ML24150A005

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Attachment 2: Decommissioning Cost Analysis Analysis for Hope Creek Generating Station
ML24150A005
Person / Time
Site: Salem, Hope Creek, Peach Bottom  PSEG icon.png
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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page iii of xxi

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 ALTERNATIV ES........................................................ 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 ESTIMATE S.............................................................................................. 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

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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 WAST ES................................................................................... 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

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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 Analys is.................................................................... D-1 E. ISFSI Decommissioning...................................................................................... E-1

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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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 1, Page 1 of 11

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 engine ering 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 ma de 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.

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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 s tructure. 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 be low 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.

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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

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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 cou ld be treated as a generic alternative.

The NRC had considered rulemaking to a lter 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 rul emaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the unr esolved 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

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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 plan ts 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 include d a requirement that it consider

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

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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

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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. 305 3, 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 Isl and 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.

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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, Sub part K[15]), has been constructed to support continued plant operations. The facility is assumed to be expanded to suppor t 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.

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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

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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 Terminatio n,[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

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from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Supe rfund).[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.

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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

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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 fr om 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

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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 prop osed 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 hav e 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

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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.

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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

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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 pl an, 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

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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

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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 crea tes 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 embedme nts.

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.

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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 t he 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.

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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.

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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,

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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.

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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.

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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.

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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

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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

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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

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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.

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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

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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.

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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.

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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

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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:

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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

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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.

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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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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) i s 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

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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.

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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

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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

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salvage value on this machinery and equipment wou ld 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

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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,

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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.

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TABLE 3.2 SAFSTOR ALTERNATIVE TOTAL ANNUAL EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & 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

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TABLE 3.2 (continued)

SAFSTOR ALTERNATIVE TOTAL ANNUAL EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page 29 of 37

TABLE 3.2 (continued)

SAFSTOR ALTERNATIVE TOTAL ANNUAL EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & 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

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TABLE 3.2a SAFSTOR ALTERNATIVE LICENSE TERMINATION EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page 31 of 37

TABLE 3.2a (continued)

SAFSTOR ALTERNATIVE LICENSE TERMINATION EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page 32 of 37

TABLE 3.2a (continued)

SAFSTOR ALTERNATIVE LICENSE TERMINATION EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor& 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 12300001 23 2108 6900006 9

Total 694,612 119,343 28,326 120,262 112,861 1,075,404

  • Schedule of Expenditures for Disposal of GTCC included in Table 3.2a (thousands, 2021 Dollars)

Equipment Year Labor& Materials Energy Burial Other Total

2101 00008 22822 2102 0000 4,920 4,920 2103 0000 1,496 1,496

Total 00000 7,239

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page 33 of 37

TABLE 3.2b SAFSTOR ALTERNATIVE SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & Materials Energy Burial Other Total

2044 00004 17417 2045 00005 75575 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page 34 of 37

TABLE 3.2b (continued)

SAFSTOR ALTERNATIVE SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & 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 000000 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Page 35 of 37

TABLE 3.2c SAFSTOR ALTERNATIVE SITE RESTORATION EXPENDITURES (thousands, 2021 Dollars)

Equipment Year Labor & Materials Energy Burial Other Total

2044-99 000000 2100 48400004 84 2101 1,236 16000 1,252 2102 2,602 96000 2,698 2103 4,290 98000 4,388 2104 5,041 99000 5,141 2105 2,631 52000 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 3, Page 37 of 37

FIGURE 3.2 SAFSTOR SCENARIO MANPOWER LEVELS

500

- Craft 450 - - Utili ty - DOC

- secu ri ty M 400 - - Other Staff

- Total 350

300

1/1 I!:! 250 IL

200

/1 r-\\ \\

150

100 I, \\ \\

( ~ r'\\_ I ' \\

50 ~ \\

- !l: r-.... \\ - ~

0

~

Year

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 1 of 7

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.

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 2 of 7

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.

