Cask [Report HI-2002444] (Reference 8) and "Shielding Evaluation for the Trojan ISFSI Completion Project" [Report HI-2012749 Revisions 5 and 6, Table 0.1]

(Reference 11 ). Activation levels are estimated to be no greater than the values shown in Table 2-1. Activation levels at various decay times are provided in Table 2-1. A comparison of the physical differences between the two casks is provided in Table 2-2.

Table 2 Concrete Cask Activation Activity After Activity After Activity After Activity After Activity After 60-Year 60-Year 60-Year 60-Year Storage -

Nuclide 60-Year Storage- Storage-Storage 1 Year Decay Storage (Ci/m3) 2 Years Decay 5 Years Decay (pCi/gm) (pCi/gm)

(pCi/2:m) (pCi/2:m)

Concrete Cask Steel 54Mn 3.62E-04 4.62E+Ol 2.06E+Ol 9.14E+OO 8.03E-01 ssFe 6.82E-03 8.72E+02 6.77E+02 5.25E+02 2.45E+02 Total 7.18E-03 9.19E+02 6.97E+02 5.34E+02 2.46E+02 Concrete Cask Concrete 39Ar 4.42E-06 l.88E+OO l.87E+OO l.87E+OO l.85E+OO 41Ca 3.66E-07 l.56E-01 l.56E-01 l.56E-01 l.56E-01 54Mn l.59E-06 6.75E-Ol 3.00E-01 l.34E-02 l.17E-02 ssFe 2.95E-05 l.25E+Ol 9.73E+OO 7.55E+OO 3.52E+OO Total 3.58E-05 1.52E+Ol 1.21E+Ol 9.70E+OO 5.54E+OO 2-4 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 2 Comparison of the Trojan TranStor and HI-STORM 100 Concrete Casks Tro.ian TranStor Concrete Cask ID STORM 100 Concrete Overpack Inner Shell: 2" A36 Steel Inner Shell: 1Yi SA516 Gr70 Outer Shell: %" SA516 Gr70 Rebar in Concrete: #6 Rebar Rebar: None, but does have four radial steel ASTM A615 Gr 60 plates, %" SA516 Gr70 Concrete Side Walls: 29" thick Concrete Side Walls: 27.5" thick Overall Dimensions: Overall Dimensions:

Height: 211.5" Height: - 231" Diameter: 136.5" Diameter: -134" Concrete Density: 145 lbs/ft3 Concrete Densitv: 155 lbs/ft3 Concrete Strength: 4,000 psi (min.) Concrete Strength: 3,300 psi (min.)

For the purpose of establishing if activation levels would likely result in exceeding a site release criteria, the estimated concentrations were compared against concentrations extracted from NUREG/CR-5512 (Reference 9) that would result in a dose of25 mrem/yr.

Based on a comparison, activation levels in all of the Concrete Casks should be below the site release criteria after a maximum decay period of two years. Therefore, as a conservative assumption, the estimate assumes that the last Concrete Cask emptied (therefore having the greatest neutron exposure duration and the least time to decay) is activated above release levels, and is disposed of as low-level radioactive waste. If measured activation levels are greater than noted in the above Table 2-1, PGE would have the option of waiting for one or more years to allow for additional decay of the nuclides. A table comparing residual activation and concentrations equivalent to 25 mrem/year is provided in Table 2-3.

Table 2 Comparison of Residual Activation Activity v. Concentration Equivalent to 25 mrem/year Concentration Percent of Residual Residual Activity After equivalent to 25 Activity v.

Nuclide 60-Year Storage -

mrem/yr 1 Concentration for 2 Years Decay (pCi/gm)

(pCi/gm) 25 mrem/yr Concrete Cask Steel 54Mn l.39E+Ol 9.14E+OO 65.8%

ssFe 9.35E+03 5.25E+02 5.6%

Total <100.0%

Concrete Cask Concrete 39Ar Note2 41Ca 5.15E+Ol l.56E-01 0.3%

54Mn l.39E+Ol 1.34E-01 1.0%

ssFe 9.35E+03 7.55E+OO 0.1%

Total <100.0%

Note 1: Values extracted from Table 6.91, NUREG/CR-5512, Vol 3, Residual Radioactive Contamination from Decommissioning, Parameter Analysis, October 1999.

Note 2: 39Ar is not listed in Table 6.91 ofNUREG/CR-5512, Vol 3. It is assumed it was not listed because Argon, being an inert gas, would have minimal impact on Total Effective Dose Equivalent (TEDE).

2-5 Revision 2

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2-6 Revision2

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2-7 Revision2

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---~J UFTl~G-TRUNNIONS OUTER SH.ELL SECTION A-A TOJANISFSI SAFETY ANALYSIS REPORT FIGURE 4.7-1 .

• TRANSFER CASK 2-9 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 3.0 PROJECTED RADIOLOGICAL DECOMMISSIONING SCHEDULE 3.1 PGE'S ASSUMPTIONS AND BASIS FOR THE TROJAN ISFSI PROJECTED RADIOLOGICAL DECOMMISSIONING SCHEDULE This section provides the Trojan ISFSI radiological decommissioning projected schedule. The DOE is responsible for the acceptance of spent fuel and related nuclear material in accordance with the terms of the 1982 Nuclear Waste Policy Act. The PGE contract with DOE, "Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste," provides the basis for the schedule forecast in DOE's most recent Acceptance Priority Ranking Report (APR) for receipt of spent fuel and/or high-level radioactive waste. The DOE schedule published with the July 2004 APR used 2010 for commencing Repository operations and specified the first shipment date for Trojan fuel in 2013. This schedule covered only 10 years of Repository operations and did not specify a projected date for the final Trojan fuel shipment (the schedule covered only 587 of the 791 Trojan spent fuel assemblies). PGE projected the July 2004 schedule out to cover the remaining 204 fuel assemblies and arrived at 2023 as being the estimated date of the final shipment.

The DOE's Project Decision Schedule published in January 2009 included a new anticipated date of 2020 for commencing Repository operations. Using the same modeling assumptions, PGE used this most recent DOE schedule to project and estimate a new first fuel shipment date of 2023 and a final fuel shipment date of 203 3. PGE recognizes this date of commencing Repository operations is highly unlikely and without any additional information from the U.S .

Department of Energy, PGE has modified its radiological decommissioning cost estimate with an end date of March 2059, which coincides with Trojan's recently renewed license, SNM-2509, which expires March 31 , 2059. Characterization of a sample of empty Concrete Casks to determine the level of neutron activation and beginning preparation of the proposed Final ISFSI Radiological Decommissioning Plan, pursuant to 10 CFR 72.54(d) (Reference 5), is projected to be performed in 2054. ISFSI facility radiological decommissioning is projected to begin in year 2057, following the last spent fuel shipment. The radiological decommissioning cost estimate in Section 4.0 and funding plans in Section 5.0 are based on the assumption that ISFSI facility radiological decommissioning will begin in 2057 and complete in 2058, awaiting the NRC ' s acceptance of Trojan' s final status survey for Part 72 license termination.

In March 2010, the DOE filed a motion with the Atomic Safety and Licensing Board to withdraw its Yucca Mountain Repository license application and subsequently closed down the Yucca Mountain project. Based on this, it is unlikely that the DOE will take possession of Trojan's spent fuel by the previously projected date of 2033 and it may be much later. Thus, as a conservative measure, Trojan has modified its projected dates for spent fuel shipments (2049-2057) and ISFSI facility radiological decommissioning (2055-2058), as discussed above.

Figure 3-1, Trojan ISFSI Project Timeline, provides an overall project timeline of major activities, including ISFSI radiological decommissioning, and their projected dates.

