Text

Updated Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1
	ML23080A210
Person / Time
Site:	Crane
Issue date:	03/21/2023
From:	David Helker; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	TMI-23-004
	Download: ML23080A210 (1)
	v • d • e

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com 10 CFR 50.82(a)(4)(i)

TMI-23-004 March 21, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289

Subject:

Updated Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

References:

1)

Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1," dated April 5, 2019 (ML19095A010) 2)

Letter from Justin C. Poole (U.S. Nuclear Regulatory Commission to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1, - Exemptions from the Requirements of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) (EPID L-2019-LLE-0009),"

dated October 16, 2019 (ML192549A179) 3)

Letter from Amy M. Snyder (U.S. Nuclear Regulatory Commission to David P. Rhoades (Constellation Energy Generation, LLC), "Three Mile Island Nuclear Station, Unit 1, - Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Constellation Energy Generation, LLC (EPID L-2021-LLE-0030)," dated June 8, 2022 (ML22126A143)

Constellation Energy Generation, LLC (CEG) is submitting the updated site-specific Decommissioning Cost Estimate (DCE) for Three Mile Island Nuclear Station, Unit 1 (TMI-1).

On April 5, 2019, in accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), CEGs predecessor Exelon Generation Company, LLC submitted a site-specific DCE for TMI-1 (Reference 1). to this letter provides the updated TMI-1 DCE. This DCE will be used in the March 2023 Decommissioning Funding Report for TMI-1. The March 2023 funding submittal will be submitted under a separate cover letter. The minimum formula cost amount using the formula in 10 CFR 50.75(c) is discussed in Attachment 2.

U.S. Nuclear Regulatory Commission Updated Site-Specific Decommissioning Cost Estimate Docket No. 50-289 March 21, 2023 Page 2 to this letter contains the projected annual cash flow from the Nuclear Decommissioning Trust Fund (NDTF) for TMI-1 Radiological Decommissioning (RD),

Spent Fuel Management (SFM), and Site Restoration (SR). SFM and SR are included because CEG has been issued exemptions to use the decommissioning trust funds for these expenses (References 2 and 3). The costs in Attachment 3 for RD (including decommissioning for the Independent Spent Fuel Storage Installation (ISFSI)), SFM, and SR are from Attachment 1, Table 6-2, which have been escalated from June 2022 dollars in Attachment 1, to December 31, 2022, dollars using an escalation rate of 1.53% (which corresponds to an APR of 3.0784%). The NDTF balance as of December 31, 2022, was

$617,077,222. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention). demonstrates that adequate funding is available in the NDTF to complete radiological decommissioning, spent fuel management, and site restoration.

Pursuant to 10 CFR 50.75(f)(1) and 10 CFR 50.82(8)(v) the financial assurance summary report will be updated and submitted to the NRC annually. The cost estimates and financial levels will be adjusted in accordance with Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (applicable revision at the time) and will be used to demonstrate funding assurance. If the funding assurance demonstration shows the decommissioning trust fund is not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in the Regulatory Guide, will be put in place at an appropriate time.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Jill Fisher at Jill.Fisher@constellation.com.

Respectfully, David P. Helker Sr. Manager, Licensing Constellation Energy Generation, LLC : Three Mile Island Nuclear Station - Unit 1 - Site-Specific Decommissioning Cost Estimate : Three Mile Island Nuclear Station - Unit 1 - Minimum Formula Calculation : Three Mile Island Nuclear Station - Unit 1 - Annual Decommissioning Fund Cash Flow

U.S. Nuclear Regulatory Commission Updated Site-Specific Decommissioning Cost Estimate Docket No. 50-289 March 21, 2023 Page 3 cc:

w/ Attachment NRC Regional Administrator - NRC Region I NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 2 Director, Bureau of Radiation Protection, PA Department of Environmental Protection B. Werner, Bureau of Radiation Protection, PA Department of Environmental Resources Three Mile Island Nuclear Station - Unit 1 Site-Specific Decommissioning Cost Estimate

DECOM-2022-DCE-TMI Rev. 0 2022DECOMMISSIONING COSTANALYSISREPORT Three Mile Island Nuclear Station Unit 1 December 2022

DECOM-2022-DCE-TMI Rev. 0 Page i of vi APPROVALS PREPARER:

Jill Fisher_______________________________________________________________

NAME SIGNATURE DATE REVIEWER:

Dipal Patel____________________________________________________________

NAME SIGNATURE DATE APPROVER:

Jeffrey Dunlap_____________________________________________________________

NAME SIGNATURE DATER Fisher, Jill T.

Digitally signed by Fisher, Jill T.

Date: 2022.12.19 14:09:37 -06'00' Patel, Dipal A.

Digitally signed by Patel, Dipal A.

Date: 2022.12.19 14:53:51 -06'00' Dunlap, Jeffrey A.

Digitally signed by Dunlap, Jeffrey A.

Date: 2022.12.19 14:58:58 -06'00'

DECOM-2022-DCE-TMI Rev. 0 Page ii of vi EXECUTIVE

SUMMARY

This report presents the cost to complete decommissioning of the Three Mile Island Nuclear Station Unit 1 (TMI-1). TMI-1 entered decommissioning on September 26, 2019 commensurate with the permanent removal of all fuel from the reactor. This report constitutes the TMI-1 Site-Specific Decommissioning Cost Estimate (DCE).

The primary objectives of the decommissioning project are to remove the facility from service, and reduce residual radioactivity to levels permitting unrestricted release, so that the plants operating license can be terminated within 60-years after permanent cessation of operations. The costs to restore the site to greenfield conditions are also included in the cost estimate.

The selection of a preferred decommissioning alternative is influenced by numerous factors including the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, the status of other units at the site, regulatory requirements, and public concerns. Based on these factors, the SAFSTOR alternative has been selected.

The cost elements are assigned to one of five subcategories: Radiological Decommissioning (radiological remediation), Spent Fuel Management, Site Restoration, ISFSI Radiological Decommissioning, Radiological Decommissioning Planning. The Radiological Decommissioning and Radiological Decommissioning Planning subcategories are used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR 50.75). The cost reported for this subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.

Section 2 of this report, Decommissioning Scenario and Schedule, discusses three decommissioning scenarios, and provides the schedule for the selected scenario. The methodology used to develop the estimated costs, including financial aspects, is discussed in Section 3, Cost Estimate Methodology. Section 4, Assumptions, provides a discussion of the assumptions used in developing the various costs elements and considerations; including the cost associated with decontamination and component removal, waste disposal, and labor. These assumptions serve as the foundation in the development of the anticipated cost to decommission TMI-1.

Based on the SAFSTOR scenario, the major milestones associated with the decommissioning time periods are discussed in Section 5.

The following table summarizes the estimated costs for the SAFSTOR alternative reflecting the various cost elements. Additional detail regarding the estimated costs is provided in Section 6 of this report.

DECOM-2022-DCE-TMI Rev. 0 Page iii of vi SAFSTOR Alternative for Three Mile Island Unit 1 (thousands, June 2022 dollars)

Cost Element Total Decontamination 5,250 Removal 174,165 Packaging 32,400 Transportation 13,722 Waste Disposal 52,405 Waste Processing 9,560 Program Management1 461,312 Security 191,279 Spent Fuel Storage 39,441 Insurance and Regulatory Fees 61,160 Energy 21,413 Characterization and Licensing Surveys 5,503 Property Taxes 6,212 Miscellaneous Equipment and Supplies 45,473 Total2 1,119,295 Cost Element Total Radiological Decommissioning 884,419 Spent Fuel Management 121,824 Site Restoration 105,364 ISFSI Radiological Decommissioning 7,687 Radiological Decommissioning Planning 0

Total2 1,119,295 1 Includes engineering costs.

