ML24150A005
| ML24150A005 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Salem, Hope Creek  |
| Issue date: | 12/31/2021 |
| From: | Public Service Enterprise Group, TLG Services |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML24150A002 | List: |
| References | |
| LR-N24-0040 | |
| Download: ML24150A005 (1) | |
Text
Document P07-1794-001, Rev. 0 DECOMMISSIONING COST ANALYSIS for the HOPE CREEK GENERATING STATION prepared for PSEG Nuclear LLC prepared by TLG Services, LLC Bridgewater, Connecticut December 2021 LR-N24-0040 Attachment 2 Page 1 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page iii of xxi TLG Services, LLC TABLE OF CONTENTS SECTION PAGE 1.
INTRODUCTION................................................................................................. 1-1 1.1 Objectives of Study......................................................................................... 1-1 1.2 Site Description............................................................................................... 1-2 1.3 Regulatory Guidance...................................................................................... 1-3 1.3.1 High-Level Radioactive Waste Management.................................... 1-5 1.3.2 Low-Level Radioactive Waste Disposal............................................. 1-9 1.3.3 Radiological Criteria for License Termination................................ 1-10 2.
DECOMMISSIONING ALTERNATIVES........................................................ 2-1 2.1 DECON............................................................................................................ 2-2 2.1.1 Period 1 - Preparations........................................................................ 2-2 2.1.2 Period 2 - Decommissioning Operations............................................ 2-4 2.1.3 Period 3 - Site Restoration.................................................................. 2-7 2.1.4 ISFSI Operations and Decommissioning........................................... 2-9 2.2 SAFSTOR........................................................................................................ 2-9 2.2.1 Period 1 - Preparations...................................................................... 2-10 2.2.2 Period 2 - Dormancy.......................................................................... 2-11 2.2.3 Periods 3 and 4 - Delayed Decommissioning................................... 2-12 2.2.4 Period 5 - Site Restoration................................................................ 2-13 3.
COST ESTIMATES.............................................................................................. 3-1 3.1 Basis of Estimates.......................................................................................... 3-1 3.2 Methodology.................................................................................................... 3-1 3.3 Impact of Decommissioning Multiple Reactor Units................................... 3-3 3.4 Financial Components of the Cost Model..................................................... 3-3 3.4.1 Contingency.......................................................................................... 3-3 3.4.2 Financial Risk...................................................................................... 3-6 3.5 Site-Specific Considerations........................................................................... 3-7 3.5.1 Spent Fuel Management..................................................................... 3-7 3.5.2 Reactor Vessel and Internal Components........................................ 3-10 3.5.3 Primary System Components........................................................... 3-11 3.5.4 Main Turbine and Condenser........................................................... 3-12 3.5.5 Transportation Methods.................................................................... 3-12 3.5.6 Low-Level Radioactive Waste Disposal........................................... 3-13 3.5.7 Site Conditions Following Decommissioning................................... 3-14 LR-N24-0040 Attachment 2 Page 2 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page iv of xxi TLG Services, LLC TABLE OF CONTENTS (continued)
SECTION PAGE 3.6 Assumptions.................................................................................................. 3-15 3.6.1 Estimating Basis............................................................................... 3-15 3.6.2 Labor Costs........................................................................................ 3-15 3.6.3 Design Conditions.............................................................................. 3-16 3.6.4 General............................................................................................... 3-17 3.7 Cost Estimate Summary............................................................................. 3-19 4.
SCHEDULE ESTIMATE.................................................................................... 4-1 4.1 Schedule Estimate Assumptions................................................................... 4-1 4.2 Project Schedule.............................................................................................. 4-2 5.
RADIOACTIVE WASTES................................................................................... 5-1 6.
RESULTS............................................................................................................... 6-1 7.
REFERENCES...................................................................................................... 7-1 TABLES SAFSTOR Alternative, Decommissioning Cost Elements............................. xxi 3.2 SAFSTOR, Total Annual Expenditures........................................................ 3-27 3.2a SAFSTOR, License Termination Expenditures............................................ 3-30 3.2b SAFSTOR, Spent Fuel Management Expenditures..................................... 3-33 3.2c SAFSTOR, Site Restoration Expenditures................................................... 3-35 5.2 SAFSTOR Alternative, Decommissioning Waste Summary.......................... 5-6 6.2 SAFSTOR Alternative, Decommissioning Cost Elements............................. 6-5 LR-N24-0040 Attachment 2 Page 3 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page v of xxi TLG Services, LLC TABLE OF CONTENTS (continued)
SECTION PAGE FIGURES 3.2 Manpower Levels, SAFSTOR........................................................................ 3-37 4.1 DECON Activity Schedule............................................................................... 4-3 4.3 Decommissioning Timeline, SAFSTOR.......................................................... 4-7 5.1 Radioactive Waste Disposition........................................................................ 5-3 5.2 Decommissioning Waste Destinations, Radiological...................................... 5-4 APPENDICES B.
Unit Cost Factor Listing.................................................................................... B-1 D.
SAFSTOR, Detailed Cost Analysis.................................................................... D-1 E.
ISFSI Decommissioning...................................................................................... E-1 LR-N24-0040 Attachment 2 Page 4 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page xxi of xxi TLG Services, LLC SAFSTOR ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2021 dollars)
Cost Element Cost Decontamination 59,555 Removal 305,511 Packaging 27,587 Transportation 12,748 Waste Disposal 63,148 Off-site Waste Processing 72,822 Program Management [1]
456,037 Severance 14,836 NEI Fees 9,705 Security 200,046 Spent Fuel Pool Equipment Modifications 1,483 Spent Fuel Management [2]
165,354 Insurance and Regulatory Fees 59,660 Energy 29,364 Characterization and Licensing Surveys 42,796 Property Taxes 4,710 Miscellaneous Equipment 31,898 Total [3]
1,557,262 Cost Element Cost NRC License Termination 1,075,404 Spent Fuel Management [4]
328,275 Site Restoration 153,583 Total [3]
1,557,262
[1]
Includes engineering costs
[2] Includes costs for the dry storage system components, spent fuel loading and transfer, spent fuel pool O&M and EP fees
[3] Columns may not add due to rounding
[4] Reflects savings in ISFSI operations with the adjacent Salem Generating Station units LR-N24-0040 Attachment 2 Page 5 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 1 of 11 TLG Services, LLC
- 1. INTRODUCTION This report presents estimates of the cost to decommission the Hope Creek Generating Station (Hope Creek), for the selected decommissioning scenarios following the scheduled and permanent cessation of plant operations. The estimates are designed to provide the owner, PSEG Nuclear LLC (PSEG), with the sufficient information to assess the plant owners financial obligations, as they pertain to the eventual decommissioning of the nuclear station.
The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2018,[1]* updated to reflect current assumptions pertaining to the disposition of the nuclear plant and relevant industry experience in undertaking such projects. The costs are based on several key assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, performance uncertainties (contingency) and site restoration requirements.
The analysis is not a detailed engineering evaluation, but an estimate prepared in advance of the detailed engineering required to carry out the decommissioning of the nuclear unit. It may also not reflect the actual plan to decommission Hope Creek; the plan may differ from the assumptions made in this analysis based on facts that exist at the time of decommissioning.
The 2018 plant inventory, the basis for the decontamination and dismantling requirements and cost, and the decommissioning waste streams, was reviewed for this analysis.
1.1 OBJECTIVES OF STUDY The objectives of this study are to prepare comprehensive estimates of the cost to decommission Hope Creek, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.
The operating license for Hope Creek was originally scheduled to expire at midnight on April 11, 2026. PSEG submitted an application to renew the license for an additional twenty years in August 2009. The application was subsequently approved in July 2011. As such, this analysis assumes that the unit will operate until midnight, April 11, 2046.
- Annotated references for citations in Sections 1-6 are provided in Section 7.
LR-N24-0040 Attachment 2 Page 6 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 2 of 11 TLG Services, LLC 1.2 SITE DESCRIPTION Hope Creek is located on the southern part of Artificial Island on the east bank of the Delaware River in Lower Alloways Creek Township, Salem County, New Jersey. The site is 15 miles south of the Delaware Memorial Bridge, 18 miles south of Wilmington, Delaware, 30 miles southwest of Philadelphia, Pennsylvania, and 71/2 miles southwest of Salem, New Jersey.
The Nuclear Steam Supply System (NSSS) consists of a boiling water reactor and a two-loop recirculation system. In 2018, an extended power uprate was authorized, increasing the authorized maximum power level by approximately 1.6 percent. This increased the thermal power rating of 3,840 MWt to 3,902 MWt (thermal), with a corresponding net electrical output of 1,219 megawatts (electric).
The two-loop reactor recirculation system contains two, vertical centrifugal pumps and is located within the primary containment structure. This structure consists of the drywell, the suppression system, and interconnecting vent system.
The drywell is a steel pressure vessel in the shape of a light bulb. The pressure suppression chamber is a torus-shaped steel pressure vessel located below and encircling the drywell.
This chamber is connected to the drywell by eight equally spaced vent pipes.
These vent pipes are connected to a common header within the suppression chamber. Eighty downcomers, connected to the header, terminate below the water level of the suppression pool. As a system, the drywell, suppression chamber, and interconnecting piping, acts to reduce the pressure increase in the event of a local process system piping failure.
Heat produced in the reactor is converted to electrical energy by the power conversion system. A turbine-generator system converts the thermal energy of steam produced in the reactor vessel into mechanical shaft power and then into electrical energy. The units turbine generator consists of a tandem compound, six-flow, non-reheat unit. It is comprised of one double-flow, high-pressure turbine and three double-flow, low-pressure turbines driving a direct-coupled generator at 1,800 rpm. The turbine is operated in a closed feedwater cycle, which condenses the steam; the condensate/feedwater is returned to the reactor recirculation system. Heat rejected in the main condenser is removed by the circulating water system.
The circulating water system is designed to circulate the flow of water required to remove the heat load from the main condenser and other auxiliary equipment and to discharge it to the atmosphere through a natural draft cooling tower.
LR-N24-0040 Attachment 2 Page 7 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 3 of 11 TLG Services, LLC Some heat may be rejected to the Delaware estuary from the cold water side of the cooling tower in the form of blowdown.
1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[2] This rule set forth financial criteria for decommissioning licensed nuclear power facilities.
The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose.
Subsequent to the rule, the NRC issued Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors,[3] which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.
The rule defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated or activated portion of the plants systems, structures, and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations.
The rule also placed limits on the time allowed to complete the decommissioning process. For the SAFSTOR alternative, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient leverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the definition of decommissioning.
At the conclusion of a 60-year dormancy period (or longer for ENTOMB if the NRC approves such a case), the site would still require significant remediation to meet the unrestricted release limits for license termination.
The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with rulemaking permitting the controlled release of a site,[4] the NRC did re-evaluate the alternative. The resulting feasibility study, based upon an assessment by LR-N24-0040 Attachment 2 Page 8 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 4 of 11 TLG Services, LLC Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. The staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative.
The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombments.[5] However, the NRCs staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRCs current priorities, at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.
In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.[6] When the regulations were originally adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facilitys operating licensed life. Since that time, several licensees permanently and prematurely ceased operations.
Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The new amendments allow for greater public participation and better define the transition process from operations to decommissioning.
Under the revised regulations, licensees will submit written certification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel.
Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Prior to or within 2 years following permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequence and
- schedule, and an estimate of expected costs.
Prior to completing decommissioning, the licensee is required to submit applications to the NRC to terminate the license, which will include a License Termination Plan (LTP).
In 2011, the NRC issued regulations to improve decommissioning planning and thereby reduce the likelihood that any current operating facility will become a LR-N24-0040 Attachment 2 Page 9 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 5 of 11 TLG Services, LLC legacy site.[7] The regulations require licensees to report additional details in their decommissioning cost estimate including a decommissioning estimate for the ISFSI. This estimate is provided in Appendix E.
1.3.1 High-Level Radioactive Waste Management Congress passed the Nuclear Waste Policy Act (NWPA) in 1982,[8]
assigning the federal governments long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA Amendments Act of 1987[9]
designated Yucca Mountain as the sole site to be considered for a permanent geologic repository. The DOE was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made.
Today, the country is at an impasse on high-level waste disposal, despite DOEs submittal of its License Application for a geologic repository to the NRC in 2008. The Obama administration eliminated the budget for the repository program while promising to conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle and make recommendations for a new plan. Towards this goal, the Obama administration appointed a Blue Ribbon Commission on Americas Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commissions charter included a requirement that it consider
[o]ptions for safe storage of used nuclear fuel while final disposition pathways are selected and deployed.[10]
On January 26, 2012, the Blue Ribbon Commission issued its Report to the Secretary of Energy containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are:
[T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage facilities
[T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear waste.[11]
LR-N24-0040 Attachment 2 Page 10 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 6 of 11 TLG Services, LLC In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the Blue Ribbon Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[12]
With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:
Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2021 with an initial focus on accepting used nuclear fuel from shut-down reactor sites; Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and Makes demonstrable progress on the siting and characterization of repository sites to facilitate the availability of a geologic repository by 2048.
The NRCs review of DOEs license application to construct a geologic repository at Yucca Mountain was suspended in 2011, when the Obama administration significantly reduced the budget for completing that work. However, the US Court of Appeals for the District of Columbia Circuit issued a writ of mandamus (in August 2013)[13] ordering NRC to comply with federal law and resume its review of DOE's Yucca Mountain repository license application to the extent allowed by previously appropriated funding for the review. That review was completed with the publication of a five-volume safety evaluation report.
A supplement to DOEs environmental impact statement and adjudicatory hearing on the contentions filed by interested parties must be completed before a licensing decision can be made. Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report.
Holtec International submitted a license application to the NRC on March 30, 2017 for a consolidated interim spent fuel storage facility in southeast New Mexico called HI-STORE CIS (Consolidated Interim LR-N24-0040 Attachment 2 Page 11 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 7 of 11 TLG Services, LLC Storage) under the provisions of 10 CFR Part 72. The application is currently under NRC review.
Waste Control Specialists submitted an application to the NRC on April 28, 2016, to construct and operate a Consolidated Interim Storage Facility (CISF) at its West Texas facility. On April 18, 2017, WCS requested that the NRC temporarily suspend all safety and environmental review activities, as well as public participation activities associated with WCSs license application. In March 2018, WCS and Orano USA, announced their intent to form a joint venture to license the facility. The joint venture has stated that they will request that the NRC resume its review of the original CISF license application.
On May 10, 2018, the U.S. House of Representatives passed H.R. 3053, the Nuclear Waste Policy Amendments Act of 2018. Proposed to amend the Nuclear Waste Policy Act of 1982, the legislation, if approved by the Senate and signed by the President, would provide the DOE the authority to site, construct, and operate one or more Monitored Retrieval Storage (MRS) facilities while a permanent repository is licensed and constructed and/or to enter into an MRS agreement with a non-Federal entity for temporary storage.
PSEGs current spent fuel management plan for Artificial Island assumes just-in-time acceptance, i.e., the DOE will be able to complete the transfer of spent fuel so as not to impede a deferred decommissioning scenario (SAFSTOR) and the termination of the earliest operating license (Salem Generating Station, Unit 1) within the required 60-year period (from the cessation of operations). To achieve this objective, based upon the oldest fuel receiving the highest priority and an annual maximum rate of transfer of 3,000 metric tons of uranium, DOE would commence pickup of spent fuel from Hope Creek no later than 2042, with fuel completely removed from Artificial Island by 2088. Different DOE acceptance schedules result in different completion dates.
The NRC requires that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[14] This requirement is prepared for through inclusion of certain cost elements in the decommissioning estimates, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.
LR-N24-0040 Attachment 2 Page 12 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 8 of 11 TLG Services, LLC The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following three and one-half years, the assemblies are packaged into MPCs for transfer to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the storage requirements for decay heat.
An ISFSI, operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[15]), has been constructed to support continued plant operations. The facility is assumed to be expanded to support decommissioning. This will allow decommissioning activities to proceed within the reactor building.
Since the ISFSI is used by both Hope Creek and the adjacent Salem units, costs to operate and maintain the ISFSI are shared between the stations. The sharing on the Salem - Hope Creek site is established by a census split of personnel; Hope Creek pays for 43.0% of shared costs.
DOE has breached its obligations to remove fuel from reactor sites, and has also failed to provide the plant owners with information about how it will ultimately perform. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to DOEs contracts with plant licensees to remove the fuel (the Standard Contract), but DOE has not explained what any such amendment would involve. Consequently, the plant owner has no information or expectations on how DOE will remove fuel from the site in the future. In the absence of information about how DOE will perform, and for purposes of this analysis only, it is assumed that DOE will accept already-canistered fuel. If this assumption is incorrect, it is assumed that DOE will have liability for costs incurred to transfer the fuel to DOE-supplied containers.
PSEGs position is that the DOE has a contractual obligation to accept Hope Creeks fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, including the cost of storing spent fuel in this study is appropriate to ensure the availability of sufficient decommissioning funds at the end of the stations life if the DOE has not met its obligation. The cost for the interim storage of spent fuel has been calculated and is separately presented as "Spent Fuel Management expenditures in this report.
LR-N24-0040 Attachment 2 Page 13 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 9 of 11 TLG Services, LLC 1.3.2 Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for shallow-land disposal. With the passage of the Low-Level Radioactive Waste Policy Act in 1980,[16] and its Amendments of 1985,[17] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. It was expected that groups of states would combine together to jointly deal with their radioactive wastes; these organizations are referred to as waste disposal compacts.
New Jersey is a member of the three-state Atlantic Interstate Low-Level Radioactive Waste Management Compact, formed after South Carolina formally joined the Northeast Regional Compact. The Barnwell Low-Level Radioactive Waste Management Facility, located in South Carolina, is expected to be available to support the decommissioning of Hope Creek. As such, the rate schedule for the Barnwell facility is used to generate disposal costs for the higher activity waste forms waste (Class A containerized waste, large components and Class B and C material[18]). It is also assumed that PSEG can access other disposal sites, should it prove cost-effective. Low activity waste forms and suspected material are either routed to EnergySolutions facility in Clive, Utah or to a Tennessee-based radioactive waste processor.
The dismantling of the components residing closest to the reactor core generates radioactive waste considered unsuitable for shallow-land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste.
The DOE issued its final Environmental Impact Statement for the disposal of GTCC on January 2016.[19 ] The study evaluated the potential environmental impacts associated with constructing and operating a new facility or using an existing facility, disposal methods, and locations. DOE is awaiting Congressional action on the report and its recommendations. At this time, the federal government has not LR-N24-0040 Attachment 2 Page 14 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 10 of 11 TLG Services, LLC identified a specific cost for disposing of GTCC or a schedule for acceptance.
For purposes of this analysis only, the GTCC radioactive waste is assumed to be packaged and disposed of in a manner similar to irradiated spent fuel and at a cost equivalent to that envisioned for the spent fuel. The GTCC is packaged in the same canisters used for spent fuel and either stored on site or shipped directly to a licensed facility as it is generated (depending upon the timing of the decommissioning and whether the spent fuel has already been removed from the site prior to the start of decommissioning).