3-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN FIGURE 3-1 TROJAN ISFSI PROJECT TIMELINE ISFSI Storage Operations Non-Radiological Radiological Decommissioning Decommissioning Transfer MPCs Prepare ISFSI for from the ISFSI I Demolition / Site Spent Fuel Storage MPC Transfer 1 to DOE I Fi nal St atus Survey NRC Review Restoration 1

1 I

2015 2045 2048 2049 2055 2057 2058 March 31, 2059 2059 Normal Spent Projected Date Prepare Start MPC Notify NRC Complete MPC Complete Final NRC Accept Final Complete Fuel Storage for DOE to Facility for Transfer to and Prepare Transfer to Status Survey Status Survey Demolition/

Start Accepting MPC transfer DOE Final D-Plan DOE 10 CFR 72 License Site Restoration Spent Fuel Termination Year Line is Not to Scale 3-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 4.0 ISFSI RADIOLOGICAL DECOMMISSIONING COST ESTIMATE Pursuant to 10 CFR 72.30(b)(2), (b)(3) and (b)(5), this section provides a detailed site-specific radiological decommissioning cost estimate for the Trojan ISFSI. This radiological decommissioning cost estimate includes the cost of an independent contractor to perform essentially all decommissioning activities; a 25 percent contingency factor; the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and identification of and justification for the key assumptions. Refer to Section 2.4 for PGE's determination that currently there is no volume of ISFSI onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

4.1 DECOMMISSIONING COST ESTIMATE UPDATES The site-specific radiological decommissioning cost estimate for the Trojan ISFSI was prepared using the guidance in NUREG-1757, Volume 3, Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, Section A.3 .1 , Preparing the Site-Specific Cost Estimate (Reference 10).

In accordance with 10 CFR 72.30(b)(4) and (c), the Trojan ISFSI radiological decommissioning cost estimate and associated funding plan will be adjusted over the life of the ISFSI at the time of license renewal and at intervals not to exceed 3 years. Since radiological decommissioning of the ISFSI primarily consists of performing contamination and radiation surveys and disposing of radioactive waste, the radiological decommissioning cost estimate and funding plan adjustments will normally be made to incorporate increased labor costs, and increased radioactive waste burial costs. The ISFSI radiological decommissioning cost estimate and associated funding plans may also be updated to reflect new information from the DOE that would change PGE's assumptions and projection that the final spent fuel shipment would occur in 2057. During future updates, PGE will update the information submitted with the previous revision of this plan and will specifically consider the effect of the following events on decommissioning costs:

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

(1) Spills of radioactive material producing residual radioactivity in onsite subsurface material (refer to Section 2.4). - NO CHANGES (2) Facility modifications. - NO CHANGES (3) Changes in authorized possession limits. -NO CHANGES (4) Actual remediation costs during radiological decommissioning that exceed the previous cost estimate. - NO CHANGES 4-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 4.2 DECOMMISSIONING COST ESTIMATE The scope of the radiological decommissioning cost estimate includes:

• Radiological characterization of the emptied Concrete Casks

• the disposal of any radioactive materials that exceed the release criteria

• a final status survey and NRC license termination;

• PGE staff and overhead associated with preparation of the Final Radiological Decommissioning Plan and management and oversight of the contractor performing final status survey.

The estimated costs are based on reasonable and documented assumptions. The estimate includes sufficient funds to allow an independent third party to assume responsibility for and carry out the radiological decommissioning of the facility if the licensee is unable to do so. This estimate is based on PGE's current assumed projection that the final shipment of spent fuel will be completed in the year 2057 promptly followed by radiological decommissioning of the ISFSI Facility in 2058. The costs of operating the ISFSI and packaging spent fuel and transfer to DOE are considered operations and maintenance expenses and are not within the scope of the radiological decommissioning estimate. Line-item costs are reported in 2019 dollars.

Contingency is included as a separate line item at the sub-total level (refer to Section 4.3, Radiological Decommissioning Cost Estimate Results).

4.2.1 CHARACTERIZATION Characterization of the potentially activated Concrete Cask(s) will be conducted. The purpose of this characterization is to determine the isotopic concentrations and distributions in the cask's steel liner and concrete shell. This information will be used to establish if activation levels have created radioactive material that exceeds the site release criteria. Radiological characterization of the facility ' s structures, as an element ofradiological decommissioning planning, is not considered necessary due to the limited scope of contamination-producing activities conducted at the ISFSI, and the post-spent fuel transfer survey and decontamination work performed after each transfer.

The costs and assumptions associated with characterization are described in the following sections.

4.2.1 .1 Labor Cost The labor cost associated with characterizing ten percent (four) of the Concrete Casks is based on working one day per cask, and mobilization and demobilization. A total of five working days are scheduled. A summary of the labor cost categories, hourly rate, number of hours, and total cost is provided in Table 4.2-1.

4-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.2-1 Labor Cost - Characterization of Activated Cask Hourly Rate Labor Catee:orv ($s/hr) Person-Hours Total Cost ($s)

Laborer 65.02 80 5,201 Radiation Protection Technician 67.00 40 2,680 Total 120 7,881 4.2.1.2 Non-Labor Cost The estimated non-labor cost for the characterization effort is associated with the core drilling and sample analysis. A swnmary of the equipment, hourly rate (rent and operate), number of hours for each item of equipment, and total costs is provided in the Table 4.2-2.

Table 4.2-2 Non-Labor Cost- Characterization of Concrete Casks Hourly Rate Equipment - Total Cost Item ($s/hr) Hours ($s)

Equipment Telescoping boom to 45' high 500 lb capacity 41.07 40 1,643 Telescoping boom Hourly Operating Cost 13.09 20 262 Water Control Equip. & Misc. Tools (Pumps/Wet-Dry HEPA Vac./Filters/55 gal drums/Misc.) 1,729 Core Boring Equipment 7.37 40 295 Core Boring Hourly Operating Cost 1.64 40 66 Saw, Concrete Cutting Equipment 6.19 40 248 Saw Hourly Operating Cost 5.79 40 232 No. of Samples Total Cost -

Subcontracted Services Cost Per Unit (Per Core) 4 Cores ($s)

Concrete Samples Gamma Spectroscopy - Concrete 161 15 9,660 Iron 55 and other hard to detect nuclides -

Concrete 823 15 449,380 Total Activity - Concrete 54 15 3,240 Special Preparation - Concrete 54 15 3,240 Steel Samples Gamma Spectroscopy - Steel 161 1 644 Iron 55 and other hard to detect nuclides - Steel 823 1 3,292 Total Activity - Steel 54 l 216 Special Preparation - Steel 54 I 216 Sample Materials (2% of lab / preparation costs) - - 1,398 Shipping (4 cores total) 45 - 180 PPE (ti) 5% Labor Est. 394 Total - Non-Labor 76,332 4-3 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 4.2.1.3 Assumptions Characterization will consist of taking a core sample from a representative number of Concrete Casks, analyzing the isotopic concentration and distributions in the sample, and correlating those results with cask internal dose measurements. The following are the critical assumptions used in estimating characterization costs:

• 10% of the Concrete Casks will be sampled (four total).

• Segmenting of the cores into two-inch sample segments. This will be done on site.

• Analysis of the samples will be performed at a licensed laboratory.

• Based on correlating the results of the samples, and internal radiation dose measurements, the extent and impact of activation can be established sufficiently to allow for radiological decommissioning planning.

• Supervision of the coring activities and analysis of the results will be done by the PGE staff assigned to spent fuel transfers and ISFSI O&M (no additional PGE labor costs associated with this characterization task).

