Text

Decommissioning Funding Status Report
	ML15086A337
Person / Time
Site:	Crane
Issue date:	03/27/2015
From:	Halnon G; GPU Nuclear
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	TMI-15-036
	Download: ML15086A337 (150)
	v • d • e

{{#Wiki_filter:CPU GPU Nuclear, Inc. Three Mile lsland Nuclear Station Route 441 South Post Office Box 480 Middletown, PA 1 7057-0480 Tel 71 7-948-8461 10 cFR 50.75 10 CFR 50.82 NUCLEAS March 27.2015 TMI-15-036 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

SUBJECT:

Three Mile lsland Nuclear Station, Unit 2 Docket No. 50-320. License No. DPR-73 Decommissioninq Fundinq Status Report for the Three Mile lsland Nuclear Station. Unit 2 Pursuant to 10 CFR 50.75 and 10 CFR 50.82, GPU Nuclear, lnc. is hereby submitting three (3) reports to the Nuclear Regulatory Commission (NRC) for Three Mile lsland Nuclear Station, Unit 2 for the year ending December 31, 2014. Attachment 1 provides a decommissioning funding status report based on the Nuclear Regulatory Commission (NRC)formula described in 10 CFR 50.75(c). Attachment 2 provides a decommissioning funding status report based upon a site-specific decommissioning cost estimate. contains a financial assurance status report as required by 10 CFR 50.82(a)(B)(v). Enclosure A provides a copy of the Decommissioning Cost Analysis for Three Mile lsland Unit 2, December 2014. Enclosure B provides a copy of the Escalation Analysis for Three Mile lsland Unit 2 2013 Sife-Specific Decommissioning Cosf Esfimafe, February 2015. There are no regulatory commitments contained in this letter. lf there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - FirstEnergy Nuclear Operating Company Fleet Licensing, at (330) 315-6810. Grdgory Sincerely, Director,Fleet Regulatory Affairs

2. 3. Three Mile lsland Nuclear

Station, Unit 2 TMt-15-036 Page 2 Attachments:

1. Three Mile lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC Formula Three Mib lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report -

Site-Specific Decommissioning Cost Estimate Three Mile lsland Nuclear Station. Unit 2 FinancialAssurance Status Report

Enclosures:

A. Decommissioning Cost Anatysis for Three Mile lsland Unit 2, December 2014 B. Escatation Anatylis forThree Mile tstand tJnit 2 2013 Sife-specific Decommissioning Cost Estimate, February 2015 cc: NRC Region lAdministrator NRC Project Manager NRC Resident Inspector TMt-15-036 Three Mile lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC Formula Page 1 of 3 This report reflects the FirstEnergy Corp. subsidiary ownership interests in the Three Mile f sland Nuclear

Station, Unit 2 as of December 31,2014.

1. The minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(b) and (c) (see Schedule 1):

Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated $252,161,563 126,08A,782 126.080,782 $5q4j23J120 After Tax $338,038,657 182,710,464 211.780,107 ve-sn-ru

2. The amount accumulated in external trust funds as of December 31,2014:

3. 4. There are no longer any funds to be collected from the ratepayers. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning fundi, and rates of other factors used in funding projections: 1A0o/o 2.A0o/o 2053 2034 Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated Consolidated Ownership lnterest in Unit Estimated Net Investment Rate Year of Site Restoration Completion Year of Three Mib lsland Nuclear Station, Unit 1 Operating License Expiration 5. 6. An additional assumption is that the decommissioning activities for Three Mile lsland Nuclear Station, Unit 2 will commence after the shutdown of Three Mile lsland Nuclear Station, Unit 1. Three Mile lsland Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in2040' There are no contracts upon whlch the owners/licensees are relying pursuant to 10 cFR 50.75(e)(1)(v). There are no modifications to the licensee's current method of providing financial assurance since the last submitted report.

Attachment 1 TMr-15-036 Page 2 of 3 7. 8. There were no amendments to the trust agreements for the above-mentioned owners of Three Mile lsland Nuclear Station, Unit 2. Mathematical rounding was performed during the development of the supporting calculations.

Attachment 1 TMr-15-036 Page 3 of 3 Schedule 1 FIRSTENERGY CORP. Calculation of Minimum Financial Assurance Amount December 31,2014 THREE MILE ISLAND NUCLEAR

STATION, UNIT 2 Pennsvlvania Regions Labor (L) = Northeast EnergY (E) = National Waste Burial (B) = Generic For PWR Unit l=

f= $= Adjustment Factor 2.661 2.222 13.885 Ratio 0.65 0.13 0.22 $126,080,782 $126,080,782 $252.161,563 $504,323,126 Escalation Factorl 1.73 0.289 3.055 5.074 $99,393,600 $504,323,126 PWR Escalation Factor = Base Amount for PWR between 1200 MWt and 3400 MWt = ($ZS + 0'00BBP) million (P = power level in megawatts thermal = 2772) ($7S + 0.0088(2772)) million = Escalated Amount for unitl = 99,393,600 x 5.074 Owner/Licenseel Ownership Pennsylvania Electric Company 25o/o Jersey Central Power & Light Company 25o/o Metropolitan Edison Company 50o/o FirstEnergy Corp. Consolidated 10Qo/o Note 1: Mathematical rounding was performed during the development of the supporting calculations. TMt-15-036 Three Mile lsland Nuclear

Station, Unit 2 Decommissioning Funding Status Report - Site-specific Decommissioning Cost Estimate Page 1 of 4

1. Decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c) are based upon a site-specific decommissioning cost study, Decommissioning Cost Analysis forThree Mile lsland lJnit 2, dated December 2014, and escalated to 2014 dollars:

Radiological Non-Radiological FirstEnergy Corp. Consolidated

2. The amount accumulated in external trust funds as of December 31,2014:

$1,180,928,000 40.560.000 gl2zLt88*000 After Tax $338,038,657 192,710,464 211,780.107 s732529.228 100o/o 2.77o/o 2.00o/o 2053 2034 Metropolitan Edison ComPanY Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated

3. There are no longer any funds to be collected from the ratepayers' Consolidated Ownership Interest in Unit Estimated Rate of Escalation in Decommissioning Costs Estimated After-Tax Rate of Return Year of Site Restoration Completion Year of Three Mile lsland Nuclear Station. Unit 1 end of license

4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:

5. 6. An additional assumption is that the decommissioning activities for Three Mib lsland Nuclear Station, Unit 2 will commence after the shutdown of Three Mile lsland Nuclear Station, Unit 1. Three Mile lsland Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040. There are no contracts upon which the owners/licensees are relying pursuant to 10 cFR 50.75(eX1Xv). There are no modifications to the licensee's current method of providing financial assurance since the last submitted report. TMt-15-036 Page 2 of 4 7. 8. 9. 10. There were no amendments to the trust agreements for the above-mentioned owners of Three Mile lsland Nuclear Station, Unit 2. Site-Specific Cost Analysis Assumptions 10 CFR 50.75(eX1)(i), states, in part, that: A licensee that has prepaid funds based on a site-specific estimate under 50.75(bX1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate G based on a period of safe storage that is specifically described in the estimate. In accordance w1h Regulatory Guide 1.159, Revision 2, afacility specific analysis may be used to demonstrate the adequacy of decommissioning funds, provided that: NRC-required cost estimate for decommissioning costs, as defined in 10 CFR -50.2, is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(cX1) and (2). The site-specific radiological decommissioning cost estimate is $1,180,928,000 which is greater than the 10 CFd5O.75(c) cost estimate of $504,323,126. The analysis assumes a 2 percent yearly rate of return. 'The analysis also assumes a period of safe storage. The cash flows were contained in a decommissioning cost estimate that was prepared for Three Mile lsland Nuclear Station, Unit 2. The cash flow analysis assumes the yearly expenses are incurred at the beginning of year. Schedule 1 provides the site-specific analysis. The analysis values are in 2014 dollars. The analysis includes both the radiological and site restoration costs. Mathematical rounding was performed during the development of the supporting calculations.

References:

A. Decommissioning Cost Anatysis for Three Mite lstand lJnit 2, December 2014 B. Esca/a tion Anatysis for Three Mite tstand lJnit 2 2013 Sife-Specrfrc Decommissioning Cost Estimafe, February 2015 TMt-15-036 Page 3 of 4 Schedule 1 FIRSTENERGY CORP. Funding Analysis December 31,2014 THREE MILE ISLAND NUCLEAR

STATION, UNIT 2 Estimated Net Investment Rate Estimated Escalation Rate Estimated After-Tax Rate of Return Qualified Trust Balance on December 31,2014 Non-Qualified Trust Balance on December 31,2014 Total After-Tax 2.00o/o 2.00%

$732,529,228 $732,529,228 Year Beginning Balance Deposits Earnings Withdrawall Ending Balance 2015 732.529.228 14,463,385 (9.360.000)2 737,632,613 2016 737.632,613 14.690.092 (3.128.000) 749,194,705 2017 749,194,705 14.921.494 (3.120.000) 760,996,199 2018 760,996,199 15.157.524 (3.120,000) 773.033.723 2019 773,033,723 15.398.274 (3.120.000) 785.311.997 2020 785,311,997 15.643.680 (3.128.000) 797.827.677 2021 797.827.677 15.894.154 (3.120.000) 810,601,831 2022 810,601,831 16.149,637 (3.120.000) 823.631.467 2023 823,631,467 16.410.229 (3.120.000) 836.921.697 2024 836.921.697 16.675.874 (3.128.000) 850.469.571 2025 850.469,571 16.946,991 (3.120,000) 864.296.562 2A26 864.296,562 't7.223,531 (3.120,000) 878.400,093 2027 878.400.093 17.505.602 (3.120,000) 892,785,695 2028 892.785.695 17.793.154 (3.128,000) 907.450,849 2029 907.450,849 18,086,617 (3.120,000) 922.417,466 2030 922.417.466 18,385,949 (3,120,000) 937.683.415 2031 937.683,415 18,691,268 (3.120.000) 953,254,684 2032 953.254,684 19,002,534 (3.128.000) 969,129,217 2033 969,129,217 19.320.184 (3.120.000) 985,329,402 2034 985,329,402 19.644.188 (3.120,000) 1.001.853,590 2035 1.001.853.590 19.974.672 (3,120,000) 1.018.708.262 2036 1.018.708,262 20,311,605 (3.128,000) 1.035,891,867 2037 1,035.891.867 20.655.437 (3,120,000) 1.053.427,304 TMt-15-036 Page 4 of 4 Schedule 1 (Continued) Notes:

1. Withdrawal are assumed to be made at the beginning of the period.

2. The Decommissioning Cost Analysis for Three Mile lsland Unit 2, December 2014, had withdrawals for the years 2013 and 2014. Those withdrawals were included in the 2015 period.

Year Beginning Balance Deposits Earnings Withdrawall Ending Balance 2038 1.053,427,304 21.006.146 (3,120,000) 1.071.313,450 2039 1.071.313,450 21,363,869 (3.120,000) 1.089.557.319 2040 1,089,557,319 20.693,006 (54.907.000) 1,055,343,326 2041 1.055,343.326 19,291,187 (90,784,000) 983.850.512 2042 983.850.512 17.396,970 (114.002,000) 887,245,482 2043 887.245.482 15.464.870 (114,002,000) 788.708.352 2044 788.708.352 13,487,887 (114.314,000)687,882,239 2045 687,882,239 11.477.605 (114.002.000)585,357,844 2046 585.357.844 9.695.777 (100.569.000) 494.484.621 2047 494.484.621 8,387,952 (75.087,000) 427.785.573 2048 427,785,573 7.049.871 (75,292,000) 359.543.445 2049 359.543.445 5,689,129 (75,087,000) 290.145.574 2050 290.145.574 4,301,171 (75,087,000) 219.359.745 2051 219,359,745 2.934,615 f2.629.000) 149.665.360 2052 149.665,360 2.348.847 rc2,223,000) 119.791.207 2053 119.791.207 1,811,724 (29,205,000) 92.397.931 TOTAL n.221.478.000)

1.

2.

TMt-15-036 Three Mib lsland Nuclear Station, Unit 2 FinancialAssurance Status Report Page 1 of 1 Formal decommissioning has not started at the Three Mile lsland Nuclear Station, Unit 2. A special disbursement of decommissioning trust funds occurred in 2005 for $416,400.00. Notification of this use of decommissioning funds was made to the NRC by letter dated February 1, 2005 (Accession No. ML050380143). No funds were spent on decommissioning activities tn 2014. Decommissioning funds estimated to be required are based upon a site-specific decommissioning cost study, Decommissioning Cost Analysis for Three Mile lsland Unit 2, dated December 2014. and escalated to 2014 dollars:

3. The amount accumulated in external trust funds as of December 31,2014:

Radiological Non-Radiological FirstEnergy Corp. Consolidated Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated $1,180,928,000 40,560,000 $l-2ZlJtE8*000 After Tax $338,038,657 182,710,464 211.780.107 wj2*w.229 4. 5. There are no longer any funds to be collected from the ratepayers. There are no modifications to the licensee's current method of providing financial assurance since the last submitted report. There were no amendments to the trust agreements for the above-mentioned owners of Three Mile lsland Nuclear

Station, Unit 2.

Mathematical rounding was performed during the development of the supporting calculations.

8.

References:

A. Decommissioning Cost Anatysis for Three Mile lsland Unit 2, December 2414 B. Escalation Analysis for Three Mile lsland lJnit 2 2013 Site-Specific Decommissioning Cost Estimafe, February 2015 6. 7.

Enclosure A TMt-15-036 Decommissioning Cost Analysis for Three Mile lsland Unit 2, December 2014 (123 pages follow)

Document F07-1676-001, Rev, 0 DECOMMISSIOMNG COST ANALYSIS for THREE MILE ISLAND UNIT 2 prepared for FirstEnergy Corporation prepared by TLG Services,Inc. Bridgewater, Connecticut December 2014

Three Mile Island. Unit 2 D e c ontni e sion ing Co st An aly si s Fr*je*t*Iaqqg*r Project Engineer Sechnisal &fnmqsrer Document F07-1676-001, Rev. 0 Page ii of xuiii APPROVALS I &at*"*C 14,,L' n{ft,et I {,#i$,#'",, iSatc nl",lwvy D.tG TLG Sen:ices, Inc.

Three Mile Island. Unit 2 Decommissioning Cost Analysia Document F07-1676-001, Reu. 0 Page iii of xuiii 1. TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

"'..."""'vii'xviii INTRODUCTION 1-1 1.1 Objectives of Study ......1'1 L.2 Site Description....... .....I'2 1.3 Regulatory Guidance ...L'4 1.3.1 Nuclear Waste Policy Act........... ........ 1'5 I.3.2 low-Level Radioactive Waste Acts......... .....-.....L'7 1.3.3 Radiological Criteria for License Termination.......... .....-... 1'9 DECOMMISSIONING ALTERNATI\\'ES ...........2.I 2.L DECON... .....2-2 2.I.t Period 2 - Dormancy........... -....-..........2-2 2.L.2 Period 3 - Preparations .....2'3 2.I.3 Period 4 - Decommissioning Operations -..........2-5 2.L.4 Period 5 - Site Restoration............... ...................2-8 2.2 SAFSTOR and Delaved DECON ...........-......2-9 cosr ESTIIVIATE.............. 3-1 3.1 Basis of Estimate .........3-1 3.2 Methodology............. ..--3-1 3.3 Impact of Decommissioning Multiple Reactor Units ...3-3 3.4 Financial Components of the Cost Model............... ......3-4 3.4.L Contingency ..-...3'4 3.4.2 Financial Risk......... ...........3-7 3.5 Site-Specific Considerations......... ....'............3'8 3.5.1 Spent FueI Management..... ...............3-8 3.5.2 Reactor Vessel and Internal Components........... ...............3'9 3.5.3 Steam Generators............... ..............3'10 3.5.4 Other Primary System Components............... .3-11 3.5.5 Other Systems Known to Contain High Levels of Radioactivity.....3-12 3.5.6 Reactor Building Structures Decontamination..... ...........3.13 3.5.7 Demolition of Other Contaminated Structures......... ......3'14 3.5.8 MainTurbine and Condenser.......... .................3'14 2. 3. TLG Seruices, Inc.

Three Mile Island Unit 2 Decommissioning Cost Ana,lysie Document F07-1676-001, Reu. 0 Page iu of xuiii TABLE OF CONTENTS (continued) SECTION PAGE 3.5.9 Transportation Methods .3'I4 3.5.10 Low-Level Radioactive Waste Disposal ...........3'15 3.5.11 Additional Decommissioning Facilities ...........3-16 3.5.12 Remediation of Soil and Underground Piping .................3'17 3.5.13 Site Conditions Following Decommissioning ..3'17 Assumptions............. ..3-L7 3.6.1 Estimating Basis .............3'17 3.6.2 Labor Costs .....3-19 3.6.3 Design Conditions ............3-18 3.6.4 General... .........3-19 Cost Estimate Summarv.......... .3-20 SCHEDULE ESTIMATE............. .......4.1 4.I Schedule Estimate Assumptions............. .....4'L 4.2 Project Schedule.. .........4'2 RADIOACTIVE WASTES ...5.1 RESLTLTS ...........6-1 REFERENCES......... ...........7-r 3.6 3.7 5. 6. 7. TLG Seruices, Inc.

Three Mile Island Unit 2 D ecommissioning Cost Analysis SECTION 1.1 L.2 1.3 3.1 3.2 3.3 5.1 5.2 5.3 6.1 6.2 6.3 4.r 4.2 4.3 4.4 A. B. C. D. E. TABLE OF CONTENTS (continued) Document F07-1676-001, Rev. 0 Pa,ge v of xviii PAGE TABLES Summary of Decommissioning Cost Elements, DECON.......... .... xvi Summary of Decommissioning Cost Elements, Delayed DECON................ xvii Summary of Decommissioning Cost Elements, SAFSTOR...... ... xviii Inventory of Spent Fuel, Auxiliary and Fuel Handling Buildings..............1'10 Inventory of Spent Fuel, Reactor Building 1-12 Inventory of Spent Fuel, Reactor Coolant System ..... 1'13 Schedule of Total Annual Expenditures, DECON............. ..........3-2L Schedule of Total Annual Expenditures, Delayed DECON ........3'23 Schedule of Total Annual Expenditures, SAFSTOR........ ...........3'25 Decommissioning Waste Summary, DECON ................5'5 Decommissioning Waste Summary, Delayed DECON... ...............5-6 Decommissioning Waste Summary, SAFSTOR.............. ...............5-7 Summary of Decommissioning Cost Elements, DECON.......... ....6'3 Summary of Decommissioning Cost Elements, Delayed DECON.................6-4 Summary of Decommissioning Cost Elements, SAFSTOR...... .....6-5 FIGURES Activity Schedule ..........4'3 Decommissioning Timeline, DECON ...........4'4 Decommissioning Timeline, Delayed DECON... ...........4'5 Decommissioning Timeline, SAFSTOR .......4'6 TMI-2 Waste Streams Summary ..................5'3 Decommissioning Waste Destinations fr,adiological) ...................5-4 APPENDICES Unit Cost Factor Development............ A'1 Unit Cost Factor Listing..... B-1 Detailed Cost Analysis, DECON.............. C-l Detailed CostAnalysis, Delayed DECON ........D-l Detailed Cost Analysis, SAFSTOR........... ........ E-l 5.1 5.2 TLG Sensices, Inc.

Three MiIe Island. Unit 2 D e cotnmi esionin g Co st An a Iy si s Document F07-1676-001, Reu. 0 Page vi of xviii REVISION LOG Item nevisCd. 0 T2.TT.L4 Original Issue TLG Serttices, Inc.

Three Mile Island, Unit 2 D e commissioning Co st An aly sie Document F0 7-1 6 76-00 7' Reu. 0 Page vii of xuiii E)GCUTIVE

SUMMARY

This report presents estimates of the cost to decommission the Three Mile Island, Unit 2 nuclear unit (TMI-2) for the selected decommissioning scenarios following the scheduled cessation of plant operations at the adjacent Unit 1 reactor. This analysis relies upon site-specific, technical information, originally developed in an evaluation for the GPU Nuclear Corporation in 1995-96,t11 and last updated in 2008 for FirstEnergy.tzl fhs analysis has been further 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 the FirstEnerry Corporation with suffi.cient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear unit. The decommissioning of TMI-2 is a continuation of the decontamination efforts started in the 1980s, following its accident. The ultimate goal of the decommissioning is to remove the radioactive material from the site that would preclude its release for unrestricted use. The estimates are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, radioactive waste disposal options, and site remediation requirements. The estimates also include the dismantling of non-essential structures and limited restoration of the site. Alternatives and Reeulations The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.t31 In this rule, 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. "Decommissioning Cost Estimate for the Three Mile Island, Unit 2," Document No. G01'1196-003, TLG Services, Inc., February 1996. "Decommissioning Cost Estimate for Three Mile Island lJnit 2," Document No. F07-1601-002, TLG Services, Inc., January 2009. 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. TLG Seruices, Inc,

Three MiIe Island. Unit 2 D ecorntnissioning Co st Analysis Docurnent F07-1676-001, Rev. 0 Page uiii of xuiii 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 levet that permits the property to be released for unrestricted use shortly after cessation of opel'4f,ieng.r'[41 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 usg."[5] 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 defi.ned as "the alternative in which radioactive contaminants are encased in a structurally long-Iived 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."t6l As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years. The 60-year restriction has limited the practicality of 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 identifr 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 pending the completion of additional research studies, e.9., on engineered barriers. In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants to clarify ambiguities and codifr procedures and terminology as a means of enhancing effrciency and uniformity in the decommissioning process. tzl 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 stafffor implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning Ibid. Page FR24022, Column 3. Ibid Ibid. Page FR24023, Column 2. 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. 4 5 7 TLG Serttices, Inc.

Three MiIe Island Unit 2 D e c otnmissioning Co st An aly eis Docurnent F07-1676-001, Reu. 0 Page ix of rviii process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. Decommissionine Scenarios Three decommissioning scenarios were evaluated for the nuclear unit. The two delayed dismantling scenarios, Delayed DECON and SAFSTOR, include some consideration of the decommissioning activities planned at the adjacent Unit 1. The scenarios selected are representative of alternatives available to the owner and are defined as follows: DECON: The adjacent TM-l is promptly decommissioned upon the scheduled cessation of operations in 2034. TM-2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040. The decommissioning program for TMI-2 runs independently from the TMI-I decommissioning effort; license termination of Unit 2 occurs in 2053, approximately 10 years after Unit 1 completes its decommissioning program (exclusive of the on-site ISFSI operations for Unit 1 fuel). Delayed DECON: One of the decommissioning alternatives for Unit 1 is to defer decommissioning until the spent fuel has been removed from the site.t8l This scenario assumes that the decontamination and dismantling activities at TMI-2 are synchronized with the adjacent unit such that the licenses for both units are terminated concurrently. SAFSTOR: In the second scenario, TMI-1 is placed into long-term storage. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit 1. As with the first scenario, termination of the licenses is coordinated. The scenarios consider that Exelon Generation has extended the operating license at the adjacent Unit I to 2034. The scenarios are also based upon the premise that decommissioning work at Unit 2 would not begin prior to final shutdown of Unit I in 2034, consistent with the agreement between Exelon and FirstEnerry. MethodoloeV The methodology used to develop the estimates described within this document follows the basic approach originally presented in the cost estimating guidelines tsl developed by the Atomic Industrial Forum (now Nuclear Enerry Institute). This reference Timelines for the Unit 1 decommissioning scenarios are included in Section 4 of this report. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986. 1. 2. 3. TLG Sentices, Inc.

Three Mile Island Unit 2 De commissioning Cost Analysis Document F07-1676-001, Reu. 0 Page x of xuiii 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 sched.ule. 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. Continsencv Consistent with cost estimating practice, contingencies are applied to the decontamination and. dismantling costs developed 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."tt0l 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 ind.ustry 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 in{lation in the cost of decommissioning over the time intervals identified for each scenario. 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 fi'rlly expended throughout the program. Inclusion of contingency is necessarT to provide assurance that sufficient funding will be available to accomplish the intended tasks. Low-Level Radioactive Waste Disposal The contaminated. and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is generally 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 Disposal Act' in 1980 and its ro Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239. TLG Seruices" Inc.

