RS-09-111, Submittal of Clinton Power Station Site-Specific Safstor Decommissioning Cost Estimate

Submittal of Clinton Power Station Site-Specific Safstor Decommissioning Cost Estimate

ML092400249
Person / Time
Site:	Clinton
Issue date:	08/27/2009
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2010-0209, RS-09-111
Download: ML092400249 (138)

Text

Exelon Nuclear www.exeloncorp.com 4300 Winfield Road Warrenville, IL 60555 RS-09-111 August 27, 2009 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Clinton Power Station Facility Operating License No. NPF-62 NRC Docket No. 50-461 Subject :

Submittal of Clinton Power Station Site-Specific SAFSTOR Decommissioning Cost Estimate

Reference:

Letter from Keith R. Jury (Exelon Generation Company) to U.S. NRC, "Decommissioning Funding Assurance Plan," dated July 29, 2009 Exelon.

Nuclear 10 CFR 50.75(f)(1)

In the referenced letter, Exelon Generation Company, LLC (EGC) committed to provide a site-specific SAFSTOR Decommissioning Cost Estimate (DCE) for Clinton Power Station (CPS). The DCE is provided as Attachment 1, and, in accordance with 10 CFR 50.75(b)(1), is greater than the amount specified in 10 CFR 50.75(c). The DCE has been performed assuming that CPS is granted license extension, since it is intended to reflect the most likely decommissioning scenario for CPS. However, this determination of the minimum funding requirement does not credit the additional 20-year license renewal period. shows the radiological decommissioning (license termination) cash flow based on the DCE in Attachment 1, assuming the SAFSTOR scenario, and does not include the costs of dismantling non-radiological systems and structures or the cost of managing and storing spent fuel onsite. EGC has not made a final determination of the decommissioning approach for CPS. For the purpose of choosing a decommissioning option to demonstrate adequacy of funding to meet regulatory requirements, the SAFSTOR option has been selected. EGC may choose a different decommissioning option in the future, recognizing that the chosen option must meet NRC requirements for decommissioning funding.

August 27, 2009 U.S. Nuclear Regulatory Commission Page 2 The costs presented in Attachment 2 occur 20 years earlier than those in the Attachment 1 DCE to model the current license expiration date. No credit is taken for license renewal. The cash flow analysis assumes a 2% annual real rate of return on trust fund dollars until plant shutdown and on remaining trust fund dollars through the decommissioning period. The site-specific estimate is based on a period of safe storage specifically described in the Attachment 1 DCE. The Attachment 1 DCE presents the results in 2007 dollars. These results are converted into 2009 dollars by using the latest site-specific escalation factor, which is re-calculated on an annual basis.

For CPS, the decommissioning funding assurance is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i).

There are no additional amounts to be collected from ratepayers for CPS, nor are there any contracts relied upon to pursuant to 10 CFR 50.75(e)(1)(v). presents the calculation of radiological decommissioning funding assurance. The Table in Attachment 3 compares the funding assurance, calculated using the NRC generic formula, as recently published by the NRC, to the funding assurance calculated using the site-specific DCE methodology, as allowed by 10 CFR 50.75(e)(1)(i). Based on the site-specific methodology, and July 31, 2009 trust fund values, CPS meets all NRC radiological decommissioning funding assurance requirements.

There are no new regulatory commitments contained in this letter.

If you have any questions about this letter, please contact Patrick Simpson at (630) 657-2823.

Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments:

1. Clinton Power Station Decommissioning Cost Estimate

2. Clinton Power Station Radiological Decommissioning Projected SAFSTOR Cash Flow

3. Clinton Power Station NRC Funding Assurance Calculations

ATTACHMENT 1 Clinton Power Station Decommissioning Cost Estimate

Document E16-1555-005, Rev. 0 DECOMMISSIONING COST ANALYSIS for the CLINTON POWER STATION prepared for AmerGen Energy, LLC prepared by TLG Services, Inc.

Bridgewater, Connecticut October 2007

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TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

............................................................................... vii-xvi

1.

INTRODUCTION...................................................................................................1-1 1.1 Objectives of Study...........................................................................................1-1 1.2 Site Description.................................................................................................1-1 1.3 Regulatory Guidance........................................................................................1-2 1.3.1 Nuclear Waste Policy Act......................................................................1-4 1.3.2 Low-Level Radioactive Waste Acts......................................................1-6 1.3.3 Radiological Criteria for License Termination....................................1-7

2.

DECOMMISSIONING ALTERNATIVES..........................................................2-1 2.1 DECON..............................................................................................................2-2 2.1.1 Period 1 - Preparations.........................................................................2-2 2.1.2 Period 2 - Decommissioning Operations..............................................2-4 2.1.3 Period 3 - Site Restoration....................................................................2-8 2.1.4 ISFSI Operations and Decommissioning............................................2-9 2.2 SAFSTOR AND DELAYED DECOMMISSIONING...................................2-10 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..................................................................2-14

3.

COST ESTIMATE...................................................................................................3-1 3.1 Basis of Estimate..............................................................................................3-1 3.2 Methodology......................................................................................................3-1 3.3 Financial Components of the Cost Model.......................................................3-3 3.3.1 Contingency...........................................................................................3-3 3.3.2 Financial Risk........................................................................................3-5 3.4 Site-Specific Considerations.............................................................................3-7 3.4.1 Spent Fuel Management.......................................................................3-7 3.4.2 Reactor Vessel and Internal Components.........................................3-10 3.4.3 Primary System Components.............................................................3-11 3.4.4 Main Turbine and Condenser.............................................................3-11 3.4.5 Transportation Methods.....................................................................3-12 3.4.6 Low-Level Radioactive Waste Disposal.............................................3-12 3.4.7 Site Conditions Following Decommissioning....................................3-14

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TABLE OF CONTENTS (continued)

SECTION PAGE 3.5 Assumptions....................................................................................................3-14 3.5.1 Estimating Basis.................................................................................3-14 3.5.2 Labor Costs..........................................................................................3-15 3.5.3 Design Conditions................................................................................3-15 3.5.4 General.................................................................................................3-16 3.6 Cost Estimate Summary...............................................................................3-18

4.

SCHEDULE ESTIMATE......................................................................................4-1 4.1 Schedule Estimate Assumptions.....................................................................4-1 4.2 Project Schedule................................................................................................4-2

5. RADIOACTIVE WASTES.....................................................................................5-1

6.

RESULTS.................................................................................................................6-1

7.

REFERENCES........................................................................................................7-1 TABLES Summary of Decommissioning Cost Elements, DECON................................ xv Summary of Decommissioning Cost Elements, Delayed DECON................. xvi Summary of Decommissioning Cost Elements, SAFSTOR........................... xvii 3.1 Schedule of Annual Expenditures, DECON................................................. 3-19 3.2 Schedule of Annual Expenditures, Delayed DECON................................... 3-20 3.3 Schedule of Annual Expenditures, SAFSTOR.............................................. 3-21 5.1 Decommissioning Waste Summary, DECON................................................. 5-3 5.2 Decommissioning Waste Summary, Delayed DECON................................... 5-4 5.3 Decommissioning Waste Summary, SAFSTOR.............................................. 5-5 6.1 Summary of Decommissioning Cost Elements, DECON............................... 6-4 6.2 Summary of Decommissioning Cost Elements, Delayed DECON................. 6-5 6.3 Summary of Decommissioning Cost Elements, SAFSTOR............................ 6-6

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TABLE OF CONTENTS (continued)

SECTION PAGE FIGURES 4.1 Activity Schedule.............................................................................................. 4-3 4.2 Decommissioning Timeline, DECON.............................................................. 4-4 4.3 Decommissioning Timeline, Delayed DECON................................................ 4-5 4.4 Decommissioning Timeline, SAFSTOR.......................................................... 4-6 APPENDICES A.

Unit Cost Factor Development............................................................................. A-1 B.

Unit Cost Factor Listing...................................................................................... B-1 C.

Detailed Cost Analysis, DECON.......................................................................... C-1 D.

Detailed Cost Analysis, Delayed DECON........................................................... D-1 E.

Detailed Cost Analysis, SAFSTOR...................................................................... E-1

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REVISION LOG No.

CRA No.

Date Item Revised Reason for Revision 0

10-29-2007 Original Issue

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EXECUTIVE

SUMMARY

This report presents estimates of the cost to decommission the Clinton Power Station (Clinton) for the identified decommissioning scenarios following a scheduled cessation of plant operations. The analysis relies upon site-specific, technical information, developed in an evaluation in 2003-04 [1] for AmerGen Energy, LLC (AmerGen), a wholly owned subsidiary of Exelon Corporation, and updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The updated estimates are designed to provide AmerGen with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The primary goal of the decommissioning is the removal and disposal of the contaminated systems and structures so that the plants operating license can be terminated. The analysis recognizes that spent fuel will be stored at the site in the fuel buildings storage pool and/or in an independent spent fuel storage installation (ISFSI) until such time that it can be transferred to a Department of Energy (DOE) facility. Consequently, the estimates also include those costs to manage and subsequently decommission these storage facilities.

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.

The estimates incorporate a

minimum cooling period of approximately five and one-half years for the spent fuel that resides in the fuel buildings storage pool when operations cease. In the DECON and SAFSTOR scenarios, any residual fuel remaining in the pool after the cooling period is relocated to the ISFSI to await transfer to a DOE facility (the fuel is assumed to remain in the storage pool for the Delayed DECON scenario and transferred directly from the pool to an off-site DOE facility). The estimates also include the dismantling of non-essential structures and limited restoration of the site.

Alternatives and Regulations The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.[2] In this rule, 1

Decommissioning Cost Analysis for the Clinton Power Station, Document No. E16-1455-007, Rev.

0, TLG Services, Inc., May 2004 2

U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53,

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the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB.

DECON is defined as "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."[3]

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[4] Decommissioning is to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety.

ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."[5] As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of long-lived radioactive material. In 1997, the Commission directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations, however, rulemaking has been deferred based upon several factors (e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRCs current priorities) at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.

Number 123 (p 24018 et seq.), June 27, 1988 3

Ibid. Page FR24022, Column 3 4

Ibid.

5 Ibid. Page FR24023, Column 2

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In 1996, the NRC amended its decommissioning regulations to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[6] The amendments allow for greater public participation and better define the transition process from operations to decommissioning. Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 amendments relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in these regulations.

Decommissioning Scenarios The following scenarios were evaluated and are representative of the alternatives available to the owner:

1.

DECON: The plants operating license currently expires on September 29, 2026. However, for purposes of this study, the license is assumed to be renewed for an additional 20 years (until 2046). The first scenario assumes that an ISFSI is constructed to accommodate any residual spent fuel so as to facilitate decontamination and dismantling activities within the fuel building. 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 2058.

2.

Delayed DECON: In the second scenario, the unit is prepared for an abbreviated period of storage. The spent fuel discharged to the storage pool once operations cease remains in the pool until it can be transferred to a DOE facility. Decommissioning is delayed until the transfer of the fuel to the DOE is complete (i.e., in the year 2058). The unit is then decommissioned.

3.

SAFSTOR: The nuclear unit is placed into safe-storage in the third scenario.

However, decommissioning is deferred beyond the fuel storage period to the maximum extent possible; termination of the license would conclude within the maximum required 60-year period. As in the DECON scenario, spent fuel is relocated to an ISFSI until it can be transferred to a DOE facility. Dormancy continues following the removal of spent fuel from the site, timed to allow final decommissioning and license termination to be completed within 60 years of final shutdown.

6 U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors," NRC, Federal Register Volume 61, (p 39278 et seq.), July 29, 1996

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Methodology The methodology used to develop the estimates described within this document follows the basic approach originally presented in the cost estimating guidelines [7]

developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest available information on worker productivity in decommissioning.

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 estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.

Contingency Consistent with standard cost estimating practice, contingencies are applied to the decontamination and dismantling costs 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.[8] The cost elements in the estimates are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. 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, by contrast, are expected to be fully expended throughout the program. Inclusion of contingency is necessary to provide assurance that sufficient funding will be available to accomplish the intended tasks.

7 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986 8

Project and Cost Engineers Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239

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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,[9] and its Amendments of 1985,[10] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

AmerGen is currently able to access the disposal facility in Barnwell, South Carolina. However, in June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation allows South Carolina to gradually limit access to the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. At that time, EnergySolutions disposal facility in Clive, Utah may be the only alternative destination for a majority of the waste forms generated from decontamination and dismantling. As such, the costs reported for direct disposal (burial) are primarily based upon Exelons current pricing agreement with EnergySolutions.

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C as defined by 10 CFR §61) generated in the decontamination and dismantling of the reactor vessel. In the interim (at least until new waste disposal options become available) and for purposes of this analysis, waste disposal costs for this material (generally less than 2% of the total waste volume) are based upon Exelons currently negotiated cost of disposal at the Barnwell site.

Material exceeding Class C limits (limited to material closest to the reactor core and comprising approximately 0.2% of the total waste volume) is generally not suitable for shallow-land disposal. This material is packaged in the same multipurpose canisters used for spent fuel storage/transport and designated for geologic disposal.

A significant portion of the metallic waste 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 eliminate the portion of waste that does 9

Low-Level Radioactive Waste Policy Act of 1980, Public Law 96-573, 1980 10 Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, 1986

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not require disposal as radioactive waste, compaction, incineration or metal melt.

The estimates reflect the savings from waste recovery/volume reduction.

High-Level Radioactive Waste Management Congress passed the Nuclear Waste Policy Act [11] (NWPA) in 1982, assigning the responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. Two permanent disposal facilities were envisioned, as well as an interim storage facility. To recover the cost, the legislation created a Nuclear Waste Fund through which money is collected from the sale of electricity generated by the power plants. The NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to initiate the disposal of spent nuclear fuel and high level waste, as required by the NWPA and the utility contracts. As a result, utilities initiated legal action against the DOE. While legal actions continue, the DOE has no plans to receive spent fuel prior to completing the construction of its geologic repository.

Operation of DOEs yet-to-be constructed repository is contingent upon the review and approval of the facilitys license application by the NRC and the successful resolution of pending litigation. The latest timetable for submittal of the license application is mid-2008. Assuming a timely review, DOE expects that receipt of fuel could begin as early as 2017,[12] although 2020 may be more likely according to the director of the DOEs waste program.[13 ]

Once the repository is operational, fuel acceptance will be prioritized and spent fuel assemblies will need to meet certain acceptance criteria, including heat output.

These conditions require that the fuel discharged upon the cessation of operations be actively cooled and stored for a minimum period at the generating site prior to transfer (a minimum of five years as defined in 10CFR§961 for standard fuel). As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10CFR§50.54(bb).[14] This 11 Nuclear Waste Policy Act of 1982 and Amendments, U.S. Department of Energys Office of Civilian Radioactive Management, 1982 12 DOE Announces Yucca Mountain License Application Schedule, U.S. Department of Energys Office of Public Affairs, Press Release July 19, 2006 13 Remarks of OCRWM Director Ward Sproat to the National Academy of Science, November 2006 14 U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities,

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funding requirement is fulfilled 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/or ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core.

In the DECON and SAFSTOR scenarios the assemblies are packaged into multipurpose canisters for transfer to a newly constructed ISFSI. A five and one-half year cooling period is provided for the final core to meet the conditions for dry storage.

Once the storage pool is emptied, the fuel building can be either decontaminated and dismantled or prepared for long-term storage. The ISFSI, which can be operated under the stations general license, will be designed to accommodate the dry storage casks needed to off-load the wet storage pool. In the Delayed DECON scenario, the storage pool remains operational and used for the interim storage of the fuel until the transfer to DOE can be completed (no ISFSI is required).

The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. For purposes of this analysis, acceptance of commercial spent fuel by the DOE is expected to begin in 2018. With a large fleet of reactors, Exelon is able to re-assign allocations between its units to minimize on-site storage costs. Assuming spent fuel from the older units is given priority and with a maximum rate of transfer of 3,000 metric tons of uranium (MTU)/year), the assemblies residing in the Clinton storage pool at the time of shutdown would be scheduled for pickup in the years 2056 through 2058 (assuming the cessation of plant operations in 2046). This equates to 64 multi-purpose canisters (at 68 assemblies per canister).

Exelons strongly held position is that the DOE has a contractual obligation to accept Clintons fuel in a timely manner and consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds at the end of the stations life if, contrary to its contractual obligation, the DOE has not performed.

Subpart 54 (bb), Conditions of Licenses

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Site Restoration The efficient removal of the contaminated materials at the site will result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities will substantially damage power block structures, potentially weakening the footings and structural supports. Prompt demolition once the license is terminated 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 cost to dismantle site structures with a work force already mobilized is more efficient and less costly than if the process were deferred. Experience at shutdown generating stations has shown that plant facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force.

Consequently, this analysis assumes that non-essential site structures within the restricted access area are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then graded and stabilized.

Summary The costs to decommission Clinton were evaluated for several decommissioning scenarios, incorporating the attributes of both the DECON and SAFSTOR decommissioning alternatives. Regardless of the timing of the decommissioning activities, the estimates assume the eventual removal of all the contaminated and activated plant components and structural materials, such that the facility operator may then have unrestricted use of the site with no further requirement for an operating license. Delayed decommissioning is initiated after the spent fuel has been removed from the site and is accomplished within the 60-year period required by current NRC regulations. In the interim, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility can be completed. Once the transfer is complete, the storage facilities are also decommissioned.

The scenarios analyzed for the purpose of generating the estimates are described in Section 2. The assumptions are presented in Section 3, along with schedules of annual expenditures. The major cost contributors are identified in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendices C, D, and E. Cost summaries for the various scenarios are provided at the end of this section for the major cost components.

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SUMMARY

OF DECOMMISSIONING COST ELEMENTS DECON (thousands of 2007 dollars)

Activity Total Decontamination 20,716 Removal 158,458 Packaging 15,829 Transportation 10,548 Waste Disposal 55,662 Off-site Waste Processing 25,564 Program Management [1]

298,887 Spent Fuel Pool Isolation 10,503 Spent Fuel Management 124,876 Insurance and Regulatory Fees 10,669 Energy 6,731 Characterization and Licensing Surveys 15,676 Property Taxes 22,305 Miscellaneous Equipment 5,972 Site O&M 3,666 Total [2]

786,061 NRC License Termination 547,591 Spent Fuel Management 155,245 Site Restoration 83,225

[1] Includes engineering and security

[2] Columns may not add due to rounding

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SUMMARY

OF DECOMMISSIONING COST ELEMENTS DELAYED DECON (thousands of 2007 dollars)

Activity Total Decontamination 28,052 Removal 148,111 Packaging 12,819 Transportation 7,604 Waste Disposal 37,773 Off-site Waste Processing 25,564 Program Management [1]

353,365 Spent Fuel Pool Isolation 10,503 Spent Fuel Management 31,915 Insurance and Regulatory Fees 15,732 Energy 8,872 Characterization and Licensing Surveys 17,100 Property Taxes 29,948 Miscellaneous Equipment 9,630 Site O&M 5,663 Total [2]

742,651 NRC License Termination 476,232 Spent Fuel Management 181,048 Site Restoration 85,372

[1] Includes engineering and security

[2] Columns may not add due to rounding

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SUMMARY

OF DECOMMISSIONING COST ELEMENTS SAFSTOR (thousands of 2007 dollars)

Activity Total Decontamination 27,039 Removal 152,473 Packaging 12,025 Transportation 6,251 Waste Disposal 30,714 Off-site Waste Processing 30,148 Program Management [1]

424,198 Spent Fuel Pool Isolation 10,503 Spent Fuel Management 123,640 Insurance and Regulatory Fees 46,990 Energy 12,765 Characterization and Licensing Surveys 17,100 Property Taxes 76,770 Miscellaneous Equipment 22,433 Site O&M 17,901 Total [2]

1,010,952 NRC License Termination 691,981 Spent Fuel Management 233,606 Site Restoration 85,365

[1] Includes engineering and security

[2] Columns may not add due to rounding

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1. INTRODUCTION This report presents estimates of the cost to decommission the Clinton Power Station (Clinton), for the scenarios described in Section 2, following a scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2003-04,[1] updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects. The current estimate is designed to provide AmerGen Energy, LLC (AmerGen), a wholly owned subsidiary of Exelon Corporation (Exelon), with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear unit. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning 1.1 OBJECTIVES OF STUDY The objectives of this study are to prepare comprehensive estimates of the cost to decommission Clinton, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities. The plants operating license currently expires on September 29, 2026. However, for purposes of this study, the license is assumed to be renewed for an additional 20 years (until 2046).

1.2 SITE DESCRIPTION Clinton is located in east central Illinois, approximately 60 miles northeast of Springfield. The station is comprised of a single boiling water reactor with supporting facilities.

The Nuclear Steam Supply System (NSSS) consists of a BWR/6 boiling water reactor system designed by General Electric. The reactor recirculation system is comprised of the reactor vessel and two recirculation pump loops external to the reactor vessel which provides the driving flow of water to the reactor vessel jet pumps. Each external loop contains one high-capacity, motor-driven recirculation pump and three motor-operated gate valves for pump maintenance. The recirculation loops are a part of the nuclear system process barrier and are located inside the containment structure. The design reactor thermal power level is 3473 Megawatts thermal (MWt). The corresponding net electrical output is approximately 1022 Megawatts electric (MWe).

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The BWR-Mark III containment structure at Clinton consists of a lined, reinforced concrete cylinder with a hemispherical domed roof and a flat base slab. The drywell consists of a cylindrical reinforced concrete structure that surrounds the reactor vessel. The lower portion of the drywell is submerged in the suppression pool. The drywell and suppression pool are connected by three rows of circular vents which are located below the normal water level of the suppression pool.

Heat produced in the reactor is converted to electrical energy by the power conversion system. A turbine-generator system converts the thermal energy of the steam produced in the reactor into mechanical shaft power and then into electrical energy. The turbine consists of one high-pressure, double-flow turbine element, and two double-flow, low-pressure turbine elements all aligned in tandem. The generator is driven at 1800 rpm and rated at 1100 MVA. The exhaust steam from the turbine is condensed and deaerated in the main condenser. The heat rejected to the main condenser is removed by the circulating water system.

The circulating water system provides the heat sink required for removal of waste heat in the power plants thermal cycle. The system has the principal function of removing heat by absorbing this energy in the main condenser.

Water is withdrawn from Lake Clinton via the intake tunnels by the circulating water pumps. After passing through the plant condensers, the water is routed through the 3.4 mile long discharge flume back to the lake.

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

• Annotated references for citations in Sections 1-6 are provided in Section 7.

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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 SAFSTOR, 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 recent rulemaking permitting the controlled release of a site, the NRC has re-evaluated this alternative.[4] The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most, reactors. However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombments.[5] However, the NRCs staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRCs current priorities, at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.

The NRC published amendments to its decommissioning regulations in 1996.[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

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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. Within two years of submitting notice of 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).

1.3.1 Nuclear Waste Policy Act Congress passed the Nuclear Waste Policy Act[7] (NWPA) in 1982, assigning the responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. Two permanent disposal facilities were envisioned, as well as an interim storage facility. To recover the cost, the legislation created a Nuclear Waste Fund through which money is collected from the sale of electricity generated by the power plants. NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to initiate the disposal of spent nuclear fuel and high level waste, as required by the NWPA and utility contracts. Delays continue and, as a result, generators have initiated legal action against the DOE in an attempt to resolve the impasse.[8]

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Operation of DOEs yet-to-be constructed repository is contingent upon the review and approval of the facilitys license application by the NRC and the successful resolution of pending litigation. The latest timetable for submittal of the license application is mid-2008. Assuming a timely review, DOE expects that receipt of fuel could begin as early as 2017,[9]

although 2020 may be more likely according to the director of the DOEs waste program.[10]

Once the repository is operational, fuel acceptance will be prioritized and spent fuel assemblies will need to meet certain acceptance criteria, including heat output. These conditions require that the fuel discharged upon the cessation of operations be actively cooled and stored for a minimum period at the generating site prior to transfer (five years as defined in 10CFR§961 for standard fuel). As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10CFR§50.54(bb).[11] This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pools and ISFSI.

At shutdown, the spent fuel pools are expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the next five and one-half years the assemblies are packaged into multipurpose canisters for transfer to the repository or to the ISFSI. It is assumed that this period provides the necessary cooling for the final core to meet DOEs transport system requirements for decay heat.

The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. For purposes of this analysis, the acceptance of commercial spent fuel by the DOE is expected to begin in 2018. Given this scenario and an anticipated rate of transfer, spent fuel is projected to remain at the Clinton site for approximately 12 years after the cessation of operations. Consequently, costs are included within the analysis for the continued operation of the storage pool and the construction of an ISFSI, as required, and for the long-term caretaking of the spent fuel at the site until the year 2058.

AmerGen will construct an independent spent fuel storage installation (ISFSI) to support decommissioning operations (DECON and

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SAFSTOR scenarios). Once the storage pool is emptied, the fuel building is either decontaminated and dismantled or prepared for long-term storage. In the Delayed DECON scenario, the storage pool remains operational and is used for the interim storage of the fuel (i.e.,

no ISFSI is required).

Exelons strongly held position is that the DOE has a contractual obligation to accept Clintons fuel in a timely manner and consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds at the end of the stations life if, contrary to its contractual obligation, the DOE has not performed.

1.3.2 Low-Level Radioactive Waste Acts 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. Congress passed the Low-Level Radioactive Waste Policy Act in 1980,[12] declaring the states as being ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation. After little progress, the Low-Level Radioactive Waste Policy Amendments Act of 1985,[13] extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. However, to date, no new compact facilities have been successfully sited, licensed, and constructed.

AmerGen is currently able to access the disposal facility in Barnwell, South Carolina. However, in June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact.

The legislation allows South Carolina to gradually limit access to the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. At that time, EnergySolutions disposal facility in Clive, Utah may be the only alternative destination for a majority of the waste forms generated from decontamination and dismantling. As such, the costs reported for direct disposal (burial) are

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primarily based upon Exelons current pricing agreement with EnergySolutions.

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C as defined by 10 CFR §61) generated in the dismantling of the reactor vessel. In the interim (at least until new waste disposal options become available) and for purposes of this analysis, waste disposal costs for this material (generally less than 2%

of the total waste volume) are based upon Exelons currently negotiated cost of disposal at the Barnwell site.