4.2.2 DISPOSAL OF RADIOACTIVE MATERIALS The disposal of activated/contaminated materials will take place promptly after all spent fuel has been removed from the ISFSI. Decontamination materials generated for each MPC transfer are assumed to have been accumulated in waste containers and placed in storage until all the spent fuel has been transferred from the site. The level of activation of the Concrete Cask and steel liner is expected to be minimal, but for planning/estimating purposes it is assumed that portions of the last Concrete Cask (emptied in 2057) are activated above release levels.

Since there is a railway siding adjacent to the ISFSI, and cask handling equipment will be available (from the last MPC transfer), the Concrete Cask will be transported and disposed of as a one-piece shipment. The decontamination materials will be placed into an LSA container, and transported with the Concrete Cask rail shipment.

4.2.2.1 Labor Cost The estimated labor cost for disposing of the activated Concrete Cask and decontamination waste resulting from the spent fuel transfer campaigns is provided in Table 4.2-3.

Table 4.2-3 Labor Cost - Disposal of Activated Cask Hourly Total Cost Labor Category Rate ($s/hr) Person-Hours ($s)

Mechanic 87.00 80 6,960 Radiation Protection Technician 67.00 40 2,680 Total 120 9,640 4-4 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 4.2.2.2 Non-Labor Cost The estimated non-labor cost for disposing of the activated Concrete Cask and decontamination waste resulting from the spent fuel transfer campaigns is provided in Table 4.2-4. A summary of the material, subcontracted services and disposal charges is also provided in Table 4.2-4.

Table 4.2-4 Non-Labor Cost- Disposal of Activated Cask Item Total Cost ($s)

Equipment No additional equipment required -

equipment provided during MPC transfer Materials B-25 LSA Box 1,592 Package Closure Material 2,400 Package Bracing and Tiedowns 6,400 PPE (ii), 5% Labor Est. 482 Subcontracted Services Engineering Services (Packaging) 13,040 Railroad (Consulting Services) 13 ,040 I-Time Shipment Allowance 6,000 Transport to Disposal Site 5,444 Demurrage Charges 3,200 Disposal Services Concrete Cask - 3,000 ft3 716,400 B-25 LSA Box 22,925 Special Case Package 13 ,040 Railcar Return to Service 2,680 Total - Non-Labor 806,642 4.2.2.3 Assumptions In order to be reasonably conservative in estimating the ISFSI radiological decommissioning cost, it is assumed that the last Concrete Cask to be unloaded will have activation levels that exceed release criteria. The following are the critical assumptions used in estimating the disposal cost of activated and contaminated materials.

• Surface contarp_ination, if any, can be readily removed and will not result in any components or facilities to be disposed of as radioactive waste.

• There is the potential that neutron activation of the Concrete Casks will result in the steel liner potentially exceeding release criteria. With the radionuclides expected to be present in the liner, natural radioactive decay could reduce the radionuclide concentration levels below release levels within a year or so of transferring the fuel.

• After each spent fuel shipment campaign, all empty Concrete Casks will be stored at the Trojan site, i.e., subsequent to the last spent fuel shipment there will be 34 empty Concrete Casks onsite.

4-5 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN

• One activated Concrete Cask (in its entirety) will be prepared for shipping, and transported in one piece to an off-site disposal facility via railway (the last Concrete Cask to be unloaded).

• Moving the activated Concrete Cask to the rail spur and securing it to the railcar will be done by the MPC transfer crew at the end of the last spent fuel transfer campaign.

• The Concrete Cask will be transported via railway and disposed of at the U.S.

Ecology facility in Washington. Decontamination materials resulting from and accumulated during the fuel transfer campaigns will be placed into an LSA container and transported along with the Concrete Cask

• Waste volume is based on the maximum dimensions of the Concrete Cask (rectangular envelope around the cask). Waste cost is based on a U.S. Ecology 2019 price list, including disposal fees ; heavy object surcharges, and tax and fee riders.

The fully loaded cost of disposal for the material was estimated at $238.80 per cubic foot.

• Openings in the Concrete Cask (air ventilation path) will be sealed to the extent necessary to preclude access to the cask or release of materials inside the cask to the environment.

4.2.3 FINAL STATUS SURVEY A proposed Final Radiological Decommissioning Plan will be prepared and approved by the NRC and the Oregon Department of Energy (ODOE) to support promptly performing a final status survey. The final status survey of the ISFSI will be performed in accordance with this plan. The final status survey will be contracted to and conducted by an experienced third party.

NRC staff and NRC contractor fees have been incorporated within the final status survey cost estimate.

4.2.3.1 Labor Cost The labor cost associated with planning (includes review of proposed Final Radiological Decommissioning Plan) and completing the final status survey, including an estimate of the NRC and NRC contractor hours and cost is provided in Table 4.2-5 .

4-6 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.2-5 Labor Cost - Final Status Survey Labor Category Hourly Rate Person-Hours Total Cost ($s)

($s/hr)

Survey Contractor Labor Sr. Rad Engineer 163.00 1,144 186,472 HP Supervisor 131.00 848 102,608 Radiation Protection 67.00 2,912 195,104 Technician - FSS Laborer 65.02 2,912 189,327 Foreman 87.72 728 63,860 Craftsman Coring/Concrete 84.62 80 6,770 Cutting Equipment Equipment Operator 85.66 1,092 95,536 Crane Operator 89.78 80 7, 183 Draftsmen/CAD operator 91.85 182 16,716 Clerk 19.61 936 18,353 Contractor Labor - Subtotal 10,914 879,929 NRC/ORISE Labor NRC Inspector 278.00 264 73 ,392 NRC Inspector HQ 278.00 168 46,704 Management ORISE Project Manager 139.00 144 20,016 ORISE Site Team Leader 112.00 120 13,440 ORISE Survey Crew 70.00 80 5,600 NRC/ORISE Labor - 776 159,152 Subtotal Labor - Total 11,690 1,039,081 4.2.3.2 Non-Labor Cost The non-labor cost associated with planning and completing the final status survey, including an estimate of the NRC and NRC contractor hours and cost and ODOE fees, is provided in Table 4.2-6. Costs are organized by a Summary of Non-Labor Cost, Survey Contractor's costs (Travel Expenses/Equipment/Laboratory) and NRC/ORISE costs (Travel Expenses/Laboratory).

4-7 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.2-6 Summary of Non-Labor Cost - Final Status Survey Activity Total Cost ($s)

(a) Contractor Travel 298,596 (b) NRC/ORISE Travel/Miscellaneous 10,825 (c) Contractor Equipment/Consumables 224,022

( d) Contractor Laboratory Services 81,145

( e) NRC/ORISE Laboratory Services 9,042 (f) Oregon Department of Energy Fees 204,300 Total 827,930 The table entries above are broken out into greater detail in the fo llowing series of Tables 4.2-6(a) through 4.2-6(e).