A significant portion of the metallic waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be surveyed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to isolate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates reflect the savings from waste recovery/volume reduction.
1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, Radiological Criteria for License Termination,[20] amending 10 CFR §20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).
The decommissioning estimates for Hope Creek assume that the site will be remediated to a residual level consistent with the NRC-prescribed level as well as the State of New Jerseys remedial action levels for radioactive material.
It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived LR-N24-0040 Attachment 2 Page 15 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 11 of 11 TLG Services, LLC from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).[21]
An additional limit of 4 millirem per year, as defined in 40 CFR §141.16, is applied to drinking water.[22]
On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU)[23] provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.
The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees. The present study does not include any costs for this occurrence.
LR-N24-0040 Attachment 2 Page 16 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 1 of 13 TLG Services, LLC
- 2. DECOMMISSIONING ALTERNATIVES Detailed cost estimates were developed to decommission Hope Creek based upon the approved decommissioning alternatives: DECON and SAFSTOR. Although the alternatives differ with respect to technique, process, cost, and schedule, they attain the same result: the ultimate release of the site for unrestricted use.
Two decommissioning scenarios were evaluated for the Hope Creek nuclear unit.
The scenarios selected are representative of alternatives currently available to the owner and are defined as follows:
- 1.
The first scenario assumes that the unit would be promptly decommissioned (DECON alternative) upon the expiration of the current operating license, i.e.,
in 2046. The spent fuel in the plants spent fuel storage pool is transferred to the ISFSI within three and one-half years. The equipment, structures, and portions of the plant containing radioactive contaminants are removed or decontaminated to a level that permits the facility to be released for unrestricted use. Non-essential structures are then demolished. Spent fuel storage operations continue at the site (ISFSI) until the transfer of the fuel to the DOE is complete, assumed to be in the year 2088. At that time, the ISFSI is decommissioned and the site released for alternative use.
- 2.
In the second scenario, the nuclear unit is placed into safe-storage (SAFSTOR alternative) at the end of its current operating license. The spent fuel in the plants spent fuel storage pool is transferred to the ISFSI within three and one-half years and the plant reconfigured for long-term storage. Spent fuel storage operations continue at the site until the transfer of the fuel to the DOE is complete, assumed to be in the year 2088. The unit remains in protective storage following the removal of the spent fuel. Decommissioning operations commence in 2100, with the decontamination and dismantling of Hope Creek completed in 2106, within the required 60-year period following final shutdown.
The following sections describe the basic activities associated with each alternative.
Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work (i.e., engineering and planning at the time of decommissioning).
The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both plant LR-N24-0040 Attachment 2 Page 17 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 2 of 13 TLG Services, LLC and licensee from reactor operations (i.e., power production) to facilitate de-activation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee would then be prohibited from reactor operation.
The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimates developed for Hope Creek 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.
2.1 DECON The DECON alternative, as defined by the NRC, is "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations." This study does not address the cost to dispose of the spent fuel residing at the site; such costs are funded through a surcharge on electrical generation. However, the study does estimate the costs incurred with the interim on-site storage of the fuel pending shipment by the DOE to an off-site disposal facility. Those costs are separately presented as "Spent Fuel Management Expenditures" in this report.
2.1.1 Period 1 - Preparations In anticipation of the cessation of plant operations, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Through implementation of a staffing transition plan, the organization required to manage the intended decommissioning activities is assembled from available plant staff and outside resources. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, a
characterization of the facility and major components, and the development of the PSDAR.
Engineering and Planning The PSDAR, required prior to or within two years of permanent cessation of operations, provides a description of the licensees planned decommissioning activities, a timetable, a site-specific decommissioning LR-N24-0040 Attachment 2 Page 18 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 3 of 13 TLG Services, LLC cost estimate, and the associated financial requirements of the intended decommissioning program. Upon receipt of the PSDAR, the NRC will make the document available to the public for comment in a local meeting to be held in the vicinity of the reactor site. Ninety days following submittal and NRC receipt of the PSDAR, the licensee may begin to perform major decommissioning activities under a modified 10 CFR §50.59 procedure, (10 CFR §50.59 establishes the conditions under which licensees may make changes to the facility or procedures and conduct test or experiments, i.e., without prior NRC approval). Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC, as defined by 10 CFR §61. Major components are further defined as comprising the reactor vessel and internals, large bore reactor recirculation system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the §50.59 process in decommissioning. The proposed activity must not:
foreclose release of the site for possible unrestricted use, significantly increase decommissioning costs, cause any significant environmental impact, or violate the terms of the licensees existing license Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations.
The environmental impact associated with the planned decommissioning activities is also considered. Typically, a licensee will not be allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously evaluated environmental assessments or impact statements. In this instance, the licensee would have to submit a license amendment for the specific activity and update the environmental report.
The decommissioning program outlined in the PSDAR will be designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR §20) for protection of personnel from exposure to radiation hazards. It will also address the continued protection of the health and safety of the public and the environment during the dismantling activity. Consequently, with the development of the PSDAR, activity specifications, cost-benefit and safety analyses, and LR-N24-0040 Attachment 2 Page 19 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 4 of 13 TLG Services, LLC work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities.
Site Preparations Following final plant shutdown, and in preparation for actual decommissioning activities, the following activities are initiated:
Characterization of the site and surrounding environs. This includes radiation surveys of work areas, major components (including the reactor vessel and its internals), internal piping, and primary shield cores.
Isolation of the spent fuel storage pool and fuel handling systems, such that decommissioning operations can commence on the balance of the plant. Decommissioning operations are scheduled around the fuel handling area to optimize the overall project schedule. The fuel is transferred to the ISFSI as it decays to the point that it meets the definition of standard fuel. Consequently, it is assumed that the fuel pool remains operational for approximately three and one-half years following the cessation of operations.
Specification of transport and disposal requirements for activated materials and/or hazardous materials, including shielding and waste stabilization.
Development of procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste (including dry-active waste, resins, filter media, metallic and non-metallic components generated in decommissioning), site security and emergency programs, and industrial safety.
2.1.2 Period 2 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful amendment of the 10 CFR §50 operating license (releasing the site, exclusive of the ISFSI).
Significant decommissioning activities in this phase include:
Construction of temporary facilities and/or modification of existing facilities to support dismantling activities. This may include a centralized processing area to facilitate equipment removal and component preparations for off-site disposal.
LR-N24-0040 Attachment 2 Page 20 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 5 of 13 TLG Services, LLC Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on and off site) to facilitate hauling and transport. Modifications may be required to the containment structure to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the reactor building to support the segmentation of the reactor vessel internals and component extraction.
Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.
Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages.
Decontamination of components and piping systems as required to control (minimize) worker exposure.
Removal of piping and components no longer essential to support decommissioning operations.
Transfer of the steam separator and dryer assemblies to the dryer-separator pool for segmentation. Segmentation by weight and activity maximizes the loading of the shielded transport casks. The operations are conducted under water using remotely-operated tooling and contamination controls.
Disconnection of the control blades from the drives on the vessel lower head. Blades are transferred to the spent fuel pool for packaging.
Disassembly, segmentation, and packaging of the core shroud and in-core guide tubes. Some of the material is expected to exceed Class C disposal requirements. As such, those segments are packaged in modified fuel storage canisters for geologic disposal.
Removal and segmentation of the remaining internals, fuel support castings, and core plate assembly.
Draining and decontamination of the reactor well and the permanent sealing of the spent fuel transfer gate. Installation of a shielded platform for segmentation of the reactor vessel. Cutting operations are performed in air using remotely operated equipment within a contamination control envelope, with the water level maintained just below the cut to minimize the working area dose rates. Sections are LR-N24-0040 Attachment 2 Page 21 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 6 of 13 TLG Services, LLC transferred to the dryer-separator pool for packaging and interim storage.
Disconnection of the control rod drives and instrumentation tubes from reactor vessel lower head. The lower reactor head and vessel support skirt are then segmented.
Removal of the reactor recirculation pumps. Exterior surfaces are decontaminated and openings covered. Components can serve as their own burial containers provided that all penetrations are properly sealed.
Demolition of the sacrificial shield activated concrete by controlled demolition.
At least two years prior to the anticipated date of license termination, an LTP is required. Submitted as a supplement to the Final Safety Analysis Report (FSAR) or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local meeting. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including:
Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems).
Removal of the steel liners from the drywell, disposing of the activated and contaminated sections as radioactive waste. Removal of any activated/contaminated concrete.
Removal of the steel liners from the steam separator and dryer pool, reactor well and spent fuel storage pool.
Surveys of the decontaminated areas of the containment structures.
Removal of the contaminated equipment and material from the turbine, service and radwaste buildings, and any other contaminated facility. Use radiation and contamination control techniques until radiation surveys indicate that the structures can be released for unrestricted access and conventional demolition. This activity may LR-N24-0040 Attachment 2 Page 22 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 7 of 13 TLG Services, LLC necessitate the dismantling and disposition of most of the systems and components (both clean and contaminated) located within these buildings. This activity will facilitate surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.
Removal of the remaining components, equipment, and plant services in support of the area release survey(s).
Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination is released for unrestricted disposition, e.g., as scrap, recycle, or general disposal. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.
Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).[24] This document incorporates the statistical approaches to survey design and data interpretation used by the EPA. It also identifies commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the survey is complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on the requested change to the operating license (that would release the property, exclusive of the ISFSI, for unrestricted use).
The NRC will amend the operating license if it determines that site remediation has been performed in accordance with the LTP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.
2.1.3 Period 3 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the LR-N24-0040 Attachment 2 Page 23 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 8 of 13 TLG Services, LLC NRC limits will result in substantial damage to many of the structures.
Although performed in a controlled and safe manner, blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures including the
- reactor, turbine and radwaste buildings.
Under certain circumstances, verifying that subsurface radionuclide concentrations meet NRC site release requirements will require removal of grade slabs and lower floors, potentially weakening footings and structural supports.
This removal activity will be necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station.
Dismantling of site structures following decommissioning is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The effort to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.
This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity.
Foundations and exterior walls are removed to a nominal depth of three feet below grade. The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.
Non-contaminated concrete rubble produced by demolition activities is processed to remove reinforcing steel and miscellaneous embedments.
The processed material is then used on site to backfill foundation voids.
Excess non-contaminated materials are trucked to an off-site area for disposal as construction debris.
LR-N24-0040 Attachment 2 Page 24 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 9 of 13 TLG Services, LLC 2.1.4 ISFSI Operations and Decommissioning The ISFSI will continue to operate under a general license (10 CFR §50) following the amendment of the operating license to release the adjacent (power block) property. Assuming the DOE starts accepting fuel from Hope Creek fuel in 2041 (based upon the oldest fuel receiving the highest priority and an annual maximum rate of transfer of 3,000 metric tons of uranium), transfer of spent fuel from the ISFSI is anticipated to continue through the year 2088. Throughout this period cost for operating and maintaining the ISFSI are shared with the adjacent Salem units.
At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The Commission will terminate the §50 license if it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI. Costs for demolishing the ISFSI are shared with the adjacent Salem units.
Spent fuel is stored on the ISFSI in multi-purpose canisters, each with a steel and concrete overpack. For purposes of this cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required remediation performed on the storage overpack (some minor neutron-induced activation is assumed), and the license for the facility terminated, the overpacks can be dismantled using conventional techniques for the demolition of steel and reinforced concrete. The concrete storage pad is then removed and the area regraded.
2.2 SAFSTOR The NRC defines SAFSTOR as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use." The facility is left intact (during the dormancy period), with structures maintained in a sound condition.
Systems not required to operate in support of the spent fuel pool or site surveillance and security are drained, de-energized, and secured. Minimal cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination are performed. Access to contaminated areas is secured to provide controlled access for inspection and maintenance.
LR-N24-0040 Attachment 2 Page 25 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 10 of 13 TLG Services, LLC The engineering and planning requirements are similar to those for the DECON alternative, although a shorter time period is expected for these activities due to the more limited work scope. Site preparations are also similar to those for the DECON alternative. However, with the exception of the required radiation surveys and site characterizations, the mobilization and preparation of site facilities is less extensive.
2.2.1 Period 1 - Preparations Preparations for long-term storage include the planning for permanent defueling of the reactor, revision of technical specifications appropriate to the operating conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.
The process of placing the plant in safe-storage includes, but is not limited to, the following activities:
Isolation of the spent fuel storage services and fuel handling systems located in the reactor building so that safe-storage operations may commence on the balance of the plant. This activity may be carried out by plant personnel in accordance with existing operating technical specifications. Activities are scheduled around the fuel handling systems to the greatest extent possible.
Draining and de-energizing of the non-contaminated systems not required to support continued site operations or maintenance.
Disposing of contaminated filter elements and resin beds not required for processing wastes from layup activities for future operations.
Draining of the reactor vessel, with the internals left in place and the vessel head secured.
Draining and de-energizing non-essential, contaminated systems with decontamination as required for future maintenance and inspection.
Preparing lighting and alarm systems whose continued use is required; de-energizing portions of fire protection, electric power, and HVAC systems whose continued use is not required.
Cleaning of the loose surface contamination from building access pathways.
Performing an interim radiation survey of plant, posting warning signs where appropriate.
LR-N24-0040 Attachment 2 Page 26 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 11 of 13 TLG Services, LLC Erecting physical barriers and/or securing all access to radioactive or contaminated areas, except as required for inspection and maintenance.
Installing security and surveillance monitoring equipment and relocating security fence around secured structures, as required.
2.2.2 Period 2 - Dormancy The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phases of the deferred decommissioning alternatives. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, 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 personnel perform equipment maintenance, inspection activities, routine services to maintain safe conditions, adequate lighting, heating, and ventilation, and periodic preventive maintenance on essential site services.
An environmental surveillance program is carried out during the dormancy period to ensure that releases of radioactive material to the environment are prevented and/or detected and controlled. Appropriate emergency procedures are established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program constitutes an abbreviated version of the program in effect during normal plant operations.
Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public from the consequences of their own actions. The security fence, sensors, alarms, and other surveillance equipment provide security. Fire and radiation alarms are also monitored and maintained. While remote surveillance is an option, it does not offer the immediate response time of a physical presence.
The transfer of the spent fuel to a DOE facility continues during this period until complete. Whenever possible, costs for maintaining the ISFSI are shared between Hope Creek and the adjacent Salem units.
The length of the dormancy period is such that decommissioning (license termination) is accomplished within 60 years of final shutdown. As such, LR-N24-0040 Attachment 2 Page 27 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 12 of 13 TLG Services, LLC decommissioning operations for Hope Creek are scheduled to commence in 2100, approximately 54 years after shutdown.
It is required that the licensee submit an application to terminate the license, along with a LTP (described in Section 2.1.2), thereby initiating the third phase.
2.2.3 Periods 3 and 4 - Delayed Decommissioning 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 activities and the writing of activity specifications and detailed procedures are also initiated at this time.
Much of the work in developing a termination plan is relevant to the development of the detailed engineering plans and procedures. The activities associated with this phase and the follow-on decontamination and dismantling processes are detailed in Sections 2.1.1 and 2.1.2. The primary difference between the sequences anticipated for the DECON and deferred scenarios is the absence, in the latter, of any constraint on the availability of the fuel storage pool located within the reactor building for decommissioning.
Variations in the length of the dormancy period are expected to have some effect upon the quantities of radioactive wastes generated from system and structure removal operations. However, given the levels of radioactivity and spectrum of radionuclides expected from sixty years of plant operation, no plant process system identified as being contaminated upon final shutdown will become releasable due to the decay period alone. (i.e., there is no significant reduction in the waste generated from the decommissioning activities). However, due to the lower activity levels, a greater percentage of the waste volume can be designated for off-site processing and recovery.
The delay in decommissioning also yields lower working area radiation levels. As such, the estimate for this delayed scenario incorporates reduced ALARA controls for the SAFSTOR's lower occupational exposure potential.
LR-N24-0040 Attachment 2 Page 28 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 2, Page 13 of 13 TLG Services, LLC Although the initial radiation levels due to 60Co will substantially decrease during the dormancy period, the internal components of the reactor vessel will still exhibit sufficiently high radiation dose rates to require remote sectioning under water due to the presence of long-lived radionuclides such as 94Nb, 59Ni, and 63Ni. Therefore, the dismantling procedures described for the DECON alternative would still be employed during this scenario. Portions of the sacrificial shield will still be radioactive due to the presence of activated trace elements with long half-lives (152Eu and 154Eu). Decontamination will require controlled removal and disposal. It is assumed that radioactive corrosion products on inner surfaces of piping and components will not have decayed to levels that will permit unrestricted use or allow conventional removal.
These systems and components will be surveyed as they are removed and disposed of in accordance with the existing radioactive release criteria.
2.2.4 Period 5 - Site Restoration Following completion of decommissioning operations, site-restoration activities can begin.
Dismantling, as a
continuation of the decommissioning process, is a cost-effective option, as described in Section 2.1.3. The basis for the dismantling cost in this scenario is consistent with that described for DECON, presuming the removal of structures and site facilities to a nominal depth of three feet below grade and the limited restoration of the site.
LR-N24-0040 Attachment 2 Page 29 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 1 of 37 TLG Services, LLC
- 3. COST ESTIMATES The cost estimates prepared for decommissioning Hope Creek consider the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimates, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.
3.1 BASIS OF ESTIMATES The estimates were developed using the site-specific, technical information from the 2018 analysis. This information was reviewed for the current analysis. The review confirmed that there were no substantive changes over the three-year period to the configuration of the plant or site facilities. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where experience from ongoing decommissioning programs provided viable alternatives or improved processes.
3.2 METHODOLOGY The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[25]
and the DOE "Decommissioning Handbook."[26]
These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch) were developed using local labor rates. The activity-dependent costs were estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures relied upon information available in the industry publication, 2021 "Building Construction Cost Data," published by RSMeans.[27]
The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.
LR-N24-0040 Attachment 2 Page 30 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 2 of 37 TLG Services, LLC The estimates also reflect lessons learned from TLGs involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells and associated facilities, completed in 1997. In addition, the planning and engineering for the Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, Crystal River, Vermont Yankee and Fort Calhoun nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.
Work Difficulty Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment. WDFs were assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined, hazardous environments.
The ranges used for the WDFs are as follows:
Access Factor 10% to 20%
Respiratory Protection Factor 10% to 50%
Radiation/ALARA Factor 10% to 40%
Protective Clothing Factor 10% to 30%
Work Break Factor 8.33%
The factors and their associated range of values were developed in conjunction with the AIF/NESP-036 study. The application of the factors is discussed in more detail in that publication.
Scheduling Program Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiologically controlled areas.
The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities are based upon productivity information available from the RSMeans "Building Construction Cost Data" publication.
An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning LR-N24-0040 Attachment 2 Page 31 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 3 of 37 TLG Services, LLC estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.
3.3 IMPACT OF DECOMMISSIONING MULTIPLE REACTOR UNITS The offset in shutdown dates for the Salem and Hope Creek nuclear units are such that there is little interaction in the respective decommissioning activities in a DECON scenarios, i.e., the Salem units are assumed to be decommissioned prior to the cessation of Hope Creek operations. However, ISFSI operation costs are shared over that time period that both Salem and Hope Creek spent fuel is present on site. ISFSI operations are also shared in the SAFSTOR scenario during that time period.