Material exceeding Class C limits (limited to material closest to the reactor core and comprising approximately 0.2% of the total waste volume) is generally not suitable for shallow-land disposal. This material is packaged in the same multipurpose canisters used for spent fuel storage/transport and designated for geologic disposal.

A significant portion of the metallic waste 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 eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates reflect the savings from waste recovery/volume reduction.

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, Radiological Criteria for License Termination,[14] 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 Clinton assume that the site will be remediated to a residual level consistent with the NRC-prescribed level.

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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 from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).[15]

An additional limit of 4 millirem per year, as defined in 40 CFR

§141.16, is applied to drinking water.[16]

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) [17] 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 the Clinton for three variations of the approved decommissioning alternatives: DECON and SAFSTOR.

Although the scenarios differ with respect to technique, process, cost, and schedule, they attain the same result: the ultimate release of the site for unrestricted use.

Three decommissioning scenarios were evaluated for the nuclear unit. The scenarios selected are representative of alternatives available to the owner and are defined as follows:

1.

DECON: The plants operating license currently expires on September 29, 2026. However, for purposes of this study, the license is assumed to be renewed for an additional 20 years (until 2046). The first scenario assumes that an ISFSI is constructed to accommodate any residual spent fuel so as to facilitate decontamination and dismantling activities within the fuel building. 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 2058.

2.

Delayed DECON: In the second scenario, the unit is prepared for an abbreviated period of storage. The spent fuel discharged to the storage pool once operations cease remains in the pool until it can be transferred to a DOE facility. Decommissioning is delayed until the transfer of the fuel to the DOE is complete (i.e., in the year 2058). The unit is then decommissioned.

3.

SAFSTOR: The nuclear unit is placed into safe-storage in the third scenario.

However, decommissioning is deferred beyond the fuel storage period to the maximum extent possible; termination of the license would conclude within the maximum required 60-year period. As in the DECON scenario, spent fuel is relocated to an ISFSI until it can be transferred to a DOE facility. Dormancy continues following the removal of spent fuel from the site, timed to allow final decommissioning and license termination to be completed within 60 years of 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).

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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 and licensee from reactor operations (i.e., power production) to facilitate de-activation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee would then be prohibited from reactor operation.

The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimates developed for Clinton 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.

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.

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Engineering and Planning The PSDAR, required within two years of the notice to cease operations, provides a

description of the licensees planned decommissioning activities, a timetable, 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, i.e., without specific NRC approval. Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC, as defined by 10 CFR

§61. Major components are further defined as comprising the reactor vessel and internals, large bore reactor recirculation system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the §50.59 process in decommissioning. The proposed activity must not:



foreclose release of the site for possible unrestricted use,



significantly increase decommissioning costs,



cause any significant environmental impact, or



violate the terms of the licensees existing license.

Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations. The environmental impact associated with the planned decommissioning activities is also considered. Typically, a licensee will not be allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously evaluated environmental assessments or impact statements. In this instance, the licensee would have to submit a license amendment for the specific activity and update the environmental report.

The decommissioning program outlined in the PSDAR will be designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR §20) for protection of personnel from exposure to radiation hazards. It will also address the continued protection of the health and safety of the public and the environment during the

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dismantling activity. Consequently, with the development of the PSDAR, activity specifications, cost-benefit and safety analyses, and 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.



An ISFSI is designed, licensed and constructed to support offloading the spent fuel pool in support of the decommissioning program.



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 areas to optimize the overall project schedule. The fuel is transferred to the ISFSI as it decays to the point that it meets the heat load criteria of the containers.

Consequently, it is assumed that the fuel pool remain operational for approximately 51/2 years following the cessation of plant 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 termination of the

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10 CFR §50 operating license. 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.



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 buildings 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 a modified fuel storage canister for geologic disposal.

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Removal and segmentation of the remaining internals including the jet pump assemblies, fuel support castings, and core plate assembly.



Draining and decontamination of the reactor well and the permanent sealing of the spent fuel transfer gate. Install 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 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 supporting structure 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.



Transfer of the spent fuel from the storage pool to the ISFSI pad for interim storage. Spent fuel storage operations continue throughout the active decommissioning period. Fuel transfer is expected to begin in 2056 and to be completed by the end of the year 2058.

At least two years prior to the anticipated date of license termination, an LTP is required. Submitted as a supplement to the Final Safety Analysis Report (FSAR) or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local meeting. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including:



Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or

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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 structure.



Removal of the contaminated equipment and material from the turbine 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 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).[18] 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.

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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 final termination of the license.

The NRC will terminate 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 NRC limits will result in substantial damage to many of the structures. Although performed in a controlled, 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.

Prompt dismantling of site structures 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 cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.

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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.

Concrete rubble produced by demolition activities is processed to remove rebar and miscellaneous embedments. The processed material is then used on site to backfill voids. Excess materials are trucked to an off-site area for disposal as construction debris.

2.1.4 ISFSI Operations and Decommissioning The ISFSI will continue to operate under a separate and independent license (10 CFR §72) following the termination of the §50 operating license. Assuming the DOE starts accepting fuel in 2018, transfer of spent fuel from Clinton is anticipated to begin in 2056 and continue through the year 2058.

At the conclusion of the spent fuel transfer process, the ISFSI will be decommissioned. The Commission will terminate the §72 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.

The assumed design for the ISFSI is based upon the use of a multi-purpose canister and a concrete overpack for pad storage. For purposes of this cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required decontamination performed, and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad will then be removed, and the area graded and landscaped to conform to the surrounding environment.

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2.2 SAFSTOR AND DELAYED DECOMMISSIONING The NRC defines SAFSTOR as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use." The facility is left intact (during the dormancy period), with structures maintained in a sound condition. Systems not required to operate in support of the spent fuel pool or site surveillance and security are drained, de-energized, and secured.

Minimal cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination is performed. Access to contaminated areas is secured to provide controlled access for inspection and maintenance.

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.

The following discussion is appropriate for both the SAFSTOR and Delayed DECON scenarios, the primary differences being in the length of the dormancy period. In the Delayed DECON scenario, the fuel remains in the fuel buildings storage pool until such time that the transfer to a DOE facility is complete. Decommissioning operations are assumed to begin once fuel is off site. By contrast, in the SAFSTOR scenario, the spent fuel is relocated to a newly constructed ISFSI. The plant remains in safe-storage after the fuel is removed from site. Decommissioning operations are initiated such that the license is terminated within the required 60-year time period.

2.2.1 Period 1 - Preparations Preparations for long-term storage include the planning for permanent defueling of the reactors, 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:

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Isolation of the spent fuel storage services and fuel handling systems located in the fuel 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.



In the SAFSTOR scenario an ISFSI is designed, licensed and constructed to support offloading the spent fuel pool in support of the decommissioning program.



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.



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

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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 its 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. Fuel is shipped from the pool or the ISFSI (depending upon the scenario). After an optional period of storage (such that license terminations are accomplished within 60 years of final shutdown), it is required that the licensee submit applications to terminate the license, along with an 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.

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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 facilities located within the reactor buildings for decommissioning.

Variations in the length of the dormancy period are expected to have little effect upon the quantities of radioactive wastes generated from system and structure removal operations. Given the levels of radioactivity and spectrum of radionuclides expected from fifty to 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 estimates for the delayed scenarios incorporate reduced ALARA controls for the lower occupational exposure potential.

Although the initial radiation levels due to 60Co will 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 deferred scenarios. 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.

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2.2.4 Period 5 - Site Restoration Following completion of decommissioning operations, site-restoration activities can begin. If the site structures are to be dismantled, dismantling as a continuation of the decommissioning process is clearly the most appropriate and cost-effective option, as described in Section 2.1.3. The basis for the dismantling cost in the deferred scenarios 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 ESTIMATE The cost estimates prepared for decommissioning Clinton 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 ESTIMATE The estimates were developed with site-specific, technical information developed in an evaluation prepared for AmerGen Energy in 2003-04. The information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or 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,"[19] and the DOE "Decommissioning Handbook."[20] 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, "Building Construction Cost Data," published by R.S. Means.[21]

This analysis reflects 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 Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock

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Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-1 nuclear units have provided additional insight into the

process, the regulatory

aspects, and the technical challenges of decommissioning commercial nuclear units.

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.

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 "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

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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 estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.

3.3 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.

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.

3.3.1 Contingency 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[22] 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 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.

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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 station 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 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%,

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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%

Reactor Segmentation 75%

NSSS Component Removal 25%

Reactor Waste Packaging 25%

Reactor Waste Transport 25%

Reactor Vessel Component Disposal 50%

GTCC Disposal 15%

Non-Radioactive Component Removal 15%

Heavy Equipment and Tooling 15%

Supplies 25%

Engineering 15%

Energy 15%

Characterization and Termination Surveys 30%

Construction 15%

Taxes and Fees 10%

Insurance 10%

Staffing 15%

The contingency values are applied to the appropriate components of the estimates on a line item basis. A composite value is then reported at the end of each estimate. For example, the composite contingency value reported for the DECON alternative is 18.6%. Values for the other alternatives are delineated within the detailed cost tables in Appendices D and E.

3.3.2 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,

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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, in the start and rate of acceptance of spent fuel by the DOE).



Pricing changes for basic inputs, such as labor, energy, materials, and burial.

It has been TLGs experience that the results of a risk analysis, when compared with the base case estimate for decommissioning, indicate that the chances of the base decommissioning estimates being too high is a low probability, and the chances that the estimate is too low is a higher probability. This cost study, however, does not add any additional cost to the estimate for financial risk since there is insufficient historical data from which to project future liabilities.

Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimate.

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3.4 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 impact of the considerations identified below is included in this cost study.

3.4.1 Spent Fuel Management The cost to dispose of spent fuel generated from plant operations is not reflected within the estimates to decommission the Clinton site.

Ultimate disposition of the spent fuel is within the province of the DOEs Waste Management System, as defined by the NWPA. As such, the disposal cost is financed by a 1 mill/kWhr surcharge paid into the DOEs waste fund during operations. However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactors until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimate, as described below.

The total inventory of assemblies that will require handling during decommissioning is based upon several assumptions. The pickup of commercial fuel is assumed to begin in the year 2018. The maximum rate at which the fuel is removed from the commercial sites is based upon an annual capacity at the geologic repository of 3,000 metric tons of uranium (MTU). Any delay in the startup of the repository or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in the fuel remaining at the site longer.

In the DECON and SAFSTOR scenarios, an ISFSI is constructed for the interim caretaking of the spent fuel until such time that the transfer of spent fuel to the DOE is complete. Assuming that the DOE commences repository operation in 2018, fuel is projected to be removed from the Clinton site by the year 2058. In the Delayed DECON scenario, the fuel remains in the storage pool.

Operation and maintenance costs for the storage facilities are included within the estimates and address the cost for staffing the facilities, as well as security, insurance, and licensing fees. The estimates include the costs to purchase (DECON and SAFSTOR scenarios), load, and

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transfer the fuel storage canisters. Costs are also provided for the final disposition of the facilities once the transfer is complete.

Repository Startup Operation of the DOEs yet-to-be constructed geologic repository is contingent upon the review and approval of the facilitys license application by the NRC, the successful resolution of pending litigation, and the development of a national transportation system. By comparison, the NRCs review of the application for an interim storage facility submitted by the Private Fuel Storage consortium began in 1997. The Nuclear Regulatory Commission granted an operating license for the facility in September 2005, after eight years of review. With a more technically complex and politically sensitive application for permanent disposal, it is not unreasonable to expect that NRC approval to construct the repository at Yucca Mountain will require at least as long a review period. Therefore, the spent fuel management plan described in this section is predicated upon the DOE initiating the pickup of commercial fuel in the year 2018.

Spent Fuel Management Model The Exelon nuclear fleet consists of 21 units at 11 sites in Illinois, Pennsylvania, and New Jersey, including the inactive units at Dresden, Peach Bottom, and Zion. The ability to complete the decommissioning of these units, particularly for the DECON and Delayed DECON alternatives, is highly dependent upon when the DOE is assumed to remove spent fuel from the sites.

The DOE's repository program assumes that spent fuel will be accepted for disposal from the nation's commercial nuclear plants in the order (the "queue") in which it was removed from service ("oldest fuel first").[23] A computer model developed by Exelon Nuclear was used to determine when the DOE would provide allocations in the queue for removal of spent fuel from the individual sites. Repository operations were based upon annual industry-wide acceptance rates of 400 MTU/year for year 1, 600 MTU/ year for year 2, 1200 MTU/year for year 3, 2000 MTU/year for year 4, and 3000 MTU/year for year 5 and beyond.[24]

ISFSIs are constructed as necessary to maintain full-core discharge capability at the individual sites. Once the DOE begins repository

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operations, queue allocations are used to ship spent fuel from Exelon's operating sites. Spent fuel shipments are then made from decommissioning sites in the order of retirement.

Canister Design A multi-purpose storage canister (similar to the HOLTEC HI-STORM system), with a 68-fuel assemblies capacity, is assumed for future cask acquisitions. A unit cost of $500,000 is used for pricing the internal multi-purpose canister (MPC), with an additional cost of $250,000 for the concrete overpack. The DOE is assumed to provide the MPC for fuel transferred directly from the pool to the DOE at no cost to the owner.

Canister Loading and Transfer An average cost of $250,000 is used for the labor to load/transport the spent fuel from the pool to the ISFSI pad, based upon Exelon experience. For estimating purposes, 50% of this cost is used to estimate the cost to transfer the fuel from the ISFSI to the DOE.

Operations and Maintenance Annual costs (excluding labor) of approximately $738,410 and $82,164 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively.

ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a vertical, reinforced concrete storage overpack is used as a basis for the cost analyses. Approximately 50% of the overpacks are 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).

Approximately 10% of the concrete and steel is assumed to be removed from the overpacks for controlled disposal. The cost to dispose of this material, as well as the demolition of the ISFSI facility, is included in the estimates.

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3.4.2 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 cavity.

Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.

The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal (i.e., GTCC).

Although the material is not classified as high-level waste, the DOE has indicated it will accept this waste for disposal at the future high-level waste repository.[25] However, the DOE has not been forthcoming with an acceptance criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and waste form requirements. As such, for purposes of this study, the GTCC has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel. It is not anticipated that the DOE would 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 Clinton site.

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. 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 Clinton 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.

3.4.3 Primary System Components 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 recirculation pumps and motors are lifted out intact, packaged, and transported for processing and/or disposal.

3.4.4 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

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

3.4.5 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.[26] 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 demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with §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.

Transport of the highly activated metal, produced in the segmentation of the reactor vessels 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. 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.[27]

3.4.6 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is treated to reduce the total volume requiring controlled disposal. The treated material, meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning and recovery of the waste stream is performed off site at a licensed processing center.

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The mass of radioactive waste generated during the various decommissioning activities is reported by line-item in Appendices C, D and E, and summarized in Section 5. The Section 5 waste summaries are consistent with 10 CFR §61 classifications. Commercially available steel containers are 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 waste volumes are calculated on the exterior package dimensions for containerized material or a dimensional calculation for components serving as their own waste containers.

The more highly activated reactor components are transported 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.

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. The cost to dispose of the majority of the material generated from the decontamination and dismantling activities (> 98%) is based upon Exelons current disposal agreement with EnergySolutions for its facility in Clive, Utah.

Since the EnergySolutions facility is not able to accept the higher activity waste (Class B and C) generated in the decontamination of the reactor vessel and segmentation of the components closest to the core, the cost of disposal of this material (< 2% of the total volume) at a yet-to-be determined facility were based upon Exelons rates for the Barnwell facility.

Material exceeding Class C limits (limited to material closest to the reactor core and comprising approximately 0.2% of the total waste volume) is generally not suitable for shallow-land disposal. This material is packaged in the same multipurpose canisters used for spent fuel storage/transport and designated for geologic disposal.

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3.4.7 Site Conditions Following Decommissioning The NRC will terminate (or amend) 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. The NRCs involvement in the decommissioning process will end at this point. 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.

Non-essential structures or buildings severely damaged in decontamination process are removed to a nominal depth of three feet below grade. Concrete rubble generated from demolition activities is processed and made available as clean fill. The excavations will be regraded such that the power block area will have a final contour consistent with adjacent surroundings.

The estimates do not assume the remediation of any significant volume of contaminated soil. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria.

3.5 ASSUMPTIONS The following are the major assumptions made in the development of the estimates for decommissioning the site.

3.5.1 Estimating Basis 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.

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3.5.2 Labor Costs The craft labor required to decontaminate and dismantle the nuclear units will be acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis. Costs for site administration, operations, construction, and maintenance personnel are based upon average salary information provided by AmerGen or from comparable industry information.

AmerGen will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. The owner 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, activation, and structural analyses) under the direction of AmerGen.

3.5.3 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.[28] Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Clinton components, projected operating life, and different periods of decay. Additional short-lived isotopes were derived from CR-0130[29] and CR-0672,[30] and benchmarked to the long-lived values from 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.

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Activation of the reactor building structures is confined to the sacrificial shield. More extensive activation (at very low levels) of the interior structures within containment has been detected at several reactors and their owners have elected to dispose of the affected material at a controlled facility rather than reuse the material as fill on site or send it to a landfill. The ultimate disposition of the material removed from the reactor buildings will depend upon the site release criteria selected, as well as the designated end use for the site.

3.5.4 General Transition Activities Existing warehouses will be cleared of non-essential material and remain for use by Exelon 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. Exelon 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 salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis

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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 more than 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.

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.

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 and the limits for coverage defined in the NRCs proposed rulemaking Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors.[31]

NRCs financial protection requirements are based on various reactor (and spent fuel) configurations.

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Taxes Property taxes are included for all decommissioning periods. Exelon provided a schedule of decreasing tax payments against the current tax assessment. These reductions continue until reaching a minimum property tax payment of $1 million per year; this level is maintained for the balance of the 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.

3.6 COST ESTIMATE

SUMMARY

A schedule of expenditures for each scenario is provided in Tables 3.1 through 3.3. Decommissioning costs are reported in the year of projected expenditure; however, the values are provided in thousands of 2007 dollars.

Costs are not inflated, escalated, or discounted over the period of expenditure. The annual expenditures are based upon the detailed activity costs reported in Appendices C through E, along with the schedules discussed in Section 4.

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TABLE 3.1 SCHEDULE OF ANNUAL EXPENDITURES DECON (thousands, 2007 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2046 15,748 9,144 285 12 2,681 27,870 2047 58,639 31,625 1,394 1,782 15,380 108,820 2048 59,993 24,661 1,339 22,385 13,296 121,675 2049 62,537 25,927 1,053 27,317 7,977 124,811 2050 58,334 16,463 837 7,290 5,167 88,091 2051 58,215 16,196 831 6,726 5,088 87,056 2052 41,364 7,751 538 5,599 4,253 59,505 2053 34,407 5,315 222 471 2,693 43,107 2054 25,128 12,462 111 0

2,458 40,159 2055 25,128 12,462 111 0

2,458 40,159 2056 6,297 3,330 11 0

2,301 11,938 2057 4,286 2,355 0

0 2,277 8,918 2058 4,248 2,663 0

2 11,618 18,532 2059 1,387 1,957 0

265 1,810 5,420 455,713 172,312 6,731 71,849 79,457 786,061

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TABLE 3.2 SCHEDULE OF ANNUAL EXPENDITURES DELAYED DECON (thousands, 2007 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2046 10,580 253 285 12 2,657 13,787 2047 49,525 5,943 1,108 285 20,648 77,509 2048 18,586 1,634 438 138 4,853 25,649 2049 11,144 947 222 32 3,437 15,781 2050 11,144 947 222 32 3,437 15,781 2051 11,144 947 222 32 3,437 15,781 2052 11,175 951 222 32 3,447 15,826 2053 11,144 947 222 32 3,437 15,781 2054 11,144 947 222 32 3,437 15,781 2055 11,144 947 222 32 3,437 15,781 2056 11,750 2,676 222 32 3,447 18,126 2057 12,006 3,534 222 32 3,437 19,231 2058 12,068 3,534 224 32 3,434 19,292 2059 34,131 1,352 1,108 43 2,180 38,814 2060 47,182 11,702 1,083 13,187 7,470 80,624 2061 54,705 16,222 1,021 23,181 11,423 106,552 2062 58,212 10,055 831 11,704 4,523 85,326 2063 44,405 6,459 485 5,087 3,024 59,460 2064 24,256 10,878 131 6

1,172 36,444 2065 22,101 12,390 111 0

1,015 35,616 2066 9,749 5,465 49 0

448 15,710 487,291 98,728 8,871 53,960 93,799 742,651

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TABLE 3.3 SCHEDULE OF ANNUAL EXPENDITURES SAFSTOR (thousands, 2007 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2046 13,507 9,036 285 12 2,681 25,521 2047 58,847 33,644 1,108 285 20,742 114,626 2048 21,722 11,041 438 138 5,158 38,498 2049 14,164 10,009 222 32 3,809 28,236 2050 14,164 10,009 222 32 3,809 28,236 2051 14,164 10,009 222 32 3,809 28,236 2052 7,165 2,634 138 30 2,805 12,772 2053 4,923 289 111 30 2,477 7,830 2054 4,923 289 111 30 2,477 7,830 2055 4,923 289 111 30 2,477 7,830 2056 5,513 2,018 111 30 2,484 10,156 2057 5,786 2,877 111 30 2,477 11,280 2058 5,779 2,874 111 30 2,476 11,270 2059 2,769 284 111 29 2,150 5,343 2060 2,776 284 111 29 2,156 5,357 2061 2,769 284 111 29 2,150 5,343 2062 2,769 284 111 29 2,150 5,343 2063 2,769 284 111 29 2,150 5,343 2064 2,776 284 111 29 2,156 5,357 2065 2,769 284 111 29 2,150 5,343 2066 2,769 284 111 29 2,150 5,343 2067 2,769 284 111 29 2,150 5,343 2068 2,776 284 111 29 2,156 5,357 2069 2,769 284 111 29 2,150 5,343 2070 2,769 284 111 29 2,150 5,343 2071 2,769 284 111 29 2,150 5,343 2072 2,776 284 111 29 2,156 5,357 2073 2,769 284 111 29 2,150 5,343 2074 2,769 284 111 29 2,150 5,343 2075 2,769 284 111 29 2,150 5,343 2076 2,776 284 111 29 2,156 5,357 2077 2,769 284 111 29 2,150 5,343 2078 2,769 284 111 29 2,150 5,343 2079 2,769 284 111 29 2,150 5,343 2080 2,776 284 111 29 2,156 5,357 2081 2,769 284 111 29 2,150 5,343

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TABLE 3.3 (continued)

SCHEDULE OF ANNUAL EXPENDITURES SAFSTOR (thousands, 2007 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2082 2,769 284 111 29 2,150 5,343 2083 2,769 284 111 29 2,150 5,343 2084 2,776 284 111 29 2,156 5,357 2085 2,769 284 111 29 2,150 5,343 2086 2,769 284 111 29 2,150 5,343 2087 2,769 284 111 29 2,150 5,343 2088 2,776 284 111 29 2,156 5,357 2089 2,769 284 111 29 2,150 5,343 2090 2,769 284 111 29 2,150 5,343 2091 2,769 284 111 29 2,150 5,343 2092 2,776 284 111 29 2,156 5,357 2093 2,769 284 111 29 2,150 5,343 2094 2,769 284 111 29 2,150 5,343 2095 2,769 284 111 29 2,150 5,343 2096 2,776 284 111 29 2,156 5,357 2097 2,769 284 111 29 2,150 5,343 2098 2,769 284 111 29 2,150 5,343 2099 2,769 284 111 29 2,150 5,343 2100 2,769 284 111 29 2,150 5,343 2101 13,847 657 463 33 2,161 17,161 2102 36,161 2,998 1,108 408 2,213 42,889 2103 52,705 16,052 1,061 20,938 10,972 101,728 2104 56,866 13,107 928 16,886 8,202 95,989 2105 58,036 9,564 831 11,235 4,983 84,649 2106 30,886 6,057 193 27 1,665 38,827 2107 22,170 12,909 111 0

1,036 36,226 2108 22,231 12,945 111 0

1,039 36,325 2109 182 106 1

0 9

298 585,032 181,336 12,765 51,486 180,333 1,010,952

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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 3.4.1.

A schedule or sequence of activities is presented in Figure 4.1 for the DECON decommissioning alternative. The schedule is also representative of the work activities identified in the delayed dismantling scenarios, absent any spent fuel constraints. The scheduling sequence assumes that fuel is removed from the spent fuel pool within the first 51/2 years after operations cease. 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 2003" computer software.[32]

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 tables, 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 DECON decommissioning schedule:



The fuel building is isolated until such time that all spent fuel has been discharged from the spent fuel pool to the DOE or to the ISFSI.

Decontamination and dismantling of the storage pool are initiated once the transfer of spent fuel to the ISFSI is complete.



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

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and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.



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 schedule for decommissioning Clinton.

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 fuel building for final decontamination.

In Figure 4.1, the schedule is based upon years following the final shutdown date of September 29, 2046. Project timelines are provided in Figures 4.2 through 4.4; the milestone dates are based on this same shutdown date. The start of decommissioning activities in the Delayed Decommissioning scenario is concurrent with the end of the fuel transfer activity (i.e. to an off-site DOE facility).

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FIGURE 4.1 ACTIVITY SCHEDULE

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FIGURE 4.2 DECOMMISSIONING TIMELINE DECON (not to scale)

(Shutdown September 29, 2046)

ISFSI Operations Pool and ISFSI Operations Storage Pool Empty 03/2052 Period 1 Transition and Preparations 09/2046 03/2048 02/2056 06/2059 Period 2 Decommissioning Period 3 Site Restoration ISFSI Operations 12/2058 ISFSI D&D 10/2053

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FIGURE 4.3 DECOMMISSIONING TIMELINE DELAYED DECON (not to scale)

(Shutdown September 29, 2046)

Spent Fuel Storage Storage Pool Empty 12/2058 Period 1 Transition and Preparations 09/2046 03/2048 03/2064 06/2066 06/2060 Period 2 Dormancy 12/2058 Period 3 Delayed Preparations Period 4 Decommissioning Period 5 Site Restoration

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FIGURE 4.4 DECOMMISSIONING TIMELINE SAFSTOR (not to scale)

(Shutdown September 29, 2046)

ISFSI Empty 12/2058 Spent Fuel Storage Storage Pool Empty 03/2052 Period 1 Transition and Preparations 09/2046 03/2048 09/2106 01/2109 03/2103 Period 2 Dormancy 08/2101 Period 3 Delayed Preparations Period 4 Decommissioning Period 5 Site Restoration

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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(s). This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[33] the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, §71 defines radioactive material as it pertains to packaging and transportation and §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 §173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in subpart 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 volumes of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in Appendices C, D, and E and summarized in Tables 5.1 through 5.3. The quantified waste volume summaries shown in these tables are consistent with §61 classifications. The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.

