NOC-AE-08002286, Response to Request for Additional Information for Request for Exemption from 10 CFR 50.82(a)(8) (TAC No. MD6869/MD6870)

Response to Request for Additional Information for Request for Exemption from 10 CFR 50.82(a)(8) (TAC No. MD6869/MD6870)

ML081070281
Person / Time
Site:	South Texas
Issue date:	04/09/2008
From:	Sheppard J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-08002286, STI: 32291463, TAC MD6869, TAC MD6870
Download: ML081070281 (59)

Text

Nuclear Operating Company South Texas ProlectElectric Generating Station P.. Box 289 Wadsworth, Texas 77483 V\ -

April 9, 2008 NOC-AE-08002286 File No.: G25, D57, D43.1 10 CFR 2.390 10 CFR 50.82(a)(8)

U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Washington, D.C. 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Response to Request for Additional Information for Request for Exemption from 10 CFR 50.82(a)(8) (TAC No. MD6869/MD6870)

By letter dated September 19, 2007, STP Nuclear Operating Company ("STPNOC"), acting on behalf of NRG South Texas LP ("NRG South Texas"), the City Public Service Board of San Antonio ("CPS") and the City of Austin, Texas ("Austin Energy") (together, the "STP Owners"),

requested an exemption pursuant to 10 CFR 50.12 from Nuclear Regulatory Commission

("NRC") regulations to permit the immediate withdrawal of certain funds from the nuclear decommissioning trust funds (NDTs) maintained by the STP Owners for South Texas Project Electric Generating Station Units 1 and 2. Specifically, the STP Owners requested an exemption from provisions of 10 CFR 50.82(a)(8)(i) & (ii) which may restrict the withdrawal of funds from NDTs until after permanent plant shutdown.

The purpose of this exemption request is to permit the use of NDT funds, not to exceed

,$20 million per unit, in order to pay for the prompt disposal of certain major radioactive components (MRCs). , These MRCs are the reactor pressure vessel ("RPV") heads to be removed from the Facility in the upcoming Fall 2009 Unit 1 outage and the Spring 2010 Unit 2 outage, as well as the steam generators that were removed from the Facility in 2000 and 2002.

On March 3, 2008, NRC requested that STPNOC provide additional information regarding the exemption request, and STPNOC's response is provided as an Enclosure to this letter. In addition to the requested information, STPNOC is also providing supporting documentation as Attachments 1, 2 and 3 to the Enclosure. Attachments 2 and 3 provide certain cost estimates and. proposals that are commercially sensitive, because they either reflect STPNOC's methodologies for estimating project costs that are expected to be competitively bid (if the Exemption Request is denied) or are a specific bid proposal that has been submitted to STPNOC. STPNOC therefore requests that this proprietary information be withheld from public disclosure pursuant to 10 CFR 2.390, as described in the enclosed Affidavit of James J.

Sheppard.

This letter and attachment contain no new commitments.

STI: 32291463

NOC-AE-08002286 Page 2 of 5 If NRC requires additional information concerning this request, please contact either Mr. Philip Walker at (361) 972-8392, or me at (361) 972-8757.

J. J. Sheppard President & Chief Executive Officer

Enclosure:

Response to NRC Request for Additional Information

NOC-AE-08002286 Page 3 of cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esq.

U.S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mohan C. Thadani U.S. Nuclear Regulatory Commission Mohan C. Thadani Thad Hill Senior Project Manager Eddy Daniels U.S. Nuclear Regulatory Commission Catherine Callaway One White Flint North (MS 7 D1) Brad Porlier 11555 Rockville Pike Steve Winn Rockville, MD 20852 Staney Rostad NRG South Texas LP Senior Resident Inspector J. Nesrsta/R. J. Temple U.S. Nuclear Regulatory Commission E. Alarcon/Kevin Polio P.O. Box 289, Mail Code: MN116 City Public Service Wadsworth, TX 77483 Richard A. Ratliff Jon C. Wood Bureau of Radiation Control Cox Smith Matthews Texas Department of State Health Services 1100 West'49th Street C. Kirksey Austin, TX 78756 City of Austin C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Brian Almon Public Utility Commission P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Environmental and Natural Resources Policy Director P.O. Box 12428 Austin, TX 78711-3189 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 STI: 32291463

NOC-AE-08002286 Page 4 of 5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

STP Nuclear Operating Company ) Docket Nos. 50-498

) 50-499 South Texas Project Units 1 and 2 )

AFFIDAVIT I, James J. Sheppard, President and CEO of STP Nuclear Operating Company (STPNOC) do hereby affirm and state:

1. I am authorized to execute this affidavit on behalf of STPNOC.

2. STPNOC is providing information in support of its Exemption Request dated September 19, 2007. The information being provided in Attachments 2 and 3 to

'STPNOC's response to NRC request for additional information contains STPNOC's Projections of project costs and bid proposals made to STPNOC. Attachments 2 and 3 constitute proprietary commercial and financial information that should be held in

,confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390(a)(4), because:

This information is and has been held in confidence by STPNOC.

ii. This information is of a type that is customarily held in confidence by STPNOC, and there is a rational basis for doing so because the information contains sensitive financial information concerning projected costs of STPNOC or bid proposals made to STPNOC; iii. This information is being transmitted to the NRC voluntarily and in confidence.

iv. This information is not available in public sources and could not be gathered readily from other publicly available information.

v. Public disclosure of this information would create substantial harm to the competitive position of STPNOC by disclosing its internal cost projections and/or consideration of bid proposals.

NOC-AE-08002286 Page 5 of 5

3. Accordingly, STPNOC requests that the designated documents be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4).

J. J. Sheppard President & Chief Executive Officer STATE OF TEXAS

)

COUNTY OF M AT/ ( jO R D\

Subscribed and sworn to me, a Notary Public, in and for the State of Texas, this J day of April, 2008.

. .... LOIS J, MILLS Public, State oin aNotary aTo My CommiýSsion Expires JULY,2011 Notary Public in and for the State of Texas

Enclosure NOC-AE-08002286 Page 1 of 8 SOUTH TEXAS PROJECT UNITS 1 AND 2 Response to NRC Request for Additional Information In 2007, the STP Nuclear Operating Company (STPNOC) initiated a new site-specific decommissioning cost study for South Texas Project Units 1 and 2 (STP Units 1 & 2) that was conducted by TLG Services, Inc. and completed in March 2008 (2008 TLG Study). Attachment 1 to this Enclosure provides selected pages that are relevant to this RAI response. STPNOC notes that TLG's estimates for disposal of large components are lower in current 2007 dollars than the estimate provided in the 2004 study in 2004 dollars and submitted to NRC with STPNOC's September 19, 2007 Exemption Request. The current TLG estimates are based, in part, upon the attractive pricing in current proposals that STPNOC has received for the disposal of these large components in 2008. The differences between the estimates in the 2004 TLG Study and the estimates in the 2008 TLG Study are indicative of the pricing available currently, and not necessarily the pricing that may be expected if this cost is deferred'until the end of plant operating life.

1. The STP Nuclear Operating Company (STPNOC, licensee) stated that the cost to construct an on-site storage mausoleum would be $1.4 million. In addition, STPNOC stated that the mausoleum also resulted in an annual cost to maintain it, and the eventual cost to decommission it. These costs are part of the basis for the exemption request. Please provide a detailed cost for the mausoleum as well as the associatedmaintenance and decommissioningcosts.

STPNOC has prepared a "Project Evaluation and Approval" which was the basis for estimated cost to construct an on-site mausoleum for the reactor pressure vessel (RPV) heads. This analysis resulted in a Total Probabilistic Cost of approximately $1.4 million.

A copy of this project evaluation is provided as Attachment 2, which is marked confidential and proprietary. STPNOC has not yet sought competitive bids for this project, but STPNOC would expect to seek competitive bids for this project if the pending Exemption Request is denied. Therefore, STPNOC requests that this document be withheld from public disclosure pursuant to 10 CFR 2.390, as supported by the Affidavit of James J. Sheppard.

Annual maintenance costs for the mausoleum are for ongoing surveillance and surveys and potential repairs or improvements during the life of the facility. Based upon experience with the Old Steam Generator Storage Facility (OSG SF), which is described in greater detail below in answer to RAI 3, STPNOC believes that annual expense for an RPV Head Storage Facility (RPVH SF) would be in the range of $5,000-10,000 per year.

As reflected in Line Item 3b1.1.13 in the Unit 2 decommissioning cost estimates in the 2008 TLG Study, the estimated cost to decommission the RPVH SF is $94,000. This item is highlighted on the relevant page provided in Attachment 1 (Appendix C, Page 21 of 23).

2. STPNOC stated that the purpose of the exemption request is to permit the use of the decommissioning trust funds, not to exceed $20.0 million per unit, for the prompt disposal of certain major radioactive components (MRCs). Pleaseprovide a detailed cost breakdown of the projected cost of decommissioning MRCs, up to

$20.0 million per unit, including the type and number of components that would be

Enclosure NOC-AE-08002286 Page 2 of 8 disposed.' If the costs exceed $20.0 million, provide details of how STPNOC will fund any additionalcosts.