3.4 FINANCIAL COMPONENTS OF THE COST MODEL TLGs proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration.
3.4.1 Contingency Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages.
In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.
The activity-and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers Project and Cost Engineers' Handbook[28]
as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, a contingency factor has been applied. In the AIF/NESP-036 study, the types of unforeseeable LR-N24-0040 Attachment 2 Page 32 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 4 of 37 TLG Services, LLC events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.
The use and role of contingency within decommissioning estimates is not a safety factor issue. Safety factors provide additional security and address situations that may never occur. Contingency funds are expected to be fully expended throughout the program. They also provide assurance that sufficient funding is available to accomplish the intended tasks. An estimate without contingency, or from which contingency has been removed, can disrupt the orderly progression of events and jeopardize a successful conclusion to the decommissioning process.
For
- example, the most technologically challenging task in decommissioning a commercial nuclear plant is the disposition of the reactor vessel and internal components, now highly radioactive after a lifetime of exposure to core activity. The disposition of these components forms the basis of the critical path (schedule) for decommissioning operations. Cost and schedule are interdependent, and any deviation in schedule has a significant impact on cost for performing a specific activity.
Disposition of the reactor vessel internals involves the underwater cutting of complex components that are highly radioactive. Costs are based upon optimum segmentation, handling, and packaging scenarios.
The schedule is primarily dependent upon the turnaround time for the heavily shielded shipping casks, including preparation, loading, and decontamination of the containers for transport. The number of casks required is a function of the pieces generated in the segmentation activity, a value calculated on optimum performance of the tooling employed in cutting the various subassemblies. The expected optimization, however, may not be achieved, resulting in delays and additional program costs. For this reason, contingency must be included to mitigate the consequences of the expected inefficiencies inherent in this complex activity, along with related concerns associated with the operation of highly specialized tooling, field conditions, and water clarity.
Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a LR-N24-0040 Attachment 2 Page 33 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 5 of 37 TLG Services, LLC successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a
contingency. Individual activity contingencies ranged from 10% to 75%,
depending on the degree of difficulty judged to be appropriate from TLGs actual decommissioning experience. The contingency values used in this study are as follows:
Decontamination 50%
Contaminated Component Removal 25%
Contaminated Component Packaging 10%
Contaminated Component Transport 15%
Low-Level Radioactive Waste Disposal 25%
Low-Level Radioactive Waste Processing 15%
Reactor Segmentation 75%
NSSS Component Removal 25%
Reactor Waste Packaging 25%
Reactor Waste Transport 25%
Reactor Vessel Component Disposal 50%
GTCC Disposal 15%
Spent Fuel Management 15%
Non-Radioactive Component Removal 15%
Heavy Equipment and Tooling 15%
Supplies 25%
Engineering 15%
Energy 15%
Insurance and Fees 10%
Characterization and Termination Surveys 30%
Operations and Maintenance Expense 15%
Construction 15%
Property Taxes 10%
ISFSI Decommissioning 25%
The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of the detailed estimate provided in Appendices C and D. A contingency of 25% is applied to the subtotal of the ISFSI decommissioning costs, reported in Appendix E.
LR-N24-0040 Attachment 2 Page 34 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 6 of 37 TLG Services, LLC 3.4.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk.
Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur.
Consideration is sometimes necessary to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term financial risk. Included within the category of financial risk are:
Transition activities and costs: ancillary expenses associated with eliminating 50% to 80% of the site labor force shortly after the cessation of plant operations, added cost for worker separation packages throughout the decommissioning program, national or company-mandated retraining, and retention incentives for key personnel.
Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, legal challenges, and national and local hearings.
Changes in the project work scope from the baseline estimate, involving the discovery of unexpected levels of contaminants, contamination in places not previously expected, contaminated soil previously undiscovered (either radioactive or hazardous material contamination), variations in plant inventory or configuration not indicated by the as-built drawings.
Regulatory changes (e.g., affecting worker health and safety, site release criteria, waste transportation, and disposal).
Policy decisions altering national commitments (e.g., in the ability to accommodate certain waste forms for disposition) or in the timetable for such, for example, the start and rate of acceptance of spent fuel by the DOE.
Pricing changes for basic inputs such as labor, energy, materials, and disposal. Items subject to widespread price competition (such as materials) may not show significant variation; however, others such as waste disposal could exhibit large pricing uncertainties, particularly in markets where limited access to services is available.
This cost study does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to LR-N24-0040 Attachment 2 Page 35 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 7 of 37 TLG Services, LLC project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.
3.5 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impacts of the considerations identified below are included in this cost study.
3.5.1 Spent Fuel Management The cost to dispose of spent fuel generated from plant operations is not reflected within the estimates to decommission Hope Creek. Ultimate disposition of the spent fuel is within the province of the DOEs Waste Management System, as defined by the Nuclear Waste Policy Act. As such, the disposal cost was financed by a 1 mill/kWhr surcharge paid into the DOEs waste fund during operations. On November 19, 2013, the U.S. Court of Appeals for the D.C. Circuit ordered the Secretary of the Department of Energy to suspend collecting annual fees for nuclear waste disposal from nuclear power plant operators until the DOE has conducted a legally adequate fee assessment.
The NRC does, however, require licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy. This requirement is prepared for through inclusion of certain high-level waste cost elements within the estimates, as described below.
Completion of the decommissioning process is highly dependent upon the DOEs ability to remove spent fuel from the site. PSEGs current spent fuel management plan for Artificial Island assumes just-in-time acceptance, i.e., the DOE will be able to complete the transfer of spent fuel so as not to impede a deferred decommissioning scenario (SAFSTOR) and the termination of the earliest operating license (Salem Generating Station, Unit 1) within the required 60 year period (from the cessation of operations). To achieve this objective, based upon the oldest fuel receiving the highest priority and an annual maximum rate of transfer of 3,000 metric tons of uranium, DOE would commence pickup of spent fuel from Hope Creek no later than 2042, with fuel completely removed from Artificial Island by 2088.
LR-N24-0040 Attachment 2 Page 36 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 8 of 37 TLG Services, LLC ISFSI An ISFSI has been constructed to support continued plant operations.
The ISFSI will continue to operate throughout decommissioning, and beyond the conclusion of the remediation phase in the DECON decommissioning scenario, until such time that the transfer of spent fuel to the DOE can be completed. The scenario is similar for the SAFSTOR alternative; however, based upon the expected completion date for fuel transfer, the ISFSI will be emptied prior to the commencement of deferred decommissioning operations.
Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the estimates and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided for the final disposition of the facilities once the transfer is complete. Whenever appropriate, costs for maintaining the ISFSI are shared between Hope Creek and the adjacent Salem units. The sharing on the Salem - Hope Creek site is established by a census split of personnel; Hope Creek pays for 43.0% of shared costs.
Storage Canister Design The Holtec HI-STORM FW system (with a 68 fuel assembly capacity) is assumed for future cask acquisitions. For fuel transferred directly from the pool to the DOE, for purposes of this estimate only, the DOE was assumed to provide Transport, Aging and Disposal (TAD) canisters with a 44 assembly capacity. DOE has not identified any cask systems it may use.
Canister Loading and Transfer The estimates include the cost for the labor and equipment to transfer and load each spent fuel canister into the DOE transport cask or to the ISFSI from the wet storage pool. For estimating purposes, an allowance is used to estimate the cost to transfer the fuel from the ISFSI into the DOE transport cask.
LR-N24-0040 Attachment 2 Page 37 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 9 of 37 TLG Services, LLC Operations and Maintenance The estimates also include the cost of operating and maintaining the spent fuel pool and the ISFSI, respectively. Pool operations are expected to continue approximately three and one half years after the cessation of operations. ISFSI operation costs are shared over that time period that both Salem and Hope Creek spent fuel is present on site.
ISFSI Decommissioning In accordance with 10 CFR §72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor-related GTCC waste have been removed.
A multi-purpose (storage and transport) dry shielded storage canister with a vertical, steel and reinforced concrete storage overpack is used as a basis for the cost analyses. The overpack steel is assumed to have some level of neutron-induced activation, as a result of the long-term storage of the fuel, i.e., to levels exceeding free-release limits. As an allowance, 12 overpacks are assumed to require remediation, equivalent to the number of overpacks required to accommodate the final core offload. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the estimates.
In accordance with the specific requirements of 10 CFR §72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities; 2) an adequate contingency factor; and 3) the cost of meeting the criteria for unrestricted use. The cost summary for decommissioning the ISFSI is reported in Appendix E.
GTCC The dismantling of the reactor internals is expected to generate radioactive waste considered unsuitable for shallow land disposal (i.e.,
low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal LR-N24-0040 Attachment 2 Page 38 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 10 of 37 TLG Services, LLC of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste.[29] Although the DOE is responsible for disposing of GTCC waste, any costs for that service have not been determined. For purposes of this estimate, the GTCC is packaged in canisters compatible with the spent fuel dry storage system and disposed of at a cost equivalent to that envisioned for the spent fuel.
It is assumed that the DOE would not accept this waste prior to completing the transfer of spent fuel. Therefore, until such time the DOE is ready to accept GTCC waste, it is reasonable to assume that this material would remain in storage at the Hope Creek site (for the DECON alternative). In the SAFSTOR scenario, the GTCC material is shipped directly to a DOE facility as it is generated since the fuel has been removed from the site prior to the start of delayed dismantling.
3.5.2 Reactor Vessel and Internal Components The NSSS (reactor vessel and reactor recirculation system components) will be decontaminated using chemical agents prior to the start of cutting operations (for DECON alternative only). A decontamination factor (average reduction) of 10 is assumed for the process.
The reactor pressure vessel and internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed in the dryer-separator pool, where a turntable and remote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor well.
Transportation cask specifications and transportation regulations dictate the segmentation and packaging methodology.
Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites that have been decommissioned.
Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel.
Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (including the internals). However, its location on the Columbia River simplified the transportation analysis since:
LR-N24-0040 Attachment 2 Page 39 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 11 of 37 TLG Services, LLC the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport, there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and transport speeds were very low, limited by the overland transport vehicle and the river barge.
As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State.
The characteristics of this arid site proved favorable in demonstrating compliance with land disposal regulations.
It is not known whether this option will be available when Hope Creek ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensees ability to accept highly radioactive packages and effectively isolate them from the environment. Additionally, with BWRs, the diameter of the reactor vessel may severely limit overland transport.
Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition.
3.5.3 Primary System Components In the DECON scenario, the reactor recirculation system components are assumed to be decontaminated using chemical agents prior to the start of dismantling operations. This type of decontamination can be expected to have a significant ALARA impact, since in this scenario the removal work is done within the first few years of shutdown. A decontamination factor (average reduction) of 10 is assumed for the process. Disposal of the decontamination solution effluent is included within the estimate as a "process liquid waste" charge. In the SAFSTOR scenario, radionuclide decay over the dormancy period is expected to provide the same benefit and, therefore, a chemical decontamination is not included.
Reactor recirculation piping is cut from the reactor vessel once the water level in the vessel (used for personnel shielding during dismantling and cutting operations in and around the vessel) is dropped below the nozzle zone. The piping is boxed and transported by shielded van. The reactor LR-N24-0040 Attachment 2 Page 40 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 12 of 37 TLG Services, LLC recirculation pumps and motors are lifted out intact, packaged, and transported for processing and/or disposal.
3.5.4 Main Turbine and Condenser The main turbine will be dismantled using conventional maintenance procedures. The turbine rotors and shafts will be removed to a laydown area. The lower turbine casings will be removed from their anchors by controlled demolition. The main condensers will also be disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it will be surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components will be packaged and readied for transport in accordance with the intended disposition.
3.5.5 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.[30] The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart 173.411) for transport unless they are demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.
Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.
Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer.
LR-N24-0040 Attachment 2 Page 41 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 13 of 37 TLG Services, LLC The maximum level of activity per shipment assumed permissible was based upon the license limits of the available shielded transport casks.
The segmentation scheme for the vessel and internal segments is designed to meet these limits.
The transport of large intact components (e.g., large heat exchangers and other oversized components) will be by a combination of truck, rail, and/or multi-wheeled transporter. Truck transport costs were estimated using published tariffs from Tri-State Motor Transit.[31] The disposal cost for the GTCC material is assumed to be inclusive of the transportation cost.
3.5.6 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptance criteria of the disposal site) and recovery of the waste stream is performed off site at a licensed processing center. Any material leaving the site is subject to a survey and release charge, at a minimum.
The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in the detailed Appendices C and D, and summarized in Section 5. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. The volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.
The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, with surcharges added for the special handling requirements and the radiological characteristics of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.
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Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 14 of 37 TLG Services, LLC Disposal fees are calculated using the current disposal agreement for the Atlantic Compact, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel internals. Low-level radioactive material, or material suspected to be contaminated, is either routed to EnergySolutions facility in Clive, Utah or to a waste processor for conditioning and treatment, including volume reduction and disposal.
Material exceeding Class C limits (limited to material closest to the reactor core and comprising less than 1% of the total waste volume) is generally not suitable for shallow-land disposal. This material is packaged in the same multipurpose canisters used for spent fuel storage/transport.
3.5.7 Site Conditions Following Decommissioning The NRC will amend or terminate the site license if it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.
Building codes and environmental regulations will dictate the next step in the decommissioning process, as well as the Owners own future plans for the site, e.g., the electrical switchyard will remain in support of the electrical transmission and distribution system. The new switchyard for AI Transmission line is assumed to remain functional in support of the regional electrical distribution system. The existing shoreline and site access road will be left intact along with the Salem aux guardhouse (NERC/CIP equipment) and the Wind port which will be located north of the cooling tower.
The large underground tunnels between the cooling water intake, turbine building, and cooling tower will be isolated, sealed, and abandoned in place. Site utility and service piping are abandoned in place. Electrical manholes are backfilled with suitable earthen material and abandoned.
The estimate does not assume the remediation of any significant volume of contaminated soil. This assumption may be affected by continued plant operations.
Structures will be removed to a nominal depth of three feet below grade.
Concrete rubble generated from demolition activities will be processed and made available as clean fill. The site will be graded following the LR-N24-0040 Attachment 2 Page 43 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 15 of 37 TLG Services, LLC removal of non-essential structures to conform to the adjacent landscape, and vegetation will be established to inhibit erosion. This degree of site restoration will constitute compliance with the CAFRA document dated July 9, 1976.
3.6 ASSUMPTIONS The following are the major assumptions made in the development of the estimates for decommissioning the site.
3.6.1 Estimating Basis Decommissioning costs are reported in the year of projected expenditure; however, the values are provided in 2021 dollars. Costs are not inflated, escalated, or discounted over the periods of performance.
The estimates rely upon the physical plant inventory that was the basis for the 2018 analysis (updated to reflect any material changes to the plant over the past three years).
The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.
3.6.2 Labor Costs For purposes of this analysis, it is assumed that PSEG will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. PSEG will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases. Contract personnel will provide engineering services (e.g., for preparing the activity specifications, work procedures, neutron activation, and structural analyses) under the direction of PSEG.
Plant personnel labor costs were provided by PSEG. Average costs were provided by department or work group and included payroll overheads.
LR-N24-0040 Attachment 2 Page 44 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 16 of 37 TLG Services, LLC Decommissioning Operations Contractor (DOC) labor costs were based on utility labor costs with modified markups to account for employee benefits, DOC overhead and profit.
The craft labor required to decontaminate and dismantle the nuclear unit will be acquired through standard site contracting practices. Craft labor costs were based upon information from PSEG. Craft labor costs include applicable overheads and profit.
A profile of the staffing level for decommissioning, including contractors and craft, is provided in Figures 3.1 and 3.2 for the DECON and SAFSTOR scenarios, respectively. Utility staffing levels will gradually decrease after completing the removal of physical systems at each of the unit. Staffing levels and management support will vary based upon the amount and type of decommissioning work. Craft manpower levels decrease after systems removal and structures decontamination and drop substantially during the delay period and the license termination survey period. However, for the SAFSTOR alternative, craft staff levels increase again during the site restoration period due to the work associated with structures demolition.
Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel (in accordance with the requirements of 10 CFR Part 37, Part 72, and Part 73). Once the fuel has been transferred to the DOE in 2088, the security organization will be reduced to Part 37 requirements.
3.6.3 Design Conditions Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major NSSS components to be shipped under current transportation regulations and disposal requirements.
The curie contents of the vessel and internals at final shutdown are derived from those listed in NUREG/CR-3474.[32] Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Hope Creek components, projected operating life, and different periods of decay. Additional short-lived isotopes were LR-N24-0040 Attachment 2 Page 45 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 17 of 37 TLG Services, LLC derived from NUREG/CR-0130[33]
and NUREG/CR-0672,[34]
and benchmarked to the long-lived values from NUREG/CR-3474.
The disposal cost for the control blades removed from the vessel with the final core load is included within the estimates. Control blade residence time in the reactor is assumed to be controlled such that the blades do not become GTCC material. Disposition of any blades stored in the pool from operations is considered an operating expense and therefore not accounted for in the estimates.
Neutron activation of the reactor building structure is confined to the sacrificial shield.
3.6.4 General Transition Activities Existing warehouses will be cleared of non-essential material and remain for use by PSEG and its subcontractors. The plants operating staff will perform the following activities at no additional cost or credit to the project during the transition period:
Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale.
Drain and collect acids, caustics, and other chemical stores for recycle and/or sale.
Processes operating waste inventories, i.e., the estimates do not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioning expense.
Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. PSEG will make economically reasonable efforts to salvage equipment following final plant shutdown.
However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a LR-N24-0040 Attachment 2 Page 46 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 18 of 37 TLG Services, LLC salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the possible salvage value that an owner may realize based upon those efforts.
It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimates do not include the additional cost for size reduction and preparation to meet furnace ready conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project.
Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property will be removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts will also be made available for alternative use.
The concrete debris resulting from building demolition activities is crushed on site to reduce the size of the debris. The resulting crushed concrete is used to backfill below grade voids. The rebar removed from the concrete crushing process is disposed of as scrap steel in a similar fashion as other scrap metal as discussed previously.
Energy For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage.
Replacement power costs are used for the cost of energy consumption during decommissioning for tooling, lighting, ventilation, and essential services.
Emergency Planning FEMA emergency planning fees are included for approximately 10 months after the cessation of plant operations. At that time, the fees are discontinued. The timing is based upon the anticipated condition of the spent fuel (i.e., the hottest spent fuel assemblies are assumed to be cool LR-N24-0040 Attachment 2 Page 47 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 19 of 37 TLG Services, LLC enough that no substantial Zircaloy oxidation and off-site event would occur with the loss of spent fuel pool water). State emergency planning fees are included until all fuel has been moved from the pool into dry storage (approximately three and one-half years following the cessation of operations).
Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance provided in SECY-00-0145, Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning.[35] The NRCs financial protection requirements are based on various reactor (and spent fuel) configurations.