The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners.

In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste),

where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone, i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides.

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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 Clinton is primarily generated during Period 2 of the DECON alternative and Period 4 of the deferred alternatives. 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 and activated materials are routed for controlled disposal. 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. The cost to dispose of the majority of the material generated from the decontamination and dismantling activities (> 98%) is based upon Exelons current disposal agreement with EnergySolutions for its facility in Clive, Utah.

Since the EnergySolutions facility is not able to accept the higher activity waste (Class B and C) generated in the decontamination of the reactor vessel and segmentation of the components closest to the core, the cost of disposal of this material (< 2% of the total volume) at a yet-to-be determined facility were based upon Exelons rates for the Barnwell facility.

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TABLE 5.1 DECOMMISSIONING WASTE

SUMMARY

DECON Waste Volume Weight Class1 (cubic feet)

(pounds)

Low-Level Radioactive Waste EnergySolutions (Clive, Utah)

Containerized A

160,829 11,833,483 Bulk A

33,347 3,363,716 Future Disposal Facility 2 B

2,156 246,431 C

689 43,240 Geologic Repository (Greater-than Class C)

>C 482 86,500 Total 3 197,503 15,573,370 Processed Waste (off-site) 505,717 21,170,880 Scrap Metal 150,712,000 1

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 2

EnergySolutions is currently not able to receive Class B and C material 3

Columns may not add due to rounding.

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TABLE 5.2 DECOMMISSIONING WASTE

SUMMARY

DELAYED DECON Waste Volume Weight Class1 (cubic feet)

(pounds)

Low-Level Radioactive Waste EnergySolutions (Clive, Utah)

Containerized A

160,392 11,621,662 Bulk A

29,242 2,856,638 Future Disposal Facility 2 B

1,502 157,200 C

287 36,625 Geologic Repository (Greater-than Class C)

>C 482 86,500 Total 3 191,906 14,758,625 Processed Waste (off-site) 505,717 21,170,880 Scrap Metal 150,712,000 1

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 2

EnergySolutions is currently not able to receive Class B and C material 3

Columns may not add due to rounding.

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TABLE 5.3 DECOMMISSIONING WASTE

SUMMARY

SAFSTOR Waste Volume Weight Class1 (cubic feet)

(pounds)

Low-Level Radioactive Waste EnergySolutions (Clive, Utah)

Containerized A

128,355 7,665,828 Bulk A

23,784 2,407,445 Future Disposal Facility 2 B

1,502 157,200 C

287 36,625 Geologic Repository (Greater-than Class C)

>C 482 86,500 Total 3 154,411 10,353,598 Processed Waste (off-site) 597,250 24,967,690 Scrap Metal 150,712,000 1

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 2

EnergySolutions is currently not able to receive Class B and C material 3

Columns may not add due to rounding.

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6. RESULTS The analysis to estimate the costs to decommission Clinton relied upon the site-specific, technical information developed for a previous analysis prepared in 2003-

04. While not an engineering study, the estimates provide AmerGen with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The estimates described in this report are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The decommissioning scenarios assume continued operation of the plants spent fuel pool for a minimum of 51/2 years following the cessation of operations for continued cooling of the assemblies. For the DECON and SAFSTOR scenarios, an ISFSI is constructed and used to safeguard the spent fuel, once sufficiently cooled, until such time that the DOE can complete the transfer of the assemblies to its repository. The spent fuel remains in the storage pool in the Delayed-DECON alternative.

The cost projected to promptly decommission (DECON) Clinton is estimated to be

$786.1 million. The majority of this cost (approximately 69.7%) is associated with the physical decontamination and dismantling of the nuclear unit so that the license can be terminated. Another 19.7% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 10.6% is for the demolition of the designated structures and limited restoration of the site.

The primary cost contributors, identified in Tables 6.1 through 6.3, 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 assumed, for purposes of this analysis, that AmerGen will oversee the decommissioning program, using a DOC to manage the decommissioning labor force and the associated subcontractors. The size and composition of the management organization varies with the decommissioning phase and associated site activities.

However, once the operating license is 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 51/2 years following the cessation of operations. The pool will be isolated

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and an independent spent fuel island created. This will allow decommissioning operations to proceed in and around the pool areas. Over the 51/2-year period, the spent fuel will be packaged into transportable steel canisters for loading into a DOE-provided transport cask (DECON and SAFSTOR alternatives). The canisters will be stored in concrete overpacks at the ISFSI until the DOE is able to receive them. Dry storage of the fuel under a separate license 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, disposal of the majority of the radioactive material is at EnergySolutions facility in Clive, Utah or some alternative facility. Highly activated components, requiring additional isolation from the environment, are packaged for geologic disposal. Disposal of these components 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 table 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 union 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-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can be more cost effective than deferral, due to the deterioration of the facilities (and therefore the working conditions) with time.

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

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 6, Page 3 of 6 TLG Services, Inc.

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 unit.

License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings. The status of any plant components and materials not removed in the decommissioning process will also require confirmation and will add to the expense of surveying the facilities alone.

The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 6, Page 4 of 6 TLG Services, Inc.

TABLE 6.1

SUMMARY

OF DECOMMISSIONING COST ELEMENTS DECON (thousands of 2007 dollars)

Work Category Cost Decontamination 20,716 2.6 Removal 158,458 20.2 Packaging 15,829 2.0 Transportation 10,548 1.3 Waste Disposal 55,662 7.1 Off-site Waste Processing 25,564 3.3 Program Management [1]

298,887 38.0 Spent Fuel Pool Isolation 10,503 1.3 Spent Fuel Management 124,876 15.9 Insurance and Regulatory Fees 10,669 1.4 Energy 6,731 0.9 Characterization and Licensing Surveys 15,676 2.0 Property Taxes 22,305 2.8 Miscellaneous Equipment 5,972 0.8 Site O&M 3,666 0.5 Total [2]

786,061 100.0 NRC License Termination 547,591 69.7 Spent Fuel Management 155,245 19.7 Site Restoration 83,225 10.6

[1] Includes engineering and security

[2] Columns may not add due to rounding

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 6, Page 5 of 6 TLG Services, Inc.

TABLE 6.2

SUMMARY

OF DECOMMISSIONING COST ELEMENTS DELAYED DECON (thousands of 2007 dollars)

Work Category Cost Decontamination 28,052 3.8 Removal 148,111 19.9 Packaging 12,819 1.7 Transportation 7,604 1.0 Waste Disposal 37,773 5.1 Off-site Waste Processing 25,564 3.4 Program Management [1]

353,365 47.6 Spent Fuel Pool Isolation 10,503 1.4 Spent Fuel Management 31,915 4.3 Insurance and Regulatory Fees 15,732 2.1 Energy 8,872 1.2 Characterization and Licensing Surveys 17,100 2.3 Property Taxes 29,948 4.0 Miscellaneous Equipment 9,630 1.3 Site O&M 5,663 0.8 Total [2]

742,651 100.0 NRC License Termination 476,232 64.1 Spent Fuel Management 181,048 24.4 Site Restoration 85,372 11.5

[1] Includes engineering and security

[2] Columns may not add due to rounding

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 6, Page 6 of 6 TLG Services, Inc.

TABLE 6.3

SUMMARY

OF DECOMMISSIONING COST ELEMENTS SAFSTOR (thousands of 2007 dollars)

Work Category Cost Decontamination 27,039 2.7 Removal 152,473 15.1 Packaging 12,025 1.2 Transportation 6,251 0.6 Waste Disposal 30,714 3.0 Off-site Waste Processing 30,148 3.0 Program Management [1]

424,198 42.0 Spent Fuel Pool Isolation 10,503 1.0 Spent Fuel Management 123,640 12.2 Insurance and Regulatory Fees 46,990 4.6 Energy 12,765 1.3 Characterization and Licensing Surveys 17,100 1.7 Property Taxes 76,770 7.6 Miscellaneous Equipment 22,433 2.2 Site O&M 17,901 1.8 Total [2]

1,010,952 100.0 NRC License Termination 691,981 68.4 Spent Fuel Management 233,606 23.1 Site Restoration 85,365 8.4

[1] Includes engineering and security

[2] Columns may not add due to rounding

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 7, Page 1 of 3 TLG Services, Inc.

7. REFERENCES 1

Decommissioning Cost Analysis for the Clinton Power Station, Document No.

E16-1455-007, Rev. 0, TLG Services, Inc., May 2004

2.

U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988

3.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," October 2003

4.

U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination

5.

U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, Entombment Options for Power Reactors, Advanced Notice of Proposed Rulemaking, Federal Register Volume 66, Number 200, October 16, 2001

6.

U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors,"

Nuclear Regulatory Commission, Federal Register Volume 61 (p 39278 et seq.), July 29, 1996

7.

Nuclear Waste Policy Act of 1982 and Amendments, U.S. Department of Energys Office of Civilian Radioactive Management, 1982

8.

U.S. Court of Federal Claims awarded Yankee Atomic, Connecticut Yankee and Maine Yankee damages over the federal governments failure to remove spent fuel from the sites in a September 2006 ruling

9.

DOE Announces Yucca Mountain License Application Schedule, U.S.

Department of Energys Office of Public Affairs, Press Release July 19, 2006

10.

Remarks of OCRWM Director Ward Sproat to the National Academy of Science, November 2006

11.

U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 7, Page 2 of 3 TLG Services, Inc.

7. REFERENCES (continued)

12.

Low-Level Radioactive Waste Policy, Public Law 96-573, 1980

13.

Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, January 15, 1986

14.

U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination, Federal Register, Volume 62, Number 139 (p 39058 et seq.), July 21, 1997

15.

Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination, EPA Memorandum OSWER No. 9200.4-18, August 22, 1997

16.

U.S. Code of Federal Regulations, Title 40, Part 141.16, Maximum contaminant levels for beta particle and photon radioactivity from man-made radionuclides in community water systems

17.

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

18.

Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),

NUREG/CR-1575, Rev. A, EPA 402-R-97-016, Rev. A, August 2000

19.

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

20.

W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.

Department of Energy, DOE/EV/10128-1, November 1980 21 "Building Construction Cost Data 2007," Robert Snow Means Company, Inc.,

Kingston, Massachusetts

22.

Project and Cost Engineers Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Section 7, Page 3 of 3 TLG Services, Inc.

7. REFERENCES (continued)

23.

Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004

24.

Civilian Radioactive Waste Management System Total System Description, Revision 02 (TDR-CRW-SE-000002), DOE/RW-0500, September 2001

25.

"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

26.

U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 1996

27.

Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, January 2004

28.

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

29.

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

30.

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

31.

Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors, 10 CFR Parts 50 and 140, Federal Register Notice, Vol. 62, No. 210, October 30, 1997

32.

"Microsoft Project 2003," Microsoft Corporation, Redmond, WA, 2003

33.

Atomic Energy Act of 1954, (68 Stat. 919)

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 1 of 4 TLG Services, Inc.

APPENDIX A UNIT COST FACTOR DEVELOPMENT

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 2 of 4 TLG Services, Inc.

APPENDIX A UNIT COST FACTOR DEVELOPMENT Example:

Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1.

SCOPE Heat exchangers weighing < 3,000 lbs. will be removed in one piece using a crane or small hoist. They will be disconnected from the inlet and outlet piping. The heat exchanger will be sent to the waste processing area.

2.

CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes)

(minutes)*

a Remove insulation 60 (b) b Mount pipe cutters 60 60 c

Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e

Cap openings 20 (d) f Rig for removal 30 30 g

Unbolt from mounts 30 30 h

Remove contamination controls 15 15 i

Remove, wrap, send to waste processing area 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):

+ Respiratory protection adjustment (50% of critical duration) 128

+ Radiation/ALARA adjustment (37.1% of critical duration) 95 Adjusted work duration 478

+ Protective clothing adjustment (30% of adjusted duration) 143 Productive work duration 621

+ Work break adjustment (8.33 % of productive duration) 52 Total work duration (minutes) 673

• • • Total duration = 11.217 hr ***

• Alpha designators indicate activities that can be performed in parallel

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 3 of 4 TLG Services, Inc.

APPENDIX A (Continued)

3.

LABOR REQUIRED Duration Rate Crew Number (Hours)

($/hr)

Cost Laborers 3.00 11.217 40.37 1358.49 Craftsmen 2.00 11.217 50.71 1137.63 Foreman 1.00 11.217 52.52 589.12 General Foreman 0.25 11.217 55.22 154.85 Fire Watch 0.05 11.217 40.37 22.64 Health Physics Technician 1.00 11.217 46.32 519.57 Total labor cost

$3,782.30

4.

EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs



Blotting paper 50 @ $0.46/sq ft {1}

$23.50



Plastic sheets/bags 50 @ $0.14/sq ft {2}

$7.00



Gas torch consumables 1 @ $7.60 x 1 /hr {3}

$7.60 Subtotal cost of equipment and materials

$37.60 Overhead & profit on equipment and materials @ 16.25 %

$6.11 Total costs, equipment & material

$43.71 TOTAL COST:

Removal of contaminated heat exchanger <3000 pounds:

$3,826.01 Total labor cost:

$3,782.30 Total equipment/material costs:

$43.71 Total craft labor man-hours required per unit:

81.88

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 4 of 4 TLG Services, Inc.

5.

NOTES AND REFERENCES



Work difficulty factors were developed in conjunction with the Atomic Industrial Forums (now NEI) program to standardize nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5 of the Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.



References for equipment & consumables costs:

1. www.mcmaster.com online catalog - Spill Control (7193T88)

2. R.S. Means (2007) 01 56 13.60-0200, page 20

3. R.S. Means (2007) 01 54 33.40-6360, page 608



Material and consumable costs were adjusted using the regional indices for Bloomington, Illinois.

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 1 of 7 TLG Services, Inc.

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

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit TLG Services, Inc.

Removal of clean instrument and sampling tubing, $/linear foot 0.44 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.67 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 6.62 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 12.84 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 24.91 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 32.31 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 47.55 Removal of clean pipe >36 inches diameter, $/linear foot 56.54 Removal of clean valve >2 to 4 inches 84.97 Removal of clean valve >4 to 8 inches 128.39 Removal of clean valve >8 to 14 inches 249.12 Removal of clean valve >14 to 20 inches 323.06 Removal of clean valve >20 to 36 inches 475.52 Removal of clean valve >36 inches 565.36 Removal of clean pipe hanger for small bore piping 27.74 Removal of clean pipe hanger for large bore piping 102.07 Removal of clean pump, <300 pound 214.82 Removal of clean pump, 300-1000 pound 596.40 Removal of clean pump, 1000-10,000 pound 2,370.45 Removal of clean pump, >10,000 pound 4,578.23 Removal of clean pump motor, 300-1000 pound 251.29 Removal of clean pump motor, 1000-10,000 pound 987.83 Removal of clean pump motor, >10,000 pound 2,222.62 Removal of clean heat exchanger <3000 pound 1,269.19 Removal of clean heat exchanger >3000 pound 3,186.37 Removal of clean feedwater heater/deaerator 9,008.39 Removal of clean moisture separator/reheater 18,554.33 Removal of clean tank, <300 gallons 276.53 Removal of clean tank, 300-3000 gallon 875.31 Removal of clean tank, >3000 gallons, $/square foot surface area 7.29

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit TLG Services, Inc.

Removal of clean electrical equipment, <300 pound 118.03 Removal of clean electrical equipment, 300-1000 pound 409.11 Removal of clean electrical equipment, 1000-10,000 pound 818.23 Removal of clean electrical equipment, >10,000 pound 1,938.19 Removal of clean electrical transformer < 30 tons 1,346.04 Removal of clean electrical transformer > 30 tons 3,876.36 Removal of clean standby diesel generator, <100 kW 1,374.86 Removal of clean standby diesel generator, 100 kW to 1 MW 3,068.79 Removal of clean standby diesel generator, >1 MW 6,353.02 Removal of clean electrical cable tray, $/linear foot 10.98 Removal of clean electrical conduit, $/linear foot 4.79 Removal of clean mechanical equipment, <300 pound 118.03 Removal of clean mechanical equipment, 300-1000 pound 409.11 Removal of clean mechanical equipment, 1000-10,000 pound 818.23 Removal of clean mechanical equipment, >10,000 pound 1,938.19 Removal of clean HVAC equipment, <300 pound 118.03 Removal of clean HVAC equipment, 300-1000 pound 409.11 Removal of clean HVAC equipment, 1000-10,000 pound 818.23 Removal of clean HVAC equipment, >10,000 pound 1,938.19 Removal of clean HVAC ductwork, $/pound 0.46 Removal of contaminated instrument and sampling tubing, $/linear foot 1.38 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 18.22 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 31.81 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 50.44 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 99.94 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 120.35 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 167.29 Removal of contaminated pipe >36 inches diameter, $/linear foot 198.10 Removal of contaminated valve >2 to 4 inches 389.16 Removal of contaminated valve >4 to 8 inches 468.84

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit TLG Services, Inc.

Removal of contaminated valve >8 to 14 inches 964.54 Removal of contaminated valve >14 to 20 inches 1,227.69 Removal of contaminated valve >20 to 36 inches 1,638.04 Removal of contaminated valve >36 inches 1,946.10 Removal of contaminated pipe hanger for small bore piping 95.16 Removal of contaminated pipe hanger for large bore piping 314.68 Removal of contaminated pump, <300 pound 833.51 Removal of contaminated pump, 300-1000 pound 1,925.74 Removal of contaminated pump, 1000-10,000 pound 6,317.24 Removal of contaminated pump, >10,000 pound 15,387.15 Removal of contaminated pump motor, 300-1000 pound 810.97 Removal of contaminated pump motor, 1000-10,000 pound 2,563.34 Removal of contaminated pump motor, >10,000 pound 5,754.95 Removal of contaminated heat exchanger <3000 pound 3,826.01 Removal of contaminated heat exchanger >3000 pound 11,057.37 Removal of contaminated feedwater heater/deaerator 27,067.28 Removal of contaminated moisture separator/reheater 59,257.58 Removal of contaminated tank, <300 gallons 1,383.82 Removal of contaminated tank, >300 gallons, $/square foot 27.17 Removal of contaminated electrical equipment, <300 pound 651.00 Removal of contaminated electrical equipment, 300-1000 pound 1,568.59 Removal of contaminated electrical equipment, 1000-10,000 pound 3,019.73 Removal of contaminated electrical equipment, >10,000 pound 5,879.30 Removal of contaminated electrical cable tray, $/linear foot 31.40 Removal of contaminated electrical conduit, $/linear foot 14.37 Removal of contaminated mechanical equipment, <300 pound 724.84 Removal of contaminated mechanical equipment, 300-1000 pound 1,734.48 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,333.70 Removal of contaminated mechanical equipment, >10,000 pound 5,879.30 Removal of contaminated HVAC equipment, <300 pound 724.84

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit TLG Services, Inc.

Removal of contaminated HVAC equipment, 300-1000 pound 1,734.48 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,333.70 Removal of contaminated HVAC equipment, >10,000 pound 5,879.30 Removal of contaminated HVAC ductwork, $/pound 1.90 Removal/plasma arc cut of contaminated thin metal components, $/linear in.

3.45 Additional decontamination of surface by washing, $/square foot 7.11 Additional decontamination of surfaces by hydrolasing, $/square foot 30.74 Decontamination rig hook up and flush, $/ 250 foot length 6,155.66 Chemical flush of components/systems, $/gallon 12.74 Removal of clean standard reinforced concrete, $/cubic yard 115.91 Removal of grade slab concrete, $/cubic yard 157.76 Removal of clean concrete floors, $/cubic yard 308.75 Removal of sections of clean concrete floors, $/cubic yard 914.22 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 206.24 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,835.23 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 260.73 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,429.54 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 395.41 Removal of below-grade suspended floors, $/cubic yard 308.75 Removal of clean monolithic concrete structures, $/cubic yard 777.20 Removal of contaminated monolithic concrete structures, $/cubic yard 1,834.53 Removal of clean foundation concrete, $/cubic yard 609.46 Removal of contaminated foundation concrete, $/cubic yard 1,708.95 Explosive demolition of bulk concrete, $/cubic yard 26.33 Removal of clean hollow masonry block wall, $/cubic yard 86.49 Removal of contaminated hollow masonry block wall, $/cubic yard 291.29 Removal of clean solid masonry block wall, $/cubic yard 86.49 Removal of contaminated solid masonry block wall, $/cubic yard 291.29 Backfill of below-grade voids, $/cubic yard 17.17 Removal of subterranean tunnels/voids, $/linear foot 97.18

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit TLG Services, Inc.

Placement of concrete for below-grade voids, $/cubic yard 126.19 Excavation of clean material, $/cubic yard 2.34 Excavation of contaminated material, $/cubic yard 34.53 Removal of clean concrete rubble (tipping fee included), $/cubic yard 176.67 Removal of contaminated concrete rubble, $/cubic yard 22.28 Removal of building by volume, $/cubic foot 0.26 Removal of clean building metal siding, $/square foot 1.02 Removal of contaminated building metal siding, $/square foot 3.62 Removal of standard asphalt roofing, $/square foot 2.05 Removal of transite panels, $/square foot 2.06 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 12.18 Scabbling contaminated concrete floors, $/square foot 7.14 Scabbling contaminated concrete walls, $/square foot 18.59 Scabbling contaminated ceilings, $/square foot 63.56 Scabbling structural steel, $/square foot 5.98 Removal of clean overhead crane/monorail < 10 ton capacity 568.59 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,615.30 Removal of clean overhead crane/monorail >10-50 ton capacity 1,364.64 Removal of contaminated overhead crane/monorail >10-50 ton capacity 3,876.03 Removal of polar crane > 50 ton capacity 5,681.55 Removal of gantry crane > 50 ton capacity 24,227.29 Removal of structural steel, $/pound 0.19 Removal of clean steel floor grating, $/square foot 3.95 Removal of contaminated steel floor grating, $/square foot 11.57 Removal of clean free standing steel liner, $/square foot 10.93 Removal of contaminated free standing steel liner, $/square foot 31.81 Removal of clean concrete-anchored steel liner, $/square foot 5.47 Removal of contaminated concrete-anchored steel liner, $/square foot 37.06 Placement of scaffolding in clean areas, $/square foot 13.71 Placement of scaffolding in contaminated areas, $/square foot 23.31

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit TLG Services, Inc.

Landscaping with topsoil, $/acre 17,857.85 Cost of CPC B-88 LSA box & preparation for use 1,576.14 Cost of CPC B-25 LSA box & preparation for use 1,412.58 Cost of CPC B-12V 12 gauge LSA box & preparation for use 1,208.16 Cost of CPC B-144 LSA box & preparation for use 6,188.48 Cost of LSA drum & preparation for use 131.05 Cost of cask liner for CNSI 14 195 cask 158.68 Cost of cask liner for CNSI 8 120A cask (resins) 6,290.96 Cost of cask liner for CNSI 8 120A cask (filters) 1,025.30 Decontamination of surfaces with vacuuming, $/square foot 0.62

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 1 of 13 TLG Services, Inc.

APPENDIX C DETAILED COST ANALYSIS DECON

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 2 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 Prepare preliminary decommissioning cost 118 18 136 136 1,300 1a.1.2 Notification of Cessation of Operations a

1a.1.3 Remove fuel & source material n/a 1a.1.4 Notification of Permanent Defueling a

1a.1.5 Deactivate plant systems & process waste a

1a.1.6 Prepare and submit PSDAR 181 27 209 209 2,000 1a.1.7 Review plant dwgs & specs.

417 63 480 480 4,600 1a.1.8 Perform detailed rad survey a

1a.1.9 Estimate by-product inventory 91 14 104 104 1,000 1a.1.10 End product description 91 14 104 104 1,000 1a.1.11 Detailed by-product inventory 118 18 136 136 1,300 1a.1.12 Define major work sequence 680 102 782 782 7,500 1a.1.13 Perform SER and EA 281 42 323 323 3,100 1a.1.14 Perform Site-Specific Cost Study 454 68 522 522 5,000 1a.1.15 Prepare/submit License Termination Plan 372 56 427 427 4,096 1a.1.16 Receive NRC approval of termination plan a

Activity Specifications 1a.1.17.1 Plant & temporary facilities 446 67 513 462 51 4,920 1a.1.17.2 Plant systems 378 57 435 391 43 4,167 1a.1.17.3 NSSS Decontamination Flush 45 7

52 52 500 1a.1.17.4 Reactor internals 644 97 741 741 7,100 1a.1.17.5 Reactor vessel 590 88 678 678 6,500 1a.1.17.6 Sacrificial shield 45 7

52 52 500 1a.1.17.7 Moisture separators/reheaters 91 14 104 104 1,000 1a.1.17.8 Reinforced concrete 145 22 167 83 83 1,600 1a.1.17.9 Main Turbine 189 28 218 218 2,088 1a.1.17.10 Main Condensers 189 28 218 218 2,088 1a.1.17.11 Pressure suppression structure 181 27 209 209 2,000 1a.1.17.12 Drywell 145 22 167 167 1,600 1a.1.17.13 Plant structures & buildings 283 42 325 163 163 3,120 1a.1.17.14 Waste management 417 63 480 480 4,600 1a.1.17.15 Facility & site closeout 82 12 94 47 47 900 1a.1.17 Total 3,871 581 4,452 4,064 388 42,683 Planning & Site Preparations 1a.1.18 Prepare dismantling sequence 218 33 250 250 2,400 1a.1.19 Plant prep. & temp. svces 2,419 363 2,782 2,782 1a.1.20 Design water clean-up system 127 19 146 146 1,400 1a.1.21 Rigging/Cont. Cntrl Envlps/tooling/etc.