Table 4.2-6a Contractor Non-Labor Cost (Travel) - Final Status Survey Item Total Cost ($s)

Sr. Rad Engineer 68,837 HP Supervisor 51 ,285 Radiation Protection Technician - PSS 134,305 Foreman 44,169 Travel/Per Diem - Sub Total 298,596 Table 4.2-6b NRC/ORISE Non-Labor Cost (Travel/Miscellaneous) - Final Status Survey Item Total Cost ($s)

Travel/Per Diem NRC Inspector Included in Hourlv Rate ORISE Proiect Manager 1,915 ORISE Site Team Leader 2,524 ORISE Survey Crew 4,703 Travel/Per Diem - Sub Total 9,142 Equipment/Consumables On-Site Consumables 1,683 Equipment/Consumables - Sub Total 1,683 Sub Total - Travel/Per Diem 10,825 4-8 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.2-6c Contractor Non-Labor Cost (Equipment/Consumables)- Final Status Survey Item Daily Rate Equipment- Total Cost ($s)

($s/day) Hours Eq uipment/Consumables Aerial Lift Scissor type to 15" high 1000 lb.cap., 52.67 728 4,793 electric Aerial Lift Operating Cost (50% of time) 29.12 728 1,325 Telescoping boom to 45' high 500 lb capacity 328.55 364 14,949 Telescoping boom Operating Cost (50% of time) 104.72 364 2,382 Forklift (5000#) 247.19 728 22,494 Forklift Operating Cost (25% of time) 129.33 728 2,942 Water Control Equip. & Misc. Tools 3,457 (Final Status Survey)

Core Boring Equipment 58.93 80 589 Core Boring Operating Cost (50% of time) 13.10 80 66 Saw, Concrete Cutting Equ ipment 49.54 80 495 Saw Operating Cost (25% of time) 46.31 80 I 16 Pickup Truck 3/4 Ton 62.06 728 5,647 Pickup Truck, Operating Cost 77.18 728 7,024 Crane, 350 ton capacity 80' boom 4250.23 80 42,502 Crane, Operating Cost (50% of time) 1526.95 80 7,635 Temporary Facilities 46,900 Mobilization/DeMobi lization 8,683 HP Equipment Costs 38,823 Consumables 1.5% of Labor Cost 13,199 Equipment/Consumables - Sub Total 224,022 Table 4.2-6d Contractor Non-Labor Cost (Laboratory Services) - Final Status Survey Cost Per Unit No. of Total Cost ($s)

Laboratory Services - Sample Analysis ($s) Samples Gamma Spectroscopy 161 98 15,778 Iron 55 and other hard to detect nuclides 823 63 51,849 Total Activity 54 63 3,402 Sample Preparation 54 106 5,292 Sampling (Supplies & Materials) 3,816 Transport of Samples 1,008 Sampling/Analysis - Sub Total 81,145 4-9 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.2-6e NRC/ORISE Non-Labor Cost (Laboratory Services) - Final Status Survey Cost Per Unit No. of Total Cost ($s)

Laborato ry Services - Sample Analysis ($s) Samples Gamma Spectroscopy 161 11 1,771 Iron 55 and other hard to detect nuclides 823 7 5,761 Total Activity 54 7 378 Sample Preparation 54 12 594 Sampling (Supplies & Materials) 425 Transport of Samples 113 Samplin2/ Analys is - Sub Total 9,042 4.2.3 .3 Assumptions The final status survey will be conducted by a third-party contractor. Management and oversight will be provided by PGE staff. The NRC will conduct on-site visits, review the results of the survey and will contract with a third party (ORISE) to independently verify the survey results.

The following are the critical assumptions used in estimating the demolition and site restoration costs:

• All activated and contaminated material will be removed from the facility prior to initiating the survey.

• The contractor will work with PGE in developing the Final Radiological Decommissioning Plan, Final Status Survey Plan, and Final Status Survey Report.

It is assumed that similar facilities will have been decommissioned prior to the Trojan ISFSI; therefore this will not be a "first-of-a-kind" activity.

• The subcontractor will provide all labor, materials and equipment necessary to complete the survey. Sample analysis will be done by outside laboratories at the contractor's expense.

• An estimate of NRC and NRC contractor fees has been incorporated into the estimate. NRC staff costs are based on hourly rates published in 10 CFR 170. NRC contractor costs are based on estimated hourly rates and travel and living expenses.

• ORISE hourly costs are based on the hourly costs used for PGE' s subcontractor labor (for equivalent positions).

• The Oregon Department of Energy (ODOE) is assumed to participate in the Final Radiological Decommissioning Plan and Final Status Survey Plan and Report reviews. ODOE costs are incorporated into the estimate and are based on historical annual fees charged during Trojan Nuclear Plant decommissioning.

• The NRC and the ODOE will complete their reviews of the Final Status Survey Report; the Trojan ISFSI site will meet the criteria for unrestricted release; and the ISFSI License will be promptly terminated. Following license termination, PGE may proceed with demolition of ISFSI clean facilities and components and site restoration.

4-10 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 4.2.4 PGE STAFF AND OVERHEAD COSTS PGE will provide a staff to prepare the proposed Final Radiological Decommissioning Plan and oversee the radiological decommissioning activities. In addition to the cost of labor it is assumed that certain overhead expenses will be incurred.

The costs and assumptions associated with each of these activities are described in the following sections.

4.2.4.1 Labor Cost The cost of PGE labor is based on preparing the proposed Final Radiological Decommissioning Plan and contracting for and managing the final status survey (license termination). Costs estimated for this activity are provided by labor cost category, hourly rate, number of hours, and total cost in Table 4.2-7.

Table 4.2-7 PGE Labor Cost - Final Radiological Decommissioning Plan Labor Category Hourly Person- Total Cost Rate Hours ($s)

($s/hr)

Project Manager 119.00 1,880 223,720 Project Engineer 103.00 2,036 209,708 Licensing Specialist 103.00 2,036 209,708 Admin Assistant 47.00 1,410 66,270 Total 7,362 709,406 Note: These PGE Labor Costs are spread out over three years in Table 4.3-2.

4.2.4.2 Non-Labor Cost Non-labor costs for radiological decommissioning work are principally included in specific work activities, including the final status survey. The PGE non-labor cost associated with license termination are those costs expected to be directly incurred by PGE and not accounted for in the subcontractors' scope of work. These costs are provided in Table 4.2-8.

4-11 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.2-8 Non-Labor Cost - Final Radiological Decommissioning Plan Item License Term ination Cost

($s)

Equ ipment No equipment provided by PGE Other (Materials/ Services)

Insurance (allowance) 85,IOO Utilities (allowance) 40,IOO Travel (allowance) 6,000 Total - Non-Labor 131,200 4.2.4.3 Assumptions The Final Radiological Decommissioning Plan is developed and approved prior to the last MPC being transferred to the DOE. The final status survey is assumed to start promptly after the last of the spent fuel has been removed, and the activated Concrete Cask is disposed of at U.S. Ecology in Washington.

• PGE will begin preparing the proposed Final Radiological Decommissioning Plan three years prior to completion of spent fuel shipments (year 2057) and expects to obtain NRC and ODOE approval by 2057, such that the Final Status Survey will commence promptly after the last fuel shipment.

• The cost of PGE labor associated with operating and maintaining the ISFSI and spent fuel transfer to DOE is not included within the radiological decommissioning scope of work.

• The site is assumed to be radiologically clean after the activated Concrete Cask has been shipped to U.S. Ecology.

• PGE will prepare the proposed Final Radiological Decommissioning Plan. The final status survey contractor will support PGE's Final Radiological Decommissioning Plan development.

• PGE will contract to have the final status survey done by third parties. Therefore, PGE's principal role is to write bid specifications, select contractors and oversee the final status survey work.

• Labor costs are based on rates published in R.S. Means 2019, Building Construction Cost Data, PGE's experience and the estimator's experience.

• Where labor is subcontracted, the costs include contractor' s overhead and profit.

• Insurance costs are an allowance and include costs for Supplier's and Transporter's premium, and general liability insurance.

• Utility costs are an allowance and include electric, water, phone, and sewage.

4-1 2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN

• Travel costs are an allowance for miscellaneous travel.

• Estimated NRC fees and ODOE fees are included in the Final Status Survey estimate.