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 3 of 7

FIGURE 4.1 DECON ACTIVITY SCHEDULE

ID T a s k N am e y. 1 I YI I Y2 I Y3 I Y4 I Y5 I Y6 I Y7 I Ys I Y9 IY1o lYn lY1 2 IY 13 1 Hope Cr eek s che dule DE CON I I ' ' ' ' ' ' ' ' ' ' '

I I I I 2 Shutdown plant

  • I I I I I I I I I 3 P erio d l a
  • S hu t down throug h tran siti on ' ' '

I I I 5 Fue l stor a ge p ool op era t ion s I I I I I I 6 Dry fue l s to ra g e opera t ion s : : ' I 7 R econfigu re p lant I I I 8 P r epar e a ctivi ty s p ecifi cati ons I I I

I I I 9 P erform s ite cha rac t e rizatio n ' ' '

I 4 Certificate of permanent cessation of operat ions s u bmitted

  • I I

I I

I 10 P SDAR submitted :.

I ll Wr itte n certificate of p erm anen t remo val of fuel sub mitted :.

I I

I I

12 Site s pecific decommi ssioning cos t es timate s ubmitted :+

I 13 DO C staff mobilized :+

I 14 P eriod lb

  • Decommissi on in g pr eparat i on s *~

16 Fue l stora ge p ool op er atio n s -

16 R econfigu re p la nt (continu e d) -

17 Dry fue l s t ora ge operat io n s -

18 P r ep are d etai led work p1*oced ures -

19 D econ NSSS -

20 I sol ate s p en t fu el po ol -

21 P eriod 2a

  • La r ge compone n t r emova l

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 4 of 7

FIGURE 4.1 (continued)

DECON ACTIVITY SCHEDULE

ID Tas k Name Y -1 I Yl I Y2 I Y3 I Y4 I Y5 I Y6 I Y7 I Ys I Y9 IY10 IYn lY12 IY 13 22 Fue l storage pool operat ions ' ' lli-jl ' '

I I 23 Dry fue l sto r age operat ions I I

I I 24 Prepara t ion for reac tor vesse l remo val -I I

I I 27 Non -essent ia l systems " -i-11

I I 28 Main t u rb ine/gene r ato r -i-11

I I 29 Main condenser -i-11

I 25 Reac tor vesse l & interna ls 26 Rema i ning la rge NSSS components disposition I -

30 Li cense term ina tion plan s ubmi tted.,

I 31 P eriod 2b - Decontam i nation (followi ng wet fu el)

I I I '

32 Dry fuel s torage operations ' ' ' I 33 Remo ve systems no t supporting wet fuel s torage I I

I 34 Decon buildings not supporting wet fuel storage..

35 Li cense term ina tion plan approved.,

I 36 Fue l storage pool available for decommission i ng

  • I I

37 P eri od 2f - P l ant license te r mination '11111"

I 38 Dry fuel sto r age operat ions

  • I

I 39 Fina l Site Survey 40 NRC review & appro v al *

  • 41 Part 50 license te rminated 42 P eriod 3b - S ite resto r ati on ' '

I I 43 Dry fuel sto r age operat ions I I

I I 44 Building demoli tio n s, backfill and land scapi ng ~~/P'/tpWJ

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 5 of 7

FIGURE 4.1 (continued)

DECON ACTIVITY SCHEDULE

ID Task Name Y-1 1 Yl I Y2 I Y 3 I Y4 1 Y5 I Y6 I Y7 I Y8 I Y9 IY1 0IY11IY1 2IY13. ;

45 Turbine & Admin Building Interior Demo liti on...... ' ' '

50 Reactor Building Interior Demolition ' ' * * ' ' '

53 Dies e l & Contro l Building Interior Demo litio n ' ' * '

56 Service & Radwa ste Building Int erior Demo litio n ' ' ' '

React.or Building Ext-erior Demolition ' ' ** ' ' '

51....