2,048 307 2,355 2,355 1a.1.22 Procure casks/liners & containers 112 17 128 128 1,230 1a.1 Subtotal Period 1a Activity Costs 11,597 1,740 13,336 12,948 388 78,609 Period 1a Collateral Costs 1a.3.1 Spent Fuel Capital and Transfer 39,540 5,931 45,471 45,471 1a.3 Subtotal Period 1a Collateral Costs 39,540 5,931 45,471 45,471 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 3 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 1,320 132 1,452 1,452 1a.4.2 Property taxes 6,312 631 6,943 6,943 1a.4.3 Health physics supplies 377 94 471 471 1a.4.4 Heavy equipment rental 349 52 401 401 1a.4.5 Disposal of DAW generated 14 6

38 12 70 70 675 13,531 21 1a.4.6 Plant energy budget 964 145 1,108 1,108 1a.4.7 NRC Fees 258 26 284 284 1a.4.8 Emergency Planning Fees 450 45 495 495 1a.4.9 Site O&M Cost 250 37 287 287 1a.4.10 Spent Fuel Pool O&M 738 111 849 849 1a.4.11 ISFSI Operating Costs 82 12 94 94 1a.4.12 Security Staff Cost 5,955 893 6,848 6,848 157,471 1a.4.13 Utility Staff Cost 26,183 3,927 30,110 30,110 423,400 1a.4 Subtotal Period 1a Period-Dependent Costs 726 14 6

38 42,511 6,118 49,413 47,975 1,438 675 13,531 21 580,871 1a.0 TOTAL PERIOD 1a COST 726 14 6

38 93,648 13,789 108,220 60,924 46,909 388 675 13,531 21 659,480 PERIOD 1b - Decommissioning Preparations Period 1b Direct Decommissioning Activities Detailed Work Procedures 1b.1.1.1 Plant systems 429 64 494 444 49 4,733 1b.1.1.2 NSSS Decontamination Flush 91 14 104 104 1,000 1b.1.1.3 Reactor internals 363 54 417 417 4,000 1b.1.1.4 Remaining buildings 122 18 141 35 106 1,350 1b.1.1.5 CRD housings & NIs 91 14 104 104 1,000 1b.1.1.6 Incore instrumentation 91 14 104 104 1,000 1b.1.1.7 Removal primary containment 181 27 209 209 2,000 1b.1.1.8 Reactor vessel 329 49 379 379 3,630 1b.1.1.9 Facility closeout 109 16 125 63 63 1,200 1b.1.1.10 Sacrificial shield 109 16 125 125 1,200 1b.1.1.11 Reinforced concrete 91 14 104 52 52 1,000 1b.1.1.12 Main Turbine 189 28 217 217 2,080 1b.1.1.13 Main Condensers 189 28 218 218 2,088 1b.1.1.14 Moisture separators & reheaters 181 27 209 209 2,000 1b.1.1.15 Radwaste building 248 37 285 256 28 2,730 1b.1.1.16 Reactor building 248 37 285 256 28 2,730 1b.1.1 Total 3,060 459 3,519 3,193 327 33,741 1b.1.2 Decon NSSS 430 215 645 645 1,067 1b.1 Subtotal Period 1b Activity Costs 430 3,060 674 4,164 3,838 327 1,067 33,741 Period 1b Additional Costs 1b.2.1 Spent Fuel Pool Isolation 9,133 1,370 10,503 10,503 1b.2.2 Site Characterization 897 269 1,167 1,167 1b.2.3 Hazardous liquid disposal 7

411 104 523 523 1,571 89,546 1b.2.4 Contaminated asbestos disposal 8

5 2

15 15 60 1,800 1b.2.5 Clean asbestos disposal 2

0 2

2 1b.2 Subtotal Period 1b Additional Costs 15 416 10,033 1,746 12,210 12,210 1,631 91,346 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 4 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 1b Collateral Costs 1b.3.1 Decon equipment 726 109 834 834 1b.3.2 DOC staff relocation expenses 829 124 953 953 1b.3.3 Process liquid waste 28 47 270 2,284 630 3,260 3,260 183 721 90,984 176 1b.3.4 Small tool allowance 1

0 2

2 1b.3.5 Pipe cutting equipment 957 143 1,100 1,100 1b.3.6 Decon rig 1,243 186 1,430 1,430 1b.3.7 Spent Fuel Capital and Transfer 6,000 900 6,900 6,900 1b.3 Subtotal Period 1b Collateral Costs 1,997 958 47 270 2,284 6,829 2,094 14,479 7,579 6,900 183 721 90,984 176 Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 22 6

28 28 1b.4.2 Insurance 662 66 728 728 1b.4.3 Property taxes 2,110 211 2,321 2,321 1b.4.4 Health physics supplies 193 48 242 242 1b.4.5 Heavy equipment rental 175 26 201 201 1b.4.6 Disposal of DAW generated 8

3 20 6

37 37 355 7,109 11 1b.4.7 Plant energy budget 966 145 1,111 1,111 1b.4.8 NRC Fees 130 13 143 143 1b.4.9 Emergency Planning Fees 225 23 248 248 1b.4.10 Site O&M Cost 125 19 144 144 1b.4.11 Spent Fuel Pool O&M 370 55 425 425 1b.4.12 ISFSI Operating Costs 41 6

47 47 1b.4.13 Security Staff Cost 2,986 448 3,434 3,434 78,951 1b.4.14 DOC Staff Cost 4,136 620 4,756 4,756 63,789 1b.4.15 Utility Staff Cost 9,311 1,397 10,708 10,708 147,969 1b.4 Subtotal Period 1b Period-Dependent Costs 22 368 8

3 20 21,062 3,089 24,572 23,851 721 355 7,109 11 290,709 1b.0 TOTAL PERIOD 1b COST 2,449 1,326 55 288 2,720 40,984 7,603 55,425 47,478 7,621 327 2,169 721 189,439 1,254 324,450 PERIOD 1 TOTALS 2,449 2,052 69 294 2,758 134,632 21,391 163,646 108,401 54,530 715 2,844 721 202,970 1,274 983,930 PERIOD 2a - Large Component Removal Period 2a Direct Decommissioning Activities Nuclear Steam Supply System Removal 2a.1.1.1 Recirculation System Piping & Valves 49 45 8

12 99 63 277 277 530 64,091 1,943 2a.1.1.2 Recirculation Pumps & Motors 49 42 13 31 18 263 110 527 527 250 2,473 187,000 1,998 2a.1.1.3 CRDMs & NIs Removal 199 158 321 111 203 239 1,231 1,231 6,985 131,119 7,284 2a.1.1.4 Reactor Vessel Internals 166 2,726 5,033 2,034 15,013 280 11,443 36,695 36,695 1,753 1,435 689 357,865 39,200 1,700 2a.1.1.5 Reactor Vessel 81 5,751 1,904 850 2,046 280 6,107 17,019 17,019 12,291 1,319,880 39,200 1,700 2a.1.1 Totals 545 8,722 7,279 3,038 18 17,625 560 17,962 55,749 55,749 250 24,032 1,435 689 2,059,955 89,625 3,400 Removal of Major Equipment 2a.1.2 Main Turbine/Generator 348 885 180 2,586 152 628 4,780 4,780 54,728 1,613 2,607,544 7,309 2a.1.3 Main Condensers 1,174 952 194 2,781 163 876 6,139 6,139 58,848 1,735 2,803,815 24,681 Cascading Costs from Clean Building Demolition 2a.1.4.1 Reactor Building 905 136 1,041 1,041 11,450 2a.1.4.2 Auxiliary Building 216 32 248 248 2,582 2a.1.4.3 Radwaste Building 500 75 575 575 6,493 2a.1.4.4 Turbine Building 508 76 585 585 6,771 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 5 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 Cascading Costs from Clean Building Demolition (continued) 2a.1.4.5 Fuel Building 237 36 273 273 2,912 2a.1.4 Totals 2,367 355 2,722 2,722 30,209 Disposal of Plant Systems 2a.1.5.1 Acid Feed & Handling 26 1

1 21 10 59 59 488 19,822 533 2a.1.5.2 Auxiliary Steam 484 13 19 319 173 1,008 1,008 7,493 304,278 9,740 2a.1.5.3 Breathing Air 36 5

42 42 820 2a.1.5.4 CO2 & Generator Purge 16 2

18 18 349 2a.1.5.5 Caustic Handling 13 0

0 8

5 26 26 183 7,431 256 2a.1.5.6 Chem Radwaste Reprocessing & Disposal 395 391 39 36 94 168 361 1,484 1,484 2,211 2,121 249,902 14,872 2a.1.5.7 Chilled Water - RCA 1,035 27 40 679 369 2,149 2,149 15,914 646,286 20,760 2a.1.5.8 Chilled Water Non-RCA 166 25 191 191 3,682 2a.1.5.9 Chlorination 44 7

51 51 953 2a.1.5.10 Circulating Water - RCA 161 16 24 400 105 706 706 9,379 380,877 3,419 2a.1.5.11 Circulating Water Non-RCA 51 8

58 58 1,090 2a.1.5.12 Cntnmnt Aux & Fuel Bldg Equip Drains 90 5

5 8

24 31 162 162 187 253 30,046 1,844 2a.1.5.13 Cntnmnt Aux & Fuel Bldg Floor Drains 156 8

8 34 32 54 292 292 792 367 62,936 3,212 2a.1.5.14 Component Cooling Water Non-RCA 119 18 137 137 2,622 2a.1.5.15 Condensate 904 159 174 584 772 549 3,142 3,142 13,689 8,197 1,291,159 19,496 2a.1.5.16 Condensate Booster 855 161 178 543 806 539 3,082 3,082 12,724 8,568 1,284,382 18,468 2a.1.5.17 Condensate Polishing 690 46 45 188 188 259 1,416 1,416 4,398 2,104 357,430 14,429 2a.1.5.18 Condenser Vacuum 179 17 25 430 115 767 767 10,094 409,927 3,731 2a.1.5.19 Containment Combustible Gas 75 4

4 33 14 28 158 158 781 147 44,863 1,568 2a.1.5.20 Cycled Condensate 617 41 40 181 163 232 1,275 1,275 4,242 1,929 327,937 12,878 2a.1.5.21 Drywell Cooling 485 20 25 242 62 179 1,012 1,012 5,664 655 288,770 9,748 2a.1.5.22 Drywell Purge 138 11 15 118 42 66 391 391 2,764 451 152,687 2,951 2a.1.5.23 ECCS Equipment Cooling 72 2

4 51 3

27 159 159 1,190 32 51,154 1,484 2a.1.5.24 Extraction Steam 473 54 63 236 271 236 1,333 1,333 5,531 2,875 482,498 10,135 2a.1.5.25 Feedwater 519 88 100 331 445 315 1,799 1,799 7,772 4,722 739,273 11,221 2a.1.5.26 Feedwater Heater Drains Turbine Cycle 1,238 112 126 507 527 548 3,058 3,058 11,899 5,704 985,459 26,301 2a.1.5.27 Feedwater Heater Misc.

193 13 13 29 62 71 382 382 685 664 87,316 4,010 2a.1.5.28 Filtered Water 4

1 4

4 86 2a.1.5.29 Generator Hydrogen Seal Oil 25 0

1 10 8

44 44 243 9,883 469 2a.1.5.30 Generator Stator Cooling 16 0

1 9

6 32 32 207 8,423 339 2a.1.5.31 High Pressure Core Spray 251 36 39 131 170 134 761 761 3,077 1,807 287,030 5,388 2a.1.5.32 Hydrogen 22 0

0 7

7 36 36 168 6,815 403 2a.1.5.33 Laundry Equip & Flr Drains RW Reprocess 209 14 14 90 49 82 459 459 2,116 646 132,817 4,399 2a.1.5.34 Leak Detection 42 1

1 1

3 11 58 58 30 29 3,822 928 2a.1.5.35 Local Instrument Panels 5

1 6

6 116 2a.1.5.36 Low Pressure Core Spray 97 21 21 65 97 64 365 365 1,535 1,028 154,545 2,081 2a.1.5.37 Machine Shop Equipment 10 0

1 10 4

25 25 225 9,119 216 2a.1.5.38 Machine Shop Ventilation 222 5

8 114 7

76 431 431 2,665 71 114,605 4,249 2a.1.5.39 Main Steam 833 74 80 298 347 359 1,991 1,991 6,987 3,685 614,246 17,632 2a.1.5.40 Main Steam Isolation Valve 21 1

1 1

4 7

35 35 23 47 5,157 429 2a.1.5.41 Make-up Demineralizer - RCA 184 4

6 103 63 360 360 2,419 98,255 3,595 2a.1.5.42 Make-up Demineralizer Non-RCA 208 31 239 239 4,416 2a.1.5.43 Makeup Condensate Storage 240 15 14 22 67 84 442 442 518 715 85,161 4,912 2a.1.5.44 Misc. Building Drains 16 2

19 19 357 2a.1.5.45 Miscellaneous Ventilation 30 4

34 34 643 2a.1.5.46 Nuclear Boiler 0

17 1

1 1

3 5

27 27 17 30 3,359 363 2a.1.5.47 Oil Transfer 90 4

6 104 39 243 243 2,429 98,662 1,834 2a.1.5.48 Reactor Core Isolation Cooling 216 15 15 77 57 84 463 463 1,796 698 127,607 4,557 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 6 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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) 2a.1.5.49 Refrigeration Piping 17 3

20 20 388 2a.1.5.50 Sanitary 151 23 174 174 3,202 2a.1.5.51 Screen House & MU Pump House Ventilation 31 5

36 36 736 2a.1.5.52 Standby Liquid Control 26 1

1 18 9

55 55 413 16,763 529 2a.1.5.53 Switchgear Heat Removal 16 2

19 19 356 2a.1.5.54 Turbine Building Closed Cooling Water 148 4

5 90 52 299 299 2,106 85,531 2,948 2a.1.5.55 Turbine Electrohydraulic Control 9

0 0

4 3

16 16 84 3,405 185 2a.1.5.56 Turbine Gen Misc Drains & Vents 50 2

2 6

9 16 86 86 136 96 14,138 1,013 2a.1.5.57 Turbine Gland Seal Steam 335 40 50 453 130 196 1,205 1,205 10,629 1,384 555,788 7,100 2a.1.5.58 Turbine Oil 54 4

5 37 18 25 144 144 866 199 52,601 1,145 2a.1.5.59 Turbine-Gen Aux & Misc Devices 240 51 62 289 250 180 1,073 1,073 6,779 2,656 513,573 5,243 2a.1.5 Totals 396 13,063 1,131 1,280 6,974 4,792 5,922 33,558 32,510 1,048 163,551 51,880 11,205,730 280,825 2a.1.6 Scaffolding in support of decommissioning 3,063 50 11 140 17 798 4,080 4,080 2,969 185 150,174 70,739 2a.1 Subtotal Period 2a Activity Costs 941 28,737 10,296 4,704 12,499 22,750 560 26,540 107,027 105,979 1,048 280,345 79,444 1,435 689 18,827,220 503,388 3,400 Period 2a Additional Costs 2a.2.1 Disposal of stored turbine rotors 17 100 40 743 130 1,030 1,030 15,719 707,358 352 2a.2 Subtotal Period 2a Additional Costs 17 100 40 743 130 1,030 1,030 15,719 707,358 352 Period 2a Collateral Costs 2a.3.1 Process liquid waste 138 65 359 138 164 864 864 1,234 89,037 241 2a.3.2 Small tool allowance 375 56 431 388 43 2a.3.3 Spent Fuel Capital and Transfer 23,000 3,450 26,450 26,450 2a.3 Subtotal Period 2a Collateral Costs 138 375 65 359 138 23,000 3,670 27,745 1,252 26,450 43 1,234 89,037 241 Period 2a Period-Dependent Costs 2a.4.1 Decon supplies 79 20 99 99 2a.4.2 Insurance 905 91 996 996 2a.4.3 Property taxes 3,390 339 3,729 3,356 373 2a.4.4 Health physics supplies 2,450 613 3,063 3,063 2a.4.5 Heavy equipment rental 3,043 456 3,500 3,500 2a.4.6 Disposal of DAW generated 212 87 556 173 1,028 1,028 9,960 199,586 304 2a.4.7 Plant energy budget 1,635 245 1,880 1,880 2a.4.8 NRC Fees 614 61 676 676 2a.4.9 Emergency Planning Fees 357 36 393 393 2a.4.10 Site O&M Cost 446 67 513 513 2a.4.11 Spent Fuel Pool O&M 1,318 198 1,516 1,516 2a.4.12 ISFSI Operating Costs 147 22 169 169 2a.4.13 Security Staff Cost 8,912 1,337 10,248 10,248 235,651 2a.4.14 DOC Staff Cost 18,424 2,764 21,188 21,188 283,154 2a.4.15 Utility Staff Cost 33,174 4,976 38,150 38,150 527,189 2a.4 Subtotal Period 2a Period-Dependent Costs 79 5,493 212 87 556 69,323 11,397 87,148 84,697 2,077 373 9,960 199,586 304 1,045,994 2a.0 TOTAL PERIOD 2a COST 1,158 34,622 10,673 5,190 13,241 23,443 92,884 41,738 222,949 192,958 28,527 1,464 296,064 90,638 1,435 689 19,823,200 504,285 1,049,394 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 7 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 2b - Site Decontamination Period 2b Direct Decommissioning Activities Disposal of Plant Systems 2b.1.1.1 Component Cooling Water - RCA 178 4

6 101 61 350 350 2,361 95,865 3,548 2b.1.1.2 Containment Monitoring 56 1

1 4

4 16 83 83 98 44 7,962 1,241 2b.1.1.3 Control Rod Drive 397 19 19 57 88 135 715 715 1,333 930 137,526 8,291 2b.1.1.4 Diesel Fuel Oil 59 9

68 68 1,256 2b.1.1.5 Diesel General 52 8

60 60 1,133 2b.1.1.6 Diesel-Generator Room Ventilation 77 12 88 88 1,817 2b.1.1.7 Drains-Laundry to Radwaste 17 1

1 1

4 5

29 29 34 39 4,837 340 2b.1.1.8 Electrical - Clean Non-RCA 1,545 232 1,777 1,777 33,545 2b.1.1.9 Electrical - Clean RCA 6,131 125 188 3,190 2,052 11,687 11,687 74,814 3,038,244 126,548 2b.1.1.10 Equip Drain Radwaste Reprocessing 1,132 69 67 307 271 414 2,261 2,261 7,207 3,254 551,230 23,620 2b.1.1.11 Fire Protection Non-RCA 154 23 177 177 3,416 2b.1.1.12 Floor Drain Radwaste Reprocessing 705 54 55 235 227 282 1,558 1,558 5,507 2,655 439,585 14,712 2b.1.1.13 HVAC - Auxiliary Building 31 1

2 23 3

12 73 73 540 36 25,200 663 2b.1.1.14 HVAC - Control Room 242 36 279 279 5,686 2b.1.1.15 HVAC - Fuel Building 313 8

11 161 10 107 611 611 3,782 107 163,158 5,975 2b.1.1.16 HVAC - Laboratory 504 13 18 257 17 173 982 982 6,035 181 261,272 9,695 2b.1.1.17 HVAC - Off Gas Building 128 6

7 64 18 48 271 271 1,499 192 78,082 2,607 2b.1.1.18 HVAC - Radwaste Building 713 21 30 395 37 253 1,449 1,449 9,269 389 411,319 13,769 2b.1.1.19 HVAC - Service Building 52 8

60 60 1,145 2b.1.1.20 HVAC - Turbine Building 589 15 22 316 20 204 1,167 1,167 7,421 211 320,323 11,248 2b.1.1.21 Hoists Cranes & Elevators 6

1 7

7 123 2b.1.1.22 Instrument Air - RCA 374 5

7 115 112 613 613 2,708 109,971 7,089 2b.1.1.23 Instrument Air Non-RCA 17 3

20 20 389 2b.1.1.24 Off Gas 171 9

10 64 33 63 349 349 1,490 352 91,689 3,537 2b.1.1.25 Plant Service Water - RCA 176 5

8 130 65 384 384 3,043 123,583 3,532 2b.1.1.26 Plant Service Water Non-RCA 156 23 180 180 3,494 2b.1.1.27 Process Radiation Monitoring 93 4

3 11 13 29 154 154 253 142 23,024 1,902 2b.1.1.28 Reactor Recirculation 20 47 4

4 6

21 29 130 130 140 223 25,667 1,390 2b.1.1.29 Reactor Water Clean-up 230 286 20 21 48 101 224 931 931 1,133 1,086 141,994 8,682 2b.1.1.30 Residual Heat Removal 462 538 87 89 278 402 530 2,386 2,386 6,526 4,271 648,075 14,073 2b.1.1.31 Screen Wash 6

1 7

7 132 2b.1.1.32 Service Air - RCA 230 4

6 106 75 421 421 2,476 100,556 4,507 2b.1.1.33 Service Air Non-RCA 14 2

16 16 309 2b.1.1.34 Shutdown Service Water - RCA 92 2

4 63 33 195 195 1,481 60,155 1,829 2b.1.1.35 Shutdown Service Water Non-RCA 99 15 114 114 2,196 2b.1.1.36 Solid Radwaste Reprocessing & Disposal 435 566 33 33 157 132 424 1,781 1,781 3,684 1,568 275,491 19,866 2b.1.1.37 Standby Gas Treatment 67 2

2 22 4

21 118 118 513 39 24,299 1,386 2b.1.1.38 Suppression Pool Cleanup & Transfer 108 9

9 26 43 44 238 238 615 453 65,567 2,256 2b.1.1.39 Suppression Pool Make-up 49 7

8 32 36 28 160 160 742 383 64,491 1,065 2b.1.1.40 Turb OG RW Cntrl & DG Bldg Equip Drains 203 11 10 18 48 68 357 357 425 512 62,620 4,124 2b.1.1.41 Turb OG RW Cntrl & DG Bldg Floor Drains 329 20 19 91 75 119 652 652 2,128 890 157,436 6,825 2b.1.1 Totals 1,146 16,704 558 662 6,279 1,605 6,000 32,955 30,104 2,850 147,259 17,958 7,509,222 358,963 2b.1.2 Scaffolding in support of decommissioning 3,829 62 14 175 22 997 5,100 5,100 3,711 231 187,718 88,424 Decontamination of Site Buildings 2b.1.3.1 Reactor Building 2,786 3,509 412 464 330 1,843 2,891 12,236 12,236 7,734 24,635 2,570,182 127,462 2b.1.3.2 Auxiliary Building 324 192 29 38 50 87 248 968 968 1,171 1,733 217,879 10,187 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 8 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 Decontamination of Site Buildings (continued) 2b.1.3.3 Control Building 374 145 29 38 2

91 255 935 935 56 1,825 184,549 10,262 2b.1.3.4 Diesel Generator Building 108 38 8

10 25 72 263 263 500 49,962 2,911 2b.1.3.5 Radwaste Building 1,269 575 105 140 45 330 899 3,364 3,364 1,067 6,612 701,151 36,363 2b.1.3.6 Turbine Building 1,135 605 97 129 117 298 840 3,221 3,221 2,735 5,944 699,469 34,324 2b.1.3 Totals 5,997 5,064 681 820 544 2,674 5,206 20,986 20,986 12,763 41,249 4,423,191 221,509 2b.1 Subtotal Period 2b Activity Costs 7,144 25,597 1,301 1,496 6,999 4,301 12,203 59,040 56,190 2,850 163,733 59,438 12,120,130 668,896 Period 2b Collateral Costs 2b.3.1 Process liquid waste 231 190 1,072 501 421 2,415 2,415 3,628 323,419 707 2b.3.2 Small tool allowance 493 74 567 567 2b.3.3 Spent Fuel Capital and Transfer 22,000 3,300 25,300 25,300 2b.3 Subtotal Period 2b Collateral Costs 231 493 190 1,072 501 22,000 3,795 28,282 2,982 25,300 3,628 323,419 707 Period 2b Period-Dependent Costs 2b.4.1 Decon supplies 2,012 503 2,515 2,515 2b.4.2 Insurance 1,122 112 1,234 1,234 2b.4.3 Property taxes 2,212 221 2,433 2,433 2b.4.4 Health physics supplies 3,182 795 3,977 3,977 2b.4.5 Heavy equipment rental 3,742 561 4,304 4,304 2b.4.6 Disposal of DAW generated 255 105 670 209 1,240 1,240 12,008 240,639 366 2b.4.7 Plant energy budget 1,600 240 1,840 1,840 2b.4.8 NRC Fees 761 76 838 838 2b.4.9 Emergency Planning Fees 442 44 487 487 2b.4.10 Site O&M Cost 553 83 636 636 2b.4.11 Spent Fuel Pool O&M 1,634 245 1,879 1,879 2b.4.12 Radwaste Processing Equipment/Services 411 62 473 473 2b.4.13 ISFSI Operating Costs 182 27 209 209 2b.4.14 Security Staff Cost 11,044 1,657 12,701 12,701 292,034 2b.4.15 DOC Staff Cost 21,946 3,292 25,238 25,238 337,051 2b.4.16 Utility Staff Cost 39,471 5,921 45,391 45,391 625,623 2b.4 Subtotal Period 2b Period-Dependent Costs 2,012 6,924 255 105 670 81,379 14,049 105,394 102,820 2,574 12,008 240,639 366 1,254,709 2b.0 TOTAL PERIOD 2b COST 9,387 33,014 1,747 2,673 6,999 5,472 103,379 30,046 192,717 161,992 27,874 2,850 163,733 75,074 12,684,190 669,970 1,254,709 PERIOD 2c - Decontamination Following Wet Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 Remove spent fuel racks 500 45 92 104 572 429 1,740 1,740 6,066 544,292 1,017 Disposal of Plant Systems 2c.1.2.1 Electrical - Contaminated 1,014 16 23 335 20 314 1,722 1,722 7,867 209 338,266 21,336 2c.1.2.2 Fire Protection - RCA 616 15 23 385 217 1,255 1,255 9,018 366,214 12,406 2c.1.2.3 Fuel Handling & Transfer 24 2

2 7

9 10 55 55 173 99 15,919 521 2c.1.2.4 Fuel Pool Cooling & Cleanup 874 92 92 277 417 387 2,139 2,139 6,503 4,489 660,961 18,344 2c.1.2.5 Fuel Support 99 10 12 47 52 48 268 268 1,100 556 94,533 2,141 2c.1.2.6 HVAC - Containment Building 734 33 45 477 93 288 1,669 1,669 11,185 985 542,563 14,540 2c.1.2.7 Potable Water 11 2

12 12 231 2c.1.2.8 Process Sampling 459 19 14 32 68 141 733 733 758 722 95,460 9,361 2c.1.2 Totals 3,830 187 212 1,561 659 1,406 7,854 7,842 12 36,603 7,060 2,113,916 78,881 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 9 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 Decontamination of Site Buildings 2c.1.3.1 Fuel Building 821 785 33 43 110 94 656 2,542 2,542 2,574 1,829 284,744 32,703 2c.1.3 Totals 821 785 33 43 110 94 656 2,542 2,542 2,574 1,829 284,744 32,703 2c.1.4 Scaffolding in support of decommissioning 766 12 3