4.3 RADIOLOGICAL DECOMMISSIONING COST ESTIMATE RESULTS The total estimated cost for radiological decommissioning and termination of the ISFSI license is

$4.510 million (2019 dollars). The estimate is based on Trojan ISFSI-specific information, an assumed projected final spent fuel shipment date, published labor, equipment and material, and waste disposal costs. Contingency has been included at the rate recommended in NUREG-1757 (25% contingency).

It is assumed that PGE will oversee the radiological decommissioning program, but essentially all of the work will be performed by contractors. Costs associated with operating and maintaining the ISFSI, packaging spent fuel and transfer to DOE, non-radiological decommissioning, and site restoration are not included since these activities are considered outside the scope of radiological decommissioning.

As described in this report, the last spent fuel shipment is assumed to be transferred to the DOE and be removed from the site in 2057.

There is expected to be a minimum amount of radioactive waste generated as a result of spent fuel packaging for shipping activities. As a conservative assumption it is assumed that one Concrete Cask will have been neutron activated and will require disposal as radioactive waste.

Such waste is assumed to be transported to the U.S . Ecology facility in Richland, Washington.

The ISFSI facilities used to store and transfer the spent fuel are assumed to be decontaminated (if necessary) as part of each spent fuel transfer campaign. As such, with the exception of disposing of the activated Concrete Cask, radiological decommissioning will principally consist of performing a Final Status Survey.

The schedule for completion is controlled to a large extent by the projected schedule for DOE acceptance of spent fuel. In the event that the DOE schedule changes, the decommissioning costs would be expected to remain the same (in 2019 dollars), but the timing of expenditures would change.

A radiological decommissioning cost breakout by major categories is provided in Table 4.3-1. In addition, radiological decommissioning costs, as a series of annual costs, are provided in Table 4.3-2.

4-13 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 4.3-1 Radiological Decommissioning Costs (costs in thousands, 2019 dollars)

Radiological Decommissioning Activity Labor Non- Total Labor Characterization (Tables 4.2-1 and 4.2-2) 8 76 84 Decontamination and Disposal (Tables 4.2-3 and 4.2-4) 10 807 816 Final Status Survey (Tables 4.2-5 and 4.2-6) 1,039 828 1,897 PGE Staff (Final Radio logical Decommissioning Plan)

(Tables 4.2-7 and 4.2-8) 709 131 841 Sub-Total (w/o contingency) 1,766 1,842 3,608 Contingency @ 25% 442 461 902 Total 2,208 2,303 4,510 Table 4.3-2 ISFSI Radiological Decommissioning Annual Costs (costs in thousands, 2019 dollars)

Radiological Decommissioning Radiological Decommissioning Year of Expenditure w/o 25% Contingency with 25% Contingency 2054 1 84 105 2055 173 216 2056 147 184 2057 963 1,204 2058 2,240 2,800 Total 3,608 4,510 Note 1: Characterization work is projected to occur in 2054 to support preparation of the Trojan proposed Final Radiological Decommissioning Plan. ODOE-related decommissioni ng planning and review expenses are projected to occur in 2055 -2058 . Final status survey is projected to occur in 2057-2058 fo llowed by license termination in 2059.

4-14 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 5.0 ISFSI RADIOLOGICAL DECOMMISSIONING FUNDING PLAN Pursuant to 10 CFR 72.30(b), this section provides the co-owners' radiological decommissioning funding plans. As required by 10 CFR 72.30(b)(4) and 72.30(c), the means for adjusting the cost estimate and associated funding plans over the life of the Trojan ISFSI are discussed in Section 4.1 .

5.1 RADIOLOGICAL DECOMMISSIONING FUNDING PLAN The following Table 5 .1 -1 , "ISFSI Radiological Decommissioning Total Annual Costs in Nominal Dollars" provides the basis for the Trojan co-owner funding plans.

Table 5.1-1 ISFSI Radiological Decommissioning Total Annual Costs in Nominal Dollars (costs in thousands)

Year of All Co-Owner's PG E's EWEB's PacifiCo rp's Expenditure Total Costs 1 67.5% Share 30% Share 2.5% Share 2054 225 152 67 6 2055 475 321 142 12 2056 412 278 124 10 2057 2,756 1,860 827 69 2058 6,549 4,421 1,965 163 Total 10,417 7,032 3,125 260 Note I: To create this Table 5.1 -1, the 2019 dollar values shown in Table 4.3-2 were converted to nominal dollars by multiplying by an annual escalation factor of 2.20% for years 2020 through 2058. This calculated annual average escalation factor value is based on the November 2019 Global Insight All-Urban Consumer Price Index PCCPI values for years 2020-2049.

5.2 TROJAN CO-OWNERS ' DECOMMISSIONING FUNDING PLANS The radiological decommissioning funding plans for each of the Trojan co-owners, needed to provide the total cash flow in Table 5.1-1 , are described below.

5.2.1 PGE FUNDING PLAN Table 5.2-1 , "Portland General Electric Decommissioning Funding Cash Flow" provides PGE' s radiological decommissioning funding cash flow in nominal dollars for radiological decommissioning. Funded from an external trust fund, the expenditures described in this table are PGE' s share (67.5 %) of the expenditures described in Table 5.1-1. The funding plan described in Table 5.2-1 ensures that PGE's 67.5% portion of the radiological decommissioning activity expenditures will be fully funded. It is noted that the Trojan ISFSI Radiological Decommissioning Fund Sub-Account' s market value specified in Table 5.3-1 , PGE' s Decommissioning Trust Funds ' Balances, is substantiaJJy more than the amount of PGE' s 67.5%

5-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN share of funds required for ISFSI facility radiological decommissioning as specified in Table 5.2-1 (PGE Trust Fund Expenditures, Column A, Total). Therefore, no additional amount remains to be collected for PGE's share of ISFSI faci lity radiological decommissioning.

Table 5.2-1 Portland General Electric Decommissioning Funding Cash Flow ISFSI Radiological Decommissioning (PGE 67.5% Nominal $ x 1000)

PGE PGE PGE PGE PGE PGE Trust Fund Trust Fund DOE Trust Fund Taxes, Fees. and Trust Fund Year Expend itures Contributions Settlement Net Earnings Expenses EOY Balance A B F C D E 2019 5,420 2020 0 0 0 108 0 5,528 2021 0 0 0 111 0 5,639 2022 0 0 0 113 0 5,752 2023 0 0 0 115 0 5,867 2024 0 0 0 117 0 5,984 2025 0 0 0 120 0 6,104 2026 0 0 0 122 0 6,226 2027 0 0 0 125 0 6,351 2028 0 0 0 127 0 6,478 2029 0 0 0 130 0 6,608 2030 0 0 0 132 0 6,740 2031 0 0 0 135 0 6,875 2032 0 0 0 138 0 7,013 2033 0 0 0 140 0 7,153 2034 0 0 0 143 0 7,296 2035 0 0 0 146 0 7,442 2036 0 0 0 149 0 7,591 2037 0 0 0 152 0 7,743 2038 0 0 0 155 0 7,898 2039 0 0 0 158 0 8,056 2040 0 0 0 161 0 8,217 2041 0 0 0 164 0 8,381 2042 0 0 0 168 0 8,549 2043 0 0 0 171 0 8,720 2044 0 0 0 174 0 8,894 2045 0 0 0 178 0 9,072 2046 0 0 0 181 0 9,253 2047 0 0 0 185 0 9,438 2048 0 0 0 189 0 9,627 2049 0 0 0 193 0 9,820 2050 0 0 0 196 0 10,016 2051 0 0 0 200 0 10,216 2052 0 0 0 204 0 10,420 2053 0 0 0 208 0 10,628 2054 (152) 0 0 213 0 10,689 5-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN PGE PGE PGE PGE PGE PGE Trust Fund Trust Fund DOE Trust Fund Taxes, Fees.and Trust Fund Year Expenditures Contributions Settlement Net Earnings Expenses EOY Balance A B F C D E 2055 (321) 0 137 214 0 10,719 2056 (278) 0 288 214 0 10,944 2057 (1,860) 0 250 219 0 9,553 2058 (4,421) 0 1,674 191 0 6,997 2059 0 0 3,978 140 0 11,115 Total (7,032) 0 6 ,328 6,399 0 Column A: For years 2054-2058, these numbers show incurred costs. No funds for decommissioning costs will be disbursed from this JSFSI Radiological Decommissioning Fund Sub-Account until after the NRC approves the JSFSI Final Radiological Decommissioning Plan.