The MRC disposal project involves the disposal of eight steam generators and two reactor pressure vessel heads, as well as demolition and removal of the steam generator mausoleum. The requested authorization to withdraw up to $20 million per unit is based upon proposals for this work that STPNOC received from EnergySolutions, LLC. A copy of these proposals is provided as Attachment 3, which is marked as proprietary and confidential. STPNOC requests that these documents be withheld from public disclosure pursuant to 10 CFR 2.390, as supported by the Affidavit of James J.

Sheppard.

As reflected in Line Items 2a.1.1.6 in the Unit 1 and Unit 2 decommissioning cost estimates in the 2008 TLG Study, the estimated cost to decommission the steam generators is $14.3 million per unit. These items are highlighted on the relevant pages provided in Attachment 1 (Appendix C, Pages 4 and 15 of 23). As reflected in Line Items 2b.2.1 in the Unit 1 and Unit.2 decommissioning cost estimates in the 2008 TLG Study, the estimated cost to decommission the "Spare RX closure head[s]" (assuming that they remain on site) is $1.3 million per unit. These items are highlighted, on the relevant pages provided in Attachment 1 (Appendix C, Pages 7 and 18 of 23). Thus, the current TLG estimate for disposal of the steam generators and RPV heads is

$31.2 million, not including $329,000 for the demolition of the steam generator

• mausoleum discussed furtherin the response to RAI 3 below.

.The current EnergySolutions proposal exceeds this new TLG estimate, but not

.substantially. More importantly, the EnergySolutions proposal for steam generator

,disposal is more than 15% lower than TLG's 2004 estimate for the disposal of these

eight steam generators, without taking into account inflation from 2004 to 2008. Also,

• the variation in price estimates reflects current favorable changes in market conditions, which suggests that the current opportunity for disposal is desirable as compared with other times in the last decade or more.

The EnergySolutions proposals are for fixed price contracts, and STPNOC therefore does not anticipate the possibility of costs exceeding the amount up to $20 million per unit authorized for withdrawal, which includes an approximately 20% margin for costs exceeding the expected costs. If unexpected costs are incurred that exceed these amounts, STPNOC's owners would fund those costs through STPNOC operating or capital budgets.

3. The licensee stated that STP currently has eight steam generatorscurrently being stored on site resulting from the 2000 and 2002 steam generators' replacements.

Please describe in detail the $10,000.00 per year annual costs, and how these steam generators are currently being stored on site. The submittal also stated that STPNOC constructed a separate facility to store these steam generators; please provide a description and the cost of this storage facility. In addition, provide an estimate of the additionalannual cost to store the MRCs as a result of replacement of the vessel heads during 2009 and 2010 outages, if the MRCs are not immediately sent for disposal.

Enclosure NOC-AE-08002286 Page 3 of 8 The eight steam generators currently maintained at the STPNOC site are stored in a specially constructed mausoleum or OSG SF. This OSG SF is currently located outside the protected area for STP Units 1 & 2, but it would be within the site protected area for the proposed new STP Units 3 & 4. The OSG SF was constructed in 1999-2000 at a cost of approximately $3.076 million.

Annual maintenance costs for the mausoleum are for quarterly surveys, which are estimated at 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per year, five hours each for two Health Physics Technicians four times per year, at a cost of $60 per hour. Supervisor review and reporting is an additional estimated four hours per year at $65 per hour. This results in an annual cost of $2,660. In addition, STPNOC anticipates that there may be need for occasional repairs or replacements associated with the facility. For example, within the last few years a hurricane caused damage to the roof of the SG Facility, which had to be replaced. In this prior instance, the replacement was covered by a contractor's warranty.

However, the warranty has now expired, and any future such replacement estimated at

$150,000 would be paid by STPNOC. Therefore, over the remaining life of the SG Facility, which is assumed to be at least 20 years, STPNOC projects that an annualized average cost of $7,500 per year for repairs and replacements can reasonably be expected.

In addition, STPNOC anticipates that it will incur increased security costs for the

,OSG SF, if it is not removed from the site before the area around this facility is made

• part of the STP protected area with the development of STP Units 3:& 4. Storage

-,`facilities would not require security protection, because they are not safety-related

,structures, systems, or components. However, increased security costs are expected "for the OSG SF and RPVH SF, because they will be inside the protected area, requiring

.,security lighting and periodic checks by security officers 365 days per year, on both days

ý.and nights. Because the buildings create obstructions, as opposed to open land with clear sight lines, STPNOC estimates that the increased security cost will be one-man-year per year (2080 hours0.0241 days <br />0.578 hours <br />0.00344 weeks <br />7.9144e-4 months <br /> per year), or $52,000, until the OSG SF and RPVH SF are decommissioned and removed from the site. In addition, the buildings likely will cause the need for security fences, lighting and camera coverage, which will increase the complexity of the required security coverage. However, no reliable estimate of these costs is presently available.

As reflected in Line Item 3bW.1.15 in the Unit 2 decommissioning cost estimates in the 2008 TLG Study, the estimated cost to decommission the OSG SF mausoleum is

$329,000. This item is highlighted on the relevant page provided in Attachment 1 (Appendix C, Page 21 of 23).

If the RPV heads are not disposed off-site, they will need to be stored in a newly constructed mausoleum because there is no adequate additional space to store the RPV heads in the OSG SF. The costs associated with the RPVH SF are discussed above in the response to RAI 1.

4. STPNOC stated that the decommissioning trust balances as of December 31, 2006, totaled $364.9 million for Unit 1 and $445.8 million for Unit 2. This is the amount that STP submitted to the NRC for compliance with 10 CFR 50.75(f) to demonstrate that STP exceeded the NRC minimum requirements for radiological decommissioning. In addition, STP stated that the decommissioning site-specific

Enclosure NOC-AE-08002286 Page 4 of 8 cost estimates included not only radiologicalcleanup required by NRC, but the costs of dismantling the facilities and restoring the site, as well as the cost for storage and monitoring the spent fuel until the U.S. Department of Energy takes custody of the fuel. STPNOC needs to identify the source of the funds to support these additionalnon-radiologicalactivities.

STPNOC's owners expect that their current trust fund balances together with future collections will fund all of the activities necessary for decommissioning STP Units 1 & 2, including basic radiological decommissioning, spent fuel management and site restoration activities. The site-specific decommissioning cost estimates for STP Units 1

& 2 have included estimates for all of these expected costs, and the owners have been funding their trust funds accordingly. In addition, the Public Utility Commission of Texas (PUCT) has approved collections from retail electric customers to fund these activities.

In some cases, the STPNOC owners have not maintained separate subaccounts to specifically track the funds being collected to fund decommissioning activities relating to spent fuel management, i.e., other than the basic radiological costs specified in 10 CFR 50.75(b) & (c). For example, the City Public Service Board of San Antonio (CPS) has maintained separate subaccounts for spent fuel management costs relating to its 28%

legacy interest in STP Units 1 & 2, but it has not maintained separate subaccounts for its 12% interest in STP Units 1 & 2 that was acquired in 2005 from AEP Texas Central Company (legacy AEP interest).

'ý,The&STPNOC owners that are subject to the jurisdiction of the PUCT (NRG Energy for (its 44% interest in STP Units 1 & 2,1 and CPS forits 12% legacy AEP interest) expect to

,,*seek PUCT authorization in 2008 to create a'nd maintain specific subaccounts for the

',,spent fuel management costs that have been collected to date, as well' as for the

• iremaining funds that are to be collected. Based upon nuclear decommissioning trust

fund (NDT) balances as of 12/31/2007, Tables 1 and 2 below set forth the NDT balances for each unit and for each of the owners, as well as the NRC formula amount and site-specific cost estimate for each unit and for each of the owners. The Balance breakdown between "Basic & Site Restoration" and "Spent Nuclear Fuel Management" is a projection of the balance that would be allocated based upon the 2008 TLG Study.

NRG Energy owns 30.8% interests in STP Units 1 & 2 that were formerly owned by Houston Lighting & Power Company and 13.2% interests that were formerly owned by AEP Texas Central Company.

Enclosure NOC-AE-08002286 Page 5 of 8 Table 1 Ownership NRC Balance Balance Balance TLG TLG TLG (Unit 1) Formula (Total) (Basic + (SNF (Basic + (SNF (Total)

Site) Mgmt.) Site) Mgmt.)

Total 375,884.0 391,626.0 284,001.3 107,624.7 509,082.0 192,921.0 702,003.0 NRG (30.8%) 115,772.3 121,955.0 88,439.9. 33,515.1 156,797.3 59,419.7 216,216.9 NRG (13.2%) 49,616.7 47,135.9 34,182.2 12,953.7 67,198.8 25,465.6 92,664.4 CPS (28%) 105,247.5 124,652.2 90,395.9 34,256.3 142,543.0 54,017.9 196,560.8 CPS (12%) 45,106.1 44,922.2 32,576.9 12,345.3 61,089.8 23,150.5 84,240.4 Austin 2 60,141.4 52,960.7 38,406.3 14,554.4 81,453.1 30,867.4 112,320.5 (16%)

Table 2 Ownership NRC Balance Balance Balance TLG TLG TLG (Uneit (Unit 2RC Formu (alae (Basic + (SNF (Basic + (SNF Tl)

2) Formula (Total) Site) Mgmt.) Site) Mgmt.) (Total)

Total 375,884.0 476,863.7 360,789.0 116,074.7 590,166.0 189,871.0 780,037.0 NRG (30.8%) 115,772.3 155,857.9 117,920.1 37,937.8 181,771.1 58,480.3 240,251.4 NRG (13.2%) 49,616.7 57,256.4 43,319.5 13,936.9 77,901.9 25,063.0 102,964.9 CPS(.

