ML21153A407

NR-3605-0006, Decommissioning Funding Plan for the American Centrifuge Plant

ML21153A407
Person / Time
Site:	07007004
Issue date:	10/31/2011
From:	American Centrifuge Operating
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML21152A073	List: ML21152A164 ML21153A407 ML21161A272
References
ACO 21-0027, EPID L-2020-LLA-0085, EPID L-2020-SPR-0009, NR-3605-0006 NR-3605-0006
Download: ML21153A407 (60)

Text

NR-3605-0006 Decommissioning Funding Plan for the American Centrifuge Plant in Piketon, Ohio ACPDOCUMENTCONTROL_

CONTROLLED COPY# SOD(o '8 Revision 14 Information contained within does not contain Docket No. 70-7004 Export Controlled Information October 2011 Reviewer: R.S. Lykowski Date: 10-20-11

Decommissioning Funding Plan for the American Centrifuge Plant Blank Page

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Decommissioning Funding Plan for the American Centrifuge Plant NR-3605-0006 DECOMMISSIONING FUNDING PLAN for the American Centrifuge Plant in Piketon, Ohio Docket No. 70-7004 Revision 14

Decommissioning Funding Plan for the American Centrifitge Plant Blank Page

Revision 14 Decommissioning Funding Plan for the American Centrifuge Plant UPDATED LIST OF EFFECTIVE PAGES Revision 0- 10 CFR 1045 review completed by L. Sparks on 07/29/04 and the Export Controlled Information review completed by R. Coriell on 07/30/04.

Revision I - 10 CFR 1045 review completed by L. Sparks on 03/07/05 and the Export Controlled Information review completed by R. Coriell on 03/10/05.

Revision 2 - IO CFR I045 review completed by J. Weidner on 05/23/05 and the Export Controlled Information review completed by R. Coriell on 05/23/05.

Revision 3 - 10 CFR 1045 review completed by J. Weidner on 06/21/05 and the Export Controlled Information review completed by D. Hupp on 06/21/05.

Revision 4 - 10 CFR I 045 review completed by J. Weidner on 08/30/05 and the Export Controlled Information review completed by D. Hupp on 08/30/05.

Revision 5 - IO CFR 1045 review completed by J. Weidner on 09/02/05 and the Export Controlled Information review completed by R. Coriell on 09/02/05.

Revision 6- 10 CFR I045 review completed by J. Weidner on 10/19/05 and the Export Controlled Information review completed by D. Hupp on 10/19/05.

Revision 7 - 10 CFR I045 review completed by J. Weidner on 11/22/05 and the Export Controlled Information review completed by D. Hupp on 11/22/05.

Revision 8 - 10 CFR I 045 review completed by J. Weidner on 03/17/06 and the Export Controlled Information review completed by D. Hupp on 03/16/06.

Revision 9 - IO CFR 1045 and Export Controlled Information reviews were completed by R. Coriell on 08/11/06.

Revision IO- 10 CFR 1045 and Export Controlled Information reviews were completed by M. Basham on 06/05/08.

Revision 11 - IO CFR 1045 and Export Controlled Information reviews were completed by R. S. Lykowski on 1/27/09.

Revision 12 - 10 CFR 1045 and Export Controlled Information reviews were completed by R.S. Lykowski on 4/22/10.

Revision 13 -- Reviewed and determined to be UNCLASSIFIED. Derivative Classifier R.S. Lykowski. Sensitive information reviews completed and approved for public release by R.S. Lykowski on 2/16/11.

Revision 14 -- Reviewed and determined to be UNCLASSIFIED. Derivative Classifier R.S. Lykowski. Sensitive information reviews completed and approved for public release by R.S. Lykowski on I 0/20/1 I.

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Decommissioning Funding Plan for the American Centriji,ge Plant Revision 14 Page Number Revision Number Page Number Revision Number Cover Page 14 B-11 8 Inside Cover Page 14 B-12 8 ULOEP-1 14 C-1 12 ULOEP-2 14 C-2 12 12 C-3 13 ii 12 C-4 14 1 12 C-5 12 2 12 C-6 12 3 12 C-7 14 4 12 C-8 12 5 12 C-9 12 6 11 C-10 12 7 11 C-11 12 8 11 C-12 12 A-I 8 C-13 12 A-2 8 C-14 12 A-3 8 C-15 12 A-4 8 C-16 12 A-5 8 C-17 14 A-6 8 C-18 12 B-1 8 C-19 12 B-2 8 C-20 12 B-3 8 C-21 14 B-4 8 C-22 12 B-5 8 C-23 12 B-6 8 C-24 12 B-7 8 C-25 12 B-8 8 C-26 12 B-9 8 D-1 12 B-10 8 D-2 12 D-3 12 D-4 12 ULOEP-2

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 TABLE OF CONTENTS 1.0 Introduction .............................................................................................................................. I 2.0 General Information ................................................................................................................. I 3.0 Decommissioning Cost Estimate ............................................................................................. 2 4.0 Decommissioning Funding Mechanism .................................................................................. 5 5.0 Adjusting Decommissioning Costs and Funding ..................................................................... 6 6.0 Record Keeping Plans Related to Decommissioning Funding ................................................ 6 APPENDICES APPENDIX A Model Payment Surety Bond ............................ :............................................ A-1 APPENDIX B Model Standby Trust Agreement .................................................................... B-1 APPENDIX C Decommissioning Cost Estimate Tables ......................................................... C-1 Table C3.4 Facility Description Summary ............................................................................ C-3 Table C3.4A Quantities of Materials or Waste Accumulated Before Shipping or Disposal.. .. C-4 Table C3.5 Number and Dimensions of Facility Components (Total Volume) .................... C-5 Table C3.5A Number and Dimensions of Facility Components (Total Area) ......................... C-9 Table C3.6 Planning and Preparation (Productive Work Days) .......................................... C-11 Table C3.7 Decontamination or Dismantling of Radioactive Facility Components ........... C-12 Table C3.8 Restoration of Contaminated Areas on Facility Grounds (Productive Work Days) ...................................................................................................... C-13 Table C3.9 Final Radiation Survey (Productive Work Days) ............................................. C-14 Table C3.10 Site Stabilization and Long-Term Surveillance (Productive Work Days) ........ C-15 Table C3.l l Total Work Days by Labor Category ................................................................ C-16 Table C3.14 Packaging, Shipping, and Disposal ofRadioactive Wastes ............................. C-17 Table C3.15 Equipment/Supply Costs ................................................................................... C-18 Table C3 .16 Laboratory Costs ............................................................................................... C-19 Table C3.17 Miscellaneous Costs .......................................................................................... C-20 Table C3.18 Total Decommissioning Costs .......................................................................... C-21 Table C3 .18A Total Incremental Decommissioning Costs .................................................... C-22 Table C3.19 Estimated Volume of Annual Depleted Uranium Generated ............................ C-23 Table C3.19A Estimated Incremental Machine Disposal Cost .............................................. C-24 Table C3.20 Table Labor Distribution ...................................................................................C-25 APPENDIX D Decommissioning Cost Estimate Tables (Proprietary) .................................. D-1 Table D3.12 Worker Unit Cost Schedule ............................................................................... D-3 Table D3.13 Total Labor Costs by Major Decommissioning Task ........................................ D-4

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Blank Page ii

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12

1.0 INTRODUCTION

The Licensee hereby submits, pursuant to the provisions of the Atomic Energy Act of 1954, as amended, and the rules and regulations of the U.S. Nuclear Regulatory Commission -

(NRC), its Decommissioning Funding Plan (DFP) for the American Centrifuge Plant (ACP) in Piketon, Ohio. This DFP sets forth the information required by 10 Code of Federal Regulations (CFR) Part 70 regarding the Licensee's plans for funding the decommissioning of the ACP and disposal of depleted uranium generated as a result of ACP operations.

As indicated below, the Licensee presently intends to provide for decommissioning funding through a surety bond in accordance with applicable requirements of 10 CFR Part 70.

However, the Licensee may choose to utilize alternate financial assurance funding methods.

Alternate funding methods, if chosen, will be prepared using the guidance provided in NUREG 1757, Volume 3, Appendix A and will satisfy the requirements of 10 CFR Part 70. The actual funding method to be used will be executed prior to the commencement of enrichment operations. In the interim, appropriate model documentation for this funding method is provided in Appendix A and B of this plan. Upon execution of the funding instruments, the Licensee will supplement this portion of its application.

2.0 GENERAL INFORMATION Plant

Description:

The ACP is located in the U.S. Department of Energy (DOE) reservation in Piketon, Ohio, in areas and facilities leased from the DOE. 1 The ACP encompasses the construction, start-up, operation, and maintenance of a uranium enrichment process using American Centrifuge technology that will produce 3.8 million separative work units (SWU) annually at full capacity. Chapter 1.0 of the License Application for the American Centrifuge Plant provides a description of the various facilities associated with the ACP.

Licensed Material: The NRC granted a license to construct and operate a uranium enrichment plant to enrich uranium hexafluoride (UF6) using centrifuge technology. Uranium enriched in the 235 0 isotope up to the licensed limit of 10 weight percent 235 0 will be withdrawn and shipped from the plant. Material depleted in the 235 0 isotope (UF6 tails) will also be withdrawn and stored on site. At full capacity, the ACP generates approximately 8,400 Metric Tons (MT) ofUF6 tails annually. Therefore, pursuant to 10 CFR 70.25(a), a DFP is required.

Schedule: Construction of the ACP commenced following issuance of the license by the NRC. Based on the unique modular aspects of the centrifuge technology, capacity is brought on line -in phases.

1 Details regarding the planned operations of the ACP may be found in the License Application and the accompanying Environmental Report.

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Period of Operation: Construction activities began at the ACP following receipt of the Material License SNM-2011. The materials license provides the expiration date for the license.

Decommissioning Costs: The Licensee has prepared a site-specific decommissioning cost estimate for the decommissioning of the ACP and disposal of the UF6 tails. This cost estimate utilizes current information regarding the activities and associated costs of decommissioning the 3.8 million SWU plant.

The estimate and associated funding mechanisms will be adjusted over time, in accordance with the applicable provisions of 10 CPR Part 70 as described in Section 5.0 of this plan.

Decommissioning Funding: As set forth in this DFP, the Licensee presently intends to utilize a surety bond to provide reasonable assurance of the availability of decommissioning funds when needed. This funding mechanism is intended to satisfy the provisions of 10 CPR Part 70 with respect to decommissioning financial assurance for license applicants. However, as described in .Section 1.0 of this plan, the Licensee may choose to utilize alternate financial assurance funding methods. As described in Section 10.10.4 of the License Application for the American Centrifuge Plant, the financial assurance for a portion of the decommissioning costs to include the disposition of centrifuge machines and UF6 tails will be provided incrementally as centrifuges are built/installed and UF6 tails generated. Full funding for decommissioning of the facilities will be provided in the initial executed financial assurance instrument. In this way, financial assurance will be made available as the decommissioning liability is incurred.