Columns A and D: Annual escalation factor is 2.20% per year Column 8: Due to the ISFSI radiological 'decommissioning account being more than fully funded, PGE stopped contributions to this trust account at the end of 2012.

Column C: Annual Net Earnings of2% is based on JOCFR 50.75(e)(l)(ii)

Column F: DOE Settlement calculated as 90% of prior year expenditures thru start of fuel campaign in 2048. Resuming in 2055 to reflect commencement of ISFSI Radiological Decommissioning in 2054.

5.2.2 EWEB/BPA FUNDING PLAN Table 5.2-2, "EWEB/BPA Decommissioning Funding Annual Cash Obligations" provides EWEB/BPA's radiological decommissioning funding cash flow in nominal dollars for radiological decommissioning. The expenditures described in this table are EWEB/BPA's share (30%) of the expenditures described in Table 5 .1-1. BP A is obligated through Net Billing Agreements to pay costs associated with EWEB's share of Trojan, including radiological decommissioning costs. As a government agency, EWEB uses a Statement oflntent for their financial instrument (see Section 6.3 and Appendix 7-2, Certification of Financial Assurance).

EWEB's Statement oflntent and Certification of Financial Assurance both document BPA's obligation to pay the decommissioning funding obligations ofEWEB . The funding plan described in Table 5.2-2 ensures that EWEB/BPA's 30% portion of the radiological decommissioning activity expenditures will be fully funded.

Table 5.2-2 EWEB/BP A Decommissioning Funding Annual Cash Obligations ISFSI Radiological Decommissioning (EWEB / BPA 30% Nominal$ x 1000)

Year EWEB I BP A Obligations 2054 67 2055 142 2056 124 2057 827 2058 1,965 Total 3,125 5-3 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 5.2.3 PACIFICORP FUNDING PLAN Table 5.2-3, "PacifiCorp Decommissioning Funding Cash Flow" provides PacifiCorp's radiological decommissioning funding cash flow in nominal dollars for radiological decommissioning. Funded from an external trust fund, the expenditures described in this table are PacifiCorp's share (2.5%) of the expenditures described in Table 5.1-1. The funding plan described in Table 5.2-3 ensures that PacifiCorp' s portion of the radiological decommissioning activity expenditures will be fully funded. It is noted that the Trojan ISFSI Radiological Decommissioning Fund Sub-account's market value specified in Table 5.3-2, PacifiCorp's Decommissioning Trust Funds' Balances, is equal to the full amount of PacifiCorp's 2.5% share of funds required for ISFSI facility radiological decommissioning as specified in Table 5.2-3 (PacifiCorp Trust Fund Expenditures, Column A, Total). Therefore, no additional amount remains to be collected for PacifiCorp' s share ofISFSI facility radiological decommissioning.

Table 5.2-3 PacifiCorp Decommissioning Funding Cash Flow ISFSI Radiological Decommissioning (PacifiCorp 2.5% Nominal$ x 1000)

PacifiCorp PacifiCorp PacifiCorp PacifiCorp PacifiCorp PacifiCorp Trust Fund Trust Fund DOE Trust Fund Taxes, Fees. and Trust Fund Year Expenditures Contributions Settlement Net Earnings Expenses EOY Balance A B F C D E 2019 155 2020 0 0 3 0 158 2021 0 0 3 0 161 2022 0 0 3 0 164 2023 0 0 3 0 167 2024 0 0 3 0 170 2025 0 0 3 0 173 2026 0 0 3 0 176 2027 0 0 4 0 180 2028 0 0 4 0 184 2029 0 0 4 0 188 2030 0 0 4 0 192 2031 0 0 4 0 196 2032 0 0 4 0 200 2033 0 0 4 0 204 2034 0 0 4 0 208 2035 0 0 4 0 212 2036 0 0 4 0 216 2037 0 0 4 0 220 2038 0 0 4 0 224 2039 0 0 4 0 228 2040 0 0 5 0 233 2041 0 0 5 0 238 2042 0 0 5 0 243 2043 0 0 5 0 248 2044 0 0 5 0 253 2045 0 0 5 0 258 5-4 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN PacifiCorp PacifiCorp PacifiCorp PacifiCorp PacifiCorp PacifiCorp Trust Fund Trust Fund DOE Trust Fund Taxes, Fees, and Trust Fund Year Expenditures Contributions Settlement Net Earnings Expenses EOY Balance A B F C D E 2046 0 0 5 0 263 2047 0 0 5 0 268 2048 0 0 5 0 273 2049 0 0 5 0 278 2050 0 0 6 0 284 2051 0 0 6 0 290 2052 0 0 6 0 296 2053 0 0 6 0 302 2054 (6) 0 6 0 302 2055 (12) 5 6 0 302 2056 (10) 11 6 0 308 2057 (69} 9 6 0 254 2058 (163} 62 5 0 158 2059 0 147 3 0 309 Total (260) 0 234 179 0 Column A: For years 2054-2058, these numbers show incurred costs. No funds for decommissioning costs will be disbursed from this ISFSI Radiological Decommissioning Fund Sub-Account until after the NRC approves the ISFSI Final Radiological Decommissioning Plan.

Columns A and D: Annual escalation factor is 2.20% per year.

Column B: Due to the ISFSI radiological decommissioning account being full y funded, PacifiCorp has stopped contributions to this trust account.

Column C: Annual Net Earnings of2% is based on 10 CFR 50.75(e)(l)(ii).

Column D: There are no Trustee Fees or Expenses associated with this trust account.

Col umn F: DOE Settlement calculated as 90% of prior year expenditures thru start of fuel campaign in 2048. Resuming in 2055 to reflect commencement of ISFS I Radiological Decommissioning in 2054.

5-5 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 5.3 STATEMENT OF PGE ' S AND PACIFICORP'S TRUST BALANCES Pursuant to NUREG-1757, Volume 3, Section 4.3.2.1 guidance, the balances in PGE's and PacifiCorp's Nuclear Decommissioning Trusts, that include funds for Trojan ISFSI radiological decommissioning, are provided in Table 5.3-1, PGE's Decommissioning Trust Funds' Balances.

and Table 5.3-2, PacifiCorp's Decommissioning Trust Funds' Balances.

Table 5.3-1 PGE's Decommissioning Trust Funds' Balances ISFSI Radiological Total Market Value of Trojan Co-Owner Decommissioning Fund All Funds in PGE's Market Value Trojan Decommissioning (as of 12-31-2019) Trust Accounts (as of 12-31-2019)

Portland General Electric

$5,420,379 $45,842,729 (PGE)

Note I: PGE's market value of funds in the Trojan ISFSI Rad iological Decommissioning Fund Sub-Account and the total market value of all funds in all five Decommissioning Trust Accounts are specified in the above Table. These are evidenced by The Northern Trust Company's Accounting Statements "Closing Balance, Market Value" for PG E's Nuclear Decommissioning Trust Accounts as of December 31, 2019.