46 Turbine & Admin Building Exterior Demo litio n '

I 47 U nit 1 Turbine Pede stal Demoli tio n " I 48 U nit 2 Turbine Pede stal Demo litio n ', '

49 Turbine & Admin Building Backfill ' *' I

  • 57 Service & Radwa ste Building Exterior Demo litio n I I I I I I I I 58 Service & Radwa ste 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

TLG Services, LLC LR-N24-0040 Attachment 2 Page 65 / 99 Hope Creek Generating Station Document P07-1794- 001, Rev. 0 Decommissioning Cost Analysis Section 4, Page 7 of 7

FIGURE 4.3 DECOMMISSIONING TIMELINE SAFSTOR (not to scale)

S h ut do w n A p ri l 11, 20 46

END

P er io d 1 P er io d 3 P er io d 4 P er io d 5 SAFSTOR P er io d 2 D eco m mis sio n in g D eco m mis sio n in g S it e P re pa r a t io ns D or ma nc y P re pa r a t io ns Operations Restoration

Ap r-20 46 Ju l-21 08

Oc t-20 47 Ap r-21 00 Nov-21 01 Ap r-21 06

F u el Po ol Operations Oc t-20 49

ISFSI O perat ions D ec-20 88

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 1 of 6

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, uti lization, 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 quanti ty 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.

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 2 of 6

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.

TLG Services, LLC LR-N24-0040 Attachment 2 Page 68 / 99 Hope Creek Generating Station Document P07-1794- 001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 3 of 6

FIGURE 5.1 RADIOACTIVE WASTE DISPOSITION

D AW

En er gySol ut io ns

Oak Ri dge, TN

Met al P ro ce ssin g

Bul k Waste En er gySol ut io ns (C on ta mi na t ed S o il and Concrete) C l i ve, U ta h

D eco m mis sio n in g

Lo w-Le vel Radi oactive Waste S tr ea ms

C on ta in er ize d Wa s te

R ea c to r W a s te B a r nw el l, SC (C lass es A, B, an d C)

R es i ns

(C lass A, B and C)

R ea c to r W a s te G eo lo gic D isp o sal

(Class GTCC) F ed er al F aci li ty

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 4 of 6

FIGURE 5.2 DECOMMISSIONING WASTE DESTINATIONS RADIOLOGICAL

Hope Creek Generating Station

EnergySolutions Clive, UT Oak Ridge, TN

Barnwell, SC

The figure indicates the destinations for the low -level radioactive waste designated for direct disposal (Containerized Classes A, B and C at t he 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).

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 5, Page 6 of 6

TABLE 5.2 SAFSTOR ALTERNATIVE DECOMMISSIONING WASTE

SUMMARY

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

Low-Level Radioactive Waste (near -surface A 166,489 10,633,670 disposal) Barnwell B 2,379 238,787

C 630 70,187

Greater than Class C Spent Fuel (geologic repository) Equivalent GTCC 1,633 314,644

Processed/Conditioned (off-site recycling Recycling center) 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 6, Page 1 of 5

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 decommissi oning 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

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of 5

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 an d 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-

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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 regula ting 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 decomm issioning 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.

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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

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7. REFERENCES
1. Decommissioning Cost Analysis for the Hope Creek Generating Station, Document No. P07 -1756-001, Rev. 1, TLG Services, Inc., July 20, 2019
2. U.S. Code of Federal Regulations, Title 10, Par ts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, 53 Fed. Reg. 24018, June 27, 1988 [Open]
3. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Rev. 2, October 2011 [Open]
4. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination [Open]
5. U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, Entombment Options for Power Reactors, Advance Notice of Proposed Rulemaking, 66 Fed.