2 Columns may not add up due to rounding.

DECOM-2022-DCE-TMI Rev. 0 Page iv of vi ACRONYMS AE Architect Engineer AIF/NESP Atomic Industrial Forum/National Environmental Studies Project ALARA As Low as Reasonably Achievable BWI Babcock & Wilcox International BWR Boiling Water Reactor CE Combustion Engineering CEA Control Element Assembly CFR Code of Federal Regulations D.C.

District of Columbia DCE Decommissioning Cost Estimate DOC Decommissioning Operations Contractor DOE Department of Energy DSAR Defueled Safety Analysis Report Constellation Constellation Generation Company FLEX Diverse and Flexible Coping Strategies FEMA Federal Emergency Management Agency FOL Facility Operating License GAO Government Accountability Office GTCC Greater than Class C [Waste]

HTGR High Temperature Gas-Cooled Reactor IP Industrial Package ISFSI Independent Spent Fuel Storage Installation LLW Low Level Waste LSA Low Specific Activity LTP License Termination Plan MPC Multi-Purpose Canister MTHM Metric Tons Heavy Metal NMPC Niagara Mohawk Power Corporation NRC United States Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Report (NRC)

NWPA Nuclear Waste Policy Act (1982)

PDCE Preliminary Decommissioning Cost Estimate PERT Program Evaluation and Review Technique PSDAR Post Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor RCS Reactor Coolant System RPV Reactor Pressure Vessel SCO Surface Contaminated Object S&L Sargent and Lundy SWEC Stone and Webster Engineering Corporation UFSAR Updated Final Safety Analysis Report U.S.

United States WDF Work Difficulty [Adjustment] Factor

DECOM-2022-DCE-TMI Rev. 0 Page v of vi TABLE OF CONTENTS EXECUTIVE

SUMMARY

.............................................................................................................. ii ACRONYMS................................................................................................................................ iv 1.

OVERVIEW........................................................................................................................... 1 2.

DECOMMISSIONING SCENARIO AND SCHEDULE.......................................................... 3 2.1.

Decommissioning Methods............................................................................................ 3 2.2.

Decommissioning Schedule........................................................................................... 3 3.

COST ESTIMATE METHODOLOGY.................................................................................... 6 3.1.

Methodology Bases........................................................................................................ 6 3.2.

Financial Components of the Cost Model....................................................................... 6 4.

ASSUMPTIONS.................................................................................................................... 9 4.1.

General........................................................................................................................... 9 4.2.

Labor Costs.................................................................................................................... 9 4.3.

Transition Activities....................................................................................................... 10 4.4.

Non-Radioactive Waste................................................................................................ 10 4.5.

Radioactive Waste........................................................................................................ 10 4.6.

Component Removal.................................................................................................... 12 4.7.

Spent Fuel Management.............................................................................................. 12 4.8.

Independent Spent Fuel Installation............................................................................. 13 4.9.

Site Restoration............................................................................................................ 13 4.10. Site Conditions Following Decommissioning................................................................ 13 5.

SCHEDULE......................................................................................................................... 16 5.1.

Schedule Assumptions................................................................................................. 16 6.

COST ESTIMATE................................................................................................................ 17 7.

REFERENCES.................................................................................................................... 23

DECOM-2022-DCE-TMI Rev. 0 Page vi of vi Tables and Figures Figure 4-1: Total Labor Hours..................................................................................................... 14 Table 4-1: Burial Volumes by Waste Category........................................................................... 15 Table 5-1: Decommissioning Timeline........................................................................................ 16 Table 6-1: TMI-1 SAFSTOR Alternative..................................................................................... 18 Table 6-2: Total Annual Expenditures......................................................................................... 19 Table 6-3: Total Cost by WBS.................................................................................................... 21

DECOM-2022-DCE-TMI Rev. 0 Page 1 of 23

1. OVERVIEW This report presents decommissioning cost estimates for Three Mile Island Nuclear Station Unit 1 (TMI-1). TMI-1 is located on Three Mile Island, which is situated in the Susquehanna River upstream from York Haven Dam, in Londonderry Township of Dauphin County, Pennsylvania, approximately 10 miles southeast of Harrisburg, Pennsylvania.

The Three Mile Island Nuclear Station site also includes a second unit (TMl-2} owned by Energy Solutions. TMl-2 has been shut down since the accident in 1979. The TMl-2 structures are intermingled with those of TMl-1; however, the decommissioning of TMl-2 and TMl-1 are independent actions, and this decommissioning cost estimate only applies to TMl-1.

TMI-1 is a Babcock & Wilcox Pressurized Water Reactor (PWR), owned and operated by Constellation Energy Generation, LLC.

TMI-1 was licensed to generate 2,568 megawatts thermal (MWt). TMI-1 structures are located on the northern most section of Three Mile Island. The principal structures of TMI-1 include the reactor building, turbine generator building, fuel handling building, the TMI-1 intake pump and screenhouse structure and the TMI-1 FLEX Storage Facility (formerly the TMI-2 intake pump and screenhouse structure), two natural draft cooling towers, circulating waste pump hoses, waste storage and handling buildings, long-term steam generator storage building, independent spent fuel storage installation (ISFSI), desilting basis, and administrative buildings.

The primary objectives of the decommissioning project are to remove the facility from service, and reduce residual radioactivity to levels permitting unrestricted release, so that the plants operating license can be terminated within 60-years after permanent cessation of operations.

The costs to restore the site to greenfield conditions are also included in the cost estimate.

This analysis is not a detailed engineering evaluation, but an estimate prepared in advance of the detailed engineering processes required to carry out the decommissioning of the nuclear unit. It also may not reflect the actual plan to decommission TMI-1; the plan may differ from the assumptions made in this analysis based on facts that exist at the actual time of decommissioning.

The cost elements are assigned to one of five subcategories:

(1) Radiological Decommissioning - this subcategory is used to accumulate costs that are consistent with decommissioning as defined by the Nuclear Regulatory Commission (NRC) in its financial assurance regulations (i.e., 10 CFR 50.75) and separately address the cost of radiological decommissioning as defined by 10 CFR 50.2. The cost reported for this subcategory along with the Radiological Decommissioning Planning subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.

(2) Spent Fuel Management - this subcategory contains costs associated with the containerization and transfer of spent fuel from the wet storage pool to a Department of Energy (DOE) transport cask or to the ISFSI for interim storage, as well as the transfer of the spent fuel in storage at the ISFSI to the DOE. Costs are included for management of the ISFSI until such time that the transfer is complete. It does not include any costs related to the final storage of the spent fuel at a national repository.

DECOM-2022-DCE-TMI Rev. 0 Page 2 of 23 (3) Site Restoration - this subcategory is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet below grade and backfilled to conform to local surface elevation.

(4) ISFSI Radiological Decommissioning - this subcategory is used to capture costs associated with activities directly related to radiological decontamination or dismantlement of the spent fuel dry storage facility as required by 10 CFR 72.30.

(5) Radiological Decommissioning Planning - this subcategory is used to accumulate costs associated with planning for radiological decommissioning that are incurred prior to the cessation of plant operations.

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

The estimates were developed, and costs are presented in 2022 dollars. As such, the estimates do not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the station or during the decommissioning period.

DECOM-2022-DCE-TMI Rev. 0 Page 3 of 23

2. DECOMMISSIONING SCENARIO AND SCHEDULE 2.1.

DECOMMISSIONING METHODS Constellation evaluated the following decommissioning scenarios:

(1) DECON - spent fuel is transferred to the ISFSI shortly after shutdown and decommissioning and dismantlement is performed concurrently with the spent fuel campaign.