(28%) 105,247.5 152,352.7 115,268.1 37,084.63 165,246.5 53,163.9 218,410.4 (CPS (12%) 45,106.1 46,482.3 35,167.9 11,314.4 70,819.9 22,784.5 93,604.4 Austin 4 (16%) 60,141.4 64,914.4 49,113.4 15,801.0 94,426.6 30,379.4 124,805.9 2 NDT Balance for Austin is based upon 12/31/2006.

CPS's current subaccount of $5.54 million is being reevaluated to align with the latest cost estimate.

NDT Balance for Austin is based upon 12/31/2006.

Enclosure NOC-AE-08002286 Page 6 of 8 The comparison based upon NRC's current formula amount shows that the STP trust funds are robustly funded, even without taking credit for future earnings and ongoing contributions. However, by just taking credit for a 2% real rate of return on earnings through the remaining life of the current operating licenses, it can be seen that, even when excluding the portion of the existing trust fund balances allocable to spent fuel management, the remaining balances for each owner and each owner's share for each unit exceed the NRC minimum. This is reflected in Table 3 and Table 4, which provide the discounted value of the of the NRC minimum amount that would be required to be funded in current dollars, when a 2% real rate of return for earnings is taken into account.

The analysis reflected in Tables 3 and 4 shows that, even excluding the percentage of the balances allocable to spent fuel management, the remaining funds for each owner's share of each unit are sufficient to satisfy NRC's minimum decommissioning funding assurance requirements, even without taking into account that the owners continue to make contributions to their trust funds to assure that funding will be sufficient to meet the total site-specific decommissioning cost estimate. For Unit 1, the current total balance exceeds the NRC required minimum amount by more than $40 million, and for Unit 2, by more than $120 million.

Enclosure NOC-AE-08002286 Page 7 of 8 Table 3 Balance Balance Balance (Total) (Basic + Site) (SNF Mgmt.)

Total 237,774.8 391,626.0' 284,001.3 107,624.7 NRG (30.8%) 73,234.6 121,955.0 88,439.9 33,515.1 NRG (13.2%) 31,386.3 47,135.9 34,182.2 12,953.7 CPS (28%) 66,576.9 124,652.2 90,395.9 34,256.3 CPS (12%) 28,533.0 44,922.2 32,576.9 12,345.3 Austin' 38,044.0 52,960.7 38,406.3 14,554.4 (16%)

Table 4 Balance Balance Balance (Total) (Basic + Site) (SNF Mgmt.)

Total 231572.6 476,863.7 360,789.0 116,074.7 NRG (0% 71,324.4 155,857.9 117,920.1 37,937.8 (30.8%)

NRG (13.2%) 30,567.6 57,256.4 43,319.5 13,936.9 CPS (28%) 64,840.3 152,352.7 115,268.1 37,084.66 CPS (12%) 27,788.7 46,482.3 35,167.9 11,314.4 Austin 7 37,051.6 64,914.4 49,113.4 15,801.0 (16%)

5 NDT Balance for Austin is based upon 12/31/2006.

6 CPS's current subaccount of $5.54 million is being reevaluated to align with the latest cost estimate.

7 NDT Balance for Austin is based upon 12/31/2006.

Enclosure NOC-AE-08002286 Page 8 of 8 ATTACHMENTS:

1. Selected Pages from 2008 TLG Study (non-proprietary)

2. Project Evaluation and Approval (proprietary)

3. EnergySolutions Proposa!s (proprietary)

ATTACHMENT 1 SELECTED PAGES FROM 2008 TLG STUDY

Attachment 1 Page 1 of 6 South Texas ProjectElectric GeneratingStation Document S30-1564-002, Rev. 0 Decommissioning CostAnalysis Section 6, Page 3 of 3 TABLE 6.1 COST

SUMMARY

DECOMMISSIONING COST ELEMENTS (thousands of 2007 dollars)

Cost Element __Unit 1 Unit 2 ~Total IPercentage Decontamination 14,628 14,973 29,6021 2.0 Removal 102,281 134,827 237,108 16.0 a..

.a Packaging ..... ....... .........

-18,817 ....

. . . ... .... 8... .. . .118,814

_,14 . ......

-37,631 3 ,6 ! . .. . . .2_

__2.5 Transportation 11,544 11,511 23,055 1.6 Waste Disposal 73,513 73,293 146,806 1 9.9 Off-site Waste Processing 31,393 30,623 62,015 4.2 Program Management Ell 218,590,. 272,828 491,418 33.2 Severance 10,587 14,988 25575 1.7 FelE2 156,773 152,003 308,776 20.8 Spent fuel pool Iation 10,720 7,1471 17,866 1.2 Insurance and Regulatory Fees 17,836 16,891 34,727 2.3 Energy 10,455 20,9201 1.4 Characterization and Licensing Surveys 9,; 879 8,056 17,935 1.2 Survey & Release of Scrap Metal County Taxes 2, 003 6, 892 2,078

_5453 5 J 4,081 .

12,344 0.3 0.8 6,-092 16:68 12,179 08 Total [3 702,' 003 780,037 1,482,039 100.0 Cost Element Unit 1. Unit2 Total Percentage License Termination 462,762 508,903 971,665 65.6 Spent Fuel Management 192,921 189,871 382,792 25.8 Site Restoration' 46,319 81,263 127,582 8.6

[3] 1,482,039 Total 702,003 780,037 100.0

[13 Includes engineering and security costs

[2] Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees

[3] Columns may not add due to rounding TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1564-002, Rev. 0 DecommissioningCost Analysis Appendix C, Page 4 of 23 Attachment 1 Page 2 of 6 Table C-1 South Texas Project Electric Generating Station, Unit I DECON Decommissioning Cost Estimate (thousands of 2007 dollars)

Activity Decon Removal Off-site LLRW INRC Spent Fuel Sit . Processed Burial Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Volumes Class C G0CC Burial /IUtility Processed Craft and Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Fee Cs. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours 1b.2 Subtotal Period lb AdditionalCosts 11.787 2,138 13,924 13.924 .

• Period lb Collateral Costs lb3.1 DCcon equipment 945 142 1,087 , 1,087 1b53.2 DOC staff relocation expenses - 829 124 953 953 1b.3.3 . Process liquid waste 72 - 84 " 273 1,090 - 358 1,878 1,878 479 852 123,248 259 b13.4 Small tool allowance 2 0 2 2 1b.3.5 Pipe cutting equipment - 957 143 1.100 1,100 11b.3.6 Decon rig 1,243 186 1,430 1.430 lb.3.7 Spent Fuel Capital and Transfer 8,384 1,258 9,642 9,642 lb.3.8 Matagorda County Taxes and Fees - 667 - 667 667 1b.3.9 Matagorda Country ospital District Taxes and Fe - S- 281 - 281 281 15.3 Subtotal Period lb Collateral Costs 2.260 958 84 273 1.090 10.161 2.212 17,038 7,396 9,642 479 852 123,248 259 Period lb Period-Depandent Costs 7 37 37 1b.4.1 Decon supplies 29 -

1b.4.2 Insurance - 664 66 730 730 1b.4.3 Health physics supplies 282 71 353 353 1b.4.4 Heavy equipment rental

• 212 32 244 244 1b.4.5 Disposal of DAWgenerated 10 2 26 8 45 45 366 7,320 12 b1.4.6 Plant energy budget 1.401 210 1,611 1,611 1b.4.7 NRC Fees 129 13 142 142 Ib.4.8 Emergency Planning Fees 139 14 153 153 11b.4.9 Spent Fuel Pool O&M 507. 76 582 582 1b.4.10 ISFSI Operating Costs 32 5 36 36 15.4.11 Secuity Staff Cost 428 64. 492 492 13,743 lb.4.12 DOCStaff Cost 3,990 599 4.589 4.589 64,486 15.4.13 UtilityStaff Cost 11,583 1,733 13.286 13,286 223.057 1b.4 Subtotal Peoiod 1 b Period-Dependent Costs 29 .494 10 2 26 18,843 2,897 22.301 21,529 772 366 7.320 12 301.286 tb.0 TOTALPERIOD 1b COST 2,896 1,452 94 275 1,116 43,429 7.946 57.209 46,224. 10,414 571 845 852 130.568 1,338 334.529 PERIOD I TOTALS 2,896 2,367 110 279 1.159 100,533 16,178 123,522 92,154 30.385 983 1,463 852 142,927 1,359 873,396 PERIOD 2a - Large Component Removal Period 2a Direct Decommissioning Activities Nuclear Steam Supply System Removal 2o.1. t.1 Reactor CoaowntPiping 144 15i 23 32 312 195 807 857 - 1.185 143.269 8.530 2a.1.1.2 Pressurizer Relief Tank 21 18 7 10 - 88 39 183 183 - 365 40,513 1.189 2a.1.1.3 Reactor Coolant Pumps &Motors 71 58 42 59 128 1.428 439 2.226 2,226 443 5.712 967,806 4,074 2a.1.1.4 Pressuizer 24 34 328 817 - 544 267 1.713 1,713 - 2,175 240,508 2.341 2a.1.1.5 Steam Generators 281 2,901 2,534 2,016 2,934 5,.554 3,250 19.472 19.472 51,348 22,217 4,500.407 23,235 2,050 2a.1.1.6 Retired Steam Generator Units - - 1,716 1,972 2,934 5,421 - 2.263 14,306 14,306 51.348 21.685 4.239.824 10,800 1,425 2a.1,1.7 CRDMs/ICls/Service Structure Removal 96 57 185 57 193 137 726 726 - 3,936 88,569 4,400 -