Reg. 52551, October 16, 2001 [Open]

6. U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, 61 Fed. Reg. 39278, July 29, 1996 [Open]
7. U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70, and 72,

"Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, (p 35512 et seq.), June 17, 2011 [Open]

8. Nuclear Waste Policy Act of 1982, 42 U.S. Code 10101, et seq. [Open]
9. Nuclear Waste Policy Amendments of 1987, 42 U.S. Code 10172 [Open]
10. Charter of the Blue Ribbon Commission on Americas Nuclear Future, Objectives and Scope of Activities [Open]
11. Blue Ribbon Commission on Americas Nuclear Future, Report to the Secretary of Energy, p. 27, 32, January 2012 [Open]
12. Strategy for the Management and Disposal of Used Nuclear Fuel and High -

Level Radioactive Waste, U.S. DOE, January 11, 2013 [Open]

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7. REFERENCES (continued)
13. United States Court of Appeals for the District of Columbia Circuit, In Re:

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

14. U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses [Open]
15. U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites [Open]
16. Low-Level Radioactive Waste Policy Act, Public Law 96 -573, 1980 [Open]
17. Low-Level Radioactive Waste Policy Am endments Act of 1985, Public Law 99-240, January 15, 1986 [Open]
18. U.S. Code of Federal Regulations, Title 10, Part 61, Licensing Requirements for Land Disposal of Radioactive Waste [Open]
19. Final Environmental Impact Statement for the Disposal of Greater -Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC -Like Waste, (DOE/EIS-0375), January 2016 [Open]
20. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Final Rule, Radiological Criteria for License Termination, 62 Fed. Re g. 39058, July 21, 1997 [Open]
21. Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination, EPA Memorandum OSWER No. 9200.4 -18, August 22, 1997

[Open]

22. U.S. Code of Federal Regulations, Title 40, Part 141.66, Maximum contaminant levels for radionuclides [Open]
23. Memorandum of Understanding Between the Environmental Protection Agency and the Nuclear Regulatory Commission: Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites, OSWER 9295.8-06a, October 9, 2002 [Open]
24. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),

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

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7. REFERENCES (continued)
25. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP -036, May 1986
26. W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.

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

27. "Building Construction Cost Data 2021," RSMeans (From the Gordian Group),

Kingston, Massachusetts

28. Project and Cost Engineers Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984
29. "Strategy for Management and Disposal of Greater -Than-Class C Low-Level Radioactive Waste, Federal Register Volume 60, Number 48 (p 13424 et seq.),

March 1995 [Open]

30. U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178 [Open]
31. Tri-State Motor Transit Company, published tariffs, as amended
32. 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]
33. R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,"

NUREG/CR-0130 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1978 [Open Main Report] [Open Appendices]

34. H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR -0672 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1980 [Open Main Report] [Open Appendices]
35. SECY-00-0145, Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning, June 2000 [Open]

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Section 7, Page 4 of 4

7. REFERENCES (continued)
36. "Microsoft Project Professional," Microsoft Corporation, Redmond, WA
37. Atomic Energy Act of 1954, (68 S tat. 919) [Open]

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APPENDIX B

UNIT COST FACTOR LISTING (DECON: Power Block Structures Only)

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APPENDIX B

UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit Removal of clean instrument and sampling tubing, $/linear foot 0.86 Removal of clea n 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 po und 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, 30 0-3000 gallon 1,714.93 Removal of clean tank, >3000 gallons, $/square foot surface area 14.29

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APPENDIX B

UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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 g enerator, <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, >1 0,000 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

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APPENDIX B

UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit 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 p ipe 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 poun d 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

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APPENDIX B

UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit 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 s urface 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 concret e 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 mas onry block wall, $/cubic yard 83.83 Backfill of below-grade voids, $/cubic yard 45.62 Removal of subterranean tunnels/voids, $/linear foot 174.08

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APPENDIX B

UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit Placement of concrete for below -grade voids, $/cubic yard 156.04 Excavation of clean material, $/cub ic 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 fo ot 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 cle an 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

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APPENDIX B

UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit 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