3.0 DECOMMISSIONING COST ESTIMATE Pursuant to 10 CPR 70.25(e) and the guidance provided by the NRC in NUREG-1757, Consolidated NMSS Decommissioning Guidance, the Licensee has evaluated the estimated costs of decommissioning the ACP. These estimated costs involve plant decommissioning costs and tails disposal costs. The plant will be decommissioned such that the facilities may be released for unrestricted use. The estimated costs for decommissioning are patterned after NRC guidance in Appendix A of NUREG-1757 Volume 3, as set forth in the tables contained in Appendix C and D of this DFP and noted below (Note: To maintain consistent table sequence numbers with those presented in NUREG-1757, Appendix A, Tables 3.1 through 3.3 are not used):

Facility Description Summary (Table C3.4 and Table C3.4A)

Number and Dimensions of Facility Components (Table C3.5 and Table C3.5A)

Planning and Preparation (Table C3.6)

Decontamination or Dismantling of Radioactive Facility Components (Table C3.7)

Restoration of Contaminated Areas on Facility Grounds (Table C3.~)

Final Radiation Survey (Table C3.9) 2

Decommissioning Funding Plan for the American Centriji,ge Plant Revision 12

• Site Stabilization and Long-Term Surveillance (Table C3.10)

• Total Work Days by Labor Category (Table C3.1 I)

• Worker Unit Cost Schedule (Table D3.12)

• Total Labor Costs by Major Decommissioning Task (Table D3.13)

• Packaging, Shipping, and Disposal of Radioactive Wastes (Table C3.14)

• Equipment/Supply Costs (Table C3.15)

• Laboratory Costs (Table C3.16)

• Miscellaneous Costs (Table C3 .17)

• Total Decommissioning Costs (Table C3.18)

• Total Incremental Decommissioning Costs (Table C3.18A)

• Estimated Volume of Annual Depleted Uranium Generated (Table C3.19)

• Estimated Incremental Machine Disposal Cost (Table C3.19A)

• Total Labor Distribution (Table C3.20)

Chapter 10.0 of the License Application for the American Centrifuge Plant describes specific features that serve to minimize the level and spread of radioactive contamination during operation that simplify the eventual plant decommissioning and minimize worker exposure. The decommissioning estimated costs _are based on decontaminating the plant to the radiological criteria for unrestricted use in 10 CFR 20.1402. The total estimated cost of plant decommissioning in 2008 dollars, excluding tails disposition costs, is $377.3 million (Table C3.18).

The following assumptions are utilized in the decommissioning cost estimate:

• No credit is taken for salvage value of equipment or materials;

• Inventories of materials and wastes at the time of decommissioning will be in amounts that are consistent with routine plant conditions and operations over the 30-year license;

• Decommissioning activities take place immediately on cessation of operations without multiyear storage-for-decay periods.

Cost estimates to dispose of UF6 tails generated during ACP operation are presented in Table C3.19. The ultimate disposal of UF6 tails is to be determined. The Licensee intends to evaluate possible commercial uses of UF6 tails. UF6 tails, which are not commercially reused, will be converted to a stable form and disposed of in accordance with the USEC Privatization Act and other applicable statutory authorizations and requirements at DOE's DUF6 conversion facilities and/or other licensed facilities. UF6 tails are stored in steel cylinders until they can be 3

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 processed in accordance with the disposal strategy established and selected by the Licensee.

Depending on technological developments and the existence of facilities available prior to ACP shutdown, the tails may have commercial value and may be marketable for further enrichment or other processes. However, for the purposes of calculating the UF6 tails disposition costs, the Licensee assumes that the total quantity of tails generated during ACP operation are processed by the DOE DUF6 conversion facility in Piketon, Ohio.

The Licensee. provides financial assurance to incrementally fund the estimated cost of conversion and disposal of the UF6 tails inventory as it is generated during ACP operation. The estimated cost of conversion and disposal is based on the actual accumulated depleted uranium

• inventory and a conservative forecast of the amount of depleted uranium to be generated for the upcoming period of operation. This funding is in addition to the funding requirements for decommissioning the ACP as described above.

At full capacity, the ACP will generate approximately 8,400 MT of UF6 tails annually.

The Licensee estimates that it will take approximately four years for the ACP to ramp up to the full capacity of 3.8 million SWU per year.

Our examination of the available information has identified that the unit cost to dispose of tails (depleted uranium) for the ACP could range between $3.66/kilogram (kg) uranium (U) to

$4.95/kg U, depending on a number of factors and assumptions. The unknown factors include:

location(s) for processing depleted uranium, transportation costs, escalation rate(s) of various construction cost components; de-escalation rate(s) of future operating costs (to present day dollars); volume of tails disposed; revenue/avoided disposal cost from sale of conversion products (e.g., hydrogen fluoride) or higher assay tails (tail stripping); construction and operations budget contingencies; allocation of decontamination and decommissioning costs (between the Licensee and DOE); and DOE oversight costs.

The Licensee has developed the depleted uranium tails disposal cost estimate for the ACP based on a methodology and supporting data contained in a redacted report prepared by DOE's consultant, LMI 2

• This redacted report was provided by DOE 3

• Using the methodology and supporting data contained in the redacted LMI report, the Licensee prepared an analysis of the estimated depleted uranium disposal costs specific to the ACP. As documented in this analysis, the Licensee has developed a unit cost of $4.95/kg U for processing the ACP depleted uranium at the DOE's Portsmouth DUF6 Conversion Facility. Consistent with NRC guidance regarding decommissioning cost estimates, the estimated unit cost for depleted UF6 disposal does not assume any resale or reuse of any products resulting from the conversion process. The Licensee believes the unit cost of $4.95/kg U is a reasonable depleted uranium disposal unit cost for the purposes of ACP decommissioning funding and should be viewed as the conservative upper bound of the range mentioned. Based on the total estimated volume of depleted uranium generated over the 30-years of operation and the estimated cost for disposal, the Licensee's liability for disposal of depleted uranium is $717.6 million in 2008 dollars. With a 25 percent contingency, this represents a total liability of $896.9 million in 2008 dollars for 30-years of operation. Although a total liability is provided, the Licensee will incrementally fund the estimated costs associated with disposal of the depleted uranium inventory as the depleted uranium is generated during ACP operation.

2 LMI Government Consulting, Report DE523Tl, "An Analysis ofDOE's Cost to Dispose ofDUF 6," Revision I, July 2005 [Redacted January 31, 2006].

3 Mr. Larry W. Brown (DOE) letter to Mr. Phil Sewell (USEC), "Conversion and Disposal of Depleted Uranium Hexafluoride (DUF6) Generated by USEC at the American Centrifuge Plant in Piketon, Ohio," dated February 10, 2006.

4

Decommissioning Funding Plan/or the American Centrifi1ge Plant Revision J2 The Licensee's total decommissioning liability is the sum of the total plant decommissioning costs and the tails disposition costs. The Licensee's total liability for decommissioning the ACP, including applicable contingencies, is $1,274.2 million.

4.0 DECOMMISSIONING FUNDING

MECHANISM The Licensee presently intends to utilize a surety bond to provide reasonable assurance of decommissioning funding, pursuant to 10 CPR 70.25(£). Accordingly, the Licensee provides with this application model documentation related to the use of the surety method of providing decommissioning financial assurance. 4 However, as described in Section 1.0 of this plan, the Licensee may choose to utilize alternate financial assurance funding methods. Upon finalization of the specific funding instruments to be utilized and at least 90 days prior to the commencement of enrichment operations, the Licensee will supplement its application to include the signed, executed documentation.

As noted above, the Licensee presently intends to utilize a surety bond to provide financial assurance for decommissioning. The surety bond will provide an ultimate guarantee that decommissioning costs will be paid in the event the Licensee is unable to meet its decommissioning obligations at the time of decommissioning. A copy of a model surety bond is provided in Appendix A to this plan. The Licensee describes below the particular attributes it presently anticipates including in the surety bond.

With respect to the surety bond, the Licensee presently anticipates providing for the following attributes: First, a company that is listed as a qualified surety in the Department of Treasury's most recent edition of Circular 570 for the State where the surety was signed with an underwriting limitation greater than or equal to the level of coverage specified in the bond will issue the bond. Second, the bond will be written for a specified term and will be renewable automatically unless the issuer serves notice at least 90 days prior to expiration of intent not to renew. Such notice must be served upon the NRC, the trustee of the external or standby trust, and the Licensee. Further, in the event the Licensee is unable to provide an acceptable replacement within 30 days of such notice, the full amount of the bond will be payable automatically, prior to expiration, without proof of forfeiture.

The surety bond will require that the surety company will deposit any funds paid under its terms directly into either an external trust or a standby trust. A copy of a model standby trust is provided as Appendix B to this plan.

4 The model documentation is derived from Appendix A.9 in NUREG-1757 Volume 3, Consolidated NMSS Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, September 2003. The Licensee will consider this model documentation as guidance in preparing and executing funding instruments for the ACP. In the event the Licensee ultimately selects another form of decommissioning funding, model documentation from this volume of NUREG-1757 will also be used as guidance in the preparation of funding instruments.

5

Decommissioning Funding Plan for the American Centrifuge Plant Revision 11 5.0 ADJUSTING DECOMMISSIONING COSTS AND FUNDING Pursuant to 10 CFR 70.25(e), the Licensee will update the decommissioning cost estimate for the ACP and the financial assurance over the life of the plant. The modular aspect of the American Centrifuge technology allows enrichment operations to begin well before the full capacity of the plant is reached. Thus, the decommissioning liability for centrifuge machines and UF6 tails is incurred incrementally as more centrifuge machines, and associated equipment, are added to the process, until such time as full capacity of the facility (i.e., 3.8 million SWU) is achieved. Once full capacity of the facility is achieved, the UF6 tails are generated at a relatively constant rate throughout the life of the plant.

• Full funding for decommissioning of the facilities will be provided in the initial executed financial assurance instrument. To ensure adequate financial assurance is in place as centrifuge machines, and associated equipment, are added to the process and placed into operation, the Licensee will forecast and update the cost estimates and provide a revised funding instrument to NRC annually to cover the upcoming year of operation. This incremental funding approach will be utilized until operation at full capacity. Once full capacity of the facility is achieved, the Licensee will annually adjust the cost estimate for UF6 tails disposal and all other decommissioning costs will be adjusted periodically, and no less frequently than every three years, consistent with the requirements of 10 CFR 70.25(e) and the recent NRC final rule regarding financial assurance for materials licensees (68 FR 57327, October 3, 2003). The method for adjusting the cost estimate will consider the following:

Changes in general inflation (e.g., labor rates, consumer price index)

Changes in price of goods (e.g., packing materials)

Changes in price of services (e.g., shipping and disposal costs)

Changes in plant condition or operations Changes in decommissioning procequres or regulations A record of the updating effort and results will be retained for review (see further discussion regarding record keeping below).

6.0 RECORD KEEPING PLANS RELATED TO DECOMMISSIONING FUNDING Pursuant to 10 CFR 70.25(g), the Licensee will keep records of information that could have a material effect on the ultimate costs of decommissioning until termination of the license.

Information maintained in these records includes:

Records of spills or other unusual occurrences involving the spread of contamination in and around the plant, equipment, or site. Records of spills or other unusual 6

Decommissioning Funding Plan for the American Centrifuge Plant Revision 11 occurrences may be limited only 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 radionuclides, quantities, fonns, and concentrations; As-built drawings and modifications of structures and equipment in areas where radioactive materials are used and/or stored, including locations that possibly could be inaccessible (e.g., buried pipes which may be subject to contamination); and A list contained in a single document that is updated every two years of the following:

Areas designated and formerly designated as restricted areas as defined under 10 CFR 20.1003.

Areas outside of restricted areas that require documentation under 10 CFR 70.25(g)(l ).

Areas outside of restricted areas where current and previous wastes have been buried as documented under 10 CPR 20.2108.

Areas outside of restricted areas that contain material such that, if the license expired, the Licensee would be required to either decontaminate the area to meet the criteria for decommissioning in 10 CFR Part 20, Subpart E, or would apply for NRC approval for disposal under 10 CPR 20.2002.

Records of the cost estimate performed for the DFP, and records of the funding method used for assuring funds, including a copy of the financial assurance mechanism and any supporting documentation.

7

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DecommissioningFunding Plan for the American Centrifuge Plant Revision 8 Appendix A Model Payment Surety Bond A-I

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 PAYMENT SURETY BOND Date bond executed: - - - - - - - - - -

Effective date: - - - - - - - - - -

Principal: [Insert legal name and business address of licensee]

Type of organization: [Insert proprietorship, " partnership, " or" corporation"]

State of incorporation: _ _ _ _ _ _ _ (if applicable)

NRC license number, name and address of facility, and amount for decommissioning activities guaranteed by this bond: _ _ _ _ _ _ _ _ _ _ _ __

Surety: [Insert name and business address]

Type of organization: [Insert "proprietorship, " partnership, " or "corporation"]

State of incorporation: _ _ _ _ _ _ _ (if applicable)

Surety's qualification in jurisdiction where license facility is located.