(2) Shortened SAFSTOR (SHORTSTOR) - spent fuel is transferred to the ISFSI and decommissioning starts approximately 30 years after permanent shutdown.

(1) SAFSTOR - spent fuel is transferred to the ISFSI and the plant facility is left intact until the decommissioning starts sometime in the future (dormancy phase), with structures maintained in a sound condition. Decommissioning commences such that license termination is completed within the required 60-years.

The scenarios also recognize that spent fuel will be stored at the site in the spent fuel storage pool(s) and/or in an ISFSI until such time that it can be transferred to a DOE facility. This estimate also includes the cost to operate and eventually decommission the ISFSI.

The selection of a preferred decommissioning alternative is influenced by numerous factors at the time of plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, the status of other units at the site, regulatory requirements, and public concerns. Based on these factors, the SAFSTOR alternative has been selected (Reference 7.10).

2.2.

DECOMMISSIONING SCHEDULE The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases; 1) the initial phase begins with the permanent shutdown and through the transition to storage or decommissioning activities, 2) the next phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two; and 3) the final phase pertains to the activities involved in radiological decommissioning and license termination. The decommissioning estimates developed herein are also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures and differs from those presented by the NRC.

The major Milestones as defined by the Constellation Nuclear Management Model are:

Decommissioning Planning - begins 2 years prior to shutdown when a small utility staff, the Decommissioning Transition Organization (DTO), is established to perform planning and licensing activities and ends at plant shutdown.

This milestone is complete for TMI-1.

Shutdown through Permanent Defuel - This is a short period (< 1 month) where the plant staff defuels the reactor. The only decommissioning activity during this period is continued planning by the DTO.

This milestone is complete for TMI-1.

DECOM-2022-DCE-TMI Rev. 0 Page 4 of 23 Permanent Defuel through Zirconium Fire Window - this period runs from permanent defuel until the end of the Zirconium fire (Zirc fire) window when the fuel no longer has enough heat to generate Zirc fire conditions in less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. A Decommissioning Organization (DO) is established during this period to meet all security, emergency planning, and fire protection requirements, but also performs activities to deenergize and deactivate plant systems and initiate the pool to pad activities required to move all the spent fuel from the SFP to the ISFSI.

This milestone is complete for TMI-1.

End of Zirc Fire Window through All Fuel on Pad - Fuel is moved from the pool to the pad, and emergency planning and insurance requirements are reduced due to the end of the Zirc fire window.

All Fuel On The Pad through All Fuel Shipped To DOE and License Termination -

Further reduction in emergency planning and security requirements due to the fact that all fuel has been shipped off-site to the DOE. This period ends when the NRC license has been terminated.

Site Restoration - after the license has been terminated, final demolition of any non-radiological structures, site grading and preparation for reuse of the land can be completed.

2.2.1.

SAFSTOR Schedule 2.2.1.1.

Pre-shutdown and Period 1 (Shutdown through Transition) - Preparations Prior to the permanent shutdown and defueling, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, characterization of the facility and major components, and the development of the Post Shutdown Decommissioning Activities Report (PSDAR).

Following the final shutdown and defueling, the site will be prepared to minimize operation and maintenance to those systems/components/areas that are required to support the safe handling and management of spent fuel. Those systems/components that will not be required will be isolated and removed from service. Radiation controls will be put in place to reduce radiation and contamination in areas that will need to be accessed to support decommissioning. Areas not needed will have access restricted to minimize radiation/contamination exposure and potential safety hazards. ISFSI construction will occur and spent fuel in the spent fuel storage pool will be transferred to the ISFSI. The security area will be adjusted to reflect protection of equipment and areas necessary to support the safe handling and management of spent fuel.

This period is complete for TMI-1.

2.2.1.2.

Period 2 - Dormancy Phase The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phase of the SAFSTOR scenario. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, maintenance of necessary area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. Resident maintenance

DECOM-2022-DCE-TMI Rev. 0 Page 5 of 23 personnel will perform maintenance and inspection activities to maintain safe conditions. The transfer of the spent fuel from the spent fuel pool to the ISFSI continues during this period until complete. Additionally, the transfer of the spent fuel to a DOE facility occurs during this period.

2.2.1.3.

Period 3 - Site Reactivation and Decommissioning Preparations Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for decommissioning activities and the writing of work packages, activity specifications and decommissioning procedures are initiated. The environmental impact associated with the planned decommissioning activities is also considered. If the consequences of a planned decommissioning activity are predicted to be greater than what is bounded by previously evaluated environmental assessments or impact statements, a license amendment would have to be submitted to the NRC for the specific activity and the environmental report would have to be updated.

2.2.1.4.

Period 4 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures. Existing facilities will be modified, and/or temporary facilities will be constructed to support decommissioning, decontamination, and dismantling activities. Components and piping systems will be decontaminated as necessary to control (minimize) worker exposure and facilitate packaging and transportation. Piping and components no longer essential to support decommissioning operations will be removed. The reactor internal and external components will be removed. Some larger Nuclear Steam Supply System (NSSS) components may be decontaminated and sealed in such a manner as to serve as their own shipping/burial containers. The reactor will be segmented, removed, and placed in shielded casks. Activated portions of the reactor and other biological shield walls will be demolished by controlled processes.

The License Termination Plan (LTP), which includes the Final Survey Plan, is developed, and submitted to the NRC. Once the survey is complete, the results are provided to the NRC for their review and evaluation. Once the NRC approves the LTP, the final remediation of site facilities and services may start. Subsequently, the NRC independently confirms the radiological site conditions and approves a license amendment that releases the property, inclusive of the ISFSI, for unrestricted use.

2.2.1.5.

Period 5 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin.

Remaining structures are removed, exterior walls and foundations are removed to a nominal depth of three feet below grade, and non-contaminated concrete rubble produced by demolition activities is processed and then used to backfill foundation voids. The plant area is graded and vegetation is established to inhibit erosion.

DECOM-2022-DCE-TMI Rev. 0 Page 6 of 23

3. COST ESTIMATE METHODOLOGY 3.1.

METHODOLOGY BASES The systematic approach used herein for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs. The costs and schedules follow the general guidance and sequence in Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors (Reference 7.1). The format and content of the estimates is consistent with the recommendations of Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Reference 7.2). The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates" (Reference 7.3) and the DOE "Decommissioning Handbook" (Reference 7.4).

The unit cost factors used in this analysis incorporate site-specific costs and the latest available information about worker productivity in decommissioning. The detail provided in the unit cost factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. The activity-dependent costs were estimated with the item quantities based on plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures are based on cost data from RSMeans (Reference 7.5).

Critical path was used to determine the total decommissioning program schedule and establish carrying costs, which include program management, administration, field engineering, equipment rental, quality assurance, and security.

3.2.

FINANCIAL COMPONENTS OF THE COST MODEL The cost model used provides distinct cost elements, however these distinct cost elements do not comprise the total estimated cost to accomplish the project goal. Additional factors as described below are also taken into consideration.

3.2.1.

Contingency Contingencies are necessary to provide assurance that sufficient funding will be available since the cost elements are based on ideal conditions and maximum efficiency. They are an integral part of the total cost to complete the decommissioning process and are expected to be fully expended. A contingency is then applied on a line-item basis. Contingency, in this analysis, is not intended to address changes in price escalation and inflation in the cost of decommissioning over the remaining operating life of the station, or duration of the decommissioning program and dry fuel storage period.