35 4

199 1,020 1,020 742 46 37,544 17,685 2c.1 Subtotal Period 2c Activity Costs 1,321 5,425 324 361 1,706 1,328 2,690 13,156 13,143 12 39,919 15,001 2,980,496 130,286 Period 2c Collateral Costs 2c.3.1 Process liquid waste 121 44 240 77 120 603 603 833 49,965 162 2c.3.2 Small tool allowance 103 16 119 119 2c.3.3 Decommissioning Equipment Disposition 100 27 284 35 65 511 511 6,000 373 303,507 88 2c.3 Subtotal Period 2c Collateral Costs 121 103 144 267 284 113 201 1,233 1,233 6,000 1,206 353,472 251 Period 2c Period-Dependent Costs 2c.4.1 Decon supplies 223 56 278 278 2c.4.2 Insurance 429 43 472 472 2c.4.3 Property taxes 846 85 931 931 2c.4.4 Health physics supplies 747 187 934 934 2c.4.5 Heavy equipment rental 1,431 215 1,646 1,646 2c.4.6 Disposal of DAW generated 101 42 266 83 492 492 4,767 95,523 145 2c.4.7 Plant energy budget 326 49 375 375 2c.4.8 NRC Fees 291 29 320 320 2c.4.9 Emergency Planning Fees 169 17 186 186 2c.4.10 Site O&M Cost 211 32 243 243 2c.4.11 Radwaste Processing Equipment/Services 315 47 362 362 2c.4.12 ISFSI Operating Costs 70 10 80 80 2c.4.13 Security Staff Cost 2,220 333 2,553 2,553 58,710 2c.4.14 DOC Staff Cost 5,862 879 6,741 6,741 88,286 2c.4.15 Utility Staff Cost 11,138 1,671 12,809 12,809 172,157 2c.4 Subtotal Period 2c Period-Dependent Costs 223 2,178 101 42 266 21,878 3,735 28,423 28,157 266 4,767 95,523 145 319,153 2c.0 TOTAL PERIOD 2c COST 1,665 7,707 570 670 1,989 1,707 21,878 6,626 42,811 42,533 266 12 45,919 20,974 3,429,491 130,682 319,153 PERIOD 2e - License Termination Period 2e Direct Decommissioning Activities 2e.1.1 ORISE confirmatory survey 141 42 183 183 2e.1.2 Terminate license a

2e.1 Subtotal Period 2e Activity Costs 141 42 183 183 Period 2e Additional Costs 2e.2.1 Final Site Survey 11,020 3,306 14,326 14,326 230,140 2e.2 Subtotal Period 2e Additional Costs 11,020 3,306 14,326 14,326 230,140 Period 2e Collateral Costs 2e.3.1 DOC staff relocation expenses 829 124 953 953 2e.3 Subtotal Period 2e Collateral Costs 829 124 953 953 Period 2e Period-Dependent Costs 2e.4.1 Insurance 350 35 385 385 2e.4.2 Property taxes 745 74 819 819 2e.4.3 Health physics supplies 1,034 258 1,292 1,292 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 10 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 2e Period-Dependent Costs (continued) 2e.4.4 Disposal of DAW generated 8

3 22 7

40 40 389 7,792 12 2e.4.5 Plant energy budget 144 22 165 165 2e.4.6 NRC Fees 256 26 282 282 2e.4.7 Emergency Planning Fees 149 15 164 164 2e.4.8 Site O&M Cost 186 28 214 214 2e.4.9 ISFSI Operating Costs 61 9

70 70 2e.4.10 Security Staff Cost 1,910 287 2,197 2,197 50,514 2e.4.11 DOC Staff Cost 3,905 586 4,490 4,490 56,731 2e.4.12 Utility Staff Cost 5,574 836 6,410 6,410 80,046 2e.4 Subtotal Period 2e Period-Dependent Costs 1,034 8

3 22 13,280 2,182 16,529 16,294 234 389 7,792 12 187,291 2e.0 TOTAL PERIOD 2e COST 1,034 8

3 22 25,269 5,655 31,991 31,756 234 389 7,792 230,152 187,291 PERIOD 2 TOTALS 12,210 76,377 12,997 8,536 22,229 30,644 243,409 84,065 490,468 429,240 56,902 4,326 505,717 187,075 1,435 689 35,944,680 1,535,088 2,810,547 PERIOD 3b - Site Restoration Period 3b Direct Decommissioning Activities Demolition of Remaining Site Buildings 3b.1.1.1 Reactor Building 5,134 770 5,904 5,904 65,001 3b.1.1.2 Auxiliary Building 1,945 292 2,236 2,236 23,242 3b.1.1.3 Circulating Water Screenhouse 3,165 475 3,640 3,640 38,383 3b.1.1.4 Control Building 4,641 696 5,337 5,337 56,578 3b.1.1.5 Diesel Generator Building 1,618 243 1,860 1,860 20,234 3b.1.1.6 Make-Up Water Pump House 344 52 396 396 5,100 3b.1.1.7 Miscellaneous Site Work 1,504 226 1,729 1,729 21,227 3b.1.1.8 Miscellaneous Structures 2,442 366 2,808 2,808 44,561 3b.1.1.9 Radwaste Building 4,502 675 5,177 5,177 58,440 3b.1.1.10 Service Building 353 53 406 406 5,585 3b.1.1.11 Transformer and Tank Pads 147 22 169 169 2,463 3b.1.1.12 Turbine Building 4,693 704 5,397 5,397 63,415 3b.1.1.13 Turbine Pedestal 1,080 162 1,243 1,243 12,474 3b.1.1.14 Fuel Building 2,159 324 2,483 2,483 26,720 3b.1.1 Totals 33,727 5,059 38,786 38,786 443,422 Site Closeout Activities 3b.1.2 BackFill Site 57 9

66 66 201 3b.1.3 Grade & landscape site 1,408 211 1,619 1,619 4,449 3b.1.4 Final report to NRC 141 21 163 163 1,560 3b.1 Subtotal Period 3b Activity Costs 35,192 141 5,300 40,634 163 40,471 448,071 1,560 Period 3b Additional Costs 3b.2.1 Concrete Crushing 1,281 8

193 1,482 1,482 7,355 3b.2.2 Screenhouse Cofferdam 934 140 1,074 1,074 10,159 3b.2.3 Discharge Flume Backfill 3,741 561 4,302 4,302 23,931 3b.2.4 Unit 2 Excavation Backfill 1,226 184 1,410 1,410 13,128 3b.2 Subtotal Period 3b Additional Costs 7,183 8

1,079 8,269 8,269 54,573 Period 3b Collateral Costs 3b.3.1 Small tool allowance 386 58 444 444 3b.3.2 Spent Fuel Capital and Transfer 191 29 220 220 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 11 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3b.3 Subtotal Period 3b Collateral Costs 386 191 87 664 220 444 Period 3b Period-Dependent Costs 3b.4.1 Insurance 1,063 106 1,169 1,169 3b.4.2 Property taxes 2,264 226 2,491 0

2,092 398 3b.4.3 Heavy equipment rental 5,246 787 6,033 6,033 3b.4.4 Plant energy budget 218 33 251 251 3b.4.5 NRC ISFSI Fees 489 49 537 537 3b.4.6 Emergency Planning Fees 453 45 498 498 3b.4.7 ISFSI Operating Costs 186 28 214 214 3b.4.8 Site O&M Cost 566 85 651 651 3b.4.9 Security Staff Cost 5,808 871 6,679 5,544 1,136 153,586 3b.4.10 DOC Staff Cost 11,330 1,699 13,029 13,029 160,674 3b.4.11 Utility Staff Cost 8,584 1,288 9,872 0

2,369 7,503 128,776 3b.4 Subtotal Period 3b Period-Dependent Costs 5,246 30,961 5,218 41,425 0

12,424 29,001 443,036 3b.0 TOTAL PERIOD 3b COST 48,007 31,302 11,683 90,991 163 12,644 78,184 502,644 444,596 PERIOD 3c - Fuel Storage Operations/Shipping Period 3c Direct Decommissioning Activities Period 3c Collateral Costs 3c.3.1 Spent Fuel Capital and Transfer 7,809 1,171 8,980 8,980 3c.3 Subtotal Period 3c Collateral Costs 7,809 1,171 8,980 8,980 Period 3c Period-Dependent Costs 3c.4.1 Insurance 1,342 134 1,476 1,476 3c.4.2 Property taxes 2,398 240 2,637 2,637 3c.4.3 Plant energy budget 3c.4.4 NRC ISFSI Fees 617 62 679 679 3c.4.5 Emergency Planning Fees 572 57 629 629 3c.4.6 Site O&M Cost 715 107 822 822 3c.4.7 ISFSI Operating Costs 235 35 270 270 3c.4.8 Security Staff Cost 6,091 914 7,005 7,005 161,074 3c.4.9 Utility Staff Cost 2,617 393 3,010 3,010 40,269 3c.4 Subtotal Period 3c Period-Dependent Costs 14,586 1,942 16,528 16,528 201,343 3c.0 TOTAL PERIOD 3c COST 22,395 3,113 25,508 25,508 201,343 PERIOD 3d - GTCC shipping Period 3d Direct Decommissioning Activities Nuclear Steam Supply System Removal 3d.1.1.1 Vessel & Internals GTCC Disposal 375 8,152 1,260 9,787 9,787 482 86,500 3d.1.1 Totals 375 8,152 1,260 9,787 9,787 482 86,500 3d.1 Subtotal Period 3d Activity Costs 375 8,152 1,260 9,787 9,787 482 86,500 Period 3d Period-Dependent Costs 3d.4.1 Insurance 21 2

23 23 3d.4.2 Property taxes 3d.4.3 Plant energy budget TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 12 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3d Period-Dependent Costs (continued) 3d.4.4 NRC ISFSI Fees 9

1 10 10 3d.4.5 Emergency Planning Fees 9

1 10 10 3d.4.6 Site O&M Cost 11 2

13 13 3d.4.7 ISFSI Operating Costs 4

1 4

4 3d.4.8 Security Staff Cost 93 14 107 107 2,469 3d.4.9 Utility Staff Cost 40 6

46 46 617 3d.4 Subtotal Period 3d Period-Dependent Costs 187 26 213 213 3,086 3d.0 TOTAL PERIOD 3d COST 375 8,152 187 1,286 10,000 9,787 213 482 86,500 3,086 PERIOD 3e - ISFSI Decontamination Period 3e Direct Decommissioning Activities Period 3e Additional Costs 3e.2.1 ISFSI License Termination 724 3

85 214 1,170 423 2,617 2,617 4,257 510,109 11,226 2,560 3e.2 Subtotal Period 3e Additional Costs 724 3

85 214 1,170 423 2,617 2,617 4,257 510,109 11,226 2,560 Period 3e Collateral Costs 3e.3.1 Small tool allowance 7

1 8

8 3e.3 Subtotal Period 3e Collateral Costs 7

1 8

8 Period 3e Period-Dependent Costs 3e.4.1 Insurance 158 16 174 174 3e.4.2 Property taxes 3e.4.3 Heavy equipment rental 225 34 259 259 3e.4.4 Plant energy budget 3e.4.5 Site O&M Cost 84 13 97 97 3e.4.6 Security Staff Cost 193 29 222 222 5,096 3e.4.7 Utility Staff Cost 258 39 297 297 3,866 3e.4 Subtotal Period 3e Period-Dependent Costs 225 693 130 1,048 1,048 8,961 3e.0 TOTAL PERIOD 3e COST 955 3

85 214 1,862 553 3,672 3,672 4,257 510,109 11,226 11,521 PERIOD 3f - ISFSI Site Restoration Period 3f Direct Decommissioning Activities Period 3f Additional Costs 3f.2.1 ISFSI Site Restoration 1,186 42 184 1,412 1,412 3,120 160 3f.2 Subtotal Period 3f Additional Costs 1,186 42 184 1,412 1,412 3,120 160 Period 3f Collateral Costs 3f.3.1 Small tool allowance 2

0 3

3 3f.3 Subtotal Period 3f Collateral Costs 2

0 3

3 Period 3f Period-Dependent Costs 3f.4.1 Insurance 16 2

17 17 3f.4.2 Property taxes 3f.4.3 Heavy equipment rental 73 11 84 84 3f.4.4 Plant energy budget 3f.4.5 Site O&M Cost 40 6

46 46 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix C, Page 13 of 13 Table C Clinton Power Station DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:01:31 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3f Period-Dependent Costs (continued) 3f.4.6 Security Staff Cost 91 14 104 104 2,403 3f.4.7 Utility Staff Cost 96 14 111 111 1,491 3f.4 Subtotal Period 3f Period-Dependent Costs 73 243 47 363 363 3,894 3f.0 TOTAL PERIOD 3f COST 1,262 285 231 1,777 1,777 3,120 4,054 PERIOD 3 TOTALS 50,224 378 85 8,365 56,030 16,867 131,948 9,949 43,814 78,184 4,257 482 596,609 516,990 664,600 TOTAL COST TO DECOMMISSION 14,660 128,652 13,444 8,914 22,229 41,768 434,071 122,323 786,061 547,591 155,245 83,225 505,717 194,176 2,156 689 482 36,744,250 2,053,353 4,459,077 TOTAL COST TO DECOMMISSION WITH 18.43% CONTINGENCY:

$786,061 thousands of 2007 dollars TOTAL NRC LICENSE TERMINATION COST IS 69.66% OR:

$547,591 thousands of 2007 dollars SPENT FUEL MANAGEMENT COST IS 19.75% OR:

$155,245 thousands of 2007 dollars NON-NUCLEAR DEMOLITION COST IS 10.59% OR:

$83,225 thousands of 2007 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

197,021 cubic feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:

482 cubic feet TOTAL SCRAP METAL REMOVED:

75,356 tons TOTAL CRAFT LABOR REQUIREMENTS:

2,053,353 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, Inc.

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix D, Page 1 of 13 TLG Services, Inc.

APPENDIX D DETAILED COST ANALYSIS DELAYED DECON

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 2 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 SAFSTOR site characterization survey 363 109 471 471 1a.1.2 Prepare preliminary decommissioning cost 118 18 136 136 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 181 27 209 209 2,000 1a.1.8 Review plant dwgs & specs.

118 18 136 136 1,300 1a.1.9 Perform detailed rad survey a

1a.1.10 Estimate by-product inventory 91 14 104 104 1,000 1a.1.11 End product description 91 14 104 104 1,000 1a.1.12 Detailed by-product inventory 136 20 156 156 1,500 1a.1.13 Define major work sequence 91 14 104 104 1,000 1a.1.14 Perform SER and EA 281 42 323 323 3,100 1a.1.15 Perform Site-Specific Cost Study 454 68 522 522 5,000 Activity Specifications 1a.1.16.1 Prepare plant and facilities for SAFSTOR 446 67 513 513 4,920 1a.1.16.2 Plant systems 378 57 435 435 4,167 1a.1.16.3 Plant structures and buildings 283 42 325 325 3,120 1a.1.16.4 Waste management 181 27 209 209 2,000 1a.1.16.5 Facility and site dormancy 181 27 209 209 2,000 1a.1.16 Total 1,470 220 1,690 1,690 16,207 Detailed Work Procedures 1a.1.17.1 Plant systems 107 16 123 123 1,183 1a.1.17.2 Facility closeout & dormancy 109 16 125 125 1,200 1a.1.17 Total 216 32 249 249 2,383 1a.1.18 Procure vacuum drying system 9

1 10 10 100 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 3,618 597 4,215 4,215 35,890 Period 1a Period-Dependent Costs 1a.4.1 Insurance 1,320 132 1,452 1,452 1a.4.2 Property taxes 6,312 631 6,943 6,943 1a.4.3 Health physics supplies 377 94 471 471 1a.4.4 Heavy equipment rental 349 52 401 401 1a.4.5 Disposal of DAW generated 14 6

38 12 70 70 675 13,531 21 1a.4.6 Plant energy budget 964 145 1,108 1,108 1a.4.7 NRC Fees 258 26 284 284 1a.4.8 Emergency Planning Fees 450 45 495 495 1a.4.9 Site O&M Cost 250 37 287 287 1a.4.10 Spent Fuel Pool O&M 738 111 849 849 1a.4.11 Security Staff Cost 5,955 893 6,848 6,848 157,471 1a.4.12 Utility Staff Cost 26,183 3,927 30,110 30,110 423,400 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 3 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 1a.4 Subtotal Period 1a Period-Dependent Costs 726 14 6

38 42,429 6,106 49,319 47,975 1,343 675 13,531 21 580,871 1a.0 TOTAL PERIOD 1a COST 726 14 6

38 46,047 6,703 53,533 52,190 1,343 675 13,531 21 616,761 PERIOD 1b - SAFSTOR Limited DECON Activities Period 1b Direct Decommissioning Activities Decontamination of Site Buildings 1b.1.1.1 Reactor Building 2,771 1,385 4,156 4,156 56,016 1b.1.1.2 Auxiliary Building 305 153 458 458 6,485 1b.1.1.3 Control Building 353 177 530 530 7,503 1b.1.1.4 Diesel Generator Building 103 51 154 154 2,182 1b.1.1.5 Radwaste Building 1,195 597 1,792 1,792 25,369 1b.1.1.6 Turbine Building 1,069 534 1,603 1,603 22,689 1b.1.1.7 Fuel Building 800 400 1,199 1,199 16,275 1b.1.1 Totals 6,595 3,298 9,893 9,893 136,519 1b.1 Subtotal Period 1b Activity Costs 6,595 3,298 9,893 9,893 136,519 Period 1b Additional Costs 1b.2.1 Spent Fuel Pool Isolation 9,133 1,370 10,503 10,503 1b.2 Subtotal Period 1b Additional Costs 9,133 1,370 10,503 10,503 Period 1b Collateral Costs 1b.3.1 Decon equipment 726 109 834 834 1b.3.2 Process liquid waste 179 64 351 113 177 883 883 1,217 73,045 237 1b.3.3 Small tool allowance 103 15 119 119 1b.3 Subtotal Period 1b Collateral Costs 904 103 64 351 113 301 1,836 1,836 1,217 73,045 237 Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 2,110 528 2,638 2,638 1b.4.2 Insurance 333 33 366 366 1b.4.3 Property taxes 1,061 106 1,167 1,167 1b.4.4 Health physics supplies 573 143 716 716 1b.4.5 Heavy equipment rental 88 13 101 101 1b.4.6 Disposal of DAW generated 32 13 85 26 157 157 1,524 30,535 46 1b.4.7 Plant energy budget 243 36 279 279 1b.4.8 NRC Fees 65 7

72 72 1b.4.9 Emergency Planning Fees 113 11 125 125 1b.4.10 Site O&M Cost 63 9

72 72 1b.4.11 Spent Fuel Pool O&M 186 28 214 214 1b.4.12 Security Staff Cost 1,501 225 1,726 1,726 39,691 1b.4.13 Utility Staff Cost 6,599 990 7,589 7,589 106,720 1b.4 Subtotal Period 1b Period-Dependent Costs 2,110 661 32 13 85 10,164 2,157 15,223 14,884 339 1,524 30,535 46 146,411 1b.0 TOTAL PERIOD 1b COST 9,610 764 96 364 198 19,298 7,125 37,455 37,116 339 2,741 103,580 136,803 146,411 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 4 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 405 61 466 466 3,000 1c.1.2 Install containment pressure equal. lines 35 5

41 41 700 1c.1.3 Interim survey prior to dormancy 733 220 953 953 14,893 1c.1.4 Secure building accesses a

1c.1.5 Prepare & submit interim report 53 8

61 61 583 1c.1 Subtotal Period 1c Activity Costs 440 786 294 1,520 1,520 18,593 583 Period 1c Collateral Costs 1c.3.1 Process liquid waste 133 47 260 84 131 655 655 904 54,218 176 1c.3.2 Small tool allowance 3

0 4

4 1c.3 Subtotal Period 1c Collateral Costs 133 3

47 260 84 132 659 659 904 54,218 176 Period 1c Period-Dependent Costs 1c.4.1 Insurance 329 33 362 362 1c.4.2 Property taxes 1,049 105 1,154 1,154 1c.4.3 Health physics supplies 160 40 199 199 1c.4.4 Heavy equipment rental 87 13 100 100 1c.4.5 Disposal of DAW generated 4

1 9

3 17 17 168 3,374 5

1c.4.6 Plant energy budget 240 36 276 276 1c.4.7 NRC Fees 64 6

71 71 1c.4.8 Emergency Planning Fees 112 11 123 123 1c.4.9 Site O&M Cost 62 9

72 72 1c.4.10 Spent Fuel Pool O&M 184 28 212 212 1c.4.11 Security Staff Cost 1,485 223 1,707 1,707 39,260 1c.4.12 Utility Staff Cost 6,528 979 7,507 7,507 105,560 1c.4 Subtotal Period 1c Period-Dependent Costs 247 4

1 9

10,054 1,486 11,801 11,466 335 168 3,374 5

144,820 1c.0 TOTAL PERIOD 1c COST 133 690 51 262 93 10,839 1,912 13,980 13,645 335 1,072 57,592 18,774 145,403 PERIOD 1 TOTALS 9,743 2,180 162 632 329 76,184 15,740 104,968 102,952 2,017 4,488 174,703 155,598 908,576 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 1,345 202 1,547 1,547 2a.1.5 Maintenance supplies 1,353 338 1,691 1,691 2a.1 Subtotal Period 2a Activity Costs 2,698 540 3,237 3,237 Period 2a Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 16,000 2,400 18,400 18,400 2a.3 Subtotal Period 2a Collateral Costs 16,000 2,400 18,400 18,400 Period 2a Period-Dependent Costs 2a.4.1 Insurance 5,455 546 6,001 6,001 2a.4.2 Property taxes 12,360 1,236 13,596 13,596 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 5 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 2a Period-Dependent Costs (continued) 2a.4.3 Health physics supplies 926 231 1,157 1,157 2a.4.4 Disposal of DAW generated 104 43 272 85 504 504 4,883 97,849 149 2a.4.5 Plant energy budget 2,074 311 2,385 2,385 2a.4.6 NRC Fees 2,321 232 2,553 2,553 2a.4.7 Emergency Planning Fees 2,151 215 2,366 2,366 2a.4.8 Site O&M Cost 2,689 403 3,092 3,092 2a.4.9 Spent Fuel Pool O&M 7,941 1,191 9,132 9,132 2a.4.10 Security Staff Cost 45,200 6,780 51,981 51,981 1,195,234 2a.4.11 Utility Staff Cost 56,198 8,430 64,628 64,628 830,491 2a.4 Subtotal Period 2a Period-Dependent Costs 926 104 43 272 136,388 19,660 157,393 157,393 4,883 97,849 149 2,025,726 2a.0 TOTAL PERIOD 2a COST 926 104 43 272 155,086 22,600 179,031 179,031 4,883 97,849 149 2,025,726 PERIOD 2 TOTALS 926 104 43 272 155,086 22,600 179,031 179,031 4,883 97,849 149 2,025,726 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 3a.1.1 Prepare preliminary decommissioning cost 118 18 136 136 1,300 3a.1.2 Review plant dwgs & specs.

417 63 480 480 4,600 3a.1.3 Perform detailed rad survey a

3a.1.4 End product description 91 14 104 104 1,000 3a.1.5 Detailed by-product inventory 118 18 136 136 1,300 3a.1.6 Define major work sequence 680 102 782 782 7,500 3a.1.7 Perform SER and EA 281 42 323 323 3,100 3a.1.8 Perform Site-Specific Cost Study 454 68 522 522 5,000 3a.1.9 Prepare/submit License Termination Plan 372 56 427 427 4,096 3a.1.10 Receive NRC approval of termination plan a

Activity Specifications 3a.1.11.1 Re-activate plant & temporary facilities 668 100 769 692 77 7,370 3a.1.11.2 Plant systems 378 57 435 391 43 4,167 3a.1.11.3 Reactor internals 644 97 741 741 7,100 3a.1.11.4 Reactor vessel 590 88 678 678 6,500 3a.1.11.5 Sacrificial shield 45 7

52 52 500 3a.1.11.6 Moisture separators/reheaters 91 14 104 104 1,000 3a.1.11.7 Reinforced concrete 145 22 167 83 83 1,600 3a.1.11.8 Main Turbine 189 28 218 218 2,088 3a.1.11.9 Main Condensers 189 28 218 218 2,088 3a.1.11.10 Pressure suppression structure 181 27 209 209 2,000 3a.1.11.11 Drywell 145 22 167 167 1,600 3a.1.11.12 Plant structures & buildings 283 42 325 163 163 3,120 3a.1.11.13 Waste management 417 63 480 480 4,600 3a.1.11.14 Facility & site closeout 82 12 94 47 47 900 3a.1.11 Total 4,048 607 4,655 4,242 413 44,633 Planning & Site Preparations 3a.1.12 Prepare dismantling sequence 218 33 250 250 2,400 3a.1.13 Plant prep. & temp. svces 2,419 363 2,782 2,782 3a.1.14 Design water clean-up system 127 19 146 146 1,400 3a.1.15 Rigging/Cont. Cntrl Envlps/tooling/etc.