Surety's bond number: - - - - - - - -

Total penal sum of bond: $_ _ _ _ __

Know all persons by these presents, that we, the Principal and Surety hereto, are firmly bound to the U.S. Nuclear Regulatory Commission (hereinafter called NRC) in the above penal sum for the payment of which we bind ourselves, our heirs, executors, administrators, successors, and assigns jointly and severally; provided that, where the Sureties are corporations acting as co-sureties, we, the Sureties, bind ourselves in such sum "jointly and severally" only for the purpose of allowing a joint action or actions against any or all of us, and for all other purposes each Surety binds itself, jointly and severally with the Principal, for the payment of such sum only as it is set forth opposite the name of such Surety; but if no limit of liability is indicated, the limit of liability shall be the full amount of the penal sum.

WHEREAS, the U.S. Nuclear Regulatory Commission, an agency of the U.S. Government, pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, has promulgated regulations in Title 10, Chapter I, of the Code of Federal Regulations, Part [insert 30, 40, 70, or 72], applicable to the Principal, which require that a license holder or an applicant for a facility license provide financial assurance that funds will be available when needed for facility decommissioning; A-2

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 NOW, THEREFORE, the conditions of the obligation are such that if the Principal shall faithfully, before the beginning of decommissioning of each facility identified above, fund the standby trust fund in the amount(s) identified above for the facility; Or, if the Principal shall fund the standby trust fund in such amount(s) after an order to begin facility decommissioning is issued by NRC or a U.S. District Court or other court of competent jurisdiction; Or, if the Principal shall provide alternative financial assurance, and obtain NRC's written approval of such assurance, within 30 days after the date a notice of cancellation from the Surety is received by both the Principal and NRC, then this obligation shall be null and void; otherwise it is to remain in full force and effect.

The Surety shall become liable on this bond obligation only when the Principal has failed to fulfill the conditions described above. Upon notification by NRC that the Principal has failed to perform as guaranteed by this bond, the Surety shall place funds in the amount guaranteed for the facility into the standby trust fund.

The liability of the Surety shall not be discharged by any payment or succession of payments hereunder, unless and until such payment or payments shall amount in the aggregate to the penal sum of the bond, but in no event shall the obligations of the Surety hereunder exceed the amount of said penal sum.

The Surety may cancel the bond by sending notice of cancellation by certified mail to the Principal and to NRC provided, however, that cancellation shall not occur during the 90 days beginning on the date of receipt of the notice of cancellation by both the Principal and NRC, as evidenced by the return receipts.

The Principal may terminate this bond by sending written notice to NRC and to the Surety 90 days prior to the proposed date of termination, provided, however, that no such notice shall become effective until the Surety receives written authorization for termination of the bond from NRC.

The Principal and Surety hereby agree to adjust the penal sum of the bond yearly so that it guarantees a new amount, provided that the penal sum does not increase by more than 20 percent in any one year and no decrease in the penal sum takes place without the written permission of NRC.

If any part of this agreement is invalid, it shall not affect the remaining provisions that will remain valid and enforceable.

A-3

Decommissioning Funding Plan for the American Centrifugf! Plant Revision 8 In Witness Whereof, the Principal and Surety have executed this financial guarantee bond and have affixed their seals on the date set forth above.

The persons whose signatures appear below hereby certify that they are authorized to execute this surety bond on behalf of the Principal and Surety.

Principal

[Signatures]

[Names]

[Titles]

[Corporate Seal]

Corporate Surety

[Name and address]

State of Incorporation: _ _ _ _ _ _ _ _ __

Liability limit: $- - - - - - - - -

[Signatures]

[Names and titles]

[Corporate Seal]

[For every co-surety, provide signatures, names and titles, corporate seal, and other information in the same manner as for the Sureties above].

Bond Premium: $- - - - - - -

A-4

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Model Certification of Financial Assurance CERTIFICATION OF FINANCIAL ASSURANCE Principal: [Legal names and and business address of licensee]

NRC license number, name and address of the facility Issued to: U.S. Nuclear Regulatory Commission I certify that [insert name of licensee] is licensed to possess the following types of [insert all that apply: "sealed sources or plated foils with a half-life great than 120 days licensed under 10 CFR Part 30, " "unsealed byproduct material with a half-life greater than 120 days licensed under 10 CFR Part 30, " "source material in a readily dispersible form licensed under 10 CFR Part 40, " and "unsealed special nuclear material licensed under 10 CFR Part 70 "] in the following amounts:

Type of Material Amount of Material

[List materials and quantities of materials noted above. For byproduct materials and special nuclear materials, list separately the type and amount of each isotope authorized by the license.]

I also certify that financial assurance in the amount of [insert the total of all prescribed amounts calculated from Checklist 2, or the amount of the site-specific cost estimate, in US dollars] has been obtained for the purpose of decommissioning as prescribed by 10 CFR Part [insert 30, 40, or 70].

[Signatures and titles ofofficials of institution]

[Corporate seal]

[Date]

A-5

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Blank Page A-6

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Appendix B Model Standby Trust Agreement B-1

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 STANDBY TRUST AGREEMENT TRUST AGREEMENT, the Agreement entered into as of [insert date] by and between [insert name of licensee], a [insert name of State] [insert "corporation, " partnership, " or

proprietorship"], herein referred to as the "Grantor," and [insert name and address of a trustee acceptable to NRC], the "Trustee."

WHEREAS, the U.S. Nuclear Regulatory Commission (NRC), an agency of the U. S.

Government, pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, has promulgated regulations in Title 10, Chapter I of the Code of Federal Regulations, Part [insert 30, 40, 70, 72]. These regulations, applicable to the Grantor, require that a holder of, or an applicant for, a materials license pursuant to 10 CPR Part [insert 30, 40, 70, or 72] provide assurance that funds will be available when needed for required decommissioning activities.

WHEREAS, the Grantor has elected to use a [insert "letter of credit," "line of credit," "surety bond, " "insurance policy, " "parent company guarantee, " or "self-guarantee"], to provide

[insert "all" or part"] of such financial assurance for the facilities identified herein; and WHEREAS, when payment is made under a [insert "letter of credit, "line of credit," "surety bond, " insurance policy, " parent company guarantee, " or "self-guarantee"], this standby trust shall be used for the receipt of such payment; and WHEREAS, the Grantor, acting through its duly authorized officers, has selected the Trustee to be the trustee under this Agreement, and the Trustee is willing to act as trustee; NOW, THEREFORE, the Grantor and the Trustee agree as follows:

Section 1. Definitions. As used in this Agreement:

(a) The term "Grantor" means NRC licensee who enters into this Agreement and any successors or assigns of the Grantor.

(b) The term "Trustee" means the trustee who enters into this Agreement and any successor Trustee.

• Section 2. Costs of Decommissioning. This Agreement pertains to the costs of decommissioning the materials and activities identified in License Number Iinsert license number} issued pursuant to 10 CPR Part [insert 30, 40, 70, 72], as shown in Schedule A.

Section 3. Establishment of Fund. The Grantor and the Trustee hereby establish a standby trust fund (the Fund) for the benefit of NRC. The Grantor and the Trustee intend that no third party have access to the Fund except as provided herein.

Section 4. Payments Constituting the Fund. Payments made to the Trustee for the Fund shall consist of cash, securities, or other liquid assets acceptable to the Trustee. The Fund is established initially as consisting of the property, which is acceptable to the Trustee, described in B-2

Decommissioning Funding Plan for the American Centri.fi1ge Plant Revision 8 Schedule B attached hereto. Such property and any other property subsequently transferred to the Trustee are referred to as the "Fund," together with all earnings and profits thereon, less any payments or distributions made by the Trustee pursuant to this Agreement. The Fund shall be held by the Trustee, IN TRUST, as hereinafter provided. The Trustee shall not be responsible nor shall it undertake any responsibility for the amount of, or adequacy of the Fund, nor any duty to collect from the Grantor, any payments necessary to discharge any liabilities of the Grantor established by NRC.

Section 5. Payment for Required Activities Specified in the Plan. The Trustee shall make payments from the Fund to the Grantor upon presentation to the Trustee of the following:

(a) A certificate duly executed by the Secretary of the Grantor attesting to the occurrence of the events, and in the form set forth in the attached Certificate of Events, and (b) A certificate attesting to the following conditions; (1) that decommissioning is proceeding pursuant to an NRC-approved plan; (2) that the funds withdrawn will be expended for activities undertaken pursuant to that plan; and (3) that NRC has been given 30 days prior notice of[insert name of licensee]'s intent to withdraw funds from the escrow fund.

No withdrawal from the Fund for a particular license can exceed 10 percent of the remaining funds available for that license unless NRC written approval is attached.

In addition, the. Trustee shall make payments from the Fund as NRC shall direct, in writing, to provide for the payment of the costs of required activities covered by this Agreement. The*

Trustee shall reimburse the Grantor or other persons as specified by NRC from the Fund for expenditures for required activities in such amounts as NRC shall direct in writing. In addition, the Trustee shall refund to the Grantor such amounts as NRC specifies in writing. Upon refund, such funds shall no longer constitute part of the Fund as defined herein.

Section 6. Trust Management. The Trustee shall invest and reinvest the principal and income of the Fund and keep the Fund invested as a single fund, without distinction between principal and income, in accordance with general investment policies and guidelines which the Grantor may cqmmunicate in writing to th.e Trustee from time to tim~, subject, however, to the p,rovisions of this section. In investing, reinvesting, exchanging, selling, and managing the Fund, the Trustee shall discharge its duties with respect to the Fund solely in the interest of the beneficiary and with the care, skill, prudence, and diligence under the circumstances then prevailing which persons of prudence, acting in a like capacity and familiar with such matters, would use in the conduct of an enterprise of a like character and which like aims; except that:

(a) Securities or other obligations of the Grantor, or any other owner or operator of the facilities, or any of their affiliates as defined in the Investment Company Act of 1940, as amended (15 U.S.C. 80a-2(a)), shall not be acquired or held, unless they are securities or 8-3

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 other obligations of the Federal or a State government; (b) The Trustee is authorized to invest the Fund in time or demand deposits of the Trustee, to the extent insured by an agency of the Federal government, and in obligations of the Federal government such as GNMA, FNMA, and FHLM bonds and certificates or State and Municipal bonds rated BBB or higher by Standard & Poor's or Baa or higher by Moody's Investment Services; and (c) For a reasonable time, not to exceed 60 days, the Trustee is authorized to hold uninvested cash, awaiting investment or distribution, without liability for the payment of interest thereon.

Section 7. Commingling and Investment. The Trustee is expressly authorized in its discretion:

(a) To transfer from time to time any or all of the assets of the Fund to any common, commingled, or collective trust fund created by the Trustee in which the Fund is eligible to participate, subject to all of the provisions thereof, to be commingled with the assets of other trusts participating therein; and (b) To purchase shares in any investment company registered under the Investment Company Act of 1940 (15 U.S.C. 80a-1 et seq.), including one that may be created, managed, underwritten, or to which investment advice is rendered, or the shares of which are sold by the Trustee. The Trustee may vote such shares in its discretion.

Section 8. Express Powers of Trustee. Without in any way limiting the powers and discretion conferred upon the Trustee by the other provisions of this Agreement or br law, the Trustee is expressly authorized and empowered; (a) To sell, exchange, convey, transfer, or otherwise dispose of any property held by it, by public or private sale, as necessary to allow duly authorized withdrawals at the joint request of the Grantor and NRC or to reinvest in securities at the direction of the Grantor; (b) To make, execute, acknowledge, and deliver any and all documents of transfer and conveyance and any and all other instruments that may be necessary or appropriate to carry out the powers herein granted; (c) To register any securities held in the Fund in its own name, or in the name of a nominee, and to hold any security in bearer form or in book entry, or to combine certificates.

representing such securities with certificates of the same issue held by the Trustee in other fiduciary capacities, to reinvest interest payments and funds from matured and redeemed instruments, to file proper forms concerning securities held in the Fund in a timely fashion with appropriate government agencies, or to deposit or arrange for the deposit of such securities in a qualified central depository even though, when so deposited, such securities may be merged and held in bulk in the name of the nominee or such depository with other securities deposited therein by another person, or to deposit or aiTange for the deposit of any securities issued by the U.S. Government, or any agency or instrumentality thereof, with a Federal Reserve Bank, but the books and records of the B-4

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Trustee shall at all times show that all such securities are part of the Fund; (d) To deposit any cash in the Fund in interest-bearing accounts maintained or savings certificates issued by the Trustee, in its separate corporate capacity, or in any other banking institution affiliated with the Trustee, to the extent insured by an agency of the Federal government; and (e) To compromise or otherwise adjust all claims in favor of or against the Fund.