Three Mile Island, Unit 2 D e commi ssioning Co st An aly sis Docurnent F07-1676-001, Reu. 0 Pa.ge xi of xuiii Amendments of 1985, tttl the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. It was expected that groups of states would combine together to jointly deal with their radioactive wastes; these organizations are referred to as waste disposal compacts. Few approved facilities for the disposal of LLW are currently available. Construction of the newest facility, in Texas, is now complete and the facility was declared operational by the operator, Waste Control Specialists 0MCS), in November zOLl. The facility will be able to accept limited quantities of non-Compact waste; however, at this time the cost for non-Compact generators is being negotiated on an individual basis. All options and services currently available to FirstEnerry for disposition of the various waste streams produced by the decommissioning process were considered. The majority of the low-level radioactive waste designated for direct disposal (Class A t121) can be sent to Enerrysolutions'facility in Clive, Utah. Therefore, disposal costs for Class A waste were based upon FirstEnergy's agreement with EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream. The Texas facility is licensed to receive the higher activity waste forms (Classes B and C). As such, for this analysis, disposal costs for the Class B and C waste based upon the preliminary and indicative information on the cost for such WCS. Waste exceeding Class C limits Qimited to material closest to the reactor core, or material contaminated with spent fueI debris from the March 1979 accident) is generally not suitable for shallow-Iand disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste, referred to as Greater Than Class C (GTCC)). The Low'Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. "Low-Level Radioactive Waste Poliry Amendments Act of 1985," Public Law 99-240, January 15, 1986 Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55 were from n TLG Services, Inc.

Three Mile Island. Unit 2 D e corntni ssioning Co st An aly sis Document F07-1670-001, Reu. 0 Page xii of xuiii For purposes of this analysis, this material is packaged in the same multipurpose canisters used for spent fuel storage/transport (e.g., at TMI-I) and designated for geologic disposal. The GTCC is shipped directly to a disposal facility as it is generated. 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-Ievel 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. Material removed during decommissioning that is free of contamination will be designated for conventional disposal or reuse / recovery. Fuel-Bearine Waste Management There will be some wastes generated in the decommissioning of TMI-2 that are not suitable for shallow land burial and therefore cannot be shipped for disposal to EnergySolutions. This material, primarily associated with systems and structures contaminated with fuel debris, requires greater isolation from the environment. For estimating purposes, a geologic waste repository, or some interim storage facility, is assumed to be available for the disposal of this material. Congress passed the "Nuclear Waste Policy Act" (NW.PA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The DOE was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made. Today, the country is at an impasse on high-level waste disposal, even with the License Application for a geologic repository submitted by the DOE to the NRC in 2008. The current administration has cut the budget for the repository program while promising to "conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle... and make recommendations for a new plan."[l3] Towards this goal, the administration appointed a Blue Ribbon Commission on America's Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commission's charter 13 Blue Ribbon Commission on America's Nuclear Future Charter, http://cvbercemeterv.unt.edu/archive/brc/20120620215336/httn:l/brc.eov/index.php?q=paee/charter TLG Services, Inc.

Three Mile Island. Unit Z D e commission ing Co st An aly si s Docurnent F07-1676-001, Rev. 0 Page xiii of xviii includes a requirement that it consider "[o]ptions for safe storage of used nuclear fuel while final disposition pathways are selected and deployed."tt4l On January 26, 2OI2, the Blue Ribbon Commission issued its "Report to the Secretary of Enerry" containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are: o "[T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage fsgilfliss"ttrl o "[T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear 1ryasf,s."[16l In January 2013, the DOE issued the "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission and as 'oa framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear f11s1..."[171 "With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next L0 years that: o Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2O2l with an initial focus on accepting used nuclear fuel from shut-down reactor sites; Advances toward. the siting and licensing of a larger interim storage facility to be available by 2O25 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and 14 Ibid. "Blue Ribbon Commission on America's Nuclear Future, Report to the Secretary of Energy," http://www.brc.gov/sites/default/files/documents/brc finalreoort ian2012.pdf, p. 32, January 2012 Ibid., p.27 "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S. DOE, January 11, 2013 16 17 TLG Seruices,Inc.

Three MiIe Island. Unit 2 D ecommissioning Cost Analysis Docutnent F07-rc7e-001' Reu, 0 Page xiv of xuiii o Makes demonstrable progress on the siting and characterization repository sites to facilitate the availability of a geologic repository 2049.Dt18t Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program had assumed that spent fuel allocations would be accepted for disposal from the nation's commercial nuclear plants, with timited exceptions, in the order (the "queue") in which it was discharged from the 1sssfe1.[lel The estimates for TMI-2 assume the timely removal of waste designated for geologic disposal, without the need for interim on site storage (once containerized). Site Restoration The effi.cient removal of the contaminated materials at the site may result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities will substantially damage power block structutes, 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. The site is then backfilled, graded and stabilized. Summarv The costs to decommission TMI-2 are evaluated for three decommissioning scenarios. Regardless of the timing of the decommissioning activities, the estimates assume the eventual removal of all the contaminated and neutron-activated plant components and Ibid., p.2 U.S. Code of Federal Regulations, Title 10, Part 961. 11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a)... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance..." of by 18 19 TLG Seruices, Ine.

Three Mile Ieland Unit 2 D e c omtni ssion ing Co st An aly sis Docutnent F07-1676-001' Reu. 0 Page xv of xuiii structural materials, such that the facility operator may then have unrestricted use of the site with no further requirement for an license. The scenarios analyznd 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 identifi.ed 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. TLG Seruiees, Inc.

Three Mile Island Unit 2 D e commi seioning Co st An aly sis Docum.ent F07-1676-001, Reu. 0 Page xui of xviii DECON COST SUMMARI DECOMMISSIONING COST ELEMENTS (thousands of 2013 dollars) Cost Element Total Decontamination 35,403 Removal 189.064 Packaeine 28.008 Transportation 26,427 Waste Disnosal 276.1.L2 Off-site Waste Processine 11.053 Program Managemsnf ttl 484.509 Securitv 55,590 Insurance and ReEulatorv Fees r5.766 Enererv 18.061 Characterization and Licensins Surveys L0.844 Propertv Taxes 0 Miscellaneous Equipment 23.851 Site O&M 4,968 PDMS MonitorinE 8"908 fefal tzl 1.188,564 Cost Element NRC License Termination 1.149.098 Site Restoration 39.467 fsfsl tzl 1.188.564 trl I2l Includes engineering costs Columns may not add due to rounding TLG Seruices,Inc.

Three Mile Island Unit 2 D e commissioning Co st An aly si s Docurnent F07-1676-007, Reu, 0 Page xvii of xuiii DELAYED DECON COST

SUMMARY

DECOMMISSIOMNG COST ELEMENTS (thousands of 2013 dollars) l1l l2l 131 Includes dormancy costs following TMI-1 shutdown in 2034 Includes engineering costs Columns may not add due to rounding Cost Element fgfalttl Decontamination 35.321 Removal 190.858 Packasine 28.007 Transportation 26.310 Waste Disposal 276.022 Off-site Waste ProcessinE 11.053 Program Managemsnf I2l 472.755 Securitv 46.850 Insurance and ReEulatorv Fees 21.899 Energy L9.459 Characterization and Licensins Surveys L0.844 Propertv Taxes 0 Miscellaneous Eouinment 26.259 Site O&M 4.968 PDMS Monitorine 6.949 Total t31 1,L77,554 Cost Element License Termination 1,139,536 Site Restoration 38.018 Total t31 L.r77.554 TLG Sentices, Inc.

Three fuIiIe Island. Unit 2 D e commissioning Co st An aly si s Docurnent F07-167G001, Reu, 0 Page xuiii of xuiii SAFSTOR COST

SUMMARY

DECOMMISSIOMNG COST ELEMENTS (thousands of 2013 dollars) t{ t2) t3I Includes dormanry costs following TMI-1 shutdown in2034 Includes engineering costs Columns may not add due to rounding Cost Element Totalttl Decontamination 35,286 Removal 196.595 Packaeine 28.065 Transportation 26.298 Waste Disnosal 275.884 Off-site Waste Processins 11,206 Prosram Manasemsnf [21 482.930 Securitv 56.699 Insurance and Reeulatory Fees 4t.497 EnerEv 28,227 Characterization and Licensing Surveys 1,0,844 Pronertv Taxes 0 Miscellaneous Equipment 33,617 Site O&M 4,968 PDMS Monitorins 6,949 Total t3I 1,239,065 Cost Element License Termination L,20L,047 Site Restoration 38.018 Total tsl 1.239.065 TLG Seruices,Inc.

Three Mile Island. Unit 2 D ecomtniesioning Co et Analyeis Document F07-1670-001, Reu. 0 Section 1, Page I of 13

1. INTRODUCTION This report presents estimates of the cost to decommission the Three Mile Island Unit 2 nuclear unit (lMI -2) fot the scenarios described in Section 2. This analysis relies upon site-specific, technical information, originally developed in an evaluation for the GPU Nuclear Corporation in 1995-96 [1]*, and last updated in 2008 for FirstEnergy Corporation.tzl Jhs analysis is designed to provide the FirstEnerry Corporation with sufficient information to assess its 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 objective of this study was to prepare estimates of the cost, schedule, and waste volumes generated to decommission TMI-Z, including all areas affected by the March 1979 accident. Three decommissioning scenarios were evaluated for TMI-2. In the delayed scenarios (Delayed DECON and SAFSTOR) decommissioning activities are coordinated to some extent with the adjacent operating unit (TMI-1 or Unit 1). The scenarios consider that Exelon Generation has extended the operating license for Unit I to 2034. The three scenarios are also based upon the premise that decommissioning work at Unit 2 would not begin prior to final shutdown of Unit 1 in 2034, consistent with the agreement between Exelon and FirstEnergy. DECON The adjacent TMI-I is promptly decommissioned upon the scheduled cessation of operations in 2034. TMI-2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040. The decommissioning program for TMI-2 runs independent from the TMI-I decommissioning effort; license termination of Unit 2 occurs in 2053, approximately 10 years after Unit 1 completes its decommissioning program (exclusive of the on-site ISFSI operations for Unit I fuel). Delayed DECON Decommissioning of TMI-2 commences upon the removal of TMI-1's spent fuel from the site in 2051. The decommissioning program for TMI-2 runs concurrently with the TMI-I decommissioning effort and concludes with the termination of both licenses. " Annotated references for citations in Sections 1-6 are provided in Section 7. TLG Serpices, Inc.

Three Mile Island Unit 2 D ecomrnissioning Cost Analysis Docutnent F07-1670-001' Reu. 0 Section 7,Page 2 of 13 SAFSTOR TMI-I is placed into safe-storage with decommissioning deferred 60 years. TMI-2 remains in storage with decommissioning deferred until it can be sequenced with TMI-I. The decommissioning program for TMI-2 runs concurrently with the TMI-I decommissioning effort and concludes with the termination of both licenses. L.2 SITE DESCRIPTION TMI-Z is located on the northern-most section of Three Mile Island near the east shore of the Susquehanna River in Dauphin County, Pennsylvania. The station is comprised of two pressurized water reactors. This study specifically addresses the decommissioning requirements for Unit 2, although the timing of each scenario is dependent upon the associated activities at the adjacent unit. The nuclear steam supply system (NSSS) consists of a pressurized water reactor rated at a core thermal power level of 2772MWth with a corresponding turbine-generator gross output of 959 MWe. The NSSS consists of the reactor with two independent primary coolant loops, each containing two reactor coolant pumps and a steam generator. An electrically heated pressurizer and connecting piping complete the system. The system is housed within a steel' lined, post-tensioned concrete structure (reactor building) in the shape of a right, vertical cylinder with a hemispherical dome and a flat, reinforced concrete basemat. A welded steel liner plate, anchored to the inside face of the reactor building, serves as a leak-tight membrane. Heat produced in the reactor was converted to electrical energy by the turbine generator system. This system converted the thermal energy of the steam into mechanical shaft power and then into electrical energy. The turbine-generator is a tandem-compound design, consisting of one double-flow, high pressure turbine and two double-flow, low-pressure turbines driving a directly coupled generator at 1800 rpm. The turbine operated in a closed feedwater cycle where steam was condensed, feedwater heated, and ultimately returned to the steam generators. Heat rejected in the main condensers was removed by the condenser circulating and river water systems. The condenser circulating water was cooled in two hyperbolic natural draft cooling towers located to the east of the station. The towers provided the heat sink required for removal of waste heat in the power plant's thermal cycle. Cooling tower blowdown was discharged to the Susquehanna River. TMI-2's operating license was issued on February 8, 1978, with commercial operation declared on December 30, 1978. On March 28, 1979, the unit TLG Seruices, Inc.

Three Mile Island Unit 2 D e c otnmi seionin g Co st,4n alyeie Document F07-1676-007, Reu. 0 Section 7,Page 3 of I3 experienced an accident initiated by interruption of secondary feedwater flow. The steam generator boiled dry, resulting in the reducti.on of primary-to-secondary heat exchange. This caused an increase in the primary coolant temperature, creating a surge into the pressurizer, and an increase in system pressure. The pilot operated relief valve (POR\\D opened to relieve the pressure, but failed to close when the pressure decreased. The reactor coolant pumps were turned off and a core heat-up began as the water level decreased to uncover the top of the core. The melting temperature of the zircaloy fuel cladding was exceeded, resulting in relocation of the molten zfucaloy and some liquefied fuel to the lower core regions, solidifying near the coolant interface. Based on the end-state core and core support assembly configuration and supporting analysis of the degraded core heat-up, it is believed that as the crust failed, molten core material migrated to the lower internals. The majority of the molten material flowed down through the region of the southeastern assemblies and into the core bypass region. A portion of the molten core material flowed around the bypass region and migrated down into the lower internals and lower head region. Limited damage to the core support assembly occurued as the core material flowed to the lower plenum. It is estimated that about L7 - 20 tons of material relocated to the lower internals and lower head region. Several in-core instrument guide tubes were melted but overall vessel integrity was maintained throughout the accident. As a result of this accident, small quantities of core debris and fission products were transported through the RCS and the reactor building as a result of the coolant flow through the PORV and the makeup and purification system (X{U&P) during the accident. In addition, a small quantity of core debris was transported to the auxiliary and fuel handling buildings (AFHB) via the MU&P. Further spread of the debris also occurred as part of the post-accident water processing cleanup activities. GPU Nuclear conducted a substantial program to defuel the reactor vessel and decontaminate the facility. As a result, TMI-2 has been placed in a safe, inherently stable condition suitable for long-term management, and any threat to the public heatth and safety has been eliminated. Fuel and core material removed in the defueling has been shipped off site. The current long-term management condition is termed Post-Defueling Monitored Storage (PDMS). The costs for maintaining TMI-2 in this state from 2013 until the shutdown of Unit 1 in 2034 (PDMS is continued until 204O for the DECON scenario) is included in the cost estimates in this analysis. Substantial contaminated areas still exist on site, as well as trace quantities of spent nuclear fuel (SNF). Several cubicles in the auxiliary and fuel handling buildings remain locked, and the basement of the reactor building has been TLG Sentices, Ine.

Three Mile Island, Unit 2 Decomm.issioning Cost Analysis Document F07-1676-001, Rev. 0 Seeti'on I, Page 4 of I3 uninhabitable since the accident. The quantity of fuel remaining at TMI'2 is a small fraction of the initial fuel load; approximately 99% was successfully removed in the defueling. Additionally large quantities of radioactive fi.ssion products were released into various systems and structures. Most of this radioactivity was removed as part of the waste processing activities during the TMI-2 Clean-up Program which concluded with entry into Post-Defueling Monitored Storage in December 1993. Significant quantities of radioactive fission products were removed from the reactor coolant system in preparation for the PDMS. However, the remaintng Lo/o of the fuel and the remaining fission products pose unique problems in completing the decommissioning of TMI-2. A summary of the quantity and suspected location of the remaining fuel debris is provided in Tables 1.1 through 1.3. 1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial d.ecommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988 t31. This rule set forth fi.nancial criteria for decommissioning licensed nuclear power facilities. The regulation ad.dressed 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,"[al which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule. The rule defi.ned three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative, the option evaluated. for this analysis, assumes that any contaminated or activated portion of the plant's systems, structures, and facilities are removed or d.econtaminated 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 Ieverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the defrnition of TLG Seruices, Inc.

Three Mile Island. Unit 2 D e c ommi ssionin g Co st An aly ei e Document F07-1676-001, Rev. 0 Section 7, Page 5 of I3 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 signifrcant remediation to meet the unrestricted release limits for license termination. To use a decommissioning scenario in which the license has not been terminated within 60 years of the frnal shutdown date, FirstEnergy will need Commission approval pursuant to 10 CFR 50.82(a)(3) for completion of decommissioning beyond 60 years. 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.Fl 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.[6] However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. Rulemaking has been deferred pending the completion of additional research studies, e.g., on engineered barriers. However, this study assumes that the ENTOMB alternative is a viable option for TMI-2 and that a storage period of 100 years would be acceptable. The NRC published revisions to the general requirements for decommissioning nuclear power plants in 1996.t71 When the regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facility's licensed life. Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codifu 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. 1.3.1 Nuclear Waste Policv Act Congress passed the Nuclear Waste Policy Actt8l in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The DOE was to begin accepting spent fuel by January 31, 1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made. TLG Services, Inc.

Three MiIe Island. Unit 2 De commissioning Co st Anabeis Docutnent F07-1676-001' Reu. 0 Section I, Page 6 of 18 Today, the country is at an impasse on high-level waste disposal, even with the License Application for a geologic repositoly submitted by the DOE to the NRC in 2008. The current administration has cut the budget for the repository program while promising to "conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle... and make recommendations for a new plan."[e] Towards this goal, the administration appointed a Blue Ribbon Commission on America's Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commission's charter includes a requirement that it consider "[o]ptions for safe storage of used nuclear fuel while final disposition pathways are selected and deployed." On Januaty 26,2012, the Blue Ribbon Commission issued its "Report to the Secretary of Enerry" containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are: o "[T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage facilities"[10] o "[T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear waste." In January 2013, the DOE issued the "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nucls6l fus1..."[l11 "With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next L0 years that: Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2021, with an initial focus on accepting used nuclear fuel from shut-down reactor sites; o Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system TLG Seruices, Inc.

Three MiIe Island, Unit 2 D e comnt ission ing Co st An aly si s Docurnent F07-1670-001' Reu. 0 Section 1, Page 7 of 13 and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and o Makes demonstrable progress on the siting and characterization of repository sites to facilitate the availability of a geologic repository by 2O48." Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program had assumed that spent fuel allocations would be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the lsssfsr.u2l The estimates for TMI-2 assume the timely removal of waste designated for geologic disposal, without the need for interim on site storage (once containerized). 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 generally 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 Disposal Acl"[13] 111 1980 and its Amendments of 1985, ttal the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. It was expected that groups of states would combine together to jointly deal with their radioactive wastes; these organizations are referred to as waste disposal compacts. Few approved facilities for the disposal of LLW are currently available. Construction of the newest facility, in Texas, is now complete and the facility was declared operational by the operator, Waste Control Specialists flMCS), in November 2011. The facility will be able to accept limited quantities of non-Compact waste; however, at this time the cost for non-Compact generators is being negotiated on an individual basis. AII options and services currently available to FirstEnergy for d.isposition of the various waste streams produced by the decommissioning process were considered. The majority of the low'level radioactive waste designated for direct disposal (Class A t15l) can be sent to Energy Solutions' facility in Clive, Utah. Therefore, disposal costs for Class A waste were based upon FirstEnergy's agreement with TLG Serpicee, Inc.

Three Mile IslandUnit 2 D ecommissioning Cost Analysie Document F07-1676-001, Reu, 0 Section I, Page 8 of I3 EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream. The Texas facility is licensed to receive the higher activity waste forms (Classes B and C). As such, for this analysis, disposal costs for the Class B and C waste were based upon the preliminary and indicative information on the cost for such from WCS. Waste exceeding Class C limits (imited to material closest to the reactor core, or material contaminated with spent fuel debris from the March 1979 accident) is generally not suitable for shallow-land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste, referred to as Greater Than Class C (GTCC). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. For purposes of this analysis, this material is packaged in the same multipurpose canisters used for spent fuel storage/transport (e.g.' at TMI-I) and designated for geologic disposal. The GTCC is shipped directly to a disposal facility as it is generated. 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-Ievel 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. TLG Services, Inc.

Three Mile Island. Unit 2 D e c ommi.ssion ing Co at.$t alyeia Document F07-1676-007, Reu. 0 Section 1, Page I of 13 1.3.3 Radioloeical Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination," amending 10 CFR S20. 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 (AI"ARA). The decommissioning estimates for TMI-2 assume that the site will be remediated to a residual level consistent with the NR0-prescribed level. 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).ttel An additional limit of 4 millirem per year, as defined in 40 CFR S141.16, is applied to drinking water.trzl On October 9,2OO2, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-Iicensed sites. The Memorandum of Understanding (N{OID ttel 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. TLG Seruices, Inc.

Three Mile Island. Unit 2 D ecomrnissioning Coet Analysis Document F07-1676-007, Reu. 0 Sectinn 7, Page 10 of 13 TABLE 1.1 INI\\MNTORY OF SPENT FUEL AI.XILIARYAND FUEL HANDLING BUILDINGS I19] SNF Cubical Location Quantity (s) AX004 Seal Injection Valve Room 30 AX006 Make-up Pump 18 70 AX007 Make-up Pump 1A 230 AX015a Cleanup Filters 50 AX015b Cleanup Filters 50 AX114 MU&P Demineralizer 1A 1,060 AX115 MU&P Demineralizer 18 130 AX019 Waste Disposal Liquid Valve Room 10 FH001 MU Suction Valve Room 460 AX012 AB Sump Tank Room 100 AX020 Reactor Coolant Bleed Tank 18 I,754 AX020 Reactor Coolant Bleed Tank lC L,754 AX021 Reactor Coolant Bleed Tank 1A 310 AX024 AB Sump Filters 20 AX112 Seal Return Coolers and Filter Room 300 AX116 Makeup Tank Room 310 AX117 MU&P Filter Room 60 AX131 Miscellaneous Waste Tank Room 100 AX128 Instrument and Valve Room 10 AX218 Concentrated Waste Storage Tanks 10 AX501 RB Spray Pump 1A 10 AX502 RB Spray Pump 18 10 AX503 DHR Pump 1A 10 AX504 DHR Pump 18 10 FH003a MU Discharge Valves 10 FH003b MU Discharge Valves 100 FH004 Westinghouse Valve Room 160 TLG Services, Inc.

Three MiIe Island Unit 2 Decommissioning Co st Analysis Cubical FH101 FH112 FH1O9 TABLE 1.1 (continued) INVENTORY OF SPENT FUEL AI.XILIARY AND FUEL HANDLING BUILDINGS Document F07-1676-001, Rev. 0 Seetion l,Page 11 of 13 SNF Quantity (.e\\ 324 10 3,800 L70 40 I1,460 Location MU&P Valve Room Annulus Spent Fuel Pool "A" Embedded Valves & ([tIU System) Embedded Valves & (WDL System) TOTAL Piping Piping TLG Seruices, Inc.

Three MiIe laland. Unit 2 D e c omnr.issioning Co st An aly sis Document F07-1676401, Reu, 0 Section I,Page 12 of 13 TABLE 1.2 II\\IVENTORY OF SPENT FUEL REACTOR BUILDING Area/Component Reactor Vessel RV Head Assembly RV Upper Plenum Assembly FueI Transfer Canal Core Flood System "A" D-ring Upper Endfitting Storage Area Reactor Coolant Drain Tank Letdown Coolers RB Basement and Sump Tool Decontamination Facility (347') Defueling Water Cleanup System Defueling Tool Rack Temp React Vessel Filtration System RB Drains Total SNF Quantity (g) 925,000 1,300 2,r00 18,900 4,900 21,000 5,900 100 3,700 1,300 100 3,700 600 4,400 5,100 998,100 TLG Seruices, Inc.