2,048 307 2,355 2,355 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 6 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3a.1.16 Procure casks/liners & containers 112 17 128 128 1,230 3a.1 Subtotal Period 3a Activity Costs 11,501 1,725 13,227 12,813 413 77,559 Period 3a Period-Dependent Costs 3a.4.1 Insurance 458 46 504 504 3a.4.2 Property taxes 999 100 1,099 1,099 3a.4.3 Health physics supplies 330 82 412 412 3a.4.4 Heavy equipment rental 349 52 401 401 3a.4.5 Disposal of DAW generated 12 5

32 10 59 59 570 11,419 17 3a.4.6 Plant energy budget 964 145 1,108 1,108 3a.4.7 NRC Fees 258 26 284 284 3a.4.8 Site O&M Cost 250 37 287 287 3a.4.9 Security Staff Cost 2,465 370 2,835 2,835 65,179 3a.4.10 Utility Staff Cost 16,145 2,422 18,566 18,566 258,629 3a.4 Subtotal Period 3a Period-Dependent Costs 678 12 5

32 21,539 3,290 25,556 25,556 570 11,419 17 323,807 3a.0 TOTAL PERIOD 3a COST 678 12 5

32 33,040 5,015 38,782 38,369 413 570 11,419 17 401,366 PERIOD 3b - Decommissioning Preparations Period 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems 429 64 494 444 49 4,733 3b.1.1.2 Reactor internals 363 54 417 417 4,000 3b.1.1.3 Remaining buildings 122 18 141 35 106 1,350 3b.1.1.4 CRD housings & NIs 91 14 104 104 1,000 3b.1.1.5 Incore instrumentation 91 14 104 104 1,000 3b.1.1.6 Removal primary containment 181 27 209 209 2,000 3b.1.1.7 Reactor vessel 329 49 379 379 3,630 3b.1.1.8 Facility closeout 109 16 125 63 63 1,200 3b.1.1.9 Sacrificial shield 109 16 125 125 1,200 3b.1.1.10 Reinforced concrete 91 14 104 52 52 1,000 3b.1.1.11 Main Turbine 189 28 217 217 2,080 3b.1.1.12 Main Condensers 189 28 218 218 2,088 3b.1.1.13 Moisture separators & reheaters 181 27 209 209 2,000 3b.1.1.14 Radwaste building 248 37 285 256 28 2,730 3b.1.1.15 Reactor building 248 37 285 256 28 2,730 3b.1.1 Total 2,970 445 3,415 3,088 327 32,741 3b.1 Subtotal Period 3b Activity Costs 2,970 445 3,415 3,088 327 32,741 Period 3b Additional Costs 3b.2.1 Site Characterization 897 269 1,167 1,167 3b.2.2 Hazardous liquid disposal 7

411 104 523 523 1,571 89,546 3b.2.3 Contaminated asbestos disposal 8

5 2

15 15 60 1,800 3b.2.4 Clean asbestos disposal 2

0 2

2 3b.2 Subtotal Period 3b Additional Costs 15 416 900 376 1,707 1,707 1,631 91,346 Period 3b Collateral Costs 3b.3.1 Decon equipment 726 109 834 834 3b.3.2 DOC staff relocation expenses 829 124 953 953 3b.3.3 Pipe cutting equipment 957 143 1,100 1,100 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 7 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3b.3 Subtotal Period 3b Collateral Costs 726 957 829 377 2,887 2,887 Period 3b Period-Dependent Costs 3b.4.1 Decon supplies 22 6

28 28 3b.4.2 Insurance 254 25 280 280 3b.4.3 Property taxes 501 50 551 551 3b.4.4 Health physics supplies 182 46 228 228 3b.4.5 Heavy equipment rental 175 26 201 201 3b.4.6 Disposal of DAW generated 7

3 18 6

33 33 323 6,476 10 3b.4.7 Plant energy budget 483 72 556 556 3b.4.8 NRC Fees 130 13 143 143 3b.4.9 Site O&M Cost 125 19 144 144 3b.4.10 Security Staff Cost 1,236 185 1,421 1,421 32,679 3b.4.11 DOC Staff Cost 3,799 570 4,369 4,369 58,560 3b.4.12 Utility Staff Cost 8,094 1,214 9,309 9,309 129,669 3b.4 Subtotal Period 3b Period-Dependent Costs 22 357 7

3 18 14,622 2,232 17,261 17,261 323 6,476 10 220,907 3b.0 TOTAL PERIOD 3b COST 748 1,314 7

18 434 19,320 3,430 25,271 24,944 327 1,954 97,822 10 253,648 PERIOD 3 TOTALS 748 1,992 19 23 466 52,360 8,445 64,053 63,313 740 2,524 109,241 27 655,014 PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.1.1 Recirculation System Piping & Valves 10 40 8

9 99 42 209 209 530 64,091 1,078 4a.1.1.2 Recirculation Pumps & Motors 10 38 13 29 18 263 89 460 460 250 2,473 187,000 1,145 4a.1.1.3 CRDMs & NIs Removal 42 158 321 82 203 156 962 962 6,985 131,119 4,212 4a.1.1.4 Reactor Vessel Internals 112 2,300 3,613 973 5,407 213 5,663 18,281 18,281 1,753 1,502 287 342,025 28,950 1,290 4a.1.1.5 Vessel & Internals GTCC Disposal 8,152 1,223 9,374 9,374 482 86,500 4a.1.1.6 Reactor Vessel 5,325 1,351 375 2,056 213 5,485 14,805 14,805 13,057 1,326,615 28,950 1,290 4a.1.1 Totals 175 7,861 5,307 1,468 18 16,180 425 12,657 44,091 44,091 250 24,798 1,502 287 482 2,137,350 64,336 2,580 Removal of Major Equipment 4a.1.2 Main Turbine/Generator 307 885 180 2,586 152 618 4,729 4,729 54,728 1,613 2,607,544 6,446 4a.1.3 Main Condensers 1,051 952 194 2,781 163 845 5,985 5,985 58,848 1,735 2,803,815 22,050 Cascading Costs from Clean Building Demolition 4a.1.4.1 Reactor Building 905 136 1,041 1,041 11,450 4a.1.4.2 Auxiliary Building 216 32 248 248 2,582 4a.1.4.3 Radwaste Building 500 75 575 575 6,493 4a.1.4.4 Turbine Building 508 76 585 585 6,771 4a.1.4.5 Fuel Building 237 36 273 273 2,912 4a.1.4 Totals 2,367 355 2,722 2,722 30,209 Disposal of Plant Systems 4a.1.5.1 Acid Feed & Handling 26 1

1 21 10 59 59 488 19,822 533 4a.1.5.2 Auxiliary Steam 484 13 19 319 173 1,008 1,008 7,493 304,278 9,740 4a.1.5.3 Breathing Air 36 5

42 42 820 4a.1.5.4 CO2 & Generator Purge 16 2

18 18 349 4a.1.5.5 Caustic Handling 13 0

0 8

5 26 26 183 7,431 256 4a.1.5.6 Chem Radwaste Reprocessing & Disposal 351 39 36 94 168 153 841 841 2,211 2,121 249,902 7,339 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 8 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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.1.5.7 Chilled Water - RCA 1,035 27 40 679 369 2,149 2,149 15,914 646,286 20,760 4a.1.5.8 Chilled Water Non-RCA 166 25 191 191 3,682 4a.1.5.9 Chlorination 44 7

51 51 953 4a.1.5.10 Circulating Water - RCA 161 16 24 400 105 706 706 9,379 380,877 3,419 4a.1.5.11 Circulating Water Non-RCA 51 8

58 58 1,090 4a.1.5.12 Cntnmnt Aux & Fuel Bldg Equip Drains 81 5

5 8

24 28 150 150 187 253 30,046 1,627 4a.1.5.13 Cntnmnt Aux & Fuel Bldg Floor Drains 139 8

8 34 32 50 271 271 792 367 62,936 2,852 4a.1.5.14 Component Cooling Water Non-RCA 119 18 137 137 2,622 4a.1.5.15 Condensate 810 159 174 584 772 525 3,024 3,024 13,689 8,197 1,291,159 17,379 4a.1.5.16 Condensate Booster 766 161 178 543 806 517 2,971 2,971 12,724 8,568 1,284,382 16,493 4a.1.5.17 Condensate Polishing 619 46 45 188 188 241 1,327 1,327 4,398 2,104 357,430 12,843 4a.1.5.18 Condenser Vacuum 179 17 25 430 115 767 767 10,094 409,927 3,731 4a.1.5.19 Containment Combustible Gas 67 4

4 33 14 26 149 149 781 147 44,863 1,396 4a.1.5.20 Cycled Condensate 555 41 40 181 163 217 1,197 1,197 4,242 1,929 327,937 11,485 4a.1.5.21 Drywell Cooling 437 20 25 242 62 167 952 952 5,664 655 288,770 8,570 4a.1.5.22 Drywell Purge 124 11 15 118 42 63 373 373 2,764 451 152,687 2,624 4a.1.5.23 ECCS Equipment Cooling 65 2

4 51 3

25 150 150 1,190 32 51,154 1,312 4a.1.5.24 Extraction Steam 424 54 63 236 271 224 1,272 1,272 5,531 2,875 482,498 9,036 4a.1.5.25 Feedwater 464 88 100 331 445 301 1,730 1,730 7,772 4,722 739,273 9,995 4a.1.5.26 Feedwater Heater Drains Turbine Cycle 1,109 112 126 507 527 515 2,897 2,897 11,899 5,704 985,459 23,395 4a.1.5.27 Feedwater Heater Misc.

172 13 13 29 62 66 357 357 685 664 87,316 3,553 4a.1.5.28 Filtered Water 4

1 4

4 86 4a.1.5.29 Generator Hydrogen Seal Oil 25 0

1 10 8

44 44 243 9,883 469 4a.1.5.30 Generator Stator Cooling 16 0

1 9

6 32 32 207 8,423 339 4a.1.5.31 High Pressure Core Spray 225 36 39 131 170 128 728 728 3,077 1,807 287,030 4,792 4a.1.5.32 Hydrogen 22 0

0 7

7 36 36 168 6,815 403 4a.1.5.33 Laundry Equip & Flr Drains RW Reprocess 189 14 14 90 49 77 433 433 2,116 646 132,817 3,941 4a.1.5.34 Leak Detection 37 1

1 1

3 10 53 53 30 29 3,822 837 4a.1.5.35 Local Instrument Panels 5

1 6

6 116 4a.1.5.36 Low Pressure Core Spray 86 21 21 65 97 61 352 352 1,535 1,028 154,545 1,855 4a.1.5.37 Machine Shop Equipment 10 0

1 10 4

25 25 225 9,119 216 4a.1.5.38 Machine Shop Ventilation 201 5

8 114 7

71 405 405 2,665 71 114,605 3,671 4a.1.5.39 Main Steam 746 74 80 298 347 337 1,882 1,882 6,987 3,685 614,246 15,676 4a.1.5.40 Main Steam Isolation Valve 19 1

1 1

4 6

33 33 23 47 5,157 381 4a.1.5.41 Make-up Demineralizer - RCA 184 4

6 103 63 360 360 2,419 98,255 3,595 4a.1.5.42 Make-up Demineralizer Non-RCA 208 31 239 239 4,416 4a.1.5.43 Makeup Condensate Storage 216 15 14 22 67 78 412 412 518 715 85,161 4,359 4a.1.5.44 Misc. Building Drains 16 2

19 19 357 4a.1.5.45 Miscellaneous Ventilation 30 4

34 34 643 4a.1.5.46 Nuclear Boiler 15 1

1 1

3 5

24 24 17 30 3,359 324 4a.1.5.47 Oil Transfer 90 4

6 104 39 243 243 2,429 98,662 1,834 4a.1.5.48 Reactor Core Isolation Cooling 194 15 15 77 57 78 436 436 1,796 698 127,607 4,075 4a.1.5.49 Refrigeration Piping 17 3

20 20 388 4a.1.5.50 Sanitary 151 23 174 174 3,202 4a.1.5.51 Screen House & MU Pump House Ventilation 31 5

36 36 736 4a.1.5.52 Standby Liquid Control 26 1

1 18 9

55 55 413 16,763 529 4a.1.5.53 Switchgear Heat Removal 16 2

19 19 356 4a.1.5.54 Turbine Building Closed Cooling Water 148 4

5 90 52 299 299 2,106 85,531 2,948 4a.1.5.55 Turbine Electrohydraulic Control 9

0 0

4 3

16 16 84 3,405 185 4a.1.5.56 Turbine Gen Misc Drains & Vents 45 2

2 6

9 15 80 80 136 96 14,138 900 4a.1.5.57 Turbine Gland Seal Steam 300 40 50 453 130 187 1,161 1,161 10,629 1,384 555,788 6,310 4a.1.5.58 Turbine Oil 48 4

5 37 18 23 137 137 866 199 52,601 1,021 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 9 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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.1.5.59 Turbine-Gen Aux & Misc Devices 214 51 62 289 250 174 1,041 1,041 6,779 2,656 513,573 4,683 4a.1.5 Totals 12,060 1,131 1,280 6,974 4,792 5,473 31,710 30,662 1,048 163,551 51,880 11,205,730 251,495 4a.1.6 Scaffolding in support of decommissioning 2,745 50 11 140 17 718 3,682 3,682 2,969 185 150,174 63,258 4a.1 Subtotal Period 4a Activity Costs 175 26,391 8,324 3,134 12,499 21,305 425 20,667 92,919 91,871 1,048 280,345 80,211 1,502 287 482 18,904,620 437,793 2,580 Period 4a Additional Costs 4a.2.1 Disposal of stored turbine rotors 17 100 40 743 130 1,030 1,030 15,719 707,358 352 4a.2 Subtotal Period 4a Additional Costs 17 100 40 743 130 1,030 1,030 15,719 707,358 352 Period 4a Collateral Costs 4a.3.1 Process liquid waste 55 20 111 36 55 278 278 386 23,185 75 4a.3.2 Small tool allowance 325 49 373 336 37 4a.3 Subtotal Period 4a Collateral Costs 55 325 20 111 36 104 652 614 37 386 23,185 75 Period 4a Period-Dependent Costs 4a.4.1 Decon supplies 60 15 75 75 4a.4.2 Insurance 690 69 759 759 4a.4.3 Property taxes 1,361 136 1,497 1,347 150 4a.4.4 Health physics supplies 2,037 509 2,547 2,547 4a.4.5 Heavy equipment rental 2,320 348 2,668 2,668 4a.4.6 Disposal of DAW generated 177 73 464 145 859 859 8,323 166,794 254 4a.4.7 Plant energy budget 1,246 187 1,433 1,433 4a.4.8 NRC Fees 468 47 515 515 4a.4.9 Site O&M Cost 340 51 391 391 4a.4.10 Radwaste Processing Equipment/Services 506 76 582 582 4a.4.11 Security Staff Cost 3,356 503 3,860 3,860 88,750 4a.4.12 DOC Staff Cost 12,669 1,900 14,569 14,569 195,960 4a.4.13 Utility Staff Cost 22,201 3,330 25,531 25,531 355,000 4a.4 Subtotal Period 4a Period-Dependent Costs 60 4,357 177 73 464 42,838 7,317 55,286 55,137 150 8,323 166,794 254 639,710 4a.0 TOTAL PERIOD 4a COST 291 31,090 8,621 3,357 13,241 21,805 43,263 28,218 149,887 148,652 1,235 296,064 88,920 1,502 287 482 19,801,950 438,475 642,290 PERIOD 4b - Site Decontamination Period 4b Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks 452 45 92 104 572 405 1,668 1,668 6,066 544,292 1,017 Disposal of Plant Systems 4b.1.2.1 Component Cooling Water - RCA 178 4

6 101 61 350 350 2,361 95,865 3,548 4b.1.2.2 Containment Monitoring 50 1

1 4

4 15 76 76 98 44 7,962 1,115 4b.1.2.3 Control Rod Drive 357 19 19 57 88 124 664 664 1,333 930 137,526 7,399 4b.1.2.4 Diesel Fuel Oil 59 9

68 68 1,256 4b.1.2.5 Diesel General 52 8

60 60 1,133 4b.1.2.6 Diesel-Generator Room Ventilation 77 12 88 88 1,817 4b.1.2.7 Drains-Laundry to Radwaste 15 1

1 1

4 5

27 27 34 39 4,837 302 4b.1.2.8 Electrical - Clean Non-RCA 1,545 232 1,777 1,777 33,545 4b.1.2.9 Electrical - Clean RCA 6,131 125 188 3,190 2,052 11,687 11,687 74,814 3,038,244 126,548 4b.1.2.10 Electrical - Contaminated 909 16 23 335 20 288 1,591 1,591 7,867 209 338,266 19,043 4b.1.2.11 Equip Drain Radwaste Reprocessing 1,018 69 67 307 271 385 2,118 2,118 7,207 3,254 551,230 21,073 4b.1.2.12 Fire Protection - RCA 616 15 23 385 217 1,255 1,255 9,018 366,214 12,406 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 10 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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) 4b.1.2.13 Fire Protection Non-RCA 154 23 177 177 3,416 4b.1.2.14 Floor Drain Radwaste Reprocessing 634 54 55 235 227 264 1,468 1,468 5,507 2,655 439,585 13,131 4b.1.2.15 Fuel Handling & Transfer 22 2

2 7

9 9

52 52 173 99 15,919 465 4b.1.2.16 Fuel Pool Cooling & Cleanup 783 92 92 277 417 365 2,026 2,026 6,503 4,489 660,961 16,306 4b.1.2.17 Fuel Support 88 10 12 47 52 45 255 255 1,100 556 94,533 1,906 4b.1.2.18 HVAC - Auxiliary Building 28 1

2 23 3

12 69 69 540 36 25,200 593 4b.1.2.19 HVAC - Containment Building 661 33 45 477 93 270 1,579 1,579 11,185 985 542,563 12,668 4b.1.2.20 HVAC - Control Room 242 36 279 279 5,686 4b.1.2.21 HVAC - Fuel Building 283 8

11 161 10 100 574 574 3,782 107 163,158 5,156 4b.1.2.22 HVAC - Laboratory 456 13 18 257 17 161 921 921 6,035 181 261,272 8,390 4b.1.2.23 HVAC - Off Gas Building 115 6

7 64 18 45 255 255 1,499 192 78,082 2,299 4b.1.2.24 HVAC - Radwaste Building 644 21 30 395 37 236 1,363 1,363 9,269 389 411,319 11,921 4b.1.2.25 HVAC - Service Building 52 8

60 60 1,145 4b.1.2.26 HVAC - Turbine Building 532 15 22 316 20 190 1,097 1,097 7,421 211 320,323 9,709 4b.1.2.27 Hoists Cranes & Elevators 6

1 7

7 123 4b.1.2.28 Instrument Air - RCA 374 5

7 115 112 613 613 2,708 109,971 7,089 4b.1.2.29 Instrument Air Non-RCA 17 3

20 20 389 4b.1.2.30 Off Gas 154 9

10 64 33 59 328 328 1,490 352 91,689 3,152 4b.1.2.31 Plant Service Water - RCA 176 5

8 130 65 384 384 3,043 123,583 3,532 4b.1.2.32 Plant Service Water Non-RCA 156 23 180 180 3,494 4b.1.2.33 Potable Water 11 2

12 12 231 4b.1.2.34 Process Radiation Monitoring 84 4

3 11 13 27 142 142 253 142 23,024 1,694 4b.1.2.35 Process Sampling 414 19 14 32 68 129 678 678 758 722 95,460 8,370 4b.1.2.36 Reactor Recirculation 42 4

4 6

21 18 95 95 140 223 25,667 876 4b.1.2.37 Reactor Water Clean-up 257 20 21 48 101 102 549 549 1,133 1,086 141,994 5,295 4b.1.2.38 Residual Heat Removal 481 87 89 278 402 285 1,623 1,623 6,526 4,271 648,075 10,242 4b.1.2.39 Screen Wash 6

1 7

7 132 4b.1.2.40 Service Air - RCA 230 4

6 106 75 421 421 2,476 100,556 4,507 4b.1.2.41 Service Air Non-RCA 14 2

16 16 309 4b.1.2.42 Shutdown Service Water - RCA 92 2

4 63 33 195 195 1,481 60,155 1,829 4b.1.2.43 Shutdown Service Water Non-RCA 99 15 114 114 2,196 4b.1.2.44 Solid Radwaste Reprocessing & Disposal 509 33 33 157 132 192 1,057 1,057 3,684 1,568 275,491 10,528 4b.1.2.45 Standby Gas Treatment 60 2

2 22 4

20 109 109 513 39 24,299 1,226 4b.1.2.46 Suppression Pool Cleanup & Transfer 96 9

9 26 43 41 224 224 615 453 65,567 2,006 4b.1.2.47 Suppression Pool Make-up 44 7

8 32 36 27 154 154 742 383 64,491 947 4b.1.2.48 Turb OG RW Cntrl & DG Bldg Equip Drains 181 11 10 18 48 63 330 330 425 512 62,620 3,649 4b.1.2.49 Turb OG RW Cntrl & DG Bldg Floor Drains 295 20 19 91 75 111 610 610 2,128 890 157,436 6,080 4b.1.2 Totals 19,502 746 873 7,840 2,264 6,574 37,799 34,936 2,862 183,862 25,018 9,623,137 399,872 4b.1.3 Scaffolding in support of decommissioning 4,118 74 17 210 26 1,078 5,523 5,523 4,453 277 225,261 94,887 Decontamination of Site Buildings 4b.1.4.1 Reactor Building 2,504 3,131 412 464 330 1,843 2,656 11,341 11,341 7,734 24,635 2,570,182 113,912 4b.1.4.2 Auxiliary Building 293 171 29 38 50 87 227 895 895 1,171 1,733 217,879 9,073 4b.1.4.3 Control Building 338 130 29 38 2

91 233 862 862 56 1,825 184,549 9,146 4b.1.4.4 Diesel Generator Building 98 34 8

10 25 66 242 242 500 49,962 2,594 4b.1.4.5 Radwaste Building 1,148 513 105 140 45 330 823 3,105 3,105 1,067 6,612 701,151 32,401 4b.1.4.6 Turbine Building 1,027 539 97 129 117 298 769 2,976 2,976 2,735 5,944 699,469 30,575 4b.1.4.7 Fuel Building 738 700 33 43 110 94 594 2,312 2,312 2,574 1,829 284,744 29,187 4b.1.4 Totals 6,147 5,218 714 863 654 2,767 5,369 21,732 21,732 15,337 43,078 4,707,935 226,888 4b.1 Subtotal Period 4b Activity Costs 6,599 28,882 1,625 1,857 8,704 5,629 13,425 66,722 63,859 2,862 203,652 74,439 15,100,620 722,664 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 11 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 4b Collateral Costs 4b.3.1 Process liquid waste 218 80 439 142 218 1,097 1,097 1,525 91,513 297 4b.3.2 Small tool allowance 540 81 621 621 4b.3.3 Decommissioning Equipment Disposition 100 27 284 35 65 511 511 6,000 373 303,507 88 4b.3 Subtotal Period 4b Collateral Costs 218 540 180 466 284 177 365 2,229 2,229 6,000 1,899 395,019 386 Period 4b Period-Dependent Costs 4b.4.1 Decon supplies 2,169 542 2,711 2,711 4b.4.2 Insurance 799 80 878 878 4b.4.3 Property taxes 1,574 157 1,732 1,732 4b.4.4 Health physics supplies 3,103 776 3,879 3,879 4b.4.5 Heavy equipment rental 2,663 399 3,063 3,063 4b.4.6 Disposal of DAW generated 257 106 675 210 1,249 1,249 12,096 242,405 369 4b.4.7 Plant energy budget 1,139 171 1,309 1,309 4b.4.8 NRC Fees 542 54 596 596 4b.4.9 Site O&M Cost 394 59 453 453 4b.4.10 Radwaste Processing Equipment/Services 586 88 673 673 4b.4.11 Security Staff Cost 3,883 582 4,465 4,465 102,679 4b.4.12 DOC Staff Cost 14,266 2,140 16,406 16,406 220,143 4b.4.13 Utility Staff Cost 24,393 3,659 28,052 28,052 387,714 4b.4 Subtotal Period 4b Period-Dependent Costs 2,169 5,767 257 106 675 47,574 8,918 65,467 65,467 12,096 242,405 369 710,536 4b.0 TOTAL PERIOD 4b COST 8,986 35,188 2,063 2,429 8,988 6,481 47,574 22,708 134,418 131,555 2,862 209,652 88,434 15,738,050 723,418 710,536 PERIOD 4e - License Termination Period 4e Direct Decommissioning Activities 4e.1.1 ORISE confirmatory survey 141 42 183 183 4e.1.2 Terminate license a

4e.1 Subtotal Period 4e Activity Costs 141 42 183 183 Period 4e Additional Costs 4e.2.1 Final Site Survey 11,020 3,306 14,326 14,326 230,140 4e.2 Subtotal Period 4e Additional Costs 11,020 3,306 14,326 14,326 230,140 Period 4e Collateral Costs 4e.3.1 DOC staff relocation expenses 829 124 953 953 4e.3 Subtotal Period 4e Collateral Costs 829 124 953 953 Period 4e Period-Dependent Costs 4e.4.1 Insurance 74 7

82 82 4e.4.2 Property taxes 745 74 819 819 4e.4.3 Health physics supplies 1,032 258 1,290 1,290 4e.4.4 Disposal of DAW generated 8

3 21 7

40 40 385 7,712 12 4e.4.5 Plant energy budget 144 22 165 165 4e.4.6 NRC Fees 256 26 282 282 4e.4.7 Site O&M Cost 186 28 214 214 4e.4.8 Security Staff Cost 705 106 811 811 18,651 4e.4.9 DOC Staff Cost 3,905 586 4,490 4,490 56,731 4e.4.10 Utility Staff Cost 5,167 775 5,942 5,942 73,829 4e.4 Subtotal Period 4e Period-Dependent Costs 1,032 8

3 21 11,182 1,888 14,135 14,135 385 7,712 12 149,211 4e.0 TOTAL PERIOD 4e COST 1,032 8

3 21 23,172 5,361 29,597 29,597 385 7,712 230,152 149,211 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 12 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 9,276 67,310 10,693 5,790 22,229 28,308 114,009 56,287 313,902 309,805 4,097 505,717 177,739 1,502 287 482 35,547,720 1,392,045 1,502,037 PERIOD 5b - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b.1.1.1 Reactor Building 5,134 770 5,904 5,904 65,001 5b.1.1.2 Auxiliary Building 1,945 292 2,236 2,236 23,242 5b.1.1.3 Circulating Water Screenhouse 3,165 475 3,640 3,640 38,383 5b.1.1.4 Control Building 4,641 696 5,337 5,337 56,578 5b.1.1.5 Diesel Generator Building 1,618 243 1,860 1,860 20,234 5b.1.1.6 Make-Up Water Pump House 344 52 396 396 5,100 5b.1.1.7 Miscellaneous Site Work 1,504 226 1,729 1,729 21,227 5b.1.1.8 Miscellaneous Structures 2,442 366 2,808 2,808 44,561 5b.1.1.9 Radwaste Building 4,502 675 5,177 5,177 58,440 5b.1.1.10 Service Building 353 53 406 406 5,585 5b.1.1.11 Transformer and Tank Pads 147 22 169 169 2,463 5b.1.1.12 Turbine Building 4,693 704 5,397 5,397 63,415 5b.1.1.13 Turbine Pedestal 1,080 162 1,243 1,243 12,474 5b.1.1.14 Fuel Building 2,159 324 2,483 2,483 26,720 5b.1.1 Totals 33,727 5,059 38,786 38,786 443,422 Site Closeout Activities 5b.1.2 BackFill Site 57 9

66 66 201 5b.1.3 Grade & landscape site 1,408 211 1,619 1,619 4,449 5b.1.4 Final report to NRC 141 21 163 163 1,560 5b.1 Subtotal Period 5b Activity Costs 35,192 141 5,300 40,634 163 40,471 448,071 1,560 Period 5b Additional Costs 5b.2.1 Concrete Crushing 1,281 8

193 1,482 1,482 7,355 5b.2.2 Screenhouse Cofferdam 934 140 1,074 1,074 10,159 5b.2.3 Discharge Flume Backfill 3,741 561 4,302 4,302 23,931 5b.2.4 Unit 2 Excavation Backfill 1,226 184 1,410 1,410 13,128 5b.2 Subtotal Period 5b Additional Costs 7,183 8

1,079 8,269 8,269 54,573 Period 5b Collateral Costs 5b.3.1 Small tool allowance 386 58 444 444 5b.3 Subtotal Period 5b Collateral Costs 386 58 444 444 Period 5b Period-Dependent Costs 5b.4.1 Insurance 226 23 249 249 5b.4.2 Property taxes 1,264 126 1,391 1,391 5b.4.3 Heavy equipment rental 5,246 787 6,033 6,033 5b.4.4 Plant energy budget 218 33 251 251 5b.4.5 Site O&M Cost 566 85 651 651 5b.4.6 Security Staff Cost 2,145 322 2,466 2,466 56,709 5b.4.7 DOC Staff Cost 11,330 1,699 13,029 13,029 160,674 5b.4.8 Utility Staff Cost 6,331 950 7,280 7,280 92,151 5b.4 Subtotal Period 5b Period-Dependent Costs 5,246 22,080 4,024 31,350 31,350 309,534 5b.0 TOTAL PERIOD 5b COST 48,007 22,229 10,461 80,697 163 80,534 502,644 311,094 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix D, Page 13 of 13 Table D Clinton Power Station Delayed DECON Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Fri, Sep 14, 2007 at 10:53:26 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 5 TOTALS 48,007 22,229 10,461 80,697 163 80,534 502,644 311,094 TOTAL COST TO DECOMMISSION 19,767 120,414 10,977 6,487 22,229 29,376 419,868 113,532 742,651 476,232 181,048 85,372 505,717 189,634 1,502 287 482 35,929,510 2,050,463 5,402,447 TOTAL COST TO DECOMMISSION WITH 18.05% CONTINGENCY:

$742,651 thousands of 2007 dollars TOTAL NRC LICENSE TERMINATION COST IS 64.13% OR:

$476,232 thousands of 2007 dollars SPENT FUEL MANAGEMENT COST IS 24.38% OR:

$181,048 thousands of 2007 dollars NON-NUCLEAR DEMOLITION COST IS 11.5% OR:

$85,372 thousands of 2007 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

191,424 cubic feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:

482 cubic feet TOTAL SCRAP METAL REMOVED:

75,356 tons TOTAL CRAFT LABOR REQUIREMENTS:

2,050,463 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, Inc.