Section 9. Taxes and Expenses. All taxes of any kind that may be assessed or levied against or in respect of the Fund and all brokerage commissions incurred by the Fund shall be paid from the Fund. All other expenses incurred by the Trustee in connection with the administration of this Trust, including fees for legal services rendered to the Trustee, the compensation of the Trustee to the extent not paid directly by the Grantor, and all other proper charges and disbursements of the Trustee shall be paid from the Fund.

Section 10. Annual Valuation. After payment has been made into this standby trust fund, the Trustee shall annually, at least 30 days before the anniversary date of receipt of payment into the standby trust fund, furnish to the Grantor and to NRC a statement confirming the value of the Trust. Any securities in the Fund shall be valued at market value as of no more than 60 days before the anniversary date of the establishment of the Fund. The failure of the Grantor to object in writing to the Trustee within 90 days after the statement has been furnished to the Grantor and NRC shall constitute a conclusively binding assent by the Grantor, barring the grantor from asserting any claim or liability against the Trustee with respect to the matters disclosed in the statement.

Section 11. Advice of Counsel. The Trustee may from time to time consult with counsel with respect to any question arising as to the construction of this Agreement or any action to be taken hereunder. The Trustee shall be fully protected, to the extent permitted by law, in acting on the advice of counsel.

Section 12. Trustee Compensation. The Trustee shall be entitled to reasonable compensation for its services as agreed upon the writing with the Grantor. (See Schedule C).

Section 13. Successor Trustee. Upon 90 days notice to NRC and the Grantor, the Trustee may resign; upon 90 days notice to NRC and the Trustee, the Grantor may replace the Trustee; but such resignation or replacement shall not be effective until the Grantor has appointed a successor Trustee, the successor accepts the appointment, the successor is ready to assume its duties as Trustee, and NRC has agreed, in writing, that the successor is an appropriate Federal or State government agency or an entity that has the authority to act as a trustee and whose trust operations are regulated and examined by a Federal or State agency. The successor Trustee shall have the same powers and duties as those conferred upon the Trustee hereunder. When the resignation or replacement is effective, the Trustee shall assign, transfer, and pay over to the successor Trustee the funds and properties then constituting the Fund. If for any reason the Grantor cannot or does not act in the event of the resignation of the Trustee, the Trustee may apply to a court of competent jurisdiction for the appointment of a successor Trustee or for instructions. The successor Trustee shall specify the date on which it assumes administration of 8-5

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 the trust, in a writing sent to the Grantor, NRC, and the present Trustee, by certified mail 10 days before such change becomes effective. Any expenses incurred by the Trustee as a result of any of the acts contemplated by this section shall be paid as provided in Section 9.

Section 14. Instructions to the Trustee. All orders, requests, and instructions by the Grantor to the Trustee shall be in writing, signed by such persons as are signatories to this Agreement or such other designees as the Grantor may designate in writing. The Trustee shall be fully protected in acting without inquiry in accordance with the Grantor's orders, requests, and instructions. If NRC issues orders, requests, or instructions to the Trustee these shall be in writing, signed by NRC or its designees, and the Trustee shall act and shall be fully protected in acting in accordance with such orders, requests, and instructions. The Trustee shall have the right to assume, in the absence of written notice to the contrary, that no event constituting a change or a termination of the authority of any person to act on behalf of the Grantor or NRC hereunder has occurred. The Trustee shall have no duty to act in the absence of such orders, requests, and instructions from the Grantor and/or NRC, except as provided for herein.

Section 15. Amendment of Agreement. The Agreement may be amended by an instrument in writing executed by the Grantor, the Trustee, and NRC, or by the Trustee and NRC if the Grantor ceases to exist. All amendments shall meet the relevant regulatory requirements of NRC.

Section 16. Irrevocability and Termination. Subject to the right of the parties to amend this Agreement as provided in Section 15, this trust shall be irrevocable and shall continue until terminated at the written agreement of the Grantor, the Trustee, and NRC, or by the Trustee and NRC if the Grantor ceases to exist. Upon termination of the trust, all remaining trust property, less final trust administration expenses, shall be delivered to the Grantor or its successor.

Section 17. Immunity and Indemnification. The Trustee shall not incur personal liability of any nature in connection with and act or omission, made in good faith, in the administration of this trust, or in carrying out any directions by the Grantor or NRC issued in accordance with this Agreement. The Trustee shall be indemnified and saved harmless by the Grantor or from the

• trust fund, or both, from and against any personal liability to which the Trustee may be subjected by reason of any act or conduct in its official capacity, including all expenses reasonably incurred in its defense in the event the Grantor fails to provide such defense.

Section 18. This Agreement shall be administered, construed, and enforced according to the laws of the State of [insert name of State].

Section 19. Interpretation and Severability. As used in this Agreement, words in the singular include the plural and words in the plural include the singular. The descriptive headings for each section of this Agreement shall not affect the interpretation or the legal efficacy of this Agreement. If any part of this agreement is invalid, it shall not affect the remaining provisions which will remain valid and enforceable.

IN WITNESS WHEREOF the parties have caused this Agreement to be executed by the respective officers duly authorized and the incorporate seals to be hereunto affixed and attested as of the date first written above.

B-6

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8

[Insert name of licensee (Grantor)]

[Signature of representative of Grantor]

[Title]

ATTEST:

[Title]

[Seal]

[Insert name and address of TrusteeJ

[Signature of representative of Trustee]

[Title]

ATTEST:

[Title]

[Seal]

B-7

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Schedule A This Agreement demonstrates financial assurance for the following cost estimates or prescribed amounts for the following licensed activities:

COST ESTIMATES FOR U.S. NUCLEAR REGULATORY REGULATORY NAMEAND ADDRESS OF ASSURANCES COMMISSION ADDRESS OF LICENSED DEMONSTRATED BY LICENSE NUMBER(S) LICENSEE ACTIVITY THIS AGREEMENT The cost estimates listed here were last adjusted and approved by NRC on [insert date].

Schedule B DOLLAR AMOUNT - - - - - -

AS EVIDENCED BY - - - - - - - - -

Schedule C

[Insert name, address, and phone number ofTrustee.]

Trustee's fees shall be$_ _ _ _ _ _ _ _ _ _ _ per year.

B-8

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Model Specimen Certificate of Events

[Insert name and address of trustee]

Attention: Trust Division Gentlemen:

In accordance with the terms of this Agreement with you dated _ _ _ _ _, I, _ _ _ _ __

Secretary of [insert name of licensee], hereby certify that the following events have occurred:

l. [Insert name of licensee] is required to commence the decommissioning of its facility located at [insert location offacility] (hereinafter called the decommissioning).

2. The plans and procedures for the commencement and conduct of the decommissioning have been approved by the United States Nuclear Regulatory Commission, or its successor, on _ _ _ _ (copy of approval attached).

3. The Board of Directors of [insert name of licensee] has adopted the attached resolution authorizing the commencement of the decommissioning.

Secretary of [insert name of licensee]

Date B-9

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Model Specimen Certificate of Resolution I, _ _ _ _ _ _ _ _ _ _ _ , do hereby certify that I am Secretary of [insert name of licensee], a [insert State of incorporation] corporation, and that the resolution listed below was duly adopted at a meeting of this Corporation's Board of Directors on 20 IN WITNESS WHEREOF, I have hereunto signed my name and affixed the seal of this Corporation this _____ day of _ _ _ _ _ , 20_ __

Secretary RESOLVED, that this Board of Directors hereby authorizes the President, or such other employee of the Company as he may designate, to commence decommissioning activities at

[insert name offacility] in accordance with the terms and conditions described to this Board of Directors at this meeting and with such other terms and conditions as the President shall approve with and upon the advice of Counsel.

B-10

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Model Letter of Acknowledgment STATE OF - - - - - - - - - - - - - -

To Wit:

CITY OF On this_day of _ _ _ _, before me, a notary public in and for the city and State aforesaid, personally appeared and she/he did depose and say that she/he is the [insert title] of

_ _ _ _ _ _ _ _ _ _ [if applicable, insert ",national banking association" or ", State banking association"],

Trustee, which executed the above instrument; that she/he knows the seal of said association; that the seal affixed to such instrument is such corporate seal; that it was so affixed by order of the association; and that she/he signed her/his name thereto by like order.

[Signature of notary public]

My Commission Expires: _ _ _ _ _ _ __

[Date]

B-11

Decommissioning Funding Plan for the American Centrifuge Plant Revision 8 Model Power of Attorney

[Insert Name of Issuing Company]

Principal Bond Office: [Insert Business Address of Issuing Company]

KNOW ALL MEN BY THESE PRESENTS:

That [Insert Name of Issuing Company] does hereby appoint Insert Names ofAttorney(s)-in-Fact its true and lawful Attorney(s)-in-Fact, with full authority to execute on its behalf bonds, undertakings, recognizances and other contracts of indemnity and writings obligatory in the nature thereof, issued in the course of its business, and to bind the respective company thereby.

IN WITNESS WHEREOF, [Insert Name ofIssuing Company] have executed these presents

[Affix Company Seal] this [Insert Date] day of [Insert Month/Year]

[Insert Name of Company Official/Title]

STATE OF [Insert State] }

COUNTY OF [Insert Counry] }ss.

On this [Insert Date] day of[Insert Month], 200[Insert Year],

before me came the above named officer of [Insert Issuing Company], to me personally known to be the individual and officer described herein, and acknowledged that he executed the foregoing instrument and affixed the seals of said corporations thereto by

[Insert Notary Name] Notary authority of his office.

CERTIFICATE Excerpts of Resolutions adopted by the Boards of Directors of [Insert Issuing Company Name] on [Insert Date of Resolutions]:

"RESOLVED, that the Chairman of the Board, the President, or any Vice President be, and hereby is, authorized to appoint Attorneys-in-Fact to represent and act for and on behalf of the Company to execute bonds, undertakings, recognizances and other contracts of indemnity and writings obligatory in the nature thereof, and to attach thereto the corporate seal of the Company, in the transaction of its surety business; "RESOLVED, that the signatures and attestations of such officers and the seal of the Company may be affixed to any such Power of Attorney or to any certificate relating thereto by facsimile, and any such Power of Attorney or Certificate bearing such facsimile signatures or facsimile seal shall be valid and binding upon the Company when so affixed with respect to any bond, undertaking, recognizance or other contract of indemnity or writing obligatory in the nature thereof; "RESOLVED, that any such Attorney-in-Fact delivering a secretarial certification that the foregoing resolutions still be in effect may insert in such certification the date thereof, said date to be not later than the date of delivery thereof by such Attorney-in-Fact."

I, [Insert Name], Secretary of [Insert Name of Issuing Company] do hereby certify that the foregoing excerpts of Resolutions adopted by the Boards of Directors of this corporation, and the Powers of Attorney issued pursuant thereto, are true and correct, and that both the Resolutions and the Powers of Attorney are in full force and effect.