2a.1.1.8 Reactor Vessel Internals 74 1.923 6.447 694 66.919 212 6.756 23,025 23,025 1,377 412 861 314,544 28.867 1.287 2a.1.1.9 Reactor Vessel 52 3.724 1.359 398 - 7,069 212 6,824 19.638 19.638" - 7,750 2,128 - 1,069,368 28.867 1,287 2a,1.1 Totals 763 8.867 12,641 5,754 5.997 27,529 424 20,171 82,146 82,146 103.139 66.402 2.541 861 11.604,810 112,302 6,048 Removal of Major Equipment 2a.1.2 Main Turbine/Generatar - 102 15 117 117 3.298 2a.I.3 Main Condensers 534 80 615 615 16.323 Cascading Costs from Clean Building Demolition 2a.1.4.1 Reactor 924 139 . 1,062 1,062 13,446 2a.1.4.2 Mechanical & Electrical Auxiliary 509 76 586 586 - - 8,223 2a.1.4.3 Fuel Handling 252 38 290 290 3,461 TLG Services, Inc.

South Texas Project ElectricGeneratingStation Document 830-1564.002, Rev. 0 DecommissioningCost Analysis Appendix C, Page 7 of23 Attachment 1 Page 3 of 6 Table C-A South Texas Project Electric Generating Station, Unit I DECON Decommissioning Cost Estimate (thousands of 2007 dollars) 0-ff-Site LLRW NRC Spent Fuel sito Processed Burial Volumes Burial I Utilitysnd Activity Becon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Actlvlty Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Foot Wt., Lbs. Manhours Manhours Disposal of Plant Systems (continued) 2b.1.1.39 Nonradioactive Dms &Smtps (DR) 83 12 96 96 - 2,932 26.1.1.40 Nonradioactive Dns &Smtps (DR) RCA 256 31 40 222 244 167 960 960 2,971 1,249 232.693 6.870 2b.1.1.41 Open LoopAuxiliaryCooling (OC) 323 48 371 371 - 11,419 2b.1.1.42 Radioactive Vents & Drains (ED) 530 35 40 130 307 238 1,260 1.280 1.734 1,569 211.210 15,149 2b.1.1.43 Reactor Head Degassing(RD) 44 4 5 32 30 25 140 140 426 172 31,034 1.330 21,*11.44 Reactor Makeup Water (RM) 208 12 20 238 42 102 622 622 3.181 237 148,597 6,436 2b.1.1.45 Residual Heat Removal (RH) 310 201 98 93 190 783 454 2,131 2,131 2,548 4.008 462.821 7.567 2b.l.t.46 Safety Injection (Si) - 746 200 219 1,061 1.447 763 4.456 4.456 14,465 7.709 1.251.132 23,305 2b..1.47 Service Air (SA) 76 11 88 88 - 2,701 2b.1,1.48 Service Water (TW) 14 2 16 16 493 2b.1.1.49 Sodium Hypochiodta (SH) 13 2 1i 15 438 2b.11b50 Standby DG Fuel Oil Strg &Tmsfr (DO) 37 6 42 42 1.200 2b.1.1.51 Standby Diesel Gen Starting Air (SD) 17 2. 19 19 557 2b.1.1.52 Standby Diesel Generator (DG) 121 18 139 139 4,148 2b.1.1.53 Standby Diesel Generator Bldg HIVAC (HG) 50 7 ' 57 57 1,806 2b.1.1.54 Standby Diesel Generator Lube Oil (L.) 7 1 8 8 242 21.1t1.55 Standby Diesel Jacket Water (JW) 5 1 6 6 174 2b.1.1.56 Turbine Generator Building(XT) 25 4 28 28 785 2b.1.1.57 Turbine Generator BuildingHVAC(HT) 176 26 203 203 25 6,465 2b.1.1.58 Turbine Gland Seal (GS) 22 3 25 746 2b.1.1 Totals 1,708 12,697 1,054 1,511 14,433 5,651 7,718 44,973 41,871 3,102 193.155 30,164 10,436,170 414,401 2b.1.2 Scaffolding in support of decommissioning - 1,553 47 15 185 27 430 2.256 2,256 - 2,231 139 -112,845 55,965 Decontamination of Site Buildings 2b.1.3.1 Reactor 899 786 146 167 682 752 979 4.430 4,430 9,125 6,629 995.610 48,143 2b.1.3.2 Mechanical &Electrical Auxiliary 882 476 107 142 333 1 266 709 2,916 2,916 4,455 5.025 - 677,827 37,395 2b.1.3 Totals 1.781 1,262 253 329 1,015 1,018 1,688 7,346 7,346 13,580 11,654 1,673,437 85,538 2b.1 Subtotal Period 2b ActivityCosts 3,489 15,712 1.354 1.855 15,633 6,696 9,835 54.575 51,473 3,102 208,966 41,956 12.222,450 555,904 Period 26 AdditionalCosts 2b.2.1 Spare RX closure head - . 188 54 795 30 230 1,298 1,298 1,949 201,821 2.160 249 2b.2 Subtotal Period 2b AdditionalCosts - - 188 54 795 30 230 1,298 1,298 1,949 - 201,821

- 2.160 249 Perind 26 Collateral Costs 2b.3.1 Process liquid waste 351 - 267 868 2,840 1,043 5,370 5,370 4,250 350.377 829 2b.3.2 Smail tool allowance - 344 52 396 396 2b.3.3 Spent Fuel Capital and Transfer 26,585 3,986 30,573 30,573 2b,3.4 Survey & Release Scrap 561 84 645 645 2b.3.5 Matagorda County Taxes and Fees 416 416 416 2b.3.6 Malagorda County Hospital District Taxes and Fe - - - 176 176 176 2b.3 Subtotal Period 2b Collateral Costs 351 344 267 868 2,840 27,738 5,166 37,576 7,003 30.573 4,250 350.377 829 Period 2b Perinod-DependentCosts 2b.4.1 Decon supplies 1,438 - 359 1,797 1.797 2b.4.2 Insurance 1.244 124 1,368 1.368 2b.4.3 Health physics supplies 3,659 915 4,574 4,574 "2b.4.4 Heavy equipment rental 5,102 765 5,868 5,868 2b.4.5 Disposal of DAWgenerated 216 44 564 - 169 993 993 8,055 - 161,103 272 2b.4.6 Plant energy budget 2.548 382 2,930 2,930 2b.4.7 NRC Fees 839 84 923 923 2b.4.8 Emergency Planning Fees 675 68 743 743 2b.4.9 Spent Fuel Pool O&M 2,456 368 2,824 2,824 2b.4.10 Radwasto Processing Equipment/Services 456 69 526 526 2b64.11 ISFS Operating Costs 153 23 177 177 2b.4.12 Security Staff Cost 2,035 305 2,341 2,341 65,353 TLG Services,Inc.

South Texas ProjectElectric GeneratingStation Document 830-1564-002, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 15 of 23 Attachment 1 Page 4 of 6 Table C-2 South Texas Project Electric Generating Station, Unit 2 DECON Decommissioning Cost Estimate (thousands of2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility andi Deaon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor I

IActivity InM*Y A*IWI* I IAq*MNrINn fl,,t Cant Caete Caere Cant. lent. Costn Cntin'aenttv Contn Cosntn Cent. Cant. Ca Foor CJFnt Ca! Pnt Cu Faur CF.l. :t WI lha Maanha,,, Mnnh,,orI n A m... r ...... .........