Clinton Power Station Document E16-1555-005, Rev. 0 Decommissioning Cost Analysis Appendix E, Page 1 of 14 TLG Services, Inc.

APPENDIX E DETAILED COST ANALYSIS SAFSTOR

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 2 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 SAFSTOR site characterization survey 363 109 471 471 1a.1.2 Prepare preliminary decommissioning cost 118 18 136 136 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 181 27 209 209 2,000 1a.1.8 Review plant dwgs & specs.

118 18 136 136 1,300 1a.1.9 Perform detailed rad survey a

1a.1.10 Estimate by-product inventory 91 14 104 104 1,000 1a.1.11 End product description 91 14 104 104 1,000 1a.1.12 Detailed by-product inventory 136 20 156 156 1,500 1a.1.13 Define major work sequence 91 14 104 104 1,000 1a.1.14 Perform SER and EA 281 42 323 323 3,100 1a.1.15 Perform Site-Specific Cost Study 454 68 522 522 5,000 Activity Specifications 1a.1.16.1 Prepare plant and facilities for SAFSTOR 446 67 513 513 4,920 1a.1.16.2 Plant systems 378 57 435 435 4,167 1a.1.16.3 Plant structures and buildings 283 42 325 325 3,120 1a.1.16.4 Waste management 181 27 209 209 2,000 1a.1.16.5 Facility and site dormancy 181 27 209 209 2,000 1a.1.16 Total 1,470 220 1,690 1,690 16,207 Detailed Work Procedures 1a.1.17.1 Plant systems 107 16 123 123 1,183 1a.1.17.2 Facility closeout & dormancy 109 16 125 125 1,200 1a.1.17 Total 216 32 249 249 2,383 1a.1.18 Procure vacuum drying system 9

1 10 10 100 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 3,618 597 4,215 4,215 35,890 Period 1a Collateral Costs 1a.3.1 Spent Fuel Capital and Transfer 39,540 5,931 45,471 45,471 1a.3 Subtotal Period 1a Collateral Costs 39,540 5,931 45,471 45,471 Period 1a Period-Dependent Costs 1a.4.1 Insurance 1,320 132 1,452 1,452 1a.4.2 Property taxes 6,312 631 6,943 6,943 1a.4.3 Health physics supplies 377 94 471 471 1a.4.4 Heavy equipment rental 349 52 401 401 1a.4.5 Disposal of DAW generated 14 6

38 12 70 70 675 13,531 21 1a.4.6 Plant energy budget 964 145 1,108 1,108 1a.4.7 NRC Fees 258 26 284 284 1a.4.8 Emergency Planning Fees 450 45 495 495 1a.4.9 Site O&M Cost 250 37 287 287 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 3 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 (continued) 1a.4.10 Spent Fuel Pool O&M 738 111 849 849 1a.4.11 ISFSI Operating Costs 82 12 94 94 1a.4.12 Security Staff Cost 5,955 893 6,848 6,848 157,471 1a.4.13 Utility Staff Cost 26,183 3,927 30,110 30,110 423,400 1a.4 Subtotal Period 1a Period-Dependent Costs 726 14 6

38 42,511 6,118 49,413 47,975 1,438 675 13,531 21 580,871 1a.0 TOTAL PERIOD 1a COST 726 14 6

38 85,669 12,646 99,099 52,190 46,909 675 13,531 21 616,761 PERIOD 1b - SAFSTOR Limited DECON Activities Period 1b Direct Decommissioning Activities Decontamination of Site Buildings 1b.1.1.1 Reactor Building 2,771 1,385 4,156 4,156 56,016 1b.1.1.2 Auxiliary Building 305 153 458 458 6,485 1b.1.1.3 Control Building 353 177 530 530 7,503 1b.1.1.4 Diesel Generator Building 103 51 154 154 2,182 1b.1.1.5 Fuel Building 800 400 1,199 1,199 16,275 1b.1.1.6 Radwaste Building 1,195 597 1,792 1,792 25,369 1b.1.1.7 Turbine Building 1,069 534 1,603 1,603 22,689 1b.1.1 Totals 6,595 3,298 9,893 9,893 136,519 1b.1 Subtotal Period 1b Activity Costs 6,595 3,298 9,893 9,893 136,519 Period 1b Additional Costs 1b.2.1 Spent Fuel Pool Isolation 9,133 1,370 10,503 10,503 1b.2 Subtotal Period 1b Additional Costs 9,133 1,370 10,503 10,503 Period 1b Collateral Costs 1b.3.1 Decon equipment 726 109 834 834 1b.3.2 Process liquid waste 179 64 351 113 177 883 883 1,217 73,045 237 1b.3.3 Small tool allowance 103 15 119 119 1b.3.4 Spent Fuel Capital and Transfer 3,000 450 3,450 3,450 1b.3 Subtotal Period 1b Collateral Costs 904 103 64 351 113 3,000 751 5,286 1,836 3,450 1,217 73,045 237 Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 1,899 475 2,374 2,374 1b.4.2 Insurance 333 33 366 366 1b.4.3 Property taxes 1,061 106 1,167 1,167 1b.4.4 Health physics supplies 573 143 716 716 1b.4.5 Heavy equipment rental 88 13 101 101 1b.4.6 Disposal of DAW generated 32 13 85 26 157 157 1,524 30,535 46 1b.4.7 Plant energy budget 243 36 279 279 1b.4.8 NRC Fees 65 7

72 72 1b.4.9 Emergency Planning Fees 113 11 125 125 1b.4.10 Site O&M Cost 63 9

72 72 1b.4.11 Spent Fuel Pool O&M 186 28 214 214 1b.4.12 ISFSI Operating Costs 21 3

24 24 1b.4.13 Security Staff Cost 1,501 225 1,726 1,726 39,691 1b.4.14 Utility Staff Cost 6,599 990 7,589 7,589 106,720 1b.4 Subtotal Period 1b Period-Dependent Costs 1,899 661 32 13 85 10,185 2,107 14,983 14,620 362 1,524 30,535 46 146,411 1b.0 TOTAL PERIOD 1b COST 9,399 764 96 364 198 22,318 7,525 40,665 36,853 3,812 2,741 103,580 136,803 146,411 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 4 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 405 61 466 466 3,000 1c.1.2 Install containment pressure equal. lines 35 5

41 41 700 1c.1.3 Interim survey prior to dormancy 733 220 953 953 14,893 1c.1.4 Secure building accesses a

1c.1.5 Prepare & submit interim report 53 8

61 61 583 1c.1 Subtotal Period 1c Activity Costs 440 786 294 1,520 1,520 18,593 583 Period 1c Collateral Costs 1c.3.1 Process liquid waste 133 47 260 84 131 655 655 904 54,218 176 1c.3.2 Small tool allowance 3

0 4

4 1c.3.3 Spent Fuel Capital and Transfer 3,000 450 3,450 3,450 1c.3 Subtotal Period 1c Collateral Costs 133 3

47 260 84 3,000 582 4,109 659 3,450 904 54,218 176 Period 1c Period-Dependent Costs 1c.4.1 Insurance 329 33 362 362 1c.4.2 Property taxes 1,049 105 1,154 1,154 1c.4.3 Health physics supplies 160 40 199 199 1c.4.4 Heavy equipment rental 87 13 100 100 1c.4.5 Disposal of DAW generated 4

1 9

3 17 17 168 3,374 5

1c.4.6 Plant energy budget 240 36 276 276 1c.4.7 NRC Fees 64 6

71 71 1c.4.8 Emergency Planning Fees 112 11 123 123 1c.4.9 Site O&M Cost 62 9

72 72 1c.4.10 Spent Fuel Pool O&M 184 28 212 212 1c.4.11 ISFSI Operating Costs 20 3

24 24 1c.4.12 Security Staff Cost 1,485 223 1,707 1,707 39,260 1c.4.13 Utility Staff Cost 6,528 979 7,507 7,507 105,560 1c.4 Subtotal Period 1c Period-Dependent Costs 247 4

1 9

10,074 1,489 11,824 11,466 358 168 3,374 5

144,820 1c.0 TOTAL PERIOD 1c COST 133 690 51 262 93 13,860 2,365 17,453 13,645 3,808 1,072 57,592 18,774 145,403 PERIOD 1 TOTALS 9,532 2,180 162 632 329 121,847 22,536 157,217 102,688 54,530 4,488 174,703 155,598 908,576 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 500 75 575 575 2a.1.5 Maintenance supplies 503 126 629 629 2a.1 Subtotal Period 2a Activity Costs 1,003 201 1,203 1,203 Period 2a Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 45,000 6,750 51,750 51,750 2a.3 Subtotal Period 2a Collateral Costs 45,000 6,750 51,750 51,750 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 5 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 2a Period-Dependent Costs 2a.4.1 Insurance 2,028 203 2,230 2,230 2a.4.2 Property taxes 5,603 560 6,163 6,163 2a.4.3 Health physics supplies 344 86 430 430 2a.4.4 Disposal of DAW generated 39 16 101 32 187 187 1,815 36,370 55 2a.4.5 Plant energy budget 771 116 887 887 2a.4.6 NRC Fees 863 86 949 949 2a.4.7 Emergency Planning Fees 799 80 879 879 2a.4.8 Site O&M Cost 999 150 1,149 1,149 2a.4.9 Spent Fuel Pool O&M 2,952 443 3,394 3,394 2a.4.10 ISFSI Operating Costs 328 49 378 378 2a.4.11 Security Staff Cost 16,801 2,520 19,321 19,321 444,257 2a.4.12 Utility Staff Cost 20,888 3,133 24,021 24,021 308,686 2a.4 Subtotal Period 2a Period-Dependent Costs 344 39 16 101 52,031 7,458 59,989 59,989 1,815 36,370 55 752,943 2a.0 TOTAL PERIOD 2a COST 344 39 16 101 98,034 14,408 112,942 112,942 1,815 36,370 55 752,943 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 845 127 972 972 2b.1.5 Maintenance supplies 850 212 1,062 1,062 2b.1 Subtotal Period 2b Activity Costs 1,695 339 2,034 2,034 Period 2b Collateral Costs 2b.3.1 Spent Fuel Capital and Transfer 8,000 1,200 9,200 9,200 2b.3 Subtotal Period 2b Collateral Costs 8,000 1,200 9,200 9,200 Period 2b Period-Dependent Costs 2b.4.1 Insurance 3,172 317 3,489 3,489 2b.4.2 Property taxes 6,757 676 7,433 7,433 2b.4.3 Health physics supplies 496 124 620 620 2b.4.4 Disposal of DAW generated 61 25 161 50 297 297 2,878 57,682 88 2b.4.5 Plant energy budget 652 98 749 749 2b.4.6 NRC Fees 1,458 146 1,604 1,604 2b.4.7 Emergency Planning Fees 1,351 135 1,487 1,487 2b.4.8 Site O&M Cost 1,689 253 1,943 1,943 2b.4.9 ISFSI Operating Costs 555 83 638 638 2b.4.10 Security Staff Cost 14,400 2,160 16,560 16,560 380,777 2b.4.11 Utility Staff Cost 13,994 2,099 16,093 16,093 225,646 2b.4 Subtotal Period 2b Period-Dependent Costs 496 61 25 161 44,028 6,141 50,913 50,913 2,878 57,682 88 606,423 2b.0 TOTAL PERIOD 2b COST 496 61 25 161 53,723 7,681 62,147 62,147 2,878 57,682 88 606,423 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 5,333 800 6,133 6,133 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 6 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 2c.1.5 Maintenance supplies 5,364 1,341 6,706 6,706 2c.1 Subtotal Period 2c Activity Costs 10,697 2,141 12,839 12,839 Period 2c Period-Dependent Costs 2c.4.1 Insurance 19,538 1,954 21,492 21,492 2c.4.2 Property taxes 42,647 4,265 46,912 46,912 2c.4.3 Health physics supplies 2,946 736 3,682 3,682 2c.4.4 Disposal of DAW generated 378 156 991 309 1,833 1,833 17,755 355,795 542 2c.4.5 Plant energy budget 4,112 617 4,729 4,729 2c.4.6 NRC Fees 9,203 920 10,124 10,124 2c.4.7 Site O&M Cost 10,662 1,599 12,261 12,261 2c.4.8 Security Staff Cost 50,493 7,574 58,066 58,066 1,335,171 2c.4.9 Utility Staff Cost 48,756 7,313 56,069 56,069 778,850 2c.4 Subtotal Period 2c Period-Dependent Costs 2,946 378 156 991 185,412 25,288 215,169 215,169 17,755 355,795 542 2,114,021 2c.0 TOTAL PERIOD 2c COST 2,946 378 156 991 196,109 27,429 228,008 228,008 17,755 355,795 542 2,114,021 PERIOD 2 TOTALS 3,786 478 197 1,253 347,866 49,518 403,097 228,008 175,089 22,448 449,847 685 3,473,387 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 3a.1.1 Prepare preliminary decommissioning cost 118 18 136 136 1,300 3a.1.2 Review plant dwgs & specs.

417 63 480 480 4,600 3a.1.3 Perform detailed rad survey a

3a.1.4 End product description 91 14 104 104 1,000 3a.1.5 Detailed by-product inventory 118 18 136 136 1,300 3a.1.6 Define major work sequence 680 102 782 782 7,500 3a.1.7 Perform SER and EA 281 42 323 323 3,100 3a.1.8 Perform Site-Specific Cost Study 454 68 522 522 5,000 3a.1.9 Prepare/submit License Termination Plan 372 56 427 427 4,096 3a.1.10 Receive NRC approval of termination plan a

Activity Specifications 3a.1.11.1 Re-activate plant & temporary facilities 668 100 769 692 77 7,370 3a.1.11.2 Plant systems 378 57 435 391 43 4,167 3a.1.11.3 Reactor internals 644 97 741 741 7,100 3a.1.11.4 Reactor vessel 590 88 678 678 6,500 3a.1.11.5 Sacrificial shield 45 7

52 52 500 3a.1.11.6 Moisture separators/reheaters 91 14 104 104 1,000 3a.1.11.7 Reinforced concrete 145 22 167 83 83 1,600 3a.1.11.8 Main Turbine 189 28 218 218 2,088 3a.1.11.9 Main Condensers 189 28 218 218 2,088 3a.1.11.10 Pressure suppression structure 181 27 209 209 2,000 3a.1.11.11 Drywell 145 22 167 167 1,600 3a.1.11.12 Plant structures & buildings 283 42 325 163 163 3,120 3a.1.11.13 Waste management 417 63 480 480 4,600 3a.1.11.14 Facility & site closeout 82 12 94 47 47 900 3a.1.11 Total 4,048 607 4,655 4,242 413 44,633 Planning & Site Preparations 3a.1.12 Prepare dismantling sequence 218 33 250 250 2,400 3a.1.13 Plant prep. & temp. svces 2,419 363 2,782 2,782 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 7 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3a.1.14 Design water clean-up system 127 19 146 146 1,400 3a.1.15 Rigging/Cont. Cntrl Envlps/tooling/etc.

2,048 307 2,355 2,355 3a.1.16 Procure casks/liners & containers 112 17 128 128 1,230 3a.1 Subtotal Period 3a Activity Costs 11,501 1,725 13,227 12,813 413 77,559 Period 3a Collateral Costs 3a.3 Subtotal Period 3a Collateral Costs Period 3a Period-Dependent Costs 3a.4.1 Insurance 458 46 504 504 3a.4.2 Property taxes 999 100 1,099 1,099 3a.4.3 Health physics supplies 330 82 412 412 3a.4.4 Heavy equipment rental 349 52 401 401 3a.4.5 Disposal of DAW generated 12 5

32 10 59 59 570 11,419 17 3a.4.6 Plant energy budget 964 145 1,108 1,108 3a.4.7 NRC Fees 258 26 284 284 3a.4.8 Site O&M Cost 250 37 287 287 3a.4.9 Security Staff Cost 2,465 370 2,835 2,835 65,179 3a.4.10 Utility Staff Cost 16,145 2,422 18,566 18,566 258,629 3a.4 Subtotal Period 3a Period-Dependent Costs 678 12 5

32 21,539 3,290 25,556 25,556 570 11,419 17 323,807 3a.0 TOTAL PERIOD 3a COST 678 12 5

32 33,040 5,015 38,782 38,369 413 570 11,419 17 401,366 PERIOD 3b - Decommissioning Preparations Period 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems 429 64 494 444 49 4,733 3b.1.1.2 Reactor internals 363 54 417 417 4,000 3b.1.1.3 Remaining buildings 122 18 141 35 106 1,350 3b.1.1.4 CRD housings & NIs 91 14 104 104 1,000 3b.1.1.5 Incore instrumentation 91 14 104 104 1,000 3b.1.1.6 Removal primary containment 181 27 209 209 2,000 3b.1.1.7 Reactor vessel 329 49 379 379 3,630 3b.1.1.8 Facility closeout 109 16 125 63 63 1,200 3b.1.1.9 Sacrificial shield 109 16 125 125 1,200 3b.1.1.10 Reinforced concrete 91 14 104 52 52 1,000 3b.1.1.11 Main Turbine 189 28 217 217 2,080 3b.1.1.12 Main Condensers 189 28 218 218 2,088 3b.1.1.13 Moisture separators & reheaters 181 27 209 209 2,000 3b.1.1.14 Radwaste building 248 37 285 256 28 2,730 3b.1.1.15 Reactor building 248 37 285 256 28 2,730 3b.1.1 Total 2,970 445 3,415 3,088 327 32,741 3b.1 Subtotal Period 3b Activity Costs 2,970 445 3,415 3,088 327 32,741 Period 3b Additional Costs 3b.2.1 Site Characterization 897 269 1,167 1,167 3b.2.2 hazardous liquid disposal 7

411 104 523 523 1,571 89,546 3b.2.3 Contaminated asbestos disposal 8

5 2

15 15 60 1,800 3b.2.4 Clean asbestos disposal 2

0 2

2 3b.2 Subtotal Period 3b Additional Costs 15 416 900 376 1,707 1,707 1,631 91,346 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 8 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 3b Collateral Costs 3b.3.1 Decon equipment 726 109 834 834 3b.3.2 DOC staff relocation expenses 829 124 953 953 3b.3.3 Pipe cutting equipment 957 143 1,100 1,100 3b.3 Subtotal Period 3b Collateral Costs 726 957 829 377 2,887 2,887 Period 3b Period-Dependent Costs 3b.4.1 Decon supplies 22 6

28 28 3b.4.2 Insurance 254 25 280 280 3b.4.3 Property taxes 501 50 551 551 3b.4.4 Health physics supplies 182 46 228 228 3b.4.5 Heavy equipment rental 175 26 201 201 3b.4.6 Disposal of DAW generated 7

3 18 6

33 33 323 6,476 10 3b.4.7 Plant energy budget 483 72 556 556 3b.4.8 NRC Fees 130 13 143 143 3b.4.9 Site O&M Cost 125 19 144 144 3b.4.10 Security Staff Cost 1,236 185 1,421 1,421 32,679 3b.4.11 DOC Staff Cost 3,799 570 4,369 4,369 58,560 3b.4.12 Utility Staff Cost 8,094 1,214 9,309 9,309 129,669 3b.4 Subtotal Period 3b Period-Dependent Costs 22 357 7

3 18 14,622 2,232 17,261 17,261 323 6,476 10 220,907 3b.0 TOTAL PERIOD 3b COST 748 1,314 7

18 434 19,320 3,430 25,271 24,944 327 1,954 97,822 10 253,648 PERIOD 3 TOTALS 748 1,992 19 23 466 52,360 8,445 64,053 63,313 740 2,524 109,241 27 655,014 PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.1.1 Recirculation System Piping & Valves 10 40 8

6 31 50 34 179 179 265 265 61,459 1,078 4a.1.1.2 Recirculation Pumps & Motors 10 38 13 20 107 132 68 389 389 1,487 1,237 187,000 1,145 4a.1.1.3 CRDMs & NIs Removal 42 158 321 82 203 156 962 962 6,985 131,119 4,212 4a.1.1.4 Reactor Vessel Internals 63 2,203 3,456 667 3,966 197 4,727 15,279 15,279 2,413 1,502 287 347,905 26,617 1,197 4a.1.1.5 Vessel & Internals GTCC Disposal 8,152 1,223 9,374 9,374 482 86,500 4a.1.1.6 Reactor Vessel 5,228 1,242 375 2,056 197 5,383 14,481 14,481 13,057 1,326,615 26,617 1,197 4a.1.1 Totals 125 7,667 5,041 1,150 138 14,559 394 11,590 40,664 40,664 1,752 23,956 1,502 287 482 2,140,598 59,669 2,393 Removal of Major Equipment 4a.1.2 Main Turbine/Generator 307 903 161 2,722 600 4,693 4,693 57,609 2,592,393 6,446 4a.1.3 Main Condensers 1,051 971 173 2,927 825 5,947 5,947 61,945 2,787,524 22,050 Cascading Costs from Clean Building Demolition 4a.1.4.1 Reactor Building 905 136 1,041 1,041 11,450 4a.1.4.2 Auxiliary Building 216 32 248 248 2,582 4a.1.4.3 Fuel Building 237 36 273 273 2,912 4a.1.4.4 Radwaste Building 500 75 575 575 6,493 4a.1.4.5 Turbine Building 508 76 585 585 6,771 4a.1.4 Totals 2,367 355 2,722 2,722 30,209 Disposal of Plant Systems 4a.1.5.1 Acid Feed & Handling 26 1

1 21 10 59 59 488 19,822 533 4a.1.5.2 Auxiliary Steam 484 13 19 319 173 1,008 1,008 7,493 304,278 9,740 4a.1.5.3 Breathing Air 36 5

42 42 820 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 9 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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.1.5.4 CO2 & Generator Purge 16 2

18 18 349 4a.1.5.5 Caustic Handling 13 0

0 8

5 26 26 183 7,431 256 4a.1.5.6 Chem Radwaste Reprocessing & Disposal 351 29 29 143 114 145 810 810 3,354 1,375 244,454 7,319 4a.1.5.7 Chilled Water - RCA 1,035 27 40 679 369 2,149 2,149 15,914 646,286 20,760 4a.1.5.8 Chilled Water Non-RCA 166 25 191 191 3,682 4a.1.5.9 Chlorination 44 7

51 51 953 4a.1.5.10 Circulating Water - RCA 161 16 24 400 105 706 706 9,379 380,877 3,419 4a.1.5.11 Circulating Water Non-RCA 51 8

58 58 1,090 4a.1.5.12 Cntnmnt Aux & Fuel Bldg Equip Drains 81 4

4 14 17 27 146 146 325 180 29,340 1,625 4a.1.5.13 Cntnmnt Aux & Fuel Bldg Floor Drains 139 5

6 49 15 47 262 262 1,145 168 61,146 2,845 4a.1.5.14 Component Cooling Water Non-RCA 119 18 137 137 2,622 4a.1.5.15 Condensate 810 93 118 977 330 459 2,787 2,787 22,921 3,507 1,245,444 17,225 4a.1.5.16 Condensate Booster 766 100 126 906 398 456 2,750 2,750 21,259 4,224 1,242,066 16,349 4a.1.5.17 Condensate Polishing 619 31 34 265 100 228 1,277 1,277 6,222 1,088 348,255 12,807 4a.1.5.18 Condenser Vacuum 179 17 25 430 115 767 767 10,094 409,927 3,731 4a.1.5.19 Containment Combustible Gas 67 2

3 46 24 141 141 1,069 43,421 1,391 4a.1.5.20 Cycled Condensate 555 26 30 254 82 204 1,150 1,150 5,945 910 319,550 11,453 4a.1.5.21 Drywell Cooling 437 11 18 297 157 919 919 6,955 282,437 8,549 4a.1.5.22 Drywell Purge 124 6

9 156 56 351 351 3,655 148,412 2,612 4a.1.5.23 ECCS Equipment Cooling 65 2

3 53 25 148 148 1,252 50,856 1,311 4a.1.5.24 Extraction Steam 424 37 46 353 140 205 1,205 1,205 8,276 1,486 469,355 8,998 4a.1.5.25 Feedwater 464 55 70 544 206 265 1,605 1,605 12,765 2,191 714,912 9,918 4a.1.5.26 Feedwater Heater Drains Turbine Cycle 1,109 74 91 744 262 476 2,757 2,757 17,456 2,804 958,507 23,310 4a.1.5.27 Feedwater Heater Misc.