Note 2: Pursuant to 10 CFR 72.54 and a restriction in the PGE Nuclear Decommissioning Trust Agreement, no funds for decommissioning costs shall be disbursed from this ISFSI Radiological Decommissioning Fund Sub-Account until after the NRC approves the ISFSI Final Radiological Decomm issioning Plan.

Note 3: PG E's Nuclear Decommissioning Trust was initially established to provide financial assurance for the radiological decommissioning of Trojan Nuclear Plant and in 2008 a separate sub-account was established specifically for ISFSI radiological decommissioning. This Trust has five separate accounts and currently contains and continues to collect funds to be used only for the following activities: Trojan Nuclear Plant non-radiological decommissioning; Trojan ISFSI spent fuel management (including spent fuel packaging and transfer to the DOE); Trojan ISFSI radiological decommissioning and license termination; Trojan ISFSI non-radiological decommissioning; and Trojan Site restoration.

Note 4: It is noted that the above Trojan ISFSl Radiological Decommissioning Fund Sub-Account's market value is substantially more than the amount of PG E's 67.5% share of funds required for ISFSI facility radiological decommissioning as specified in Table 5.2-1 (PGE Trust Fund Expenditures, Column A, Total). Therefore, no additional amount remains to be collected for ISFSI facility radiological decommissioning. In the future, if additional funds are needed for ISFSI radiological decommissioning, the funds will be transferred from one of the other Trojan decommissioning trust accounts into the ISFSI Radiological Decommissioning Fund Sub-Account.

5-6 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Table 5.3-2 PacifiCorp's Decommissioning Trust Funds' Balances Total Market Value of ISFSI Radiological All Funds in PacifiCorp's Decommissioning Fund Trojan Co-Owner Trojan Decommissioning Market Value Trust Accounts (as of 12-31-2019)

(as of 12-31 -2019)

PacifiCorp $ 155,449.48 $1,953,937.39 Note 1: PacifiCorp's market value of funds in the Trojan ISFSI Radiological Decommissioning Fund Sub-Account and the total market value of all funds in both Decommissioning Trust Accounts are specified in the above Table. These are evidenced by State Street Bank's Accounting Statements "Market Value" for PacifiCorp's Trojan Decommissioning Trust Accounts as of December 31 , 2019.

Note 2: Pursuant to 10 CFR 72.54 and a restriction in the PacifiCorp Nuclear Decommissioning Trust Agreement, no funds for decommissioning costs shall be disbursed from this ISFSI Radiological Decommissioning Fund Sub-Account until after the NRC approves the ISFSI Final Radiological Decommissioning P lan.

Note: 3 PacifiCorp's Nuclear Decommissioning Trust was initially established to provide financial assurance for the radiological decommissioning of Trojan Nuclear Plant and in November 2012 a separate sub-account was established specifically for ISFSI radiological decommissioning funds. This Trust has two separate accounts and currently contains and continues to collect funds to be used only for the following activities: Trojan Nuclear Plant non-radiological decommissioning; Trojan ISFSI spent fuel management (including spent fuel packaging and transfer to the DOE); Trojan ISFSI radiological decommissioning and license termination; Trojan ISFSI non-radiological decommissioning; and Trojan Site restoration.

Note 4: It is noted that the above Trojan ISFSI Radiological Decommissioning Fund Sub-Account's market value is equal to the full amount of PacifiCorp's 2.5% share of funds required for ISFSI facility radiological decommissioning as specified in Table 5.2-3 (PacifiCorp Trust Fund Expenditures, Column A, Total).

Therefore, no additional amount remains to be collected for ISFSI facility radiological decommissioning.

In the future, if additional funds are needed for ISFSI radiological decommissioning, the funds will be transferred from the other Trojan decommissioning trust account into the ISFSI Radiological Decommissioning Fund Sub-Account.

5-7 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 5.4 MONITORING OF PGE'S AND PACIFICORP'S TRUST BALANCES Pursuant to 10 CFR 72.30(g), PGE and PacifiCorp, as Trojan ISFSI licensees, will monitor the balance of funds held in their Trojan Decommissioning Trusts for ISFSI Radiological Decommissioning to account for market variations. PGE and PacifiCorp will replenish the funds, and report such actions to the NRC, as follows:

5.4.1 If, at the end of a calendar year, the fund balance is below the amount necessary to cover the cost ofradiological decommissioning, but is not below 75 percent of the cost, the licensee will increase the balance to cover the cost, and will do so within 30 days after the end of the calendar year.

5.4.2 If, at any time, the fund balance falls below 75 percent of the amount necessary to cover the cost of radiological decommissioning, the licensee will increase the balance to cover the cost, and will do so within 30 days of the occurrence.

5.4.3 Within 30 days of taking the actions required by the above paragraphs 5.4.1 or 5.4.2, the licensee will provide a written report of such actions to the Director, Office of Federal and State Materials and Environmental Management Programs, and state the new balance of the fund.

5-8 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 6.0 TROJAN CO-OWNER FINANCIAL ASSURANCE INSTRUMENTS Pursuant to 10 CFR 72.30(b)(4), this section provides a description of the Trojan co-owners' methods (financial instruments) from 10 CFR 72.30(e) for assuring funds for radiological decommissioning.

6.1 CO-OWNER FINANCIAL ASSURANCE INSTRUMENTS The financial assurance instrument that each co-owner uses to provide funding and financial assurance for Trojan ISFSI radiological decommissioning is detailed below.

6.2 PGE'S FINANCIAL ASSURANCE INSTRUMENT As a majority co-owner in the Trojan ISFSI, PGE is responsible for funding 67.5 percent of the total ISFSI radiological decommissioning costs. As allowed by 10 CFR 72.30(e)(5), PGE provides ISFSI radiological decommissioning funding assurance using the method of 10 CFR 50.75(e)(l)(ii) (Reference 3). Specifically, PGE has established and maintains an external sinking fund in the form of a trust, which is segregated from PGE's assets and outside PGE's administrative control, and into which funds are set aside such that the total amount of funds will be sufficient to pay radiological decommissioning costs. As allowed by 10 CFR 72.30(e)(5) for licensees such as PGE that recover the total estimated radiological decommissioning costs through ratemaking regulation, this method is the exclusive mechanism that PGE relies upon to provide financial assurance for Trojan ISFSI radiological decommissioning. In the event that funds remaining to be placed into PGE's external sinking fund to cover PGE's 67.5 percent ownership share of Trojan ISFSI radiological decommissioning costs are no longer approved for recovery in rates by a competent rate regulating authority (currently Oregon Public Utility Commission (OPUC)), PGE would no longer be allowed to use the financial assurance mechanisms of 10 CFR 50.75(e), but rather would be required to use financial assurance methods as specified in 10 CFR 72.30(e)(l) through (4).

6.3 EWEB'S FINANCIAL ASSURANCE INSTRUMENT BPA is obligated through Net Billing Agreements to fund EWEB's 30 percent share of the total Trojan ISFSI radiological decommissioning costs. As allowed by 10 CFR 72.30(e)(4),

EWEB, as a government agency provides financial assurance in the form of a Statement of Intent. The Statement of Intent includes the commitment that funds for radiological decommissioning of the Trojan ISFSI will be obtained from BPA (a Federal Government agency) when necessary.

6.4 PACIFICORP'S FINANCIAL ASSURANCE INSTRUMENT PacifiCorp is responsible for funding its 2.5 percent share of the total ISFSI radiological decommissioning costs. As allowed by 10 CFR 72.30(e)(5), PacifiCorp provides ISFSI radiological decommissioning funding assurance using the method of 10 CFR 50.75(e)(l)(ii).