Three Mile Island Unit 2 Decommissioning Coet Anolysis TABLE 1.3 INVENTORY OF SPENT FUEL REACTOR COOLANT SYSTEM Docwnent F07-1676-001, Reu. 0 Section 7,Page 13 of I3 SNF Quantitv (s) 500 1,500 1,400 1,700 4,000 900 7,200 600 36,000 9,100 10,100 1,800 2,400 400 4,600 6,200 88,400 Component Pressurizer (including surge line) Decay Heat Drop Line "A" SIDE OTSG Upper Tubesheet Tube Bundle Lower Head and J-legs Hot Legs Cold Legs Core Flood Line UB" SIDE OTSG Upper Tubesheet Tube Bundle Lower Head and J-legs Hot Legs CoId Legs Core Flood Line RCS Surface Films Reactor Coolant Pumps TotaI TLG Sert:ices, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1676407, Reu. 0 Section 2, Page I of I

2. DECOMMISSIOMNG ALTERNATIVES Detailed cost estimates were developed to decommission TMI-2 for three scenarios.

Although the alternatives differ with respect to technique, process, cost, and schedule, they attain the same result: the ultimate release of the site for unrestricted use. Three decommissioning cost scenarios were evaluated for the nuclear unit. The scenarios assume that Exelon will operate the adjacent Unit 1 until its license expiration date in 2034. The scenarios are defrned as follows: DECON: The adjacent TMI-I is promptly decommissioned upon the scheduled cessation of operations in 2034. TMI-2 transitions from a PDMS status to decommissioning in 2040. The decommissioning program for TMI'2 runs concurrently with the TMI-1 decommissioning effort; license termination of Unit 2 occurs in 2053, approximately 10 years after Unit 1 completes its decommissioning program (exclusive of the on-site ISFSI operations for Unit 1 fuel). Delayed DECON: Unit 1 defers decommissioning until its spent fuel has been removed from the site. This scenario assumes that the decontamination and dismantling activities at TMI-2 are synchronized with the adjacent unit such that the licenses for both units are terminated concurrently. SAFSTOR: TMI-I is placed into long-term storage. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit

1. As with the first scenario. termination of the licenses is coordinated.

The nomenclature for these three scenarios is consistent with the Unit 1 decommissioning cost estimate. For each of the scenarios, Post-Defueling Monitored Storage (PDMS) costs of approximately $3.1 million per year have been included from 2013 until Unit 1 shutdown in 2034 (DECON continues the PDMS charges until 2040). Other decommissioning costs (including dormancy costs for the Delayed DECON and SAFSTOR scenarios) are only accrued following TMI-1 shutdown. The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase addresses the transition of reactor operations (i.e., power production) to facility de-activation and closure. 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. 1. 2. 3. TLG Serwices, Inc,

Three Mile Island. Unit 2 D ecotnmissioning Co st Analysis Docurnent F07-1676-001' Rev. 0 Section 2, Page 2 of I The decommissioning estimates developed for TMI-Z 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. The following sections describe the basic activities associated with each alternative. The three scenarios are essentiatly identical; all being variations of the NRC's SAFSTOR scenario following a dormancy period. The technical assumptions are unchanged with the only difference in the second and third scenarios being the delay in start of decommissioning expenditures and the additional storage cost during the delay period. Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work, i.e., engineering and planning at the time of decommissioning. The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both nuclear unit and licensee from reactor operations (i.e., power production) to facilitate de-activation and closure. This phase was completed when TMI-2 began the PDMS phase; the plant is in SAFSTOR dormancy. 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 TMI-2 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 As stated previously, the naming convention of the three Unit 2 decommissioning scenarios is consistent with the Unit 1 decommissioning scenarios. This scenario runs concurrent with the Unit 1 DECON scenario, and therefore is referred to as DECON for Unit 2, even though the unit is currently in SAFSTOR dormancy. 2.7.7 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 PDMS phase from 2013 to 2040 for the DECON alternative (the delayed scenarios TLG Seruices, Inc.

Three Mile Island. Unit 2 D ecomtnissioning Co st Analysis Docurnent F07-1676-001, Reu. 0 Seetion 2, Page 3 of I terminate PDMS with Unit 1 shutdown, and begin a standard SAFSTOR dormancy program in 2034). TMI-2 has been in a dormant condition since entry into PDMS in December 1993. This estimate includes the yearly g3.1 million PDMS costs for maintaining TMI-2 until the start of decommissioning in 2040. Dormancy activities during PDMS includ.e a 24-hour security force (primarily provided by the operating Unit 1), preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. 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. Most site labor activities are provided by Exelon personnel under contract to FirstEnergy. 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. Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public from the consequences of its own actions. Security is provided by fences, sensors, alarms, and other surveillance equipment. Fire and radiation alarms are also monitored. 2.L.2 Period 3 - Preparations Preparations include the planning for the removal of the remaining fuel' bearing components, decontamination of the structures and the dismantling of the remaining equipment and facilities. Typically, the process is described within a Post-Shutdown Decommissioning Activities Report (PSDAR) or a Decommissioning Plan (DP). Although the exact format and content of the decommissioning planning document has not been identified, as a minimum Technical Specification 3.2.l.L requires NRC approval prior to removal of greater than 42 kilograms of fuel from the reactor vessel. Thus in addition to the planning document, changes may be required to the existing technical specifications prior to the start of major decommissioning activities. TLG Seruices, Inc.

Three Mile Island. Unit 2 D e conm.issioning Co st An aly si s Eneineerine and Plannine The decommissioning program outlined in the PSDAR or DP will be designed to accomplish the required tasks within the AI,ARA guidelines (as defined in 10 CFR S20) for protection of personnel from exposure to radiation hazards. It wiII also address the continued protection of the health and safety of the public and the environment during the dismantling activity. Consequently, with the development of the decommissioning plan, activity specifrcations, cost-benefit and safety analyses, and work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities. The estimate assumes that FirstEnergy will provide project oversight. However, the majority of the professional, managerial, technical and administrative support staff will be provided by a decommissioning operations contractor @OC). Document F07-1676-001, Reu. 0 Section 2, Page 4 of I are Site Preparations In preparation for active decommissioning, the following initiated: Characterization of the site and surrounding environs. This includes radiation surveys of the reactor building including: the basement and elevator block wall area, areas surrounding major components (including the reactor vessel and its internals, steam generators), internal piping, and primary shield cores. Surveys of the auxiliary and fuel handling building with emphasis on areas with known and potential alpha contamination and know fission products. Surveys and sample analysis will also be performed on exterior buildings, land areas surrounding the facility, subsurface soil and groundwater. Specification of transport and disposal requirements for highly radioactive waste and/or hazardous waste, including shielding and waste stabilization. Development of procedures control and release of liquid radwaste (including dry-active waste, resins, filter media, metallic and non-metallic components generated in decommissioning), site security and emergency programs, and industrial safety. for occupational exposure control, and gaseous effluent, processing of TLG Senticee, Inc.

Three Mile Island Unit 2 D ecommissioning Co st Analysis Document F07-1676-001, Reu. 0 Section 2, Page 5 of I 2.L.3 Period 4 - Decommissionine Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and highly radioactive components and structures, including the successful termination of the 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. Refurbishment of the containment air control envelope building located outside the reactor building equipment hatch. A prefabricated metal containment building located on the 305' level of the reactor building will be required for the handling of highly contaminated material being removed from the basement or the operating deck elevations. Modification of the containment structure to facilitate handling of large equipment. This will include an evaluation to determine whether a temporary crane should be installed or whether the existing polar crane should be refurbished (the reactor vessel head wiII be the heaviest lift under the current removal scenario with the in-situ segmentation of the reactor vessel and steam generators). Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads and rail facilities (on' and off'site) to facilitate hauling and transport. Modifications may also be required to the refueling area of the building to support the segmentation of the reactor vessel internals and component extraction. Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling. Procurement Qease or purchase) of shipping canisters, cask liners, and industrial packages. Decontamination of components and structures as required to control (minimize) worker exposure. Decontamination of the reactor building so as to reduce working area dose rates and improve working conditions. The reactor building basement is known to be highty contaminated and will TLG Services, Inc.

Three Mile Island Unit 2 D ecommissioning Cost Analysia Document F07-1676-001' Reu. 0 Section 2, Page 6 of I require remote operations and tooling for the initial de contamination effort. Inventory, decontamination and removal of legacy equipment inventory lefb over from the defueling campaign. Installation of a water processing system to filter and treat water from the reactor coolant system and fuel handling pool. Removal of piping and components no longer essential to support decommissioning operations. Removal of control rod drive housings and the head service structure from reactor vessel head. Segmentation of the vessel closure head. Segmentation of the upper internals assemblies. The plenum is currently stored in the fuel transfer canal. Segmentation will maximize the loading of the shielded transport casks, i.e., by weight and activity. The operations are conducted under water using remotely operated tooling and contamination controls. Disassembly and segmentation of the remaining reactor internals, including the core former and lower core support assembty. All internals components below the top of the fuel are expected to exceed Class C disposal requirements due to fuel contamination. As such, the segments will be packaged in modifi.ed fuel storage canisters for geologic disposal. Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air using remotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Segments are transferred in' air to containers that are stored under water, for example, in an isolated area of the refueling canal. Removal of the steam generators and pressurizer for material recovery and controlled disposal. Due to the high internal and external radioactivity, these components can not serve as their own shipping containers. The steam generators are assumed to be segmented in-place. The pressurizer is assumed to be cut in half and shipped in a sealed and shielded shipping and burial container. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations. Removal of free standing concrete structures in the reactor building. TLG Services, Inc.

Three Mile Island Unit 2 D ecom,missioning Co st Analysis Document F07-1676-001, Rev, 0 Section 2, Page 7 of I Removal of the remaining internal structures within the reactor building including: the polar crane, inner pools and waII liners, biological shield, D-rings, floors and walls. At least two years prior to the anticipated date of license termination' a License Termination Plan (LTP) is required. Submitted as a supplement to the 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 wiII notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including: Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems). Processing of the structural material in the reactor, auxiliary and fuel handling buildings. Approximately 90% of the concrete removed at this stage is assumed to meet free release criteria. The remainder is sent to a waste processor. The free-released concrete is available as fill. Excess concrete is disposed of in an industrial landfill. Removal of contaminated yard piping and. any contaminated soil. Transfer of greater-than-Class C (GTCC) material to the DOE. Surveys of the decontaminated areas not designated for complete removal and disposal. Remediation and removal of the contaminated equipment and mateiial from the auxiliary and fuel buildings and any other contaminated facility. Certain areas in the auxiliary and spent fuel handling buildings contain very high contamination and radiation levels and will require additional resource and increased radiological protection to complete the decontamination. Radiation and. contamination controls will be utilized until residual levels indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems TLG Seruices, Inc. o a a

Three Mile Island, Unit 2 Decomrnissioning Co st Ana,lysis Doeument F07-1676-001, Rev. 0 Section 2, Page I of I and components (both clean and contaminated) located within these buildings. This activity facilitates surface decontamination and subsequent verifi.cation surveys required prior to obtaining release for demolition. Most of the power block structures @eactor, Auxiliary and Fuel Handling) will be removed to below the building foundations / basemat to ensure that no radioactive material remains on site. Material that is designated as scrap or general disposal (survey and release) is transferred to a designed waste processing vendor for a confirmatory survey and, if permitted, released for unrestricted disposition. 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 (MARSSI[0'"[20] This document incorporates the statistical approaches to survey design and data interpretation used by the EPA. It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the survey is complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on final termination of the license. The NRC wiII terminate the 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 facilitv is suitable for release. 2.I.4 Period 5 - 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 wiII result in substantial damage to many of the remaining structures. TLG Serttices, Inc.

Three Mile Island, Unit 2 De cornmissioning Co st Analysis Docurnent F07-fi7e00\\ Reu. 0 Section 2, Page I of I 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. 2.2 SAFSTOR and Delayed DECON The decontamination and. dismantling activities in this scenario are identical to those described in Section 2.L for DECON. However, the start of active decommissioning is deferred to coordinate with the timing of the Unit 1 Delayed DECON and SAFSTOR scenarios. As such, the presence of the dormancy period incurs storage costs (correspondingly greater for the SAFSTOR scenario, with its longer dormancy period). While it is expected that radiation dose levels will decrease over the duration of the longer dormancy period, the nature of radionuclides involved and the difficulties in working in plant areas contaminated with these radionuclides will require similar operational and radiological controls to those envisioned for earlier scenario. As such, there have been no changes incorporated into the costs to perform the field decommissioning activities identified in Section 2.1 for this scenario. Note that, with Unit I permanently shut down, there are dormancy costs for Unit 2 included in the estimate following the cessation of the PDMS charges in 2034. TLG Services, Inc.

Three Mile Island Unit 2 D e c omrn i ssi oning Co st An aly si s Document F07-1676-001, Reu, 0 Section 3, Page I of 27

3. COST ESTIMATE The cost estimates prepared for decommissioning TMI-2 consider the radiological status, unique conditions 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 rely upon site-specific, technical information originally developed in an evaluation prepared for the GPU Nuclear Corporation in 1995' 96, and last updated for FirstEnergy in 2008. 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. Some of the technical assumptions that were used are due to the unique nature and characteristics of the plant as a result of the March 1979 accident. Following the accident, TMI-2 was defueled and extensive decontamination activities were performed. This successfully removed approximately 99o/o of the original fuel and resulting fuel debris. Removal of the residual 1% was neither cost effective nor warranted due to the high radiation fields in the reactor building and adjoining auxiliary and fuel handling buildings. The remaining equipment and components containing spent nuclear fuel (SNF) will be removed, sealed and./or encapsulated in preparation for disposal during the decommissioning program. 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 pgf,imafss,r'[21] and the DOE "Decommissioning Handbook."t22] 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 TLG Seruices, Inc,

Three Mile Island Unit 2 D ecommissioning Co st Analyeis Document F0 7-16 76-00 1, Rev. 0 Section 3, Page 2 of 27 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.t2sl This analysis reflects lessons learned from TLG's 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 Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-l 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 Difficultv Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment and increase the time required to perform the activity. WDFs were assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confrned, hazardous environments. The WDF sets were developed considering the extremely difficult working conditions associated with working in high radiation areas and in areas with high alpha particle contamination. The same work difficulty factor sets were used for all three scenarios. This assumption was based upon the relatively high levels of long-lived radioactivity that exists today plus the high levels of alpha contamination. The factors and their associated range of values were developed in conjunction with the AIFA{ESP-036 study. The application of the factors is discussed in more detail in that publication. Given the radiological status of some areas at TMI-2, the range of the WDF's was increased. The ranges used for the WDFs are identified in the following table. TLG Serpices, Inc.

Three Mile Island, Unit 2 D e c onrniseion ing Co st An oly aie Document F07-1676-001' Reu. 0 Section S, Page 3 of 27 Work Difficulty Factors Other Power Block FueUAux Buildings Reactor Building NSSS Components Access Respiratory Protection Radiation/ALARA Protective Clothing Work Break 20o/o 0-25o/o L0-25o/o 0-30% 8.33o/o 30% 200o/o 40% 50o/o 8.33% 30% 50% 40% 50o/o 8.33o/o 40o/o 200% l00o/o 50% 8.33% Schedulins 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. As shown above, higher WDF's sets were assigned to systems located in the reactor building and to systems which contain SNF and/or high levels of radioactive materials. 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 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 IMPACT OF DECOMMISSIONING MULTIPLE REACTOR UNITS The DECON scenario for TMI-2 decommissioning operates independently from the adjacent Unit 2. The delayed decommissioning modes, Delayed DECON and SAFSTOR, consider opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities. There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitations on when final status surveys can take place. A summary of the principal impacts are listed below. TLG Seruices, Inc.

Three MiIe Island. Unit 2 D e c otnm i s sion in g C o st An aly si e Doeument F0 7-I 676-00 l, Reu. 0 Section 3, Page 4 of 27 Consistent with the agreement between FirstEnergy and Exelon regarding the timing of decommissioning activities at TMI'2, it is assumed that decommissioning at TMI-2 will not begin prior to 2O34. Under the terms of this agreement, decommissioning activities at Unit 2 cannot begin while Unit 1 is still in commercial operation. The decommissioning scenarios used in this analysis are structured to integrate to the extent possible with a Unit 1 decommissioning scenario. Since the security program for the site is likely to be an integrated approach, the security guard force is assumed to be shared to varying degrees between the units, depending upon the level of activities at each unit. This reduces the security costs for the decommissioning estimates for both units on site. The final radiological survey schedule is also affected by a two-unit decommissioning schedule. It would be considered impractical to try to complete the final status survey of Unit 1, while Unit 2 still has ongoing radiological remediation work and waste handling in process. As such, this analysis has structured the decommissioning scenarios for Unit 2 to coordinate the final status survev for the station. 3.4 FINANCIAL COMPONENTS OF THE COST MODEL TLG's proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration. 3.4.1 Contineency Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses. The activity-and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers "Project and Cost Engineers' TLG Services, Inc.

Three MiIe Island Unit 2 D e c otnnt i ssi onin g Co et An a ly si s Docunrent F07-1676-001, Rev, 0 Section 3, Page 5 of 27 Handbook"[24] 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 time intervals identffied for each scenario. 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, highly radioactive following the accident. 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 radioactive and highly contaminated with fuel debris. 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 TLG Seruices, Inc,

Three Mile Island Unit 2 D ecommissioning Coet Analysis Decontamination Contaminated Component Removal Contaminated Component Packaging Contaminated Component Transport Low-Level Radioactive Waste Disposal Reactor Segmentation NSSS Component Removal Reactor Waste Packaging Reactor Waste Transport Reactor Vessel Component Disposal GTCC Disposal Non-Radioactive Component Removal Heavy Equipment and Tooling Supplies Engineering Energy Characterization and Termination Surveys Construction Taxes and Fees Insurance Staffing Operations and Maintenance Expenses Document F07-1676-001, Reu. 0 Seetian 3, Page 6 of 27 50o/o 25o/o to% L5o/o 25% 75% 25o/o 25% 25% 5oo/o I5o/o t5% L5% 25o/o 15% 30% L5% L0% 10% rc% L5% 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 I0o/o to 75Yo, depending on the degree of difficulty judged to be appropriate foom TLG's actual decommissioning experience. The contingency values used in this study are as follows: 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 TLG Sentices, Inc.

Three Mile Island Unit 2 D e c o tnrni s sion ing Co st An aly ei s Docurnent F07-1676-001' frev, 0 Section 3, Page 7 of 27 national commitments, e.g., in the ability waste forms for disposition or in the the start and rate of acceptance of spent reported for the DECON alternative is 20.3%. Values for the other alternatives are delineated within the detailed cost tables in Appendices D and E. 3.4.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk. Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur. Consideration is sometimes necessarT to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term "frnancial risk." Included within the category offinancial risk are: Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, Iegal 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 to accommodate certain timetable for such, e.g., fuel by the DOE. Pricing changes for basic inputs, such as labor, energ'y, materials, and burial. Some of these inputs may vary slightly, e.g. 'L0o/o to +20%; burial could vary from -50% ta+204o/o or more. It has been TLG's 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 estimate's being too high is a low probability, and the chances that the estimate is too low is a higher probability. This is mostly due to the pricing uncertainty for low' level radioactive waste burial. and to a lesser extent due to schedule TLG Seruices,Inc.

Three Mile Island Unit 2 D e c ommi ssionin g Co st An aly sis Doeurnent F0 7-1676-00 I, Reu. 0 Section 3, Page 8 of 27 increases from changes in plant conditions and to pricing variations in the cost of labor (both crafb and staft). This cost study, however, does not include any additional costs for financial risk since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk should be revisited periodically and addressed through repeated revisions or updates ofthe base estimate. 3.5 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study. Unless otherwise noted, these assumptions are applicable to all three scenarios. 3.5.1 Spent Fuel Manaeement The cost to dispose of spent fuel generated from plant operations is not reflected within the estimates to decommission the TMI-2 site. The majority of the spent fuel was removed during the TMI'2 Clean'up Program's reactor vessel defueling effort which concluded in January 1990. Title to the spent fueI that was removed was transfened to the DOE. The remainder of the fuel (about lo/o) is dispersed within the primary system and to a lesser extent in other systems and structures. This residual material will be removed as radioactive waste and is included in the waste disposal volumes discussed in Section 5. Repository Availabilitlz There will be some wastes generated in the decommissioning of TMI-Z that are not suitable for shallow land burial and therefore cannot be shipped for disposal to either Waste Control Specialists or EnergySolutions. This material, primarily associated with systems and structures contaminated with fuel debris, requires greater isolation from the environment. The estimates for TMI-2 assume the timely removal of waste designated for geologic disposal, without the need for interim on site storage (once containerized). TLG Services, Inc.

Three Mile Island Unit 2 D ecornrnissioning Cost Analysis Document F07-1676-001, Rev. 0 Section 3, Page I of 27 3.5.2 Reactor Vessel and Internal Comoonents The majority of the reactor internal components have already been removed as a result of the accident recovery effort in the 1980's. These components are currently being stored within the reactor building. This estimate assumes that these components are segmented and shipped in shielded, reusable transportation casks commensurate with the start of major reactor vessel removal activities, i.e., Period 4a of each scenario. The reactor pressure vessel and remaining internal components (essentially the core barrel, core former, thermal shield, and flow distributor) are segmented and packaged for disposal in shielded, reusable transportation casks. Segmentation of the remaining internal components is performed in the refueling canal, 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. It is anticipated that all neutron-activated components in the reactor vessel and internals would meet existing disposal requirements as delineated in 10 CFR 561, due to the short operating history. However, the fission products and transuranic material present on all surfaces in the vessel and internals are expected to exceed Class C limits, in particular for those components located below the top of the core. The reactor vessel and the upper portions of the internals are assumed to meet Class A limits following decontamination. The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal, i.e., GTCC. Although the material is not classifi.ed as high-level waste, the DOE has indieated it will accept this waste for disposal at the future high-Ievel waste repository.t2sl 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. For purposes of this analysis, the GTC0 has been packaged and disposed of as high-level waste. It is also assumed that the DOE will accept the GTCC material in a timely manner so as not to affect the TMI-2 decommissioning schedule. No additional costs are included for the temporary storage of GTCC material. TLG Seruices, Inc.

Three Mile Island. Unit 2 D e c omm i s sion ing Co st An aly ai s Document F07-1676-001, Reu. 0 Section 3, Page 10 af 27 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 GGE) was able to dispose of the Trojan reactor as an intact package. However, its location on the Columbia River simplified the transportation analysis since: 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 for TMI-2. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition. 3.5.3 Steam Generators With the high levels of radioactivity and contamination both in the reactor building and within the steam generators, this estimate assumes that the steam generators will be segmented in place instead of one piece removal. The removal sequence assumed for the estimate is as follows: Remove the upper steam generator channel head by wire sawing the shell and tubes immediately below the upper tube sheet. Segment and decontaminate the upper channel head in the fuel transfer pool. TLG Seruices, Inc.

Three Mile Island. Unit 2 D ecom.missioning Co st Analyeis Docurnent F07-1676-001, Reu. 0 Section 3,Page 11of27 Install a steam generator work platform to allow in'place underwater segmentation of the steam generator internals. Remove the steam generator tubing and associated shroud and support plates. Remove the steam generator cylindrical shell. Remove the lower steam generator channel head. Segment and decontaminate the lower channel head in the fuel transfer pool. The steam generator tubing is packaged and shipped and buried as Class B waste. Steam generator tube support plates, shrouds, and shell plates are transported and buried as Class A waste. The estimate assumes that the steam generator channel heads will be decontaminated using a combination of machining and ultra high pressure (UHP) water sprays such that the components can be shipped and buried as Class A waste. Waste that is generated as a result of the machining and normal filtering of the water in the steam generators and the fuel transfer pool is assumed to be highly radioactive and is packaged and transferred to the DOE as GTCC waste. 3.5.4 Other Primarv Svstem Components The following discussion deals with the decontamination, removal and disposition of the pressurizer, reactor coolant piping, reactor coolant pumps and motors, and the core flood tanks. A combination of in-place decontamination, and remote decontamination of components in the fuel transfer pool was assumed in the estimate. The pressurizer and the core flood tanks are decontaminated in'place using UHP. Once decontaminated, the pressurizer is cut in half, removed from the reactor building, grouted, and packaged in a shielded container for rail shipment and burial as Class A waste. The core flood tanks are assumed to be segmented, packaged and shipped as Class A waste. Hot leg piping is accessed by cutting a hole in the core barrel. A combination of underwater remote retrieval and vacuuming is used to remove fuel and fi.ssion product material. Hot and cold leg piping and TLG Seruices, Inc. a o a

Three Mile Island. Unit 2 D ecommissioning Co st Analysie Docurnent F07-1676-001, Reu. 0 Section 3, Page 12 of 27 fittings are removed and placed in the fuel transfer pool for additional decontamination. Hydrolasing is used to remove radioactive materials. Removed material is collected using filters and demineralizers, packaged, and transferred to the DOE as GTCC material. Decontaminated piping is packaged, shipped and buried as Class A waste. The reactor coolant pump motors are removed intact and placed in shielded containers for rail transport and burial as Class A material. Reactor coolant pumps are disassembled and placed in the fuel transfer pool for decontamination. Pump components are decontaminated using UHP to remove the majority of the radioactive material. Following decontamination, the components are packaged in shielded containers for rail transport and buried as Class A material. Material removed as a result of the decontamination process is collected using frlters and shipped as GTCC material. The estimates also assume that process water used. for reactor coolant system decontamination and in the fuel transfer pool is processed using cesium/strontium preferential cation demineralizers. The resin waste is processed and buried as Class C radioactive waste. 3.5.5 Other Svstems Known to Contain Hieh Levels of Radioactivity Systems in the reactor building and portions of systems in the auxiliary and fuel handling buildings are known to contain high levels of rad.ioactivity and potentially spent fuel material from the accident. The estimates recognize the difficulty in removing these components by increasing the work difficulty factors associated with removal of these systems. The estimates also assume that these components will be packaged for direct disposal (no recycling). The disposal costs of these waste streams were also adjusted, as appropriate, to include curie surcharges commensurate with the higher radioactivity levels. These systems and. components will be decontaminated with UHP sprays to removal fuel solids and sludge from fuel bearing components in the fuel and auxiliary buildings. Solids and sludge resulting from the UHP process will be transferred to the reactor building to be packaged in canisters used for NSSS decontamination. TLG Services, Inc.