Taxes Property taxes are included for all decommissioning periods. PSEG provided a property tax payment for the entire Artificial Island site of
$87,125 (land value only, in 2021 dollars) per year. Approximately 41%
percent of this payment is assigned to Hope Creek and is maintained for the entire decommissioning program.
Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.
3.7 COST ESTIMATE
SUMMARY
Schedules of expenditures are provided in Tables 3.1 and 3.2. The tables delineate the cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).
Additional tables in Appendices C and D provide detailed costs elements. The cost elements are also assigned to one of three subcategories: License Termination, Spent Fuel Management, and Site Restoration. The subcategory License Termination is used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR §50.75). The cost reported for this subcategory is generally sufficient to terminate the plants operating license, LR-N24-0040 Attachment 2 Page 48 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 20 of 37 TLG Services, LLC recognizing that there may be some additional cost impact from spent fuel management.
The Spent Fuel Management subcategory contains costs associated with the containerization and transfer of spent fuel from the pool to the DOE or to the ISFSI for interim storage, and the transfer of the multipurpose canisters from the ISFSI to the DOE. Costs are also included for the operations of the pool and management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g., interim storage facility) is complete.
Site Restoration is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.
As discussed in Section 3.5.1, it is assumed that the DOE will not accept the GTCC waste prior to completing the transfer of spent fuel. Therefore, the cost of GTCC disposal is shown in the final year of ISFSI operation (for the DECON alternative). While designated for disposal at a federal facility along with the spent fuel, GTCC waste is still classified as low-level radioactive waste and, as such, included as a License Termination expense.
At the direction of PSEG Nuclear, TLG has assigned the ISFSI license termination and demolition costs as spent fuel management costs. These costs are assumed by PSEG Nuclear to be recoverable from the DOE.
Decommissioning costs are reported in 2021 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedules are based upon the detailed activity costs reported in Appendices C and D, along with the timelines presented in Section 4.
LR-N24-0040 Attachment 2 Page 49 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 27 of 37 SAFSTOR ALTERNATIVE TOTAL ANNUAL EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2044 3,767 0
0 0
480 4,247 2045 5,189 0
0 0
661 5,850 2046 44,682 7,279 2,148 32 10,356 64,497 2047 74,463 34,025 2,128 2,080 21,411 134,108 2048 25,885 31,748 485 17 6,846 64,981 2049 21,101 24,549 429 15 5,597 51,690 2050 5,831 2,619 242 8
1,417 10,117 2051 5,259 903 242 8
1,417 7,829 2052 5,230 774 243 8
1,421 7,676 2053 5,087 385 242 8
1,417 7,139 2054 5,173 644 242 8
1,417 7,484 2055 5,173 644 242 8
1,417 7,484 2056 5,273 904 243 8
1,421 7,848 2057 5,259 903 242 8
1,417 7,829 2058 5,259 903 242 8
1,417 7,829 2059 5,173 644 242 8
1,417 7,484 2060 5,187 645 243 8
1,421 7,503 2061 5,259 903 242 8
1,417 7,829 2062 5,259 903 242 8
1,417 7,829 2063 5,259 903 242 8
1,417 7,829 2064 5,187 645 243 8
1,421 7,503 2065 5,173 644 242 8
1,417 7,484 2066 5,259 903 242 8
1,417 7,829 2067 5,259 903 242 8
1,417 7,829 2068 5,273 904 243 8
1,421 7,848 2069 5,173 644 242 8
1,417 7,484 2070 5,173 644 242 8
1,417 7,484 2071 5,259 903 242 8
1,417 7,829 2072 5,273 904 243 8
1,421 7,848 2073 5,259 903 242 8
1,417 7,829 TABLE 3.2 TLG Services, LLC LR-N24-0040 Attachment 2 Page 50 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 28 of 37 SAFSTOR ALTERNATIVE TOTAL ANNUAL EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2074 5,173 644 242 8
1,417 7,484 2075 5,173 644 242 8
1,417 7,484 2076 5,273 904 243 8
1,421 7,848 2077 5,259 903 242 8
1,417 7,829 2078 5,259 903 242 8
1,417 7,829 2079 5,173 644 242 8
1,417 7,484 2080 5,187 645 243 8
1,421 7,503 2081 5,259 903 242 8
1,417 7,829 2082 5,259 903 242 8
1,417 7,829 2083 5,259 903 242 8
1,417 7,829 2084 5,187 645 243 8
1,421 7,503 2085 5,173 644 242 8
1,417 7,484 2086 5,259 903 242 8
1,417 7,829 2087 5,259 903 242 8
1,417 7,829 2088 5,144 516 243 8
1,421 7,331 2089 4,174 382 242 7
817 5,622 2090 4,174 382 242 7
817 5,622 2091 4,174 382 242 7
817 5,622 2092 4,185 383 243 7
819 5,637 2093 4,174 382 242 7
817 5,622 2094 4,174 382 242 7
817 5,622 2095 4,174 382 242 7
817 5,622 2096 4,185 383 243 7
819 5,637 2097 4,174 382 242 7
817 5,622 2098 4,174 382 242 7
817 5,622 2099 4,174 382 242 7
817 5,622 2100 33,056 1,635 1,710 28 1,689 38,118 2101 62,830 11,922 2,401 8,687 4,394 90,233 2102 92,165 32,950 2,300 51,709 14,807 193,931 2103 88,793 19,511 1,963 29,693 11,206 151,166 TABLE 3.2 (continued)
TLG Services, LLC LR-N24-0040 Attachment 2 Page 51 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 29 of 37 SAFSTOR ALTERNATIVE TOTAL ANNUAL EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2104 87,558 13,676 1,821 20,127 9,659 132,840 2105 74,078 8,338 1,181 10,519 5,982 100,099 2106 43,080 15,915 308 9
4,186 63,499 2107 36,868 20,969 242 0
5,021 63,100 2108 20,707 11,777 136 0
2,820 35,440 Total 964,431 270,769 29,364 123,294 169,403 1,557,262 TABLE 3.2 (continued)
TLG Services, LLC LR-N24-0040 Attachment 2 Page 52 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 30 of 37 SAFSTOR ALTERNATIVE LICENSE TERMINATION EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2044 3,767 0
0 0
63 3,830 2045 5,189 0
0 0
86 5,275 2046 42,559 1,305 2,148 32 4,438 50,482 2047 63,280 9,722 2,073 2,080 8,090 85,244 2048 2,114 553 243 17 5,748 8,674 2049 2,161 514 242 15 4,651 7,582 2050 2,339 385 242 8
975 3,949 2051 2,339 385 242 8
975 3,949 2052 2,345 386 243 8
978 3,960 2053 2,339 385 242 8
975 3,949 2054 2,339 385 242 8
975 3,949 2055 2,339 385 242 8
975 3,949 2056 2,345 386 243 8
978 3,960 2057 2,339 385 242 8
975 3,949 2058 2,339 385 242 8
975 3,949 2059 2,339 385 242 8
975 3,949 2060 2,345 386 243 8
978 3,960 2061 2,339 385 242 8
975 3,949 2062 2,339 385 242 8
975 3,949 2063 2,339 385 242 8
975 3,949 2064 2,345 386 243 8
978 3,960 2065 2,339 385 242 8
975 3,949 2066 2,339 385 242 8
975 3,949 2067 2,339 385 242 8
975 3,949 2068 2,345 386 243 8
978 3,960 2069 2,339 385 242 8
975 3,949 2070 2,339 385 242 8
975 3,949 2071 2,339 385 242 8
975 3,949 2072 2,345 386 243 8
978 3,960 2073 2,339 385 242 8
975 3,949 TABLE 3.2a TLG Services, LLC LR-N24-0040 Attachment 2 Page 53 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 31 of 37 SAFSTOR ALTERNATIVE LICENSE TERMINATION EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2074 2,339 385 242 8
975 3,949 2075 2,339 385 242 8
975 3,949 2076 2,345 386 243 8
978 3,960 2077 2,339 385 242 8
975 3,949 2078 2,339 385 242 8
975 3,949 2079 2,339 385 242 8
975 3,949 2080 2,345 386 243 8
978 3,960 2081 2,339 385 242 8
975 3,949 2082 2,339 385 242 8
975 3,949 2083 2,339 385 242 8
975 3,949 2084 2,345 386 243 8
978 3,960 2085 2,339 385 242 8
975 3,949 2086 2,339 385 242 8
975 3,949 2087 2,339 385 242 8
975 3,949 2088 2,345 386 243 8
978 3,960 2089 4,174 382 242 7
817 5,622 2090 4,174 382 242 7
817 5,622 2091 4,174 382 242 7
817 5,622 2092 4,185 383 243 7
819 5,637 2093 4,174 382 242 7
817 5,622 2094 4,174 382 242 7
817 5,622 2095 4,174 382 242 7
817 5,622 2096 4,185 383 243 7
819 5,637 2097 4,174 382 242 7
817 5,622 2098 4,174 382 242 7
817 5,622 2099 4,174 382 242 7
817 5,622 2100 32,573 1,635 1,710 28 1,689 37,635 2101*
61,594 11,906 2,401 8,687 4,394 88,982 2102*
89,563 32,855 2,300 51,709 14,807 191,233 2103*
84,356 19,305 1,963 28,743 9,469 143,836 TABLE 3.2a (continued)
TLG Services, LLC LR-N24-0040 Attachment 2 Page 54 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 32 of 37 SAFSTOR ALTERNATIVE LICENSE TERMINATION EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2104 82,305 13,420 1,821 18,758 7,156 123,460 2105 71,337 8,205 1,181 9,805 4,676 95,204 2106 16,403 690 133 9
541 17,777 2107 123 0
0 0
0 123 2108 69 0
0 0
0 69 Total 694,612 119,343 28,326 120,262 112,861 1,075,404 for Disposal of GTCC included in Table 3.2a (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2101 0
0 0
0 822 822 2102 0
0 0
0 4,920 4,920 2103 0
0 0
0 1,496 1,496 Total 0
0 0
0 0
7,239
- Schedule of Expenditures TABLE 3.2a (continued)
TLG Services, LLC LR-N24-0040 Attachment 2 Page 55 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 33 of 37 SAFSTOR ALTERNATIVE SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2044 0
0 0
0 417 417 2045 0
0 0
0 575 575 2046 2,123 5,974 0
0 5,918 14,015 2047 11,183 24,304 55 0
13,322 48,864 2048 23,771 31,195 243 0
1,098 56,306 2049 18,940 24,035 187 0
947 44,109 2050 3,492 2,234 0
0 442 6,168 2051 2,920 517 0
0 442 3,879 2052 2,885 388 0
0 443 3,716 2053 2,748 0
0 0
442 3,189 2054 2,834 259 0
0 442 3,534 2055 2,834 259 0
0 442 3,534 2056 2,928 517 0
0 443 3,888 2057 2,920 517 0
0 442 3,879 2058 2,920 517 0
0 442 3,879 2059 2,834 259 0
0 442 3,534 2060 2,842 259 0
0 443 3,543 2061 2,920 517 0
0 442 3,879 2062 2,920 517 0
0 442 3,879 2063 2,920 517 0
0 442 3,879 2064 2,842 259 0
0 443 3,543 2065 2,834 259 0
0 442 3,534 2066 2,920 517 0
0 442 3,879 2067 2,920 517 0
0 442 3,879 2068 2,928 517 0
0 443 3,888 2069 2,834 259 0
0 442 3,534 2070 2,834 259 0
0 442 3,534 2071 2,920 517 0
0 442 3,879 2072 2,928 517 0
0 443 3,888 2073 2,920 517 0
0 442 3,879 TABLE 3.2b TLG Services, LLC LR-N24-0040 Attachment 2 Page 56 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 34 of 37 SAFSTOR ALTERNATIVE SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2074 2,834 259 0
0 442 3,534 2075 2,834 259 0
0 442 3,534 2076 2,928 517 0
0 443 3,888 2077 2,920 517 0
0 442 3,879 2078 2,920 517 0
0 442 3,879 2079 2,834 259 0
0 442 3,534 2080 2,842 259 0
0 443 3,543 2081 2,920 517 0
0 442 3,879 2082 2,920 517 0
0 442 3,879 2083 2,920 517 0
0 442 3,879 2084 2,842 259 0
0 443 3,543 2085 2,834 259 0
0 442 3,534 2086 2,920 517 0
0 442 3,879 2087 2,920 517 0
0 442 3,879 2088 2,799 129 0
0 443 3,371 2089-02 0
0 0
0 0
0 2103 147 108 0
950 1,737 2,942 2104 212 156 0
1,368 2,503 4,240 2105 111 82 0
714 1,306 2,213 2106 1,534 506 0
0 222 2,263 2107 2,113 697 0
0 306 3,117 2108 1,187 392 0
0 172 1,751 Total 174,310 104,690 485 3,032 45,758 328,275 TABLE 3.2b (continued)
TLG Services, LLC LR-N24-0040 Attachment 2 Page 57 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Page 35 of 37 SAFSTOR ALTERNATIVE SITE RESTORATION EXPENDITURES (thousands, 2021 Dollars)
Year Labor Equipment
& Materials Energy Burial Other Total 2044-99 0
0 0
0 0
0 2100 484 0
0 0
0 484 2101 1,236 16 0
0 0
1,252 2102 2,602 96 0
0 0
2,698 2103 4,290 98 0
0 0
4,388 2104 5,041 99 0
0 0
5,141 2105 2,631 52 0
0 0
2,683 2106 25,143 14,718 176 0
3,423 43,460 2107 34,631 20,272 242 0
4,714 59,859 2108 19,450 11,386 136 0
2,648 33,620 Total 95,508 46,736 554 0
10,785 153,583 TABLE 3.2c TLG Services, LLC LR-N24-0040 Attachment 2 Page 58 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 37 of 37 TLG Services, LLC FIGURE 3.2 SAFSTOR SCENARIO MANPOWER LEVELS LR-N24-0040 Attachment 2 Page 59 / 99 500 Craft 450 -
Utility DOC 400 security M
Other Staff Total 350 300 1/1 I!:!
250 IL 200 150 100 50
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Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 1 of 7 TLG Services, LLC
- 4. SCHEDULE ESTIMATE The schedules for the decommissioning scenarios considered in this study follow 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 the spent fuel management plans described in Section 3.5.1.
A schedule or sequence of activities for the DECON alternative is presented in Figure 4.1. The schedule is also representative of the work activities identified in the SAFSTOR scenario, absent any spent fuel constraints. The scheduling sequence is based on the fuel being removed from the spent fuel pool within three and one half years. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project Professional" computer software.[36]
4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique) Software Package. The work activity durations used in the precedence network reflect the actual man-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:
The reactor building is isolated until such time that all spent fuel has been discharged from the storage pool to the DOE or to the ISFSI.
Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel is complete (DECON option).
All work (except vessel and internals removal) is performed during an 8-hour workday, 5 days per week, with no overtime. There are eleven paid holidays per year.
Reactor and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for the second shift.
Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.
LR-N24-0040 Attachment 2 Page 60 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 2 of 7 TLG Services, LLC For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activity.
4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based upon the durations developed in the schedules for decommissioning Hope Creek. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is also shown for the spent fuel cooling period, which determines the release of the reactor building for final decontamination.
Project timelines are provided in Figures 4.2 and 4.3, with milestone dates based on the 2046 shutdown date. The fuel pool is emptied approximately three and one half years after shutdown, while ISFSI operations continue until the DOE can complete the transfer of assemblies. Deferred decommissioning in the SAFSTOR scenario is assumed to commence so that the operating license is terminated within a 60-year period from the cessation of plant operations.
LR-N24-0040 Attachment 2 Page 61 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 3 of 7 TLG Services, LLC FIGURE 4.1 DECON ACTIVITY SCHEDULE LR-N24-0040 Attachment 2 Page 62 / 99 ID Task Name y.1 I YI I Y2 I Y3 I Y4 I Y5 I Y6 I Y7 I Ys I Y9 IY1olYnlY12IY13 1
Hope Creek schedule DECON I
I 2
Shutdown plant I
I I
I
- I I
I I
I I
3 Period la
- Shutdown through transition I
I I
5 Fuel storage pool operations I
I I
I I
I 6
Dry fuel storage operations I
I I
7 Reconfigure plant I
8 Prepare activity specifications I
I I
I I
I 9
Perform site characterization I
I I
4 Certificate of permanent cessation of operations submitted I
I I
I I
I 10 PSDAR submitted I
ll Written certificate of permanent removal of fuel submitted I
I I
I 12 Site specific decommissioning cost estimate submitted
- +
I 13 DOC staff mobilized
- +
I 14 Period lb
- Decommissionin g preparations
- ~
16 Fuel storage pool operations 16 Reconfigure plant (continued) 17 Dry fuel storage operations 18 Prepare detailed work p1*ocedures 19 Decon NSSS 20 Isolate spent fuel pool 21 Period 2a
- Large component removal
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 4 of 7 TLG Services, LLC FIGURE 4.1 (continued)
DECON ACTIVITY SCHEDULE LR-N24-0040 Attachment 2 Page 63 / 99 ID Task Name Y-1 I Yl I Y2 I Y3 I Y4 I Y5 I Y6 I Y7 I Ys I Y9 IY10IYnlY12IY13 22 Fuel storage pool operations lli-jl 23 Dry fuel storage operations I
I -
I I
24 Preparation for reactor vessel removal I
I "
I I
27 Non-essential systems I
I
-i-11 28 Main turbine/generator I
I
-i-11 29 Main condenser I
I
-i-11 25 Reactor vessel & internals I -
26 Remaining large NSSS components disposition I
30 License termination plan submitted 31 Period 2b - Decontamination (following wet fuel)
I 32 Dry fuel storage operations I
I I
33 Remove systems not supporting wet fuel storage I
I I
34 Decon buildings not supporting wet fuel storage I..
35 License termination plan approved 36 Fuel storage pool available for decommissioning I
I 37 Period 2f - Plant license termination I
'11111" 38 Dry fuel storage operations I
- I 39 Final Site Survey I
- 40 NRC review & approval 41 Part 50 license terminated 42 Period 3b - Site restoration 43 Dry fuel storage operations I
I I
I 44 Building demolitions, backfill and landscaping I
I
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Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 5 of 7 TLG Services, LLC FIGURE 4.1 (continued)
DECON ACTIVITY SCHEDULE LR-N24-0040 Attachment 2 Page 64 / 99 ID Task Name Y-1 1 Yl I Y2 I Y3 I Y4 1 Y5 I Y6 I Y7 I Y8 I Y9 IY10IY11IY12IY13 45 Turbine & Admin Building Interior Demolition 50 Reactor Building Interior Demolition 53 Diesel & Control Building Interior Demolition
56 Service & Radwaste Building Interior Demolition 51 React.or Building Ext-erior Demolition 46 Turbine & Admin Building Exterior Demolition 47 Unit 1 Turbine Pedestal Demolition I I '
48 Unit 2 Turbine Pedestal Demolition 49 Turbine & Admin Building Backfill 57 Service & Radwaste Building Exterior Demolition I
I I
I I
I I
I I 58 Service & Radwaste Building Backfill I
52 React.or Building Backfill 54 Diesel & Control Building Exterior Demolition I
55 Diesel & Control Building Backfill I
59 Kuclear Sen-ice Building Demolition I
60 Landscape Site I
I I
I I
I I
I
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 7 of 7 TLG Services, LLC FIGURE 4.3 DECOMMISSIONING TIMELINE SAFSTOR (not to scale)
Period 1 SAFSTOR Preparations Apr-2046 Oct-2047 Period 4 Decommissioning Operations Period 5 Site Restoration Jul-2108 Apr-2100 Nov-2101 Apr-2106 END Period 2 Dormancy Period 3 Decommissioning Preparations Oct-2049 Fuel Pool Operations ISFSI Operations Dec-2088 Shutdown April 11, 2046 LR-N24-0040 Attachment 2 Page 65 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 1 of 6 TLG Services, LLC
- 5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[37] the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.
Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR Parts 173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in 10 CFR
§173.411). For this study, commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.
The destinations for the various waste streams from decommissioning are identified in Figures 5.1 and 5.2. The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in Appendices C and D and summarized in Tables 5.1 and 5.2. The quantified waste volume summaries shown in these tables are consistent with §61 classifications.
The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.
The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners.
In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste),
where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.
No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone, i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides.
LR-N24-0040 Attachment 2 Page 66 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 2 of 6 TLG Services, LLC While the dose rates decrease with time, radionuclides such as 137Cs will still control the disposition requirements.
The waste material generated in the decontamination and dismantling of Hope Creek is primarily generated during Period 2 of the DECON alternative and Period 4 of SAFSTOR. Material that is considered potentially contaminated when removed from the radiologically controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components, contaminated soil-like materials, and activated materials are routed for controlled disposal at either the Barnwell Low-Level Radioactive Waste Management Facility, located in South Carolina or at EnergySolutions facility in Clive, Utah. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.
Disposal fees are calculated using current disposal agreements, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. This highly activated reactor vessel material is sent to the Barnwell facility for direct disposal, depending upon the level of activity, concentration of radionuclides or identified isotopes.
A small quantity of material will be generated during the Hope Creek decommissioning will not be considered suitable for near-surface disposal, and is assumed to be disposed of in a geologic repository, in a manner similar to that envisioned for spent fuel disposal. Such material, known as Greater-Than-Class-C or GTCC material, is estimated to require four spent fuel storage canisters (or the equivalent) to dispose of the most radioactive portions of the reactor vessel internals. The volume and weight reported in Tables 5.1 and 5.2 represent the packaged weight and volume of the spent fuel storage canisters.
LR-N24-0040 Attachment 2 Page 67 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 3 of 6 TLG Services, LLC FIGURE 5.1 RADIOACTIVE WASTE DISPOSITION Decommissioning Low-Level Radioactive Waste Streams DAW Resins (Class A, B and C)
Containerized Waste Reactor Waste (Classes A, B, and C)
Bulk Waste (Contaminated Soil and Concrete)
Metal Processing EnergySolutions Oak Ridge, TN Barnwell, SC Reactor Waste (Class GTCC)
Geologic Disposal Federal Facility EnergySolutions Clive, Utah LR-N24-0040 Attachment 2 Page 68 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 4 of 6 TLG Services, LLC FIGURE 5.2 DECOMMISSIONING WASTE DESTINATIONS RADIOLOGICAL The figure indicates the destinations for the low-level radioactive waste designated for direct disposal (Containerized Classes A, B and C at the Barnwell Low-Level Radioactive Waste Disposal Facility in South Carolina; Bulk waste at EnergySolutions facility in Clive, Utah) and processing/recovery (at EnergySolutions/Oak Ridge).
Hope Creek Generating Station Barnwell, SC EnergySolutions Clive, UT Oak Ridge, TN LR-N24-0040 Attachment 2 Page 69 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 6 of 6 TLG Services, LLC TABLE 5.2 SAFSTOR ALTERNATIVE DECOMMISSIONING WASTE
SUMMARY
Waste Cost Basis Class [1]
Waste Volume (cubic feet)
Mass (pounds)
Low-Level Radioactive Waste (near-surface disposal)
Barnwell A
166,489 10,633,670 B
2,379 238,787 C
630 70,187 Greater than Class C (geologic repository)
Spent Fuel Equivalent GTCC 1,633 314,644 Processed/Conditioned (off-site recycling center)
Recycling Vendors A
707,329 29,729,480 DAW and Concrete EnergySolutions A
129,838 5,413,139 Total [2]
1,008,298 46,399,907
[1]
Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55
[2]
Columns may not add due to rounding LR-N24-0040 Attachment 2 Page 70 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 6, Page 1 of 5 TLG Services, LLC
- 6. RESULTS This report presents estimates of the cost to decommission Hope Creek for the selected decommissioning scenarios following a scheduled cessation of plant operations. The estimates are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. While not an engineering study, the estimates provide the owner with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.
The estimates described in this report are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The decommissioning scenarios assume continued operation of the plants spent fuel pool for a minimum of three and one-half years following the cessation of operations for continued cooling of the assemblies.
The cost projected to promptly decommission the station, restore the site, and manage the spent fuel is estimated to be $1.507 billion (2021 dollars). The majority of this cost (approximately 69.61%) is associated with the physical decontamination and dismantling of the nuclear plant so that the operating license can be terminated. Another 19.33% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 11.06% is for the demolition of the designated structures and limited restoration of the site.
The cost projected for deferred decommissioning (SAFSTOR) is estimated to be
$1.557 billion (2021 dollars), assuming that the decommissioning is coordinated with the adjacent Salem units. The majority of this cost (approximately 69.06%) is associated with placing the plant in storage, ongoing caretaking of the plant during dormancy, and the eventual physical decontamination and dismantling of the nuclear plant so that the operating license can be terminated. Another 21.08% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 9.86% is for the demolition of the designated structures and limited restoration of the site.
The primary cost contributors, identified in Tables 6.1 and 6.2, are either labor-related or associated with the management and disposition of the radioactive waste.
Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the decommissioning, as well as the duration of the program. It is LR-N24-0040 Attachment 2 Page 71 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of 5 TLG Services, LLC assumed, for purposes of this analysis, that PSEG will hire a contractor to manage the decommissioning labor force. The size and composition of the management organizations varies with the decommissioning phase and associated site activities.
However, once the operating license is amended or terminated, the staff is substantially reduced for the conventional demolition and restoration of the site, and the long-term care of the spent fuel (for the DECON alternative).
As described in this report, the spent fuel pool will remain operational for a minimum of three and one half years following the cessation of operations. System modifications to support spent fuel pool offload will occur. This will allow decommissioning operations to proceed in and around the pool area. Over the three and one half-year period, the spent fuel will be packaged into transportable canisters for future loading into a DOE-provided transport cask or relocation to the ISFSI. The canisters will be stored in vertical storage casks at the ISFSI until the DOE is able to receive them. Dry storage of the fuel provides additional flexibility in the event the DOE is not able to meet the current timetable for completing the transfer of assemblies to an off-site facility and minimizes the associated caretaking expenses.
The cost for waste disposal includes only those costs associated with the controlled disposition of the low-level radioactive waste generated from decontamination and dismantling activities, including plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, disposition of the majority of the low-level radioactive material requiring controlled disposal is at the Barnwell facility. Highly activated components, requiring additional isolation from the environment (GTCC), are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.
A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processes as survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at one of the currently operating facilities. The cost identified in the summary tables for processing is all-inclusive, incorporating the ultimate disposition of the material.
Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program.
Decontamination and packaging costs also have a large labor component that is based upon prevailing wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning operations, non-LR-N24-0040 Attachment 2 Page 72 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 6, Page 3 of 5 TLG Services, LLC radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license.
The reported cost for transport includes the tariffs and surcharges associated with moving large components and/or overweight shielded casks overland, as well as the general expense, e.g., labor and fuel, of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck.
Decontamination is used to reduce the plants radiation fields and minimize worker exposure.
Slightly contaminated material or material located within a
contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for uncontrolled release in-situ. Centralized processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear plant.
License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings. The status of any plant components and materials not removed in the decommissioning process will also require confirmation and will add to the expense of surveying the facilities alone.
The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.
LR-N24-0040 Attachment 2 Page 73 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 6, Page 5 of 5 TLG Services, LLC TABLE 6.2 SAFSTOR ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2021 dollars)
Cost Element Cost Percentage Decontamination 59,555 3.8 Removal 305,511 19.6 Packaging 27,587 1.8 Transportation 12,748 0.8 Waste Disposal 63,148 4.1 Off-site Waste Processing 72,822 4.7 Program Management [1]
456,037 29.3 Severance 14,836 1.0 NEI Fees 9,705 0.6 Security 200,046 12.8 Spent Fuel Pool Equipment Modifications 1,483 0.1 Spent Fuel Management [2]
165,354 10.6 Insurance and Regulatory Fees 59,660 3.8 Energy 29,364 1.9 Characterization and Licensing Surveys 42,796 2.7 Property Taxes 4,710 0.3 Miscellaneous Equipment 31,898 2.0 Total [3]
1,557,262 100 Cost Element Cost Percentage NRC License Termination 1,075,404 69.0 Spent Fuel Management [4]
328,275 21.1 Site Restoration 153,583 9.9 Total [3]
1,557,262 100
[1]
Includes engineering
[2] Includes costs for the dry storage system components, spent fuel loading and transfer, spent fuel pool O&M and EP fees
[3] Columns may not add due to rounding
[4] Reflects savings in ISFSI operations with the adjacent Salem Generating Station units LR-N24-0040 Attachment 2 Page 74 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 7, Page 1 of 4 TLG Services, LLC
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Nuclear Waste Policy Act of 1982, 42 U.S. Code 10101, et seq. [Open]
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Nuclear Waste Policy Amendments of 1987, 42 U.S. Code 10172 [Open]
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LR-N24-0040 Attachment 2 Page 75 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 7, Page 2 of 4 TLG Services, LLC
- 7. REFERENCES (continued)
- 13.
United States Court of Appeals for the District of Columbia Circuit, In Re:
Aiken County, Et Al., August 2013 [Open]
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U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses [Open]
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Low-Level Radioactive Waste Policy Act, Public Law 96-573, 1980 [Open]
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Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, January 15, 1986 [Open]
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U.S. Code of Federal Regulations, Title 10, Part 61, Licensing Requirements for Land Disposal of Radioactive Waste [Open]
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U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Final Rule, Radiological Criteria for License Termination, 62 Fed. Reg. 39058, July 21, 1997 [Open]
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Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination, EPA Memorandum OSWER No. 9200.4-18, August 22, 1997
[Open]
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U.S. Code of Federal Regulations, Title 40, Part 141.66, Maximum contaminant levels for radionuclides [Open]
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- 24.
Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),
NUREG-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000 [Open]
LR-N24-0040 Attachment 2 Page 76 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 7, Page 3 of 4 TLG Services, LLC
- 7. REFERENCES (continued)
- 25.
T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986
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W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.
Department of Energy, DOE/EV/10128-1, November 1980
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"Building Construction Cost Data 2021," RSMeans (From the Gordian Group),
Kingston, Massachusetts
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Project and Cost Engineers Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984
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"Strategy for Management and Disposal of Greater-Than-Class C Low-Level Radioactive Waste, Federal Register Volume 60, Number 48 (p 13424 et seq.),
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U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178 [Open]
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Tri-State Motor Transit Company, published tariffs, as amended
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J.C. Evans et al., "Long-Lived Activation Products in Reactor Materials" NUREG/CR-3474, Pacific Northwest Laboratory for the Nuclear Regulatory Commission, August 1984 [Open]
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R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,"
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H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672 and
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SECY-00-0145, Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning, June 2000 [Open]
LR-N24-0040 Attachment 2 Page 77 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 7, Page 4 of 4 TLG Services, LLC
- 7. REFERENCES (continued)
- 36.
"Microsoft Project Professional," Microsoft Corporation, Redmond, WA
- 37.
Atomic Energy Act of 1954, (68 Stat. 919) [Open]
LR-N24-0040 Attachment 2 Page 78 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 1 of 7 TLG Services, LLC APPENDIX B UNIT COST FACTOR LISTING (DECON: Power Block Structures Only)
LR-N24-0040 Attachment 2 Page 79 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit TLG Services, LLC Removal of clean instrument and sampling tubing, $/linear foot 0.86 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 9.11 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 12.99 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 25.09 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 48.54 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 63.06 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 92.80 Removal of clean pipe >36 inches diameter, $/linear foot 110.28 Removal of clean valve >2 to 4 inches 168.16 Removal of clean valve >4 to 8 inches 250.92 Removal of clean valve >8 to 14 inches 485.43 Removal of clean valve >14 to 20 inches 630.61 Removal of clean valve >20 to 36 inches 927.97 Removal of clean valve >36 inches 1,102.75 Removal of clean pipe hanger for small bore piping 56.29 Removal of clean pipe hanger for large bore piping 202.61 Removal of clean pump, <300 pound 422.23 Removal of clean pump, 300-1000 pound 1,165.88 Removal of clean pump, 1000-10,000 pound 4,625.12 Removal of clean pump, >10,000 pound 8,941.47 Removal of clean pump motor, 300-1000 pound 489.00 Removal of clean pump motor, 1000-10,000 pound 1,924.17 Removal of clean pump motor, >10,000 pound 4,329.36 Removal of clean heat exchanger <3000 pound 2,487.02 Removal of clean heat exchanger >3000 pound 6,255.71 Removal of clean feedwater heater/deaerator 17,610.52 Removal of clean moisture separator/reheater 36,173.82 Removal of clean tank, <300 gallons 543.26 Removal of clean tank, 300-3000 gallon 1,714.93 Removal of clean tank, >3000 gallons, $/square foot surface area 14.29 LR-N24-0040 Attachment 2 Page 80 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit TLG Services, LLC Removal of clean electrical equipment, <300 pound 230.18 Removal of clean electrical equipment, 300-1000 pound 796.13 Removal of clean electrical equipment, 1000-10,000 pound 1,592.25 Removal of clean electrical equipment, >10,000 pound 3,794.01 Removal of clean electrical transformer < 30 tons 2,634.90 Removal of clean electrical transformer > 30 tons 7,588.04 Removal of clean standby diesel generator, <100 kW 2,691.32 Removal of clean standby diesel generator, 100 kW to 1 MW 6,007.19 Removal of clean standby diesel generator, >1 MW 12,436.11 Removal of clean electrical cable tray, $/linear foot 21.54 Removal of clean electrical conduit, $/linear foot 9.41 Removal of clean mechanical equipment, <300 pound 230.18 Removal of clean mechanical equipment, 300-1000 pound 796.13 Removal of clean mechanical equipment, 1000-10,000 pound 1,592.25 Removal of clean mechanical equipment, >10,000 pound 3,794.01 Removal of clean HVAC equipment, <300 pound 278.34 Removal of clean HVAC equipment, 300-1000 pound 956.62 Removal of clean HVAC equipment, 1000-10,000 pound 1,906.52 Removal of clean HVAC equipment, >10,000 pound 3,794.01 Removal of clean HVAC ductwork, $/pound 0.90 Removal of contaminated instrument and sampling tubing, $/linear foot 2.57 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 34.56 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 60.73 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 95.93 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 189.32 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 228.06 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 316.91 Removal of contaminated pipe >36 inches diameter, $/linear foot 375.17 Removal of contaminated valve >2 to 4 inches 739.12 Removal of contaminated valve >4 to 8 inches 884.72 LR-N24-0040 Attachment 2 Page 81 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit TLG Services, LLC Removal of contaminated valve >8 to 14 inches 1,826.09 Removal of contaminated valve >14 to 20 inches 2,325.22 Removal of contaminated valve >20 to 36 inches 3,102.07 Removal of contaminated valve >36 inches 3,684.68 Removal of contaminated pipe hanger for small bore piping 240.97 Removal of contaminated pipe hanger for large bore piping 799.96 Removal of contaminated pump, <300 pound 1,575.57 Removal of contaminated pump, 300-1000 pound 3,654.20 Removal of contaminated pump, 1000-10,000 pound 12,108.59 Removal of contaminated pump, >10,000 pound 29,497.99 Removal of contaminated pump motor, 300-1000 pound 1,537.46 Removal of contaminated pump motor, 1000-10,000 pound 4,910.07 Removal of contaminated pump motor, >10,000 pound 11,023.59 Removal of contaminated heat exchanger <3000 pound 7,321.50 Removal of contaminated heat exchanger >3000 pound 21,170.06 Removal of contaminated feedwater heater/deaerator 51,914.25 Removal of contaminated moisture separator/reheater 113,758.10 Removal of contaminated tank, <300 gallons 2,614.61 Removal of contaminated tank, >300 gallons, $/square foot 51.55 Removal of contaminated electrical equipment, <300 pound 1,233.36 Removal of contaminated electrical equipment, 300-1000 pound 2,997.26 Removal of contaminated electrical equipment, 1000-10,000 pound 5,772.11 Removal of contaminated electrical equipment, >10,000 pound 11,359.22 Removal of contaminated electrical cable tray, $/linear foot 59.59 Removal of contaminated electrical conduit, $/linear foot 28.53 Removal of contaminated mechanical equipment, <300 pound 1,372.44 Removal of contaminated mechanical equipment, 300-1000 pound 3,311.31 Removal of contaminated mechanical equipment, 1000-10,000 pound 6,366.53 Removal of contaminated mechanical equipment, >10,000 pound 11,359.22 Removal of contaminated HVAC equipment, <300 pound 1,372.44 LR-N24-0040 Attachment 2 Page 82 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit TLG Services, LLC Removal of contaminated HVAC equipment, 300-1000 pound 3,311.31 Removal of contaminated HVAC equipment, 1000-10,000 pound 6,366.53 Removal of contaminated HVAC equipment, >10,000 pound 11,359.22 Removal of contaminated HVAC ductwork, $/pound 3.41 Removal/plasma arc cut of contaminated thin metal components, $/linear in.