IN WITNESS WHEROF, I have hereunto set my hand and affixed the facsimile seal of each corporation

[Affix Company Seal] this [Insert Date] day of [Insert Month/Year]

[Name of Issuing Company] Secretary B-12

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 APPENDIX C DECOMMISSIONING COST ESTIMATE TABLES C-1

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Blank Page C-2

Revision 13 Decommissioning Funding Plan for the American Centrifuge Plant Table C3.4 Facility Description Summary NRC license Numbers and Types (i.e., Part 30, 40, 70, or 72)

- 10 CFR Part 70 - To construct and operate a uranium enrichment facility Types and Quantities of Materials Authorized Under the Licenses Listed Above

- 300,000 Metric Tons ofUF6 (Uranium Hexafluoride)

Description of How Licensed Materials Are Used

- Uranium is fed to the plant, where it is enriched to the desired mu assay. The enriched product is withdrawn and transferred to customer cylinders. The enriched product is shipped to fuel fabricators for further processing and will ultimately be used to generate electricity in nuclear power plants around the world. Tails (uranium depleted in mu isotope) will be stored on-site without undue risk.

Final disposition of depleted material will be determined pending a future evaluation of the number of existing and potential uses for this material.

Description of Facility, Including Buildings, Rooms, Grounds, and Description of Where Particular Types of Materials Are Used X-3001 and X-3002 Process Buildings - Buildings that house the centrifuge machines and auxiliary process equipment.

X-3012 Process Support Building - Area that houses the Area Control Room, maintenance shops and stores, and other support areas.

X-3344 Customer Services Building -Area that houses the equipment necessary to liquid sample UF6 cylinders.

X-3346 Feed and Withdrawal Building - Area that house the equipment necessary to supply UF6 to the process buildings and to withdraw UF6 from the process buildings in its enriched and depleted concentrations and the equipment to blend and transfer product material into customer cylinders. This facility utilizes previously existing and refurbished gaseous diffusion plant (GDP) equipment.

X-3346A Feed and Product Shipping and Receiving Building - Area that houses the equipment necessary to receive UF6 feed material from previous process manufacturers and to ship UF 6 product material to customers, as well as shipping empty feed cylinders.

X-6002 Boiler Building -A building that houses the equipment necessary to supply Recirculating Heating Water (RHW) to requisite buildings on the centrifuge plant site.

X-7725 Recycle/Assembly (RIA) Facility -A large, multiple level building where material and components are shipped, received, stored components or subassemblies are inspected or tested, and centrifuge machines are assembled and a statistical amount gas tested. This facility also stores wrecked contaminated centrifuges and utilizes previously existing and refurbished GDP equipment.

X-7726 Centrifuge Training and Test Facility- Initially, the area where material and components are received; components or subassemblies are inspected and tested; components are assembled into centrifuge machines; final assembled machines are evacuated and leak checked; and limited repairs are performed to the machine or subassemblies. As the X-7725 RIA Facility becomes available, these functions will transfer to the X-7725 facility and X-7726 facility will also be used for contaminated centrifuge machine select repair operations.

X-7727H Interplant Transfer Corridor -Area that provides an enclosed throughway from the X-7725 or X-7726 facilities to the X-3001 and X-3002 buildings.

X-7746S,W and X-745G Cylinder Storage Yards-Areas that provide UF6 (Feed, Tails, or Product) cylinders (empty or full) and overpack storage; and allows cylinder handling equipment access.

Quantities of Materials or Waste Accumulated Before Shipping or Disposal

- See Table 3.4 (A)

C-3

Decommissioning Funding Plan for the American Centrifuge Plant Revision 14 Table C3.4(A) Quantities of Materials or Waste Accumulated Before Sh"lPPIIl2 or D"1sposa1 Estimated Category Description Quantity 12 Internals: Rotor Assemblies, Motors, Suspensions, and Centrifuges

• 12,000 Mounts ( classified)

Service Modules 2 Structural Components 0 Less than 1 in. Process Piping length (Lft) Includes Tubing 3 0 Piping 1-16 in. Process Piping length (Lft) 271,840 Blowers Feed/Withdrawal Exhaust Blowers 2 Pumps Vacuum (Evacuation/Purge); RHW Pumps 119 Ventilation Ductwork; Miscellaneous WISP Ducting (ft3) 3 3,677 Surfaces Building Floors, Yards, Equipment (ft 2 ) 4 2,494,819 Process Valves and MIVs (excluding Sheetmetal) 18,631 Valves Miscellaneous Valves 1,385 Process Equipment Feed Ovens, Autoclaves, Cold Boxes 91 Ridge Mast (RMC), Bridge, Wall and Jib Cranes; Cylinder Cranes 29 Transporters, Trolleys Scales Process Weighing Equipment 12 Compressors Process Gas Compressors 4 Machine Cooling Water HX, Freezer/Sublimers, Tails Coolers 36 Heat Exchangers (HX)

Source and byproduct material sources used at the Lead Sources 11 Cascade Chemical Traps (8 banks of 4); Cold Traps, Roughing Filters, Traps 71 Miscellaneous Traps Tanks (UF6) Holdup, Surge, and Dump Tanks 3 Upender Trailer Upender (X-7725)(ft3 ) 3 Cylinders Tails - 48G/48X (14, 10 Ton) 17,191 Cylinders Product and Feed (2.5 Ton) Gas Test Area (12B) 450 UF6 Portable Carts; Buffer Storage Stands; Mass Other Equipment Spectrometers; Contaminant Monitors; Miscellaneous 69 Platforms; and Gas Test Center (GTC) Stand Structures Centrifuge Transporter 5 2 Cranes (Process Area - RMC) 5 8 Cranes, Bridge X-7725 5 2 Centrifuge Mobile Equipment 5 4 Centrifuge Dismantling Equipment (6/X-7725 and Decontamination 8 2/X-7726 Assembly Stands) 6 Equipment Cutting Machines6 2 Degreasers 6 2 Decontamination Tanks 6 4 Wet Blast Cabinets 6 2 Crusher6 1 Note I: Amount includes 11,520 operational units plus 480 contaminated spare centrifuges.

Note 2: Centrifuge casings and service module structural steel is not considered waste. These items are to be removed, disassembled, decontaminated to NRC 'Free Release' criteria, and stored for later disposition.

Note 3: Piping <l" (assumed to be instrument piping/tubing), ventilation ductwork, and heat exchangers are assumed to not be internally contaminated. Therefore, these components can be externally decontaminated and remain as part of the building BOP.

Note 4: Amount of wall area (ft2) not provided, because it is not anticipated to need decontamination at the time of decommissioning.

Note 5: Equipment re-utilized from operational phase (not new or purchased).

Note 6: Equipment procured (see Table C3.15).

C-4

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.5 Number and Dimensions of Facility Components (Total Volume)

.Compacted Dimensions of Total Number of Total Factor Level of COMPONENT Component Compacted Components Volunie (ft3) (Volume Contamination (specify units) Volume (ft3)

Remainin X-3001 and X-3002 Ser,vicerMocliiles *.

sirucfufilL;:*,:r*.*

Service Modules - Piping 155,520 Lft ~45' x 4" dia x 6 13,572 0.2 2,714 High Alpha 4" runs Service Modules - Piping 25,920 Lft ~45'x2"diaxl 565 0.2 113 High Alpha 2" run 80 ea 4' X 5' X 4' 6,400 1.0 6,400 32 ea 8" dia x 8' 89 0.2 18 Buildin Headers 12,000 Lft 6" and 10" dia 6,545 0.2 48,000 Lft l ", 2", and 4" dia 4,189 640,000 Lft <1" dia 3,491 16 ea 4'X 4' X 7' 1,792 24,000 Lft 4' X 3' 288,000 Valves (12 K MIV + 6K 18,000 ea 0.4 ft 3 7,200 1.0 7,200 Miscellaneous Valves, Miscellaneous 640 ea 0.4 ft 3 256 1.0 256 Carts 30 ea 3' X 5' X 4' 1,800 0.5 900 X-3012 HVAC Ductwork .1,225 Lft 21 X 1' 2,450

• LowAl ha X-3344 Autoclaves 12 ea 8.6' dia x 20.7' 14,429 0.2 2,886 Hi h Al ha Piping (evacuation line to 400 Lft 6" dia 79 0.2 16 High Alpha X-3346 300 Lft 6" dia 59 0.1 6 1 ea 13'x3'x3' 117 59 HVAC Ductwork 750 Lft 3'x2' 4,500 C-5

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.5 Number_ and Dimensions of Facility Components (Total Volume)

Compacted Dimensions of Total ..

Number of . Total Factor Level of COMPONENT Component* Compacted Components Volume (ft3) (Vohime Contamination (specify units) Volume (ft')

• Remainin X-3346 Feed Area Electric Feed Ovens 28 ea Cold Boxes (Including 7 ea 22' X 15' X 6' Dum Freezer/Sublimers 6ea 48" dia x 144" *VF 2,714 1.0 2,714 4,000 Lft 6" dia 785 0.2 157 Valves 625 ea 0.4 ft 3 250 1.0 250 WISP S stem Ductin 300 Lft 6" dia 59 0.1 6 C linder Trans orter 3 ea 13' x 3' x 3' 351 0.5 176

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,,.,-:':",,...~;.-/)V 1/, 1/.

,1 1/.-C-/://,.-;,,.-_:I',*','*

Cold Boxes (Product) 18 ea 22' X 15' X 6' 35,640 0.2 7,128 High Alpha Piping (Product) 2,000 Lft 6" dia 393 0.2 79 High Alpha Vacuum Pumps 24 ea 2' X 5' X 2' 480 1.0 480 High Aloha Cold Boxes (Tails) 26 ea 22' X 15' X 6' 51,480 0.2 10,296 High Alpha Compressors 4 ea 6' x 5' x 4' *VF 960 1.0 960 High Alpha Compressor Train Coolers 10 ea 4' dia x 4' *VF 754 1.0 754 High Aloha Freezer/sublimers 4 ea 48" dia x 144" *VF 1,810 1.0 1,810 High Alpha Mass Spectrometers 6 ea 2'x4'x2'*VF 192 1.0 192 High Alpha Chemical Traps 16 ea 8" dia x 96" 45 0.2 9 High Alpha Cold Traps 15 ea l0"diax 12' 98 0.2 20 High Alpha Piping (Tails) 4,000 Lft 6" dia 785 0.2 157 High Aloha Blowers (Vent Exhaust 2 ea 4' X 10' X 4' 320 0.2 64 Low Alpha Sys)

Roughing Filters 4 ea 3'diax4' 113 0.2 23 High Aloha C-6

Decommissioning Funding Plan for the American Centrifuge Plant Revision 14 Table C3.5 Number and Dimensions of Facility Components (Total Volume)

Compacted.

Dimensions of** . Total

. Number of Total Factor Level*of COMPONENT Component .Compacted Components Voluine (ft3) (Volume .Contamination (specify units) Volume (ft3)

Remainin Holdu Tanks 2 ea 8' dia x 14' 1,407 0.3 422 Sur e Tanks 1 ea 12' dia x 55' 6,220 0.3 1,866 Vacuu 8 ea 3' X 3' X 3' 216 1.0 216 WISPS 300 Lft 6" dia 59 0.1 6 Containment Monitors 5 ea 2'x3'x2' 60 0.2 12 Cylinder Transporter (IP, 2 ea 13'x3'x3' 234 0.5 117 Low Alpha

',.,~-::.!~!2s:-,;v,-,,y.,.J/,.';',;':.,',<'.//~"-7/N, i,1/4',.//,, ...,,,* .(/4,::'.-'/4-:'//4':;""J.-,.:,,::,,r-,{";' ....,.~ ,l/4-r*~,:7,::0,Y/,<'.,;, ...-.-: .. '1// .:.V,{-"/,, ,:,:///*;,~,v,-;,..;,v/.!','~'/.l; ,.f,/,*//4.(_.,;:,;,*.-<',,Z.-';,~,: //*///.?.,.///,-'~ .;>/_,~*~*.<,///*~.F//.R; .-*'lS**..~----*~//,-";<,_-:1/_,~-//,-:;~ -,--':, 'N1/,f',;,1/.,.(, f./,(: //,7/.<--l"'.*X:-'/ ,, /4" //..:.,1/,,~,;y/;.," ,(/4-!; ,,-,,_,-'.,; ,_,;,,;...-/>'1;"'/4< /1/,,.,.....h/,*Y,,% .:/*.,;;,.