6-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN Specifically, PacifiCorp has established and maintains an external sinking fund in the form of a trust, which is segregated from PacifiCorp's assets and outside PacifiCorp's administrative control, and into which funds are set aside such that the total amount of funds will be sufficient to pay radiological decommissioning costs. As allowed by 10 CFR 72.30(e)(5) for licensees such as PacifiCorp that recover the total estimated radiological decommissioning costs through ratemaking regulation, this method is the exclusive mechanism that PacifiCorp relies upon to provide financial assurance for Troj an ISFSI radiological decommissioning. In the event that funds remaining to be placed into PacifiCorp's external sinking fund to cover PacifiCorp's 2.5 percent ownership share of Trojan ISFSI radiological decommissioning costs are no longer approved for recovery in rates by a competent rate regulating authority (currently OPUC),

PacifiCorp would no longer be allowed to use the financial assurance mechanisms of 10 CFR 50.75(e), but rather would be required to use financial assurance methods as specified in 10 CFR 72.30(e)( l ) through (4).

6.5 SUBMIT FINANCIAL ASSURANCE DOCUMENT TO NRC IF 10 CFR 72.30{e)

INFORMATION CHANGES Pursuant to the requirements in 10 CFR 72.30(e), PGE's Nuclear Decommissioning Trust Agreement, EWEB's Statement of Intent, and PacifiCorp's Nuclear Decommissioning Trust Agreement include the licensee's name, license number, and docket number; and the name, address, and other contact information of the issuer, and the trustee, if applicable. When any of the foregoing information changes in one of these financial instruments, the licensee will, within 30 days, submit a copy of the financial instrument refl ecting such changes to the NRC in accordance with 10 CFR 72.4.

6-2 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN 7.0 TROJAN ISFSI CO-OWNERS' CERTIFICATIONS THAT FINANCIAL ASSURANCE HAS BEEN PROVIDED FOR THEIR SHARE OF RADIOLOGICAL DECOMMISSIONING COSTS Pursuant to 10 CFR 72.30(b)(6), this section provides the Trojan Co-Owners' (PGE, EWEB, and PacifiCorp) Certifications that financial assurance for radiological decommissioning of the Trojan ISFSI has been provided for their share of the amount of the cost estimate for radiological decommissioning. These documents will be updated at the time of license renewal and at intervals not exceeding 3 years to reflect any changes in the ISFSI radiological decommissioning cost estimate and/or funding plans.

Pursuant to 10 CFR 72.30(b)(l), these Certifications coupled with the co-owners' financial assurance instruments (PGE's and PacifiCorp's Trusts and EWEB's Statement oflntent) provide reasonable assurance that funds will be provided and will be available for Trojan ISFSI radiological decommissioning.

See the following Appendices for original signed copies of Certifications of Financial Assurance from the Trojan ISFSI licensees:

7-1 Certification of Financial Assurance from Portland General Electric Company for 67.5%

Ownership 7-2 Certification of Financial Assurance from Eugene Water and Electric Board (EWEB) for 30% Ownership 7-3 Certification of Financial Assurance from PacifiCorp for 2.5% Ownership 7-1 Revision 2

TROJAN ISFSI PRELIMINA RY RADIOLOGICAL DECOMMISSIONING PLAN 8.0 RECORD KEEPING FOR DECOMMISSIONING Records of information important to the safe and effective decommissioning of the Trojan ISFSI will be maintained for the life of the ISFSI. The following documents will be maintained as records for radiological decommissioning:

Pursuant to 10 CFR 20.150 1(b) (Reference 2), if applicable, records from surveys describing the location and amount of subsurface residual radioactivity identified at the site will be kept with records important for radiological decommissioning and such records will be retained in accordance with 10 CFR 72.30(:f).

Pursuant to 10 CFR 72.30(:f), the Trojan ISFSI shall keep records of information important to the radiological decommissioning of the facility in an identified location until the site is released for unrestricted use. If records important to the radiological decommissioning of the facility are kept for other purposes, reference to these records and their locations may be used. Information important to decommissioning consists of the following:

( 1) Records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site. These records may be limited to instances when contamination remains after any cleanup procedures or when there is reasonable likelihood that contaminants may have spread to inaccessible areas as in the case of possible seepage into porous materials such as concrete. These records will include any known information on identification of involved nuclides, quantities, forms, and concentrations.

(2) As-built drawings and modifications of structures and equipment in restricted areas where radioactive materials are used and/or stored, and of locations of possible inaccessible contamination. If required drawings are referenced, each relevant document need not be indexed individually. If drawings are not available, the Trojan ISFSI will substitute appropriate records of available information concerning these areas and locations.

(3) A list contained in a single document and updated no less than every 2 years of the following:

(i) All areas designated and formerly designated as restricted areas as defined under 10 CFR 20.1003 ; and (ii) All areas outside of restricted areas that require documentation under 10 CFR 72.30(:f)(l).

(4) Records of the cost estimate performed for the radiological decommissioning funding plan and records of the funding method used for assuring funds are available for radiological decommissioning.

8-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN

9.0 REFERENCES

1. Code of Federal Regulations, Title 10, Part 20.1402, "Radiological Criteria for Unrestricted Use."

2. Code of Federal Regulations, Title 10, Part 20.1501 (b), "General" related to survey records.

3. Code of Federal Regulations, Title 10, Part 50.75, "Reporting and Recordkeeping for Decommissioning Planning."

4. Code of Federal Regulations, Title 10, Part 72.30, "Financial Assurance and Recordkeeping for Decommissioning."

5. Code of Federal Regulations, Title 10, Part 72.54, "Expiration and Termination of Licenses and Decommissioning of Sites and Separate Buildings or Outdoor Areas."

6. Code of Federal Regulations, Title 10, Part 72.130, "Criteria for Decommissioning."

7. Oregon Administrative Rule (OAR) 345-026-0370, "Standards for Council Approval of ISFSI Decommissioning Plan."

8. Holtec's FSAR, Revision 1, for the HI-STORM 100 Concrete Cask (Report HI-2002444).

9. NUREG/CR-5512, Volume 3, Residual Radioactive Contamination from Decommissioning, Parameter Analysis, Table 6.91, October 1999.

10. NUREG-1757, Volume 3, Revision 1, "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness."

11. Shielding Evaluation for the Trojan ISFSI Completion Project, HI-2012749, Revisions 5 and 6.

9-1 Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN APPENDIX 7-1 Certification of Financial Assurance from Portland General Electric Company for 67.5% Ownership Not included due to personnel unavailability associated with COVID-19/coronavirus workplace restrictions.

Will be provided in a separate mailing for insertion as Appendix 7 in PGE-1082 once Certifications of Financial Assurance are completed and signed.

Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN APPENDIX 7-2 Certification of Financial Assurance from Eugene Water and Electric Board (EWEB) for 30% Ownership - Enclosed Not included due to personnel unavailability associated with COVID-19/coronavirus workplace restrictions.

Will be provided in a separate mailing for insertion as Appendix 7 in PGE-1082 once Certifications of Financial Assurance are completed and signed.

Revision 2

TROJAN ISFSI PRELIMINARY RADIOLOGICAL DECOMMISSIONING PLAN APPENDIX 7-3 Certification of Financial Assurance from PacifiCorp for 2.5% Ownership - Enclosed Not included due to personnel unavailability associated with COVID-19/coronavirus workplace restrictions.

Will be provided in a separate mailing for insertion as Appendix 7 in PGE-1082 once Certifications of Financial Assurance are completed and signed.

Revision 2