6.63 Additional decontamination of surface by washing, $/square foot 13.41 Additional decontamination of surfaces by hydrolasing, $/square foot 58.76 Decontamination rig hook up and flush, $/ 250 foot length 11,596.92 Chemical flush of components/systems, $/gallon 22.28 Removal of clean standard reinforced concrete, $/cubic yard 90.42 Removal of grade slab concrete, $/cubic yard 102.88 Removal of clean concrete floors, $/cubic yard 556.72 Removal of sections of clean concrete floors, $/cubic yard 1,691.02 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 130.76 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 3,419.86 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 177.27 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 4,526.25 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 697.97 Removal of below-grade suspended floors, $/cubic yard 248.71 Removal of clean monolithic concrete structures, $/cubic yard 1,451.70 Removal of contaminated monolithic concrete structures, $/cubic yard 3,408.58 Removal of clean foundation concrete, $/cubic yard 1,137.50 Removal of contaminated foundation concrete, $/cubic yard 3,174.87 Explosive demolition of bulk concrete, $/cubic yard 75.83 Removal of clean hollow masonry block wall, $/cubic yard 31.73 Removal of contaminated hollow masonry block wall, $/cubic yard 83.83 Removal of clean solid masonry block wall, $/cubic yard 31.73 Removal of contaminated solid masonry block wall, $/cubic yard 83.83 Backfill of below-grade voids, $/cubic yard 45.62 Removal of subterranean tunnels/voids, $/linear foot 174.08 LR-N24-0040 Attachment 2 Page 83 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit TLG Services, LLC Placement of concrete for below-grade voids, $/cubic yard 156.04 Excavation of clean material, $/cubic yard 4.00 Excavation of contaminated material, $/cubic yard 59.77 Removal of clean concrete rubble (tipping fee included), $/cubic yard 32.02 Removal of contaminated concrete rubble, $/cubic yard 36.99 Removal of building by volume, $/cubic foot 0.42 Removal of clean building metal siding, $/square foot 2.14 Removal of contaminated building metal siding, $/square foot 7.06 Removal of standard asphalt roofing, $/square foot 4.01 Removal of transite panels, $/square foot 3.52 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 18.82 Scabbling contaminated concrete floors, $/square foot 12.36 Scabbling contaminated concrete walls, $/square foot 33.44 Scabbling contaminated ceilings, $/square foot 115.51 Scabbling structural steel, $/square foot 9.92 Removal of clean overhead crane/monorail < 10 ton capacity 1,108.83 Removal of contaminated overhead crane/monorail < 10 ton capacity 3,047.87 Removal of clean overhead crane/monorail >10-50 ton capacity 2,661.17 Removal of contaminated overhead crane/monorail >10-50 ton capacity 7,313.63 Removal of polar crane > 50 ton capacity 11,154.02 Removal of gantry crane > 50 ton capacity 42,366.53 Removal of structural steel, $/pound 0.31 Removal of clean steel floor grating, $/square foot 7.89 Removal of contaminated steel floor grating, $/square foot 22.42 Removal of clean free standing steel liner, $/square foot 21.42 Removal of contaminated free standing steel liner, $/square foot 60.45 Removal of clean concrete-anchored steel liner, $/square foot 10.71 Removal of contaminated concrete-anchored steel liner, $/square foot 70.45 Placement of scaffolding in clean areas, $/square foot 19.62 Placement of scaffolding in contaminated areas, $/square foot 36.68 LR-N24-0040 Attachment 2 Page 84 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit TLG Services, LLC Landscaping with topsoil, $/acre 27,759.19 Cost of CPC B-88 LSA box & preparation for use 2,219.99 Cost of CPC B-25 LSA box & preparation for use 1,920.09 Cost of CPC B-12V 12 gauge LSA box & preparation for use 1,746.75 Cost of CPC B-144 LSA box & preparation for use 10,537.79 Cost of LSA drum & preparation for use 290.06 Cost of cask liner for CNSI 8 120A cask (resins) 13,533.00 Cost of cask liner for CNSI 8 120A cask (filters) 9,963.47 Decontamination of surfaces with vacuuming, $/square foot 1.27 LR-N24-0040 Attachment 2 Page 85 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix D, Page 1 of 12 TLG Services, LLC APPENDIX D DETAILED COST ANALYSIS SAFSTOR LR-N24-0040 Attachment 2 Page 86 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 2 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours PERIOD 0a - Pre-Shutdown Early Planning Period 0a Direct Decommissioning Activities Period 0a Additional Costs 0a.2.1 Utility Resources 9,024 1,354 10,378 10,378 41,600 0a.2.2 Environmental Report for PSDAR 25 4
29 29 0a.2.3 Emergency Plan Calculations 125 19 144 144 0a.2.4 Security Modifications (planning) 1,000 150 1,150 1,150 0a.2 Subtotal Period 0a Additional Costs 10,174 1,526 11,700 10,550 1,150 41,600 0a.0 TOTAL PERIOD 0a COST 10,174 1,526 11,700 10,550 1,150 41,600 PERIOD 1a - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 SAFSTOR site characterization survey 570 171 741 741 1a.1.2 Prepare preliminary decommissioning cost 205 31 235 235 1,300 1a.1.3 Notification of Cessation of Operations a
1a.1.4 Remove fuel & source material n/a 1a.1.5 Notification of Permanent Defueling a
1a.1.6 Deactivate plant systems & process waste a
1a.1.7 Prepare and submit PSDAR 315 47 362 362 2,000 1a.1.8 Review plant dwgs & specs.
205 31 235 235 1,300 1a.1.9 Perform detailed rad survey a
1a.1.10 Estimate by-product inventory 157 24 181 181 1,000 1a.1.11 End product description 157 24 181 181 1,000 1a.1.12 Detailed by-product inventory 236 35 271 271 1,500 1a.1.13 Define major work sequence 157 24 181 181 1,000 1a.1.14 Perform SER and EA 488 73 561 561 3,100 1a.1.15 Perform Site-Specific Cost Study 787 118 905 905 5,000 Activity Specifications 1a.1.16.1 Prepare plant and facilities for SAFSTOR 774 116 891 891 4,920 1a.1.16.2 Plant systems 656 98 754 754 4,167 1a.1.16.3 Plant structures and buildings 491 74 565 565 3,120 1a.1.16.4 Waste management 315 47 362 362 2,000 1a.1.16.5 Facility and site dormancy 315 47 362 362 2,000 1a.1.16 Total 2,551 383 2,933 2,933 16,207 Detailed Work Procedures 1a.1.17.1 Plant systems 186 28 214 214 1,183 1a.1.17.2 Facility closeout & dormancy 189 28 217 217 1,200 1a.1.17 Total 375 56 431 431 2,383 1a.1.18 Procure vacuum drying system 16 2
18 18 100 1a.1.19 Drain/de-energize non-cont. systems a
1a.1.20 Drain & dry NSSS a
1a.1.21 Drain/de-energize contaminated systems a
1a.1.22 Decon/secure contaminated systems a
1a.1 Subtotal Period 1a Activity Costs 6,218 1,018 7,237 7,237 35,890 Period 1a Additional Costs 1a.2.1 Prepare and submit PSDAR (credit)
(315)
(47)
(362)
(2,000) 1a.2.2 ISFSI Security Modifications 2,150 323 2,473 2,473 1a.2.3 Prepare/submit Irradiated Fuel Management Plan (Reassigned to SF) 157 24 181 181 1,000 1a.2.4 Security Modifications 1,500 225 1,725 1,725 1a.2 Subtotal Period 1a Additional Costs 3,493 524 4,017 4,378 (1,000)
Period 1a Collateral Costs 1a.3.1 Spent Fuel Capital and Transfer 9,540 1,431 10,971 10,971 1a.3.2 Severance 707 106 813 813 1a.3.3 Barnwell Annual Access Fee 500 75 575 575 1a.3.4 Emergency Operations Facility 171 26 196 196 1a.3 Subtotal Period 1a Collateral Costs 10,918 1,638 12,555 1,388 11,167 TLG Services, LLC LR-N24-0040 Attachment 2 Page 87 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 3 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 1a Period-Dependent Costs 1a.4.1 Insurance 1,794 179 1,973 1,973 1a.4.2 Property taxes 895 89 984 984 1a.4.3 Health physics supplies 614 153 767 767 1a.4.4 Heavy equipment rental 756 113 869 869 1a.4.5 Disposal of DAW generated 13 4
35 11 64 64 610 12,190 20 1a.4.6 Plant energy budget 2,573 386 2,959 2,959 1a.4.7 NRC Fees 964 96 1,060 1,060 1a.4.8 Emergency Planning Fees 2,276 228 2,504 2,504 1a.4.9 Spent Fuel Pool O&M 853 128 981 981 1a.4.10 ISFSI Operating Costs 49 7
56 56 1a.4.11 NEI Fees 582 87 669 669 1a.4.12 Security Staff Cost 11,631 1,745 13,376 13,376 187,409 1a.4.13 Utility Staff Cost 31,789 4,768 36,557 36,557 422,240 1a.4 Subtotal Period 1a Period-Dependent Costs 1,370 13 4
35 53,405 7,992 62,820 59,279 3,541 610 12,190 20 609,649 1a.0 TOTAL PERIOD 1a COST 1,370 13 4
35 74,034 11,172 86,628 67,542 19,086 610 12,190 20 644,539 PERIOD 1b - SAFSTOR Limited DECON Activities Period 1b Direct Decommissioning Activities Decontamination of Site Buildings 1b.1.1.1 Reactor Building 10,440 5,220 15,661 15,661 109,556 1b.1.1.2 Low Level Radwaste Storage Facility 204 102 306 306 2,280 1b.1.1.3 Service & Radwaste Building 855 428 1,283 1,283 9,597 1b.1.1.4 Turbine Building 3,406 1,703 5,109 5,109 38,305 1b.1.1.5 Reactor (post fuel) 1,275 637 1,912 1,912 13,416 1b.1.1 Totals 16,181 8,090 24,271 24,271 173,155 1b.1 Subtotal Period 1b Activity Costs 16,181 8,090 24,271 24,271 173,155 Period 1b Additional Costs 1b.2.1 Spent Fuel Pool equipment modifications 1,289 193 1,483 1,483 1b.2.2 ISFSI Expansion 8,788 1,318 10,106 10,106 1b.2.3 Leaking Fuel Characterization 221 33 254 254 1b.2 Subtotal Period 1b Additional Costs 10,297 1,545 11,842 1,483 10,359 Period 1b Collateral Costs 1b.3.1 Decon equipment 1,073 161 1,234 1,234 1b.3.2 Process decommissioning water waste 230 160 221 996 413 2,020 2,020 1,415 84,887 276 1b.3.3 Process decommissioning chemical flush waste 1b.3.4 Small tool allowance 277 42 318 318 1b.3.5 Spent Fuel Capital and Transfer 8,681 1,302 9,984 9,984 1b.3.6 Severance 643 96 740 740 1b.3.7 Barnwell Annual Access Fee 125 19 143 143 1b.3 Subtotal Period 1b Collateral Costs 1,303 277 160 221 996 9,449 2,033 14,439 4,455 9,984 1,415 84,887 276 Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 2,897 724 3,621 3,621 1b.4.2 Insurance 159 16 174 174 1b.4.3 Property taxes 175 18 193 193 1b.4.4 Health physics supplies 1,139 285 1,424 1,424 1b.4.5 Heavy equipment rental 189 28 217 217 1b.4.6 Disposal of DAW generated 24 8
65 20 116 116 1,113 22,255 36 1b.4.7 Plant energy budget 525 79 604 604 1b.4.8 NRC Fees 177 18 195 195 1b.4.9 Emergency Planning Fees 10 1
11 11 1b.4.10 Spent Fuel Pool O&M 213 32 244 244 1b.4.11 ISFSI Operating Costs 12 2
14 14 1b.4.12 NEI Fees 145 22 167 167 1b.4.13 Security Staff Cost 1,691 254 1,945 1,945 27,579 1b.4.14 Utility Staff Cost 7,925 1,189 9,114 9,114 105,271 1b.4 Subtotal Period 1b Period-Dependent Costs 2,897 1,328 24 8
65 11,033 2,686 18,039 17,770 270 1,113 22,255 36 132,850 1b.0 TOTAL PERIOD 1b COST 20,380 1,605 183 229 1,060 30,779 14,354 68,591 47,979 20,613 2,528 107,142 173,467 132,850 TLG Services, LLC LR-N24-0040 Attachment 2 Page 88 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 4 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours PERIOD 1c - Preparations for SAFSTOR Dormancy Period 1c Direct Decommissioning Activities 1c.1.1 Prepare support equipment for storage 593 89 682 682 3,000 1c.1.2 Install containment pressure equal. lines 69 10 79 79 700 1c.1.3 Interim survey prior to dormancy 733 220 953 953 9,036 1c.1.4 Secure building accesses a
1c.1.5 Prepare & submit interim report 92 14 106 106 583 1c.1 Subtotal Period 1c Activity Costs 661 825 333 1,819 1,819 12,736 583 Period 1c Collateral Costs 1c.3.1 Process decommissioning water waste 134 93 130 582 241 1,181 1,181 827 49,650 161 1c.3.3 Small tool allowance 6
1 7
7 1c.3.4 Spent Fuel Capital and Transfer 8,681 1,302 9,984 9,984 1c.3.5 Severance 643 96 740 740 1c.3.6 Barnwell Annual Access Fee 125 19 143 143 1c.3 Subtotal Period 1c Collateral Costs 134 6
93 130 582 9,449 1,660 12,055 2,071 9,984 827 49,650 161 Period 1c Period-Dependent Costs 1c.4.1 Insurance 159 16 174 174 1c.4.2 Property taxes 175 18 193 193 1c.4.3 Health physics supplies 226 57 283 283 1c.4.4 Heavy equipment rental 189 28 217 217 1c.4.5 Disposal of DAW generated 3
1 9
3 16 16 152 3,039 5
1c.4.6 Plant energy budget 525 79 604 604 1c.4.7 NRC Fees 177 18 195 195 1c.4.8 Emergency Planning Fees 10 1
11 11 1c.4.9 Spent Fuel Pool O&M 213 32 244 244 1c.4.10 ISFSI Operating Costs 12 2
14 14 1c.4.11 NEI Fees 145 22 167 167 1c.4.12 Security Staff Cost 1,688 253 1,941 1,941 27,528 1c.4.13 Utility Staff Cost 7,925 1,189 9,114 9,114 105,271 1c.4 Subtotal Period 1c Period-Dependent Costs 415 3
1 9
11,029 1,716 13,173 12,904 270 152 3,039 5
132,799 1c.0 TOTAL PERIOD 1c COST 134 1,083 97 131 591 21,303 3,709 27,047 16,794 10,253 979 52,689 12,903 133,383 PERIOD 1 TOTALS 20,515 4,057 293 364 1,687 126,116 29,234 182,266 132,314 49,952 4,117 172,022 186,390 910,771 PERIOD 2a - SAFSTOR Dormancy with Wet Spent Fuel Storage Period 2a Direct Decommissioning Activities 2a.1.1 Quarterly Inspection a
2a.1.2 Semi-annual environmental survey a
2a.1.3 Prepare reports a
2a.1.4 Bituminous roof replacement 440 66 507 507 2a.1.5 Maintenance supplies 295 74 369 369 2a.1 Subtotal Period 2a Activity Costs 735 140 875 875 Period 2a Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 72,236 10,835 83,072 83,072 2a.3.2 Severance 5,160 774 5,934 5,934 2a.3.3 Barnwell Annual Access Fee 1,001 150 1,152 1,152 2a.3 Subtotal Period 2a Collateral Costs 78,398 11,760 90,158 7,086 83,072 Period 2a Period-Dependent Costs 2a.4.1 Insurance 1,274 127 1,402 1,375 27 2a.4.2 Property taxes 874 87 961 961 2a.4.3 Health physics supplies 493 123 616 616 2a.4.4 Disposal of DAW generated 10 3
27 8
48 48 461 9,216 15 2a.4.5 Plant energy budget 843 126 970 485 485 2a.4.6 NRC Fees 590 59 649 649 2a.4.7 Emergency Planning Fees 82 8
90 90 2a.4.8 Spent Fuel Pool O&M 1,708 256 1,964 1,964 2a.4.9 ISFSI Operating Costs 98 15 113 113 2a.4.10 NEI Fees 1,165 175 1,340 1,340 2a.4.11 Security Staff Cost 13,562 2,034 15,596 515 15,081 221,135 2a.4.12 Utility Staff Cost 13,046 1,957 15,003 3,376 11,627 164,545 2a.4 Subtotal Period 2a Period-Dependent Costs 493 10 3
27 33,241 4,977 38,751 9,364 29,387 461 9,216 15 385,680 TLG Services, LLC LR-N24-0040 Attachment 2 Page 89 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 5 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 2a.0 TOTAL PERIOD 2a COST 493 10 3
27 112,375 16,876 129,784 17,325 112,459 461 9,216 15 385,680 PERIOD 2b - SAFSTOR Dormancy with Dry Spent Fuel Storage Period 2b Direct Decommissioning Activities 2b.1.1 Quarterly Inspection a
2b.1.2 Semi-annual environmental survey a
2b.1.3 Prepare reports a
2b.1.4 Bituminous roof replacement 8,633 1,295 9,928 9,928 2b.1.5 Maintenance supplies 5,781 1,445 7,226 7,226 2b.1 Subtotal Period 2b Activity Costs 14,414 2,740 17,154 17,154 Period 2b Collateral Costs 2b.3.1 Spent Fuel Capital and Transfer 19,990 2,998 22,988 22,988 2b.3.2 Severance 5,747 862 6,609 6,609 2b.3 Subtotal Period 2b Collateral Costs 25,737 3,861 29,597 6,609 22,988 Period 2b Period-Dependent Costs 2b.4.1 Insurance 24,977 2,498 27,475 15,661 11,814 2b.4.2 Property taxes 1,464 146 1,611 69 1,541 2b.4.3 Health physics supplies 4,522 1,131 5,653 5,653 2b.4.4 Disposal of DAW generated 88 30 240 73 431 431 4,133 82,659 135 2b.4.5 Plant energy budget 8,263 1,239 9,503 9,503 2b.4.6 NRC Fees 10,901 1,090 11,991 11,991 2b.4.7 Emergency Planning Fees 1,608 161 1,768 1,768 2b.4.8 ISFSI Operating Costs 1,922 288 2,210 2,210 2b.4.9 NEI Fees 2,283 342 2,626 2,626 2b.4.10 Security Staff Cost 93,475 14,021 107,497 23,112 84,385 1,386,237 2b.4.11 Utility Staff Cost 74,521 11,178 85,699 62,218 23,482 951,426 2b.4 Subtotal Period 2b Period-Dependent Costs 4,522 88 30 240 219,415 32,168 256,463 131,263 125,200 4,133 82,659 135 2,337,664 2b.0 TOTAL PERIOD 2b COST 4,522 88 30 240 259,566 38,769 303,214 155,026 148,189 4,133 82,659 135 2,337,664 PERIOD 2c - SAFSTOR Dormancy without Spent Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 Quarterly Inspection a
2c.1.2 Semi-annual environmental survey a
2c.1.3 Prepare reports a
2c.1.4 Bituminous roof replacement 2,492 374 2,866 2,866 2c.1.5 Maintenance supplies 1,669 417 2,086 2,086 2c.1 Subtotal Period 2c Activity Costs 4,161 791 4,952 4,952 Period 2c Period-Dependent Costs 2c.4.1 Insurance 4,088 409 4,496 4,496 2c.4.2 Property taxes 404 40 445 445 2c.4.3 Health physics supplies 1,273 318 1,592 1,592 2c.4.4 Disposal of DAW generated 25 8
67 20 120 120 1,153 23,069 38 2c.4.5 Plant energy budget 2,385 358 2,743 2,743 2c.4.6 NRC Fees 2,886 289 3,175 3,175 2c.4.7 NEI Fees 659 99 758 758 2c.4.8 Security Staff Cost 23,887 3,583 27,470 27,470 353,543 2c.4.9 Utility Staff Cost 15,611 2,342 17,953 17,953 206,233 2c.4 Subtotal Period 2c Period-Dependent Costs 1,273 25 8
67 49,921 7,458 58,752 58,752 1,153 23,069 38 559,777 2c.0 TOTAL PERIOD 2c COST 1,273 25 8
67 54,082 8,249 63,704 63,704 1,153 23,069 38 559,777 PERIOD 2 TOTALS 6,289 123 41 333 426,022 63,894 496,702 236,055 260,647 5,747 114,943 187 3,283,120 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 3a.1.1 Prepare preliminary decommissioning cost 205 31 235 235 1,300 3a.1.2 Review plant dwgs & specs.