Three Mile Island Unit 2 D ecommissioning Cost Analysis Docurnent F07-1676-001, Reu. 0 Section 8, Page 13 of 27 3.5.6 Reactor Buildine Structures Decontamination Significant radioactive contamination exists throughout the TMI'2 reactor building. This contamination is due to fission products (eoSr and 137Cs in particular) released from the damaged fuel. The radiation levels are not expected to decrease significantly from current levels due to the long half lives of these elements. The dispersion of spent fuel within the reactor buitding includes alpha-decaying isotopes in addition to the beta and gamma radiation normally encountered during decommissioning. These unusual conditions require additional controls and more engineered decommissioning methods to perform the structure decontamination and demolition. Based upon these conditions, the estimates assume that the entire interior structure of the reactor building is removed and disposed as potentially contaminated material. The lower elevations of the reactor building are highly contaminated. Significant activity has been absorbed in the concrete block walls, in the four-foot thick D-ring concrete walls, and on the lower level concrete floors. Initial decontamination of this area (Period 4a) is assumed to be performed using remotely-operated machines. Surface material will be bulk removed from the concrete walls, packaged in shielded casks and, on average concentration, buried as Class B waste (i.e., most of the debris mass will be Class A, but there will be hot spots ranging to Class C or GTCC). Once the highly contaminated surfaces are decontaminated, free standing concrete walls will be removed (in Period 4b using more conventional means) and shipped for direct burial as radioactive waste. The upper portion of the containment inner steel liner and the entire polar crane will be removed using conventional radioactive demolition techniques (in Period 4b) and packaged, shipped and buried as rad.ioactive waste. Following liner removal, the outer reactor building concrete walls wiII be demolished. This remaining structural material from the reactor building will be surveyed on site, with 90% of the concrete volume assumed to meet free release criteria. The remaining 10% is sent to a waste processor. The free released concrete is acceptable for use as frll. Excess material will be sent to an industrial landfill. TLG Services, Inc.

Three Mile Island Unit 2 D ecommissioning Cost Analysis Doeument F07-1676-001, Reu. 0 Section 3, Page 14 of 27 3.5.7 Demolition of Other Contaminated Structures Significant contamination exists within the auxiliary and fuel buildings. Similar to the reactor building, locations within these buildings will require special engineered methods to safely decontaminate and dispose ofthe structures. The estimate assumes that the entire auxiliary and fuel building structures (all walls and floors down to the footings) will be removed and the resultant structural material monitored and processed with the same criteria as the reactor building. Selected areas of the buildings will require remote operated machines and dedicated engineered ventilation systems and enclosures to allow decontamination and material removal. 3.5.8 Main Turbine and Condenser The main turbine will be dismantled using conventional maintenance procedures. The remaining turbine internals wiII be removed to a laydown area. The lower turbine casings will be removed from their anchors by controlled demolition. This study recognizes that one of the Iow pressure turbine rotors and the main electrical generator has already been removed from the site. The main condensers will also be disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it will be surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components will be packaged and readied for transport in accordance with the intended disposition. 3.5.9 Transportation Methods Contaminated piping, components, and structural material other than the highly contaminated reactor coolant system components and reactor building structures will qualifr as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.tza1 The contaminated material will be packaged in Industrial Packages (IP'l, IP-z or IP-3, as defined in subpart t73.4LL) for transport unless demonstrated to qualifu as their own shipping containers. It is anticipated that the reactor vessel, after decontamination with UHP water sprays, and due to its limited operating lifetime, will qualify as LSA II or III, once the reactor internals and remaining fuel debris is TLG Seruices,Inc.

Three Mile Island Unit 2 D e c onr,m,i s si onin g C o st An aly sis Document F07-1676-001' Rev. 0 Section 3, Page 15 of 27 removed. Portions of the reactor vessel internal components ate expected to be transported to the DOE's geologic repository in spent fuel casks bv rail. Waste resulting from fi.ltering and demineralization of the reactor coolant system, and processing the fuel transfer pool water is assumed to require shipment in shielded truck casks. Transport of other highly radioactive waste such as reactor coolant system components, and waste from the decontamination of the reactor building basement are by shielded truck cask. Truck cask shipments may exceed 95,000 pounds, including payload, 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 are by a combination of truck, rail, and/or multi-wheeled transporter. Truck transportation costs are estimated using published tariffs from Tri-State Motor Transit.t271 The low-level radioactive waste requiring controlled disposal will be sent to the EnergySolutions facility in Clive, Utah. Memphis, Tennessee, is used as the destination for off-site processing. BuIk material shipped off site to the waste processor or to EnergySolutions is primarily moved via gondola railcars. 3.5.10 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. All options and. services currently available to FirstEnergy for d.isposition of the various waste streams produced by the decommissioning process were considered. The majority of the low-Ievel radioactive waste designated for direct disposal can be sent to EnergySolutions' facility in Clive, Utah. Therefore, disposal costs for TLG Seruices,Inc.

Three Mile Island. Unit 2 D ecommissioning Cost Analysis Docurnent F0 7-I 6 76-00 I, Reu. 0 Section 3, Page 16 of 27 Class A waste were based upon Firstfinergy's agreement with EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream. Very low-level radioactive waste, e.g., structural steel and contaminated concrete, is sent to a waste processing facility. More highty contaminated and activated material is sent to EnergySolutions. Disposal fees are based upon current charges for operating waste. Waste Control Specialists (WCS) is licensed to receive the higher activity waste forms (Classes B and C). As such, for this analysis, disposal costs for the Class B and C waste were based upon the preliminary and indicative information on the cost for such from WCS. The Idaho National Engineering and Environmental Laboratory (INEEL) is currently storing waste from the TMI-2 defueling operation. Costs have been included in this estimate to pay INEEL for the final disposal of this waste; the timing of when this payment occurs will be dependent upon the DoE's schedule for cleanup of INEEL. This estimate assumes that the payment occurs during Period 4 of each cost scenario. This study assumes that most of the concrete resulting from the demolition of the reactor, auxiliary and fueI handling buildings can be surveyed and" released on site for fill of below grade voids, or shipped off site to a local construction debris landfill. Should there be restrictions to this approach; the cost impact on the decommissioning program could become quite large, potentially up to tens of millions of dollars.

3. 5. 1 1 Additional Decommissionine Facilities Additional specialized facilities are required in support of the d.ecommissioning. These include refurbishment of the containment air control envelope building located outside the reactor building equipment hatch, and the contamination control cubicle located outside the other personnel airlock, for reactor building radiological control and access.

Construction of a prefabricated metal enclosure at the 305 foot elevation within the reactor build.ing for the handling of highly-contaminated material will be required. A radioactive waste packaging and processing facility will also be required (Note that such a facility already exists on site, but wiII require refurbishment). TLG Seruices, Inc.

Three Mile Island Unit 2 D e c omrnissionin g C o st An aly ei s Document F07-1676-001' Reu. 0 Section 3, Page 17 of 27 3.5.12 Remediation of Soil and Undersround Pipine The estimates include the cost to remove certain underground piping. An allowance is also included for the removal, packaging, transportation and disposal of approximately 49,000 cubic feet of contaminated soil. 3.5. 13 Site Conditions Following Decommissionine The NRC will terminate (or amend) the site licenses if it determines that site remediation has been performed in accordance with the license termination plan, and that the termination survey and associated documentation d.emonstrate that the facility is suitable for release. The NRC's 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 owner's 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 regrad.ed such that the power block area will have a frnal contour consistent with adjacent surroundings. This estimate assumes the reactor, auxiliary, fuel buildings will be removed completely, i.e., down to and including their foundations and basemats. Concrete from these buildings will be surveyed on-site using conventional monitoring equipment; concrete which meets the release criteria will be disposed of either on site as fill, or in an off'site landfill. 3.6 ASSUMPTIONS The following are the major assumptions made in the development of the estimates for decommissioning the site. 3.6.1 Estimatine Basis The study follows the principles of AI"ARA through the use of work duration ad.justment 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 Iengthen a task's duration, increasing costs and lengthening the overall schedule. AT.ARA planning is considered in the costs for engineering and TLG Services, Inc.

Three Mile Island. Unit 2 D e c omrnissioning Co st Ana,ly si s Document F07-1676-001, Rev. 0 Section 3, Page 18 of 27 planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule. All costs are reported in 2013 dollars. No costs have been included for the preparation of an environmental impact statement, should it be required. 3.6.2 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 FirstEnergy or from comparable industry information. FirstEnergy will provide limited oversight support staff in the areas of overall management, licensing, radiological and industrial safety and engineering. It will also hire a DOC to provide the balance of the professional, management, administrative and physical staff. This study assumes that there is some sharing of security staffing positions with the adjacent Unit 1. This has the effect of lowering site security costs. 3.6.3 Desien Conditions Fuel cladding failure as a result of the accident will most likely prevent shipment of untreated major NSSS components under current transportation regulations and disposal requirements. Therefore, this estimate assumes that aggressive mechanical decontamination of reactor coolant system components is required prior to shipment. The estimated curie contents of the vessel and internals are neutron activation products derived from those listed in NIIREGICP,'3474.I281 Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the TMI-2 components, the operating history of 95 effective full-power days, and different period.s of decay. Additional short-Iived isotopes were derived from CR-0130 t2e1 and CR-0672t301and benchmarked to the long-lived values from CR-3474. The activation products present in the reactor vessel base TLG Seruices, Ine.

Three Mile Island Unit 2 D e c ommi ssi onin g C o st An aly eis Docurnent F0 7-I 6 76-00 1, Rev. 0 Section 3, Page 19 of 27 metal are assumed to be the controlling factor in their disposal, following surface decontamination of fuel debris. Reactor vessel internals whose elevation in the reactor places them at or below the original top of the fuel assemblies are assumed to be both sufficiently geometrically complex to preclude effective decontamination and contaminated with spent fuel so as to require disposal as GTCC material. Control elements and incore detector assemblies are assumed to have been removed with the damaged fuel. Neutron activation of the reactor building structure and the biological shield is considered minimal due to the short operating life of TMI'2. 3.6.4 General The plant staff will perform the following activities (FirstEnergy wiII be augmented as necessary, either by direct hiring, or subcontracting to fulfiIl the staff requirements): Drain and collect lubricating oils for recycle and./or sale. Process defueling waste inventories, i.e., the estimates include costs for the removal of lead shielding and spent fuel handling equipment that remains in the reactor building. Scrap and Salvase Material located within the rad.iation controlled area, and not shipped for direct disposal, is sent off-site for survey and release. Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property owned by FirstEnergy (and outside the radiation controlled area) is removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts are also available for alternative use. Enereig For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with long term dormancy. Replacement power costs are used for the cost of energy consumption TLG Seruices, Inc, staff

by a

a

Three MiIe Island Unit 2 D e c ommi ssionin g Co st An aly sis Docurnent F07-1676-001, Reu. 0 Section 3, Page 20 of 27 during decommissioning for tooling, lighting, ventilation, and essential services. Insurance Costs for continuing coverage (nuclear liability and property insurance) during dormancy and decommissioning are included and based upon current PDMS premiums and anticipated shared costs with the adjacent Unit 1. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."tsll The NRC's financial protection requirements are based on various reactor configurations. Taxes Property taxes are not included. 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 ofthe project. 3.7 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 2013 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 schedule discussed in Section 4. TLG Services, Inc.

Three Mile Island, Unit 2 D e c omrn i ssion ing Co st An aly si s Docutnent F07-1676-001, Reu. 0 Section 3, Page 21 of 27 TABLE 3.1 DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2013 dollars) Y Equipment & Labor Materials E BuriaI ear ne 20L3 2,486 0 224 0 326 3,036 20t4 2.486 0 224 0 326 3,036 20L5 2.486 0 224 0 326 3.036 20L6 2.493 0 224 0 327 3.044 2017 2,486 0 224 0 326 3.036 2018 2.486 0 224 0 326 3.036 2019 2.486 0 224 0 326 3.036 2020 2.493 0 224 0 327 3.044 2021 2.486 0 224 0 326 3.036 2022 2.486 0 224 0 326 3.036 2023 2.486 0 224 0 326 3.036 2024 2.493 0 224 0 327 3.044 2025 2,486 0 224 0 326 3,036 2026 2.486 0 224 0 326 3.036 2027 2,486 0 224 0 326 3,036 2028 2.493 0 224 0 327 3.444 2029 2,486 0 224 0 326 3.036 2030 2.486 0 224 0 326 3.036 2031 2.486 0 224 0 326 3.036 2032 2.493 0 224 0 327 3.044 2033 2.486 0 224 0 326 3.036 2034 2.486 0 224 0 326 3,036 2035 2.486 0 224 0 326 3.036 2036 2.493 0 224 0 327 3.044 2037 2,486 0 224 0 326 3,036 2038 2,486 0 224 0 326 3.036 2039 2.486 0 224 0 326 3.036 TLG Services, Inc.

Three Mile Island. Unit 2 Decommissioning Cost Analysis Docutnent F07-1676-001, Reu. 0 Section 3, Page 22 of 27 TABLE 3.1 (continued) DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DPENDITURES (thousands, 2013 dollars) Y Equipment & Labor Materials E Burial ea a 2040 42,184 1.311 854 22 9.056 53.427 204L 57,835 6.878 1.r22 r4.512 7,989 88.337 2042 50.240 15.149 L.122 33.610 10.808 110.929 2043 50.240 15.149 L.L22 33.610 10.808 110.929 2044 50,377 15.191 t.L25 33,702 10.838 111.233 2045 50.240 15.149 r,t22 33.610 10,808 110.929 2046 47.661 12.938 t.024 27.5L7 8.718 97,858 2047 42.77L 8.743 838 15,960 4.752 73.063 2048 42.888 8.767 840 16.004 4,765 73.263 2049 42.777 8.743 838 15.960 4,752 73.063 2050 42,77r 8.743 838 15.960 4.752 73,063 2051 4L.768 8,391 810 15,131 4.570 70.671 2052 24.33L 4,863 255 814 1,091 31.354 2053 18,079 7.945 t04 1.820 47L 28.4r8 Total 67I,323 137.959 18.061 258.232 102.989 1.188,564 TLG Seruices, Inc.

Three Mile leland. Unit 2 D e c otnmiseionin g Co st An a ly si e Document F07-1676-001' Reu, 0 Section 3, Page 23 of 27 TABLE 3.2 DELAYED DE CON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DGENDITURES (thousands, 2013 dollars) Equipment & Year Labor Materials Burial 2013 2.486 0 224 0 326 3.036 20r4 2,486 0 224 0 326 3.036 2015 2.486 0 224 0 326 3.036 2016 2.493 0 224 0 327 3.044 20L7 2.486 0 224 0 326 3,036 2018 2.486 0 224 0 326 3.036 2019 2.486 0 224 0 326 3,036 2020 2,493 0 224 0 327 3.044 202L 2.486 0 224 0 326 3.036 2022 2.486 0 224 0 326 3.036 2023 2.486 0 224 0 326 3,036 2024 2.493 0 224 0 327 3.044 2025 2,486 0 224 0 326 3.036 2026 2,486 0 224 0 326 3,036 2027 2.486 0 224 0 326 3.036 2028 2.493 0 224 0 327 3.044 2029 2,486 0 224 0 326 3.036 2030 2,486 0 224 0 326 3,036 2031 2.486 0 224 0 326 3.036 2032 2,493 0 224 0 327 3.044 2033 2.486 0 224 0 326 3.036 2034 1,150 240 236 4 482 2.r12 2035 588 341 242 6 547 L.724 2036 590 342 242 6 548 r.728 2037 588 341 242 6 547 1,724 2038 588 341 242 6 547 L.724 2039 588 341 242 6 547 r.724 TLG Services, Ine.

Three Mile Island. Unit 2 D e c onmi ssion in g Co st An aly si s Docurnent F07-1676-001, Reu. 0 Section 3, Page 24 of 27 TABLE 3.2 (continued) DELAYED DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DPENDITURES (thousands, 2013 dollars) Equipment & Year ,abor Materials t 2040 590 342 242 6 548 r.728 2041 588 341 242 6 547 L,724 2042 588 341 242 6 547 1..724 2443 588 34L 242 6 547 t.724 2044 590 342 242 6 548 r.728 2045 2t.420 885 Dbb 15 4.901 27.776 2046 59.4r2 3.573 T.T22 5.6L7 9.680 79.404 2047 51.713 13.861 I.t22 30,900 9,785 107.381 2048 50.377 15.181 L.L25 33,687 ro.824 1 1 1.194 2049 50.239 15.140 1.t22 33.595 10,795 110.890 2050 50.239 15.140 I,T22 33.595 10,795 110.890 205L 50,239 15.140 L.L22 33.595 10.795 110,890 2052 40.986 8.757 840 15.988 4.75r 71.322 2053 40.874 8.733 838 t5.945 4.738 7r.r28 2054 40.874 8.733 838 r5.945 4.738 7L,L28 2055 40.874 8.733 838 t5,945 4.738 7t,L28 2056 40.986 8.757 840 15.988 4.75L 7L.322 2057 28.r32 3,949 456 4.649 2.275 39,461 2058 24.464 11.029 156 2,509 700 38.859 2059 1.008 469 6 L07 28 1.619 Total 65t.L22 L4L.727 19,459 258.t43 107,103 L.L77.554 TLG Seruices,Inc.

Three Mile Island. Unit 2 Decommissioning Cost Anolyeia Doeurnent F07-1676-001, Rev. 0 Section 3, Page 25 of 27 TABLE 3.3 SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2013 dollars) Y Labor Equipment & Materials E ear 2013 2,486 0 224 0 326 3.036 20r4 2.486 0 224 0 326 3.036 2015 2.486 0 224 0 326 3.036 20t6 2.493 0 224 0 327 3.044 2017 2,486 0 224 0 326 3.036 2018 2,486 0 224 0 326 3,036 20L9 2.486 0 224 0 326 3.036 2020 2.493 0 224 0 327 3.O44 202t 2,486 0 224 0 326 3.036 2022 2.486 0 224 0 326 3.036 2023 2.486 0 224 0 326 3.036 2024 2,493 0 224 0 327 3.044 2025 2.486 0 224 0 326 3.036 2026 2.486 0 224 0 326 3.036 2027 2.486 0 224 0 326 3.036 2028 2,493 0 224 0 327 3,044 2029 2.486 0 224 0 326 3.036 2030 2,486 0 224 0 326 3.036 203I 2.486 0 224 0 326 3.036 2032 2,493 0 224 0 327 3,044 2033 2.486 0 224 0 326 3.036 2034 L.T47 239 236 4 48r 2.t07 2035 584 339 242 6 546 L.716 2036 585 340 242 6 548 1.72t 2037 584 339 242 6 546 1.716 2038 584 339 242 6 546 L,7L6 2039 584 339 242 6 546 1.716 2040 585 340 242 6 548 t.721 204t 584 339 242 6 546 I.7T6 2042 584 339 242 6 546 L.7L6 2043 584 339 242 6 546 1.716 2044 585 340 242 6 548 r.72L TLG Seruices, hr.c.

Three Mile Island Unit 2 D e c ornrni s sionin g Co st An aly si s Docurnent F0 7-16 76-00 1, Reu, 0 Section 3, Page 26 of 27 TABLE 3.3 (continued) SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2013 dollars) Equipment & Year Labor Materials Burial 2045 584 339 242 6 546 1.716 2046 584 339 242 6 546 t.7L6 2047 584 339 242 6 546 r.716 2048 585 340 242 6 548 t.721 2049 584 339 242 6 546 1,716 2050 584 339 242 6 546 r.716 205r 584 339 242 6 546 L.716 2052 585 340 242 6 548 I.72I 2053 584 339 242 6 546 1.716 2054 584 339 242 6 546 1.716 2055 584 339 242 6 546 1.716 2056 585 340 242 6 548 L.727 2057 584 339 242 6 546 1.716 2058 584 339 242 6 546 1.716 2059 584 339 242 6 546 1.716 2060 585 340 242 6 548 L.72L 2061 584 339 242 6 546 t.716 2062 584 339 242 6 546 t.7L6 2063 584 339 242 6 546 T,7L6 2064 585 340 242 6 548 t.72L 2065 584 339 242 6 546 L.7t6 2066 584 339 242 6 546 t,7L6 2067 584 339 242 6 546 1.716 2068 585 340 242 6 548 1.721 2069 584 339 242 6 546 1,7t6 2070 584 339 242 6 546 1,716 207r 584 339 242 6 546 1.716 2072 585 340 242 6 548 L.72r 2073 584 339 242 6 546 1.716 2074 584 339 242 6 546 L.7t6 2075 584 339 242 6 546 L.716 2076 585 340 242 6 548 L.721 TLG Serttices, Inc,

Three Mile Island Unit 2 D e c ommi s sioning Co st An aly sis Document F0 7-1 6 76-00 1, Reu. 0 Section 3, Page 27 of 27 Y TABLE 3.3 (continued) SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DGENDITURES (thousands, 2013 dollars) Equipment & terials ear Labor Ma 2077 584 339 242 6 546 1.716 2078 584 339 242 6 546 t.7L6 2079 584 339 242 6 546 1.716 2080 585 340 242 6 548 L.72L 2081 5.872 477 321 8 1,651 8.330 2082 59.162 2,301 L.L22 L.449 11,987 76.02r 2083 54.3L2 11.604 1.T22 26,L47 7.999 101.178 2084 50.377 15,L77 t.125 33,673 10.818 11 1.171 2085 50.239 15.136 L.L22 33.581 10.789 110.867 2086 50,239 15.136 L.L22 33.581 10.789 110.867 2087 50.239 15,136 t.t22 33,581 10.789 110.867 2088 43,42L 10.455 916 20.657 6,353 81.802 2089 40.801 8.729 838 15.920 4.729 7L,017 2090 40.801 8.729 838 15.920 4.729 7t.0r7 2091 40,901 8.729 838 15.920 4.729 7T,OL? 2092 40.913 8,753 840 15.963 4.742 7L,2LT 2093 32.864 5.738 599 8,866 3.193 5I.259 2094 24.035 8.524 196 1.821 857 35.434 2095 7.527 3.503 46 803 207 12.086 Total l 671.870i L53,977 1 28,227 258.L57 l 126,834 1.239,065 TLG Services, Inc.

Three Mile Island Unit Z Decommissioning Cost Analysis Docurnent F07-1676-00 7, Rev. 0 Section 4, Page I of 6

4. SCHEDULE ESTIMATE The schedules for the decommissioning scenarios considered in this study follow the sequence presented in the AIFAIESP-036 study, with minor changes to reflect recent experience and site-specific constraints.

A schedule or sequence of activities is presented in Figure 4.1 through 4.3 for the three decommissioning scenarios. 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 2010' computer seft"'r4rc.[321 4.I SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT @rogram 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 decommissioning schedule: The DECON alternative begins decommissioning of TMI'2 in 2040. The existing PDMS yearly costs of $3.1 million are continued until that date. The existing PDMS yearly costs cease upon the shutdown of the adjacent Unit 1 on April 19, 2034 for the Delayed DECON and SAFSTOR scenarios; normal SAFSTOR dormancy costs will commence at that date until decommissioning begins. The Delayed DECON alternative defers decommissioning of TMI-2 until TMI-1's spent fuel has been removed from the site. This scenario assumes that the decontamination and dismantling activities at TMI-2 are synchronized with the adjacent unit such that the licenses for both units are terminated concurrently. The SAFSTOR alternative places TMI-2 into long-term storage along with TMI-I. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit 1. As with the second scenario, termination of the licenses is concurrent. AII work (except vessel and internals removal and some of the decontamination of NSSS components in the refueling canal) is per' TLG Serttices, Inc.

Three Mile Island Unit 2 D e c ommi ssionin g C o st An oly eis Document F07-1676-001' Reu. 0 Section 4, Pa,ge 2 of 6 formed during an 8-hour workday, 5 days per week, with no There are eleven paid holidays per year. Steam generator removal activities are performed with limited parallel work on the A and B steam generators. Reactor and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for the second shift. Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessaly during demolition of heavy components and structures. Reactor building basement decontamination using remote equipment will occur prior to the start of reactor coolant system component removal. 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 TMI'2. 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. Project timelines are provided in Figures 4.2 through 4.4. TLG Seruices,Inc.