~; Feed/Tails Area

, * ,,. ** ,.,., -~~-.- <:> .,'->_ , :._ -** f':,,,";'~ :- --~*'/, '.i~/~ .,* /~-*-:r. _., :- ,.:,* .*! ..* /4'.*, - ...-*.:-->. ---~-:-..-< .. // ,.,.,,*. ,r',. ,.__, .,,_ -:'x"J* ,,,_,... _,.:,,;,. +, --~, ,---*~-- ... :,.,,; >,.*,~,;-:, :(~ ., .,.,,,/,,* .,,;. ..-* *. 'r/, .,.,, '/ ,*,-.,,; ,.,:.~,-,.* ..... .,;, ,..,~

HVAC Ductw.ork 3,500 Lft

• 3' x 2' 21,000 Pi in <l";Tubin 24,000Lft l"dia 131 Valves 625 ea 0.4 ft 3 250

/.,: ,,/~.-

Common Area

/.-:,-;* ,.y,,;,.~~.0,:.-:,-,..7 //H..-;;,,-:-//4.~ ,.v /,z:,:::-~:--...?,<,-;:*:,..v ,.;,;..-,,.._,,:;-,y_,c.~.;.;,:-<" ;;-:~*,.:,,:.--,x,.,.c-: ;;,-,,....,, ;***,..h:-;,,-,{,*V-:,... y,,:.,,* ,,;,,.,;,:-,.,.0-..-:,,. :,;. .>>' --:*-~*:.~*~.1,,--:,,* '"'/.~*-:,;:-,,.x ,,-:,;:-:*.-:.:::~;.-  :-'>'h: ,,--:.-;.:, ,:-.,* ,:,,,,.*

Tails C linders 17,191 ea 139 ft 3 2,389,565 ha Product Parent C linders 444 ea 108.9 ft 3 48,352 a Gas Test Area Cylinders 6 ea 2.38 ft 3 14 ha 12B Sources sealed 11 ea 1.5" Dia x 0.25" 0 None X-2232C IPP x2 5,000 Lft 10" dia 2,727 0.2 545 Hi ha IPP x4 10,000 Lft 8" dia 3,491 0.2 698 Hi ha IPP x2 5,000 Lft 20" dia 10,908 0.2 2,182 Hi ha X-6002 Boilers 3 ea 24' X 14' X 12' 12,096 0.3 3,629 Low Al ha Pum s,RHW 3 ea 4' X 4' X 10' 480 1.0 480 Low Al ha X-7725 20ea 5' X 25' X 1.5' 3,750 Low Al ha Tra s, Gas Test Stand 4 ea 8" dia x 8' 11 Low Al ha HVAC Ductwork 3,800 Lft . 3' x2' 22,800 LowAl ha C-7

Decommissioning Funding Plan/or the American Centrifuge Plant Revision 12 Table C3.5 Number and Dimensions of Facility Components (Total Volume)

Compacted Dimensions of Total

• Number of Total Factor LeveI*of COMPONENT Component . *** . Compacted Components Volume (fP). (Volume

• Contamination (specify units) Volume (ft3)

Remainin . .

Vacuum Pum s 7 ea 2' X 5' X 2' 140 1.0 140 Valves Miscellaneous 120 ea 0.4 ft 3 48 1.0 48 Mass S ectrometers 1 ea 2' x4' x2' *VF 32 1.0 32 u enders 3 ea 40' X 5' x4' 2,400 0.3 720 Platform, Steel 1 ea 44' X 20' X 20' 17,600 Trolle Monorail 12 ea 5'x5'x8' 2,400 ore StandtStructures*with . 44' x 60' xTO' ...,-,,*.,:

158,400;_:r>*-*

.1* /

.Platforml"

• Gas Test Stand Equ't (MIV 2' X 5' X 1' 60 Low Alpha sets X-7727H 23 units '3'xTx50' 3,450 LowAl ha 7,913,768 Assumptions:

• Centrifuge casings and service module structural steel is not considered waste. These items are to be removed, disassembled, decontaminated to NRC 'Free Release' criteria, and stored for later disposition. Centrifuge machine internals are considered for waste and accounted for in Table C3.14.

• Total Component Volume does not include the centrifuge casing, service modules (structure), piping <l", HVAC ductwork, some heat exchangers, and Tails cylinder component volume in this volumetric calculation; the piping, HV AC ductwork, and heat exchangers are essentially decontaminated to a 'free release'.

criteria, and remain in the buildings; the centrifuge casings and service module structure are decontaminated to a 'free release' criteria and are stored for later disposition. Tails cylinders are considered to be part of the Tails classified waste disposal costs calculated by a different means in Table C3.19 elsewhere.

*.~ii~fi~Mi~~~~ti~~~§;~ir~~1~fu;

~~fuiii~~i

~~,~~J~~;~~t.1!9mr,e item~Jj§J~i ;: :~*~*** ,;ill:~ s~* :':':::'Y! ::~'.j>{:~~[~'.:;i*::' r1~'.,.*~;'::diiL \.

• • Highlighted rows repre.sent HVAC ductw-ork, and heat excJ}angers. -

2

X~1:.'* ..... :J

• Highlighted rows represent Tails cylinders.

C-8

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.5(A) Number and Di~ensions of Facility Components (Total Area)

Dimensions of.

Number.of Total Area Level of Component Component /Area Components (ft2) 1 Contamination (specify units) 1 * .

X-3001 and X-3002 416' X 730' Cranes (RMC) 4/Building -650' x 2' x 2 rails 20,800 Low Alpha Floors 2 Buildings 303,680 ft2 607,360 Low Alpha X-3012 240' X 201' Maintenance Shop 3 (floors only) 100' x39' 11,700 Low Alpha

., ,,. 75 WorlvBencll {'*

• *** 5 1,: . ,. .J' X .5' I*

.Low Alpha Small Parts .r ". .**'

.** Misc.

i'Varied .  :*

... 11 } . Low Aloha .;

Floors (-60%) 2 1 Building 28,950 ft2 28,950 Low Alpha X-3344 200' X 200' Scales  :>:.Y: .. *.  ;

3*ea . . . 11' X 6"  ;, . 198

• LowAloha . *.*

Cylinder Transport 1 set -200' x 2 rails 167 Low Alpha Floors 1 Building 40,000 ft2 40.000 Low Alpha X-3346 488' X 352' Scales .:\ . * .. ** .*, *. **.::' *.....

• 3 ea 11' x6'  ; .i98', ./ .... Low Aloha ..***.**.

Crane,s*

2ea ,..:, 1,200' x 2' x2 rails

. 9,600', .

. ... ** . Low Alpha **

Cylinder Transport 4 sets -352' x 2 rails 1,173 Low Alpha Floors 1 Building 107,920 ft2 107,920 Low Alpha X-3346A 100' X 190' Scales *.. '" ::<. *<*< *c,**

• <" 4ea* 11' x 6'. **. 264 Low Alpha Floors 1 Building 19,000 ft2 19,000 Low Alpha Cylinder Storage Yards X:-745O-2 . .: *:.

• i 1.lot 245'X550' 135,057 *LowAJpha.

X-7,J.SH (FutureJot) : .**: *:..-*>. *.

.  : . llot  : 486' i2, 178' ,,. 1,Q59,l5Q Low Alpha

.X07746S ... 1,' ,, .. * . 1 lot 'j . 197'x,, 163' *,. 32,968 .... ** LowAlpha X:fJ946W.  ::::< . .........:.,,, .: *** 1 fot ... 796'Xl66! < 132 543 :" '**Low Alpha ..

C-9

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.5(A) Number and Dimensions of Facility Components (Total Area) (Cont.)

' Dimensions of

• Number of Total Area Level of Component . Component (ft2) 1 Components Contamination

. (specify units) 1 * '

X-2232C 2,500' X 5' Housing 1 Equivalent Area 12,500 ft2 12,500 Low Alpha X-6002 120' X 160'

.F'loors ""'

. ,t ,;,;:')' *, , . '.:n Building .* ;;%{,;; . *.

19,'.200:ft2 .. J***** 0  ; . *"<,,,: Nonif *::"'

X-7725 540' X 820' Scates . .. . {.c;;.";., \,*; .. . >* * * . '.' ::2.ea . '":"

,.* .. .3\x3' i, 18 'Low\A.1lpha. ' i .*,

. TfQ1Jey, Moh6rait: .*. *.* !:::ti, . :c;;:;p,'

• 1 ea. ":'l,350Lft x 2' x.ltail * . ,'/S 2,700 *' > Low Aioha Cranes, Double-Girder Bridge 5 ea ~204' x 2.3' x 2 rails 4,692 Low Alpha (Trolley) (shared)

Cranes, Single-Girder Bridge 2 ea ~80' x 1.3' x 2 rails (shared) 416 Low Alpha

• cranes;:Bddge (30 abandoned) .. .. 0 ~10()'.X 2' X 2 rails  :

0

.LowAJpha Cranes, \Vall (5 abandoned) * **. . . 0 ,,::;50* x 2' x2 .rails  : . b LbwAl'pha Buffer Storage (~75%) 2 1 lot ~208' X 283' 45,000 . Low Alpha South Bldg Floors 1 lot 536' X 272' 145,792 Low Alpha X-7726 286' X 84'

• .y

3::;. '.' .. * *:

• ts;:*,. *. ,;,5o*X:'2i x1ltails

• • • 300 '._:,c,~ . ,Low Alpha Cranes 4ell: *,: ,;,,.._="t Cranes (xl Job, xl Monorail, and 4 ea 189 ft2 189 Low Alpha x2 Mini-Monorail)

Floors (multiple levels) 1 Building - 49,500 ft2 49,500 Low Alpha X-7727H ~750' X 30' Floors 1 Building 26,078 ft2 26,078 Low Alpha Total Area 2,494,819 Note 1: Actual areas were determined by AutoCAD and vary somewhat from a given straight area calculation (1 *w).

Note}: l'e,!",9t!n.tages/Arec1s.)!stt!d c1rt!,rt!c1g~ic proba!)i!it),'. 8!J1.qCJr spact! !lt!e,,4\n.gpote,ntial de9CJn.!c1!11.i_11c1!Jo!\ .. :.* .. *:..*., ............ ,

1

¥.ligl)Hgllted fclws'r~pl'ese1:1};iJ~111s/~qtiipiij~Jit t<)l{ll11ain .i11jpl~9lJmd*.}Vill qe_qecon!a,!hipatedto. a, tpre~;R¢J~:i~e': crit~l"ion,.