o Cos .... ... .... .... .. . .... C n inn "-I costs. ..... .... .... ....... ....... ....... ....... ....... st W Lb . ...... .. ...... . Iaho Period lb Additional Costs 1b.2.1 Site Characterization 1,054 316 1,370 1,370 1b.2.2 Spent fuel pool isolation 6.214 932 7,147 7,147 1b.2 Subtotal Period lb Additional Costs 7,268 1,248 8,517 . 8,517 Period 1b Collateral Costs 1b.3.1 Decon equipment 945 142 1,087 1,087 tb.3.2 DOC staff relocation expenses - - - 829 124. 953 953 lb.3.3 Process liquid waste 72 84 273 1,074 354 1,857 1,857 479 852 121,094 259 lb.3.4 Small tool allowance 2 0' 2 2 lb.3.5 Pipe cutting equipment - 957 143 1,100 1,100 Ib.3.6 Decon rig 1,243 - 186 1,430 1,430 1b.3.7 Spent Fuel Capital and Transfer 7,755 1,163 8.918 8,918 1b.3.8 Matagorda-County Taxes and Fees - . 422 - 422 422 lb.3.9 Matagorda County Hospital District Taxes and Fe - 178 - 178 178 lb.3 Subtotal Period lb Collateral Costs 2,260 958 84 273 1,074 9,183 2,113 15,946 7,028 8,918 479 852 121,094 259 Period 1o Period-Dependent Costs lb.4.1 . Decon supplies 29 - 7 37 37 1b.4.2 Insurance 664 66 730 730 1b.4.3 Health physics supplies 282 71 353 353 1 b.4.4 Heavy equipment rental 212 32 244 244 1b.4.5 Disposal of DAW generated 10 2 26 - 8 45 45 -" 366 7,320 12 1b.4.6 Plant energy budget 1,401 210 1,611 1,611 1b.4.7 NRC Fees 129 13 142 142 lb.4.8 Emergency Planning Fees 139 14 153 153 Ib.4.9 Spent Fuel Pool O&M 507 76 582 582 1b.4.10 ISFSI Operating Costs 32 5 36 - 36 I b.4.11 Security Staff Cost 2,469 370 2,840 2,840 79,286 11.4.12 DOC Staff Cost -- - - 3,990 599 4,559 4,589 .- 64,486 tb.4.13 UtilityStaff Cost - - - 11,5953 1,733 13,286 13,286 - - 223,057 tb.4. Subtotal Period lb Period-Dependent Costs .29 494 10 2 26 20,884 3,203 24,648 23,876 772 366 .7,320 12 366,829 1b.0 TOTAL PERIOD 1b COST 2,900 1,453 94 275 1,099 38,465 7,040 -. 51,325 41,391 9,690 244 845 852 128,414 1,338 381,057 2,900 2,367 PERIOD 1 TOTALS 110 279 1,143 94.760 15,254 116,813 87,645 28,747 421 - -1,463 852 140,773 "1,359 1,007.051 PERIOD 2a - Large Component Removal Period 2a Direct Decommissioning Activities Nuclear Steam Supply System Removal 252 883 883 2a.1,.1. Reactor Coolant Piping 153 161 23 32 3112 1,185 -- 143,269 8,530 2a.1.1.2 Pressudzer Relief Tank 22 19 7 10 - 88 40 187 187 - 365 40,513 1,189 2a.1 .1.3 Reactor Coolant Pumps & Motors 71 58 42 59 128 1,426 439 2,226 2,226 443 5,712 967,806 4,074 2a.l.1,4 Pressurizer 24 34 328 517 - 544 267 1.713 1.713 - 2,175 240,508 2.341 -

2a.l.1.5 Steam Generators 298 2,901 2,534 2,016 2,934 5,554 3,259 19,497 19,497 51,348 22,217 4,500,407 23,235 2,050 2a.1.1.6 Retired Steam Generator Units 1,716 1.972 2,934 5,421 2,263 14,306 14,306 51,348 21,685 4,239,824 10,800 1,425 2a.1.1.7 CRDMs/ICls/Service Strocture Removal 102 63, 185 57 - 193 142 741 741 - 3,936 88,569 4,400 2a..1.8 Reactor Vessel Internals 79 1.923 6.447 694 6,914 212 6,756 23,024, 23,024 1.377 412 861 314,544 28,867 1,287 2a.I.1.9 Reactor Vessel 55 3,724 1,359 398 - 6,995 212 6,789 19,532 19,532 - 7,750 2,128 - 1,069,368 28,867 1,287 2a.1.1 Totals 803 8,884 12.641 5.754 5,997 27,449 424 20,156 82,108 82,108 103,139 66,402 2,541 861 11,604,810 112,302 6,048 Removal of Major Equipment 2a 1.2 Main Turbine/Generater 102 15 117 117 3,298 2a,1,3 Main Condensers 534 80 , 615 615 16,323 TLG Services, Inc.

South Texas ProjectElectric Generating Station Document S30.1564-002, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 18 of 23 Attachment 1 Page 5 of 6 Table C-2 South Texas Project Electric Generating Station, Unit 2 DECON Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial B Volumes Burial I Craft Utility and Contractor Decon Removal Packaging Transport Processing Disposal Other Total Total LIc Term. Management Restoration Volume Class A Class Class C GTCC Processed Attinit Cost Cost Costs Costs "Costs Costs Costs Continsencs Costs Costs Costs Costs Co. Poet Co. Foot Co. Feet Co. Foot Co. Foot Wt.. Lbss, Monhoors Monboors I IIIUUA *MVlLy *U*t I*tlUI L n ex Cost Cast Costs Costs Costs Costs Costs Contingen Cast. ýosts Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt. Lbs. Manhours an ours Disposal of Plant Systems (continued) 2b.1.1.34 Main Steam (MS) 259 39 298 - 298 - - - 9,094 2b.I.1.35 Main Steam (MS) RCA 29 5 7 64 29 26 159 159 852 150 48,060 794 2b.1.1.36 Main Turbine & Lube Oil (LT/TM) 86 13 99 . - 99g - - 2,904 2b.1.1.37 Mechrnical Auxiliary Bldg HVAC [HM) RCA 1,364 71 140 1,932 159 699 4,366 4,366 25,859 812 1,123,019 28,436 2b.1 .1.38 Mechanical Auxiliary Building (XM) 161 2 5 71 4 53 296 296 9-44 21 40,236 4,385 2b.I.1.39 Miscellaneous "rains(MD) 40 6 45 - 45 - - 1,376 2b.1.1.40 Miscellaneous HVAC(HZ) - ill 17 127 - 127 - - - 3,966 2b.1.1.41 Misceltanmus HVAC (HZ) RCA 23 1 2 34 2 12 74 74 449 12 19,323 447 2b.1.1.42 Miscellaneous Reactor Coolant (RC) 21 204 49 57 139 465 212 1,148 1,148 - 1.854 2,422 288,607 6,654 2b.1.1.43 Miscellaneous Yard Areas & Bldgs (XY) 2,085 313 2,398 - 2,398 - - - 70.812 2b.1.1.44 Nonradioactive Dins & Stmps (DR) RCA 300 34 43 228 269 186 1,059 1,059 - 3.053 1,375 247,284 7,508 2b.1.1.45 Nonradioactive Plumbing Dms & Smps (OR) 89 13 103 - 103 - - 3,149 2b.1.1.46 Oily Waste (OW) 202 30 233 - 233 - - - 7,103 2b.1.1.47 Radioactive Vents & Drains (ED) 563 35 40 125 306 245 1,314 1,314 - 1.672 1,564 208,197 15,031 2b.1.1.48 Reactor Head Degassing (RD) 51 5 5 33 32 ,27 153 153 437 181 32.245 1,430 2b.1.1.49 Reactor Makeup Water (RM) 239 12 21 255 41 112 680 680 3,410 230 157,301 6,872 2b.1.1.50 Residual Heat Removal (RH) 310 200 92 89 187 745 442 2,064 2,064 - 2,501 3,810 443,218 7,000 2b.1.1.51 SG Sludge Lancing & Chem Creanlng (SL) 0 0 9 - 0 -- 8 2b.1.1.52 Safety Injection (SI) 966 201 226 1,121 1,481 834 4,828 4,828 - 15,003 7,882 1,288,472 28,132 2b.1.1.53 Secondary Process Sampling (SS) 35 5 40 - 40 - - - - 1,187 2b.I.1.54 Service Air (SA) 101 15 118 116 3,619 2b.1 .1.55 Service Water (TW) 61 9 70 70 2,112 2b.1.1.56 Standby DG Fuel Oil Strg & Trnsfr (DO) 36 5 41 41 1,166 2b.1.1.57 Standby Diesel Gen Starting Air (SD) 16 2 18 18 534 2b.1.1.58 Standby Diesel Generator (DG) ill 17 128 128 3,794 2b.1.1.59 Standby Diesel Generator Bldg HVAC(HG) 50 7 57 57 1,815 2b1.11.60 Standby Diesel Generator Lube Oil (LU) 4 1 4 4 124 2b.1.1.61 Standby Diesel Jacket Water (JW) 4 1 5 5 14 -

2b.1.1.62 Turbine Generator Building (XT) 105 16 121 121 3,516 2b.1.1.63 Turbine Generator Building HVAC (HT) 182 27 209 209. 6,685 2b.1.1.64 Turbine Gland Seal (GS) 28 4 29 29 877 2b.1.1 Totals 1,707 16,957 962 1,317 11,396 5,649 7,883 45,870 38,685 7.185 152,507 30,154 8,784,640 528,631 47 15 .185 27 2b.1.2 Scaffolding in support of decommissioning - 1,691 464 2.428 2,428 2,231 139 112,845 55,966 Decontamination of Site Buildings 2b.1.3.1 Reactor 955 830 146 187 682 752 1.018 4,571 4,571 9,125 68629 995,610 48,143 2b.,.3.2 Mechanical &Electrical Auxiliary 936 500 107 142 333 266 743 3.030 3,030 4,455 5,025 677,827 37,395 2b.l.3 Totals 1,894 1,330 253 329 1,015 1,018 1.761 7,600 7,600 13,580 11.654 1,673,437 85,538 2b.1 Subtotal Period 21 Activity Costs 3,600 19,978 1,262 1,660 12,595 6,694 10,108 55,898 48.713 7,185 168,318 41.946 10,570,920 670,135 Pettod 2b Additonal Costs 2b.2.I Spare RXclosure head - - 188 54 - 795 30 230 1,290 1,298 1,940 - 201,821 2.160 249 2b.2 Subtotal Period 21 Additional Costs - - 168 54 - 795 30 230 1,298 1.298 1949 - 201,821 2,160 249 Period 25 Collateral Costs 2b.3.1 Process liquid maste 358 - 267 *866 2,733 1,019 5,242 5,242 4,243 336,451 827 2b.3.2 Small tool alloance - 440 66 506 506 2b.3.3 Spent Fuel Capital and Transfer 21,948 3,292 25,240 - 25,240 2b.3.4 Survey &Release Scrap 577 87 664 664 2b.3.5 Matagorda County Taxes and Fees 304 - 304 304 2b.3.6 Matagorda County Hospital OistdictTaxes and FE 130 - 130 130 2b.3.7 Severance - - 316 47 363 363 2b.3 Subtotal Period 2b Collateral Costs 358 440 267 866 2,733 23,276 4,511 32,450 7,210 25.240 4,243 336,451 827 TLG Services, Inc.