Three Mile Island Unit 2 D ecommissioning Cost Analysis Document F07-1676-001, Reu. 0 Section 4, Page 3 of 6 FIGURE 4.1 DECON ACTIVITY SCHEDULE lask Name ,oa ' r a l, r s l ' l, r l ' s e '3s l '44 '49 'g IAtr Urxit ? DECOI{ Bhoduh !F E I w I w W t i,, ffi i,......:

i' M, r i,,, ',

i,i,, K i, fsi wi

li:

,, d ' ! i t li li'ri ,li*{ $,il :: ,il ,,,,F i'iF iE. i,w : ., iF

i w

',, i f f i ww K F m M @W,,, i, I I i,,'- is i c i,t, r l l iw P*iod t&c - PDMBDolmenoy P;isil;;;td"i -st.;'i; Poiod fu - n""*tir-t f.'"ii S Hea*fir"ate {Jnit I i*;;it-d;;;d;;6 "ariscoN p*t#*.i"# A" D-l*3",t bEcoN Parisil,ta lTnit ? - Large cmponrnt renrsval F}:IAB, Coutrnol, guttn* Blai. O&D

acsag*.:rrixate Rc.retor Bldg Leqt.r latcl*

oecoata;;;ilr pr"*' dtdc u;p"t t* Rcroo!"e PB,, RCP's g nCg pirn"ti (Ire p*"tt"ii O. tr-i""t NSSS C"-p*""-i; A Stean Geoefrtor Bamo:ral Remar-e icsulaiion Ere.*t nork pl*tfu::c I*trll t-*p **rppott* g C/H lif*i"g t"g" C"r & raruor-r "pe"i"l""""i h;;a Cut & rrmow ffC;ba L;ii,'g src-Gb-#

'"f";"."""i'#

n:Tot e u"epo." elatu & rb*"d" Cle*n:*c*ndnrg:i{e, *ut & rer**ll;e *bell wall Re:nor'e lot*er ch*n:rel L**d **nbl" B Etea:n a.*rt"r i"*oirl Reactcr l'eesel Rssovil 9re,ry1*1]qy- &r Reler*r'*.es*el yye+'al &te.cisr $ressurr l'agssl rlgeyal Feriod 4b Unit Z. sit Deao;ta-i"itl"* ti;n'"t &'6."*; BHs Deb Fuel llaadli:rg Auxiliars Elde B&D Liaercr T"tei""dm S"rtrt Ph&id--- - -O".uit" sorr.tg & r.elea* of plant conmodities D-Rd; & Bi*t.,ld ;*'";;i Aeactec El.dg. Lines ruror,:

i*-Bt{c

& B"**;'iffi;iis"* Llnilergmun& giping & soil reurediatien Priod {e L'nit t. Pldnt Uoe""e t t*laa*o I'ilrs! iisams $rr',e3* \\]fi,C Ttai&ca{i*rrr arrd retiew Fart 5O Soeqse tffiilrrted i;'i"d 5tdnit's]sil n sto'iti* Rexsre rr m ainin g b"rtdid;--- 9,:*-:m3*PxF-y*4rod Landec,ap* TLG Seruices, Inc.

Three Mile Island. Unit 2 D e c ornm.issionin g C o st An aly sis Decommissioning Acouals Begin Period 0a PDMS Mmitorirg Document F07-1676-001, Reu. 0 Section 4, Page 4 of 6 FIGURE 4.2 DE COMMISSIONING TIMELINE DECON (not to scale) Period 5 Site Restcation TLG Services, Ine.

Three Mile Island Unit 2 D e c ommi ssionin g C o st An aly sis Period 1 SAFSTOR TMI-2 Decommlsslonlnt Accruals Bedn Period 2 TMF2 Delayed DECON Dormancy A Apr-2034 FIGURE 4.3 DECOMMISSIONING TIMELINE DELAYED DECON (not to scale) Period 3 De@mmissioning Preparations Document F07-1676-001, Reu. 0 Section 4, Page 5 of 6 Period 4 Decommissionlng OpeEtions Period 2 Dormancy Period 5 Site Restoratlon TMI.2 Re6ctlv!tlon TLG Seruices, Inc.

Three Mile Island. Unit 2 D e c ornm i ssion ing Co st An aly sis TMI.2 Decommissionlnt Aeruals Begin Period 2 TMI.2 custodial sAFsToR Dormancl Document F07-1676-001, Rev, 0 Section 4, Page 6 of 6 FIGURE 4.4 DECOMMISSIONING TIMELINE SAFSTOR (not to scale) TMFl Shutdom Period 2 Dormancy Period 3 Dcommissioning Preparations Period 4 Decommissioning Operations Period 5 Site Restoration TMI.2 Ractlvatlon TLG Seruices, Ine,

Three Mile Island. Unit 2 Decommissioning Cost Analysis disposal of radioactive materials and radioactive material as it pertains to specifies its disposition. Docutnent F07-1676-001, Reu. 0 Seetion 5, Page I of 7 processes. In particular, $71 defines packaging and transportation and 561

5. RADIOACTIVE \\ryASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,t33l 16" 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 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 5173-178. Shipping containers are required to be Industrial Packages (IP-l, 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.

Figure 5.1 summarizes the categories of radioactive waste streams and their disposition. Figure 5.2 identifies of the intended disposal site and processing center. 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 calculated based on the exterior dimensions for containerized material and on displaced volume of components serving as their own waste containers. The reactor vessel, internals, other reactor coolant system components, and certain structural materials are categorized. as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners or LSA boxes shipped within shielded vans. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Most of the waste generated by the decommissioning process appears to be Class C or less, based. upon the available information regarding the amount of fission products and transuranics present in the buildings, and the quantities of building materials assumed shipped as radioactive waste. This basis should be reexamined if TLG Seruices,Inc. are the

Three Mile laland. Unit 2 D ecommissioning Cost Ana.lysis Doeument F07-1676-001, Reu, 0 Section 5, Page 2 of 7 additional characterization information becomes available in the future regarding the quantities of fission products and transuranics in more localized surveys. No process system containing/handling radioactive substances at the time of decommissioning is presumed to meet material release criteria by decay alone, i.e., systems radioactive in 2013 will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides. 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 TMI'2 is primarily generated during Period 4 of the defined alternatives. 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 d.econtamination and dismantling activities is based upon FirstEnergy's disposal agreement with EnetgySolutions for its facility in Clive, Utah. EnergySolutions 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. As such, for this analysis, disposal costs for the Class B and C waste were based upon the preliminary and indicative information on the cost for such from WCS. TLG Seruices, Inc,

Three Mile Island, Unit 2 D ecommissioning Cost Analyeis i ti"*"g--- \\ tow-iild RadiDactivt waste 'r--*"...::-T.: Document F0 7-I 6 76-00 7, Reu. 0 Section 5, Page 3 of 7 FIGURE 6.1 TMI.2 WASTE STREAMS

SUMMARY

Resin N5S5 Dcontamlnatlon (OassB/!i,,, TLG Servicea, Inc.

Three Mile Island. Unit 2 D e c ommi ssio n ing Co st An a,ly ei s Doeument F07-1676-001, Rev. 0 Seetion 5, Page 4 of 7 FIGURE 5.2 DE COMMISSIONING WASTE DESTINATIONS RADIOLOGICAL TLG Services, Inc.

Three Mile Island. Unit 2 D e c orntnission in g C o st An aly sis Docurnent F07-1676-001, Rev. 0 Section 5, Page 5 of 7 tU TABLE 5.1 DECON ALTERNATIVE DECOMMISSIOMNG WASTE

SUMMARY

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 Columns may not add due to rounding Waste Cost Basis Class It1 Waste Volume (cubic feet) Weight (nounds) Geolosic Repository Spent Fuel GTCC 2.856 564.685 Equivalent 357 20,5r4 Primary waste stream wcs C 2,734 237,772 WCS B 26,9L8 1.928,673 Secondary waste stream EnerEvSolutions A r77.759 13.891,318 Tertiarv waste stream Concrete EnerEySolutions A 613,465 66,003,571 SoiI EnerEvSolutions A 48.992 3.723,4L4 DAW EnerwSolutions A 17,010 340.195 Survev & Release 61,736 3.704,L37 Processed Waste (Off-Site) Recycling Vendors 67,958 2.843,938 Totalt2l 1.019.785 93,258,2L7 TLG Seruiees, Inc.

Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1676'001, Reu. 0 Section 5, Page 6 of 7 t1l I2l TABLE 5.2 DELAYED DECON ALTERNATIVE DECOMMISSIONING WASTE

SUMMARY

Waste is classifred according to the requirements as delineated in Title 10 CFR, Part 61.55 Columns may not add due to rounding Waste Cost Basis Ql2sg ttl Waste Volume (cqbis tp.pt)_"" Weight (oounds) Geolosic Repositorv Spent Fuel GTCC 2.856 564.685 Equivalent 357 24,5t4 Primarv waste stream WCS c 2.734 237.772 WCS B 26,918 1,928,673 Secondary waste stream EnersySolutions A L77.438 13.872.058 Tertiarv waste stream Concrete EnersvSolutions A 613.465 66,003,572 Soil EnercySolutions A 48.992 3.723.4L4 DAW EnersySolutions A 18.060 361.194 Survev & Release 61,736 3.704,L37 Processed Waste (Off-Site) Recycling Vendors 67.958 2.843.938 fefsltzl L,020,5L4 93,259,957 TLG Seruices, Inc.

Three Mile Island. Unit 2 D e c ommi ssi onin g Co st An aly ei s Docurnent F07-1676-001, Reu, 0 Section 5, Page 7 of 7 IU TABLE 6.3 SAFSTOR ALTERNATIVE DE COMMISSIONING WASTE

SUMMARY

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 Columns may not add due to rounding. Waste Cost Basis Qlssg ttl Waste Volume (cubic feet) Weight (pounds) Geoloeic Repositorv Spent Fuel GTCC 2,856 564,685 Equivalent 357 20.5L4 Primarv waste stream wcs C 2,734 237,772 WCS B 26.918 1.928.673 Secondary waste stream EnergySolutions A 176.490 13.805.128 Tertiarv waste stream Concrete EnerEvSolutions A 613.465 66,003,568 Soil EnergySolutions A 48,992 3.723.474 DAW EnercvSolutions A 2L,4L5 428.298 Survev & Release 61,736 3,7A4,137 Processed Waste (Off-Site) Recycling Vendors 68,950 2.895.277 Totalt2l 1"023,913 93.311.466 TLG Services, Inc.

Three Mile Island Unit 2 D e c omm. i ssion ing Co st An aly si e Document F0 7-16 76-00 I, Reu. 0 Section 6, Page 7 of 5

6. RESULTS The analysis to estimate the costs to decommission TMI-2 relied upon the site' specific, technical information developed in 1995-96 and last updated in 2008. While not an engineering study, the estimates provide FirstEnergy with sufficient information to assess its 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, radioactive waste disposal options, and site remediation requirements. The decommissioning scenarios assume that the remainder of the spent fuel (less than 1%), which is dispersed throughout the reactor coolant and support systems, is packaged, shipped and buried as radioactive waste. Some of the waste that is generated is assumed to be GTCC. This waste is assumed to be transferred to the DOE at the time that it is processed and collected during the decommissioning. No costs have been included for the temporary storage of GTCC material. The cost projected to decommission TMI-2, i.e., by the DECON alternative, is estimated to be g1.19 billion. The majority of this cost (approximately 97%) is associated with the physical decontamination and dismantling of the nuclear unit so that the lieense can be terminated. The remaining 3% is for the demolition of the designated structures and limited restoration of the site. The costs for the other decommission alternatives, Delayed DECON and SAFSTOR, are estimated at $1.18 billion and $1.24 billion, respectively. 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 d.ecommissioning, as well as the duration of the program. It is assumed, for purposes of this analysis, that FirstEnergy 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 license is terminated, the staff is substantially reduced for the conventional demolition and restoration of the site. The cost for waste d.isposal includes only those costs associated with the controlled disposition of the radioactive waste generated from decontamination and d"ismantling activities, includ.ing plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, disposal of TLG Seruices,Inc.

Three Mile Island Unit 2 D ecommissioning Cost Analysis Docurnent F07-1676-001' Reu, 0 Section 6, Page 2 of 5 the lower level material, including concrete and structural steel, is at the EnergySolutions facility. The more highly radioactive waste is sent to Waste Control Specialists in Texas. Highly contaminated components, requiring additional isolation from the environment, are packaged for geologic disposal. Removal costs reflect the labor-intensive nature of the decommissioning process, as weII as the management controls required to ensure a safe and suecessful 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 license. The reported cost for transport includes the tariffs and surcharges associated with moving large component.,rrd/o" overweight shielded casks overland, as well as the general expense, e.g., Iabor and fuel, of transporting material to the destinations identified in this report. License termination survey costs are associated with the labor intensive and complex activity of verifuing 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. Due to the complete removal of the reactor, auxiliary and fuel buildings, the final termination survey effort is reduced. 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. TLG Seruices, Inc,

Three Mile Island. Unit 2 D e c omm issionin g Co st An a ly sie Docutnent F07-1676-001, Reu, 0 Section 6, Page 3 of 5 TABLE 6.1 DECON ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2013 dollars) l1l I2l Includes engineering costs Columns may not add due to rounding Cost Element Total Percentage Decontamination 35,403 3.0 Removal 189,064 15.9 Packaeine 28.008 2.4 Transportation 26,427 2.2 Waste Disposal 276,LLz 23.2 Off-site Waste Processins 11.053 0.9 ProEram Management [11 484.509 40.8 Securitv 55,590 4.7 Insurance and Reeulatory Fees L5,766 1.3 EnerEv 18.061 1.5 Characterization and Licensing Surveys 10.844 0.9 Property Taxes 0 0.0 Miscellaneous Equipment 23,851 2.O Site O&M 4,968 0.4 PDMS MonitorinE 8.908 0.8 Total tzl 1",188,564 100.0 Cost Element Total Percentage License Termination 1,1-491099 96.7 Site Restoration 39.467 3.3 Total tzl 1.188,564 100.0 TLG Services, Inc,

Three Mile Island Unit 2 Decommiesioning Cost Analysis Document F07-1676-001, Reu. 0 Section 6, Page 4 of 5 TABLE 6.2 DELAYED DECON ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2013 dollars) trl I2l 131 Includes dormancy costs following TM-l shutdown in 2034 Includes engineering costs Columns may not add due to rounding Cost Element Total ttl Percentage Decontamination 35,321 3.0 Removal 190.858 t6.2 Packaeine 28,007 2.4 Transnortation 26.310 2.2 Waste Disposal 276.022 23.4 Off-site Waste Processins 11.053 0.9 Prosram Managemsnl tzl 472.755 40.2 Securitv 46,850 4.0 Insurance and Regulatorv Fees 21,899 1.9 Enersv 19"459 L.7 Characterization and Licensins Survevs 10.844 0.9 Pronertv Taxes 0 0.0 Miscellaneous Equipment 26.259 2.2 Site O&M 4,968 0.4 PDMS Monitorine 6.949 0.6 Total t31 L,L77,554 100.0 Cost Element Total Percentase License Termination 1,139,536 96.8 Site Restoration 38.018 3.2 Total t31 L.I17,554 100.0 TLG Services, Inc.

Three Mile Island. Unit 2 Decommissioning Cost Analysis Docum.ent F0 7-1 6 76-00 1, Rev. 0 Sectian 6, Page 5 of 5 TABLE 6.3 SAFSTOR ALTERNATIVE DECOMMISSIOMNG COST ELEMENTS (thousands of 2013 dollars) lll 12) t31 Includes dormancy costs following TMI-I shutdown in 2034 Includes engineering costs Columns may not add due to rounding Cost Element Total [tl Percentage Decontamination 35.286 2.9 Removal 196,595 15.9 Packaeine ?8pQq, 2.3 Transportation 26.298 2.1 Waste Disposal 275.884 22.3 Off-site Waste Processins 11.206 0.9 Program ManaEement t2l 482.930 39.0 Securitv 56,699 4.6 Insurance and Regulatory Fees 4L.497 3.4 Energy 28.227 2.3 Characterization and Licensine Survevs 10.844 0.9 Propertv Taxes 0 0.0 Miscellaneous Equipment 33.617 2.7 Site O&M 4,968 0.4 PDMS Monitorine 6.949 0.6 Total t31 1.239.065 100.0 Cost Element Total Percentage License Termination r.20t.o47 96.9 Site Restoration 38.018 3.1 fef2l tsl 1.239.065 100.0 TLG Seruicea, Inc.

Three Mile Island. Unit 2 D ecommissioning Co et Analysis Document F07-1676-001' Reu. 0 Section TPage 1of3 1.

7. REFERENCES "Decommissioning Cost Estimate for the Three Mile Island, Unit 2," Document No. G01-1196-003, TLG Services, Inc., February 1996 "Decommissioning Cost Estimate for Three Mile Island Unit 2," Document No.

F07-1601-002, TLG Services, Inc., January 2009

3.

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

4.

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

5.

U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "Radiological Criteria for License Termination." Federal Register, Volume 62, Number L39 (p 39058 et seq.), July 21, 1997 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 16,200L

7.

U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 6L G,39278 et seq.), JuIy 29, 1996 "Nuclear Waste Policy Act of 1982 and Amendments," IJ.S. Department of Energy's Offrce of Civilian Radioactive Management, 1982 BIue Ribbon Commission on America's Nuclear Future's

Charter, http://cvbercemetery.unt.edn/archive/brc/201206?0215336/http://brc.eov/indgx.p hP?q=Pae./.h.*,.t "Blue Ribbon Commission on America's Nuclear Future, Report to the Secretary of Energy," http://www.brc.eov/sites/defaulUfiIes

/documents /brc finalreport ian2012.pdf, January 2012 Stratery for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S. DOE, January 11, 2013 8. 9. 10. 11. TLG Seruices, Inc.

Three Mile Island, Unit 2 Decommissioning Cost Analysis Dacurnent FA7-rc76-007, Rev, 0 Section 7 Page 2 of 3 13. t4. 12. 15. 16. 17. 18. 19. 20. 21.

7. REFERENCES (continued)

'Acceptance Priority Ranking & Annual Capacity ll.eport," DOE/RW-0567, July 2004 "Low-Level Radioactive Waste Policy Act," Public Law 96-573, 1980 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, January/ 15, 1986 Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55 "Establishment of Cleanup Levels for CERCI"A Sites with Radioactive Contamination " EPA Memorandum OSWER No. 9200.4-18, August 22, 1997 U.S. Code of Federal Regulations, Title 40, Part 141.1"6, "Maximum contaminant levels for beta particle and photon radioactivrty from man-made radionuclides in community water systems." "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 Three Mile Island Unit 2 Post Defueling Monitored Storage Safety Analysis Report, 1995 Update, Chapter 4 (Fuel), GPU Nuclear Corporation 1995 "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIIVD," NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIFATESP-036, May 1986 W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980 TLG Services, Inc.

Three MiIe Island. Unit 2 D e c ornmi ssionin g C o st An aly si s Doeument F0 7-16 7 6-00 I' Reu. 0 Section 7 Page 3 of 3 REFERENCES (continued) "Building Construction Cost Data 2013," Robert Snow Means Company, Inc., Kingston, Massachusetts Project and Cost Engineers' Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984 "Strategy for Management and Disposal of Greater-Than-Class C Inw-Level Radioactive Waste," Federal Register Volume 60, Numbet 48 k, 13424 et seq.), March 1995 U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 1996 Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-109397 and Supplements, 2000 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 R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," NIIREG/CR-0l3O and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1978 H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NIIREG/CR-A672 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1980 "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 "Microsoft Project 2010," Microsoft Corporation, Redmond, WA, 2010 'Atomic Enerry Act of 1954," (68 Stat. 919) 7. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. TLG Seruices, Inc.

Three MiIe Island Unit 2 D e c ommi ssioning Co st An aly si s Document F07-1676-001, Reu, 0 Append.ix A, Page I of 4 APPENDD( A UNIT COST FACTOR DEVELOPMENT TLG Seruices, Inc.

APPENDD(A UMT COST FACTOR DEVELOPMENT Example: Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1.

SCOPE Three Mile Island. Unit 2 Decornmissioning Co st Analysis Heat exchangers weighing < 3,000 lbs. will be removed small hoist. They will be disconnected foom the inlet exchanger will be sent to the waste processing area.

2.

CALCULATIONS Act Activity ID Description Docum.ent F07-1676-001, Rev, 0 Append,ix 4 Page 2 of 4 rn one plece usrng a crane or and outlet piping. The heat Activity Duration (minutes) Critical Duration (minutes)* a b c d e f o b h i Remove insulation Mount pipe cutters Install contamination controls Disconnect inlet and outlet lines Cap openings Rig for removal Unbolt from mounts Remove contamination controls Remove, wrap, send to waste processing area Totals (Activity/Critical) 60 60 2A 60 20 30 30 15 60 355 (b) 60 (b) 60 (d) 30 30 15 60 255 64 64 383 115 498 42 544 Duration adjustment(s) : + Respiratory protection adjustment (25o/o of.cntical duration) + RadiatiodAl\\IL\\ adjustment (25% of ctitical duration) Adjusted work duration

Protective clothing adjustment (30% of adjusted duration)

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

- Total duration = 9.000 hr {'R
alpha designators indicate activities that can be performed in parallel TLG Serttices, Inc.

Three Mile Isla,nd Unit 2 Decotnmissioning Cost Analysis

3.

LABOR REQUIRED Crew Document F07-1676-001, Reu. 0 Append.ix 4 Poge 3 of 4 APPENDXA (continued) Number Duration (hours) Rate ($ihr) Cost ($) Laborers Craftsmen Foreman General Foreman Fire Watch Health Physics Technician Total Labor Cost 3.00 2.00 1.00 0.25 0.05 1.00 9.000 9.000 9.000 9.000 9.000 9.000 33.92 59.98 6r.79 65.28 33.92 48.84 $915.84 r,079.64 556.11 r46.88 L5.26 439.56 $3,153.29 $24.50 $11.00 $13.49 $48.ee $7.84 $56.83

4.

EQUIPMENT & CONSUMABLES COSTS Equipment Costs Consumable s/lVlaterials Costs ' universal sorbent 50 @ $o'49 sq ft {tl - Tarpaulins (oil resistant/fire retardant) 50 @ $0.22lsq ft {zt -Gas torch consumables 1@ $13.49/hr x t hr {3} Subtotal cost of equipment and materials Overhead & profi"t on equipment and materials @ L6.00 o/o Total costs, equipment & material TOTAL COST: Removal of contaminated heat exchanger <3000 pounds: Total labor cost: Total equipment/material costs: Total craft labor man-hours required per unit: $3,210.12 $3,153.29 $56.83 65.700 TLG Sentices, Inc.

Three Mile Island. Unit 2 De commiesioning Co st Analysis Document F07-1676-001, Rev. 0 Appendix 4 Page 4 of 4 D. NOTES AND REFERENCES r Work difficulty factors were developed in conjunction with the Atomic Industrial Forum's (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," AIFAIESP-036, May 1986.

References for equipment & consumables costs:

1. www.mcmas.ter.com online catalog, McMaster Carr Spill Control (71e3T88)

2. R.S. Means (2013) Division 01 56, Section 13.60-0600, page 22

3. R.S. Means (2013) Division 01 54 33, Section 40'6360, page 688 Material and consumable costs were adjusted using the regional indices for Harrisburg, Pennsylvania.

TLG Seruices, Inc.

Three Mile Island. Unit 2 D e cotnmi ssioning Co st An a.ly si s Docutnent F07-1670-001, Reu. 0 Appendix B, Page I of 7 APPENDD( B UNIT COST FACTOR LISTING (SAFSTOR: Power Block Structures Only) TLG Seruices, Inc.