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APPENDIX D

DETAILED COST ANALYSIS

SAFSTOR

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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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 1,083134 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 29519 - - - 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 80919 - - - 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 - - 1,043986 - - - 138,461 2,413 -

4a.1.1.2 Recirculation Pumps & Motors 12 73 19 28 192 154 - 98 576 576 - - 515620 - - - 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 - - 39,8051,605 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 - - 17,70545,514 - - - 2,973,956 33,704 -

4a.1.5.11 Condensate Demineralizer Process (AK) - 1,144 45 59 577 172 - 429 2,427 2,427 - - 1,3126,672 - - - 354,933 12,589 -

4a.1.5.12 Condensate Pre-filter - 283 26 28 230 122 - 143 832 832 - - 9352,658 - - - 167,571 3,152 -

4a.1.5.13 Condensate Transfer (AP) - 1,637 60 78 756 231 - 598 3,360 3,360 - - 1,7638,736 - - - 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 - - 4,85514,612 - - - 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 - - 240374 - - - 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 26,808275,239 - - - 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 - - 2172,464 - - - 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 66,831474,424 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 76,115474,424 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 - - 11,4494,418 - - - 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 - - 3,6835,395 - - - 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 - - 1,7982,488 - - - 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 - - 1,5685,485 - - - 323,147 12,965 -

4b.1.2.25 HPCI Steam (FD) - 267 13 13 111 53 - 100 557 557 - - 4011,285 - - - 77,925 2,918 -

4b.1.2.26 High Pressure Coolant Injection (BJ) - 312 57 41 198 292 - 192 1,092 1,092 - - 2,2232,292 - - - 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 - - 8,86214,768 - - - 1,167,985 39,274 -

4b.1.2.29 Miscellaneous Nuclear Boiler Recirc (BB) - 262 13 15 122 60 - 102 574 574 - - 4581,412 - - - 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 - - 757568 - - - 71,384 1,941 -

4b.1.2.39 Reactor Water Cleanup (BG) - 686 41 27 109 208 - 248 1,318 1,318 - - 1,5861,255 - - - 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 - - 11,12513,138 - - - 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 - - 4,7445,591 - - - 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 48,653171,132 - - - 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 - - 3263,696 - - - 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 - - 33,17139,031 - - - 3,670,503 152,416 -

4b.1.4.2 Low Level Radwaste Storage Facility 189 52 2 20 8 18 - 116 406 406 - - 62995 - - - 33,526 2,605 -

4b.1.4.3 Service & Radwaste Building 795 243 16 85 39 105 - 505 1,788 1,788 - - 2,817454 - - - 154,301 11,260 -

4b.1.4.4 Turbine Building 3,168 1,596 66 393 977 348 - 2,282 8,829 8,829 - - 10,76111,300 - - - 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 - - 13,9521,177 - - - 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 - - 61,33052,058 - - - 5,552,987 246,731 -

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 - 11,391 123,648226,886 - - - 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 - - 5296,000 - - - 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 - - 8056,000 - - - 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 11,391 209,188232,886 - - - 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 15,360 285,654707,310 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis 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 RestorationVolume 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 238,64441,220 23,291 10,822 63,324 43,979 894,956 241,027 1,557,262 1,075,404 328,275 153,583 296,327707,329 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 Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix E, Page 1 of 2

APPENDIX E

ISFSI DECOMMISSIONING

TLG Services, LLC Hope Creek Generating Station Document P07-1794-001, Rev. 0 Decommissioning Cost Analysis Appendix E, Page 2 of 2

Table E Hope Creek Generating Station ISFSI Decommissioning Cost Estimate (thousands of 2021 dollars)

LLRW Burial Oversight Removal Packaging Transport Disposal Other Total Volume Craft and Costs Costs Costs Costs Costs Costs Class A Manhours Contractor Activity Description (cubic feet) Manhours

Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 387 -387 - 1,168 Decontamination (activated disposition) 381 272 758 2,426 - 61,3443,837 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)

TLG Services, LLC