South Texas Project Electric GeneratingStation Document S30.1564-002, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 21 of 23 Attachment 1 Page 6 of 6 Table C-2 South Texas Project Electric Generating Station, Unit 2 DECON Decommissioning Cost Estimate (thousands of 2007 dollars)

Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity 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 Contlinency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Macboors Monhours PERIOD 2 TOTALS 7,899 62,391 15,620 9,540 26,628 41.392 233,441 76,940 473,851 399,799 62.292 11,760 378,116 142,098 2,541 861 - 28,284,790 1,331,478 2,801,520 PERIOD 3b -Site Restoration Period 3b Direct Decommissioning Activities Demolition of Remaining Site Buildings 3b.1.1.1 Reactor 5,488 823 "6,311 6,311 77,001 3b.1.t.2 Basins 81 12 94 94 1,476 30.1.1.3 Circulating Water Intake & Discharge 2,380 357 2,736 2,736 43,105 3b.1.1.4 Diesel Generator 781 117 898 898 11.474 3b.1.1.5 Essential Cooling Pond/Intake/Discharge 618 93 711 711 12,244 3b.1.1.6 Isl Valve Cubicle & Aux Fdwr Strg Tnk 684 103 786 786 11,329 3b.1.1.7 Maintenance Operations Facility 373 56 429 429 8.372 3b.1.1.8 Mechanical & Electrical Auxiliary 4,606 691 5,297 5,297 74,736 3b.1.1.9 Miscellaneous Slabs, Foundations & Pads 803 120 923 923 16,946 3b.1.1.10 Miscellaneous Yard Buildings 2,004 301 2,304 2,304 ) 34,045 3b.1.1.11 Nuclear Support Center 535 80 615 615 12,272 301 3b.1.1.12 Nuclear Training Facility &Annex 81 45 346 346 7,275 3b,1.1.13 Reactor vessel head storage 12 94 94 1,633 3b.1.1.14 Sewage Treatment Plant 54 8 62 62 970 286 3b.1.1.15 Steam Generator Mausoleum 106 43 329 329 3,985 3b.1.1.16 Tank Pads & Foundations 16 121 121 2,203 3b.1.1.17 Transformer Pads 136 20 156 156 2,829 3b.I.1.18 Trenches & Culverts 1,739 261 2,000 2.000 26,320 3b6.1.1.19 Turbine Generator 2,264 340 2,603 2,603 44,990 3b.1.1.20 Turbine Generator Pedestal 886 133 1.018 1,018 10,798 3b.1.1.21 Warehousns 3,022 453 3.475 3,475 45,676 3b.1.1.22 Yard Piping 361 54 415 415 3,030 3b.1.1.23 Fuel Handling 2,285 343 2,628 2,628 31,762 3b.1.t Totals 29,870 4,481 34,351 34,351 484,471 Site Closeout Activities 3b.1.2 Remove Rubble 5,461 822 6,303 6,303 3,306 3b.1.3 Grade &landscape site 2,261 339 2,600 - 2,600 5,471 3b.1.4 Final report to NRC 53 8 61 61 - - 668 3b.1 Subtotal Period 3b Activity Costs 37,612 53 5,650 43,315 61 43.254 493,248 668 Period 30 Additional Costs 3b.2.1 Intake Cofferdam 969 145 1,114 1,114 9,312 -

3b.2.2 Discharge Cofferdam 324 49 373 373 3.115 -

3b.2.3 Concrete Processing - 1,470 5 221 1.695 1.695 7,478 3b.2 Subtotal Period 36 Additional Costs 2,762 415 3.182 3,182 19,905 Period 30 Collateral Costs 3b.3.1 Small tool allowance 335 50 386 - 386 3b.3.2 Spent Fuel Capital and Transfer 468 70 539 - 539 3b.3.3 Matagorda County Taxes and Fees 45 - 45 45 30b.3.4 Matagorda County Hospital District Taxes and Ft 45 - 45 45 3b.3.5 Severance 1,171 176 1,346 1,346 3b.3 Subtotal Period 30 Collateral Costs 335 1,730 296 2,361 1,437 539 386 Period 3b Period-Dependent Costs 3b.4.1 insurance - 796 80 875 875 - - - - . - -

3b.4.2 Heavy equipment rental 5,127 - 769 5,896 - 5,896 - - - - -

3b.4.3 Plant energy budget 251 38 288 86 202 - - - - -

TLG Services, Inc.

ATTACHMENT 2 PROJECT EVALUATION AND APPROVAL Proprietary& Confidential Withhold from Public Disclosure Pursuantto 10 CFR 2.390 Non-Proprietary Version

Non-Proprietary Attachment 2 Project Evaluation and Approval Page 1 of 5 N

$0 xls]Estlmate

/endor Svs Previous 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 20162 2017, 2021 2019 2020' 2021 2022 2023 2024 2025 2026 2027 Estimate Page 7

Non-Proprietary Attachment 2 Project Evaluation and Approval Pagce 2 Pae2of 5 Project Description. Storage Facility for Reactor Vessel Head CR Number 07-1642-RVOlON PIP No# 0 ESTIMATE ASSUMPTIONS Basis for estimate Construct long term storage facility for Reactor Vessel Head. Estimate based on commercial rates - no permitting, licensing included material rates from ENR A publication indexes for 2007.

B Risk considerations Monitoring requirements, sumps, electrical commodities etc.

C Complexity Relatively simple construction - additional efforts for containing contamination D Escalation factors Concurrence Signatures Unill Unit 2 Projects Date Signed Projects 2007 2007 PIP Supervisor Projects Schedule Manhours Field Engineer Estimate Manhours Project Manager Non Man Sup/

Training Craft dollars Health Phsysic MaterialtRental dolla Procedures STP Material Obsolescence Schedule Manhours Estimate Manhours STP INSTALLATION Craft dollars MM/Steve Blossom/Ron Korczynski EM Rudy Stastny/Dave Thornton I&C Jeff Lovejoy/Tony Vajdos AOV/MOV Brent Heraty/EdMatejoech WORKSHEET Desc Type Information Accuracy Avg Accuracy Rank Score SCOPE MATERIAL CONTRACTS Labor Estimate Page 7

Non-Proprietary Attachment 2 Project Evaluation and Approval Page 3 of 5 Project Desctiption Storage Facility for Reactor Vessel Head CR No# 07-1642-RVOION Project Requestor J LeValley PIP No# 0 Estimator Nagle Estimate Page 7

Non-Proprietary Attachment 2 Project Evaluation and Approval Page 4 of 5 Storaqe Faclity for Reactor Vessel Head 0 Project Risk Score Sheet for evaluating need of special management controls Estimate Page7

Non-Proprietary Attachment 2 Project Evaluation and Approval Page 5 of 5 Estimate Page 7

ATTACHMENT 3 ENERGYSOLUTIONS PROPOSALS Proprietary& Confidential Withhold from Public Disclosure Pursuantto 10 CFR 2.390 Non-Proprietary Version

Non-Proprietary Attachment 3 ENERGYSOLUTIONS September 24, 2007 ES-2007-001056 Mr. Joe Sheppard South Texas Project P. O. Box 289 Wadsworth, TX 77483

Dear Mr. Sheppard:

EnergySolutions is pleased to provide the attached proposal in response to our discussions.

EnergySolutions has been providing large component transportation and disposal services for over 20 years and is confident that we have offered the most efficient and cost effective option for STP.

Please note that EnergySolutions' proposal shall remain valid for STP's acceptance for a period of 60 days from the date of this letter. If you have any questions concerning our proposal or need additional information, please don't hesitate to contact me:

We appreciate the opportunity to bid on this work and look forward to talking with your further about our offer.