Three Mile Island. Unit 2 Decotnm.iesioning Cost Anolyeia Unit Cost Factor APPENDD( B UNIT COST FACTOR LISTING (Power Block Structures Only) Docurnent F07-1670-001, Rev. 0 Append.ix B, Page 2 of 7 Cost/Unit($) Removal of clean instrument and sampling tubing, $/linear foot Removal of clean pipe 0.25 to 2 inches diameter, $Ainear foot Removal of clean pipe >2 to 4 inches diameter, $llinear foot Removal of clean pipe >4 to 8 inches diameter, $/linear foot Removal of clean pipe >8 to 14 inches diameter, $Ainear foot Removal of clean pipe >14 to 20 inches diameter, $/linear foot Removal of clean pipe >20 to 36 inches diameter, $/linear foot Removal of clean pipe >36 inches diameter, $llinear foot Removal of clean valve >2to 4 inches Removal of clean valve >4to 8 inches Removal of clean valve >8 to 14 inches Removal of clean valve >l4to 20 inches Removal of clean valve >20 to 36 inches Removal of clean valve >36 inches Removal of clean pipe hanger for small bore piping Removal of clean pipe hanger for large bore piping Removal of clean pump, <300 pound Removal of clean pump, 300-1000 pound Removal of clean pump, 1000-10,000 pound Removal of clean pump, >10,000 pound Removal of clean pump motor, 300-1000 pound Removal of clean pump motor, 1000-10,000 pound Removal of clean pump motor, >10,000 pound Removal of clean heat exchanger <3000 pound Removal of clean heat exchanger >3000 pound Removal of clean feedwater heater/deaerator Removal of clean moisture separator/reheater Removal of clean tank, <300 gallons Removal of clean tank, 300-3000 gallon Removal of clean tank, >3000 gallons, $/square foot surface area TLG Seruiceq Inc. 0.65 5.73 8.28 18.2r 32.80 42.69 62.52 74.66 L22.0r t82.L4 328.42 426.90 625.24 746.63 41.06 128.91 307.22 837.90 2,992.23 5,785.54 358.40 r,246.71 2,802.79 1,685.84 4,237.90 11,387.33 22,925.30 395.46 r,240.33 10.06

Three Mile Island, Unit 2 D e c ornm,i ssionin g Co st Analy si s Unit Cost Factor APPENDD( B UNIT COST FACTOR LISTING (Power Block Structures Only) Document F07-1676-001, Rev. 0 Append,ixB, Page 3 of 7 Cost/Unit($) Removal of clean electrical equipment, <300 pound Removal of clean electrical equipment, 300-1000 pound Removal of clean electrical equipment, 1000-10,000 pound Removal of clean electrical equipment, >10,000 pound Removal of clean electrical transformer < 30 tons Removal of clean electrical transformer > 30 tons Removal of clean standby diesel generator, <100 kW Removal of clean standby diesel generator, 100 kW to 1MW Removal of clean standby diesel generator, >1 IVIW Removal of clean electrical cable tray, $/linear foot Removal of clean electrical conduit, $Ainear foot Removal of clean mechanical equipment, <300 pound Removal of clean mechanical equipment, 300-1000 pound Removal of clean mechanical equipment, 1000-10,000 pound Removal of clean mechanical equipment, >10,000 pound Removal of clean HVAC equipment, <300 pound Removal of clean HVAC equipment, 300-1000 pound Removal of clean IIVAC equipment, 1000-10,000 pound Removal of clean IIVAC equipment, >10,000 pound Removal of clean IIVAC ductwork, $/pound Removal of contaminated instrument and sampling tubing, $/linear foot Removal of contaminated pipe 0.25 to 2 inches diameter, $llinear foot Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot Removal of contaminated pipe >4 to 8 inches diameter, $Ainear foot Removal of contaminated pipe >8 to L4 inches diameter, $llinear foot Removal of contaminated pipe >14 to 20 inches diameter, $Ainear foot Removal of contaminated pipe >20 to 36 inches diameter, $llinear foot Removal of contaminated pipe >36 inches diameter, $/linear foot Removal of contaminated valve >2to 4 inches Removal of contaminated valve >4to 8 inches TLG Seruices,Inc. 172.57 578.96 L,L48.82 2,659.64 1,878.11 5,319.28 1,888.50 4,212.30 9,7L8.57 IO.DD 6.65 L72.57 578.96 t,148.82 2,659.64 201.26 680.14 1,360.00 2,659.64 0.69 1.10 L5.52 26.I4 43.62 83.77 loa.79 138.62 164.58 329.26 398.41

Three Mile Island. Unit 2 Decommissioning Cost Analysis Unit Cost Factor APPENDD( B UMT COST FACTOR LISTING (Power Block Structures Only) Docutnent F07-1676-001, Rev. 0 Append.ix B, Page 4 of 7 Cost/Unit($) Removal of contaminated valve >8 to 14 inches Removal of contaminated valve >14 to 20 inches Removal of contaminated valve >20 to 36 inches Removal of contaminated valve >36 inches Removal of contaminated pipe hanger for small bore piping Removal of contaminated pipe hanger for large bore piping Removal of contaminated pump, <300 pound Removal of contaminated pump, 300-1000 pound Removal of contaminated pump, 1000-10,000 pound Removal of contaminated puop, >10,000 pound Removal of contaminated pump motor, 300-1000 pound Removal of contaminated pump motor, 1000-10,000 pound Removal of contaminated pump motor, >10,000 pound Removal of contaminated heat exchanger <3000 pound Removal of contaminated heat exchanger >3000 pound Removal of contaminated tank, <300 gallons Removal of contaminated tank, >300 gallons, $/square foot Removal of contaminated electrical equipment, <300 pound Removal of contaminated electrical equipment, 300-1000 pound Removal of contaminated electrical equipment, 1000-10,000 pound Removal of contaminated electrical equipment, >10,000 pound Removal of contaminated electrical cable tray, $/linear foot Removal of contaminated electrical conduit, $/Iinear foot Removal of contaminated mechanical equipment, <300 pound Removal of contaminated mechanical equipment, 300-1000 pound Removal of contaminated mechanical equipment, 1000-10,000 pound Removal of contaminated mechanical equipment, >10,000 pound Removal of contaminated IIVAC equipment, <300 pound Removal of contaminated IIVAC equipment, 300-1000 pound Removal of contaminated IIVAC equipment, 1000-10,000 pound TLG Sentiees, Inc. 796.48 L,0L2.72 1,345.01 1,604.65 r06.09 326.47 696.25 1,655.34 5,414.54 13,160.39 7rL.77 2,L99.r7 4,965.06 3,2L0.12 9,308.12 L,L62.67 23.76 545.67 1,339.76 2,573.65 5,2r0.82 26.68 L2.65 614.05 1,5t4.27 2,9L3.58 5,2L0.82 614.05 L,5L4.27 2,913.58

Three Mile Island Unit 2 D ecomrnissioning Co at Analysie Unit Cost Factor APPENDD( B UNIT COST FACTOR LISTING (Power Block Structures Only) Document F07-1676-001' Reu. 0 Append.ixB,Page 5of 7 Cost/Unit($) Removal of contaminated IIVAC equipment, >10,000 pound Removal of contaminated IIVAC ductwork, $/pound RemovaVplasma arc cut of contaminated thin metal components, $/linear in. Additional decontamination of surface by washing, $/square foot Additional decontamination of surfaces by hydrolasing, $/square foot Decontamination rig hook up and flush, $/ 250 foot length Chemical flush of components/systems, $/gallon Removal of clean standard reinforced concrete, $/cubic yard Removal of grade slab concrete, $/cubic yard Removal of clean concrete floors, $/cubic yard Removal of sections of clean concrete floors, $/cubic yard Removal of clean heavily rein concrete wI#9 rebar, $/cubic yard Removal of contaminated heavily rein concrete wf#9 rebar, $/cubic yard Removal of clean heavily rein concrete wfi#18 rebar, $/cubic yard Removal of contaminated heavily rein concrete wI#18 rebar, $/cubic yard Removal heavily rein concrete wi#18 rebar & steel embedments, $/cubic yard Removal of below-grade suspended floors, $/cubic yard Removal of clean monolithic concrete structures, $/cubic yard Removal of contaminated monolithic concrete structures, $/cubic yard Removal of clean foundation concrete, $/cubic yard Removal of contaminated foundation concrete, $/cubic yard Explosive demolition of bulk concrete, $/cubic yard Removal of clean hollow masonry block wall, $/cubic yard Removal of contaminated hollow mason-ry block wall, $/cubic yard Removal of clean solid masonry block wall, $/cubic yard Removal of contaminated solid masoruy block wall, $/cubic yard BackfiIl of below-grade voids, $/cubic yard Removal of subterranean tunnels/voids, $/linear foot Placement of concrete for below-grade voids, $/cubic yard Excavation of clean material, $/cubic yard TLG Seruices, Inc. 5,zLO.82 t.57 3.03 5.90 29.59 5,166.38 15.07 r6L.72 204.76 384.77 L,r72.57 246.65 1,631.53 3L2.r7 2,15L.28 472.38 384.77 970.85 r,625.26 773.t2 L,5L2.45 34.4r L27.29 225.66 L27.29 225.66 29.40 140.98 106.48 3.72

Three Mile Island. Unit 2 Decomm.issioning Co st Ana,lysis Unit Cost Factor APPENDD( B UNIT COST FACTOR LISTING (Power Block Structures Only) Document F0 7-1 6 7 6-00 1, Reu. 0 AppendixB, Page 6 of 7 Cost/Unit($) Excavation of contaminated material, $/cubic yard Removal of clean concrete rubble (tipping fee included), $/cubic yard Removal of contaminated concrete rubble, $/cubic yard Removal of building by volume, $/cubic foot Removal of clean building metal siding, $/square foot Removal of contaminatedbuilding metal siding, $/square foot Removal of standard asphalt roofing, $/square foot Removal of transite panels, $/square foot Scariffing contaminated concrete surfaces (drill & spall), $/square foot Scabbling contaminated concrete floors, $/square foot Scabbling contaminated concrete walls, $/square foot Scabbling contaminated ceilings, $/square foot Scabbling structural steel, $/square foot Removal of clean overhead crane/monorail < 10 ton capacity Removal of contaminated overhead crane/monorail < 10 ton capacity Removal of clean overhead crane/monorail >10-50 ton capacity Removal of contaminated overhead crane/monorail >10'50 ton capacity Removal of polar crane > 50 ton capacity Removal of gantry crane > 50 ton capacity Removal of structural steel, $/pound Removal of clean steel floor grating, $/square foot Removal of contaminated steel floor grating, $/square foot Removal of clean free standing steel liner, $/square foot Removal of contaminated free standing steel liner, $/square foot Removal of clean concrete-anchored steel liner, $/square foot Removal of contaminated concrete-anchored steel liner, $/square foot Placement of scaffolding in clean areas, $/square foot Placement of scaffolding in contaminated areas, $/square foot Landscaping with topsoil, $/acre Cost of CPC B-88 LSA box & preparation for use TLG Seruiees, Inc. 32.49 23.55 22.75 0.34 r.67 2.95 2.60 2.56 9.36 5.46 t4.71 50.37 4.69 850.33 t,454.77 2,042.99 3,473.58 7,581.02 30,668.72 0.24 6.t7 10.94 1,5.27 27.59 ,.oo 32.10 13.55 18.24 2r,3L2.72 L,727.27

Three Mile Isla.nd Unit 2 D ecornmissioning Cost Analysis Unit Cost Factor APPENDD( B UNIT COST FACTOR LISTING (Power Block Structures Only) Document F07-1676-001' Reu. 0 Append,ixB,Page 7of 7 Cost/Unit($) Cost of CPC B-25 LSA box & preparation for use Cost of CPC B-12V 12 gauge LSA box & preparation for use Cost of CPC 8-144 LSA box & preparation for use Cost of LSA drum & preparation for use Cost of cask liner for CNSI 8 120A cask (resins) Cost of cask liner for CNSI 8 120.A cask (frlters) Decontamination of surfaces with vacuuming, $/square foot L,584.45 1,301.09 8,595.11 192.13 7,110.93 6,993.18 0.96 TLG Seruiees, Inc.

Three Mile Island. Unit 2 Decomnt issioning Cost Analysis Docurnent F07-1676-001, Reu. 0 Append,ix C, Page l of 8 APPENDX C DETAILED COST ANALYSIS DECON TLG Sercices, Inc.

3 3 6 5 6 F 6 i E + - _ d d d a d d d E. 6 ' i i a d 8 : x R B g F 5 s. ; _ 9 - S e e E F B x r i d j F B E g p, : 3 ; s ; 3 d J F j d j d B f i R F E q R C E q g E. F R E 6 8 B E 3. 3 3 : 8 s S. j d d j d 8 S ? 3 F r t ; N { N a c N - q - - p s q g e s s 6 6 g $ E ; i i d i i d s S g F E e i E d @ a $ e g. E g g F, s g $ 3 3 4 8 3 5 B $ i g e F " E a g E g EgPR*F BF.C,R.S N N 3 6 B a g E 8 5 P d I d'F I ts 8," i.t i a*EEiitE;sEs giiiciE;EEE ' : 9 9 : 9 9 ? i N o ! e F;;;;;; 5ii$Bi EE q g I I F r 5 s E $ {? s e { A,e "E i t " 1 F, i i r - i E E , E* telilsl,gg.tii l g, r :5s f:ffB* E i EiilgiiEgif e i$jig3ilgi a e

q o - o o s o o 9 l l

= l - ! - N 6 ' t - N e ! 6 @ F 6 o : i. i - - i - -. a ' 1 -. -. H i E E i s s E s i ! H i s c

s s s s. t s s 5 s s s e s e s ; s g s s E]

.5 o F l ^

E !

5 5 ? M A c 6

{ iH

! H ' ; E

. 3 l

i !

. i E a sfii z d ; E5 l i 5 6 { $ {. s E { - 5 6 3 f A

. 3 9 $ g c g g g c q E E 6 - - i d r r i - d d i

g

. E 3 S S ! 6 g:lH 6 E g B d d d

t s 3 P 5 H S 3 3 3 s 5. s F s g i p F q S $. d "

:. $ F
S i S F q S F - 9.

. e. i 3.

3 e 3 R E g F.

t q F e q q q 6 N 9 s 8 E 5 B ' 3 d 3 8, c t Ei, $ Al.E s i !,i;t i a i i "cai; -er .s-5 ti! "iu,E e ;i+ $,.,f i:;iiii*sBig! E i E tgii3s:ffi33;iEii,* lE; Egliig $s:iisisffg {..r===r==::_ - g { !=======:::=;;ii!=_ $=*_ E=*r*"

i: ;:e::eit}3, i

l;;;;::;;:j;; ; H E E;;;;;;;;eaeeaeeaae i### Ia;#;s &ae*eeiliiiiill g $p;i..5;sQFP. 3333 ;*3 3g*qg p F F .. S s s s F. c F i $ E B g 5 8 S 3 t X ' X 6 R ; ; 8 8 $ 3 j j l 8 s s,, : l E E q s H R F s P g 6 I F N g S S g e j d j d d 1

i

{ d d d J - _ i d d 6 N, O

T

E P E R B

8.,.. q 3 q i t s. f r, 3 e 5 o l c ^ q i E 5 6 E E 6

r FF E " 1. ; t f i *. 1 {
EE sHi t l X t r z

d q ! s. \\ : i $ r $ s : ! o !. s

.1 E 5 S A

$ss $3 $EB.q$qgi333qtgi$g g*c gqq$ g*$ $ E R ; 9 9 ? ; 9, 9 8 t s 9 8 t d - a d j d d d d d d d H 3 { F F S g B S ; $ t 9 S n s E r i g e g i B i _ i 6 6. 4 d d I 8 3 6 A e - B< s _!=sig i",*,9 ;g*"e*iEt,*g F ; g tsce ,i:E,i, i, iEtEe*,Eesaift{ieleit*e "E : ; r i { riir ili!r, fE i:, siEEEEiiiit $ i E Q { i : : : : : : : : : - i - - i : - i ; r r ; : : ; : : 3 ;. ' : : : : : : : B s * * * $ f } * $.

q.,

r

f r F 5 ! ; ; ; ; ; ; ; ; ; ;

5 i l l ; ; E " i ; ; i ! ; ! ! ; ! i s ; ! ! ! i ! ! ! ! i i s ! ; ! ! ! ! i ; ! g r I g a. q. o. 3. 3 c 3 :. ; $. $ $ : 8. 9 E q c s. c F B i d

e ' * : : { e F x E ; g 3 5 i s ' B R + g

. 8.,.. 8 d d i - _ d d d s g. g, c. c. ! 8 s @. ' 9, 9 3 E 5 g !, r. *. H. $ { E 5. 3 s. R s f i i g c.

e J = $ ;
I E E E S. ; = H s E E q f r 3 R R $ f i g g i q a *
p i i : $ R ; I I i s n e s o R d e e. s - 3 r 3 8 $ g ! $
R 8 p
8 3 - g - $

3 d. s, =. ;. s s !, : N. F 4 3 3 3 -. :. Q s g - 3 8 ' g e 5 8 8 S. 9 -, s 8 q b g., q, s. i e : @ t s 3 d d d d d d d d F R e S ; 3 8 t s 8 3 d j i d d d d $ 8 E E S 6 e F 6 9 B F S E d d d j d d d 9 E @ t E q

R 3 3 ' n o E d e s f i E t s s ! F g 3 R s 3 P R :
i F i R 9 : $

d t ' r _ i d d e 5 o t r l ^

EE 5 6 !

E a

r iH i J l. ; :

e ! *. 9

XE; o v t

, Y Z z t S E E5 s

i 5 E T !

{.s i.t P 9

H H p $ 5 3 H s E SF! 3 A E98Sff" d d d ? F d a s Eg33:e3$:fii:$$B EF3* 3 g I - ee g iEt -E i 8,, ^{ gs,E??tg" ifti ii,ri:ii*uisigi E i ii siiisr53tiffi s ','"- {-'r'rc:::iill- ^ g;= i=llllllllii!itii===r = d a o l ; ' ; ; ! 9 : : ! ! ! a - ' s s s r t s e s r : : s : e s e : e i ! E & i 5 * + +

d t ' E ? l 9 " E

r E {. i ;

3 E F !

x *, i i E :. J d ; t E !

d i rgEiigii?-:

! i N 6 r 6 @ F @ I I n r e d q 4 q q

3 !. " 8 8 s 8 a 9 I

3 S &. F . E d 6 d i d d d .. 8 3 d 3 E ? R E B E N { e a o o 9 q: B g p S E s g. $ s d 6 d d { d 6 < _ d ... - 9. . t s 8 E h 8 E j d - ' d d E E H { s s f i s R g s s E d E K s o. o 1 i d B E s : R s 3 P g e E 3 3 R B Q 3. ! F p $ _ d j d d g : E

3 : B e
3 3 3 3 ! 8 3 !. i E d g N F e = o g N 6 6 s e
e 1 - H r R g

$ s s i ' f r ' s g R 3 e R R. $ R E g 3 5 Q 3 e

g = = : F 6 " E e @ f i 5 $ H c i j F E F E ; : E F : E $ $ $

E - ' ' d d 6 - N f l g i s a $ E. F E 3 : R E : E $ g E R i d d 6 d J d l i - f : S f l

? : C 9 : E R R 6 E E 3 N d J 9 T

J i d i d j d d i j d d d r d t s s 3 3 8 3 8 8 8 a 6 o N N 6 - o - . 8. . i : d 8 $ 3 $ E i i j i d d d d ... F S ; 3 8 o 9 6 d { d d d s a 6 I s.. E f p t e 5 q F 4 ^ E.E 5 a ! - - = e 6

FF

! i 1 ' ; E F : *. 9 { XE; U E E L Y X F X F z c s u:

l R F E {

- E l ! d

. s

_ { q l

E r 8 S A

9 d S B E j d d 4. '.. . ' ' o ? n i : E S 3 6 $E 8eE!ilfr3Es$E - J i d i i j d { N d d R q. E g E E f i $ ? s ! $ g

r r d

{ + - _ d i s 6 o s 9. F R : g q R 3 E $ g E d i d 5 d d 8 t s $ ' R S 3 $ _ : ; 3 3 8 S 8 S F d 1

F Eg, ".i
I e E _ ! t

,i-EEE;** ii ii 5l i i-$"8,l E ;ii gsp;r;; ! i-E e F E,,,*,n,uil{f ga,id s rEA, 3, "E ? i }i_! g g i Int !.gEi5EHj::; Eit?e t;ss

,: [=i=',

I iilgri;gifg liffgi gg:iiiigsnssEgE l i fEIg Erg !E; E;ll;lll- {-*.=*rr-.. i====- i===::e:::i:::- - E ;-=- i=. !r-Ezzzaaeaa

!!!!i!!e$A; E!!i: A I;;;;1;;;;;;;;; ; H Is;; Eq{ i**

$ 9 *

3 - S F

8 g d F n I c c B p $ c a 3 F 3 3 ; 5 3 E g p. p E.. g g d d d d i i i d i d d d d d d ; d F d d 3 9 *. S 3 I 3 5 P : l 3 S B ' 3 C C d d i d g d d - d ! E ssFcEg$3 d + j d - _ + d N 9 9 Q a g 9 3 E 3 3 e $ 8 3 3 3 3 8 3 8 d d d d i d d d d { d 8 3 s a A B S E F o a 9 a { 6 - o - t q o - = + d d i - _ d d d d d d

e 3 o N 5 o 3 5

E 3 R i l 3 B t ' d d { d d d i l E J : F 5 8 3 9 9 8 . ss..t lq f ; c B " s f ; ^ g $ ! : ; 3 3 ! $ F. g E i d d d d 5 6 t - d i a tr H e 5 o t s l ^ e 1 l t r ' : 6 : 5 a ! E 6

s'i5

! r ' ; E F = ' = ! ! E t '. 1 8 S , i I z I { c _ r $ R u f P r F ' t : s6 r S u { s

. 1 xs t 8 s !

6 b g. R i s l a 6 ' ' F 3

; : 3 E 3 6 T A L : ; F S d F F. g

F p $ $ $

: ' $ " 5 E 3 : : ' : F ; ! '

i ; s i l g 3 r 3 9 8 3 S 9 $

8 g i d i d d x 3. 8 3 9 p E s : : s 3 d 5 g t s ! g 3 g q 3. d ; d - i i 6 r d d + E : r 9 S e : 5 8 S R 3 S \\ e

: 9 8 6 F t : ! 2 o e 3 : t s N 3 +

' ' s I s r ? E E r E 6 F s E R q q F $ s g i. 8 S F E i l

d j d t

6 R J r F

s E

i g !r: ,igEti E r*, igEit.E{ii,E *.i;.gEi _* E iiu," ! lti-l iii*:"i t::iisg;stfi i r i I aiii:s:iii!ii,:,

tEE iit}$gg: ig t

R R : : - ^. -.. - c o e : a e : 3 E ; : : : : s : : E ?,. F ; E E : : : : : : : : = = = i = = i ! : 1. E ;, i { i { r, I i t i * * + { * + g i + * *

H E r A e
a a c a a
6
a i o : t 6 3

!l e o H ^ e J l I ' = X c 5 d E - & Q -. : q

E ' ! F i ; 1. ; t F = ' = i i E E 3 o Y i r

x ; F X F z a P

- a

r S E

\\ ! i$ - E ! . d !. 9 ! lsi s 6 EA

s s d 3 E g F 5 9

; g I

5 g 9 s ' A b 3si t E ! d g i e3: s t ; g E E ! :. E

E: ?

. t E E a C ; E i E ' i :, i ; : g3 F4 - 7 E 1 8 E E - a o I . l s t r x e 8 e ; i I E e g 3 H : C ! Q 8 isiiEe?Fit I : F I!Eii#trs; P: F ! - N 6 ! B o F o X i a ' + ! i a ! ! ! e E l E

. ; N " i e 3 F 5 5 g i d d d g s s e 8 3 t r d d !

,., r. F E 6 ; 3 s, E P 5 g 3 3 R F P I N i s d o g g d l 1 t { a d 1 d r i d g E g j i g3c E r :. { 3 B a 5 q t s ] ^ . t E E 5 6 ! g 6

E i i

! H ' ; E F : = ' = i > E 8 ,, E n o x i z q : \\ !E5 r 5 5 6 d s t l i i' ' E ! d F d

Three Mile leland Unit 2 D e comrnissio ning Co st An aly sis Document F07-1676-001, Reu. 0 Append,ixD, Page I of I APPENDX D DETAILED COST ANALYSIS DELAYED DECON TLG Seruices, Inc.