Constellation examined the major activities (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 10% to 75%, depending on the degree of difficulty judged to be appropriate. The contingency values used in this study are as follows:

DECOM-2022-DCE-TMI Rev. 0 Page 7 of 23 Engineering 15%

Staffing - Utility and DOC Staff 15%

Decontamination 50%

Contaminated Removal (includes contaminated component removal and contaminated concrete removal) 25%

NSSS Component Removal 25%

Reactor Segmentation 75%

Reactor Waste Packaging 25%

Reactor Waste Transport 25%

Reactor Vessel Component Disposal 50%

Contaminated Component Packaging 10%

Contaminated Component Transport 15%

Low-Level Radioactive Waste Disposal 25%

Non-Radioactive Component Removal 15%

Supplies 25%

GTCC Disposal 25%

Other - includes: Operations and Maintenance Expense, Heavy Equipment and Tooling, and Construction 15%

Energy 15%

Characterization, Licensing and Termination Surveys 30%

Taxes, Fees, and Insurance 10%

Spent Fuel Transfer Costs 15%

ISFSI Decommissioning 25%

Low-Level Radioactive Waste Processing 15%

3.2.2.

Financial Risk This cost study does not include any specific costs for financial risk since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.

3.2.3.

Work Difficulty Factors Work difficulty factor (WDF) adjustments have been applied to account for the inefficiencies in working in a power plant environment. WDFs were assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined and/or hazardous environments. The study applies WDFs to account for use of radiological dose minimization practices (e.g., radiological protection instruction, mock-up training, and use of respiratory protection and protective clothing). Changes to worker exposure limits may also impact the decommissioning cost and project schedule.

The factors and their associated range of values were developed in conjunction with the process described in AIF/NESP-036 (Reference 7.3).

DECOM-2022-DCE-TMI Rev. 0 Page 8 of 23 3.2.4.

Scheduling Program Durations The WDF adjusted unit factors are applied against the inventory of materials to be removed in the radiologically controlled areas. The resulting work hours are used to develop the decommissioning program schedule. The scheduling of conventional removal and dismantling activities are based upon productivity information from RSMeans (Reference 7.5). Dismantling of the fuel handing systems and decontamination of the spent fuel pools is dependent upon the timing of the transfer of the spent fuel assemblies to the ISFSI.

The program schedule is used to determine the period-dependent costs for program management, administration, field engineering, equipment rental, contracted services, etc. The study relies upon regional or site-specific salary and wage rates for the personnel associated with the intended program.

DECOM-2022-DCE-TMI Rev. 0 Page 9 of 23

4. ASSUMPTIONS The cost estimate herein is based on TMI-1 having ceased operation in September 2019 and the decommissioning activities completed as of December 31, 2021. The cost to complete decommissioning is estimated. This estimate includes resources to support the engineering, planning, and licensing efforts. The ISFSI is assumed to remain operational until the DOE transfers the spent fuel offsite. The estimate also includes the dismantling of non-essential structures and limited restoration of the site.

4.1.

GENERAL 4.1.1.

Energy The physical plant is assumed to be de-energized, except for those facilities associated with spent fuel storage. Minimal energy usage is assumed to support remaining plant staffing. Additional energy is required during active decommissioning.

4.1.2.

Emergency Planning Federal Emergency Management Agency (FEMA) and local fees associated with emergency planning have ended. State fees associated with emergency planning are assumed to continue through 2027.

4.1.3.

Insurance Costs for continuing coverage (nuclear liability and property insurance) during decommissioning are included and based upon current premiums.

4.1.4.

Taxes Property taxes are included for all decommissioning periods. Tax payments decrease during decommissioning until reaching a minimum property tax payment for the site; this level is maintained for the balance of the decommissioning program.

4.1.5.

NRC Fees NRC charges are included to support the decommissioning program. The license fee is reduced based on the NRC fees for a reactor in a decommissioning (possession-only status). The charges associated with NRC professional services for inspections and reviews are based on the NRC hourly rate and the anticipated level of participation commensurate with the decommissioning alternative and schedule.

4.1.6.

Contaminated Soil The estimate includes an allowance for the remediation of contaminated soil at the site as documented in the 10 CFR 50.57(g) file. This portion of the estimate may be affected by future regulatory actions.

4.2.

LABOR COSTS For purposes of this analysis, it is assumed that Constellation will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. Constellation will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases. Constellation provides the total site scope during

DECOM-2022-DCE-TMI Rev. 0 Page 10 of 23 planning, transition periods, and dormancy periods. Contract personnel will provide engineering services under the direction of Constellation.

Average Constellation labor costs are based on industry wide average salaries. Craft labor rates are based on the current Constellation craft labor contract. DOC labor costs were based on industry wide average salaries. All costs include adders for pension and benefits, payroll taxes, corporate overhead, per diems, and profit where applicable. All labor costs are adjusted to account for regional differences between the sites. A profile of the projected staffing level for decommissioning is provided in Figure 4.1 4.3.

TRANSITION ACTIVITIES Those systems and components that are not needed for the safe storage and handling of spent fuel will be removed from service and deactivated. Hazardous fluids will be drained and removed from retired plant equipment. Operating waste inventories will be processed by plant staff during the transition period.

Operation and maintenance costs for the spent fuel pool(s) are included within the estimates until the spent fuel has been transferred to the ISFSI.

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

4.4.

NON-RADIOACTIVE WASTE 4.4.1.

Processed Water It is assumed that all water released will meet the state and federal release limits. These estimates assume that processed water which meets state and federal release limits is disposed of without additional cost.

4.4.2.

Asbestos Abatement An allowance for the removal of asbestos has been added to the estimates to account for the removal and disposal costs.

4.4.3.

Scrap and Salvage Metallic material generated is processed to the greatest extent possible to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration.

The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. No credit is taken for salvage value since it would be speculative, and any recovered value would be small in comparison to the overall decommissioning expenses.

4.5.

RADIOACTIVE WASTE The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities of radioactive material.

DECOM-2022-DCE-TMI Rev. 0 Page 11 of 23 The waste material generated in the decontamination and dismantling of the site is primarily generated during Period 4. Material that is considered potentially contaminated is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal.

The volumes of radioactive waste generated during the various decommissioning activities are calculated based on the container size and are summarized consistent with 10 CFR 61 classifications. Table 4.1 provides the radwaste volumes by class expected to be generated during decommissioning.

4.5.1.

Low-Level Radioactive Waste Disposal A significant portion of the waste material may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. The estimates reflect the savings from waste recovery/volume reduction when feasible.

All options and services currently available to Constellation were taken into consideration regarding the disposition of the various waste streams produced by the decommissioning process. Disposal fees are calculated using representative costs. The disposal costs for Class A, B and C waste were based upon a representative Constellation fleet cost. Class A waste is assumed to be disposed of at a facility in Utah. This facility is not licensed to receive Class B and C wastes. Class B and C waste is assumed to be disposed of at a facility in Texas.

The waste volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

4.5.2.

Greater Than Class C Radioactive Waste The dismantling of the components residing closest to the reactor core generally generates radioactive waste considered unsuitable for shallow-land disposal (i.e., low-level waste with concentrations greater than the NRC limits for Class C waste (i.e., GTCC)). A small quantity of material generated during decommissioning will be GTCC waste; GTCC waste is expected to be a small percentage of the total waste volume. GTCC waste is assumed to be placed in spent fuel storage canisters and disposed of in a similar manner to that envisioned for spent fuel disposal.

The federal government has the responsibility for the disposal of this material. However, the federal government has not identified a cost for disposing of GTCC, a schedule for acceptance, nor acceptance criteria for this material. For purposes of this analysis, the GTCC radioactive waste is assumed to be packaged and disposed of in a similar manner as high-level waste and at a cost equivalent to that envisioned for the spent fuel.