Office: 803-758-1827 Cell: 803-960-3619 Fax- 803-758-1834 Email: mslewis duratekinc.com Sincerely, Mark S. Lewis Regional Vice President and Director Logistics and Engineering Services MSL/jtg (P-2007-015) 140 Stoneridge Drive Columbia, South Carolina 29210 http://www.enercg Solutions.com

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY PGSOUTJONS

~N FOR TRANSPORTATiON AND DisPosAL OF'STEAM GENERATORS FROMTHE SOUTH TEXAS PROJECT(STP)

J SECTION 1.0 EXECUTIVE

SUMMARY

1-i (P-2007-01 5) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DiSPOSAL'OF STEAM GENERATORS ENE£RGX SOLUTIONS FROMTHE SouTH TEXAS PROJECT (STP)

SECTION 1.0 - EXECUTIVE

SUMMARY

EnergySolutions proposes the early disposal of the eight (8) steam generators (SGs) currently stored in a mausoleum at the two-unit STP Electric Generating Station (STP). An analysis has been performed to compare the costs of early disposal with the costs of postponing disposal until the units shut down and are decommissioned. This analysis demonstrates the economic advantages of early disposal and supports the use of STP's nuclear.Decommissioning Trust Fund (DTF) for the removal of the major components from the site in advance of shut down at the site. The net effect will be to reduce the overall cost to decommission the site and make more funds available to decommission the reactors at the time the reactors shut down.

Because it would reduce the eventual cost and complexity of decommissioning the facility, the use of DTF for prompt disposal of the major components is in the public interest as well as STP's interest In addition to the economic advantages, early disposal will facilitate the decommissioning process so that:

(1) The radioactive source term (contaminated SGs) will be reduced; (2) The site workers will be exposed to less radiation; and (3) An unnecessary management and regulatory burden can be eliminated.

Therefore, there are compelling operational, regulatory, safety, and cost advantages to proceeding with early removal of the SGs.

1.1 ECONOMIC ADVANTAGE The STP licenses are projected to expire in 2027 and 2028 with the disp 1-2 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PRoPosAL To STP NUCLEAR OPERATING COMPANY EN ERGF .SOLUTIOnS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROM THE SouTH TEXAS PROJECT (STP) 1.2 PROJECT APPROACH EnergySolutions will perform the engineering, transport, and disposal of the eight (8) old SGs, currently stored in an on-site mausoleum from STP to the EnergySo/utions'Disposal Site in Clive, Utah.

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earn Generator Kemoval from Mausoleum 1-3 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by EnergySolutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSA.L To STP NUCLEAR OPERATING COWANY FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS EN ERGYSOLUTIONS FROMTHE SouTH TEXAS PROJECT (STP) 0 El 1.3 TECHNICAL BENEFITS TO STPNOC M

For example, since 2004, the Clive facility has received and disposed of over 3.4 million pounds of large components from U.S. nuclear plants proceeding with decommissioning.

a Focus on Safety. EnergySolutions has an excellent safety record, with zero recordable injuries and no Notices of Violation (NOVs) or audit findings on more than 75 large component moves. Attention to safety on all work activities assures STP of no incidents and protection of the workers, public, and the environment.

1-4 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Prpoprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY ENERGcSOLUTIaYS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROMTHE SouTm TEXAS PROJECT (STP)

" Proven Plans, Procedures, and Work Control Process: Application of an approach based upon our previous field proven practices and use of previous documents associated with similar large component projects, including SG projects, will expedite project planning and assures safe, compliant, timely project execution.

" Dedicated Large Components and Licensing Organization: Dedicated organization with expertise in all aspects of large component disposal, including capabilities to perform radiological characterization, waste characterization, structural analysis, packaging/transport/shielding design, U.S. Department of Transportation (DOT)/NRC Special Permitting, etc. This provides the capability to plan, staff, and conduct all critical tasks associated with this project as required, with depth of personnel and multi-disciplinary skills facilitating completion of key design, analysis, and reporting activities.

'o Familiarity with Clive Site and Disposition Criteria: As the operator of the Clive Site, EnergySolutions is thoroughly familiar with all permits, communication, logistics, and waste acceptance criteria (WAC) associated with Clive disposal. This assures STP of successful approval and acceptance of the SGs at the Clive Site.

a Capability to Handle Miscellaneous Waste: In the event that additional miscellaneous waste is generated, the waste can be shipped directly to Clive or the EnergySolutions' Bear Creek Operations low-level waste processing facility in Oak Ridge, Tennessee for incineration, compaction, baling, metal melting, and other waste volume reduction technologies and methods to readily receive and process the STP miscellaneous waste.

1.5 Tables 1.1 and 1.2 show 1-5 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL TO STP NUCLEAR OPERATING COMP/ANY EN ERGYSOLUTIONS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROM THE SouTH TEXAS PROJECT (STP) ril UIi i%0il1W% 211 LAPrOLIVI I [ UUV 1ý1L1lI9 F- JII I Ic1 , 1, I" a a

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1.6

SUMMARY

EnergySolutions assures STP of an experenced engineering, radioactive material management, and transportation disposal firm with the depth of expertise, safety focus, and the ready capability to perform the STP SG disposition project safely and efficiently with minimal impact to normal station operations. We will work in partnership with STP to maintain the plans defined in this offer through project commencement and completion, as well as, continue to investigate other more cost-effective solutions. EnergySolutions offers the flexibility to alter transportation methods, transportation route, process methods, and disposal locations prior to implementation in the event conditions change that limit performance or cheaper options become available.

We will gladly discuss all aspects of our approach with STP and welcome an opportunity to provide a presentation, at your convenience, highlighting the benefits of our project approach.

1-6 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS XN ERGYSOL LIONS FROM THE SouTH TEXAS PROJECT (STP)

SECTION 2.0 TECHNICAL APPROACH 2-1 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSPa. To STP NUCLEAR OPERATING COIVMPANY FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS EN ERGNSOL.UTIONS FROM THE SouTH TEXAS PROJECT (STP) 2.0 - TECHNICAL APPROACH

2.1 INTRODUCTION

EnergySolutions evaluated all feasible options for the disposition of STP's SGs, taking into consideration the technical and regulatory requirements and our understanding of the overall project goals and objectives. EnergySolutions evaluated each option based on the following factors:

Safety. Radiological and industrial safety hazards; Price: The overall price versus the value STP would receive; Schedule: The impact the option would have on the overall project schedule; Liability: The potential long-term liability issues associated with the option; and U Regulatory. Minimizing risks associated with approvals and permits for off-site transportation, processing and disposal.

2.2 PROJECT ORGANIZATION EnergySolutions personnel are the nation's leading experts at safely handling complex transportation and logistical challenges, routinely transporting thousands of loads over six million miles across the United States each year. We are the most experienced transporter and disposer of large components, having transported over 75 components with many being multi-modal projects (rail, barge and highway) and disposed of over 90 components.

A primary and critical factor of our success and ability to perform this type of work is the caliber of people we utilize to manage these types of projects and the competent support personnel and infrastructure we possess (QA, Licensing, Engineering, Regulatory Affairs, etc.).

Our proposed organization is provided in Figure 2.1.

2-2 (P-2007-015) ES-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

A PROPOSAL TO STP FOR TRANSPORTATION AND DISPOSAL OF

-NLRG SOLUTIOAS STEAM GENERATOR LOWER ASSEMBLIES FROM THE SouTH TEXAS PROJECT z

0 2-3 - 00 6CD CD (P-2007-015) ES-2007-0010C)56 ,.

Proprietary Information. All writings, drawings, specifications and other data furnished by EnergySolutions at any time are the property of EnergySo/utions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden, The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL TO STP NUCLEAR OPERATING COMWANY LGSOL NN L[TIay'S FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROMTHE SouTH TEXAS PROJECT (STP) 2.3 DESIGN AND FABRICATION 2.3.1 Figure 2.2- Typical Transportation Saddles 2.3.2 2.3.3 2.-34 2-4 (P-2007-015)

Proprietary Information All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY EN, FRCYSOLL'TItAS FOR TRANSPORTATION AND DOSPOSAL OF STEAM GENERATORS FROM THE SouTH TEXAS PROJECT (STP) 2.4 REGULATORY WORK EnergySo/utions will perform the regulatory work discussed in this section to support the off-site transportation and disposal of the SGLAs at our Clive, Utah disposal facility.

2.4.1 U.S. DOT SPECIAL PERMIT EnergySolutions has obtained a Special Permit from the U.S. DOT for the packaging and transport of radioactive SGs, although the Special Permit requires the performance and documentation of compliance analysis. Subject to the limits of the Special Permit, EnergySolutions will be able to package and transport SGs from anywhere in the United States and will use this permit to transport the STP SGLAs. Based on station specific data provided by STP, EnergySolutions will perform the required analysis and prepare the necessary documentation to demonstrate that the STP SGLAs comply with the DOT Special Permit.

EnergySolutions will take the lead role in this activity. Table 2.1 below presents a responsibility matrix for demonstrating compliance with the U.S. DOT Special Permit.

2.4.2 DISPOSAL APPROVAL PRocEss I ___ I 1 Although not included as part of this proposal, EnergySolutions can perform these activities for STP.

2-5 (P-2007-015)

Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPos. To STP NUCLEAR OPERATING COIVAN Y EN ERGYSOLUTIOIS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROMTHE SouTH TEXAS PROJECT (STP)

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2 EnergySolutions has obtained a preliminary clearance from the railroads for transport of the STP SGLAs from Buckeye rail spur to Clive, UT. A final clearance will be requested 30 days prior to the shipment and could be denied due to recent road or bridge work, thus affect the pricing and ability to perform the work as proposed.