724 109 833 833 4,600 3a.1.3 Perform detailed rad survey a
3a.1.4 End product description 157 24 181 181 1,000 3a.1.5 Detailed by-product inventory 205 31 235 235 1,300 3a.1.6 Define major work sequence 1,180 177 1,357 1,357 7,500 3a.1.7 Perform SER and EA 488 73 561 561 3,100 3a.1.8 Prepare/submit Defueled Technical Specifications 1,180 177 1,357 1,357 7,500 TLG Services, LLC LR-N24-0040 Attachment 2 Page 90 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 6 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 3a Direct Decommissioning Activities (continued) 3a.1.9 Perform Site-Specific Cost Study 787 118 905 905 5,000 3a.1.10 Prepare/submit Irradiated Fuel Management Plan 157 24 181 181 1,000 Activity Specifications 3a.1.11.1 Re-activate plant & temporary facilities 1,160 174 1,334 1,201 133 7,370 3a.1.11.2 Plant systems 656 98 754 679 75 4,167 3a.1.11.3 Reactor internals 1,117 168 1,285 1,285 7,100 3a.1.11.4 Reactor vessel 1,023 153 1,176 1,176 6,500 3a.1.11.5 Sacrificial shield 79 12 90 90 500 3a.1.11.6 Moisture separators/reheaters 157 24 181 181 1,000 3a.1.11.7 Reinforced concrete 252 38 290 145 145 1,600 3a.1.11.8 Main Turbine 329 49 378 378 2,088 3a.1.11.9 Main Condensers 329 49 378 378 2,088 3a.1.11.10 Pressure suppression structure 315 47 362 362 2,000 3a.1.11.11 Drywell 252 38 290 290 1,600 3a.1.11.12 Plant structures & buildings 491 74 565 282 282 3,120 3a.1.11.13 Waste management 724 109 833 833 4,600 3a.1.11.14 Facility & site closeout 142 21 163 81 81 900 3a.1.11 Total 7,025 1,054 8,078 7,361 717 44,633 Planning & Site Preparations 3a.1.12 Prepare dismantling sequence 378 57 434 434 2,400 3a.1.13 Plant prep. & temp. svces 3,600 540 4,140 4,140 3a.1.14 Design water clean-up system 220 33 253 253 1,400 3a.1.15 Rigging/Cont. Cntrl Envlps/tooling/etc.
2,400 360 2,760 2,760 3a.1.16 Procure casks/liners & containers 194 29 223 223 1,230 3a.1 Subtotal Period 3a Activity Costs 18,900 2,835 21,735 21,018 717 81,963 Period 3a Additional Costs 3a.2.1 Prepare/submit Defueled Technical Specifications (credit)
(1,180)
(177)
(1,357)
(7,500) 3a.2.2 Prepare/submit Irradiated Fuel Management Plan (Credit LT)
(157)
(24)
(181)
(1,000) 3a.2 Subtotal Period 3a Additional Costs (1,338)
(201)
(1,538)
(8,500)
Period 3a Collateral Costs 3a.3.1 Barnwell Annual Access Fee 500 75 575 575 3a.3 Subtotal Period 3a Collateral Costs 500 75 575 575 Period 3a Period-Dependent Costs 3a.4.1 Insurance 361 36 397 397 3a.4.2 Property taxes 36 4
39 39 3a.4.3 Health physics supplies 537 134 671 671 3a.4.4 Heavy equipment rental 756 113 869 869 3a.4.5 Disposal of DAW generated 11 4
30 9
54 54 514 10,287 17 3a.4.6 Plant energy budget 2,105 316 2,421 2,421 3a.4.7 NRC Fees 388 39 427 427 3a.4.8 NEI Fees 582 87 669 669 3a.4.9 Security Staff Cost 3,953 593 4,546 4,546 65,000 3a.4.10 Utility Staff Cost 19,977 2,997 22,974 22,974 257,920 3a.4 Subtotal Period 3a Period-Dependent Costs 1,293 11 4
30 27,402 4,328 33,066 33,066 514 10,287 17 322,920 3a.0 TOTAL PERIOD 3a COST 1,293 11 4
30 45,464 7,037 53,838 53,121 717 514 10,287 17 396,383 PERIOD 3b - Decommissioning Preparations Period 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems 745 112 857 771 86 4,733 3b.1.1.2 Reactor internals 630 94 724 724 4,000 3b.1.1.3 Remaining buildings 212 32 244 61 183 1,350 3b.1.1.4 CRD housings & NIs 157 24 181 181 1,000 3b.1.1.5 Incore instrumentation 157 24 181 181 1,000 3b.1.1.6 Removal primary containment 315 47 362 362 2,000 3b.1.1.7 Reactor vessel 571 86 657 657 3,630 3b.1.1.8 Facility closeout 189 28 217 109 109 1,200 3b.1.1.9 Sacrificial shield 189 28 217 217 1,200 3b.1.1.10 Reinforced concrete 157 24 181 90 90 1,000 3b.1.1.11 Main Turbine 327 49 376 376 2,080 3b.1.1.12 Main Condensers 329 49 378 378 2,088 TLG Services, LLC LR-N24-0040 Attachment 2 Page 91 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 7 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Detailed Work Procedures (continued) 3b.1.1.13 Moisture separators & reheaters 315 47 362 362 2,000 3b.1.1.14 Radwaste building 430 64 494 445 49 2,730 3b.1.1.15 Reactor building 430 64 494 445 49 2,730 3b.1.1 Total 5,153 773 5,926 5,359 567 32,741 3b.1 Subtotal Period 3b Activity Costs 5,153 773 5,926 5,359 567 32,741 Period 3b Additional Costs 3b.2.1 Site Characterization 3,640 1,092 4,732 4,732 19,100 7,852 3b.2.2 Dispose of Permanent Lead Shielding 2
6 10 3
21 21 19 4,650 3b.2 Subtotal Period 3b Additional Costs 2
6 10 3,640 1,095 4,753 4,753 19 4,650 19,100 7,852 Period 3b Collateral Costs 3b.3.1 Decon equipment 1,073 161 1,234 1,234 3b.3.2 DOC staff relocation expenses 1,565 235 1,800 1,800 3b.3.3 Pipe cutting equipment 1,200 180 1,380 1,380 3b.3.4 Barnwell Annual Access Fee 253 38 291 291 3b.3 Subtotal Period 3b Collateral Costs 1,073 1,200 1,819 614 4,705 4,705 Period 3b Period-Dependent Costs 3b.4.1 Decon supplies 39 10 48 48 3b.4.2 Insurance 322 32 355 355 3b.4.3 Property taxes 18 2
20 20 3b.4.4 Health physics supplies 300 75 375 375 3b.4.5 Heavy equipment rental 383 57 441 441 3b.4.6 Disposal of DAW generated 6
2 17 5
31 31 295 5,898 10 3b.4.7 Plant energy budget 1,067 160 1,227 1,227 3b.4.8 NRC Fees 197 20 216 216 3b.4.9 NEI Fees 295 44 339 339 3b.4.10 Security Staff Cost 2,004 301 2,304 2,304 32,945 3b.4.11 DOC Staff Cost 6,857 1,029 7,886 7,886 59,038 3b.4.12 Utility Staff Cost 10,125 1,519 11,644 11,644 130,727 3b.4 Subtotal Period 3b Period-Dependent Costs 39 683 6
2 17 20,885 3,253 24,885 24,885 295 5,898 10 222,710 3b.0 TOTAL PERIOD 3b COST 1,112 1,883 8
9 10 17 31,497 5,735 40,270 39,703 567 19 295 10,548 19,110 263,303 PERIOD 3 TOTALS 1,112 3,176 19 12 10 47 76,961 12,772 94,108 92,824 1,284 19 809 20,835 19,126 659,685 PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.1.1 Recirculation System Piping & Valves 44 167 42 30 140 149 131 703 703 986 1,043 138,461 2,413 4a.1.1.2 Recirculation Pumps & Motors 12 73 19 28 192 154 98 576 576 620 515 165,440 1,063 4a.1.1.3 CRDMs & NIs Removal 78 1,584 614 88 667 677 3,709 3,709 5,536 325,500 18,886 4a.1.1.4 Reactor Vessel Internals 242 7,054 9,895 1,232 7,411 373 11,955 38,163 38,163 2,592 2,379 630 498,374 30,565 1,381 4a.1.1.5 Vessel & Internals GTCC Disposal 6,294 944 7,239 7,239 1,633 314,644 4a.1.1.6 Reactor Vessel 8,878 2,951 886 6,054 373 10,701 29,844 29,844 30,118 1,925,068 30,565 1,381 4a.1.1 Totals 376 17,756 13,522 2,265 332 20,730 746 24,505 80,233 80,233 1,605 39,805 2,379 630 1,633 3,367,487 83,491 2,762 Removal of Major Equipment 4a.1.2 Main Turbine/Generator 832 2,654 906 11,932 2,399 18,722 18,722 124,489 5,601,986 9,089 4a.1.3 Main Condensers 3,417 1,505 514 6,770 2,097 14,303 14,303 70,627 3,178,200 37,186 Cascading Costs from Clean Building Demolition 4a.1.4.1 Reactor Building 1,362 204 1,567 1,567 7,884 4a.1.4.2 Low Level Radwaste Storage Facility 23 3
26 26 108 4a.1.4.3 Service & Radwaste Building 498 75 573 573 3,506 4a.1.4.4 Turbine Building 1,230 185 1,415 1,415 10,951 4a.1.4 Totals 3,114 467 3,581 3,581 22,449 Disposal of Plant Systems 4a.1.5.1 Administration Building HVAC (GC) 92 14 106 106 1,096 4a.1.5.2 Asphlt Strg/Pmp Hse/Aux Boiler HVAC (GF) 63 9
72 72 703 4a.1.5.3 Auxiliary Steam Generators (FA) 82 12 94 94 920 4a.1.5.4 Chilled Water (GB) 1,634 36 115 1,521 658 3,964 3,964 17,581 713,957 17,199 4a.1.5.5 Circulating Water (DA) 259 39 298 298 2,958 4a.1.5.6 Circulating Water - RCA (DA) 482 25 80 1,056 293 1,937 1,937 12,213 495,956 5,291 4a.1.5.7 Circulating Water Acid Injection (DE) 16 2
19 19 184 TLG Services, LLC LR-N24-0040 Attachment 2 Page 92 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 8 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Disposal of Plant Systems (continued) 4a.1.5.8 Circulating Water Dispersion (DG) 18 3
21 21 203 4a.1.5.9 Circulating Water Hypochlorination (DD) 86 13 99 99 955 4a.1.5.10 Condensate (AD) 2,979 454 502 3,937 2,308 2,033 12,212 12,212 45,514 17,705 2,973,956 33,704 4a.1.5.11 Condensate Demineralizer Process (AK) 1,144 45 59 577 172 429 2,427 2,427 6,672 1,312 354,933 12,589 4a.1.5.12 Condensate Pre-filter 283 26 28 230 122 143 832 832 2,658 935 167,571 3,152 4a.1.5.13 Condensate Transfer (AP) 1,637 60 78 756 231 598 3,360 3,360 8,736 1,763 467,671 17,918 4a.1.5.14 Condenser Air Removal (CG) 768 12 38 503 274 1,595 1,595 5,813 236,063 8,365 4a.1.5.15 Containment Atmosphere Control (GS) 484 6
20 263 164 936 936 3,036 123,306 5,193 4a.1.5.16 Cooling Tower (DB) 34 5
39 39 394 4a.1.5.17 Extraction Steam (AF) 1,927 37 122 1,614 746 4,446 4,446 18,655 757,607 21,099 4a.1.5.18 Feedwater (AE) 1,193 128 152 1,264 633 681 4,050 4,050 14,612 4,855 901,970 13,411 4a.1.5.19 Gaseous Radwaste (HA) 1,461 25 83 1,095 544 3,208 3,208 12,653 513,862 16,043 4a.1.5.20 Generator Gas Control (CC) 54 0
1 17 16 88 88 195 7,902 531 4a.1.5.21 Generator Seal Oil (CD) 89 1
4 54 31 180 180 630 25,566 942 4a.1.5.22 Gland Steam Removal (CJ,CP,CV) 459 6
20 257 157 898 898 2,977 120,879 5,011 4a.1.5.23 Intake Structure HVAC (GQ) 22 3
26 26 251 4a.1.5.24 Leak Detection (SK) 8 0
0 2
2 12 12 22 913 77 4a.1.5.25 Leak Rate Test Equipment (GP) 21 0
0 6
6 34 34 71 2,888 233 4a.1.5.26 Lube Oil Storg/Transfr/Purification (CF) 84 13 97 97 938 4a.1.5.27 MSIV Sealing (KP) 11 0
0 3
3 18 18 40 1,627 106 4a.1.5.28 Main Generator (MA) 14 0
1 19 7
41 41 221 8,982 153 4a.1.5.29 Main Steam (AB) 1,468 30 99 1,299 580 3,475 3,475 15,015 609,777 16,187 4a.1.5.30 Main Turbine (AC) 1,315 49 161 2,120 676 4,321 4,321 24,512 995,443 14,542 4a.1.5.31 Main Turbine Control Oil (CH) 184 2
5 66 57 314 314 764 31,034 1,829 4a.1.5.32 Miscellaneous (QC,QM,XX) 1 0
1 1
8 4a.1.5.33 Neutron Monitoring (SE) 90 6
5 32 31 37 201 201 374 240 30,446 1,029 4a.1.5.34 Oily Waste (LE) 199 30 229 229 2,273 4a.1.5.35 Plant Heating (GA) 1,285 12 37 491 402 2,227 2,227 5,677 230,543 13,233 4a.1.5.36 Reactor Protection (SB) 24 4
27 27 267 4a.1.5.37 Safety & Turbine Auxiliary Cooling (EG) 4,950 112 371 4,886 2,037 12,356 12,356 56,484 2,293,826 54,533 4a.1.5.38 Sampling (RC) 468 1
4 58 127 659 659 670 27,229 5,622 4a.1.5.39 Stator Cooling (CE) 88 1
3 41 29 161 161 469 19,066 930 4a.1.5.40 Steam Removal (FW) 115 17 132 132 1,315 4a.1.5.41 Storm Drains (LA,LB) 2,276 341 2,618 2,618 26,163 4a.1.5.42 Turbine Building HVAC (GE) 1,017 15 50 655 362 2,099 2,099 7,572 307,513 10,722 4a.1.5.43 Turbine Generator Lube Oil (CB) 290 13 40 525 159 1,026 1,026 6,072 246,603 3,156 4a.1.5.44 Turbine Sealing Steam (CA) 897 11 35 461 300 1,704 1,704 5,330 216,441 9,690 4a.1.5 Totals 30,070 1,113 2,115 23,808 3,497 12,054 72,658 68,781 3,877 275,239 26,808 12,883,530 331,115 4a.1.6 Scaffolding in support of decommissioning 3,946 57 20 236 28 1,038 5,326 5,326 2,464 217 124,676 48,269 4a.1 Subtotal Period 4a Activity Costs 376 59,134 18,851 5,820 43,079 24,255 746 42,561 194,823 190,946 3,877 474,424 66,831 2,379 630 1,633 25,155,880 531,598 2,762 Period 4a Additional Costs 4a.2.1 Remedial Action Surveys 2,334 700 3,035 3,035 30,582 4a.2 Subtotal Period 4a Additional Costs 2,334 700 3,035 3,035 30,582 Period 4a Collateral Costs 4a.3.1 Process decommissioning water waste 3
6 9
39 13 71 71 56 3,341 11 4a.3.3 Small tool allowance 804 121 925 832 92 4a.3.4 Barnwell Annual Access Fee 736 110 846 846 4a.3 Subtotal Period 4a Collateral Costs 3
804 6
9 39 736 244 1,842 1,749 92 56 3,341 11 Period 4a Period-Dependent Costs 4a.4.1 Decon supplies 112 28 141 141 4a.4.2 Insurance 936 94 1,030 1,030 4a.4.3 Property taxes 53 5
58 58 4a.4.4 Health physics supplies 4,088 1,022 5,110 5,110 4a.4.5 Heavy equipment rental 3,699 555 4,254 4,254 4a.4.6 Disposal of DAW generated 197 66 535 163 962 962 9,229 184,583 301 4a.4.7 Plant energy budget 2,942 441 3,383 3,383 4a.4.8 NRC Fees 798 80 878 878 4a.4.9 Liquid Radwaste Processing Equipment/Services 631 95 725 725 4a.4.10 NEI Fees 856 128 984 984 4a.4.11 Security Staff Cost 5,816 872 6,688 6,688 95,630 4a.4.12 DOC Staff Cost 23,704 3,556 27,260 27,260 211,151 4a.4.13 Utility Staff Cost 29,693 4,454 34,147 34,147 382,521 4a.4 Subtotal Period 4a Period-Dependent Costs 112 7,787 197 66 535 65,428 11,493 85,618 85,618 9,229 184,583 301 689,302 TLG Services, LLC LR-N24-0040 Attachment 2 Page 93 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 9 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 4a.0 TOTAL PERIOD 4a COST 492 67,725 19,054 5,895 43,079 24,830 69,244 54,999 285,318 281,348 3,969 474,424 76,115 2,379 630 1,633 25,343,800 562,492 692,064 PERIOD 4b - Site Decontamination Period 4b Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks 1,321 132 193 153 1,737 1,170 4,706 4,706 13,339 847,374 1,579 Disposal of Plant Systems 4b.1.2.1 Auxiliary Oil Storage (JA) 351 53 403 403 3,861 4b.1.2.2 Breathing Air (KG,KH) 588 6
20 258 189 1,062 1,062 2,985 121,232 6,058 4b.1.2.3 Building & Equip Radwaste Drains (HG) 4,956 245 160 382 1,492 1,718 8,954 8,954 4,418 11,449 907,345 52,656 4b.1.2.4 Chemical Waste (LD) 37 6
42 42 421 4b.1.2.5 Control Area Chilled Water (GJ) 373 56 429 429 4,271 4b.1.2.6 Control Rod Drive Hydraulic Supply (BF) 2,733 133 79 467 492 902 4,805 4,805 5,395 3,683 459,295 28,775 4b.1.2.7 Control Room Supply & Exhaust (GK) 68 10 79 79 787 4b.1.2.8 Core Spray Control (BE) 619 47 37 215 236 256 1,409 1,409 2,488 1,798 215,979 6,878 4b.1.2.9 Decon Facility (HD) 170 1
4 56 52 283 283 648 26,323 1,803 4b.1.2.10 Demineralized Water Makeup/Transfer (AN) 1,334 22 68 899 481 2,804 2,804 10,391 421,971 14,111 4b.1.2.11 Diesel Area Supply & Exhaust (GM) 100 15 115 115 1,149 4b.1.2.12 Diesel Fuel Oil Storage & Transfer (JE) 316 47 363 363 3,518 4b.1.2.13 Domestic Water (KD) 144 22 166 166 1,636 4b.1.2.14 Domestic Water - RCA (KD) 316 3
8 107 97 531 531 1,242 50,436 3,106 4b.1.2.15 Drywell Ventilation (GT) 91 2