GTCC canisters will remain in storage until such time the DOE is ready to accept GTCC waste; it is assumed that the DOE would not accept this waste prior to completing the transfer of spent fuel.

4.5.3.

Transportation Methods The transport of all waste material and components will be by a combination of truck and/or multi-wheeled transporter. Transportation costs for material requiring controlled disposal or processing are based upon the mileage to the respective disposal or processing site.

DECOM-2022-DCE-TMI Rev. 0 Page 12 of 23 4.6.

COMPONENT REMOVAL 4.6.1.

Reactor Vessel and Internal Components The curie contents of the reactor vessel and internals are derived from those listed in NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," (Reference 7.6) and are based on a generic model for the reactor design. Additional short-lived isotopes were derived from NUREG/CR-0130, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," (Reference 7.7) and NUREG/CR-0672, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," (Reference 7.7) and benchmarked to the long-lived values from NUREG/CR-3474 (Reference 7.6).

The reactor pressure vessel and internal components are assumed to be segmented for disposal in shielded, reusable transportation casks. Transportation cask specifications and transportation regulations dictate the segmentation and packaging methodology. Due to the uncertainty in the viability of disposing of the reactor vessel and internals as a self-contained package, segmentation is assumed as a bounding condition.

4.6.2.

System Components Reactor piping and other NSSS components will be removed. Specialized equipment will be brought in as necessary. With proper closure of all openings, access ways, and penetrations, some larger components may be used as their own shipping and burial containers.

Radioactive piping and components will be removed using methods appropriate with their potential contamination level. Non-contaminated piping and components will be removed using conventional dismantlement and removal processes.

Components will be packaged and readied for transport in accordance with the intended disposition.

4.6.3.

Retired Components The estimate includes the cost to dispose of: two retired steam generators, one reactor coolant pump motor, and sections of the NSSS piping. Since these components were removed from the plant prior to permanent shutdown, only packaging, disposal, and transportation costs are included for these components.

4.7.

SPENT FUEL MANAGEMENT Since the DOE is ultimately responsible for spent fuel disposal, the cost to dispose of spent fuel is not reflected within the estimates. However, the costs for spent fuel management while the fuel remains onsite are included and identified separately as "Spent Fuel Management.

Constellation assumes, for the purposes of this estimate, that the spent fuel will be packaged into multi-purpose containers (MPCs) over the first 3 years after shutdown. It is assumed that this period provides the necessary cooling for the spent fuel from the final core to meet the transport and/or storage requirements for decay heat. The estimate includes the cost for the labor and equipment to transfer and load each MPC and relocate it to the ISFSI. For estimating purposes, an allowance is used to estimate the cost to transfer the fuel containers from the ISFSI onto the transport vehicle for removal from the site by the DOE.

Given the status of the DOE spent fuel program, Constellation estimates that 2035 will be the most likely year when the DOE begins spent fuel removal from the industry. Constellation

DECOM-2022-DCE-TMI Rev. 0 Page 13 of 23 assumed that the DOEs repository will have a maximum annual capacity of receiving 3,000 metric tons of uranium from the industry (Reference 7.9) and that the repository will accept spent fuel in the order in which it was removed (oldest fuel first). Additionally, Constellation assumes that it can re-assign its DOE spent fuel allocations between its large fleet of units to minimize on-site storage costs.

Based on the above, the spent fuel is projected to remain onsite until the end of 2041. Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will result in spent fuel remaining at the site longer.

4.8.

INDEPENDENT SPENT FUEL INSTALLATION 4.8.1.

Construction, Operation and Maintenance An ISFSI has been constructed on site to support storage of all spent fuel. The ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. Operation and maintenance costs for the ISFSI are included as "Spent Fuel Management" expenditures in this cost estimate.

4.8.2.

ISFSI Decommissioning The ISFSI site and associated facilities also must have a proposed decommissioning plan. The cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities, 2) an adequate contingency factor (see Section 3.2.1),

and 3) the cost of meeting the criteria for unrestricted use.

4.9.

SITE RESTORATION The cost for the site restoration of non-contaminated structures has been calculated and is separately presented as "Site Restoration expenditures in this report.

While some structures may be dismantled, and the costs included in the decontamination process, the dismantlement of the remaining site structures are included in the site restoration costs. All structures are assumed to be removed to a nominal depth of three feet below grade and the voids backfilled with clean debris then topped with soil. Bulk excavation of soil and material in the immediate vicinity of the reactor building is included to remove various duct banks, catch basins, and underground utilities that may exist. The site will then be graded to conform to the adjacent landscape and vegetation established to inhibit erosion.

Site utility and service piping are abandoned in place and manholes are backfilled. Asphalt surfaces and facility roads, except for the site access road, will be broken up and the material used as backfill on site.

The existing electrical switchyard is assumed to remain functional in support of the regional electrical distribution system.

4.10. SITE CONDITIONS FOLLOWING DECOMMISSIONING Once the NRC determines that site radiological remediation has been performed in accordance with the LTP and the final radiation survey demonstrates that the facility is suitable for release, the NRC will terminate the facility license(s) (or amend the license(s) if an ISFSI is still present).

Building codes and environmental regulations will dictate the remaining actions in the decommissioning process.

DECOM-2022-DCE-TMI Rev. 0 Page 14 of 23 Figure 4-1: Total Labor Hours

DECOM-2022-DCE-TMI Rev. 0 Page 15 of 23 Table 4-1: Burial Volumes by Waste Category Class/Type Volume(cf)

Mass(lb)

A/Bulk 71,543 5,199,262 A/Containerized 239,310 14,247,161 A/DAW 22,854 457,085 A/Lead 265 187,500 A/Oil 401 25,035 A/Processed 302,461 12,606,201 B

983 151,482 B/Resin 2,149 141,857 C

382 58,900 GTCC 1,632 333,698 Total/Disposal 641,981 33,408,181

DECOM-2022-DCE-TMI Rev. 0 Page 16 of 23

5. SCHEDULE 5.1.

SCHEDULE ASSUMPTIONS The schedule for the decommissioning follows the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect spent fuel management plans.

The work activity durations are based on adjusted actual person-hour estimates. Durations are established between several milestones in each decommissioning period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is also used for the spent fuel cooling period, which determines the release of the spent fuel building for final decontamination. The project schedule is included in Table 5-1.

Table 5-1: Decommissioning Timeline Plant Status / Decommissioning Activities Start End Approximate Duration (years)

Pre-Shutdown Pre-Shutdown Planning complete complete Preparations for D&D Plant Shutdown / Defueling Outage complete complete Fuel to the ISFSI Pad In-progress July 2022 Dormancy with fuel onsite Aug 2022 Sept 2040 8.0 Fuel Shipping Sept 2040 Dec 2041 1.3 Dormancy with all fuel offsite Jan 2042 Aug 2073 31.8 Preparations for D&D Aug 2073 Aug 2074 1.0 Decommissioning Operations Large Component Removal Aug 2074 June 2077 2.8 Plant Systems Removal and Building Decontamination June 2077 Dec 2078 1.5 License Termination Dec 2078 Sept 2079 0.8 Total from Shutdown to Completion of License Termination Sept 2019 Sept 2079 60 Site Restoration Sept 2079 Sept 2081 2.0

DECOM-2022-DCE-TMI Rev. 0 Page 17 of 23

6. COST ESTIMATE The cost estimate herein is based on TMI-1 having ceased operation in September 2019 and the decommissioning activities completed as of December 31, 2021. The cost to complete decommissioning is estimated and includes the remaining cost to decontaminate the nuclear unit, manage the spent fuel until the DOE transfers it to a federal facility, dismantle the plant and restore the site for alternative use. Costs are not inflated, escalated, or discounted over the period of expenditure.