172 9

10 52 37 62 342 342 1,223 389 84,542 3,542 4a.1.5.28 Filtered Water 4

1 4

4 86 4a.1.5.29 Generator Hydrogen Seal Oil 25 0

1 10 8

44 44 243 9,883 469 4a.1.5.30 Generator Stator Cooling 16 0

1 9

6 32 32 207 8,423 339 4a.1.5.31 High Pressure Core Spray 225 20 25 224 66 112 672 672 5,250 702 276,214 4,755 4a.1.5.32 Hydrogen 22 0

0 7

7 36 36 168 6,815 403 4a.1.5.33 Laundry Equip & Flr Drains RW Reprocess 189 8

10 117 19 72 416 416 2,742 231 129,825 3,930 4a.1.5.34 Leak Detection 37 0

0 4

10 51 51 86 3,512 836 4a.1.5.35 Local Instrument Panels 5

1 6

6 116 4a.1.5.36 Low Pressure Core Spray 86 10 13 124 31 51 316 316 2,907 329 147,560 1,828 4a.1.5.37 Machine Shop Equipment 10 0

1 10 4

25 25 225 9,119 216 4a.1.5.38 Machine Shop Ventilation 201 5

7 120 70 401 401 2,806 113,939 3,669 4a.1.5.39 Main Steam 746 50 60 442 185 313 1,797 1,797 10,374 1,966 597,645 15,622 4a.1.5.40 Main Steam Isolation Valve 19 1

1 2

3 6

32 32 44 36 5,045 380 4a.1.5.41 Make-up Demineralizer - RCA 184 4

6 103 63 360 360 2,419 98,255 3,595 4a.1.5.42 Make-up Demineralizer Non-RCA 208 31 239 239 4,416 4a.1.5.43 Makeup Condensate Storage 216 11 11 42 45 74 399 399 991 474 82,690 4,349 4a.1.5.44 Misc. Building Drains 16 2

19 19 357 4a.1.5.45 Miscellaneous Ventilation 30 4

34 34 643 4a.1.5.46 Nuclear Boiler 15 0

0 1

2 5

24 24 34 21 3,277 323 4a.1.5.47 Oil Transfer 90 4

6 104 39 243 243 2,429 98,662 1,834 4a.1.5.48 Reactor Core Isolation Cooling 194 9

11 106 24 73 417 417 2,491 275 124,231 4,063 4a.1.5.49 Refrigeration Piping 17 3

20 20 388 4a.1.5.50 Sanitary 151 23 174 174 3,202 4a.1.5.51 Screen House & MU Pump House Ventilation 31 5

36 36 736 4a.1.5.52 Standby Liquid Control 26 1

1 18 9

55 55 413 16,763 529 4a.1.5.53 Switchgear Heat Removal 16 2

19 19 356 4a.1.5.54 Turbine Building Closed Cooling Water 148 4

5 90 52 299 299 2,106 85,531 2,948 4a.1.5.55 Turbine Electrohydraulic Control 9

0 0

4 3

16 16 84 3,405 185 4a.1.5.56 Turbine Gen Misc Drains & Vents 45 1

1 14 14 74 74 323 13,132 895 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 10 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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.1.5.57 Turbine Gland Seal Steam 300 22 34 570 168 1,092 1,092 13,358 542,467 6,268 4a.1.5.58 Turbine Oil 48 2

3 53 21 127 127 1,250 50,775 1,016 4a.1.5.59 Turbine-Gen Aux & Misc Devices 214 20 30 513 137 914 914 12,031 488,573 4,614 4a.1.5 Totals 12,060 727 931 9,396 2,077 5,065 30,257 29,209 1,048 220,355 22,355 10,927,060 250,572 4a.1.6 Scaffolding in support of decommissioning 2,745 50 11 140 17 718 3,682 3,682 2,969 185 150,174 63,258 4a.1 Subtotal Period 4a Activity Costs 125 26,197 7,692 2,426 15,323 16,653 394 19,153 87,965 86,917 1,048 344,629 46,496 1,502 287 482 18,597,750 432,203 2,393 Period 4a Additional Costs 4a.2.1 Disposal of stored turbine rotors 17 100 40 743 130 1,030 1,030 15,719 707,358 352 4a.2 Subtotal Period 4a Additional Costs 17 100 40 743 130 1,030 1,030 15,719 707,358 352 Period 4a Collateral Costs 4a.3.1 Process liquid waste 21 9

48 15 22 115 115 166 9,977 32 4a.3.2 Small tool allowance 321 48 369 332 37 4a.3 Subtotal Period 4a Collateral Costs 21 321 9

48 15 70 484 447 37 166 9,977 32 Period 4a Period-Dependent Costs 4a.4.1 Decon supplies 57 14 71 71 4a.4.2 Insurance 649 65 713 713 4a.4.3 Property taxes 1,279 128 1,406 1,266 141 4a.4.4 Health physics supplies 1,987 497 2,484 2,484 4a.4.5 Heavy equipment rental 2,180 327 2,507 2,507 4a.4.6 Disposal of DAW generated 174 72 457 143 846 846 8,196 164,251 250 4a.4.7 Plant energy budget 1,171 176 1,347 1,347 4a.4.8 NRC Fees 440 44 484 484 4a.4.9 Site O&M Cost 320 48 368 368 4a.4.10 Radwaste Processing Equipment/Services 476 71 547 547 4a.4.11 Security Staff Cost 3,154 473 3,627 3,627 83,393 4a.4.12 DOC Staff Cost 11,904 1,786 13,689 13,689 184,131 4a.4.13 Utility Staff Cost 20,861 3,129 23,990 23,990 333,571 4a.4 Subtotal Period 4a Period-Dependent Costs 57 4,167 174 72 457 40,252 6,900 52,079 51,938 141 8,196 164,251 250 601,096 4a.0 TOTAL PERIOD 4a COST 203 30,702 7,976 2,586 16,066 17,126 40,647 26,253 141,558 140,332 1,225 360,348 54,858 1,502 287 482 19,479,330 432,838 603,489 PERIOD 4b - Site Decontamination Period 4b Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks 452 45 92 104 572 405 1,668 1,668 6,066 544,292 1,017 Disposal of Plant Systems 4b.1.2.1 Component Cooling Water - RCA 178 4

6 101 61 350 350 2,361 95,865 3,548 4b.1.2.2 Containment Monitoring 50 0

0 8

14 73 73 185 7,495 1,113 4b.1.2.3 Control Rod Drive 357 14 15 88 53 119 645 645 2,064 559 133,952 7,387 4b.1.2.4 Diesel Fuel Oil 59 9

68 68 1,256 4b.1.2.5 Diesel General 52 8

60 60 1,133 4b.1.2.6 Diesel-Generator Room Ventilation 77 12 88 88 1,817 4b.1.2.7 Drains-Laundry to Radwaste 15 1

1 3

2 5

26 26 65 23 4,677 301 4b.1.2.8 Electrical - Clean Non-RCA 1,545 232 1,777 1,777 33,545 4b.1.2.9 Electrical - Clean RCA 6,131 125 188 3,190 2,052 11,687 11,687 74,814 3,038,244 126,548 4b.1.2.10 Electrical - Contaminated 909 13 21 353 285 1,581 1,581 8,281 336,300 19,037 4b.1.2.11 Equip Drain Radwaste Reprocessing 1,018 44 51 423 142 365 2,043 2,043 9,913 1,584 537,960 21,022 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 11 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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) 4b.1.2.12 Fire Protection - RCA 616 15 23 385 217 1,255 1,255 9,018 366,214 12,406 4b.1.2.13 Fire Protection Non-RCA 154 23 177 177 3,416 4b.1.2.14 Floor Drain Radwaste Reprocessing 634 37 42 323 128 249 1,413 1,413 7,582 1,406 429,512 13,094 4b.1.2.15 Fuel Handling & Transfer 22 1

2 11 5

9 50 50 262 54 15,494 464 4b.1.2.16 Fuel Pool Cooling & Cleanup 783 54 63 480 189 330 1,898 1,898 11,250 2,020 636,883 16,214 4b.1.2.17 Fuel Support 88 7

9 70 26 41 242 242 1,649 278 91,923 1,898 4b.1.2.18 HVAC - Auxiliary Building 28 1

2 26 11 68 68 612 24,859 592 4b.1.2.19 HVAC - Containment Building 661 21 33 560 256 1,532 1,532 13,132 533,296 12,643 4b.1.2.20 HVAC - Control Room 242 36 279 279 5,686 4b.1.2.21 HVAC - Fuel Building 283 6

10 170 99 569 569 3,993 162,145 5,153 4b.1.2.22 HVAC - Laboratory 456 10 16 273 158 913 913 6,392 259,566 8,385 4b.1.2.23 HVAC - Off Gas Building 115 3

5 80 42 245 245 1,876 76,166 2,292 4b.1.2.24 HVAC - Radwaste Building 644 16 25 428 231 1,345 1,345 10,038 407,637 11,910 4b.1.2.25 HVAC - Service Building 52 8

60 60 1,145 4b.1.2.26 HVAC - Turbine Building 532 13 20 334 187 1,087 1,087 7,839 318,337 9,704 4b.1.2.27 Hoists Cranes & Elevators 6

1 7

7 123 4b.1.2.28 Instrument Air - RCA 374 5

7 115 112 613 613 2,708 109,971 7,089 4b.1.2.29 Instrument Air Non-RCA 17 3

20 20 389 4b.1.2.30 Off Gas 154 4

5 93 54 309 309 2,172 88,201 3,139 4b.1.2.31 Plant Service Water - RCA 176 5

8 130 65 384 384 3,043 123,583 3,532 4b.1.2.32 Plant Service Water Non-RCA 156 23 180 180 3,494 4b.1.2.33 Potable Water 11 2

12 12 231 4b.1.2.34 Process Radiation Monitoring 84 1

1 23 25 134 134 529 21,497 1,687 4b.1.2.35 Process Sampling 414 3

5 92 119 634 634 2,157 87,602 8,330 4b.1.2.36 Reactor Recirculation 42 3

3 11 15 17 91 91 266 159 25,061 874 4b.1.2.37 Reactor Water Clean-up 257 15 17 74 72 97 533 533 1,738 766 139,001 5,284 4b.1.2.38 Residual Heat Removal 481 47 58 496 157 247 1,487 1,487 11,630 1,672 622,251 10,146 4b.1.2.39 Screen Wash 6

1 7

7 132 4b.1.2.40 Service Air - RCA 230 4

6 106 75 421 421 2,476 100,556 4,507 4b.1.2.41 Service Air Non-RCA 14 2

16 16 309 4b.1.2.42 Shutdown Service Water - RCA 92 2

4 63 33 195 195 1,481 60,155 1,829 4b.1.2.43 Shutdown Service Water Non-RCA 99 15 114 114 2,196 4b.1.2.44 Solid Radwaste Reprocessing & Disposal 509 22 25 214 68 182 1,020 1,020 5,026 756 268,960 10,504 4b.1.2.45 Standby Gas Treatment 60 1

1 25 19 107 107 589 23,913 1,224 4b.1.2.46 Suppression Pool Cleanup & Transfer 96 6

6 46 20 38 212 212 1,086 213 63,215 1,997 4b.1.2.47 Suppression Pool Make-up 44 5

6 48 18 24 145 145 1,117 193 62,702 942 4b.1.2.48 Turb OG RW Cntrl & DG Bldg Equip Drains 181 8

8 33 31 60 321 321 764 334 60,852 3,642 4b.1.2.49 Turb OG RW Cntrl & DG Bldg Floor Drains 295 12 13 128 33 104 585 585 3,005 366 153,049 6,062 4b.1.2 Totals 19,502 529 705 9,002 959 6,375 37,073 34,210 2,862 211,112 10,382 9,487,092 399,374 4b.1.3 Scaffolding in support of decommissioning 4,118 74 17 210 26 1,078 5,523 5,523 4,453 277 225,261 94,887 Decontamination of Site Buildings 4b.1.4.1 Reactor Building 2,497 3,066 404 454 330 1,817 2,627 11,196 11,196 7,734 24,125 2,519,185 112,645 4b.1.4.2 Auxiliary Building 285 113 16 21 50 45 194 723 723 1,171 895 134,128 7,994 4b.1.4.3 Control Building 329 67 14 19 2

46 197 675 675 56 915 93,484 7,972 4b.1.4.4 Diesel Generator Building 95 17 4

5 12 56 191 191 250 24,981 2,272 4b.1.4.5 Fuel Building 729 632 20 25 110 50 557 2,122 2,122 2,574 959 197,780 27,889 4b.1.4.6 Radwaste Building 1,114 288 54 71 45 167 693 2,432 2,432 1,067 3,336 373,533 28,179 4b.1.4.7 Turbine Building 997 339 52 68 117 152 654 2,379 2,379 2,735 3,035 408,574 26,826 4b.1.4 Totals 6,046 4,522 564 663 654 2,289 4,980 19,718 19,718 15,337 33,515 3,751,664 213,778 4b.1 Subtotal Period 4b Activity Costs 6,498 28,186 1,259 1,489 9,866 3,846 12,837 63,982 61,119 2,862 230,902 50,241 14,008,310 709,055 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 12 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 4b Additional Costs 4b.2.1 ISFSI License Termination 723 2

85 214 1,162 421 2,607 2,607 4,255 510,082 11,114 2,560 4b.2 Subtotal Period 4b Additional Costs 723 2

85 214 1,162 421 2,607 2,607 4,255 510,082 11,114 2,560 Period 4b Collateral Costs 4b.3.1 Process liquid waste 83 35 193 62 90 463 463 669 40,127 130 4b.3.2 Small tool allowance 537 81 618 618 4b.3.3 Decommissioning Equipment Disposition 100 27 284 35 65 511 511 6,000 373 303,507 88 4b.3 Subtotal Period 4b Collateral Costs 83 537 135 219 284 97 235 1,591 1,591 6,000 1,042 343,633 219 Period 4b Period-Dependent Costs 4b.4.1 Decon supplies 1,958 490 2,448 2,448 4b.4.2 Insurance 799 80 878 878 4b.4.3 Property taxes 1,574 157 1,732 1,732 4b.4.4 Health physics supplies 3,094 774 3,868 3,868 4b.4.5 Heavy equipment rental 2,663 399 3,063 3,063 4b.4.6 Disposal of DAW generated 253 104 664 207 1,228 1,228 11,898 238,427 363 4b.4.7 Plant energy budget 1,139 171 1,309 1,309 4b.4.8 NRC Fees 542 54 596 596 4b.4.9 Site O&M Cost 394 59 453 453 4b.4.10 Radwaste Processing Equipment/Services 586 88 673 673 4b.4.11 Security Staff Cost 3,883 582 4,465 4,465 102,679 4b.4.12 DOC Staff Cost 14,266 2,140 16,406 16,406 220,143 4b.4.13 Utility Staff Cost 24,393 3,659 28,052 28,052 387,714 4b.4 Subtotal Period 4b Period-Dependent Costs 1,958 5,757 253 104 664 47,574 8,860 65,171 65,171 11,898 238,427 363 710,536 4b.0 TOTAL PERIOD 4b COST 8,539 35,203 1,650 1,897 10,150 4,821 48,736 22,354 133,351 127,881 2,607 2,862 236,902 67,436 15,100,450 720,751 713,096 PERIOD 4e - License Termination Period 4e Direct Decommissioning Activities 4e.1.1 ORISE confirmatory survey 141 42 183 183 4e.1.2 Terminate license a

4e.1 Subtotal Period 4e Activity Costs 141 42 183 183 Period 4e Additional Costs 4e.2.1 Final Site Survey 11,020 3,306 14,326 14,326 230,140 4e.2 Subtotal Period 4e Additional Costs 11,020 3,306 14,326 14,326 230,140 Period 4e Collateral Costs 4e.3.1 DOC staff relocation expenses 829 124 953 953 4e.3 Subtotal Period 4e Collateral Costs 829 124 953 953 Period 4e Period-Dependent Costs 4e.4.1 Insurance 74 7

82 82 4e.4.2 Property taxes 745 74 819 819 4e.4.3 Health physics supplies 1,032 258 1,290 1,290 4e.4.4 Disposal of DAW generated 8

3 21 7

40 40 385 7,712 12 4e.4.5 Plant energy budget 144 22 165 165 4e.4.6 NRC Fees 256 26 282 282 4e.4.7 Site O&M Cost 186 28 214 214 4e.4.8 Security Staff Cost 705 106 811 811 18,651 4e.4.9 DOC Staff Cost 3,905 586 4,490 4,490 56,731 4e.4.10 Utility Staff Cost 5,167 775 5,942 5,942 73,829 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 13 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 4e.4 Subtotal Period 4e Period-Dependent Costs 1,032 8

3 21 11,182 1,888 14,135 14,135 385 7,712 12 149,211 4e.0 TOTAL PERIOD 4e COST 1,032 8

3 21 23,172 5,361 29,597 29,597 385 7,712 230,152 149,211 PERIOD 4 TOTALS 8,742 66,937 9,633 4,486 26,216 21,969 112,554 53,968 304,506 297,811 2,607 4,088 597,250 122,679 1,502 287 482 34,587,500 1,383,740 1,465,796 PERIOD 5b - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b.1.1.1 Reactor Building 5,134 770 5,904 5,904 65,001 5b.1.1.2 Auxiliary Building 1,945 292 2,236 2,236 23,242 5b.1.1.3 Circulating Water Screenhouse 3,165 475 3,640 3,640 38,383 5b.1.1.4 Control Building 4,641 696 5,337 5,337 56,578 5b.1.1.5 Diesel Generator Building 1,618 243 1,860 1,860 20,234 5b.1.1.6 Fuel Building 2,159 324 2,483 2,483 26,720 5b.1.1.7 Make-Up Water Pump House 344 52 396 396 5,100 5b.1.1.8 Miscellaneous Site Work 1,504 226 1,729 1,729 21,227 5b.1.1.9 Miscellaneous Structures 2,442 366 2,808 2,808 44,561 5b.1.1.10 Radwaste Building 4,502 675 5,177 5,177 58,440 5b.1.1.11 Service Building 353 53 406 406 5,585 5b.1.1.12 Transformer and Tank Pads 147 22 169 169 2,463 5b.1.1.13 Turbine Building 4,693 704 5,397 5,397 63,415 5b.1.1.14 Turbine Pedestal 1,080 162 1,243 1,243 12,474 5b.1.1 Totals 33,727 5,059 38,786 38,786 443,422 Site Closeout Activities 5b.1.2 BackFill Site 57 9

66 66 201 5b.1.3 Grade & landscape site 1,408 211 1,619 1,619 4,449 5b.1.4 Final report to NRC 141 21 163 163 1,560 5b.1 Subtotal Period 5b Activity Costs 35,192 141 5,300 40,634 163 40,471 448,071 1,560 Period 5b Additional Costs 5b.2.1 Concrete Crushing 1,281 8

193 1,482 1,482 7,355 5b.2.2 ISFSI Site Restoration 1,158 42 180 1,380 1,380 3,069 160 5b.2.3 Screenhouse Cofferdam 934 140 1,074 1,074 10,159 5b.2.4 Discharge Flume Backfill 3,741 561 4,302 4,302 23,931 5b.2.5 Unit 2 Excavation Backfill 1,226 184 1,410 1,410 13,128 5b.2 Subtotal Period 5b Additional Costs 8,341 49 1,259 9,649 1,380 8,269 57,642 160 Period 5b Collateral Costs 5b.3.1 Small tool allowance 388 58 446 446 5b.3 Subtotal Period 5b Collateral Costs 388 58 446 446 Period 5b Period-Dependent Costs 5b.4.1 Insurance 226 23 249 249 5b.4.2 Property taxes 1,264 126 1,391 1,391 5b.4.3 Heavy equipment rental 5,246 787 6,033 6,033 5b.4.4 Plant energy budget 218 33 251 251 5b.4.5 Site O&M Cost 566 85 651 651 5b.4.6 Security Staff Cost 2,145 322 2,466 2,466 56,709 5b.4.7 DOC Staff Cost 11,330 1,699 13,029 13,029 160,674 5b.4.8 Utility Staff Cost 6,331 950 7,280 7,280 92,151 TLG Services, Inc.

Clinton Power Station Decommissioning Cost Analysis Document E16-1555-005, Rev. 0 Appendix E, Page 14 of 14 Table E Clinton Power Station SAFSTOR Decommissioning Cost Estimate (Thousands of 2007 Dollars)

Costs run: Thu, Sep 20, 2007 at 15:02:11 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /

Utility and Activity DECCER Version 2007.02.18b 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 5b.4 Subtotal Period 5b Period-Dependent Costs 5,246 22,080 4,024 31,350 31,350 309,534 5b.0 TOTAL PERIOD 5b COST 49,167 22,271 10,641 82,079 163 1,380 80,537 505,713 311,254 PERIOD 5 TOTALS 49,167 22,271 10,641 82,079 163 1,380 80,537 505,713 311,254 TOTAL COST TO DECOMMISSION 19,021 124,062 10,292 5,338 26,216 24,017 656,899 145,108 1,010,952 691,981 233,606 85,365 597,250 152,139 1,502 287 482 35,321,280 2,045,763 6,814,027 TOTAL COST TO DECOMMISSION WITH 16.76% CONTINGENCY:

$1,010,952 thousands of 2007 dollars TOTAL NRC LICENSE TERMINATION COST IS 68.45% OR:

$691,981 thousands of 2007 dollars SPENT FUEL MANAGEMENT COST IS 23.11% OR:

$233,606 thousands of 2007 dollars NON-NUCLEAR DEMOLITION COST IS 8.44% OR:

$85,365 thousands of 2007 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

153,929 cubic feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:

482 cubic feet TOTAL SCRAP METAL REMOVED:

75,356 tons TOTAL CRAFT LABOR REQUIREMENTS:

2,045,763 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, Inc.

ATTACHMENT 2 Clinton Power Station Radiological Decommissioning Projected SAFSTOR Cash Flow (dollars, thousands)

Year 2026 Radiological Decommissioning Cost (July 31, 2009 dollars)

$14,402 Radiological Decommissioning Cost less Decommissioning Period Credit

$14,402 2027

$81,329

$79,734 2028

$14,299

$13,744 2029

$5,725

$5,395 2030

$5,725

$5,289 2031

$5,725

$5,185 2032

$5,740

$5,097 2033

$5,725

$4,984 2034

$5,725

$4,886 2035

$5,725

$4,790 2036

$5,740

$4,709 2037

$5,725

$4,604 2038

$5,741

$4,527 2039

$5,725

$4,425 2040

$5,740

$4,350 2041

$5,725

$4,254 2042

$5,725

$4,170 2043

$5,725

$4,088 2044

$5,740

$4,019 2045

$5,725

$3,930 2046

$5,725

$3,853 2047

$5,725

$3,777 2048

$5,740

$3,713 2049

$5,725

$3,630 2050

$5,725

$3,559 2051

$5,725

$3,489 2052

$5,740

$3,430 2053

$5,725

$3,354 2054

$5,725

$3,288 2055

$5,725

$3,224 2056

$5,740

$3,169 2057

$5,725

$3,098 2058

$5,725

$3,038 2059

$5,725

$2,978 2060

$5,740

$2,928 2061

$5,725

$2,862 2062

$5,725

$2,806 2063

$5,725

$2,751 2064

$5,740

$2,705 2065

$5,725

$2,645 2066

$5,725

$2,593 2067

$5,725

$2,542

ATTACHMENT 2 Clinton Power Station Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Year 2068 Radiological Decommissioning Cost (July 31, 2009 dollars)

$5,740 Radiological Decommissioning Cost less Decommissioning Period Credit

$2,499 2069

$5,725

$2,443 2070

$5,725

$2,395 2071

$5,725

$2,348 2072

$5,740

$2,309 2073

$5,725

$2,257 2074

$5,725

$2,213 2075

$5,725

$2,169 2076

$5,740

$2,133 2077

$5,725

$2,085 2078

$5,725

$2,044 2079

$5,725

$2,004 2080

$5,725

$1,965 2081

$18,231

$6,135 2082

$45,423

$14,985 2083

$108,023

$34,939 2084

$100,273

$31,796 2085

$86,981

$27,040 2086

$31,733

$9,672 2087

$77

$23 2088

$77

$23 2089

$1

$0 Total

$798,737

$409,492 Total Decommissioning Period Credit:

$389,245

ATTACHMENT 3 Clinton Power Station NRC Funding Assurance Calculations July 31, 2009 (dollars, thousands)

NRC Generic Formula CPS Site-Specific SAFSTOR Decommissioning Cost Estimate Required Minimum at Jul 31, 2009 A

$576,567

$798,737 Trust Fund Amount at Jul 31, 2009 B

$320,699

$320,699 Shutdown Date 9/29/2026 9/29/2026 Years to Shutdown C 17.175 17.175 Earnings Credit to shutdown D = B x 1 + 2% ^ C -1

$129,919

$129,919 Projected Trust Fund Amount at shutdown E = B + D

$450,618

$450,618 Decommissioning Period Earnings Credit F

$33,500

$389,245 Total Projected Trust Fund Amount G = E + F

$484,118

$839,863 Difference H = G - A

$92,449

$41,126 Prepayment Difference - Surplus/(Shortfall)

J = H / 1 + 2% ^ C

$65,795

$29,269