7 97 39 237 237 1,126 45,718 995 4b.1.2.16 Electrical 7,028 1,054 8,082 8,082 77,827 4b.1.2.17 Electrical - RCA 1,656 21 70 927 566 3,240 3,240 10,719 435,306 18,280 4b.1.2.18 Electrical - RCA (Clean) 4,223 54 170 2,238 1,422 8,107 8,107 25,871 1,050,637 43,967 4b.1.2.19 FLEX Systems 76 11 87 87 834 4b.1.2.20 Filtration/Recirc & Ventilation (GU) 147 2
6 85 51 290 290 978 39,712 1,585 4b.1.2.21 Fire Protection (KC) 595 89 685 685 6,643 4b.1.2.22 Fire Protection - RCA (KC) 1,806 18 57 745 573 3,198 3,198 8,611 349,694 19,202 4b.1.2.23 Fresh Water (AM) 106 16 121 121 1,187 4b.1.2.24 Fuel Pool Cooling (EC) 1,186 49 54 474 206 432 2,401 2,401 5,485 1,568 323,147 12,965 4b.1.2.25 HPCI Steam (FD) 267 13 13 111 53 100 557 557 1,285 401 77,925 2,918 4b.1.2.26 High Pressure Coolant Injection (BJ) 312 57 41 198 292 192 1,092 1,092 2,292 2,223 235,332 3,513 4b.1.2.27 Instrument Compressed Air (KB) 1,032 8
26 339 314 1,719 1,719 3,924 159,339 10,440 4b.1.2.28 Liquid/Chemical Radwaste (HB) 3,574 251 199 1,277 1,165 1,431 7,899 7,899 14,768 8,862 1,167,985 39,274 4b.1.2.29 Miscellaneous Nuclear Boiler Recirc (BB) 262 13 15 122 60 102 574 574 1,412 458 86,524 2,950 4b.1.2.30 Normal Drains (LF,LG) 145 22 167 167 1,676 4b.1.2.31 Primary Containment Instrument Gas (KL) 155 3
9 113 57 337 337 1,311 53,239 1,561 4b.1.2.32 Process Radiation Monitoring (SP) 186 2
5 72 58 323 323 828 33,609 2,068 4b.1.2.33 RCIC Steam (FB,FC) 681 11 35 461 246 1,433 1,433 5,334 216,624 7,435 4b.1.2.34 Rad Laundry (HH,ZZ) 123 1
3 46 38 212 212 529 21,487 1,306 4b.1.2.35 Radwaste Tank Vent Filters (GH) 607 7
23 309 202 1,149 1,149 3,575 145,201 6,518 4b.1.2.36 Reactor Auxiliaries Cooling (ED) 1,004 29 93 1,229 452 2,808 2,808 14,212 577,138 10,678 4b.1.2.37 Reactor Building HVAC (GR) 724 11 36 471 258 1,500 1,500 5,447 221,215 7,574 4b.1.2.38 Reactor Core Isolation Cooling (BD) 176 18 12 49 99 80 435 435 568 757 71,384 1,941 4b.1.2.39 Reactor Water Cleanup (BG) 686 41 27 109 208 248 1,318 1,318 1,255 1,586 152,488 7,475 4b.1.2.40 Refueling Water Transfer (BN) 159 3
8 110 58 338 338 1,272 51,637 1,758 4b.1.2.41 Residual Heat Removal (BC) 2,100 289 215 1,136 1,459 1,121 6,320 6,320 13,138 11,125 1,245,292 23,532 4b.1.2.42 Security (RG) 9 1
10 10 100 4b.1.2.43 Service Area Supply & Exhaust Air (GL) 77 12 89 89 917 4b.1.2.44 Service Compressed Air (KA) 1,042 10 30 398 326 1,805 1,805 4,601 186,848 10,498 4b.1.2.45 Service Water (EA) 105 16 121 121 1,182 4b.1.2.46 Service Water - RCA (EA) 399 17 55 722 218 1,410 1,410 8,346 338,918 4,357 4b.1.2.47 Service Water Hypochlorination (EP,EQ) 121 18 139 139 1,340 4b.1.2.48 Solid Radwaste (HC) 1,469 132 92 484 625 623 3,424 3,424 5,591 4,744 531,716 15,978 4b.1.2.49 Standby Liquid Control (BH) 78 1
3 44 27 152 152 503 20,428 818 4b.1.2.50 Standby/Emergency Diesel Generator (KJ) 254 38 292 292 2,854 4b.1.2.51 Suppression Pool/Torus Cleanup (EE) 121 1
4 51 39 215 215 587 23,833 1,313 4b.1.2 Totals 44,889 1,518 1,685 14,803 6,386 14,453 83,735 72,344 11,391 171,132 48,653 10,064,960 484,489 4b.1.3 Scaffolding in support of decommissioning 5,919 86 31 354 42 1,557 7,989 7,989 3,696 326 187,015 72,403 Decontamination of Site Buildings 4b.1.4.1 Reactor Building 9,413 4,676 1,123 706 3,376 3,952 7,588 30,834 30,834 39,031 33,171 3,670,503 152,416 4b.1.4.2 Low Level Radwaste Storage Facility 189 52 2
20 8
18 116 406 406 95 629 33,526 2,605 4b.1.4.3 Service & Radwaste Building 795 243 16 85 39 105 505 1,788 1,788 454 2,817 154,301 11,260 4b.1.4.4 Turbine Building 3,168 1,596 66 393 977 348 2,282 8,829 8,829 11,300 10,761 972,986 51,086 4b.1.4.5 Reactor (post fuel) 1,152 1,625 76 428 102 484 1,190 5,057 5,057 1,177 13,952 721,672 29,364 4b.1.4 Totals 14,716 8,192 1,283 1,632 4,503 4,907 11,681 46,914 46,914 52,058 61,330 5,552,987 246,731 TLG Services, LLC LR-N24-0040 Attachment 2 Page 94 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 10 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 4b.1.5 Prepare/submit License Termination Plan 645 97 741 741 4,096 4b.1.6 Receive NRC approval of termination plan a
4b.1 Subtotal Period 4b Activity Costs 16,037 59,131 3,081 3,500 19,660 13,072 645 28,958 144,084 132,693 11,391 226,886 123,648 16,652,330 805,202 4,096 Period 4b Additional Costs 4b.2.1 License Termination Survey Planning 1,656 497 2,153 2,153 12,480 4b.2.2 ISFSI License Termination 381 272 758 2,426 3,679 1,879 9,395 9,395 61,344 3,242,195 18,415 6,089 4b.2.3 Remove Underground Utilities 740 115 128 984 984 3,127 4b.2.4 Operational Tools & Equipment 23 65 626 169 882 882 11,760 294,000 32 4b.2.5 Asbestos Abatement 19 2
5 26 26 240 4b.2.6 Remedial Action Surveys 3,526 1,058 4,583 4,583 46,186 4b.2 Subtotal Period 4b Additional Costs 1,140 295 823 3,052 8,977 3,735 18,023 8,628 9,395 73,104 3,536,195 67,999 18,569 Period 4b Collateral Costs 4b.3.1 Process decommissioning water waste 17 31 43 194 66 351 351 276 16,543 54 4b.3.3 Small tool allowance 1,244 187 1,430 1,430 4b.3.4 Decommissioning Equipment Disposition 140 57 575 69 126 967 967 6,000 529 303,608 147 4b.3.5 Barnwell Annual Access Fee 1,111 167 1,278 1,278 4b.3 Subtotal Period 4b Collateral Costs 17 1,244 171 100 575 263 1,111 546 4,026 4,026 6,000 805 320,151 201 Period 4b Period-Dependent Costs 4b.4.1 Decon supplies 3,048 762 3,809 3,809 4b.4.2 Insurance 1,414 141 1,555 1,555 4b.4.3 Property taxes 79 8
87 87 4b.4.4 Health physics supplies 6,292 1,573 7,865 7,865 4b.4.5 Heavy equipment rental 5,734 860 6,594 6,594 4b.4.6 Disposal of DAW generated 248 83 675 206 1,212 1,212 11,632 232,635 379 4b.4.7 Plant energy budget 3,508 526 4,034 4,034 4b.4.8 NRC Fees 1,205 121 1,326 1,326 4b.4.9 Liquid Radwaste Processing Equipment/Services 953 143 1,095 1,095 4b.4.10 NEI Fees 1,292 194 1,486 1,486 4b.4.11 Security Staff Cost 8,783 1,317 10,101 10,101 144,425 4b.4.12 DOC Staff Cost 34,887 5,233 40,120 40,120 309,647 4b.4.13 Utility Staff Cost 42,553 6,383 48,936 48,936 545,348 4b.4 Subtotal Period 4b Period-Dependent Costs 3,048 12,026 248 83 675 94,675 17,467 128,222 128,222 11,632 232,635 379 999,419 4b.0 TOTAL PERIOD 4b COST 19,101 73,541 3,794 4,507 20,235 17,062 105,407 50,706 294,354 273,568 9,395 11,391 232,886 209,188 20,741,310 873,781 1,022,083 PERIOD 4f - License Termination Period 4f Direct Decommissioning Activities 4f.1.1 ORISE confirmatory survey 183 55 238 238 4f.1.2 Terminate license a
4f.1 Subtotal Period 4f Activity Costs 183 55 238 238 Period 4f Additional Costs 4f.2.1 License Termination Survey 20,278 6,083 26,362 26,362 227,763 6,240 4f.2 Subtotal Period 4f Additional Costs 20,278 6,083 26,362 26,362 227,763 6,240 Period 4f Collateral Costs 4f.3.1 DOC staff relocation expenses 1,565 235 1,800 1,800 4f.3.2 Barnwell Annual Access Fee 375 56 432 432 4f.3 Subtotal Period 4f Collateral Costs 1,941 291 2,232 2,232 Period 4f Period-Dependent Costs 4f.4.2 Property taxes 27 3
29 29 4f.4.3 Health physics supplies 1,164 291 1,455 1,455 4f.4.4 Disposal of DAW generated 7
3 20 6
36 36 350 6,999 11 4f.4.5 Plant energy budget 316 47 363 363 4f.4.6 NRC Fees 470 47 517 517 4f.4.7 NEI Fees 437 65 502 502 4f.4.8 Security Staff Cost 1,226 184 1,410 1,410 18,737 4f.4.9 DOC Staff Cost 6,790 1,018 7,808 7,808 56,992 4f.4.10 Utility Staff Cost 6,530 979 7,509 7,509 74,168 4f.4 Subtotal Period 4f Period-Dependent Costs 1,164 7
3 20 15,795 2,642 19,631 19,631 350 6,999 11 149,897 4f.0 TOTAL PERIOD 4f COST 1,164 7
3 20 38,197 9,071 48,462 48,462 350 6,999 227,774 156,137 TLG Services, LLC LR-N24-0040 Attachment 2 Page 95 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 11 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours PERIOD 4 TOTALS 19,594 142,430 22,856 10,404 63,314 41,912 212,849 114,776 628,134 603,379 9,395 15,360 707,310 285,654 2,379 630 1,633 46,092,120 1,664,048 1,870,284 PERIOD 5b - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b.1.1.1 Reactor Building 7,732 1,160 8,892 8,892 44,790 5b.1.1.2 Administration Bldg (U2 Turbine Bldg) 1,418 213 1,631 1,631 7,114 5b.1.1.3 Administration Building (TB2) 1,611 242 1,852 1,852 14,488 5b.1.1.4 Aux Boiler & Domestic Wtr Pre-Treat Bldg 250 37 287 287 1,151 5b.1.1.5 Barge Facility 1,574 236 1,810 1,810 6,990 5b.1.1.6 Carpenter Shop 34 5
39 39 309 5b.1.1.7 Circulating Water Pump Structure 1,587 238 1,825 1,825 13,166 5b.1.1.9 Diesel & Control Building 3,949 592 4,542 4,542 26,196 5b.1.1.10 Fire Water Pump House 22 3
25 25 132 5b.1.1.11 Fire Water Tank Fdn and Valve Pit 42 6
49 49 189 5b.1.1.12 Flood Wall 24 4
27 27 105 5b.1.1.13 Guard House 220 33 253 253 1,627 5b.1.1.14 Guard House Emergency Generator Building 5
1 6
6 28 5b.1.1.15 Low Level Radwaste Storage Facility 506 76 582 582 2,915 5b.1.1.16 Material Center 1,971 296 2,267 2,267 13,448 5b.1.1.17 Miscellaneous Site Structures 475 71 546 546 4,387 5b.1.1.18 Miscellaneous Yard Tanks & Pads 202 30 233 233 964 5b.1.1.19 Nuclear Service Building 388 58 446 446 3,173 5b.1.1.20 Security Improvements 1,970 296 2,266 2,266 9,271 5b.1.1.21 Service & Radwaste Building 4,492 674 5,166 5,166 31,669 5b.1.1.22 Service Water Intake Structure 1,050 157 1,207 1,207 8,117 5b.1.1.23 Turbine Building 11,407 1,711 13,118 13,118 102,356 5b.1.1.24 Turbine Pedestal 1,110 166 1,276 1,276 4,987 5b.1.1.25 Unit 2 Reactor Building Foundation 4,119 618 4,737 4,737 22,596 5b.1.1.26 Unit 2 Turbine Pedestal 983 147 1,130 1,130 4,415 5b.1.1 Totals 47,140 7,071 54,211 54,211 324,584 Site Closeout Activities 5b.1.2 BackFill Site 9,116 1,367 10,483 10,483 11,989 5b.1.3 Grade & landscape site 888 133 1,022 1,022 1,683 5b.1.4 Final report to NRC 246 37 282 282 1,560 5b.1 Subtotal Period 5b Activity Costs 57,144 246 8,608 65,998 282 65,716 338,257 1,560 Period 5b Additional Costs 5b.2.1 Concrete Crushing 2,964 14 447 3,424 3,424 10,940 5b.2.2 Service Water Intake Structure cofferdam 537 81 617 617 4,032 5b.2.3 Cooling Tower Demolition 4,549 682 5,231 5,231 20,303 5b.2.4 Cooling Tower Demolition Fill Removal 3,413 6,864 1,542 11,819 11,819 58,433 5b.2.5 ISFSI Demolition and Site Restoration 5,591 609 930 7,131 7,131 51,804 160 5b.2.6 Construction Debris 1,980 297 2,277 2,277 5b.2.7 Asphalt Milling 442 66 508 508 5b.2 Subtotal Period 5b Additional Costs 17,054 9,909 4,044 31,008 7,131 23,877 145,511 160 Period 5b Collateral Costs 5b.3.1 Small tool allowance 717 108 824 824 5b.3 Subtotal Period 5b Collateral Costs 717 108 824 824 Period 5b Period-Dependent Costs 5b.4.2 Property taxes 82 8
90 90 5b.4.3 Heavy equipment rental 7,778 1,167 8,944 8,944 5b.4.4 Plant energy budget 482 72 554 554 5b.4.5 Security Staff Cost 3,736 560 4,297 4,297 57,100 5b.4.6 DOC Staff Cost 19,920 2,988 22,908 22,908 161,784 5b.4.7 Utility Staff Cost 8,460 1,269 9,729 9,729 92,788 5b.4 Subtotal Period 5b Period-Dependent Costs 7,778 32,679 6,064 46,521 46,521 311,672 5b.0 TOTAL PERIOD 5b COST 82,693 42,834 18,825 144,352 282 7,131 136,939 483,768 313,392 PERIOD 5 TOTALS 82,693 42,834 18,825 144,352 282 7,131 136,939 483,768 313,392 TLG Services, LLC LR-N24-0040 Attachment 2 Page 96 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix D, Page 12 of 12 Table D Hope Creek Generating Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2021 Dollars)
Costs run: Mon, Dec 13, 2021 at 15:15:32 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2016.08.16d Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours TOTAL COST TO DECOMMISSION 41,220 238,644 23,291 10,822 63,324 43,979 894,956 241,027 1,557,262 1,075,404 328,275 153,583 707,329 296,327 2,379 630 1,633 46,399,910 2,353,519 7,078,853 TOTAL COST TO DECOMMISSION WITH 18.31% CONTINGENCY:
$1,557,262 thousands of 2021 dollars TOTAL NRC LICENSE TERMINATION COST IS 69.06% OR:
$1,075,404 thousands of 2021 dollars SPENT FUEL MANAGEMENT COST IS 21.08% OR:
$328,275 thousands of 2021 dollars NON-NUCLEAR DEMOLITION COST IS 9.86% OR:
$153,583 thousands of 2021 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):
299,336 Cubic Feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:
1,633 Cubic Feet TOTAL SCRAP METAL REMOVED:
109,285 Tons TOTAL CRAFT LABOR REQUIREMENTS:
2,353,519 Man-hours End Notes:
n/a - indicates that this activity not charged as decommissioning expense a - indicates that this activity performed by decommissioning staff 0 - indicates that this value is less than 0.5 but is non-zero A cell containing " - " indicates a zero value TLG Services, LLC LR-N24-0040 Attachment 2 Page 97 / 99
Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix E, Page 1 of 2 TLG Services, LLC APPENDIX E ISFSI DECOMMISSIONING LR-N24-0040 Attachment 2 Page 98 / 99
Hope Creek Generating Station Decommissioning Cost Analysis Document P07-1794-001, Rev. 0 Appendix E, Page 2 of 2 Activity Description Removal Costs Packaging Costs Transport Costs LLRW Disposal Costs Other Costs Total Costs Burial Volume Class A (cubic feet)
Craft Manhours Oversight and Contractor Manhours Decommissioning Contractor Planning (characterization, specs and procedures) 387 387 1,168 Decontamination (activated disposition) 381 272 758 2,426 3,837 61,344 3,583 License Termination (radiological surveys) 2,189 2,189 14,832 Subtotal 381 272 758 2,426 2,576 6,413 61,344 18,415 1,168 Supporting Costs NRC and NRC Contractor Fees and Costs 544 544 1,153 Insurance 97 97 Property taxes 12 12 Plant energy budget 6
6 Barnwell Annual Access Fee 168 168 Security Staff Cost 128 128 2,110 Utility Staff Cost 148 148 1,658 Subtotal 1,103 1,103 4,921 Total (w/o contingency) 381 272 758 2,426 3,679 7,516 61,344 18,415 6,089 Total (w/25% contingency) 477 340 948 3,032 4,598 9,395 The application of contingency (25%) is consistent with the evaluation criteria referenced by the NRC in NUREG-1757 ("Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. NRC's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Vol. 3, Rev. 1, February 2012)
Table E Hope Creek Generating Station ISFSI Decommissioning Cost Estimate (thousands of 2021 dollars)
TLG Services, LLC LR-N24-0040 Attachment 2 Page 99 / 99