Table 6.1 summarizes the estimated costs for the SAFSTOR scenario reflecting the various cost elements. Table 6.2 provides yearly expenditures broken down by cost contributor. The detailed cost estimate is provided in Table 6.3.

DECOM-2022-DCE-TMI Rev. 0 Page 18 of 23 Table 6-1: TMI-1 SAFSTOR Alternative (thousands, June 2022 dollars)

Cost Element Total Decontamination 5,250 Removal 174,165 Packaging 32,400 Transportation 13,722 Waste Disposal 52,405 Waste Processing 9,560 Program Management1 461,312 Security 191,279 Spent Fuel Storage 39,441 Insurance and Regulatory Fees 61,160 Energy 21,413 Characterization and Licensing Surveys 5,503 Property Taxes 6,212 Miscellaneous Equipment and Supplies 45,473 Total2 1,119,295 Cost Element Total Radiological Decommissioning 884,419 Spent Fuel Management 121,824 Site Restoration 105,364 ISFSI Radiological Decommissioning 7,687 Radiological Decommissioning Planning 0

Total2 1,119,295 1 Includes engineering costs 2 Columns may not add up due to rounding

DECOM-2022-DCE-TMI Rev. 0 Page 19 of 23 Table 6-2: Total Annual Expenditures (thousands, June 2022 dollars)

Year Radiological Decommissioning SpentFuel Management Site Restoration ISFSIRadiological Decommissioning Decommissioning Planning Total 2022 41,892 27,789 97 0

0 69,778 2023 22,801 4,847 178 0

0 27,826 2024 6,221 3,942 0

0 0

10,163 2025 6,228 3,800 0

0 0

10,028 2026 6,242 3,788 0

0 0

10,030 2027 6,245 3,788 0

0 0

10,032 2028 6,530 4,215 0

0 0

10,745 2029 6,513 4,203 0

0 0

10,716 2030 6,513 4,203 0

0 0

10,716 2031 6,513 4,203 0

0 0

10,716 2032 6,530 4,215 0

0 0

10,745 2033 6,513 4,203 0

0 0

10,716 2034 6,513 4,203 0

0 0

10,716 2035 6,513 4,203 0

0 0

10,716 2036 6,530 4,215 0

0 0

10,745 2037 6,513 4,203 0

0 0

10,716 2038 6,513 4,203 0

0 0

10,716 2039 6,513 4,203 0

0 0

10,716 2040 6,235 7,968 0

0 0

14,203 2041 5,628 15,430 0

0 0

21,058 2042 6,706 0

0 0

0 6,706 2043 6,706 0

0 0

0 6,706 2044 6,724 0

0 0

0 6,724 2045 6,706 0

0 0

0 6,706 2046 6,706 0

0 0

0 6,706 2047 6,706 0

0 0

0 6,706 2048 6,724 0

0 0

0 6,724 2049 6,706 0

0 0

0 6,706 2050 6,706 0

0 0

0 6,706 2051 6,706 0

0 0

0 6,706 2052 6,724 0

0 0

0 6,724 2053 6,706 0

0 0

0 6,706 2054 6,706 0

0 0

0 6,706 2055 6,706 0

0 0

0 6,706 Columnsmaynotaddupduetorounding

DECOM-2022-DCE-TMI Rev. 0 Page 20 of 23 Table 6-2: Total Annual Expenditures (continued)

(thousands, June 2022 dollars)

Year Radiological Decommissioning SpentFuel Management Site Restoration ISFSIRadiological Decommissioning Decommissioning Planning Total 2056 6,724 0

0 0

0 6,724 2057 6,706 0

0 0

0 6,706 2058 6,706 0

0 0

0 6,706 2059 6,706 0

0 0

0 6,706 2060 6,724 0

0 0

0 6,724 2061 6,706 0

0 0

0 6,706 2062 6,706 0

0 0

0 6,706 2063 6,706 0

0 0

0 6,706 2064 6,724 0

0 0

0 6,724 2065 6,706 0

0 0

0 6,706 2066 6,706 0

0 0

0 6,706 2067 6,706 0

0 0

0 6,706 2068 6,724 0

0 0

0 6,724 2069 6,706 0

0 0

0 6,706 2070 6,706 0

0 0

0 6,706 2071 6,706 0

0 0

0 6,706 2072 6,724 0

0 0

0 6,724 2073 26,677 0

47 0

0 26,723 2074 74,136 0

526 0

0 74,662 2075 97,315 0

1,215 0

0 98,530 2076 97,581 0

1,218 0

0 98,800 2077 92,716 0

1,365 0

0 94,081 2078 85,305 0

1,478 7,687 0

94,470 2079 22,964 0

12,845 0

0 35,809 2080 0

0 48,951 0

0 48,951 2081 0

0 37,445 0

0 37,445 Total 884,419 121,824 105,364 7,687 0

1,119,295 Columnsmaynotaddupduetorounding

DECOM-2022-DCE-TMI Rev. 0 Page 21 of 23 Table 6-3: Total Cost by WBS (thousands, June 2022 dollars)

Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security SpentFuel Storage Insuranceand Regulatory Fees Energy Characterization andLicensing Surveys Property Taxes Miscellaneous Equipmentand Supplies Grandtotal 02PlantDeactivationCosts 02.0101UtilityStaff 0