C-10

Decommissioning Funding Plan for the American Centrifi1ge Plant Revision 12 Table C3.6 Planning and Preparation (Productive Work Days)

1. Dur Prod Total Group Type Workers (#y) Factor (wd)

Supervision Salary 3 1 219 657 Engineering Salary 8 1 219 1,752 Salary 2 1 219 438 Operations Hourly 2 1 219 438 Salary 4 1 219 876 Maintenance Hourly 0 1 219 0 Plant Salarv 2 1 219 438 Support Hourly 15 1 219 3,285 Support Production Salary 0 1 219 0 Support Hourly 0 1 219 0 Total 36 7,884 Assumptions:

• Anticipated duration = I y

• Productivity Factor= 219 wd/y = 260 - 4l(Paid Absences)

Anticipated tasks considered:

• Develop Project Execution Plan and Schedule (including organization and staffing plan and needed services)

• Develop Decommissioning Plan

• Develop/implement Site Characterization Plan

• Review/approve Site Decommissioning Plan by NRC; Regulatory/License issues

• Develop Decommissioning Activity Procedures

• Design Decommissioning Service Area (DSA)

• Initial Project Support/Organization

• Initial Plant Security C-11

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.7 Decontamination or Dismantling of Radioactive Facility Components (Productive Work Days)

1. Dur Prod

• Group Type Total (wd)

Workers (#y) Factor Supervision Salary 6 5 219 6,570 Engineering Salary 5 5 219 5,475 Salary 3 5 219 3,285 Operations Hourly 21 5 219 22,995 Salary 9 5 219 9,855 Maintenance Hourly 44 5 219 48,180 Plant Salary 6 5 219 6,570 Support Hourly 17 5 219 18,615 Support Production Salary 8 5 219 8,760 Support Hourly 13 5 219 14,235 Total 132 144,540 Assumptions:

• Anticipated duration = 5 y

• Productivity Factor= 219 wd/y = 260 - 41 (Paid Absences)

Anticipated tasks considered (Listed percentages are a relative indicator of the amount of phased resource effort for each task):

• Erect Decontamination Facility (Minimal comparative effort)

• Decontamination of facilities - Internals (-1.5%)

• Dismantle centrifuge machines; Waste segregation/staging (-54.5%) [46.6 mh/machine]

• Dismantle facilities/components (-17%)

• Tails Cylinder movement/disposition (-5%) [material title transfer DOE/UDS]

• Continued Project and Security Support (-22%)'

C-12

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.8 Restoration of Contaminated Areas on Facility Grounds (Productive Work Days)

1. Dur Prod Total Group Type Workers (#y) Factor (wd)

• Supervision Salary 0 2 219 0 Engineering Salary 0 2 219 0 Salary 1 2 219 438 Operations Hourly 5 2 219 2,190 Salary 0 2 219 0 Maintenance Hourly 0 2 219 0 Plant Salary 1 2 219 438 Support Hourly 0 2 219 .o Support Production Salary 0 2 219 0 Support Hourly 0 2 219 0 Total 7 3,066 Assumptions:

• Anticipated duration = 2y

• Productivity Factor= 219 wd/y = 260 - 41 (Paid Absences)

• I person cleans -600 - 900 ft2/d (750 ft 2/d used avg value) loose contamination (minimal amount of loose contamination anticipated)

• Shares resource allocation coincident with Decontamination or Dismantling phase effort

• Minimal loose contamination and cleanup anticipated

• . Labor estimate includes non-labor cots for analytical sampling/surveying efforts Anticipated tasks considered:

• Decontamination of facilities - external/outside; cylinder

• Perform HP surveys

• Remove fixed contamination; Scarify cylinder storage yards surfaces

• Collect/dispose of yard debris C-13

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.9 Final Radiation Survey (Productive Work Days)

1. Dur Prod Total Group Type

• Workers (#v) Factor (wd)

Supervision Salary 0 2.5 219 0 Engineering Salary 1 2.5 219 548 Salary 0 2.5 219 0 Operations Hourly 0 2.5 219 0 Salary 0 2.5 219 0 Maintenance Hourly 1 2.5 219 548 Plant Salary 3 2.5 219 1,641 Support Hourly 1 2.5 219 548 Support Production Salary 0 2.5 219 0 Support Hourly 0 2.5 219 0 Total 6 3,285 Assumptions:

• Anticipated duration= 2.5y

• Productivity Factor= 219 wd/y = 260 - 41 (Paid Absences)

• Work period occurs coincident with the last 2.5 years of the D&D phase.

• Labor estimate includes non-labor costs for analytical sampling/surveying efforts.

Anticipated tasks considered:

• Develop/implement survey plans

• Collect/analyze data

• Perform confirmatory surveys

• Develop final survey report

• Terminate license C-14

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.10 Site Stabilization and Long-Term Surveillance (Productive Work Days)

1. Dur Prod *Total Group Type Workers (#y) Factor *(wd)

Supervision Salary 0 6 219 0 Engineering Salary 1 6 219 1,314 Salary 1 6 219 1,314 Operations Hourly 1 6 219 1,314 Salary 0 6 219 0 Maintenance Hourly 2 6 219 2,628 Plant Salary 0 6 219 0 Support Hourly 0 6 219 0 Support Production Salary 0 6 219 0 Support Hourly 0 6 219 0 Total 5 6,570 Assumptions:

• Anticipated duration= 6y (coincident with P&P and D&D)

• Productivity Factor= 219 wd/y = 260 - 41 (Paid Absences)

Anticipated tasks considered:

• Site stabilization - not required

• Maintain maintenance/surveillances on IROFS equipment necessary until license terminated

(-year six)

C-15

Decommissioning Funding Plan_for the American Centrifuge Plant Revision 12 Table C3.11 Total Work Days by Labor Category Labor Labor Labor Labor Labor Labor Labor Labor Total Category Category Category Category Category Category Category Category Phase Task Supervision Eng. Operations Operations Maint. Maint. Support Support Labor.

(S) (S) . (S) (H) (S) CH) (S) (H)

Planning and Preparation 657 1,752 438 438 876 0 438 3,285 7,884 Decontamination and/or Dismantling of Radioactive Facility Components 6,570 5,475 3,285 22,995 9,855 48,180 15,330 32,850 144,540 Restoration of Contaminated Areas of Facility Grounds 0 0 438 2,190 0 0 438 0 3,066 Final Radiation Survey 0 548 0 0 0 548 1,641 548 3,285 Site Stabilization and Long-Term Surveillance 0 1,314 1,314 1,314 0 2,628 0 0 6,570 Total 7,227 9,089 5,475 26,937 10,731 51,356 17,847 36,683 165,345 Assumptions:

• Individual tables describe other assumptions; this table is a summation of previous table information categorized by Salary or Hourly per phase.

C-16

Decommissioning Funding Plan for the American Centrifi1ge Plant Revision 14 Table C3.14 Packaging, Shipping, and Disposal of Radioactive Wastes

[A] Disposal [B] Number [C] [E] Total

[D] Unit Cost Waste Type Volume (ft'); of Container Unclassified Waste

($/ft' or $/gal)

1. Centrifuges Containers Volume Disposal Costs 1: Misc Total Compacted Equ't Solid Waste 76,388 850 90 $44.20 $3,381,300 2: Liquid Waste 12,000 295 55 $73.10 $1,186,048 Total $4,567,348 Assumptions:

• Unclassified, Low-Level Contaminated waste; Liquid waste from machine disassembly

• [A 1] = Total Compacted Volume (Table C3.5); [A2] =#centrifuges (Installed plus Spares) (Table C3.4a)

• [B 1] = A 1/C 1; [8 2] = A 2*5.4 qt/machine/220 qt/barrel; [C 1] = B-25 boxes volume= 90 ft 3;

[C 2] = 55 gal/barrel

• [D 1] = Unit Cost 1 = $44.20/ft3 = $30.08 (Current disposal and transportation cost- Energy Solutions, Clive, UT

[1,791 miles one way trip and Brokerage Costs])+ $13.34/ft3 (Labor costs - Handling, Waste Engineering, Radiological Waste NDA Characterization, and HP Support)+ $0.78/ft3 (Rad Characterization Equipment);

[D 2] = Unit Cost2 = $73. IO = $70.00/gal (incineration and disposal @ Diversified Scientific Services Inc.

{DSSI}, Oak Ridge, TN)+ $0.95/gal (Transportation and Brokerage cost [350 miles one way trip to DSSI]) +

$2.15/gal (Labor costs - Handling, Sampling, Lab Analyses) [$2008]

• [E1J = B1c1D1; [E2J = 8 2c2D2

• Unclassified Waste Disposal Prorated Ratio [only used in computation for contractor profitability]= amount of waste cost that is directly associated with waste disposal and not subject to contractor profit: 1(Current disposal and transportation cost)/(TotaI compacted solid waste cost) = 0.68; 2 (incineration and disposal cost +

transportation cost)/(Total liquid waste cost) = 0.97 e Unit cost information is based upon current design information and cost information from United States Enrichment Corporation gaseous diffusion operations, specifically Gas Centrifuge Enrichment Plant cleanup.

• Radioactive source and byproduct material sources total compacted volume is less than I ft 3 and is accounted in

[A 1]. Disposing of sources are estimated to cost $12,559 which includes profile development/approval, two separate shipment paths, transportation cost and material handling markups. The cost of disposing of the sources is included in [E 1]. (see Table C3. I 8)

[M] Total

[H] Number [J] [K] Unit

[F] # of [G] Factor Classified Waste Type. of Containers Cost Centrifuges (B-25/ma) Waste Containers Volume ($/ft3)

Disposal Costs 3: Classified 12,000 1.6 19,200 90 $33.02 $ 57,058,560 Waste Total 19,200 $ 57,058,560 Grand Total $ 61,625,908 Grand Total $ 61.6M (Rounded)

Assumptions:

• Classified, Low-Level Contaminated Waste

• [<J] - historical event= 1.6 B-25 boxes/machine

• [HJ= number ofB-25 boxes= FG

• [J] = B-25 boxes volume= 90 ft 3

• [K] = Unit Cost= $32.02/ft3 = $14.51/ft3 (Current DOE classified disposal cost - NTS, NV)+ $4.39/ft3 (Transportation [2,136 miles one way trip and Brokerage Costs)+ $13.34/ft3 (Labor costs - Handling, Waste Engineering, Radiological NDA Waste Characterization, and HP Support)+ $0.78/ft3 (Rad Characterization Equipment) [$2008]

• [M] = HJK

• B-25 boxes contain volume gaps, which are filled to capacity from scarified yard materials/debris.

• Classified Waste Disposal Prorated Ratio [only used in computation for contractor profitability]= amount of waste cost that is directly associated with waste disposal and not subject to contractor profit: (Current DOE Disposal cost+ Transportation cost)/(Total Classified waste cost) = 0.57

• Unit cost information is based upon current design information and cost information from United States Enrichment Corporation gaseous diffusion operations, specifically Gas Centrifuge Enrichment Plant cleanup.

C-17

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.15 Equipment/Supply Costs

[C]

[A] [B] Total Equipment/Supplies Quantity Unit Cost .Equ 't/Supply Cost Centrifuge Dismantling Equipment1 8 $27,946 $223,568 Cutting Machines2 2 $27,946 $55,892 Degreasers3 2 $16,768 $33,536 Decontamination Tanks4 4 $27,946 $111,784 Blast Cabinets 5 2 $27,946 $55,892 Crushers6 1 $279,461 $279,461 Negative Air Machines 7 2 $14,532 $29,064 B-25 Containers 8 20,050 $938 $18,806,900 55 gallon Barreis 9 295 $74 $21,830 TOTALS $19,617,927 TOTAL (Rounded) $19.6M Note 1: Specialized tooling and lift fixtures for handling various machine components. Estimate based on in-house design and fabrication.

Note 2: 10" heavy-duty metal band saws, floor mounted, for cutting long parts into manageable size. Estimate cost includes electrical hook-up and anchoring.

Note 3: All electric pressure cleaner for removing residue from the machines. Estimated cost includes electrical hook-up and anchoring.

Note 4: Geometrically safe stainless steel holding tanks for supporting the cleaning operation. Cost includes tank supports, suction pumps, associated valves and piping.

Note 5: Booth enclosures to support the degreasing operation.

Note 6: Heavy-duty metal hydraulic crusher for volume reduction, surface mounted. Estimated cost includes associated components, utility hook-ups, and anchoring.

Note 7: Heavy-duty air filtration device to maintain negative air differential and filtration between an enclosure and atmosphere.

Note 8: Approved metal containers for storage/shipment of dismantled machine and machine components.

Quantity is sum ofB-25 containers from Table C3.14 (850 + 19,200 = 20,050).

Note 9: Barrels for the capturing of dismantled machine and machine component fluids from Table C3.14 (295).

Assumptions:

• [C] = AB

• Unit costs are derived utilizing industrial standard equipment and Department of Energy Gas Centrifuge Enrichment Plant cleanout project experience.

• Unit costs increased by Inflation Index = CY2005 (3.2%)

• CY2006 (3.2%)

• CY2007 (2.7%)

• CY2008 (2.2%) [Ref. A]; Total Inflation Index (CY 08) = 1.1178; except B-25 containers and 55 gallon barrels, which are listed in actual $CY08 in lieu of2004 indexed to 2008 dollars.

[Ref A]= Implicit Price Deflator of the Gross Domestic Product for 2005 (1.032), 2006 (1.032), 2007 (1.027) or Administration (Council of economic Advisors Forecast Inflation) for 2008 (1.022) as amended by the GDP price index on June 6, 2007.