C R g g g C E $ R F R C R d r i d d d d - _ d ! d N d ' " 6 ^ C 9 c. q E6 x 6 6 3 " " 3 d i d d d d d .. i ; 3 8 S 3 E

3 S 9 3 3 9 3 s 3 s d, 4 4 6 < + 1 HA ceFSi$ q333*qR Fg.Ep*3EE"

$.43!*q. s s 3 g F S 4 d X g F E e S a Ri s3E$i3 9g$3*q$ g 3 3 E e i : : s d d d d d d L i d 3 I ! t;3 c. f a

.i f;i j r i 6 { E F i? n E g J f 5 s I ;,! { I gi - uii E 6 2 i i i

i q

Euriie i ! .r u iHcg,9s $ii g iH l;,i?l5ul !,ti l; Ir3*,Eq !si;ia!ix!Er s ie;:i i'i*i iE;ff;f?i r! ?.*3i;"ssl e"iEgi{ii*Eig + t i lEi f:ig3i i I jg;3ii; 3; iise?isig; i H i is3islsFFi: ii E i irr !;;,r,, I !:::,:, 3, !:rrr:::ru u fi f; !;:;;:;;;;; 6 6 . 3 9 : E,,,. 3 B 3 T t a ^ 3 a . : b ! 5.ti ^: gE o = ' = d E ' i : t F

5 +

E t s I 9 i i f o F FI 6 d {

8.

q d [ { s 6 1 - c ! s i l. s

. 1 E :

k a

sRERECCFC9EE d i r ' d j - i d d g -

S S i R F

{

i R S 3 t R 8 8 f r 3 S a

- - &. - 5 . E P : ; F 3 3 8 8 F F s F F S $ E ; d i d d d . $ ; 3 g F s,. F 3 F g N ' F r - 1 o { 6 - c - { p p F .,

q s s E s F F $ $ g ; "

8 8 5 3.. g x ' 3 $ R ; a 9 g g g s g p t s r t 3 3 R s 8 8 R 8 t s E 6 d { F $, : F

3 8 * [ t S 3 $ p d ! ' d d g r d - ' d

'. s $ e 3 6 5 = g s E s d g d i i d f t f i : F e 5 S 8 B 8 F 8 8 8 3 8 8 d g d d g F t - o E E : d E A. F 3 I $ i R F : F H i d i i r - i d 6 4 F H,.,, 9 * $ C p - 6 C 3 d j d d + o ! n; ,"Ei =!,* i ? i;

f e,f,B;llEtg;*,:;E.

eii

.,i, i

igi=

iii;gii II3i$s is $*fiii*igEsg E i f Eg53dsfu 9 - c e i i l E i - - " -.. " " e ? : 1 q l E 9 . { i i : : : :

! r : s e i -,. =

i i -. - = s g l r r i i - ^ 3 t t : j i : : i ' j ] l : : : : : : : : - i ; ; ; ; ; ; s s ; ; ; ; ; i i 3 ; i ! i i i ; i ; ; i ; I ; ; ; ; ;

F I E ; ; ; ; ; ; I a e

e s a e a e c c

d o ? . E u : P E A ^E.3E o ? ' : d E ; E :

E's

> E E x H t t z 2 F O E I o i b d 6r iq d E I s t 3 { 5 E l. s d.! a t E A

d F A S R 3 9 9 R ; S E ; E 3 S. 9. 9. ;. 5 3 g 3 ' $ d R J i F 3 ; 8 R :. $ F R $ F e R E : E e R R S E $ f ; E d F F : C. d j - - e T r o

3 S : 9 3 !

! :. $ F a $ i a F : 3 i : 3 I s E g g !.

E g : :

@ e. ; 3 q 3 3 ; 8 R E E F g $ E R : E F 3

8 S E

' d d p - ' 9 1

9 1 ;

g E 5 i E-z s t ui { i. Ii,*tA i i-,, sj

i; i;i*

is*gsii*'igigl i u I i aiii,gEifu, FEi Es, gisiiEE -" t-nn* {.^.-..*.""=oo I 3 ; !-r:;ii::1. E== l= }.rlllllllli; i l q q s i d 9 ! 9 4 i ! ! 1 a ! r. j

s c { * *
a a i a s e a e ; j i i J ; ; ; ; ;

f ; E i E ; ; s ; ! $ ; ! ; ! S ! s 3 ! l A ! i ; ! ! ! ; ! i l ! t 6 o 6 & 6 c i E E 8 ' ! s 3 g

p * $

d d d g d

x 3 g 3 5 e 3 R

-'l -l - 3 F s ! 3. 3 i i d d d 3 1 F $ g 3 g , S ! i ; d d d d s B x s g E : 5 3 5 9 S 9 3 3 9 F g i F - 9 ' F ' R ; s 3 E " $ 9 E d d F E q q R C 3 3 ' n " 3 x e F a ^ d t = b : . ! i E O - ^ E A = E i E : f i

5 r E E E x H t

t z 2 F O F p o a i 's$ E{ F E r$ r { f F ,!.s

. 1 x 5

! 9 H Q

3 ts g E i E S g 4 : 5 !;i $ E n re t ,f e E I r s d

i i

.FE,i s {;E,JEEIE! glffE fg:if3iis;g?rf E i r3 :

: q. : e e c e c E 4 l i g i -

i

: : ? ? ; ; ; : ; ; ; ; : ; ; ; ; ! ;

3 E j ; iT ? a - E ' i q ^ i i

sii 5!!:. E ?iffiii:i;ifiiiiiii;ri i l;;i;siiEEi!;gili;3rFis g

N d r 6 6 F 6 o e -

E : : : 9 9 5 : : : : : : : : : : ' i : : : : : E 6 d d d i d d d 6 i i. i i d. d d o d d a d 3 3 3 8 - r i +. i i i r d j o d i d d d i a s 9. x 3.. 3 . 1 ".., '. - e s g E S R g S S d + d d ; d 8 e e $ F e s. e r i d d d ? d ! d , ' d 3.. ; 3. 9 e t s 5 8. J. t s S e 3 t s S B R i P : B p g i g e s j t " ! t ; i - g - _ d d d d d - ' d d d i d F 9 ; 3

e i 9 E S 3 d d 6 d j d d 6 : : F B A 4 3 6 F R A E 3 3 dR --g

e ;: 3 $ ; e B I 8 S 5 3 9 3 S E 6 i

d i J - _ i d d d ; t ' d _. R _ S ; r d : F _ ! B $ 3 9 - E :. 9 6 E E d g R F g 3 8 r e J d d d d 3 & ? 9 R 3 ? 3 8

8 8 i e d ' 6 d

{ r _ r ; d d d d .,. p 5. F t F d 9 d s g d. H E. 3 e., s d d a d { 6 3 I 5 6 6 8. 3 9 R 6

. 3 E 3 9.

tsts E R e 3 t 3 * : E - _ 6 d

g 8 o R 3 E 3 E E S n ! ! o E I

-. + ... i. :... - 3

. 4. 4

3 E g e n 9 3 g S e F E : $ F ; " 8 e ! 8 g

- d J t r l ;

i z 4

? r E P E i F $ 6 - !. 8, $ 9

E

i i e 5

d d ' i S r F ! i

a J E r cilait!

l i E ! o t E q . t ; ! i E E t E r i 5 f ! 3 5 t iiElTn?$ 4 d,. 3 &. 2 d 8 j i n " i o i. i c e. { g I c 1 ( ) 6 . : u : I. : i a n ' i 3 o ; ' : d 3 ; ! : i* 3+

E T

H I

t 2 2 t o F F ( ) - o 0 i t d b

isd sd p

t 9 r i

. l ! . 9 r t - l H A

K e s g S : x ? 9 e - 1 B F I

3 3 B F g F S

E X ;. R ; ; 3. F + l : - ' - d E 3 R R { N 8 - A $ 8 i d = F R g $ : B i l R A. E E E i F g E 3 P i l C f r i F 3 g : E ; E E P. P a i e E i r E o e

e E 6 g q $. i $ - g E S F i i g l n i F. i i d

r J d g d d j 6 ! 3 5 9 3 t s ; S g 3 S E 3 $ R g j ! 3 3 e 3 3 8 8 t e S ; j r d j d g E E $. 8 ; : 3. $ q.. $ i 9 g f e E 8 $ s 3 E . 5 - 5 d o @ R,83_t 3 S 3 $ 3 3 3 e f r S d d d t s d d d d d d 8 $ 8 3 g E B 8 r S d d d i d d i d d i

3 e 8 3 3 8 3 8 S d d - _ j d N d i

d i g ; F F s $ i,

lgf,g,gfi3?iiiii*

i*,,u*uu,, i iliiigi3ii gfuii i;lllllillrlil!;tiii= = E=::::::=

ir*****=**.

!rr;*, S e e e + e c e e

e e e S e e e e e e e e f +
J r ' d j d d s = R r 3 5 3 e 8 3 3 C B S 3 9 F. - 8 S 3 j d - - d d a N o N

' + : o e . { j I S B S R S E E -. 4. ! - P R E s S * ' -. - e o - @ - F ' 5 - 1 q n; g 6 8 3 F 8 S " N 6 ' 1 ' I ; q S s B I n F S i b g R s e n F. $ 8 8 9 F i q g " 8 g ' g g 3 : s 3 3 i i s E. F r d d i I R d d d d d i i d J 3 ? o R ; C r ... 8 8 i 8 8 o. :. 3 t)

3 a

u :

t ! 4 v E : ^E.3E e = ' : d E T E :

5
E E :

9 t E F O F o a b d 6

lB {

si F ( B$ i r{ - c ! p d {. s ! T E A

i i : H $ f r 6 r e E d i _ d d d j j d d a t ! E a d * ,{8,,;,g,ix*, B-sr{s'i u 6;E* j'. IEi?i Et: fts tE, " &g eEt;E "EFi fu*5sii*uifigi Eiift*

i*: ;r E,;effi*u;ig; ariEeiiiisg

!;:;;;:;;;;iil;

t !,;= !s* !n* !;e;;;;;;s;*

= E F f i;;;;;;:;:; j d q a d d d d d R 6 9 3 I 8 3 I I d d o q ' F 3 f 3 3 3 6 3 8 3 i ; i d i d { ; d t d 6 d P t s 5 9 3 3 e ; g R 5 p E 8 F : d d q 6 d d . - 9 E g 3 E B * : s 3 B : 9 3 E esfrEfrp*.F3 A. $ I e, 3 " R e 3 g $ i g.

. F s"p :.3 qg 9
s g 9.

, 9 ' 3 F 3 3 ; B d d { ; @ e i x x 5 C. 3 3 3 3 $ S ; : : 3 S r j

d

+ s - d i d d d d - _ i F d d I A & 8 3 3 8 F ; d $ ' j d d a d i

.3 P 5 H e

6 a

. : b : !. 5 i r e ; ^E'3E o ? ' : d

i i E

E *

> 3 : Y z 2 F o F E o 5 { b q & l {E { i $ 3

d s !

! r {. s a 5 E E F A

F. 3 s F i H $ $ d i n d d + d n 3

d j

,s,.8 r a s & 8 i : d d { : R g 3 S s Egq 8 r a 8 3 3. 9 : Eiq*

f ; s

>, al t t, e. p F I E :

! i i

= t ;. !E r . ; i r E i ! I E

s ? ? Z E

E

E Ez r

! 5,C.i t EE, { 58.; ? 6" a =*:$ i,i i,;i,iI E,- EH E

il'i,

g lIi

sif iii fuigft;igg E I E

= r s :

i a f R r E - - : - - r - *. ! - d 6 {, o l r

- d o i '. @ F a J

E a : i : : i l - : ! + c e q d N

6 6 f i a ; ' r + ? ! r c

I F E

e a a e i *
c A i e c c e
i I E i i
i
e i ; i i r H P 8 g R p 3 : F C 3 3 S

A 9 N 9 F i d i a 8 8 r 3 P S i P S S S d d d d 9 R 9 F E 3 5 I 8 $ B S 3 R e ' - c - q ? q i 3 3 t E S e 3

E B d d i -

d i i d d a t p e 5

3 c

. : u ! r. ! i P t : ^E 3; e ; = N E J I 5 : E* t+

E F Y / '

t z 2 F O F o i t ' d 6 t B n s d s{ F. s A

{;s8

{. s

B E E

! A

Three Mile Isla,nd Unit 2 D e cotnrni ssionin g Co st An aly sis Docurnent F07-1676-001, Rev. 0 Append.ix E, Page I of 8 APPENDD( E DETAILED COST ANALYSIS SAFSTOR TLG Seruices, Inc.

9 C 9 i t q s t 9 9 9 9 ? ? a x S Y E Y 6 i F i : 6

i i d d d d d d

- _ d { d d d P f d d R - = ' ' & & F F ; 5 8,,. 3 $ S : p 3 I i d i o 9 ! : : 3 3 3 d d J d d d J $ i + 9 E.... 3 6 $ a c p $;qiq gi3g* 9.3 $i'cEtggq' gs31*g' s D e 9 F { E d t g F q s : 3 ' R3 *$5*q3 3g.i.guq$* ia 6 ! s 3 E d g 'l fi s eA s E i E F r i l " F i HE, f i tlg i I'F 'E : li';i i,;isi

ii;ilisi ii E,slis,sc$

Euiiiiiii$r ai**,i f; ! !sr !;;::,, fi !,::::, != !::::::*;, = F f; !::::;;:::; E;i::;i;i i n - - r d d d p. s g ; 3 $ 3 5 d i - ' j d d d F S 8 g E. H F g $ p 3 3 i j i i i d d d a d i i 6 6 P t o 5

E ?

r d * ' u A 6 l - t I : ' i : i3 ilg f i * ' E

E !

c 9 ! tAi 9) a i b i {* : B q R E i E. ! \\ : 5 t - a ! E d ,!.s

. t E 5 E 5 E d

r _ d o @ s c s 3., ; R q R q g g F g E E d ; - - _ L J i i _ d j - r d d g d e 5 E S g 8 5 g c g p E. g, q 3 d : g r 6 d F d d t s - ' d j d 6 d d j t j j 5 g : 3 q i : 8 ; 3 ; g 6 J 8 8 3 8 8 i 3 ; o s F $ 3 S r-d' $ p ; F.. $ 5 3 Q F. e,. 3 3 9 $ E P H N. . s a E E F ^ E R R $ F F g E E 5 3.. g x " x s R ;. g g q q

t s p 8 a a t s B R F 8 8 S R 3 3 3

g ; 3 S 3 i 9 : i ! R - - i _ t ' d d d H.... $ R $ S R

g 3

i d - d = J c t s 8 I 8 d .F rf u s,gi;{;i;,it .T E"i*.

isi,iii;iii igiigi: i i,i;iii sisl ii;lg;;g3:;ff 6, e = x i

s s A n * ; _.. -.. *. o 9 : ! t l i e 5 : : r : : E : : : : :. I ; i r : - I " E : i : : t : ! : q i i, - E ; ! : : : : : : : : : : : : : : : : : - t A, q g S s d g g 3 s 4. l e *, i s g g i ; d 4 3 3 ; t * ; s e ; e ; I H X E

e s a *
f
r s 6
4 I E ?

T O i "I iE o ;. : d

" 1 g t r: : E.

E E i o 9 9 9I.E a a r b i iq { R E I \\. 3 Ei 1 { - 4 ! t. s

. 9 x !
A

B S aa

6

,gffE?c,E $r$$t!!;FEg? EgsiEEiEssiE { i;s:;r;;r".i: j x'ii;;;;;;i;t F E t ! ; P -

- !il r$,{i-ti,s.A

aAi isl;i*

fu,;i:ii*uigigi g H I i r;tui*ili, iig 3: i-" i-",. f"qe*.....e:r: ! I { !=,r;:t:tt- 'E.. ;H=

4 d e: t n a a !

i t - a r i i ' & s r a a a "

u u * "
I ! J i ; ; ; ; ; E E E i ; ; ; ; i ! ? ! ; !

5 $ i 3 i t B $ S g g e E a s E d s s R f $ 8. 5 s ga,s.s,3.39 g * ' s. 8 i r $ ii ti 8 3 3

8. 9. ;. 9, $ $

3 : 5 3 5 9 3 e 9 s. s 3 I 6 F 9 S S ; 8 3 9 8 I o ' r 8 3 : R 5 I d d 8 g g { f s B F S g $ 3 9 8 q 3 d r ' g d d n ' d i d ? i - _ 9 t a. F. E, n. *. 8 3.. J e g 6 - E @ a g g s i s - e - F 6 R ; o { 9 3 8 5 - ' d - _ e 5 S E P e 3

B X " :

d t d d R " A ! 3 3 h. $ ; d d o N 9 3 1 F E g 3 g. $ 5 . - o I 9 i s ".. 9

s., d 5 3 S :

3 3 8 8 e q ' i " 3 3 3 9 .. e q 3 5 I E ? F d * ' u x E.E; 6 : b e 7. : N E i l g : r: *'E'l E E ! e R : o x ;

x. i a

a r b q d F F f i.ir E ! 5 t t

{st

i

{. s r 5 E A

6 H S B S S s r 3 9 3 g 8 3 d d d d + d 8 P F S S e f r. 8 r j d d d d a d d 3 3 i 3 5 i d i d d ... R. F.. 8 j - ' d I I F s s-;;c i E s i;EE r tt* g i c 3 j*fii ;a* Ei { '3 F ? ri3?iri=E g!9..cE fl ieti-i ;;jsiriiiE sifts iE*;*sii'u{ E I Ei s 5 i - " '. o *. e ' i i i i g ; - i - E ; I i : P R r 3 " I ; $ E n,, r ". - - " " i ! i r n r { ". E ; { e i J ! s e e s s $ E e s s e E s 3 * $ { s

s S c s e s + E F

E si! {ci?:. e

lllii: :lt;iiiiEiifu; N 6

6 o F o o o -

E, i d 6 6 d d 6 d d d 4 6 d d 6 o d d 6 q, i 9 6 S d d d 6 d d d d d d a.. d i i i d a 6 6 i d 8 9 3. 3 i $ 3. 4 fr - ' d i +. i j + r _ t s - - d i + D d d c j 3 3. A 9, $ 4 8 3 8. 3. 9 $ C S S E g R E d d r d d @ - d d F i a j d. ! j d ! F " -. : " t s :. -.. I. 6 d. r d i i - 9 E $. : R. R q $ : 9. E. E e ; = { R = A 3 R E $ 5 p : R 8 3 5 r 6 d J o r d - F d - i f, i F F - E R ? 3 R ; ? 3 8 : E t n s E R * : 3 9. & I 6 9 d 5 6 9 $ t s 3 5 d d i R _ q 6 : - : r - r

e. s. B ; 5 F $ E 1 g

f r s g - 8 ;. 8 3 3

X g 3 R R g 3 E d

d

d r d d d

R 3 g 5 a E a F A S t d p R q $ $ g d d ! J d - d e i F a R F E 3 1 $ F X S S S B d d d 6 r d * + s

ur=r**ruu,
R - 3

$ t ' j j d d d d . 9. ' 5 3. F 3 E d d i d d d i ' N ! : g I d d d E

E.

! d s B '. 5. 3 i d ^ 3 8. e 5 fi . : 3 E I o ; - - E. s ; H A T E

E ili i* e

> E ! o Q I 9 X ; i d i I a r b a tqF R d S e

t S6 L9 j. l

t P 9 s !

R g s g 6 s g s E S g : i 3 ? a 3 $ g F E ; f f ; c $ : E F $ E 3 3. H R 3 S,

6 d d i F j

d E e $ F d d 8 - S 5. 8 B d g p x i E E S F g s H $ 3 $ : $ B R A. a F g i $ E g F $ 9 f i : F 3 3 : A

E E p. F sessd-'ts ap-;-go g,'n! ri 553.t$-E s. !lSgEq$go B.

B d

t L g 3

R

3 3 F 3

- _ r d . 8 ; a r _ d j d d d d d d o i d d d d !.899 $i.93.e93 3,$gg gg ggr3q

. c E $ $ 9. F F : $ S e $ 3 c s 3 3 B E E I g d d d a R d d o 3 8 3 8 9 3 3 3 3 5 d d d S d d e d d d 3 3 e 9 B 3 E 3 E R d d - ' r d d d K

E d a g ; F R 9 $ d g d d d d d d d d Eu F Eiu

ni iiiggsliii:iiiEis i i,,uui,,,

i'iliiiiigEi ifu3i ff,uiiis ,'::l:-:xlr*i;:::::i::". t;::;qE:.', i=. 3;;;;il;;;*+;;;;aa.;+ I X;;;;+;

Cg;$;a$;;lg Ilil;: ;;;;;;:;

9 : E S. r E - A t. i ' d

_ d

$ : R i 3 9 8 9 8 3 3 9 8 8 3 9 F F 3 ; J d ? - R ! N - s o : B d ! E _ g " * ! - F d R S o ' 5 c 3. r @ q B S 8 8 E ^. " : ' : 5. r o 6 6 @ a 6 @ o s s 8 a @ 8 e

3 g

l F $ 9, n 3 S

- - o 6 d d A 6 ' A N p e o n d d d i : d 1 s 3

o * ;. i s

... F F . B, S . ' ' X. t 5 d ' ; i ! d : P S : ,- I.s; H ; i 5 o *. i d 3 i i n : F,fl E* E E 5 o 9 !gri F E - lra a iI*[ q R l { i.r i ! 5 t d 1 { - E ! ! d ,!.s r l 5 ' ! & t r

E 5 3 a a 3'

3 3

rF { i E i,ir"i = i iiii iii :ii i,:iii irgi g, u i iri3i,*a ri:i Q E n R ' ! - *. * @ @ - 6 6 e : l l : - E l

i : l i -. X I : : - E ;. ! ;. E : : l : : : : : E i " " i X E E : : : : : : : : : i - i i i l

! i i : 5 & c c * * + e

H * ! r
j g + i ! !

j i * = s s ; s

t t t
H H j S t a e ; c a
e f, r g

g ' . g d d d d d E d r ! : 8 3 " d 3 g E s : " 8 5 * . g F

E F E $ i ;

r

a 8 S

E S F A F 6 N F E $ F E q F F. 3 d i d

t i d o. i j r d @ 5 3 9 8 E 3 ' E E ;. : : s 3 B. E g 3 s i. E ; q g c 8 - - : R o t : ; : 9 t e g g : B N S q 3 : E E i. g c F 5 f r p S E 3 d d 4 1 9 3 3 E F i, E f l R q N F E F : d d 6 - E E E R H 5, 3 6 R e s s g i g 3 ' : S P E 6 q P s e s E 6 F s B R g S F F a I; . t P .3 + P t r d { H U : ur :'i E E ; 3 t

.E E E :

o P l tii Fq j s q { R !.I \\. n s s \\ !rs 1 5 s.t .si ,:.9 J ;E i

d d i d ' q R P 3 - - F $ : S { d d d 6 e 3 E 8 n t t e g 5 E E 9 R.. ! g E g 3 n F : d d d d d d E d 9 t 3 E S 5 3 p . ! 8 X E E ! aEz 3.2 E Ei: s i T ; ?

i ; s n ; 3 6
9 i i d a a E E i: i i ! c, '

t ; E
f f :

E t ! E E i S ; ; i 3 _ z 5 ? 3

gt t

I i"i;i.;r;.

3E E l*iiggg iii i:;es;giE$ i r e , o : E i r i : s " I :. ; : : q : ! ! : : - " E f i

f f

{

f f f f a

E H o 5 . : B l ! o i , u x _ 6 : a o *. : d i i i n t f l :. E. 8 > E : o P l c x i ! x ; Irl a d 5+ i B d R d E. r s ! 5 d o. 5 5, t rsi {. s

. 8 P 9 F t r

Enclosure B TMt-15-036 Escalation Analysis for Three Mile lsland Unit 2 2 0 1 3 Sife-Specrfrc D e co m m i s s i o n i n g C o st E sti m ate February 2015 (15 pages follow)

Document F07-1676-003, Reu. 0 ESCALATION ANALY$S for THREE MILE ISLAND UNIT 2 20 1 3 SITE-S PE CIFI C DE COMMISSIONING COST ESTIMATE prepared for FirstEnergy Corporation prepared by TLG Services,Inc. Bridgewater, Connecticut February 2015

Three MiIe Island. Unit 2 Escalation Analyeis Project M*,nnger Tschnicsl Manager Docurnent No. F07-1676-003, Rev.0 Page ii of iii {#b APPROVALS TLG Seruices, Inc.

Three Mile Island, Unit 2 Escalation Ana,Iysis Docurnent No, F07-1676-003, Reu.0 Page iii of iii REVISION LOG TLG Sentices,Inc.

Three Mile Island. Unit 2 Escalation Analysis Document No. F07-1676-003, Reu.0 Page I of 12 DECOMMISSIOMNG COST ESCALATION STUDY Purpose This report presents escalated costs for the estimates of the costs to decommission Three Mile Is1and Unit 2 (TMI-2) for the selected decommissioning scenarios. The estimates, escalated to the year of expenditure dollars, are designed to provide FirstEnergy Corporation @irstEnergy), with the information to assess its current decommissioning liability, as it relates to TMI-2. Basis This escalation analysis is based upon the recent decommissioning cost analysis performed for Three Mile Island Unit 2.r Explanatory information from this report is provided below. Three decommissioning scenarios were evaluated for Three Mile Island Unit 2 (TMI-2). The scenarios selected are representative of alternatives available to the owners and are defined as follows: DECON The adjacent TMI-I is promptly decommissioned upon the scheduled cessation of operations in 2034. TMI-2 transitions from a Post-Defueling Monitored Storage (PDMS) status to decommissioning in 2A40. The decommissioning program for TMI-2 commences after TMI-1 shutdown and is managed independently from the TMI-I decommissioning effort; license termination of Unit 2 occurs in 2053, approximately 60 years after TMI'2 flrst entered PDMS. Delayed DECON Decommissioning of TMI-2 commences upon the removal of TMI-l's spent fuel from the site in 205f. The decommissioning program for TMI' 2 runs concurrently with the TMI-I decommissioning effort and concludes with the termination of both licenses. SAFSTOR TMI-I is placed. into safe-storage with decommissioning deferred 60 years. TMI-2 remains in storage with decommissioning deferred until it can be sequenced. with TMI-I. The decommissioning program for TML? mns concurrently with the TM-l decommissioning effort and concludes with the termination of both licenses. t "Decommissioning Cost Analysis for Three Mile Island lJnit2," Document F07'1676-001, Rev. 0, TLG Services, Inc., December 2014. TLG Seruices, Inc. 2. 3.