0 0

0 28,613 0

0 0

28,613 02.0102SecurityStaff 0

0 0

6,393 0

0 0

0 6,393 02.0104BSCOverhead 0

0 0

0 5,426 0

0 0

5,426 02.0301Insurance 0

0 0

996 0

0 0

0 996 02.0501HeavyEquipment 0

1,420 0

0 0

0 1,420 02.0503HealthPhysicsSupplies 0

128 0

0 0

0 128 02.0504MaintenanceSupplies 0

0 0

639 639 02.0508SpentFuelPoolO&MSupplies 0

0 0

797 797 02.0601PlantEnergy 0

0 0

0 2,634 0

0 0

2,634 02.0702HazardousLiquidRemediation 0

275 0

0 0

0 275 02.0801NRCFees 0

0 0

1,104 0

0 0

0 1,104 02.1101Modifications 0

0 0

3,153 3,153 02.1801ProcessDecommissioningWaterWaste 0

0 7

87 866 0

0 0

0 690 1,651 02.1901SiteUpkeep 0

0 0

1,472 0

0 0

628 2,099 02.2301DisposalofDryActiveWaste 0

0 1

2 18 0

0 0

21 02.3701Severance 0

0 0

0 8,394 0

0 0

8,394 03SafeStorageOperationsCosts 03.0101UtilityStaff 0

0 0

0 128,031 0

0 0

128,031 03.0102SecurityStaff 0

0 0

82,520 0

0 0

0 82,520 03.0104BSCOverhead 0

0 0

0 21,019 0

0 0

21,019 03.0301Insurance 0

0 0

27,952 0

0 0

0 27,952 03.0503HealthPhysicsSupplies 0

3,579 0

0 0

0 3,579 03.0504MaintenanceSupplies 0

0 0

7,608 7,608 03.0601PlantEnergy 0

0 0

0 9,590 0

0 0

9,590 03.0801NRCFees 0

0 0

17,898 0

0 0

0 17,898 03.1901SiteUpkeep 0

0 0

1,449 0

0 0

22,395 23,844 03.2301DisposalofDryActiveWaste 0

0 18 63 513 0

0 0

594 03.1101Modifications 0

0 0

125 125 03.0702HazardousLiquidRemediation 0

0 0

0 241 0

0 0

241 04DismantlementCosts 04.0101UtilityStaff 0

0 0

0 48,347 0

0 0

48,347 04.0102SecurityStaff 0

0 0

29,500 0

0 0

0 29,500 04.0103DOCStaff 0

0 0

0 211,201 0

0 0

211,201 04.0201StructureRemoval 4,075 33,019 143 564 2,090 74 0

0 0

0 39,964 04.0202SystemRemoval 368 32,750 2,285 2,766 7,251 8,062 0

0 0

0 53,482 04.0301Insurance 0

0 0

3,007 0

0 0

0 3,007 04.0401ReactorPressureVessel 0

11,062 6,354 2,020 5,903 0

0 0

25,338 04.0402ReactorPressureVesselInternals 0

10,589 11,465 1,657 12,597 0

0 0

36,307 04.0403GTCCDisposal 0

0 0

0 10,036 0

0 0

10,036 04.0501HeavyEquipment 0

29,509 0

0 0

0 29,509 04.0503HealthPhysicsSupplies 0

9,535 0

0 0

0 9,535 04.0504MaintenanceSupplies 0

0 0

1,174 1,174 04.0507PlantPreparationandTemporaryServices 0

3,579 3

12 98 0

0 0

3,693 04.0601PlantEnergy 0

0 0

0 8,361 0

0 0

8,361 04.0702HazardousLiquidRemediation 0

0 41 28 97 0

0 0

165 04.0703LeadRemediation 0

0 12 89 0

84 0

0 0

0 185 04.0801NRCFees 0

0 0

3,233 0

0 0

0 3,233 04.0901Asbestos 0

9,375 0

0 0

0 9,375 04.1301Pressurizer 0

119 403 279 232 0

0 0

1,033 04.1302PressurizerReliefTank 0

19 79 210 175 0

0 0

483 04.1303Condenser 0

316 0

0 0

0 316 04.1304TurbineGenerator 0

313 0

0 0

0 313 04.1305SteamGenerators 0

2,642 4,991 931 1,872 0

0 0

10,436 04.1305RRetiredSteamGenerators 0

0 4,991 931 1,872 0

0 0

7,794 04.1306RecircPumps/ReactorCoolantPumps 0

659 703 420 630 0

0 0

2,413 04.1306RRetiredRecircPumps/ReactorCoolantPumps 0

0 175 70 158 0

0 0

402 04.1401SiteExcavation 0

923 126 1,987 2,800 0

0 0

0 2

0 0

5,838

DECOM-2022-DCE-TMI Rev. 0 Page 22 of 23 Table 6-3: Total Cost by WBS (continued)

(thousands, June 2022 dollars)

Columnsmaynotaddupduetorounding Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security SpentFuel Storage Insuranceand Regulatory Fees Energy Characterization andLicensing Surveys Property Taxes Miscellaneous Equipmentand Supplies Grandtotal 04.1701Scaffolding 0

7,776 97 40 137 0

0 0

8,051 04.1801ProcessDecommissioningWaterWaste 0

0 21 251 2,494 0

0 0

0 2,094 4,859 04.1901SiteUpkeep 0

0 0

3,080 3,080 04.2101SpentFuelRackRemoval 808 1,165 248 625 1,087 0

0 0

3,933 04.2301DisposalofDryActiveWaste 0

0 16 57 466 0

0 0

539 04.2601DOCRelocation 0

0 0

0 780 0

0 0

780 04.2700MiscDecommissioningWaste 0

0 63 103 55 675 0

0 0

0 896 04.2801Cofferdams 0

1,475 0

0 0

0 1,475 04.2901SiteGradingandLandscaping 0

5,089 0

0 0

0 5,089 04.3103RemoveRubble/BackfillSite 0

2,946 0

0 0

0 2,946 04.3300RadiationSurveys 0

0 0

5,381 0

0 5,381 04.3401ParabolicCoolingTowerDemolition 0

3,686 0

0 0

0 3,686 04.3701Severance 0

0 0

0 3,279 0

0 0

3,279 04.3201ContractedEngineeringAnalyses 0

0 0

0 129 0

0 0

129 05ISFSICosts 05.0101UtilityStaff 0

0 0

0 4,408 0

0 0

4,408 05.0102SecurityStaff 0

0 0

72,866 0

0 0

0 72,866 05.0301Insurance 0

0 0

416 0

0 0

0 416 05.0501HeavyEquipment 0

620 0

0 0

0 620 05.0504MaintenanceSupplies 0

0 0

64 64 05.0601PlantEnergy 0

0 0

0 828 0

0 0

828 05.0801NRCFees 0

0 0

634 0

0 0

0 634 05.1201FuelfromPooltoPad 0

0 0

0 23,561 0

0 0

23,561 05.1202FuelfromPadtoDOE 0

0 0

0 13,800 0

0 0

13,800 05.1601ISFSILicenseTerminationPlanning 0

0 0

0 119 0

0 0

119 05.1602ISFSILicenseTerminationRadiologicalD&D 0

259 158 531 716 665 0

0 0

0 2,328 05.1603ISFSILicenseTerminationSurveys 0

0 0

0 1,960 0

0 0

1,960 05.1604ISFSISiteRestoration 0

1,339 0

0 0

0 1,339 05.1901SiteUpkeep 0

0 0

3,027 3,027 05.3202ContractedEngineeringAnalysesISFSI 0

0 0

0 504 0

0 0

504 05.3300RadiationSurveys 0

0 0

120 0

0 120 05.3701Severance 0

0 0

0 1,180 0

0 0

1,180 05.4201FuelStorageFee 0

0 0

3,000 0

0 0

0 3,000 06PropertyTaxCosts 06.0302PropertyTaxes 0

0 0

0 6,212 0

6,212 5,250 174,165 32,400 13,722 52,405 9,560 461,312 191,279 39,441 61,160 21,413 5,503 6,212 45,473 1,119,295 Grandtotal

DECOM-2022-DCE-TMI Rev. 0 Page 23 of 23

7. REFERENCES 7.1.

Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors, Revision 1, Nuclear Regulatory Commission, October 2013 7.2.

Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Nuclear Regulatory Commission, February 2005 7.3.

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

7.4.

"Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980, W.J. Manion and T.S. LaGuardia 7.5.

Construction Cost Information, RSMeansonline.com, Gordian Company 7.6.

NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, August 1984, J.C. Evans et al.

7.7.

NUREG/CR-0130 and addenda, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1978, R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr.

7.8.

NUREG/CR-0672 and addenda, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1980, H.D. Oak, et al.

7.9.

Civilian Radioactive Waste Management System Requirements Document, DOE/RW-0406, Revision 8, September 2007 7.10. Letter from M. Gallagher (Exelon) to U.S. Nuclear Regulatory Commission, Three Mile Island Nuclear Station, Unit 1 - Post-Shutdown Decommissioning Activities Report, April 5, 2019, ML19095A041.

Three Mile Island Nuclear Station - Unit 1 Minimum Formula Calculation Minimum Formula Calculation Page 1 of 2 Three Mile Island Nuclear Station - Unit 1 Minimum Formula Calculation A formula cost amount using the formula in 10 CFR 50.75(c) is not applicable to Three Mile Island, Unit 1, because it has been shut down since September 2019, and some decommissioning activities have already occurred on this unit. However, the amount to decommission Three Mile Island, Unit 1, was calculated pursuant to 10 CFR 50.75(c) to be $553.0 million (as of December 31, 2022). The calculation of this value assumes the labor, energy, and burial factors described below and does not account for decommissioning activities that have occurred for Three Mile Island, Unit 1. The site-specific cost amount reported in the Decommissioning Cost Estimate (DCE) is greater than the minimum formula cost amount, as required by 10 CFR 50.75(b)(1).