C-18

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.16 Laboratory Costs Routine Incident

1. # Recall Freq Sample Unit Phase Activity Freq Freq Total Cost Workers Year (samples/y) Factor Cost($)

(samples/y) (samples/y)

Planning and 1 Preparation 36 1 4 0.2 2 6.2 115 $25,668 Decontamination or 2 Dismantling 132 5 12 0.6 6 18.6 115 $1,411,740 Restoration of 3 Contaminated Areas 7 2 12 0.6 4 16.6 115 $26,726 Final Radiation 4 Survey 6 2.5 12 0.6 4 16.6 115 $28,635 Long Term 5 Surveillance 5 6 4 0.2 2 6.2 115 $21,390 TOTALS 186 11 ,u,5.t'+,.t59 TOT AL (Rounded) $1.SM Assumptions:

• The utilization of the 'on-site' laboratory facility is anticipated; therefore, there are no associated transportation costs included in the derivation of the Unit Cost.

• Routine frequency is the anticipated number of samples per individual per year (see Table 4.7-3 of the License Application).

• Recall Frequency assumes 5 *percent recall rate; Recall = an individual sample submitted when analysis results exceed a predetermined urinalysis program action level (see Table 4.7-3 of the ACP License Application).

• Incident Frequency assumes two samples submitted for each incident; Incident= a special sample submitted for analysis due to an incident (for example, a personnel contamination event or an airborne release of radioactive material event occurs).

• Sample factor= routine freq%+ Recall%+ Incident%; Total cost=(# worker/phase)*(# yr)* Sample Factor* Unit Cost.

• #samples=(# worker/phase)* (Routine freq%+ Recall%+ Incident%)*# yr

• Analytical Unit Cost= $115/sample [Amount based for uranium isotopic analysis by alpha spectrometry and includes analysis performance, labor, and cost of materials plus overheads] ($CY08).

C-19

Decommissioning Funding Plan/or the American Centrifuge Plant Revision 12 Table C3.17 Miscellaneous Costs Other Direct Costs Cost Item Total Cost*

Miscellaneous Material for DeCon 1 $2,945 500 Total $2,945,500 Total (Rounded) $2.9M Note 1: Estimate based upon percentage of Decommissioning Cost subtotal (1.5%

• Total Other Costs) (values from Table C3.18) [0.015 * (Total Other Indirect Costs)].

Other Indirect Costs Cost Item Total Cost NRC Staff Review and Approval DP 2 $90,000 3

License Fees $24,556,260 DOE Lease $12,089,700 Business Ins $1,922,069 Total $38,658,029

,,n

~

$38.7M Note 2: Estimate based upon review and approval for Decommissioning Plan (DP).

Inflation Index= CY2005 (3.2%)

• CY2006 (3.2%)

• CY2007 (2.7%)

• CY2008 (2.2%)[Ref. A].

Note 3: Estimate based upon NRC Annual Operational Fees for plant.

C-20

Decommissioning Funding Plan for the American Centrifuge Plant Revision 14 Table C3.18 Total Decommissioning Costs Calculated

• Ref Task Costs Percentage

($2008, D3.13 Plannin $ 3.3 1%

Decontamination and/or Dismantling D3.13 of Radioactive Facili Com onents $ 51.5 20%

Restoration of Contaminated Areas D3.13 on Facilit Grounds $ 0.9 1%

D3.13 Final Radiation Surve $ 1.6 1%

Site Stabilization and Long-Term D3.13 Surveillance $ 3.0 1%

CS-3-6 Indirect Services $ 71.9 28%

Packaging, Shipping, and Waste C3.14 Dis osal Costs $ 61.6 24%

C3.15 $ 19.6 8%

C3.16 $ 1.5 1%

C3.17 Other Direct Costs $ 2.9 1%

C3.17 Other Indirect Costs $ 38.7 15%

Subtotal 1 $256.5 100%

G&A 2

$ 15.4 Contractor Profit3 $ 29.9 Contingency4 $ 75.5 Total Labor & Materials Cost $377.3

$ 717.6

$179.4 Total Tails Dis osal Cost $896.9 Total Decommissioning Cost Estimate osal $1,274.2 Note I: Subtotal includes labor/materials overhead allocations costs.

Note 2: General and Administrative (G&A) cost assumed to be 6% based upon current company's experience.

Note 3: Contractor Profit assumed to be 15% of the subtotal plus G&A minus other indirect costs ([excluding insurance] minus the outside services portion of the Packaging, Shipping, and Waste Disposal Costs (15% *[256.5 +

15.4- 36.7 - 36.1] = $29.9M).

Note 4: Contingency assumed to be 25% on subtotal plus G&A and contractor profit.

Note 5: Contingency assumed to be 25% on Tails Disposal cost.

Note 6: Total cost for disposal of sources= Packaging, Shipping and Waste Disposal Cost, G&A Cost (6%),

Contractor Profit (15%) and Contingency (25%) [$12,559 + $754 + $1,997 + $3,827 = $19,137] which is included in the costs listed above.

C-21

Decommissioning Funding Plan/or the American Centrifuge Plant Revision 12 Table C3.18A Total Incremental Decommissioning Costs Tails Total Total Contractor Total Disposal Total Tails*

Calendar Machine G&A Contigency Tails . Total Incremental Facility Profit Labor and Cost Disposal Year Disposal (6%) (25%) Contingency Decommissioning Cost Cost (15%) Materials (Table Cost Cost Cost C3.19) 2007 $176.1 - $10.6 $17.0 $50.9 $254.6 - - - $254.6 2008 $176.1 - $10.6 $17.0 $50.9 $254.6 - - - $254.6 2009 $176.1 -. $10.6 $17.0 $50.9 $254.6 - - - $254.6 2010 $176.1 $4.7 $10.8 $17.8 $52.4 $261.8 $1.7 $0.4 $2.1 $263.9 2011 $176.1 $29.8 $12.4 $21.8 $60.0 $300.1 $10.8 $2.7 $13.5 $313.6 2012 $176.1 $62.0 $14.3 $26.9 $69.8 $349.1 $22.5 $5.6 $28.1 $377.2 2013 $176.1 $77.2 $15.2 $29.3 $74.5 $372.3 $28.0 $7.0 $35.0 $407.3 2014-2037 $176.1 $80.5 $15.4 $29.9 $75.5 $377.3 $654.6 $163.7 $818.2 $1,195.3 Total I $377.3 $717.6 $179.4 $896.9 $1,274.2

.Note: Values are in $2008, Million Assumptions:

• Operational (license) life= 30 years (from 2007 - 2037); 365 days/yr; 24 hr/day; License Receipt= 04/13/2007

• Facility Cost= Total Labor (Planning and Preparation) [D3.13] + Decommissioning and/or Dismantling of Radioactive Facility Components [D3.13] + Restoration of Contaminated Areas on Facility Grounds [D3.13] + Final Radiation Survey [D3.13] + Site Stabilization and Long-term Surveillance [D3.13] + Indirect Services

[C3.18] + Equipment/Supply {not associated with Machine Disposal; i.e., total minus 8-25 boxes and 55 gallon drums} [C3.15] + Laboratory [C3.16] +

Miscellaneous Direct [C3.17] + Indirect Costs [C3.17] {Conservatively assumed to be constant during construction period and needed upon license receipt.}

• Total Machine Disposal Cost= Incremental machine installation captured from Table C3. l 9A

• Total Labor and Material Cost (Calculated the same as Table C3.18) = Total Facility Cost+ Total Machine Disposal Cost+ G&A + Contractor Profit+ Contingency.

The last value under years 2014-2037 is the anticipated Total Labor and Materials Cost including G&A, Contractor Profit, and Contingency. The Total is not the sum of the column, it is based upon the facilities and machine disposal cost, which is at full load by the year 2011.

• • Total Tails Disposal Cost= Incremental Tails disposal cost captured from Table C3.19 + 25% Contingency.

• Total Incremental Decommissioning Cost (during initial construction period) by year= sums across Total Labor and Materials Cost+ Total Tails Disposal Cost. The Total Incremental Decommissioning Cost is not the sum of the columns.

C-22

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.19 Estimated Volume of Annual Depleted Uranium Generated ii k [Q]

[Rl/'.' . [S]  ;

. . . >:[T) ..

(U]*.

<DtJF6 [V]

.**.eahm'.c1arvear :_*#  ;.

" .. '  ; DVFG DU Generated Tails Disl?osal *. '*i *

1. Tails Generated ' Accumulated Cost M~chine.s<< , fl,000 MTl. (1,000 MT] .. *Cylinders fi,ooo MT] f$,.2008l 2010 699 0.5 0.5 0.3 $1.7 41 2011 4,450 3.2 3.7 2.2 $10.8 259 2012 9,240 6.7 10.5 4.6 $22.5 540 2013 11,520 8.4 18.9 5.7 $28.0 672 2014-2037 11,520 195.6 214.4 132.2 $654.6 15,679 Total .,*.*\*'** . .: 214.4 145.0 $717.6 17,191 Assumptions:

• No Lead Cascade contribution considered for production/operation/cost

• Q =#machines - based upon Machine Build Schedule (Revision 6, dated 03/24/2008)

• Operational life= 28 years (from 2010 - 2037); continuous operation

• Tails Output during Operation(@ 3,800 MTSWU/yr) = 2,108 lbs UFJhr

• Weight Conversion Factor (WCF) = 0.45359 kg/lb; Tails Material Conversion Factor= 0.30668 kg/lb UF6; Tails Purity (TP) = 0.67612 gU/g; based upon Tails Assay of0.30 wt.% U 235

• U disposal cost = $4.95/kg U ($2008)

• R=T/0.67612

• U=T * (U Disposal Cost)

• 27,500 lbs UF 6 48G fill limit

• V=R

• lM/0.45359/27,500 .

• -17,191 Tails cylinders generated plus-444 product and feed cylinders for managing working inventory @End of Life C-23

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.19A Estimated Incremental Machine Disposal Cost

.::.:\_' *.* **. >,,\[U2]

[Ql . . ... JR}l:,. . [s~1*.

"" . ._ :Incremental Machine i;

Cal~~clar YeJr I ...*

• Estimated

'"lVlachine:Ratio - . " l)isi,osal C:pst

1. .JVlachJfies DJspositlJJost ,.. **. :>  : [$, 20081 \ .

2007 0 $80.5 0.0 2008 0 $80.5 0.0 2009 0 $80.5 0.0 2010 699 $80.5 0.06. $4.7 2011 4,450 $80.5 0.37 $29.8 2012 9,240 $80.5 0.77 $62.0 2013 11,520 $80.5 0.96 $77.2 2014-2037 12,000 $80.5 1.00 $80.5 Total $80.5 1.00 $80.5 Assumptions:

• Operational (license) life= 30 years (from 2007 - 2037); 365 days/yr; 24 hr/day; License Receipt 04/13/2007

• Calendar year and Q =#Machines; consistent with Table C3 .19; The difference in total number of machines is the estimated number of spares needed, which in the Tails computation, do not generate inventory from Table C3.19.

• R2 = sum of Total Classified and Unclassified Waste Disposal Cost from Table C3.14 plus the cost ofthe B-25 containers and 55-gallon barrels from Table C3.15 ($61.6M + $18.9M = $80.5M} [Assumed to be a fixed cost over the initial construction period]. *

• S2 = machine ratio (incremental installation over construction period) = Q/Total # Machines.

• u2= R2

• s2 C-24

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Table C3.20 Total Labor Distribution Group Type Job/Personnel Descriptions Program Manager, Project Manager, Office Manager, QA/Reg Manager, Rad-Supervision Salary Environmental-Safety and Health Manager, FNMCA Manager Design Engineer, Field Support, NCS Engineering Salary Engineer, Nuclear Safety, Regulatory Salary Operations FLM Operations Hourly Chemical Operations, UMH Salary Maintenance FLM, Scheduler-Planner Maintenance Mechanic, Laborer, Field Service Hourly Technician Plant Support Salary HP Support Hourly Protection Forces Support Production Salary Waste Engineer Support Hourly Waste Handler C-25

Decommissioning Funding Plan for the American Centrifuge Plant Revision 12 Blank Page C-26