Three Mile Island, Unit 2 Escalation Analysie Document No. F07-1676-003, Reu.0 Page 2 of 12 The site-specific cost estimate was prepared by TLG Services, Inc. (TLG) in year 2013 (i.e., nominal) dollars. Because the actual decommissioning will not occur for many years and may continue for decades, the nominal-dollar estimates must be escalated into the year of expenditure. That is, we must determine the dollar value of each year's expenditure at the time it is expected to be incurred. Those escalated dollars then provide the basis for fi.nancial planning and asset management. Because many of the decommissioning activities occur long in the future, small fluctuations in escalation on the cost side, and investment earnings on the trust balance side, have an exponential impact on the resources required over the long periods of time typically associated with decommissioning scenarios. In this analysis, TLG reviewed each applicable cost component separately to d"etermine the rate by which each component was expected to escalate annually. Using an accepted aggregation methodolog:y TLG determined the overall average rate the decommissioning costs were expected to escalate annually for each unit and each scenario. The average rates are provided in the results section. The following narrative describes the methodology used to escalate the schedule of decommissioning expenditures. BackEround TLG developed the cost to decommission TMI-2 in year 2013 dollars; the mathematics to transform those costs to the year in which they will actually be incurred is relatively straightforward,. The key to the analysis is selecting the appropriate forecasting indices for each of the major cost components. For that, TLG has relied. upon guidance from the Nuclear Regulatory Commission (NRC) and the industry-wide recognized expertise of IHS Global Insight. The NRC divides its reference costs for decommissioning into categories of labor, energy, and Low Level Radioactive Waste (LLR!V) disposal. To provide guidance to operators and regulators and promote uniformity, the NRC periodically reissues NUREG-1307, "Report on Waste Burial Charges." NUREG-1307 is helpful in that it id.entifi.es the appropriate ind.ices that should be used to escalate the labor and energy cost components and provides historical changes in low level radioactive waste disposal costs. TLG also allocates its costs for decommissioning into categories, with the NRC's labor category further subdivided into "labor" and "equipment and materials," and an "other' category added for regulatory fees, property taxes and other unique or one-time expenditures. TLG Sercices,Inc.

Three Mile Island. Unit 2 Escalation Analysis Docurnent No. F07-1676-003, Reu.0 Page 3 of 12 Consistent with standards defrned in the Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC), Topic 4L0-20,121 TLG develops future cash flows by escalating four of the cost categories (abor, equipment and materials, energy and other) with indices provided by IHS Global Insight of Lexington, MA. IHS Global Insight is a privately held company which acquired Global Insight in 2008. The combined company includes well-known businesses such as Cambridge Energy Research Associates (CERA), Jane's Information Group, and IHS Herold; it also includes the former companies known as DRI (Data Resources, Inc.) and WEFA (Mharton Econometric Forecasting Associates). Since Global Insight has no direct index for escalation of low level radioactive waste disposal costs, the escalation rate for LLRW disposal has been established using a broad-based inflation index (CPI, Services) combined with a comparative retrospective LLRW disposal cost escalation analysis. The timeframe of decommissioning typically exceeds that of the published indices; therefore for years beyond. the published index, the inflation factor is determined using a "moving-average" method, averaging the most recent 25 years of indices to determine the future year index. This is a well-accepted methodology for determining longer-term projections and one that appropriate by IHS Global Insight as well. Assumntions and Methodolow has been reviewed and deemed The base year (2013) costs were extracted from the "Decommissioning Cost Analysis for Three Mile Island Unit 2," issued in December 20L4, specifi.cally the Total costs cash flows from Tables 3.1 through 3.3. The decommissioning cost analysis analyzed the DECON, Delayed DECON and SAFSTOR scenarios. The primary objectives of the TMI-2 decommissioning project are to remove the facility from service, reduce residual radioactivity to levels permitting unrestricted release, restore the site, perform this work safely, and complete the work in a cost effective manner. The selection of a preferred decommissioning alternative is influenced by a number of factors. These factors include the cost of each decommissioning alternative, minimization of occupational rad.iation exposure, availability of low-Ievel waste disposal facilities, regglatory requirements, and public concerns. In addition, the existing agreement between FirstEnergy and the NRC requires decommissioning to be completed within 60 years of the beginning of the Post-Defueling Monitored Storage period, which began in 1993. The DECON scenario in the cost estimate meets this requirement. 2 Accounting Standards Codification, Topic 4LO-20, Financial Accounting Standards Board, JuIy 2009. ASC 410-20-55-14 states: "It is expected that uncertainties about the amount and timing of future cash flows can be accommodated by using the expected present value technique and therefore will not prevent the determination of a reasonable estimate of fair value." TLG Seruices,Inc.

Under the agreement with the owners of the adjacent Unit 1, TMI-Z wiII not begin d,ecommissioning prior to the final shutdown of Unit 1. The Delayed DECON and SAFSTOR methodology coordinates the Unit 1 and Unit 2 decommissioning operations to a limited extent for cost sharing. The DECON methodology assumes that TMI-2 decommissions independent of Unit 1 activities. Contaminated materials are removed, packaged, shipped and disposed of offsite. Clean materials are surveyed for radioactive contamination and released as scrap metal or construction debris. In accordance with 10 CFR 50.S2(a)(9), a license termination plan will be developed and submitted for NRC approval at least two years prior to termination of the license. Following the license termination survey and termination of the NRC license, all remaining site structures are removed to three foot below grad.e elevation, and the subgrade voids backfilled with concrete rubble and structural frll. The site is frnally graded to conform to the surrounding area, and native vegetation placed for erosion control. Under the SAFSTOR methodolory, the facility is placed in a safe and stable condition and maintained in that state, allowing levels of radioactivity to decrease through rad.ioactive decay, followed by decontamination and dismantlement. After the safe storage period., the facility will be decontaminated and dismantled to levels that permit license termination, similar to the DECON methodology. Decommissioning costs were divided into the five escalation categories, for which future rate of inflation factors were established. The five categories are: Three MiIe Island. Unit 2 Escalation Analysis Labor Equipment & Material Energy LLRW Disposal Other Document No. F07-1676-003, Reu.0 Page 4 of 12 Wages, fringes and benefits for craft, salaries and benefits for professional workers, clerical, administrative, service, contract workers, as well as for certain trades Heavy equipment, specialty tooling, packaging, small tools, construction materials, consumables, rental equipment and temporary construction facilities (trailers) Electrical power purchases (as a large industrial customer) to support site operations Costs for the processing of low'Ievel radioactive waste as weII as for the controlled disposal of material that cannot be recovered (released for unrestricted use) Site operating costs (not already accounted for), for example, taxes, fees, and costs for specialized services and project support activities (may include unspecified contributions from labor, equipment and materials, and TLG Seruices, Inc.

Three Mile Island, Unit 2 Escalation Analysis Docurnent No. F07-1676-003, Rev,0 Page 5 of 12 transportation), and payments for one'time disposal services (e.g., Greater-than-Class-C radioactive waste, or GTCC) The currently projected total costs (in thousands of 20L3 dollars) to decommission the nuclear station, with the two scenarios analyzed, are as follows: DECON $1.188,564 Delayed DECON $L,177,554 SAFSTOR s1.239.065 The costs include the monies anticipated to be spent for operating license termination (radiological remediation) and site restoration activities. The costs are based on several key assumptions in areas of regulation' component characterization, high-level radioactive waste management, Iow'level radioactive waste disposal, performance uncertainties (contingency) and site remediation and restoration requirements. The following table reflects the percentage of each cost component relative to the total costs to decommission TMI-2: Escalation The following escalation indices were established for each of the five cost categories. The escalation indices for Labor, Equipment and Material, Energy and Other were provided by IHS Global Insight Company via their Datalnsight-Web online service. The indices used show the last update as 13 October 2OL4. Global Insight does not provide historical or projected costs for disposal of radioactive waste. As such, a TlG-developed LLRW Disposal/Recycling index was used in this escalation TLG Seruices, Ine. DECON Delaved DECON SAFSTOR Escalation Category Costs (Thousands of 201 3$) o/o of Total Cost Costs (Thousands of 2013$) %of Total Cost Costs (Thousands of 2013$) %of Total Cost Labor 67t.323 oo.D 65r.r22 O D. J 67L.870 54.2 Equipment & Material 137.959 11.6 r4r.727 L2.0 r53.977 12.4 Enerey 18.061 1.5 19.459 L.7 28,227 2.3 LLRW Disposal 258.232 2L.7 258.143 2L.9 258,r57 20.8 Other Items 102.989 8.7 107.103 9.1 126.834 IQ.2

Three MiIe leland. Unit 2 Escalation Analysis Docurnent No. F07-1676-003, Reu, 0 Page 6 of 12 analysis. This index is a combination of historical information through 20t4 fuom NRC publications for disposal site rates and projections using the Consumer Price Index, Services information provided by Global Insight as discussed previously. Forecast data for labor, equipment/ materials, energy, and general inflation were available through 2O39.In order to extrapolate beyond the available Global Insight data, TLG calculated a 25-year moving average inflation factor to extend the Global Insight indices through 2095, the end point of the TMI-2 decommissioning scenarios. Index Selection The following table identifies the Global Insight forecast data sets used for the four cost categories (exclusive of LLRW disposal). Consistent with the NRC's guidance, TLG escalates the labor component of its decommissioning cost estimates using an Employment Cost Index (ECI) and the energ:y cost component with a Producer Price Index (PPD. Use of the Consumer Price Index, Services (CUSASNS) for general services, site operating costs and one-time expenditures is consistent with the intent of the index (the measure of the average change in prices over time of goods and services). Global Insight Forecast Database TLG Cost Category ECI Total Compensation @CIPCTNS) Labor Expenditures Infl ation Producer Price Index, Machinery & Eouipment (WPIP11) Equipment/Nlaterial Expenditures Inflation Producer Price Index, Fuels and Related Products and Power (WPIP05) Energy Expenditures Inflation Consumer Price Index. Services (CUSASNS) Other Items Expenditures Inflation TlG-Developed LLRW Disposal Price Index [Historical data based upon Barnwell published tari{fs; forecast data based upon the Consumer Price Index, Services (CUSASNS) plus 1% additional to reflect above-inflation increases observed at the Barnwell burial sitel LLRW Disposal / Recycling TLG Seruices, Inc.

Three MiIe Island. Unit 2 Escalation Analyeis Document No. F07-1676-003, Reu.0 Page 7 of 12 Labor The decommissioning process is labor intensive, with labor representing more than half of the total cost. The estimates for TMI-2 include the cost of the craft labor performing field activities, the field supervision and support services, project management, administration, security, and costs for specialty contractors. The Employment Cost Index (ECI) is a measure of changes in labor costs. It is one of the principal economic indicators used by the Federal Reserve Bank. The index shows changes in wages and. salaries and benefit costs, as well as changes in total compensation. The ECIPCTNS index, provided by Global Insight, is a forecast of future changes in the cost of labor, defrned as compensation per employee hour worked. The self-employed, owners-managers, and unpaid family workers are excluded. from coverage. The ECI is designed as a fixed-weight index at the occupational level, thus eliminating the effects of employment shifts among occupations. Both components of compensation, wages/salaries, and benefits, are covered. In addition to TLG's judgment, IHS Global Insight has confi.rmed that the selected ind.ex is appropriate to use in determining the rate at which the labor costs will escalate over time. Equipment and Material Equipment and material costs in the decommissioning estimates include small tools and consumables as well as the heavy construction equipment involved in the dismantling, d.emolition and movement of materials around the site. The Producer Price Indexes ePI) measures monthly average changes in selling prices received by d.omestic producers for their output. Most of the information used in the PPI is obtained by sampling of industries in the mining and manufacturing sectors of the economy. The indexes reflect price trends for a constant set of goods and services representing the total output of an industry. TLG uses a broad-based escalation index, the Producer Price Index for Machinery and Equipment WPIP1l). In addition to TLG's judgment, IHS Global Insight has confirmed that the selected index is appropriate to use in determining the rate at which the equipment and material costs will escalate over time. Energy Enerry costs in the decommissioning estimate include only direct energy purchases, primarily electric power and fuel oil for heating. TLG uses a broad'based power escalation index, ihe Producer Price Ind.ex for Fuels and Related Products and Power (WPP05). While the WPIPO5 index has some volatility (since it tracks in TLG Seruices,Inc.

Three Mile Island, Unit 2 Escalation Analysis Docutnent No. F07-1676-003, Reu.0 Poge 8 of 12 part the price of oil), the cost of energy in the decommissioning estimates is a small percentage and therefore has little effect on the overall escalation rate for decommissioning cost. In addition to TLG's judgment, IHS Global Insight has confirmed that the selected index is appropriate to use in determining the rate at which energT costs will escalate over time. Low Level Radioactive Waste Disposal The inflation index used for radioactive waste burial costs is the Global Insight Consumer Price Index, Services (CUSASNS), with an additional lo/o per year to account for differences observed (over the past 14 years) between low-level waste disposal rates reported in NRC NUREG-1307 documents and general services inllation rate (CUUR0000SAS) reported by the Bureau of Labor Statistics. Other "Othey costs in the decommissioning estimates include such items as licensing fees, taxes, special services (for example, a fee for the geologic disposal of GTCC waste), as well as labor-intensive activities such as radiological surveys that include costs for off-site analytical services. Because the "Other" costs contain this variety of cost components, TLG uses a Consumer Price Index to project future expenditures. The CPI, Services index (CUSASNS) measures changes in the prices of goods and services. It is therefore more representative of the non-labor cost elements included in the decommissioning estimates. Accordingly, the use of the CPI for "Other' costs reflects more accurately the cost components with the "Other category than the use of the "Labor" escalation factor as a proxy. In addition to TLG's judgment, IHS Global Insight has confirmed that the selected index is appropriate to use in determining the rate at which the "other" costs will escalate over time. Results With the proper escalation indices identified, TLG escalated the cost per year for the five escalation categories using the Global Insight index corresponding to that year and escalation.uiegory. Tables 1 through 3 provide escalated schedules of annual expenditures for the DECON, Delayed DECON and SAFSTOR scenarios for TMI-2. The schedules detail each of the five escalation categories through to the end of each scenario's decommissioning period for Total Costs, as well as the cost categories of License Termination and Site Restoration. TLG Seruices, Ine,

Three MiIe Island. Unit 2 Escalation Analysis Document No. F07-1676-003, Reu,0 Page I of 12 No discounting of the escalated dollars was performed. Using the escalated cash flows for each unit, TLG determined the single-value yearly escalation rate which yielded the same sum of escalated dollars for each of the four tables. The rate, referred to as a composite average annual escalation rate, is tabulated for the four decommissioning cost cash flows as follows: DECON 2.77% Delaved DECON 2.78% SAFSTOR 2.85% In a similar fashion, the composite average annual escalation rates for each of the five escalation categories can be developed. The following table details the composite annual average rates for the three decommissioning scenarios. Composite Average Annual Rate (%o) Escalation Categorv DECON Delayed DECON SAFSTOR Labor 2.7L3 2.707 2.687 Equipment/ & Material 1.146 1.153 1.176 Enersv 2.200 2.L93 2.r49 LLRW Disnosal 3.599 3.607 3.632 Other Items 2.628 2.631 2.644 Overall 2.774 2.784 2.853 Similarly, the composite average annual escalation rates for the three cost categories identifred in the decommissioning cost estimate can also be developed. The values for the three d.ecommissioning scenarios are provided in lhe following table. Composite AveraEe Annual Rate ( ) Escalation Category DECON Delayed DECON SAFSTOR License Termination 2.795 2.805 2.87r Site Restoration 2.331 2.324 2.381 Overall 2.774 2.784 2.853 TLG Seruices,Inc.

s q lsr. dj' \\ S 9 s t a

^ B (o

\\lsl{ o o I g c f l E E EE 9 E r E ; isit - g g i E E g! 3Ei a;! Egl

i!

E t t E E ' H! Eg E T tr &-s. I 6 t 5 tq f i rI r t 6I i o o o o o o 0 o o o o o o o o o o o ) o o o o o o o o o o o o o o o o S a o 6 o o o o o o N o o o o o $ ) o o o o o o o o o o o o o o o. $ H R R f r

d Ei iHHEREFHHHFHHH$ERFHHHHHRfi FRXRHEHHFfi RRHH I

t 3 zoo se $HH$$f; r$H$3R.;.EnFFBS$eq&q P P N E N N R = F S S S ' nHpFF$g:*$BsHgsg$s?s$se$geFgggBEiD33*Fe o o o o o o o o o o o o o o o o o.... E $ g E p E [ $. 8 8 8. R. ; g s s S s g E 3 b g 3 ' " RN $RFFnFFH sHs;$FsE s sssEsHH$.83:$.$iBFEEiH E f i $ P $ S E $ g B N

;: J J ; < t. i d d d d d HHEFHfi FHHHHHHFFHRFRHFHHFF$fi

H*THHFFHFFRF 6

P d N ?ii E I t t i 9 E F : . ! r q P

l o 1 *el E i_! i ttErE!

i E

I C F E 5 E igs 8 E ! ' E E 3 ;$!E 3

F 5 d E t E r 3 s c I 6 t 5 g o d\\U,3 ll.o tn x9 S a l

' B s s 5 i 5 E s E 1 r E. 9 <

t! i P B ( ) E'3 tr 9 : N 8 S E 3 F 3 8 e R 3 r d d d d d d d d d d q ? d i I P Ie 5 I E I o zo e

fi, E ; e E H g e $ $ $ q g 5 H s $ $ B t $ F fr E R. fr. B" s. H R $ $ $ F $ fi. E

- - - - P g s i R e e R j i E E E d o o o o o o o o o o o o o o o o o o o o o F [ $ F 5 E E

s $ s P $ 3 ' 3 3 b B E '

RNRRiRRRxRSFS;il8$E$$$$rfr HEfr E.3:n$3S ggE$H o o o 6 o o o o o o o o o o o o R s s b s s s q E g g g H I'*?-i9'33L';*" $$gRsig:*$gg$gBgH?Cg$3c$3e g*3!BE3Egg3$3 FHFFEE gFHHHHHFHRFHHgHHFRRFFHXXHEHHERHRH

s a l R 5 6j' \\ S O s ! !

lo Nsr& zo U

l

tr

E ?E3 r "

E : E D 5 : s !i i 8 E i P ! { l e ri! 3Ei l4! ! g t r 3 l

3 {

z a dFx* O E u 8 = u = 2

REE r 5 a

IE I a iq I I t I I I o o o o o o o 6 o o o o 6 o o o o o o o o o o o o o o o o o o o o o R E o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o e o o o o o o o o P o c o o o o o o o o o o o o o 8 p E . *.. 9 x f i 9 f r.. 6 b 6 M F; iEEFFFFHHHHHHF$HRFHFHHFRHgFR$HHHfi Hfi fi RR$$HHHRFR zo IE g g F .E

t 6 t a I I 2oo q er s F E $ fi g x s 3 $ q g 5 H ; s fi $ g s E g I c s. E E. N"R R. E $"$ N.E g$ g g3. 3. S

i ; - - - - r - N R R N n & 9 P 9: *

o o o o o o o o o o

- e e * : e e P s l P s g g R E f l F F g R p f i E $ @ -. !. d R F $ E E E R R N S - e : - - - RFRRFR$RNHsHs:sBsF3s8Fss$ssq$:fl$$$H.nEgF o o o o o o o o o o o o o o o o o o o o H $ 5 $ E $ $ q [ 9 q f r. H. e. 3 *. g " H d. F. s -. 9 m. $ - 6 o N N o o o o o e s o FHHFFfi EFHHHHFHH$RHHHHHHRHREE$HHHHFfi fi FRRH*RFgR nHsRs$s:**ss$ssssse$$seessF$3$$gFgFi3$$$ 6 E q E F 5 s* i o g t d: i

+ I f,

g;i O ; F J t fi sFila

!'B i r i* i E. 3s = i! 3iX E! el E'i s it Ei o ; t ; ! E $$ I ;'r ;r = E H i o lr i l d6 E { Id e ! T P TT E d z o ] E I z $ $ E p E: se 3 $FRfi 3 3*R gE $s$:R P P : : e P s e s e g g R E g S p E R p $ [

e s e R & e g g B g g N s E ees $s$$

$ $=gg.*iig.ggxgltu $ 5 $ E t E g $ t $

F $ 8.X.3 H.S.s g F.g$ S

- - - - r ; d s j s i $ e P P e i i d s es! s !88$rs3$$$g$$EEf $$35 $Jfi HIgFgggg$$$ gssfr $$fi o o o o o o o o o o o o o o o o o o o o o R N R & R R R S N R g H S F S F $ E B g T fl gRgR$g:** g3$gggsgg$g HHFFEfi FHHHHHHHHRHHHHHFRHfi gFHfi

Hfi Hfi fr FHgHRHHRFR o

a F at) hJ Fi

s sb gl.----

d I El

\\ l

l S l^:l

! 1,5 !l s tEB il E l3?l tEt l^l ESI:l a g & 8 8 8 8 t - - - - F E

iEiFFFFFEFIEFNIFEHfiEF!hCiiiIiTfiEFTIFfiflgiEFEEgF*PFF*gFFEfi6[$8fiAAgRiHAF*AERfifi l 8 r i i i i l,

i i i t. i 6 $E39*;i$3sg:!gE!*:93i$g:$$!t*;E:3gi 555: e:;$;"15: E;"t-{is:8i c FF:'FFP:;gi; $*: $;'$s$.Alii s::3ni:Fiistslii:rF;g:l:a3*Bgtstll I o o c. c o o o r r. e !. ! : r e e s n l t s I R t F s & t 6 s 3 8 t 5 ; e. ? : ? 9 e 5 3 s 5 8. ! 8 g & E - i - g ; g a g - i F - s - g s l i e: $s E gai FFs s:lr ftsilfrii8titsF;; r F a E s s E i s l : s 0 i s 3 3 ! B ; E 8 s $ E t C s E A r s e A F F [ 3 p F F : g S s S I i l i t s e E s g $. g B $ 3 : $ 9 5 3 : l ""'t s 9 1 3 c $ r i E t r l e F s : ! u ! s E I c t s S s s ; E E t J t s s E s E d F : r r P t " q f r q t : " ; : 3 9 5, 1 1 I

13

$x $ig:i$l i$sB33gg $.al t:::!Bi lli: ei 8i !e !ie:sE i; *gi$ia* 8${*3$i5;3$sg*} 3F*g$E$l $*l$ El iEEFFfiffFFEFFFF$Rfi*RgdPRARf,iiFiiIFAFFFfiI{PTFPftgTfig$*HR*$FFfiFEfiEFFEHgFP*PflgF$gdP @*s::*ecrsste:rFg$PF:533$$$: c c c o o. ! ? : : ! r ! r F : c r r a i s N R E a r F a R e ; s 8 a t s i 8 s 5 e : s t o " * * " r n o r 9 s l F g g t g H. f i ! i i i i ; EFflffiRFixtsEi i s F s i c s E s i ! : ! s r s c e c ! 5 : ! e i s t l s s E g t $ t E p F ! : p l p : s s s s r f I s s gg $ $. t 3 8 3 3 i 3 $ i F ? '" " 'i s E : r { c l i s t s. B s : :

s $ 3 ! s s E g E s c ; E E i E E i l E s E E p i F p F g : & t s - i $ ; * ! - g R ! R I $R

$g"rC:

l t: $gB ir g 33 9-8:::!!!1t 9:i 1! ! ! 9! ! iiis ?gl: i$i i 3 $$g8R$ig:g$n 9gig3$gf;$:$:t*

giEFFFPFFPIFXFgFgH*CIFgCIEiiiPIiiiFFfig*PEFEEF*ggi*[F*gE6HFEEEhFgi$*F{fiRfiRFF o

I L v) i i r t. xilE I $iii !g E ii'i,'i

s;ii*ii}}

TMI-15-036, Decommissioning Funding Status Report

Contents

Text

SUBJECT:

Enclosures:

References:

References:

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

Navigation menu

TMI-15-036, Decommissioning Funding Status Report

Text

SUBJECT:

Enclosures:

References:

References:

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

Navigation menu

Search