2-6 (P-2007-015)

Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY EN ERGASOLUTIONS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROM THE SOUTH TEXAS PROJECT (STP)

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S FIGURE2.3 TRANSPORTATION SECURITY PLANNING 2.6 2.6.1 PRE-MOBMLIZATION 2-7 (P-2007-015)

Proprietary Inforrnation- All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COIVPP1Y FOR TRANSPORTATION ANID DISPOSAL OF STEAM GENERATORS EN ERGYSOLUTIUVS FROMTHE SOUTH TEXAS PROJECT (STP)

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2-8 (P-2007-015)

Proprietary Information. ADiwritings, drawings, specifications and other data furnished by EnergySolutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL TO STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL. OF STEAM GENERATORS EN ERGYSOLUTIONS FROMTHE SouTH TEXAS PROJECT (STP)

I 2.6.3 SG PREPARATiO?'

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2-9 (PR2007-015)

Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential- Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL TO STP NUCLEAR OPERATING COMiPNY FOR TRANSPORTAT1ON AND DISPOSAL OF STEAM GENERATORS

[ NERGXSOLUTIONS FROM THE SOUTh TEXAS PROJECT (STP)

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2.65- PRAL TRANSPoRTATION ANt) DISPOSAL 2.7 MILESTONE SCHEDULE FIGURE 2.4 - SG SHIPM EN"T ENROUTrE TO CLIVE S

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2-10 (P-2007-015)

Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of EnergySo/utions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOS. ToSTP NUCLEAR OPERATING CONPANY E'

I-ENf G\;SOLUTIoNyS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROMTHE SouTH TEXAS PROJECT (STP)

SECTION 3A)

COMPENSATION ANDCOMMERCIAL TERMS 3-1 (P-2007-015) EnergySolutions-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by EnergySolufions at any time are the property of Energy Solufions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

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Non-Proprietary Attachment 3 A PROPOS,. TO STP NUCLEAR OPERATING COMPANY EN ERGYSOLUTIONS FOR TRANSPORTATION AND DISPOSAL OF STEAM GENERATORS FROMTHE SouTH TEXAS PROJECT (STP) 3.0 - COMPENSATION AND COMMERCIAL TERMS 3.1 COMPENSATION 3.2 MILESTONE PAYMENT SCHEDULE EnergySolutions suggests the proposed milestone payment schedule provided in Table 3.1 based on the percentage of work completed:

3.3 BASIS FOR BID 3-2 (P-2007-015) EnergySolutions-2007-001056 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION ANO DISPOS.. OF EN ERGO SOLUTIONS REACTOR HEADS FROM SOUTH TEXAS PROJECT PROPOSAL TO STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL OF REACTOR HEADS FROM SOUTH TEXAS PROJECT SUBMITTED BY:

ENERGYSOLUTIONS 140 STONERIDGE DRIVE COLUMBIA, SC 29210 JANUARY 25, 2007 (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solufions at any time are the property of EnergySolutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 EN ,ERGYSOLUTIONS January 24, 2007 ES-2007-001078 Mr. Johnny Houston STP Nuclear Operating Company South Texas Project P. O. Box 289 Wadsworth, TX 77483

Dear Mr. Houston:

EnergySolutions is pleased to provide the attached proposal in response to your verbal request for the "Disposal of Retired Reactor Vessel Closure Head Services from the South Texas Project (STP).

EnergySolutions has been providing large component transportation and disposal services for over 20 years and is confident that we have offered the most efficient and cost effective option for STP. STP's recent Life of Plant (LOP) Agreement is designed specifically for wastes such as these reactor heads.

Please note that EnergySolutions' proposal shall remain valid for STP's acceptance for a period of 120 days from the date of this letter. If you have any questions concerning our proposal or need additional information, please don't hesitate to contact me:

We appreciate the opportunity to bid on this work and look forward to talking with your further about our offer.

Office: 803-758-1827 Cell: 803-960-3619 Fax: 803-758-1834 Email: mslewis duratekinc.com Sincerely, Mark S. Lewis Regional Vice President and Director Logistics and Engineering Services MSL/jtg (P-2007-004) 140 Stoneridge Drive Columbia, South Carolina 29210 http:/iwww.energy Solutions.com

Non-Proprietary Attachment 3 A PROPOSAL To STP NUCLEAR ,OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL OF ENERY SOLUTIONS REACTOR HEADS FROM SOUTH TExAS PROJECT SECTION 1.0 - INTRODUCTION EnergySolutions is uniquely qualified to package, transport, and dispose of STP's old reactor heads.

Since our first project in 1992 to package, transport, and disposal of the Millstone steam generators, EnergySolutions has packaged, transported, and/or disposed of over 90 large components, which include reactor vessels, steam generators, reactor heads, pressurizers, heat exchangers, and turbine rotors. Our most recent reactor head disposition projects include the five (5),reactor heads from the Nuclear Management Corporation (NMC) plants and one (1) reactor head from the Millstone Unit 2 plants. The most recent Millstone project also included the pressurizer and two (2) turbine rotors.

Figure A-I is our suggested organization to accomplish this project is the same successful fashion.

SECTION 2.0 Page 1 (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of EnergySolutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request,

Non-Proprietary Attachment 3 A PROPOSAL TO STP NUCLEAR OPERATING COMPANY EN_ FRCASOLL TIONS FOR TRANSPORTATION AND DISPOSAL OF REACTOR HEADS FROM SOUTH TEXAS PROJECT 2.1 2.2 Page 2 (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of EnergySolutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

A PROPOSAL TO STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL OF EN ERGYSOLUTIONS REAC TOR HEADS FROM SOU TH TEXAS PROJECT Figure 1 Project Organization IZ~~IIIII K!

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CDCD (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by EnergySolutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be retumed to Energy Solutions upon request.

A PROPOSAL. TO STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DtSPOSAL OF LNE\RGi SOLUTIONS REACTOR HEADS FROM SouTH TEXAS PROJECT Figure 2 z0 Page 4 CD(

(P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

APROPOSAL To STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL OF ENlrsj' EGSoLuTJNs REACTOR HEADS FROM SouTH TEXAS PROJECT Figiure 3 z

0 Page 5 >fC (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosuretothi!rd parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL TO STP NUCLEAR OPERATING COMPANY 7" i\N SOL UTIONS FOR TRANSPORTATION AND DISPOSAL OF REACTOR HEADS FROM SouTH TEXAS PROJECT 2.3 I

Page 6 (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of EnergySolutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL TO STP NuCLEAR OPERATING CONPANY FOR TRANSPORTATION AND DisPosAL OF EN ERGYSOLUTIONS REACTOR HEADS FROM SouTH TEXAS PROJECT 2.4 Schedule A Level 1 schedule can be provided upon receipt of more detailed outage schedule. In order to properly plan the project, EneraySolutionswill require that STP finalize the start date and duration a mrnlnrnm *m r,{.

3.0 3.1 Page 7 (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of EnergySolutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 APROPOSAL TO STP NUCLEAR OPERATING COMPANY FOR TRANSPORTATION AND DISPOSAL OF LRG['SOLUTIONS EA REACTOR HEADSFROM SOUTH TEXAS PROJECT 3.2 Page 8 (P-2007-004) ES-2007-001078 Proprietary Information. All writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property of EnergySolutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

A PROPOSAL To STP NUCLEAR OPERATING COMPAN Y LN L RGYSOL o ,. SFOR TRANSPORTAllON.AND DISPOSAL OF

[SOREAC TOR HEADS FROM SOUTH TEXAS PROJECT ficlure:'4 z

° Page 9 0 zB (P-2007-004) ES-2007-001078 Proprietary Information. AXI writings, drawings, specifications and other data furnished by Energy Solutions at any time are the property f. Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

A PROPOSAL TO STP NUCLEAR OPERATING COMPAN Y EN -RGXSOLUTIONS FOR TRANSPORTATION AND DISPOSAL OF REACTOR HEADS FROM SOUTH TEXAS PROJECT Figure 5 0

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Page 10 >=r (P-2007-004) ES-2007-001078 CD CD Proprietary Information. All writings, drawings, specifications and other data furnished by EnergySolutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of Energy Solutions and disclosure to third parties of them or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.

Non-Proprietary Attachment 3 A PROPOSAL To0STP NUCLEAR OPERATING COPWANY FOR TRANSPORTATION AND DISPOSA.. OF EN ERGXASOLUTIONS REACTOR HEADS FROM SOUTH TEXAS PROJECT 4.0 COMPENSATION AND TERMS I_

Ua 5-.0 TIME & MATERIAL RATES The proposed Time & Material rates that would be applicable in the event that the project experienced a delay or stand down that was caused by parties other than EnergySolutions or EnergySolutions subcontractors are shown in Table G-2.

Page 11 (P-2007-004) ES-2007-001078 Proprietary Informatiorn. All writings, drawings, specifications and other data furnished by EnergySolutions at any time are the property of Energy Solutions and shall be treated as confidential. Such materials shall not be used to the detriment of EnergySolutions and disclosure to third parties of themn or information derived from them is forbidden. The materials must be returned to Energy Solutions upon request.