The labor, energy, and burial indexes used are consistent with those described in NUREG-1307, Revision 19, issued February 13, 2023.

The current labor cost indexes used are obtained from the Employment Cost Index, published by the U.S. Department of Labor, Bureau of Labor Statistics (BLS).

Specifically, Constellation Energy Generation, LLC (CEG) used the Employment Cost Index for total compensation for private industry workers by region. The labor adjustment factors were calculated according to Section 3.2 of NUREG-1307, Revision 19, using fourth quarter 2022 data. Table 1 shows the data used for this calculation.

Table 1: Labor Adjustment Factors Region Series ID 4Q2022 Index Number Base Lx Labor Adjustment Factor (Lx)

Northeast CIU2010000000210I 157.0 2.16 3.391 The current energy cost indexes used are obtained from Producer Price Indexes (PPI) -

Commodities, published by the U.S. Department of Labor, BLS. Specifically, CEG used the PPI for industrial electric power (WPU0543) and light fuel oils (WPU0573). The energy adjustment factors were calculated according to Section 3.3 of NUREG-1307, Revision 19, using December 2022 data. Table 2 shows the data used for this calculation.

Minimum Formula Calculation Page 2 of 2 Three Mile Island Nuclear Station - Unit 1 Minimum Formula Calculation Table 2: Energy Adjustment Factors WPU0543 - January 1986 (base value) 114.2 WPU0573 - January 1986 (base value) 82.0 WPU0543 - December 2022 (preliminary value) 279.1 WPU0573 - December 2022 (preliminary value) 392.6 Industrial electric power adjustment factor - Px 2.448 Light fuel oil adjustment factor - Fx 4.788 Energy Adjustment Factor (PWR) - Ex(PWR) 3.428 The waste burial adjustment factors used are taken from Table 2-1 of NUREG-1307, Revision 19, based on 2022 data. The adjustment factors CEG used for TMI assume the values for generators located in unaffiliated states. Table 3 summarizes the data used for the calculation of the waste adjustment factors.

Table 3: Waste Adjustment Factors LLW Burial Site Reactor Type Combination of Compact-Affiliated and Non-Compact Disposal Facilities Waste Adjustment Factor (Bx)

Generators Located in the Unaffiliated States and those Located in Compact-Affiliated States having no Disposal Facility Waste Adjustment Factor (Bx)

Generic LLW Disposal Site PWR N/A 13.711 The calculation methodology used for all adjustment factors is consistent with NUREG-1307, Revision 19.

Three Mile Island Nuclear Station - Unit 1 Annual Decommissioning Fund Cash Flow Annual Decommissioning Fund Cash Flow Page 1 of 2 Three Mile Island Nuclear Station - Unit 1 Annual Decommissioning Fund Cash Flow (December 31, 2022, dollars - thousands)

Radiological BOY BOY EOY Decommissioning Trust Trust Fund Trust Trust Spent Fuel, & Site Fund Value Fund Fund Year Restoration Cost Value(b)

Less Cost Earnings(c)

Value 2023

$28,251

$617,077

$588,826

$11,777

$600,603 2024

$10,318

$600,603

$590,285

$11,806

$602,091 2025

$10,181

$602,091

$591,910

$11,838

$603,748 2026

$10,183

$603,748

$593,565

$11,871

$605,436 2027

$10,186

$605,436

$595,250

$11,905

$607,155 2028

$10,909

$607,155

$596,246

$11,925

$608,171 2029

$10,879

$608,171

$597,292

$11,946

$609,237 2030

$10,879

$609,237

$598,358

$11,967

$610,325 2031

$10,879

$610,325

$599,446

$11,989

$611,435 2032

$10,909

$611,435

$600,525

$12,011

$612,536 2033

$10,879

$612,536

$601,657

$12,033

$613,690 2034

$10,879

$613,690

$602,810

$12,056

$614,866 2035

$10,879

$614,866

$603,987

$12,080

$616,067 2036

$10,909

$616,067

$605,158

$12,103

$617,261 2037

$10,879

$617,261

$606,381

$12,128

$618,509 2038

$10,879

$618,509

$607,630

$12,153

$619,782 2039

$10,879

$619,782

$608,903

$12,178

$621,081 2040

$14,420

$621,081

$606,661

$12,133

$618,794 2041

$21,379

$618,794

$597,415

$11,948

$609,363 2042

$6,808

$609,363

$602,555

$12,051

$614,606 2043

$6,808

$614,606

$607,797

$12,156

$619,953 2044

$6,827

$619,953

$613,126

$12,263

$625,389 2045

$6,808

$625,389

$618,580

$12,372

$630,952 2046

$6,808

$630,952

$624,144

$12,483

$636,627 2047

$6,808

$636,627

$629,818

$12,596

$642,415 2048

$6,827

$642,415

$635,588

$12,712

$648,299 2049

$6,808

$648,299

$641,491

$12,830

$654,321 2050

$6,808

$654,321

$647,512

$12,950

$660,463 2051

$6,808

$660,463

$653,654

$13,073

$666,727 2052

$6,827

$666,727

$659,900

$13,198

$673,099 2053

$6,808

$673,099

$666,290

$13,326

$679,616 Annual Decommissioning Fund Cash Flow Page 2 of 2 Three Mile Island Nuclear Station - Unit 1 Annual Decommissioning Fund Cash Flow (December 31, 2022, dollars - thousands)

Radiological BOY BOY EOY Decommissioning Trust Trust Fund Trust Trust Spent Fuel, & Site Fund Value Fund Fund Year Restoration Cost Value(b)

Less Cost Earnings(c)

Value 2054

$6,808

$679,616

$672,808

$13,456

$686,264 2055

$6,808

$686,264

$679,455

$13,589

$693,045 2056

$6,827

$693,045

$686,218

$13,724

$699,942 2057

$6,808

$699,942

$693,134

$13,863

$706,996 2058

$6,808

$706,996

$700,188

$14,004

$714,192 2059

$6,808

$714,192

$707,383

$14,148

$721,531 2060

$6,827

$721,531

$714,704

$14,294

$728,998 2061

$6,808

$728,998

$722,190

$14,444

$736,633 2062

$6,808

$736,633

$729,825

$14,597

$744,422 2063

$6,808

$744,422

$737,613

$14,752

$752,366 2064

$6,827

$752,366

$745,539

$14,911

$760,449 2065

$6,808

$760,449

$753,641

$15,073

$768,714 2066

$6,808

$768,714

$761,905

$15,238

$777,144 2067

$6,808

$777,144

$770,335

$15,407

$785,742 2068

$6,827

$785,742

$778,915

$15,578

$794,493 2069

$6,808

$794,493

$787,685

$15,754

$803,439 2070

$6,808

$803,439

$796,630

$15,933

$812,563 2071

$6,808

$812,563

$805,755

$16,115

$821,870 2072

$6,827

$821,870

$815,043

$16,301

$831,343 2073

$27,131

$831,343

$804,212

$16,084

$820,296 2074

$75,803

$820,296

$744,494

$14,890

$759,383 2075

$100,035

$759,383

$659,349

$13,187

$672,536 2076

$100,309

$672,536

$572,227

$11,445

$583,671 2077

$95,518

$583,671

$488,154

$9,763

$497,917 2078

$88,109

$497,917

$402,003

$8,040

$410,043 2079

$36,356

$410,043

$373,687

$7,474

$381,161 2080

$49,699

$381,161

$331,462

$6,629

$338,092 2081

$38,017

$338,092

$300,075

$6,001

$306,076 Total(a)

$1,057,744 (a) Cash flows may not add due to rounding (b) Reflects $0 annual amount remaining to be collected (c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i)

TMI-23-004, Updated Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

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